Cities Index.
Exhibit D - Resolution Certifying SEDA EIR

Fresno City Council
December 18, 2025

Document
Exhibit D - Resolution Certifying SEDA EIR
Meeting
December 18, 2025
Body
Fresno City Council
Pages
517
Original file
697.9 MB
Text extracted from the city's file for reading and search. Open the original on legistar2.granicus.com. That file is the official record.

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-611
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Paul Lake (LAKE)
Response to LAKE-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

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From: Kathryn Lemon
To: LongRangePlanning
Subject: Annexing SouthEast area.

Date: Friday, March 21, 2025 3:24:15 PM
External Email: Use caution with links and attachments

3.3 Air Quality
How will the concern about increasingly poor air quality be addressed? Adding another 200,000 people without any plan of improving the areas air quality will increase health issue for the population.

As a retired school nurse, the increase in students needing inhalers for asthma was great. Sports were limited due to very significant bad air quality days.

We cannot ignore the fact that the health of our community now & in the future depends on clean air.

Kathy LeMon, RN
Sent from my iPhone
LEMON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-615
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Kathryn LeMon (LEMON)
Response to LEMON-1
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

As discussed in Section 3.3, Air Quality, of the Recirculated Draft PEIR, the proposed project has the potential to exceed the SJVAPCD’s significance thresholds during construction and operation. Full build out of the proposed project would result in the generation of substantial long-term criteria air pollutant emissions that would exceed the SJVAPCD regional significance thresholds and would therefore not be considered consistent with the existing AQPs. MM AIR-1a, MM AIR-1b, MM AIR-1c, and MM AIR-1d would serve to reduce construction and operation-phase criteria air pollutant emissions; however, the mitigation measures would not reduce emissions to less than significant levels. Applicable SJVAPCD rules and regulations in addition to the proposed project’s policies and design guidelines would contribute to reducing long-term criteria air pollutant emissions to the extent feasible. However, due to the magnitude and intensity of development accommodated by the proposed project, impacts would remain significant and unavoidable.

As noted above, the proposed project is a policy-level document and does not propose any specific site development at this time. Future development associated with the proposed project would be required to undergo CEQA analysis on a project-by-project basis as necessary. As such, the mitigation measures identified above require future development in Plan Area to provide technical analyses as part of the project environmental review for construction, operational, and health impacts and mitigate the identified impacts in those technical studies to the greatest extent possible. The mitigation measures also include potential mitigation strategies for future development to utilize to reduce air quality impacts. Future development in the plan area will still have to go through the appropriate level of environmental review where impacts to air quality will be evaluated against the suggested significance thresholds in Appendix G to the CEQA Guidelines, which is the City’s standard practice. No further response is required.

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From: Kyle Lyman
To: LongRangePlanning
Subject: Public Comment: SEDA Environmental Review
Date: Monday, March 3, 2025 9:57:38 AM
External Email: Use caution with links and attachments
Hello,
I would like to leave a public comment for the recent SEDA environmental review and the new knowledge I’ve learned about this project.

After seeing this article:
https://fresnoland.org/2025/03/03/will-southeast-fresnos-proposed-mega-development-bedenser-than-new-york-city/?utm_medium=email I urge the city leaders and officials responsible for this project to reconsider the current plan as it has been presented. It is clear that this project will only contribute more to urban sprawl and devastate the environment. It is especially concerning to see a lack of transparency by the city for the data and numbers presented in terms of emissions, as well as urban density that has been misleadingly presented.

While I support the need for growth in our city, the plan presented will only cause more harm than good: for the environment, city traffic, and the overall health and safety of our city residents. There needs to be a much clearer understanding of what assurances will be provided to mitigate environmental impacts from this development. I’d like the city to actually provide how it got to its conclusion that this area will have more urban density than San Francisco based on job to people ratios, since it’s clear in the rest of Fresno this is far from the truth.

To make extraordinary claims, you need extraordinary evidence. The lack of substantial evidence for the city’s claims should give everyone pause and reconsideration for this project as it stands.

Thank you,
Kyle Lyman
LYMAN

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-619
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Kyle Lyman (LYMAN)
Response to LYMAN-1
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to LYMAN-2
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR.

Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

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From: art maldonado
To: Adrienne Asadoorian
Subject: Re: SEDA
Date: Tuesday, March 18, 2025 8:37:47 AM
External Email: Use caution with links and attachments
Let me know that you received this…thanks

3.17 Transportation and Traffic regarding SEDA
Concerns and Question: We have been heavily impacted by high levels of traffic in our area due to new neighborhoods, several churches and schools. How will the city address the serious damage to our roads, the high possibility of serious traffic accidents, the lack of adequate lighting for night drivers. Does the city have a financial plan to address these issues. We need to see something in place.

Sent from my iPad

MALDONADO

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-623
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Art Maldonado (MALDONADO)
Response to MALDONADO-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: John Minkler
To: LongRangePlanning
Subject: no SEDA
Date: Sunday, March 23, 2025 3:33:58 PM
External Email: Use caution with links and attachments
I am a Fresno resident and I oppose the SEDA project because of urban sprawl, pollution, and traffic problems.

John Minkler
-- John Minkler
Civic Education Center, Co-Founder/COO
700 Van Ness Ave. Suite 104, Fresno CA 93721
559-907-9534, [email protected]
www.civicedcenter.org
Youth Service Council motto: We're creating our future!

MINKLER

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-627
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx John Minkler (MINKLER)
Response to MINKLER-1
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: Kathy Moua
To: LongRangePlanning
Subject: Public Comment on the SEDA Environmental Review Date: Monday, March 3, 2025 10:18:45 AM
External Email: Use caution with links and attachments
Hello,
I am writing to express serious concerns regarding the recent environmental review for the Southeast Development Area (SEDA). The City of Fresno claims that this project will reduce vehicle miles traveled (VMT) by 80% and be a model for sustainable, high-density development. However, there is no extraordinary evidence to support such an extraordinary claim. If SEDA is truly meant to serve the community, the burden of proof is on the developers to demonstrate—through transparent, independently verified data—how this project will avoid the well-documented consequences of unchecked urban sprawl.

SEDA threatens to:

Exacerbate Fresno’s air quality crisis by expanding development rather than investing in sustainable infill and transit solutions. The city's prior environmental review was already ruled inadequate, and yet the revised version still fails to address long-term pollution impacts.

Drain public resources from existing neighborhoods that desperately need infrastructure improvements, diverting attention and funding from long-standing communities.

Displace working-class residents by increasing the cost of living while failing to provide sufficient affordable housing.

Destroy valuable farmland in a region known for agriculture, further eroding local food security and economic sustainability.

Fresno residents deserve development that prioritizes them, not one that benefits developers and special interests at the expense of existing communities. If city officials truly believe in their claims, they must provide rigorous, independently verified evidence—not vague promises—before moving forward. Until then, this project appears to be yet another example of predatory expansion that benefits a select few while harming the people who call Southeast Fresno home.

I urge the City of Fresno to reconsider the approval of this project until real, transparent, and community-driven solutions are put in place. Please do not disregard the 400 pages of public feedback from 2023 and those that will be coming in.

Thank you,
Kathy Moua
MOUA

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-631
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Kathy Moua (MOUA)
Response to MOUA-1
The comment is noted. Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

Response to MOUA-2
The comment is noted. Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to MOUA-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to MOUA-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to MOUA-5
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to MOUA-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 3, Clarification Regarding Previous Comments Received, in Section 2, Master Responses, of this document. Master Response 3 provides clarifying information related to the review of or response to any comments received on the previously circulated Draft PEIR and Partial Recirculated Draft PEIR, including comments incorporated by reference in the public comment period. No further response is required.

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City of Fresno
Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, California 93721
March 17, 2025
Subject: Comments regarding the SEDA EIR
I am a property owner in the SEPO area. I hereby respectfully o er the following comments in response to the latest EIR.

AGRICULTURAL RESOURCES:

Under Project Objectives, it is stated “Respect the major economic and cultural role of agriculture in the Valley”. The entire SEDA project shows a lack of respect for agriculture in the valley. Impact AG-1 states SEDA “would establish a bu er between the urban area of the plan and the surrounding agricultural land”. Obviously, this shows no respect for existing agricultural properties within the plan area. An example is turning existing agricultural land into Section 8 housing. Item 3.2-10 will create opportunities for small farms from 2-20 acres. What happens to the “small farms” that already exist. According to Policy HC-5-g basically states that owners of agricultural farms less than 50 acres are to be outlawed. There are also comments about “Community Farming “. This sounds like the beginning introduction into Communism.

LAND USE AND PLANNING:

Under Project Objectives the new plan will accommodate 40,000 to 45,000 new dwelling units. The original estimated annual population growth through 2050 was 1.5%. The revised population growth estimate is .18%. This would revise dwelling units needed to 5,
would accommodate 134,000 dwelling units. This vacant land would more than accommodate the actual growth beyond 2050. AND THE INFRASTRUCTURE ALREADY EXISTS. This means the SEDA plan is completely unnecessary. Your plan also includes MUZNY

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300. There are currently 8,200 vacant "infill" areas available in the city limits which town centers and commercial areas. I believe time, energy and finances should be focused on infill and actual revitalization of downtown Fresno. This would also decrease finances required for public services, fire, police etc.

TRANSPORTATION AND TRAFFIC:

Under Project Objectives, the plan would include major transit lines and ensure that schools and major town centers can be reached with or without a car. In a recent trip into Fresno, I encountered 4 fax buses on my travels, all empty and in service. Fresno residents drive cars to go places, period. Also stated, reduce energy consumption to help meet standards for greenhouse gas emissions and air pollution. The proposed plan will excee
someone please explain why expressways, arterials, drives and collector streets are all called scenic once you have removed all the agricultural. Who pays for SR-180 ramps at DeWolf, Highland and McCall?
UTILITIES AND SERVICE SYSTEMS:

Under Project Description, Fiscal Responsibility is a major goal of the plan. Fiscal plan. The cost of infrastructure for SEDA would be massive. I don’t see in the EIR any estimates regarding Fresno City funds, costs of developers and fees. Project Objectives states to provide selfAgain, no estimates on how this will be accomplished. Are we in for another “High Speed Rail” that the costs by the time the plan is completed, if it ever is, have become unsustainable? Obviously, all properties will need to be connected to City systems, estimate I have heard is that existing farms would be forced to connect to water and sewer at perhaps $100,000 depending on how far we are set back from the street. Also property owners. Also, the cost of watering an orchard, vegetables and lawns on a city water meter is unsustainable. Is the purpose of this plan to force all farmers to sell to developers for the city to provide 45,000 new unneeded dwelling units? I’m sure housing developers are chomping at the bit for this plan. I’m sure there are no donations being made to election campaigns.

In conclusion it should be very obvious that I am against this plan. We moved out here to enjoy the area and have our little farm. SEDA would put an end to our dreams. Based on what ry. Thank you for
taking the time to read and understand my comments.

Sincerely,
MUZNY

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d SJVAPCD thresholds and air quality plans facing millions of dollars in fees. Can Responsibility would be accomplished by infill and fixing downtown not by the SEDA financing for the development and ongoing maintenance of SEDA. which may not be feasible to handle 45,000 new dwelling units. The only financial required to cap our wells and remove septic systems. This cost is not feasible for most I have brought up above I firmly believe that SEDA is completely unnecessa Larry Muzny
[email protected]
City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-635
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Larry Muzny (MUZNY)
Response to MUZNY-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Please also refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Further, please refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section

3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to MUZNY-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Please also refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to MUZNY-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-636 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to MUZNY-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

From: Ruben Nieves
To: LongRangePlanning
Subject: SEDA
Date: Wednesday, March 26, 2025 9:34:31 AM
External Email: Use caution with links and attachments
To whom it may concern:

I would like to add my comment here to the opposition being felt and expressed by residents throughout our city regarding Fresno's Southeast Development Area Specific Plan. I hope the city will not move forward with SEDA because of the concerns below.

The taxpayers of Fresno have not been informed how the infrastructure for this development will be paid for. It is not clear to us whether we will be stuck with the bill. If the city has a plan for how these significant infrastructure costs will be paid for, then the public should be made aware. If the city does not yet have a plan for how the costs will be paid for, then it would be irresponsible to move the plan forward.

So many of our neighborhoods need to have streets, sidewalks, storm drains, and lighting repaired. In the heart of the Tower District, where I am a homeowner, some streets were repaved in the past two years (such as Lucerne and Hedges), while others that were in equally poor condition (such as Echo and Floradora) were not repaved, and they remain unrepaired today.

Throughout my neighborhood, sidewalks are cracked, unlevel, and even crumbling in spots.

Some blocks do not have sidewalks even though sidewalks exist on the blocks on either side.

And I know that other neighborhoods in Fresno have even greater needs of infrastructure repair and updating than my own.

With a shortfall of $20 million in the city budget, it is difficult to see how the city will be able to catch up on the needed repairs and updates. I am opposed to development plans that may very well exacerbate this problem. We can't afford for new development to suck taxpayer money away from existing Fresno neighborhoods. And I do not like the idea of taxpayers being stuck with a SEDA development bill in the near or long term.

I urge the city to say NO to SEDA.

Thank you for your consideration,
--Ruben Nieves
Ruben Nieves
635 E. Floradora Avenue
Fresno, CA 93728
NIEVES

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c-559/360-1667
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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-639
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Ruben Nieves (NIEVES)
Response to NIEVES-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: NATALIE ORTIZ
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer; Jerry Dyer
Subject: Public Comment - OPPOSE SEDA PEIR
Date: Thursday, March 20, 2025 8:31:53 PM
Attachments: Oppose Redraft of PEIR 03.10.2025.pdf
External Email: Use caution with links and attachments
Attached please find our opposition letter dated 3/19/25 to the recirculated PEIR dated 2/7/25. I’m requesting that the city clerk please forward to the appropriate councilman email address for District 5 since that is not information I have due to special election.

Thank you.

Natalie Ortiz
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March 19, 2025
[email protected]
RE: OPPOSE - SEDA PROPOSED EIR AND OPPOSE SEDA DEVELOPMENT To Whom It May Concern:

Please accept this letter as our required public comment, specifically our opposition to the recirculated PEIR on February 7, 2025. Please know that the reference numbers are set forth in this opposition as you require (however I do not see that stated anywhere, we were told put reference number or they won’t read it) … continue reading. Please be aware pursuant to Exhibit 2-2, Land Use Map, our property is located under “Flexible Research & Development” (FR&D). FR&D states in the PEIR:
“Flexible Research and Development districts would be primarily located west of the Briggs Canal and/or south of Jensen Avenue and are intended for uses such as research and development, light manufacturing, product testing centers, and office development. The area may also include compatible commercial uses such as restaurants, coffee shops, cafés, printing and publishing, dry cleaners, and other supporting businesses. Access to regional transportation corridors (both road and rail) is critical. Residential uses are not allowed in Flexible Research and Development areas.”
What this means to our household is that eminent domain will be used against us in order for the City to move forward with SEDA. The last sentence reads residential is not allowed in these areas.

Exactly what was done to homeowners in the path of the High Speed Rail, and look at them today, no land acquired yet for the rail, not one track laid, not one train running, not one person able to use the HSR and its currently under investigation as to where all the money went and way over budget that when and if it will be completed in our lifetime is the question of the day. The Federal agency, DOGE, is currently investigating HSR. What kind of research and development is being built, the PEIR fails to state but it shows this specific section of the area will be something similar to what we have near Food Max (Clovis & Kings Canyon). Take a look at the pictures I have attached as to that development. This is what will occur in SEDA.

Finding #3 “SEGA contributes to the decline of Fresno farmland.” (City of Fresno Minutes 2/10/11)
My first concern is that our local government, the City, commends itself on transparency, however, to locate the PEIR on its website is not the most obvious and direct access. That in and of itself is problematic and deceptive because as you know, not all of society is tech savvy. To locate, you click on the City’s website, then Planning and Development, (scroll all the way down) click on Long Range Planning (why the community would know to go there is beyond me), then Plans and Projects Under Review, then find Southeast Development Specific Plan (the document that Asadoorian stated we could not comment upon), then locate and click on Executive Summary which is a separate document that discusses the changes of the new recirculated PEIR, and then scroll a few links down then click on Recirculated EIR - February 2025. This is ridiculous!! The City is fully capable of having their IT staff place a link or a scrolling marquee on its homepage with a link that auto connects/opens to the Executive Summary and the PEIR. This attempt to make things difficult for the reader, adds to gamesmanship of today’s politician and government which leads the public to frustration and distrust all done in hopes that the public abandon the comment period; this tactic is no surprise to the vast majority of us.

In addition, the PEIR is over 800 pages, 800 pages! This is so overly burdensome and overly exaggerated (for comparison, the Fresno County Recommended 2024-25 posted online is 390 pages for 15 cities (PDF pages)). Furthermore, do you think it’s asking too much to again have your IT staff make this document so that the reader has the ability to click on the page number in the table of Page of 1 11
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contents and be auto routed to that page, automatically. I believe the taxpayers and members of Fresno deserve that type of efficiency from our government that we the people elected. Don’t play hide the ball!
Please be aware that I spoke to Ms. Asadoorian by telephone and she confirmed that the Specific Plan is a document that will be used by the City to support their PEIR; however, the public is not allowed to comment on the Specific Plan, only the PEIR. I find this disingenuous. If the City is being allowed to submit the “specific plan” in support of their PEIR, the public should be allowed to comment upon in opposition to the PEIR. What law states we are not allowed to comment?

PUBLIC RECORDS ACT REQUESTS
We requested information in our previous opposition to the City’s EIR back in July 2023. The City failed to respond to our requests for information. It’s our understanding it wasn’t read because the city needed a do-over, how convenient. In preparing for our opposition to the February 2025 PEIR, we submitted PRA requests through the online portal. As of this date the City has requested an extension of time to respond to my requests: R074432-030725 extension requested to March 25th; R074041-022725 extension requested to March 24th; and R073948-02265 extension requested to March 24th. I find it disingenuous and intentional that the City is requesting an extension to a date of either on or after the public comment period for the PEIR. We did notify counsel’s office of this and nothing that we requested is overly burdensome on the City, it is all information that the City does have on-hand. The City has not provided a good faith effort in an attempt to provide us with this information as a member of the public; they unilaterally picked a date that was conveniently on or after the City’s public comment deadline. My requests were all submitted well in advance to the public comment period. This in turn led me to submit a PRA (R074705-031225 inquiring about the City’s remote/telework policy for City staff and employees).

In addition, I have submitted a PRA (R075085-031725) to the City/lead agency regarding eminent domain and the process and procedures. As you should know from our previous comments to the last EIR, the City staff at one of their public meetings stated that eminent domain would not be used but further failed to respond as to what would happen if we do not comply. This is the type of full transparency the public requests of you; do not hide behind your veil of ignorance and not fully discuss the ramifications of SEDA. We the people want to hear how you will abuse your power and take this land unjustifiably under the guise of a housing crisis. The remedy to your man-made crisis:
tell your developer donors to lower the pricing of the current homes developed, making homes more affordable. zillow.com states average rent is $1,600, how about finding a way to have property owners lower their rent price so people can afford to rent. There are other ways to go about this other than allowing government to take our Prime, Unique and Important ag land.

BACKGROUND/HISTORY
In response to our PRA request #R073922-022625, the SEDA Specific Plan (Page 90 of the Plan) states, under management, neighborhood gardens can be owned by a city, county, … non-profit etc. This clearly confirms it is a land grab by our government, to take from the current property owners and line the pockets of government and developers. It further states the City encourages neighborhood organizations to seek funding for the neighborhood garden. If the people cannot find housing on their own and require assistance from government (to find and pay), how will they find funding for a neighborhood garden? But this does say “organizations” not the community members.

Who will be the ones to gain financially in these transactions? There is no actual confirmation that these so-called gardens will actually occur. The Plan the City attached to this 2010 item produced, in response to my PRA ending in 022625, paints the picture of agriculture, all in an effort to convince and fool the public and readers, the Prime Ag land the government is taking, is not lost or forgotten.

What I find once again disingenuous is the City responded to this PRA wherein I requested documents from 2006-2008, however, we received their agenda item from 2010 and attachments thereto but the City also included the SEDA Specific Plan in said response (which said Plan fails to reflect a date) and that Plan was not the plan utilized back in 2010 or 2006-08 for that matter, it wasn’t changed from SEGA to SEDA till when 2014? The City offers no explanation in attaching the Specific Plan, since it lacks a date and seems to be the same Plan that is currently posted on your website but without a date Page of 2 11
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it cannot be verified, we would have to guess where it falls in response to my PRA; is this the Plan that would have been utilized, referred to, relied upon back in 2010, 06-08? The City is merely sending documents to see what sticks in hopes of papering us to death and shut us up.

Furthermore, the Minutes I received, pursuant to the above-mentioned PRA request, dated Feb. 10, 2011, and years 2007, 2008 did not include their respective agenda items. Maybe the City Councilmembers should review the 2011 Minutes to see the chaos, lack of transparency, and problems that arose during that city council meeting. “President Brand introduced the item and clarified the intent of this action was not to kill SEGA.” Note: We the property owners say it should have been, then and now. But, the fact that he opens with that statement should give us all pause and ask why would he open with a statement as such … because there was and is reason to kill SEGA. President Brand refers to a fiscal crisis back then and like today, under a new federal administration, we are currently in a fiscal crisis: Federal funding is being frozen for waste and fraud.

Councilmember Borgeas then stated during this hearing in 2011 …. “Fresno cannot be afraid to admit when it makes mistakes.” We say and we believe have shown that SEGA/SEDA is a mistake now and then. On said minutes: Finding #3 “SEGA contributes to the decline of Fresno farmland.” True then and true today. That 2011 statement is confirmed in 2025 pursuant to the 2/7/25 PEIR (see Page 168, 169, 173 and throughout the PEIR. Per the 2/10/11 Minutes, President Brand states that SEGA was attractive looking at it from a distance. However, it seems from the minutes, as they took a deeper dive it became a totally different story. Finding #4 population projections used to justify SEGA are inconsistent with growth trends. Here we are today, 14 years later after the 2011 Minute order, and not much has been learned, gained, remedied, rectified, clarified, changed, or made obvious and transparent to the public or property owners as to why SEDA should move forward and more importantly at this time, we believe this further shows us today that SEDA should be killed (Brand’s word used). Basis for SEDA, original estimate annual population growth through 2050 1.5%; revised population growth estimate .18%; bigger than necessary for population growth 8.3X; 44,000 units planned; units actually needed 5,300; SEDA infrastructure cost estimate $0; potential infrastructure cost: $1,000,000,000+; City’s budget deficit 2025 $20,000,000; basis for infill city limits 8,200 vacant acres=134,000 units; how much sense does SEDA make: ZERO (0).

Most concerning from this read and worthy of further investigation today is Westernlund’s statement that there was a whole other side to this story and a number of things he wanted to speak to. As a tax paying citizen, registered voter, I’m perplexed as to why he would not speak candidly, openly, and honestly in said hearing, public forum, on that date. What was holding him back? Who do you represent in this capacity? If there was another side to the story, it should have been told, needs to be told, and yet no one stood up and thought it best for the We the People to call him out requesting that he speak now or the hearing cannot move forward or the development cannot move forward, that’s what you are elected to speak on behalf of the people.

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and out of control. Jurisdiction was a concern at that time, and it was further stated he had an issue with procedure and stated “stinks big time.” Brand said it was getting personal. Clearly, throughout the Minutes we see some major concerns here; has anyone completed an in-depth investigation regarding the initiation, involvement of the persons, and the development itself; or, addressed these past issues or will the City attempt to have this skirt by, sweep it under the rug, in hopes nothing is revealed. Page 157-44, Brand states he learned the City spends way too much money on consultants.

It’s now 2025, we have the same questions and concerns as reflected in the 2011 Minutes; the PEIR fails to fully and completely mitigate the issues raised in this current PEIR; and the past concerns of council. For reasons stated above, we oppose the PEIR dated 2/7/25 and believe we should look further into the concerns discussed in the 2011 hearing and if those concerns were in fact addressed, with or without public involvement; we believe it should be discussed in a public forum not private closed session. We further would like to see in a public forum, in an effort to be fully transparent, those donor contributions to the elected officials of that time as well as currently seated officials (e.g.

Statement of Economic Interests - Form 700, Gifts & Gratuities or any other forms required by the FPPC).

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We submitted PRA #R074526-030925 to the City requesting the names of persons or organizations the Planning Department, City Manager, Districts 1-7 and Mayors office have met with to discuss SEDA from 2022 to present. Of course the City requests an extension to March 31 in which to respond.

PAGE ES-1 (Executive Summary):

This document and lead agency states that the purpose of the subject PEIR is to inform of potential environmental effects as a result of implementing the SEDA project. It is further stated that this project is described as an “acceleration of housing production.” The CITY is requesting to speed up producing homes. They base this on meeting the need of “diverse housing types” and “affordability levels.” All to be completed by the year 2050. Has the revitalization of Downtown Fresno been completed? Have the vacant buildings in that location been restored, refurbished. Has new life as set forth in history when Downtown Fresno revitalization was introduced to the public been established? The honest answer is NO! The City web page states Downtown is following in the footsteps of Oakland and Sacramento. That more than 600 apartments have been recently added and the Mayor’s goal is to grow the neighborhood from 3,000 to 10,000 residents. How about the high speed rail, yet been completed? When the rail was presented by a group of past elected officials it was posed as prosperous (to who that’s unknown), and much needed; past elected officials believed a bullet-train from San Francisco to Los Angeles was needed (for who that is the unknown). Has the rail project been completed? The honest answer is NO! Look where we are at today in both projects, failure to complete (how many years later); failure to pay and/or have the money, and look at the environment.

Just like DOGE is involved in looking into the high speed rail maybe we need to have them look into this land grab and how the City is spending our money and who is benefiting from this money.

Maybe it’s time the City of Fresno’s waste and fraud be exposed. This PEIR of course states all in the name of being fiscally responsible, social equity, environmentally sustainable. I’m sure that is what was said for Downtown and the High Speed Rail. Downtown is littered with homelessness, businesses unable to stay afloat due to the increasing costs in rent, utilities, food, wages, and the inability to keep downtown Fresno safe, at its closest location to law enforcement. What this PEIR is introducing us to is Fresno 2.0. You’ve heard that term used by Gov. Newsom, after Southern Cal was devastated by wildfires (closest cities to the ocean); how interesting our government is now referring So Cal as a Smart City, to rebuild LA 2.0. Same thing with Lahaina (Maui wildfire), their government wanted a Smart City too.

The Fresno Housing Authority “manages diverse properties and programs;” they are designed and designated for “under-served populations, including farm laborers, migrant workers, seniors and those in need of support.” On their website I find over 70 properties in Fresno within a 35 mile radius. In 2024 and 2025, Fresno County developed new “affordable” housing such as Avalon Commons, The Arthur, Promesa Commons, Sarah’s Court apartments at Fancher Creek and Crossroads Village.

Population continues to be inconsistent as under this new current Federal administration, with the deportation of illegal immigrants, their need for housing will substantially decrease. In addition, the most cost effective remedy is not develop, develop, develop but how about pursuing these developers to lower the cost of their homes built to make them more affordable.

For this reason and many others as stated below is why we Southeast Property Owners strongly oppose the SEDA development and the recirculated Proposed EIR.

In addition, we have a mental health crisis, homeless problem involving substance abuse, mental health,; an illegal immigration problem, economy problem (groceries-eggs are $8 a dozen, rent, interest rates, tariffs), and the federal government is not inclined to continue writing checks. The lead agency states a population however how did they come up with the numbers on the population? You can no longer count those here illegally and therefore numbers must be adjusted. Who was included in your count, must be answered?
GV Wire article dated 12/17/24 by Edward Smith states: “A proposal would put 400-single family homes on the property occupied by the massive former IRS processing center in southeast Fresno.” This is not about housing, this is about a land grab to line the pockets of politicians and developers/ donors.

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PAGE ES-2&3:

The lead agency states this project would result in significant and unavoidable impacts. This right here should be enough and tells us all we need to know, but let’s continue.

PAGE ES-4/AES-3 and Reference 3.1:

The lead agency has confirmed this project will substantially degrade the visual character or quality of public views of both site and surroundings. Of course it will. As stated in 2011 and still true today, SEGA is a decline of Fresno farmland. The impact physically to land, air, aesthetics, birds, coyotes, will be obsolete/extinct as we are pushing the city further and deeper into rural territory that was not meant or intended for a city life or Smart City. The effects would be changing the view of green landscape, fruit trees, vineyards, to concrete buildings, cell towers, cars, lights, bus and change the sounds of birds, quiet, little to no traffic in exchange for cars, power equipment, talking, music; pollution from those vehicles and buildings. This affects not just a few but it affects 9,000 acres.

Adding a grassy knoll does not relieve these problems. You will still see those tall cement buildings, businesses and housing units, vehicles, lights whether it’s a public view (from the grassy knoll) or private view. In the cities, you hear or read about in the news sightings of coyotes, duh of course, you moved into their territory, whether coyotes, toads, skunks, all those animals don’t just up and walk to Squaw Valley to relocate, they will either die because we have removed their source of feeding or stay. Go outside in the morning, we hear birds singing; go out in the evening, you hear the toads, crickets. Under SEDA all will be lost and it will be traffic, smog, cell towers, homeless encampments.

The agency confirms there are no feasible mitigation measures available to mitigate the impact. For the reasons we stated, we oppose.

AES-4 Light & Glare:

Creates new source of light/glare adversely affecting day/night views.

The lead agency has confirmed this project will substantially degrade the visual character or quality of public views of both site and surroundings. As stated in 2011 and still true today, SEGA (SEDA) is a decline of Fresno farmland. The impact physically to land, air, aesthetics, birds, coyotes, will be obsolete or extinct as we are pushing the city further and deeper into rural territory that was not meant intended for a city, a Smart City. The effects would be changing the view of green landscape, fruit trees, vineyards, to concrete buildings, cars, lights, and change the sounds of birds, quiet, little to no traffic to cars, equipment, talking, music; pollution from those vehicles and buildings. This affects not just a few but it affects the 9,000 acres. Adding a grassy knoll does not relieve these problems. You will still see those tall cement buildings, businesses and housing units, vehicles, lights whether it’s a public view (from the grassy knoll) or private view. In the cities, you hear or read about in the news sightings of coyotes, well yes you moved into rural territory, coyotes, toads, skunks, all those animals don’t just up and walk to Squaw Valley immediately, they will either die because we have removed their source of feeding or stay. Go outside in the morning, we hear birds singing; go out in the evening, you hear the toads, crickets. In essence you are building a Smart City, just like your smart phone, laptop, the lighting, the cell towers all for public and private consumption.

The CITY has confirmed impacts remain significant and unavoidable. For the reasons stated, we oppose.

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CUMULATIVE LIGHTS/GLARE:

I refer you to my statements made under ES-4/AES-3 and 4. I reiterate same here. The impacts are significant and unavoidable. For this and all the reasons stated, we oppose.

PAGE ES-4, Impact AG-1 - Reference 3.2:

As we all know, the SEDA project will be a catastrophic loss of 9,000 acres of what we the property owners have stated from the beginning, Prime Farmland, and what the PEIR now confirms as (1) PRIME, (2) IMPORTANT STATE; (3) IMPORTANT LOCAL AND (4) UNIQUE FARMLANDS. Of that 9,000 acres, the PEIR classifies 6,741 total acres as designated Prime Farmland, Farmland of Statewide Importance, Farmland of Local Importance, AND Unique Farmland which is “scattered throughout the Plan Area.” Read that again, scattered throughout the Plan Area, scattered throughout, not a block, not a street.

Again, we are not talking one block, one street, one acre; the CITY is requesting to destroy, demolish more than half of what is designated as PRIME, OF GREAT IMPORTANCE TO THE STATE AND LOCALLY, AND UNIQUE FARMLAND. We argue that all 9,000 acres are Prime , Unique and of Importance to the State and Locally. At a time when groceries are at their highest in the store, you want to build units so a household can “hopefully” create and sustain a garden to feed “their household” but yet you are destroying farmland that feeds the state, our County and quite frankly my/ our households. They won’t even be the deed holders of this so-called housing, government and developers will be the ones to own the land, buildings, housing units. Our home sits next to the Briggs canal which is rare and unique in and of itself; the water flowing into that irrigation canal is from the Kings River. Our property along with many of my neighbors, we grow our own food, have our own farm animals and equipment and yet you want us to allow the government to take what we have paid for-worked for, and live off of, so that the government can create a Smart City/Fresno 2.0 to benefit and line their pockets under the guise of “hopefully” teaching people to have community gardens; the people work the land; the government or developers own the land, that’s your Smart City aka Fresno 2.0.

The PEIR states that loss of farmland still occurs with this Plan, the impact is significant and unavoidable EVEN WITH IMPLEMENTATION OF AVAILABLE MITIGATION. As stated back in 2011, SEGA is the decline of Fresno’s Farmland. Our communities depend on Ag; No Farmers, No Food!
For all the reasons stated in this letter and my neighbors’ letters, we strongly oppose the PEIR as well as SEDA.

PAGE ES-5/AG-2:

There are significant impacts on existing Williamson Act land. This PEIR states is unavoidable and no mitigation measures available. The California Land Conservation Act of 1965 helps preserve agricultural land and open space. It discourages premature conversion to urban uses; it further protects open space; and is supposed to keep land values relatively stable. By doing this, the value of our homes our properties declines substantially. There are supposed to be land use restrictions imposed upon the owners; however, what the City is doing is changing restrictions, better yet protections to property owners, to again line their pockets, the pockets of the developers as government deems appropriate. The California Department of Conservation’s homepage states in part:
…post World War II period. During that time California’s Agricultural and open space lands began to face dramatically increasing conversion pressures from population growth, new commercial enterprises, and rising property taxes. “Valuable farmland began disappearing at an alarming rate as conversion to urban uses became the only financially viable alternative of many landowners.” Page of 6 11
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The Williamson Act Program has remained stable and effective as a mechanism for protecting agricultural and open space land from premature and unnecessary urban development.

For all the reasons stated thus far, we oppose the PEIR and SEDA.

Impact AIR-1 - Reference 3.3:

Potential (which means to become or develop in the future) to exceed the San Joaquin Valley Air Pollution thresholds and not consistent with existing Air Quality Plans. To date, we are told when to burn our fireplace, what type of fireplace, when to burn green waste and yet here the City knowingly wants to implement a project and plan that will exceed thresholds and goes against the standards imposed upon the people of this County. The PEIR states that “due to the magnitude and intensity of development” it is unavoidable and a significant impact.

AIR-2:

Projected Cumulative emissions associated with future development projects exceeds Valley Air thresholds and is a significant and unavoidable impact.

AIR-3 Sensitive Receptors:

The lead agency can’t even respond, foresee, forecast this section. They state, “without such information” “it is not possible to conclude” and it is significant and an unavoidable impact.

For all the reasons stated, and their failure to provide a detailed or any response to include a cost, we oppose the PEIR AND SEDA.

Cumulative Air Quality:
“Not enough information to quantify” “future development projects may still exceed Valley Air District thresholds.” This is what this PEIR states. It further states that due to the size of the project no significant mitigation available to reduce the cumulative impacts to air quality. It remains significant and unavoidable.

The impacts during and post plan development will be great; again, the impacts will be great. You are adding to the vehicular traffic, the people, the businesses, the smog, the cell towers, the power grid.

People will be traveling not only for personal reasons but business. Of course there is a significant impact and it will not be avoided.

For all these reasons, we oppose the PEIR and SEDA.

References 3.4 - 3.8:

GHG-1:

Implementation of project contributes to global climate change through direct emissions of greenhouse gases not only from sources generated by project, indirectly, thru off-site energy. The project increases the population and employment which further contributes to increase in wastewater, water demand, and vehicle trips. Energy is increased due to the magnitude of new buildings constructed. The Environmental impact of the project related to GHG emissions is significant. “There is no mitigation feasible to reduce GHG emissions.” The impacts of this project are significant and unavoidable.

The Minutes dated 2/10/11, provided to me per a PRA request, states in Finding #2: “(Committee finds the SEGA region is known to have insufficient water, and cost estimates on proposed water infrastructure are extraordinarily high)”. This remains true to date. All the properties that would Page of 7 11
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remain have been informed by the City that we would be required to hook up to their water and sewer lines at our own expense. Yet the City has not provided a confirmed cost that would be assessed to property owners and stated that loans could be taken out with the City (now the City is a bank, lender) which would obviously line their pockets; and if property owners fail to be able to pay those loans a lien would be assessed on their home/property. We should not have to take a loan out for thousands, or have a lien placed on our property. What about these property owners who are of retirement years; they cannot just go back to work because of a land grab by the City? In addition, our home sits approximately 200 feet from the road, the cost would be beyond the minimum. Those of us not in prime health would be forced to choose and that is not something that should be posed to us by our government.

For all these reasons, we oppose the PEIR and SEDA.

Cumulative GHG ES-7:

I reiterate my statements here as set forth in paragraph GHG-1. It is reflected significant and unavoidable impacts.

For all these reasons, we oppose the PEIR and SEDA.

NOI-1/Reference 3.13:

The City/lead agency is unable to quantify the construction noise impacts. That’s because it is so extreme during project development and post. During, between several equipment and projects working in tandem vehicles added to the road, people, its beyond what we can imagine, quantify or explain As stated in the PEIR, the impacts are significant and unavoidable.

Cumulative Noise:

Details of individual development projects are currently unknown. It is not possible to quantify future cumulative construction noise impacts if multiple developments construct simultaneously creating a cumulative noise impact. Because they can occur simultaneously and noise can occur for prolonged periods of time, cumulative construction and noise impacts are possible and are significant and unavoidable.

For all the reasons stated throughout this opposition, we oppose the PEIR and SEDA.

Reference 3.13:

How is this fiscally responsible? There is no projected cost that’s been provided for SEDA construction nor monies allocated that we are aware of. We requested information, PRA #R073948-022625, asking for the City to identify by name/business and address all federal, state and local funding sources, grants, monies received by the City and requested by the City that will be applied to, and used for SEDA, include dates and amounts received and requested. You know the response we received from the City, they need an extension to March 24th (the deadline for public comment). This project has been in existence for over a decade, decade, and either they: (1) are lying; (2) playing hide the ball; (3) lack full transparency; or (4) abuse of power. Maybe all of the above.

This is evidence of the type of answers we the property owners receive from the City on a consistent basis as it relates to SEDA. The lead agency/city cannot confirm to current southeast property owners the cost to connect to the city’s water/sewer, which they state will be our financial responsibility to bear; they cannot confirm how much money a project of this size will cost the taxpayers, City and County citizens. This is a problem; maybe this is what the past council member meant by stinks big time? As done with the high speed rail any cost projection is a guess and can increase substantially after the project commences and you will have destroyed over 9,000 acres of farmland for what, a Smart City, you can revitalize downtown Fresno and have your Smart City, it’s already there, vacant.

Buildings exist downtown, drive throughout this City, you will find abandon buildings; and can be reconstructed by your developers for a confirmed cost. Are you receiving federal funding? If so, maybe we should get DOGE involved to see how fiscally responsible and cost effective this PEIR and Page of 8 11
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project Plan really is; or, maybe they will uncover waste and fraud at the expense of taxpayers and on this project, at the expense of the property owners.

How is this social equity? You are removing elders, our retired community, the vast majority of property owners in SEDA plan are retired, or farmers, and existing long-time property owners and families whose lives are according to their land, we grow our own food, have our own farm animals; you are forcing us from our PRIME, UNIQUE, AND GREATLY IMPORTANT TO THE STATE AND LOCAL FARMLAND, to create Fresno 2.0/Smart City under the guise of “affordable housing.” I have attached to this letter pictures of how fiscally responsible, socially equitable, and environmentally sustainable the City of Fresno, County of Fresno is currently. (See attached pictures). There is an existing development located on the northeast corner of “Kings Canyon” and Clovis Avenue, the City just added a Ross in that development, the old OSH building (because a second Ross store was needed—there is a Ross located on Kings Canyon just 2.1 miles from the new Ross, stupid right); because Southeast Property owners only shop at Ross. You have vacant buildings located within this same complex, a Smoke Shop (see attached), empty buildings, which is all a place for the homeless community and thugs to hangout, start fires to keep warm, drug interactions. SEDA monies can go towards the homeless, mental health, the west side existing property owners and your Downtown Revitalization.

Between the City and County, there have been new developments of new affordable housing. Look at the canal that runs along McKinley from Clovis Avenue to the 168 freeway, look at the homeless that camp there. If you can’t take care of that existing problem, how will you take on the homeless encampments in this new development, because if you build it they will come. This is the proof of what happens to the City of Fresno, they become a part of the have nots, they no longer receive the help that they need. The money for SEDA can be given to the homeless and provide the assistance they need. They don’t need a Smart City.

Hydrology & Water Quality - 3.10
The proposed project would have significant impact on the environment if the proposed project would:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. (PDF page 453)
c) Substantially alter the existing drainage pattern of area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
(i) Result in substantial erosion or siltation on- or off-site; (ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
(iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff;
or
(iv) Impede or redirect flood flows.
(d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
(e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

The above language from the PEIR I believe shows we will be violating the water quality standards and waste discharge; we will substantially decrease groundwater supplies or interfere; alter the Page of 9 11
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existing drainage; result in erosion … nothing good will come from SEDA. Now is not the time.

How much more money should you throw out the window?
Impact HYD-2 Groundwater Supply & Recharge:

The PEIR states:

The proposed project could substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.

It further states that groundwater alone will not be sufficient to meet future City demands, including those for SEDA. (PDF Page 492)
If you recall, the City/lead agency states this is to be fiscally responsible, environmental sustainability and socially equitable. Approving this to move forward fails us in all capacities including the people outside of SEDA where water is an issue in general such as Cantua Creek, El Porvenir. There are outside areas not only within the City of Fresno but Fresno County who need dire attention and have government focused on their water issues; not government creating new water issues for the sake of Fresno 2.0 Smart city.

The Business Journal 12/10/24: It’s Horrible: Fresno’s Record-Breaking Settlement Highlights Region’s Larger Drinking Water Problem. This article states that a review of documents and interviews of key officials uncovers a decades-long environmental crisis enabled by both corporate greed and bureaucratic neglect. It goes on to state that a darker truth emerges—the money will vanish in less than a decade, covering filtration costs for roughly eight years, according to interviews with City officials Georgeanne White and Brock Buche. Once the settlement funds run dry, Fresno residents will be left to shoulder any remaining pollution cleanup, at a cost of millions each year.

PDF Page 492 of the PEIR states, “impacts to water supply and demand would be considered at the time of annexation for each specific parcel.” How stupid and reckless, environmentally and fiscally, to wait until the time of to determine the impacts to water supply and demand. Now we see how the high speed rail is in its current situation; let’s wait until we are knee deep in this, people have lost their homes and property, with no recourse. Is this what we teach our children, don’t think about the consequences now, just do it and we will deal with it later? We are doomed if this is the mentality of our government.

Cumulative significance before mitigation is significant impact, after mitigation less than significant with mitigation incorporated. The cost associated to mitigate will be astronomical and our outer communities will pay the price and be the ones to sacrifice once again. Fix other problems before creating new ones! This is fiscally, environmentally, and socially irreparable; ultimate damage is TBD and you have no right and its the least of our people who will be the sacrificial lambs. In closing, the lead agency is not accelerating housing, it is accelerating land grabs. You are to serve the interests of your constituents not your donors.

3.19 Wildfire
There is no longer a wildfire season, wildfires occur all year. This development in no way reduces wildfire risks, it enhances the risk as well as puts a further strain on already limited resources available to other communities during hard economic times. Wildfires in Maui, Southern California, Moss Landing battery facility.

Stanford University, Stanford Woods Institute for the Environment article: Wildfire News Releases Social and Economic Disparities Impact Wildfire Protection. This article states that low income communities in California are at a greater risk of suffering the consequences because they are less protected. Financial support, educational programs, wildfire preparedness? Page of 10 11
ORTIZ 1

Page 18 of 19 ends

Reference 4.3 - Mandatory Findings
When the farms are gone, remember, it’s forever!
For all the reasons stated in this letter, the attachments, and the other southeast property owners’ letters, we strongly oppose the PEIR as well as SEDA.

Sincerely,
Attachments (Pictures) to Ortiz Opposition Letter
Cc: Annalisa Perea, District 1 - [email protected] Mike Karbassi, District 2 - [email protected]
Miguel Ariaas, District 3 - [email protected]
Tyler Maxell, District 4 - [email protected]
District 5 - TBD Due to Special Election sent to City Clerk Nick Richardson, District 6 - [email protected] Nelson Esparza, District 7 - [email protected]
Todd Stermer, City Clerk - [email protected]
Page of 11 11
David Ortiz & Natalie Ortiz
Elijah Ortiz
ORTIZ 1

Page 19 of 19 ends

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-661
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx David, Natalie, and Elijah Ortiz (First Letter) (ORTIZ 1) Response to ORTIZ 1-1
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required.

Response to ORTIZ 1-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

In addition, there is no requirement to provide “reference numbers” in comment letters responding to the Recirculated Draft PEIR. CEQA Guidelines Section 15088(a) provides:

The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The Lead Agency shall respond to comments raising significant environmental issues received during the noticed comment period and any extensions and may respond to late comments.

Therefore, this Final PEIR provides written responses to any comments received during the public comment period that identify significant environmental issues. No further response is required.

Response to ORTIZ 1-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further analysis is required.

Response to ORTIZ 1-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-662 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to ORTIZ 1-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to ORTIZ 1-6
The comment is noted. Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 1-7
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to ORTIZ 1-8
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please also refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses.

Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Additionally, please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 1-9
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-663
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 1-10
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to ORTIZ 1-11
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-12
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-13
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-14
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-15
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-664 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please also refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 1-16
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please also refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 1-17
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-18
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-665
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to ORTIZ 1-19
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-20
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-21
The comment is noted. As discussed in Section 3.8, Greenhouse Emissions, of the Recirculated Draft PEIR, the City utilizes the criteria in the CEQA Guidelines Appendix G Environmental Checklist to determine whether greenhouse emissions impacts are significant environmental effects. The vast majority of individual projects do not generate sufficient GHG emissions to create a project specific impact through a direct influence to climate change; therefore, the issue of climate change typically involves an analysis of whether a project’s contribution toward an impact is cumulatively considerable. As defined in the CEQA Guidelines, Section 15355, “cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects. For future projects, the significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds, or consistency with a regional GHG Reduction Plan (such as a CAP).

The City of Fresno developed its first GHG Plan in 2014, which includes GHG reduction targets and emissions inventories for the years 2020 and 2035. An updated GHG Plan (the GHG Plan Update) was adopted on September 30, 2021, pursuant to a certified General Plan Program EIR (State Clearinghouse Number 2019050005). However, in 2024, following a legal challenge, the 5th District Appellate Court rejected the City’s PEIR and GHG Plan Update. Both were rescinded pursuant to a Court order. The City’s previously adopted GHG Reduction Plan (2014) has not been the subject of a legal challenge and has not been invalidated by the court. As stated, the 2014 GHG Reduction Plan includes reduction targets for 2035; however, the full 25 year buildout of the proposed project goes beyond the year 2035 and is anticipated to be fully operational in the year 2050. Therefore, this analysis evaluates the consistency of the proposed project with ARB’s latest 2022 Scoping Plan, City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-666 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx including the proposed project’s consistency with relevant Scoping Plan measures and the latest RTP/SCS for the region within which the Plan is located. The 2022 Scoping Plan is consistent with the State’s longer-term AB 1279 GHG reduction targets of achieving carbon neutrality by 2045 and reducing GHG emissions to 85 percent below 1990 levels by 2045. Therefore, consistency with the 2022 Scoping Plan would also demonstrate consistency with the State’s long-term GHG reduction targets encapsulated by AB 1279.

The analysis contained within Section 3.8, Greenhouse Gas Emissions, of the Recirculated Draft PEIR provides a qualitative assessment of the proposed project’s compliance with the applicable plans, policies and regulations for the purposes of reducing GHG emissions to determine whether the proposed project would have a significant impact on the environment relative to GHGs.

As such, while the previously circulated Draft PEIR determined that impacts related to GHG emissions would be significant and unavoidable when evaluated against the City’s now decertified GHG Plan Update, the Recirculated Draft PEIR determined that impacts related to GHG emissions would be less than significant when evaluated for consistency with the 2022 Scoping Plan and the latest RTP/SCS for the region. No further response is required.

Response to ORTIZ 1-22
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to ORTIZ 1-23
The comment is noted. Please refer to Response to ORTIZ 1-21. No further response is required.

Response to ORTIZ 1-24
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-25
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-667
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 1-26
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to ORTIZ 1-27
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

Response to ORTIZ 1-28
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

Response to ORTIZ 1-29
The comment is noted. Please refer to Master Response 12, Clarifying Information on Wildfire Analysis, in Section 2, Master Responses. Master Response 12 elaborates on the methodology used in Section 3.19, Wildfire, of the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 1-30
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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October 12, 2023
March 22, 2025
Via Email Transmission Only
City of Fresno, Council Members – Districts 1 thru 7
City of Fresno, Mayor, Jerry Dyer
City of Fresno Planning Department & Commissioners, Jennifer Clark & Janice Monroe Dear Council members, Mayor, Ms. Clark and Ms. Monroe:

This letter was previously submitted in October 23; however, we were informed the City failed to read it. Please accept this letter as our second submission. As a property owner living in the Southeast Development Area (SEDA), we are contacting you concerning Fresno City's Plan to develop 9,000 acres in this area. This letter follows and is in addition to the previous letter we submitted to your City. We are concerned that this development plan will be harmful to Fresno in numerous ways and, therefore, are asking you to oppose this plan. The plan failed to provide remedies to obvious problems; failed to provide direct answers regarding Air Pollution, Water, eminent domain, annexation, zoning, and full transparency. As you know, what the City is attempting to develop is a 15 minute city, a smart city under the guise of housing needed.

However, as you further know, with Hotel Fresno in development, the wide array of vacant buildings in downtown Fresno (all throughout the City of Fresno), as well as the vacant buildings located on the northeast corner of Kings Canyon and Clovis Avenue and vacant land and new development on Clovis and Tulare there are areas that you can develop, why you are choosing prime farmland is reckless. Furthermore, it was just in the news about the old UMC building being purchased, the city could have required that the purchaser use this building for low income housing.

The number one concern with this development is the lack of water. There are no concrete answers from Fresno's Planning Commission as to how they will provide water considering the magnitude of the population increase promoted.

We are also concerned with the loss of the best agriculture soil in the world. It is sandy loam soil making it prime soil for agriculture purposes. We request that the agriculture heritage of Fresno not be turned into housing.

We are also concerned with the loss of county residency, the inner city problems created with high density housing, the climate change concerns, the loss of personal property due to eminent domain, and the loss of property value.

ORTIZ 2

Page 1 of 2 ends

1 3
2 Please let us know when an item related to SEDA will be on the City Council’s agenda.

Please help the Southeast Property Owners in opposing Fresno City's goal of developing the 9000 acres. We feel that the implementation of this proposal would have a negative effect on the property owners, the City of Fresno, and the production of food for the nation as well as the world. We request that this proposal not be implemented.

When the farmland is gone, it’s gone forever! Say NO to SEDA! Respectfully,
David & Natalie Ortiz
Elijah Ortiz
ORTIZ 2

Page 2 of 2 ends

3 CONT
City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-671
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx David, Natalie, and Elijah Ortiz (Second Letter) (ORTIZ 2) Response to ORTIZ 2-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 3, Clarification Regarding Previous Comments Received, in Section 2, Master Responses, of this document. Master Response 3 provides clarifying information related to the review of or response to any comments received on the previously circulated Draft PEIR and Partial Recirculated Draft PEIR, including comments incorporated by reference in the public comment period.

Please also refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Further, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Finally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 2-2
The comment is noted. Please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

Response to ORTIZ 2-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please also refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-672 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

August 24, 2023
March 22, 2025
Adrienne Asadoorian, Planner
City of Fresno, City Clerk
Fresno City Council, Chairman and Council Members
2600 Fresno Street, Third Floor
Fresno, CA 93721
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
OPPOSE LETTER – EIR AND EDA/PROPOSED LAND USE/ANNEXATION/ BY THE CITY OF FRESNO Dear Chairman, Council Members, City Clerk, and Ms. Asadoorian:

This letter was submitted back in August 2023; it’s our understanding the City failed to read it. This is a second submission. Please accept this letter as our opposition to the City of Fresno’s EIR report and the SEDA development, annexation, proposed land use and the map thereto, which is an item that is expected to go before the City Council in or about October 2023.

Our specific property/land sits next to what is known as the Briggs Canal. It is our understanding that water in the Briggs comes from the Kings River. This water is what irrigates properties for the food that you and I to eat and serves a greater purpose. It is serviced and maintained by Fresno Irrigation District (FID). The District’s web page, under About Us, states as follows: The FID is a leader in California water, serving over 200,000 acres of prime agricultural farmland … Farmland sitting next to or that abuts a water structure such as ours is rare in Fresno County and not easily attainable. With our property adjacent to Briggs, it is irrecoverable and we would suffer a great loss. Therefore, we oppose the redevelopment and conversion of prime farmland to serve a purpose as Flexible Research and Development, which by the City’s definition means no residential uses will not be allowed. That would therefore leave eminent domain which the City has stated would not be used however if I do not sell and my neighbor does not sell then there is no other recourse but for the city to use eminent domain. We have all seen what has occurred with the Reedley lab and as stated by many of you council members the public is placed at risk and so many other factors such as disease, groundwater contamination were common concerns. If we in this area “Flexible Research and Development” please explain with specificity what occurs to the property/land/farm owners the process and procedures and confirm if our property will be taken from us through eminent domain?
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1 The City’s project and plan area consists of Prime Farmland. We own 2.49 acres of farmland in the proposed SEDA plan area. We house two tractors, chickens, apricot trees, as well as house pets on our land. We are current fosters for the county animal shelter and we are able to assist with fostering of more than one animal primarily due to the land we have. We work our land like most, if not all of the residents in this project area. Removing farmers who grow their own food; and/or who commercially feed this Community, County and State is reckless and negligent so that the City can expand. The City’s proposed land use map reflects for our parcel “Flexible Research & Development.” You want to take irrecoverable prime farmland for Flexible Research & Development when you can place Flexible Research & Development in the vacant Orchard Supply building (vacant for more than 5 years). Does that mean a lab such as that most recently found in Reedley, CA will go here. What does “Mixed Residential” mean on the City’s map? I specifically asked if that meant low income housing, please explain. Again, there are so many other vacant buildings within the City of Fresno that would allow you to do this that we do not need to remove, redevelop and destroy Prime Farmland or Farmland in general.

We have been told on numerous occasions that we would not be required to hook up to City services (water, sewage). We believe that to be incorrect. We were told that the City would not require us to; if not the City then who? If I am the only house that does not hook up, will I be forced to hook up? What will the cost be? Is there the potential for placement of a lien on my home due to the cost of these services? Please also confirm with past projects in this area or within the City (i.e. the area in and around north Jensen and Fowler to Kings Canyon etc.) how that land development was handled and if the landowners that were pre-existing were required to hook up to City of Fresno services (water/sewage).

If so, what were the services, what was the process, the cost, who was responsible to pay those charges or for those services; how many complaints did you receive from the landowners verbal and in writing, what was the remedy of said complaints; and if any of these homes resulted in liens being placed on landowners property/homes. Please also provide on current and past projects when property owners choose to stay and not sell, the city is therefore developed around their property, how many wells have gone dry due to the new development? Does this map become the zoning map for this area? Property owners were also told by the City representatives that eminent domain is not allowed or can or will not be used on property owners and their land located on the Land Use Map for this project, please confirm if this is an accurate statement? When I spoke to Jennifer Clark at the last in-person Drop In meeting she stated that should one homeowner decide not to sell or annex, they (property owner) will not be forced to annex; however, later she stated that they (City) cannot have one house one way while the rest of the area is annexed. Please clarify this statement by Ms. Clark. How will her stated change occur if one home cannot be different from the rest? Please explain who will impose and force the annexation of the land/property owners unwilling and opposing to said annexation? Please explain the process and the impacts to the landowners as well as the changes to zoning affecting the homeowner who did not willingly annex their land. Will I still be able to farm with all these houses around me? As you know, there is vacant land and buildings in or around Kings Canyon and Clovis Avenue; you have the Orchard Supply building that currently sits empty littered with homeless people. You have vacant land and buildings all throughout the City of Fresno and other cities within Fresno County and your plan is to destroy the Prime farmland of the SEPO (Fresno Southeast Property Owners). Destroy our farmland to build more homes, which thus creates more traffic, more congestion, more land and air pollution, more crime, and homelessness. With the Briggs Canal, if that waterway remains, with the increase in population and homelessness, our canals will turn into bathing facilities and used as restrooms. Please ask your homeless task force if that is a possibility that the homeless population uses waterways as bathing facilities and toilets? If this water is intended to feed the community, is it possible for fecal of 2 7
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4 matter, urine and other forms of illness to be in said water. Furthermore, take a drive around the City of Fresno, look at their canals and waterways, you currently have homelessness on your canal banks, tents, littered with trash (e.g. McKinley and Chestnut; in front of the Social Services building Phillip and Kings Canyon, the canal located east of Clovis Avenue--north of Kings Canyon by Orchard Supply). The City is unable to handle the demands of the current crisis and you want to spread it out. Your intent is to make a 15 minute city. We have seen the destruction of Paradise, Maui, when you began to impact the rural areas which are not intended to be within the city limits. We have water issues, we were just in a drought and there is no guarantee that we will be blessed with rain in the future. How will you control air pollution? Where will you get water from? How will you get the needed money to build the infrastructure for this plan?
The City of Fresno needs a boundary, do not grow it out here destroying the aesthetic rural southeast farmland.

The EIR REPORT:

Paragraph 1.2.1 lists the potential significant environmental issues that require further analysis.

Therefore, this is incomplete. In light of this statement, we oppose this EIR and request that you vote to deny/oppose/reject.

Paragraph located on PDF page number 762 titled (Wild-2) … Pollutant Concentrations from Wildfire impacts under this topic would be less than significant and there is no substantial change. However, we disagree and oppose that statement in that the City has a wide-ranging homeless population. What factors were considered as it relates to the ongoing homeless population within city limits when addressing this issue? We see many fires started due to homelessness. City streets are littered with trash, drugs and/or paraphernalia, and the homeless population utilizing fire in order to cook or stay warm during the winter months. Therefore, we disagree with this report and believe further studies should be done. As a reminder and as stated in paragraph 3.19.7, you would be converting prime ag land to residential and mixed-use land uses. Significant and unavoidable.

Chapter 4 Other CEQA Considerations – Bulletpoint AG-1 (… Conversion of Farmland to Non-ag Uses) states 2,475 acres of land designated as Prime Farmland, 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of land designated as Farmland of Local Importance, and 1,725 acres of land designated as Unique Farmland “scattered” throughout the plan area. The impact is significant. Based on this information contained in the EIR, we oppose and request that you vote to reject/deny/oppose and that this plan does not move forward. We further request that all maps be amended to identify the land properly in full transparency. Significant and unavoidable.

Bullet Ag-2 (… Conflict with Existing Zoning or Williamson Act Contract) – This paragraph states in part that according to the Williamson Act Property map, the majority of the Williamson Act properties within the SOI and City are located within the Plan Area. It further states that there is a significant impact on existing Williamson Act Contract land. Ultimately, you are still converting Williamson Act land to non-ag land. For this reason, we strongly oppose and request that you vote to oppose and/or deny on this basis. We further request that all maps be amended to identify the land properly in full transparency.

Significant and unavoidable.

Bullet Cumulative Ag Resources and Forestry Resources Impacts states and acknowledges that there is a loss of Prime Farmland within the plan area. Under your plan, you destroy existing Prime Farmland, Unique Farmland and small farms to build or develop community farming and small farms. The EIR of 3 7
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7 states that it will be a significant impact on Ag zoning and the Williams Act Contracts and there would be land use changes resulting in the conversion of farmland to non-ag uses and is unavoidable. We were told by the City at Drop-In meeting #1 on July 24, 2023 that we would not be rezoned should property owners choose not to sell. However, Jennifer Clark at the last in person drop-in meeting stated that we cannot have just one home not similarly zoned or annexed; therefore, please confirm what occurs based on Clark’s statement. Rezoning would only occur if a neighbor complained, which thus alters my land use. The City’s statement clearly is misleading and misrepresents what is occurring. I believe the impacts would be more than significant in that you are displacing property owners who are generational farmers, and farmers of their own land; how many of us current property owners would be physically displaced, and harmed financially. Based on this information we request that you strongly oppose and/ or deny based on this statement.

Impact Air-1 paragraph states this projects exceeds the San Joaquin Valley Air Pollution Control District another significant and unavoidable impact. Based on this paragraph we request you vote to oppose and/or deny based on this paragraph. Please note that we asked at the drop-in meetings why the Air Pollution District was not a part of these meetings to share in on the added pollution due to this development.

Air-3 states that since it cannot be foreseen the amount of construction occurring nor the exact location it cannot be determined if the emissions could be adequately controlled or reduced. Based on this statement, we believe the study is not complete as it must be looked at, precise and discussed. We are opposed based on this statement and request that you vote to oppose/deny.

Greenhouse Gas Emissions cumulative impacts are significant and unavoidable. Based on this statement we oppose and request that you vote to oppose/deny.

Impact NOI-1 – This statement states that impacts are significant and unavoidable. It also states that they are unable to quantify therefore there is no true, accurate impact identified and said report is incomplete. Based on this statement we oppose and request that you vote to oppose/deny. The Cumulative Noise impact is again noted as significant and unavoidable.

Exhibit 5-2 of the EIR shows just under 2,500 acres of Prime Farmland, and Farmland of Statewide and Local Importance, Unique Farmland of Importance, etc.

The EIR Table 5-1 under paragraph 5.7 states there is no location in the City where 45,000 homes (yes the Plan calls for 45,000) could be constructed while avoiding environmental impacts to ag land. Ag land would be impacted regardless. However, the land is not your basic ag land, it is Prime Farmland, it is land that sits next to the Briggs Irrigation Ditch which is rare, it’s farmland with statewide and local importance, it’s my backyard, small farming, however, we the property owners choose to define it, its our land that you want to dismantle, convert, and take so that you can build 45,000 homes, parks, and research and development.

The Orchard Supply Building on Clovis and Kings Canyon has sat empty for a number of years, that can be your research and development. You want to take our farmland, our livelihood, what feeds our families, our communities, for a bike trail, a park, a residential development to teach people to have a garden (who will teach them there is no guarantee that they will use it for such) all the while destroying the Prime Farmland we landowners have created destroying our way of life and country life. You will add 45,000 homes during a recession, a time when most cannot afford, thereby creating more empty houses.

You want to disrupt our way of life and destroy the farmland that we have just to build more homes that of 4 7
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most cannot afford. You want to help this community have your builders or developers lower the prices of their homes to sell those existing homes already built. Convert some of these developments/homes already in progress into mixed residential. Ag land should be the last thing we convert, land that currently feeds us. That salad you had for lunch, fruit, etc. came from one of us most likely.

We oppose the alternatives set forth in the EIR due to the type of land we are looking at as referred to in this report: Prime Farmland, Farmland of Statewide and Local Importance, Unique Farmland. Based on the impacts as listed above and based on viable alternatives, we request that you deny/oppose the EIR.

Furthermore, we oppose as this EIR shows that the plan is fiscally irresponsible and environmentally irresponsible. Finally, we request that the SEDA Plan be opposed and denied. If you review the Level of Significance as outlined in the EIR, we have listed below just a few that are classified as Significant and Unavoidable; therefore, for these reasons request you oppose and deny the City’s Plan and find another area or location in the City of Fresno for said projects. The impacts are significant and unavoidable.

Finally, we were informed and received in the mail, on July 21, 2023, the City’s flyer for the “Drop-In” meeting; the first meeting set for July 24, 2023, hosted by the City of Fresno. As you can see from the dates, this was three days before the first scheduled meeting. As I verbally stated and inquired about with the City during the July 24th meeting, what is a the meaning of a Drop-in meeting? Who decided to title this meeting as a Drop-In? To title it as such, is misleading and misrepresenting the intent of the City and purposes of said meeting. This title lacks transparency and is intended to misstate and mislead the purpose of an extremely important topic of discussion. It does little to ensure community/public attendance, involvement, participation and is a sure way to prevent and limit public input. This is an extremely important meeting that impacts the community of southeast Fresno, specifically the Fresno Southeast Property Owners (SEPO) and therefore, I believe was titled as such to limit the number of attendees and silence the opposition. Furthermore, Sontaya Rose from the Mayor’s office was in attendance and can confirm as well as other City representatives, the location picked for the first important meeting on July 24th lacked the capacity to hold the number of attendees, safely and comfortably, and posed a safety hazard in that it was about 105 degrees outside and there was no working AC inside said building thereby making it 110 degrees most likely inside with all the people in the building. As I stated on that date, I believe that was a safety hazard and put citizens at risk and compromised their health and well-being. Not one representative spoke to that and acknowledged that the first meeting should be rescheduled or some other remedy. The temperature inside the building added to the frustration felt by most of the members of the community. As I stated, this meeting labeled by the City is misleading, and a calculated manner in which to misrepresent, misstate, and divert the public’s attention to what it is in actuality and that is to take and change or convert land from the property owners. Should the meeting have been labeled annexation, eminent domain, town hall, any one of those trigger words the public at large would have a true understanding of what is occurring in the southeast area of Fresno and would understand the true discussions and importance of what is happening thereby enhancing attendance and opposition. Furthermore, I see no link for those to participate virtually due to a disability, medical necessity or some other personal reason. It was stated that the City would have one day assigned to a webinar. As you know, the topics of discussion can be convoluted and we the community would need time to research the Q&A dialogue that is provided to us therefore one day for those unable to physically attend is not enough. The public should not be limited to one day; we should all be afforded the same the ability to attend all meetings. Quite frankly, the information changes so frequently it would be in the best interest of the public to attend all meetings.

As such, in this regard, we strongly oppose. Furthermore, the meeting by the City on 7/24/23 was very unorganized and lacked structure and foundation as to the discussions and topics and the City ran out of comment cards in English—the space allowed for comments was minimal on such an important topic of discussion.
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I would also like to know why no representative of the County was in attendance at these meetings? A representative of the City was asked about annexing property and the City representative responded with the City would not annex. Please confirm the process for annexation and if not the City of Fresno, then please confirm the responsible agency. Please provide details on what grounds for annexation, the criteria or guidelines that must be met to annex property/land? If this response requires information from the County, I would ask that you direct City representatives to coordinate their response and work with the County of Fresno or any other agencies involved to get said information. I believe the City of Fresno when asked these types of questions it is their responsibility to answer in detail and they are required to be fully transparent and should be able to intelligently communicate if not their agency the appropriate agency involved and that would handle. To leave the response as simple as it’s not the City, is vague and intended to mislead the public. The City knows the answer to the question and to not provide a full response is intentional. It may not be the City’s responsibility to annex but if they know that it is the responsibility of another agency they should state as such.

I believe the SEDA homeowners/property owners have a right to know the following information. If there are costs associated with any of these requests, please confirm the amount or charges, in writing, prior to providing said information.
• Please provide the number of EIR’s that are submitted to the City of Fresno per calendar year; and how many are rejected or voted as unapproved; how many are submitted to LAFCo per calendar year, voted as unapproved or rejected and the bases/reason for said vote. • On April 25, 2023, an item went to the Fresno County Board of Supervisors, Agenda Item #8 regarding a variance application that falls within SEDA. During Mr. Assemi’s comments to the Board, he referred to having received a timeline from the Mayor on the project. Please confirm what that timeline was and if a copy can be provided electronically to the property owners should they wish to received; and please explain why a developer would have that information but not the property owners who would be negatively impacted by SEDA? When was the timeline (Assemi refers to in his comments) provided to him by the Mayor? When was this timeline provide to the property owners (SEPO) who will be impacted? If it has not been provided to the property owners, why? My household has not received a timeline from the Mayor nor was one provided to property owners at any drop-in meeting and to my knowledge a timeline has not been provided to property owners in any meeting thus far by the City of Fresno. Please confirm how many variances in the SEDA project area have gone through the process, what that process is, including how many have gone to the County of Fresno Board of Supervisors for vote and the vote result from the start of the project(s)/plan to present? • Please identify the land parcels, land and farmland in the SEDA project area that have been purchased by developers, date of purchase, names of builders, corporations, school district, water districts, and any other business organization, corporation or entity from the start of SEDA to present that have purchased. Please include the names, cross-streets, parcel numbers and any other identify factors of the land pending a sale, owned, purchased or sold. • Please provide the information on when the property sold or was purchased and include land, property that is pending sale/purchase.
• Please provide the members of our community, SEPO (Southeast Property Owners), with information on how much farmland/land is currently owned in Fresno County, CA by Darrius Assemi and/or Granville Homes and any other developers, builders or business organizations. of 6 7
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If this type of development continues, the lack of farmland to our community as well as the substantial loss of prime farmland is irrecoverable and factor in good farmland with irrigation resources such as ours, it is irrecoverable. Therefore, we strongly oppose the EIR and the SEDA development and ask that you deny and reject both in order to protect and preserve our homes and land.

The City of Fresno needs a boundary, do not grow it out here destroying the aesthetic rural southeast farmland.

Once the farmland is gone, it’s gone forever! Say NO to SEDA! Thank you.

David & Natalie Ortiz
Elijah Ortiz
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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-681
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx David, Natalie, and Elijah Ortiz (Third Letter) (ORTIZ 3) Response to ORTIZ 3-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 3, Clarification Regarding Previous Comments Received, in Section 2, Master Responses, of this document. Master Response 3 provides clarifying information related to the review of or response to any comments received on the previously circulated Draft PEIR and Partial Recirculated Draft PEIR, including comments incorporated by reference in the public comment period.

Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses.

Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

As discussed in Section 2, Project Description, of the Recirculated Draft PEIR, Mixed Residential districts support the Regional and Community Town Centers with a variety of medium- and higherdensity housing, including a diverse mix of attached and detached single-family and multi-family homes. No further response is required.

Response to ORTIZ 3-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-682 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to ORTIZ 3-3
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

Response to ORTIZ 3-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

As discussed in the Recirculated Draft PEIR, the proposed project is a policy-level document, and no site-specific development is proposed at this time. The potential impacts associated with farmland, air quality, water supply, and traffic and congestion are discussed in Section 3.2, Agricultural Resources and Forestry Resources; Section 3.3, Air Quality; Section 3.10, Hydrology and Water Quality; and Section 3.17, Transportation and Traffic, respectively. Each section also discusses the methodology for determining the significance of potential impacts under CEQA. No further response is required.

Response to ORTIZ 3-5
The comment is noted. As discussed in the Recirculated Draft PEIR, the proposed project is a policylevel document, and no site-specific development is proposed at this time. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area. No further response is required.

Response to ORTIZ 3-6
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please refer to Master Response 12, Clarifying Information on Wildfire Analysis, in Section 2, Master Responses. Master Response 12 elaborates on the methodology used in Section 3.19, Wildfire, of the Recirculated Draft PEIR. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-683
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to ORTIZ 3-7
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 3-8
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 3-9
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-684 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses.

Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 3-10
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to ORTIZ 3-11
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to ORTIZ 3-12
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-685
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

Response to ORTIZ 3-13
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

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From: Sheila Otteson
To: Adrienne Asadoorian
Subject: Email with previous version of letter re: SEDA EIR as requested Date: Monday, March 24, 2025 4:25:40 PM
External Email: Use caution with links and attachments
From:

Sheila Otteson
6927 East Lane Ave
Fresno CA 93727
Date: March 23, 2025
To:

City of Fresno
Planning and Development Planning
Attn: Sophia Pagoulatos, Planning Manager
2600 Fresno St
Fresno CA 93721
Subject:

Concerns About the SEDA Recirculated EIR
Dear Ms Pagoulatos,
I have several concerns about three SEDA EIR sections related to air quality.

EIR 3.3.4 Air Quality - air quality in Fresno and it’s surrounding areas is poor and often very bad. Moving in 45,000 homes, industry, business and vehicles will only worsen the air quality. Since moving to Fresno I experience the effects of poor air quality whenever quality measurements move into moderate and beyond by difficulty in breathing.

EIR 4-1 Impact AG-1 Farmland loss - Removing thousands of acres of farm land will reduce air quality. I suspect loss of sight lines to the beauty of the mountains has limited economic value to the members of the proposed community and its developers, I would miss then terribly. The views are good for the soul.

EIR 3.17 Transportation and Traffic— Vast increases in traffic, even bus traffic, will hugely impact air quality adversely. It is laughable that someone thinks That people will only drive 5 miles a day. Just look at Hwy 180 with cars packed in all lanes and slowing below 50 mph last week. the hwy and the extension of Kings Canyon Rd go through the middle of the town-let.

I hope the city planners will produce a more reasonable plan and correct the deficiencies in the EIR. As many urge, the city should look to improve existing open spaces and improve local areas so that people can live and work in a lovely Fresno and not pillage existing farmlands and seemingly open spaces in the country side.

Sincerely,
Sheila Otteson

OTTESON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-689
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Sheila Otteson (OTTESON)
Response to OTTESON-1
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please also refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

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From: Paola Rodriguez
To: LongRangePlanning
Cc: Miguel Arias
Subject: Concerns About the SEDA Recirculated EIR 4-2
Date: Monday, March 24, 2025 5:00:39 PM
External Email: Use caution with links and attachments
Paola Rodriguez, Humanics Alumni Ambassador@Fresno State 1040 S st, 93721 Fresno CA
03/24/25
City of Fresno
Planning and Development Department
Attn: Sophia Pagoulatos, Planning Manager
Dear Mr. Pagoulatos,
I am writing to express my concern about the SEDA Recirculated Environmental Impact Report, more specifically 4-2 Growth-Induced Impacts. If I am not mistaken this SEDA project exceeds our cities budget and our outstanding bond debt does not help our financial situation. SEDA relies on Fresno's rapid population growth without considering the community already inhabiting Fresno. The Department of Finance has shown Fresno will grow to just about 72,000 residents by 2035 not 226,000 residents like SEDA predicts. My main concern is who will pay for these homes?What will the city's Plan B be if bonds are granted and the project fails to make the bonds amount back?. Why has the council approved a new community in Fresno instead of working in our Downtown district and Tower area?.I say we can start to smooth roads and local grocery stores with fresh vegetables and fruits available for everyone in Fresno.

Sincerely,
Paola Rodriguez
--
Cell number: (559)-362-9340
Email: [email protected]
1 P. RODRIGUEZ

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RI

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-693
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Paola Rodriguez (P. RODRIGUEZ)
Response to P. RODRIGUEZ-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Please also refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

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From: Peter Smith
To: LongRangePlanning; Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nelson Esparza; Nick Richardson; Sarah Boren; Georgeanne White; Jennifer Clark; Andrew Janz; District1; District2; District3; District4; District5; District6; District7; Jerry Dyer
Subject: City plan for SE Fresno
Date: Sunday, March 23, 2025 4:40:02 PM
External Email: Use caution with links and attachments
City Officials,
As a resident and citizen, I am deeply concerned about the proposal to further sprawl Fresno via the Southeast Development Area Specific Plan. I thought it was agreed years ago that sprawl is not helpful. It diminishes air quality, uses more energy, and creates a bigger, more intense heat footprint in our sweltering Valley. The only people I can think of who sprawl serves is developers (seeking max profits) and the politicians who receive developer donations for granting favors like sprawl. Let’s not do this. It is morally suspect and environmentally irresponsible.

Further concerns are raised when I contemplate that if city money is going to new development sprawl, it will not be available for the neighborhoods that already exist. I drive up and down main thoroughfares in SE Fresno most days of the week and all roads are in need of repair. Is it a win that Chestnut between Cesar Chavez and Butler was resurfaced? Yes. Is it enough? Certainly not! Drive down Tulare, Maple, Chestnut, Cedar, First streets. All are plagued with rough roads and burgeoning potholes. Since new sprawl would entail new roads, that means funding for road repair in current SE Fresno will not happen. Unacceptable.

Current fire and police services are barely adequate for SE Fresno and sprawl will only add more burden to first responder resources. Fresno is not ready for more sprawl until it can show and sustain a healthy, vibrant, in-filled city where quality of life is excellent for all citizens on all sides of town. Once we have achieved that goal, then it might be possible to consider replicating that in expansion beyond the city limits. Put the SEDA plan on ice and prioritize the initiatives that make for good governance, not profit-chasing.

Thank you for taking these concerns seriously,
Peter Smith
3863 E Kerckhoff Ave
Fresno, CA 93702
559.270.4946
P. SMITH

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-697
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Peter Smith (P. SMITH)
Response to P. SMITH-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to P. SMITH-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: Annette Paxton
To: LongRangePlanning; Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; [email protected]; Nick Richardson; Nelson Esparza; Todd Stermer
Subject: [SUSPECTED SPAM] SEDA EIR Draft (Feb 7, 2025) Concerns Date: Friday, March 21, 2025 9:42:17 AM
External Email: Use caution with links and attachments
Dear Council Members Perea, Karbassi, Arias, Maxwell, Vang, Richardson and Esparza
City of Fresno Clerk Stermer
and Planning Manager Sophia Pagoulatos
The purpose of this letter is to address my concerns of the proposed SEDA project and its affect on my home since 1988. I am rather disappointed that the City of Fresno continues to spend money to coerce its residents to believe that annexation of the surrounding rural landscape is responsible land management. I wrote in opposition to the EIR Draft dated July 14, 2023. The letter was emailed and USPS mailed to all city council and county supervisor members as well as the City of Fresno’s clerk, planner and planning manager. Please note: I received only two responses to my letter. Both responses were personal telephone calls from gentlemen who respectively do not even represent my area: then Supervisor Sal Quintero and Council Member Garry Bredefeld.

I am a lifetime Fresnan. I have chosen to be educated in Fresno (Class of 1981 CSUFresno). I chose to stay in Fresno and to establish my career. I chose to raise my family in Fresno; I believe my children are “Fresno Proud.” I have always thought that I am a part of the fabric that makes Fresno special.

Below are several issues from the February 7, 2025, EIR that I believe need to be resolved:
1) Aesthetics, Light, and Glare (AES 3-4) -- Level of significance after mitigation remains significant and unavoidable impact -- please address how the mitigation measures will be enforced. As the crow flies, my home is 3-1/2 miles from Lamonica Stadium. Right now, I see “Friday night” lights from my backyard. How will the light pollution generated by the SEDA project will not be enforced when it’s not enforced now?
2) Agricultural Resources and Forestry Resources (AG 1-2; AG 5) -- Level of significance after mitigation remains significant and unavoidable impact -- please address why the agricultural soil in Fresno County is not valuable enough to be protected? Seventy-five percent of the SEDA project’s acreage involves destruction of prime farmland that is either of statewide or local importance. The soil in this particular region of Fresno County is the richest soil in the world -- the SEDA project paves right over it. These acres can not be recreated somewhere else. This soil PAXTON

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produces food for millions of people worldwide. Much like California’s coastline protections, this soil should be protected as well. Current growers are already pushed out and ag workers are displaced. Has the EIR calculated the loss of agricultural revenue and livelihood income? Please save our agricultural jewel. Don’t violate the Williamson Act.
3) Air Quality (AIR 1-3) -- Level of significance after mitigation remains significant and unavoidable impact -- please advise why every mitigation effort listed requires a multitude of bulleted items to enforce one area.There are no reliable measures other than the Valley Air District to monitor the expansion. I think it is silly to recommend that signage to monitor idling vehicles and hand brushing or a low pressure paint sprayer will maintain air quality -- how would this even be enforced? This entire mitigation section is a game of “smoke and mirrors.” Bottom line: the SEDA project will irreversibly affect air quality.
4) Greenhouse Gas Emissions (GHG 1-2) -- Level of significance after mitigation is now “N/A” -- please address the contradiction in the July 14, 2023, EIR Draft, which stated GHG 1-2 created significant and unavoidable impact, while the February 7, 2025 EIR Draft now states the level of significance is “N/A”. How can greenhouse gas emissions from a project that adds 45,000 homes on 9,000 acres while removing 75% of farmland (the “green belt” is farmland) not address greenhouse gas emissions? I consider this a severe oversight of the EIR and should be re-evaluated. 5) Hydrology and Water Quality (HYD 1-5) – Less than significant impact with mitigation incorporated -- please address why the mitigation measures can state “less than significant impact” to the current water quality and quantity issues in the central valley. Currently, there are huge water issues without the SEDA project. This expansion will only increase an already overtaxed system. Water regulations are constantly changing. The SEDA project’s expansion does not take into consideration next year’s water availability. Additionally, the EIR Draft does not address any changes to water delivery to current residents’ using well water. I consider this a severe oversight of the EIR and the city and county of Fresno. Any changes to my current water supply created by SEDA greatly changes the property value and my ability to live in my home.
6) Land Use and Planning (Cumulative Impact) -- The project would have a less than significant cumulative impact on land use and planning) -- I can not believe that there is “no significant cumulative impact on land use.” I do my best to be a steward of this land and air. I plant a small garden and share the fruit from my trees with my neighbors. I couldn’t do this type of living within the city’s limits, which is why I chose to live in a rural setting in the County of Fresno. The SEDA project will take away my privilege of living where I chose to live 35 years ago. I will no longer be able to afford to live in my home. This cost to be annexed will force me to leave. SEDA changes my property’s land use.
7) Wildfire (WILD 1-4) -- No mitigation measures offered -- please advise how SEDA’s mitigation measures would need to be altered when California has just experienced wildfires burning through communities like Pacific Palisades and PAXTON

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5 6
7 Altadena, CA. The SEDA project encourages new neighborhoods to be built similar to what was so easily destroyed by wildfire this January 2025. There needs to be a plan in place prior to approving any annexation.

I would like to close by asking why the City of Fresno chooses not to infill within its boundaries where infrastructure already exists? There are so many blighted areas in Fresno that are at risk of vagrancy, burning and vandalism. What is the cost of infrastructure for an annexation this large? Where does the City of Fresno intend to get the money? I haven’t seen any financial reports for the cost of this project or the revenue stream to create the project. I recommend that the City of Fresno do something bold and unconventional: rebuilt from within. I would think there are grant dollars available – specifically for rebuilding from within. Clean blighted areas. Stop city sprawl. Decrease the sphere of influence boundaries. Give all residents a reason to be Fresno Proud!
To City of Fresno officials: Stop the SEDA project.

To Fresno County Supervisors: Stand up and protect the citizens who elected you.

To everyone: Stop the unrelenting land grab and protect California’s unique central valley.

QUALITY OVER QUANTITY.

Sincerely,
Annette Paxton
7412 E Pine Avenue
Fresno, CA 93737
Cell: (559) 906-0718
[email protected]
PAXTON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-703
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Annette Paxton (PAXTON)
Response to PAXTON-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 3, Clarification Regarding Previous Comments Received, in Section 2, Master Responses, of this document. Master Response 3 provides clarifying information related to the review of or response to any comments received on the previously circulated Draft PEIR and Partial Recirculated Draft PEIR, including comments incorporated by reference in the public comment period.

Further, please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Please also refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

As described in Section 3.1, Aesthetics, Light, and Glare, of the Recirculated Draft PEIR, the proposed project would include increased development in the Plan Area, leading to increased light from streetlights, exterior lighting from buildings, and vehicle headlights, compared to the current rural and agricultural land uses. Although the proposed project would comply with applicable policies and requirements and implement MM AES-4a through MM AES-4e, which require shields to direct light away from light-sensitive uses and minimize spillover onto adjacent properties, as well as nonreflective building façades, impacts related to light and glare would remain significant and unavoidable.

Section 21081.6 of the California Environmental Quality Act (CEQA) and CEQA Guidelines Section 15097 require a Lead Agency to adopt a Mitigation Monitoring and Reporting Program (MMRP) whenever it adopts a Mitigated Negative Declaration (MND) or an Environmental Impact Report (EIR) in conjunction with a project approval. The purpose of the MMRP is to ensure compliance with the mitigation measures occurs during project implementation.

The PEIR prepared for the proposed project concluded that project implementation could result in potentially significant effects on the environment, and mitigation measures were incorporated into the proposed project or are required as a condition of project approval that reduce these potential impacts to a less than significant level. The MMRP documents how and when the mitigation measures adopted by the Lead Agency will be implemented and confirms that potential environmental impacts are reduced to less than significant levels as identified in the Recirculated Draft PEIR. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-704 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to PAXTON-2
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to PAXTON-3
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Section 21081.6 of the California Environmental Quality Act (CEQA) and CEQA Guidelines Section 15097 require a Lead Agency to adopt a Mitigation Monitoring and Reporting Program (MMRP) whenever it adopts a Mitigated Negative Declaration (MND) or an Environmental Impact Report (EIR) in conjunction with a project approval. The purpose of the MMRP is to ensure compliance with the mitigation measures occurs during project implementation.

The PEIR prepared for the proposed project concluded that project implementation could result in potentially significant effects on the environment, and mitigation measures were incorporated into the proposed project or are required as a condition of project approval that reduce these potential impacts to a less than significant level. The MMRP documents how and when the mitigation measures adopted by the Lead Agency will be implemented and confirms that potential environmental impacts are reduced to less than significant levels as identified in the Recirculated Draft PEIR. No further response is required.

Response to PAXTON-4
The comment is noted. As discussed in Section 3.8, Greenhouse Emissions, of the Recirculated Draft PEIR, the City utilizes the criteria in the CEQA Guidelines Appendix G Environmental Checklist to determine whether greenhouse emissions impacts are significant environmental effects. The vast majority of individual projects do not generate sufficient GHG emissions to create a project specific impact through a direct influence to climate change; therefore, the issue of climate change typically involves an analysis of whether a project’s contribution toward an impact is cumulatively considerable. As defined in the CEQA Guidelines, Section 15355, “cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects. For future projects, the significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds, or consistency with a regional GHG Reduction Plan (such as a CAP).

The City of Fresno developed its first GHG Plan in 2014, which includes GHG reduction targets and emissions inventories for the years 2020 and 2035. An updated GHG Plan (the GHG Plan Update) was adopted on September 30, 2021, pursuant to a certified General Plan Program EIR (State City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-705
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Clearinghouse Number 2019050005). However, in 2024, following a legal challenge, the 5th District Appellate Court rejected the City’s PEIR and GHG Plan Update. Both were rescinded pursuant to a Court order. The City’s previously adopted GHG Reduction Plan (2014) has not been the subject of a legal challenge and has not been invalidated by the court. As stated, the 2014 GHG Plan includes reduction targets for 2035; however, the full 25-year buildout of the proposed project goes beyond the year 2035 and is anticipated to be fully operational in the year 2050. Therefore, this analysis will evaluate the consistency of the proposed project with ARB’s latest 2022 Scoping Plan, including the proposed project’s consistency with relevant Scoping Plan measures and the latest RTP/SCS for the region within which the Plan is located. The 2022 Scoping Plan is consistent with the State’s longerterm AB 1279 GHG reduction targets of achieving carbon neutrality by 2045 and reducing GHG emissions to 85 percent below 1990 levels by 2045. Therefore, consistency with the 2022 Scoping Plan would also demonstrate consistency with the State’s long-term GHG reduction targets encapsulated by AB 1279.

The analysis contained within Section 3.8, Greenhouse Gas Emissions, of the Recirculated Draft PEIR provides a qualitative assessment of the proposed project’s compliance with the applicable plans, policies and regulations for the purposes of reducing GHG emissions to determine whether the proposed project would have a significant impact on the environment relative to GHGs. The comment does not identify a legitimate basis for recirculation, and as such, no further response is required.

Response to PAXTON-5
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Additionally, please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

Response to PAXTON-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-706 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to PAXTON-7
The comment is noted. Please refer to Master Response 12, Clarifying Information on Wildfire Analysis, in Section 2, Master Responses. Master Response 12 elaborates on the methodology used in Section 3.19, Wildfire, of the Recirculated Draft PEIR. No further response is required.

Response to PAXTON-8
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

POTTER

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March 13, 2025
City of Fresno
Planning & Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, CA 93 721
Dear Ms. Pagoulatos,
Re: SEDAEIR, Sec3.17-5
I am writing this letter for two reasons. First to express opposition to the annexation proposed in the ~OUTHEAST AREADEVELOPMENT AREA(SEDA), previously known as the SOUTHEAST GROWTH AREA (SEGA), and second to express my opposition to the acceptance of the ENVIRONMENTAL IMPACT REPORT (EIR) currently under consideration.

Because I am not an expert, I began reading the EIR with something I am familiar with. I saw Temperance Avenue at the top of page 3.17-5, so I started reading. My question; 'HOW

CAN A DOCUMENT THAT WILL SO GREATLY AFFECT PROPERTY OWNERS IN

FRESNO COUNTY HAVE SUCH A GROSSLY ERRONEOUS STATEMENT AS THE ONE REGARDING TEMPERANCE AVENUE'?
Temperance Ave. is designated throughout as a "SUPER ARTERIAL". This is described as a 4, 5, or 6 lane road with a raised median.

It is described on page 3.17-5 as a four lane north-south arterial with an interchange at SR-180. Land adjacent to Temperance Avenue consists mostly of farmland, and the road becomes a two-lane facility south of Hamilton Avenue. The speed limit along Temperance Avenue is 40 mph.

Apart from the four lane at SR-180, nothing of the above is factual.

Temperance Avenue is a Super Arterial as defined from Shields Avenue north to Dakota Avenue. South of Shields Avenue to the four lane approaching SR-180 it is a two lane.

South of Kings Canyon it becomes a three lane for a short period before returning to a two lane. It is not largely farmland, it is largely rural residential.

The speed limit along Temperance Avenue is never 40 mph, It varies along its length from 45 mph to 55 mph.

Every scenario for the road that has been previously presented by the city has shown it as being upgraded to a six lane with raised median, a raised median to frontage roads and pedestrian walkways. This is in the city's General Plan. We attended a city meeting at Boris Elementary School on this subject.

In no way does this coincide with any description found in the Em.

POTTER

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If this is an example of the accuracy to the BIR as a whole, I think it calls into question the entire BIR Especially since it would be so easy to accurately describe a single road.

The BIR says the speed limit on Jensen Avenue is 45 mph. In fact, through the plan area, the speed limit is 55 mph. It was, until recently 65 mph.

These may be small errors but they are indicative of poor research, possibly even research that has never been actual on-site research. Such sloppiness in one area will likely be evident in other areas and calls into question the accuracy and validity of the entire BIR. Also, perusing the full report, one finds page after page of repetitive language that seems carefully crafted to actually say nothing. A classic case of boilerplate that has probably been used in many other reports.

This is certainly not the work of a report that actually took years and thousands of dollars to prepare.

I feel strongly that it would be foolish to accept this BIR because of its demonstrable errors and faulty research.

Why is this important? Because this is base or background upon which policy and implementation are built. The end product is never any better than the foundation on which it is built.

Thank you,
Ross & Marie Potter
1598 N. Temperance Ave.

Fresno, CA 93727
559-252-2085
CC: Annalisa Perea, Dist. 1
Mike Karbassi, Dist. 2
Miguel Arias, Dist. 3
Tyler Maxwell, Dist. 4
Elected Member, Dist. 5
Nick Richardson, Dist. 6
Nelson Esparza, Dist. 7
Todd Stermer, City Clerk
City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-709
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Ross and Marie Potter (POTTER)
Response to POTTER-1
The comment is noted. It recommends revisions that were already made in the Recirculated Draft PEIR. No further response is required.

Response to POTTER-2
The comment is noted. It recommends revisions that were already made in the Recirculated Draft PEIR. No further response is required.

Response to POTTER-3
The comment is noted. It recommends revisions that were already made in the Recirculated Draft PEIR. No further response is required.

Response to POTTER-4
The comment is noted. It recommends revisions that were already made in the Recirculated Draft PEIR. No further response is required.

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From: Jerry Prieto
To: LongRangePlanning
Subject: Fw: Comments On the City of Fresno-Southeast Development Area Specific Plan Project Recirculated Draft Program EIR
Date: Thursday, March 20, 2025 10:34:18 PM
External Email: Use caution with links and attachments
From: Jerry Prieto
Sent: Thursday, March 20, 2025 10:27 PM
To: [email protected]
Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Subject: Comments On the City of Fresno-Southeast Development Area Specific Plan Project Recirculated Draft Program EIR
Hello, my name is Jerry Prieto Jr. My wife Cynthia and I own and operate Red Bank Ranch, a small family farm consisting of 8.9 acres. In addition, we lease 4 additional acres from our neighbors. Our address is 2517 N. DeWolf Avenue. The following are our comments on the subject EIR.

Section 3.2 Agricultural Resources and Forestry Resources Question: Why is the EIR excluding the use of pesticides in farming practices? Organic farming does not mean that pesticides are not used. There are many pesticides that are registered for use on organic crops. The California Department of Pesticide Regulation has the sole authority to regulate both the registration and use of pesticides. This is accomplished at the local level through the County Agricultural Commissioner.

Section 3.4 Biological Resources
Question: How will the Red Bank Slough be protected from development or encroachment including the establishment of trails? This slough is one of the last remaining riparian creeks in close proximity to Fresno. It is home to Red Tail hawks, Cotton Tail rabbits, Grey Fox, California Kingsnake, Coyotes, Gopher Snake, Red Wing Blackbird, Black Backed woodpecker; Flicker woodpecker; Gilbert's Skink, Opossum, Raccoon, Valley Elderberry, Western Pond turtle and numerous bird species. These are species that I have observed in the slough over the last 23 years.

Section 3.10 Hydrology and Water Quality
Question: Why is the City of Fresno proposing to charge farmers and ranchers a recharge fee for well water that is extracted to irrigate their crops and domestic use? The Fresno Irrigation 1 2
3 PRIETO 1

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District supplies surface water to these farmers and ranchers that is applied to crops. Some of this water finds its way to the aquafer which becomes a benefit to the City. In addition, the farmers and ranchers have an overlying right to the groundwater beneath their property and Fresno City may not have the authority to assess the recharge fee. It may be appropriate to restrict the amount of extracted water should the North Kings Groundwater Sustainability Agency establish extraction allotment restrictions.

Section 3.18
Question: Will there be any exception for existing rural residential properties to the sewer connection mandate? I have been informed that the cost for the connection must be borne by the property owner and that the cost is estimated to be $50,000 for homes located near the street. The homes on some of these properties are located at the back of their property which can make the connection cost prohibitive. My home is 700 feet from the street and if a sewer line is within 300 feet of my property line I will be required to connect to that point! This seems very unreasonable.

Thank you for the opportunity to comment on the EIR.

Jerry Prieto Jr.

Red Bank Creek Ranch
2517 North DeWolf Avenue
Fresno CA 93737
3 CONT
4 PRIETO 1

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-713
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Jerry Prieto (First Letter) (PRIETO 1)
Response to PRIETO 1-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to PRIETO 1-2
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

As noted in Master Response 5, the proposed project is a policy-level document and does not propose any specific site development at this time. Future development associated with the proposed project would be required to undergo CEQA analysis on a project-by-project basis as necessary. As further detailed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR, future development associated with the implementation of the proposed project would be required to implement MM BIO-1a through MM BIO-1d, MM BIO-2a through MM BIO-2c, and MM BIO-3a through MM BIO-3b, as applicable, to reduce potential impacts to wetlands, riparian habitat or sensitive natural communities, and any special-status species. No further response is required.

Response to PRIETO 1-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

Response to PRIETO 1-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-714 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

From: Jerry Prieto
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer; Jerry Dyer
Subject: AMENDED Comments On the City of Fresno-Southeast Development Area Specific Plan Project Recirculated Draft Program EIR
Date: Friday, March 21, 2025 3:22:48 PM
External Email: Use caution with links and attachments
Hello, my name is Jerry Prieto Jr. My wife Cynthia and I own and operate Red Bank Creek Ranch, a small family cattle ranch consisting of 8.9 acres. In addition, we lease 4 additional acres from our neighbors. Our address is 2517 N. DeWolf Avenue, Fresno, CA, 93737. The following are our amended comments on the subject EIR. Original comments were submitted 3/20/25 at 10:34 P.M.

Section 3.2 Agricultural Resources and Forestry Resources Question: Why is the EIR excluding the use of pesticides in farming practices? Organic farming does not mean that pesticides are not used. There are many pesticides that are registered for use on organic crops. The California Department of Pesticide Regulation has the sole authority to regulate both the registration and use of pesticides. This is accomplished at the local level through the County Agricultural Commissioner.

Section 3.4 Biological Resources
Question: How will the Red Bank Slough be protected from development or encroachment including the establishment of trails? This slough is one of the last remaining riparian creeks in close proximity to Fresno City. It is home to Redtail hawk, Cotton Tail rabbit, Grey Fox, California Kingsnake, Coyote, Gopher Snake, Red Wing blackbird, Blacked Backed woodpecker, Flicker woodpecker, Gilbert's skink, Opossum, Raccoon, Valley Elderberry, Western Pond turtle and numerous bird species. Theses are species that I have observed in the sough over the last 23 years.

Section 3.10 Hydrology and Water Quality
Question: Why is the City of Fresno proposing to charge farmers and ranchers a recharge fee for well water that is extracted to irrigate their crops and for domestic use? The Fresno Irrigation District supplies surface water to these farmers and ranchers that is appplied to crops. Some of this water finds its way to the aquafer which becomes a benefit to the City. In addition, the farmers and ranchers have an overlying right to the groundwater beneath their property and Fresno City may not have the authority to assess the recharge fee. It may be appropriate to restrict the amount of extracted water should the North Kings Groundwater Sustainability Agency establish extraction allotment restrictions.

Section 3.18
PRIETO 2

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1 Question: Will there be any exception for existing rural residential properties to the sewer connection mandate? I have been informed that the cost for the connection must be borne by the property owner and that the cost is estimated to be $50,000 for homes located near the street. The homes on some of these properties are located at the back of their property which can make the connection cost prohibitive. Our home is 954 feet from the street and if a sewer line is within 300 feet of my property line I will be required to connect to that point! This seems very unreasonable.

Thank you for the opportunity to comment on the EIR.

Jerry Prieto Jr.

Red Bank Creek Ranch
2517 North DeWolf Avenue
Fresno, CA, 93737
PRIETO 2

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-717
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Jerry Prieto (Second Letter) (PRIETO 2)
Response to PRIETO 2-1
The comment is noted. This comment letter is a duplicate of PRIETO 1. Please refer to Response to PRIETO 1-1 through Response to PRIETO 1-4. No further response is required.

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From: Tim Pritchard
To: LongRangePlanning; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer; Annalisa Perea
Subject: [WARNING: UNSCANNABLE EXTRACTION FAILED]South East Property Owners Date: Wednesday, March 19, 2025 5:53:57 PM
External Email: Use caution with links and attachments
Anaxation is not what tax payers in this area want. The people in this area want to reside in the county. We don't want to be part of home congestion, crime heavy, city traffic, homeless camps. We are still in a drought and increasing the population will severely affect the water supply.

PRITCHARD

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-721
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Tim Pritchard (PRITCHARD)
Response to PRITCHARD-1
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

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From: Mary Ann Quann
To: LongRangePlanning
Subject: SEDA comments
Date: Sunday, March 16, 2025 9:26:09 AM
External Email: Use caution with links and attachments
I'm opposed to continuing with the SEDA plans. I don't see that encouraging infill projects and addressing current infrastructure needs in Fresno is being addressed.

Mary Ann Quann M.D.
2607 W Stuart Ave
Fresno, CA 93711
QUANN

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-725
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Mary Ann Quann (QUANN)
Response to QUANN-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

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From: Rhonda Dueck
To: LongRangePlanning; Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nelson Esparza; Nick Richardson; Jerry Dyer; Sarah Boren; Georgeanne White; Jennifer Clark; Andrew Janz; District1; District2; District3; District4; District5; District6; District7
Subject: VOTE NO on SEDA!!
Date: Sunday, March 23, 2025 10:26:46 PM
External Email: Use caution with links and attachments
Dear Fresno City Leaders,
As Fresno city leaders you are called to make decisions that are for the common good of our One Fresno.

The city of Fresno has a history or poor planning and poor decision making for development often due to significant pressure and promises from developers who often contribute towards election campaigns. This might seem like it is hidden, but the truth is that we can see this happening. It is obvious. This can stop now. Poor choices in the past do not need to continue. Please be people of integrity who make decisions that are best for Fresno - for now and into the future.

The SEDA project does not make good sense for our city as a whole for many reasons and I will highlight just a few here.

1. The research and investigation into the environmental impacts is insufficient and incomplete. This study needs to be expanded and completed so the implications are clear.

The results need to be made public and easily accessible and written to make sense to the common citizen.

2. The actual cost for infrastructure including sidewalks, sewers, lights, roads, fire station, police patrols, etc. needs to be accounted for in extensive and detailed lists and given real numbers. My understanding is that some estimates only included some of the services required in order to make the numbers more acceptable. Deceiving the public is not acceptable!

3. There is only so much money for the city to spend to keep infrastructure working and appropriately repaired. If a new housing development is going to be developed where the infrastructure does not currently exist, it means there will not be as much, if any, money available for the areas of the city where there are already homes, businesses, and schools in existence. Our current neighborhoods are desperate for upgrads and repairs. The number of reports the GOFresno receives everyday is plenty to keep our city workers busy and budget used.

4. We are lacking in efficient and sufficient public transit in the city of Fresno and expanding the city bounds will require expanding this route without significant funding available which will only make the system worse. We need to rather spend money to expand the current routes to run more often and to more places within the city limits already developed.

5. We can all agree that additional housing is needed in Fresno, but the estimates that are being used to justify this development are out of sync with estimates from those who are R. DUECK

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studying these trends closely. Also, we need affordable housing that are going to help people be closer to shopping, school, and jobs. Increasing city sprawl will not help this. Let’s rather give incentives for contractors to build in the infill spaces available so that we can use the space available that already have the existing infrastructure attached to it.

6. The downtown of a city is a reflection of the priorities and vitality of the city. The further from downtown we build and develop, the less focus and resources we will have for downtown. It seems often when there are resources reserved to focus on downtown, they get reallocated to another project further out, thus increasing the decline of our city center.

Energy and resources must be focused on downtown for revitalization for the good of our city.

I am passionate about Fresno and take great pride in living here. The decisions that you make about SEDA will impact Fresno for many years to come. Please do not make this decision lightly and do not be influenced by your political ambitions that allow people to negotiate with you in ways that benefit them, rather than our city. Rather, make the right decision that is best for Fresno. Our future is depending on you to lead well!! Thank you for your time,
Rhonda Dueck
photo
photo Rhonda Dueck
Executive Director
Jackson Community Development Corporation
559-709-3132
[email protected]
jacksoncdc.org
EMPOWERED RESIDENTS = THRIVING COMMUNITY
R. DUECK

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6 I ~ I
L_.-----_ --~=-------
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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-729
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Rhonda Dueck (R. DUECK)
Response to R. DUECK-1
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to R. DUECK-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to R. DUECK-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to R. DUECK-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to R. DUECK-5
The comment is noted. Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Additionally, please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to R. DUECK-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: Cindy Ramsey
To: LongRangePlanning
Cc: Nelson Esparza; Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Todd Stermer Subject: Recirculated SEDA EIR 2025
Date: Monday, March 24, 2025 8:42:59 AM
External Email: Use caution with links and attachments
To: [email protected]
With copy to:

Annalisa Perea:
[email protected]
Mike Karbassi:[email protected]
Miguel Arias:[email protected]
Tyler Maxwell:[email protected]
Nick Richardson:[email protected]
Nelson Esparza:[email protected]
Todd Stermer:[email protected]
Date: March 24, 2025
Re: Draft Recirculated Program Environmental Impact Report Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California (the “EIR”) and SEDA Southeast Development Area Specific Plan Draft (the “SEDA Plan”) Dear Sophia Pagoulatos, Planning Manager, Planning and Development Department, City of Fresno:

I am writing this letter in reference to the EIR and SEDA Plan. After reviewing all of this information for quite some time now, it is clear that the best interest of the citizens of Fresno is not in mind. It clearly leans towards unethical expansion and not logical in fill and revitalization of a city that could use support in neglected areas. Instead valuable farmland and generationally owned land parcels are being stripped away little by little to create cheap and fast new builds by greedy developers. It would be good to know that our politicians and city officials have our backs on this disaster of a plan and are willing to respond to us with logical and intelligent solutions that support the growth of the city without annialating the last of our rural residential farmland. I humbly ask that all of you reply to the below question and concerns:

1. On ES-2 under Quantified Objectives, the EIR states that its objectives are to accommodate 40,000 - 45,000 dwelling units with only 30,000 - 37,000 jobs as per Chapters 3.14 and 2.3 respectively. What is the rationale on building more houses than actual jobs for people? How will future residents be able to buy a home here without enough jobs to accommodate the same number of dwelling units?

2. On ES-2 under Fiscal Responsibility, the EIR states that the SEDA Plan will provide self-financing for the development and ongoing maintenance while not reducing the City of Fresno’s resources already dedicated to the City while not burdening residents outside of the SEDA however the cost of the SEDA Plan and the self-financing thereof is not listed anywhere with the EIR nor the SEDA Plan. How much is the SEDA Plan expected to cost and what is the cost of self-financing? If the cost of the SEDA Plan will not burden residents outside of the SEDA, how does the City of Fresno plan on burdening the residents inside the SEDA and at what costs? How much will SEDA residents’ taxes increase?

3. Under the same page and section (ES-2, Fiscal Responsibility) and in regards to Chapters 3.11 and 3.18, why isn’t the City of RAMSEY

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Fresno considering the renovation and adaptive reuse of existing structures since this is typically much less expensive than large-scale new construction. The City of Fresno could prioritize retrofitting underutilized spaces instead of spending millions, if not billions, on new infrastructure, utilities (including water, sewer and power), and roads.

4. On ES-2 under Social Equity, the EIR states that the SEDA Plan will promote health by reducing harmful emissions from cars and industry in Chapter 3.8 (Greenhouse Gas Emissions), but how can the SEDA Plan accomplish this during the building phase with all of the emissions from building equipment, subsequent air pollution, hazardous materials, etc.? What steps will be taken and upheld to ensure the safety of residents, workers and wildlife? Prolonged exposure to fine particulate matter and diesel exhaust has been linked to an increase in heart attacks, strokes, and other cardiovascular conditions. What is the City of Fresno going to do to mitigate this exposure?

5. On ES-5 under Impact AG-2 which refers to Chapter 3.2 (Agricultural Resources and Forestry Resources) of the EIR, it states that the SEDA Plan includes land under the Williamson Act and convert it to non-agricultural uses without any mitigation to reduce it to less than significant which contradicts the purpose of this program. Please provide details on how the City of Fresno plans to pay for the monetary penalties of up to 25% of the market value of the land plus 25% of the value of any incompatible improvements? Will SEDA residents’ taxes be used to pay for these penalties?

6. In reference to Chapter 3.10 (Hydrology and Water Quality), what is the budget for the stormwater systems, water supply, altering the existing drainage patterns, capturing the substantial increase in runoff and building additional areas/sources for capturing additional flood water?

7. Where is the City of Fresno planning on getting the millions of gallons of water required to build 40,000-45,000 dwelling units as per Chapter 3.10 (Hydrology and Water)?

8. On page 2-18 and in reference to Chapter 3.17 (Transportation and Traffic), the EIR states that the City of Fresno will provide “high quality transit service” without any information on how this will be accomplished. What the budget is for such high quality transit service? Please provide the environmental impact report for such transit service? A blank check is unacceptable and such questions must be addressed prior to approval.

9. How does the City of Fresno plan on acquiring and funding the necessary resources of adding additional police, fire, ambulatory and other emergency and protective services to accommodate the additional population and increase of businesses and other infrastructure to not only maintain, but reduce both crime and response time to emergencies based on the proposed SEDA Plan (referencing Chapter 3.15 (Public Services))?

10. How much money or other financial and non-financial kickbacks are you, all those copied herein and other city officials receiving from land developers, builders, contractors, corporations, etc. to get the SEDA Plan approved?

11. With reference to Chapter 3.9 (Hazards and Hazardous Materials), what is the City of Fresno’s plan to prevent public and environmental hazards caused by accidents involving the release of hazardous materials into the environment both in the air and water? What is the City of Fresno’s plan to mitigate the increase in construction waste in our landfills?

12. Referencing Chapter 3.2 (Agricultural Resources and Forestry Resources), the proposed plan will permanently convert thousands of acres of Prime Farmland and Farmland of Statewide Importance into non-agricultural uses, with no feasible mitigation to preserve this essential resource. What is the City of Fresno doing to preserve this fundamental resource and at the very least mitigate this issue? Why isn’t the City of Fresno considering focusing on urban infill development, instead of destroying farmland, in an effort to preserve Fresno’s farmland and agricultural economy and maintain food production stability?

13. Referencing Chapter 3.3 (Air Quality), the SEDA Plan will generate significant criteria air pollutants during construction and operation, exceeding San Joaquin Valley Air Pollution Control District (SJVAPCD) thresholds. Mitigation measures cannot fully reduce these emissions and this needs to be addressed by the City of Fresno since we have been working to reduce the pollution for the last twenty years and just within the last decade we have finally seen an improvement where we can actually see the surrounding mountains. The SEDA Plan could reverse all those efforts. Please detail how the City of Fresno would address the following in regards to air quality:
- air pollution and respiratory issues due to the increase emissions of particulate matter, ozone, nitrogen dioxide and diesel particulate matter, all of which are linked to asthma, bronchitis and lung cancer. - exposure to Toxic Air Contaminants that have been linked to severe illnesses including leukemia

14. One of the SEDA Plan’s goals is to reduce vehicle miles traveled (see pages 6, 12, 25, 33, 64, 78 and 110 in accordance with Chapters 3.14 and 3.17). However, per the SEDA plan, only 37,000 jobs are estimated to be created with 40,000-45,000 dwelling units to be built. How can the SEDA Plan accomplish a reduction in vehicle miles travelled when (at the absolute least, assuming 1 person per household) a minimum of 8,000 people (difference between 45,000 dwelling units and 37,000 jobs created) will have to travel outside of the plan area to commute to their jobs when more and more companies are implementing a return to office policy? Additionally if people must travel outside of the plan area, this leads to increased vehicle emissions and traffic resulting in higher rates of health issues (respiratory and cardiovascular diseases) due to prolonged exposure to vehicle exhaust.

A very concerned SE property owner,
Cindy Ramsey
RAMSEY

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-733
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Cindy Ramsey (RAMSEY)
Response to RAMSEY-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR.

Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

Response to RAMSEY-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

Response to RAMSEY-3
The comment is noted. As discussed in Section 3.3, Air Quality, of the Recirculated Draft PEIR, the proposed project has the potential to exceed the SJVAPCD’s significance thresholds during construction and operation. Full build out of the proposed project would result in the generation of substantial long-term criteria air pollutant emissions that would exceed the SJVAPCD regional significance thresholds and would therefore not be considered consistent with the existing AQPs.

MM AIR-1a, MM AIR-1b, MM AIR-1c, and MM AIR-1d would serve to reduce construction and operation-phase criteria air pollutant emissions; however, the mitigation measures would not reduce emissions to less than significant levels. Applicable SJVAPCD rules and regulations in addition to the proposed project’s policies and design guidelines would contribute to reducing long-term criteria air pollutant emissions to the extent feasible. However, due to the magnitude and intensity of development accommodated by the proposed project, impacts would remain significant and unavoidable.

As noted above, the proposed project is a policy-level document and does not propose any specific site development at this time. Future development associated with the proposed project would be required to undergo CEQA analysis on a project-by-project basis as necessary. As such, the mitigation measures identified above require future development in Plan Area to provide technical analyses as part of the project environmental review for construction, operational, and health impacts and mitigate the identified impacts in those technical studies to the greatest extent possible. The City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-734 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx mitigation measures also include potential mitigation strategies for future development to utilize to reduce air quality impacts. Future development in the plan area will still have to go through the appropriate level of environmental review where impacts to air quality will be evaluated against the suggested significance thresholds in Appendix G to the CEQA Guidelines, which is the City’s standard practice.

Additionally, please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Please also refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to RAMSEY-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Please also refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to RAMSEY-5
The comment is noted. Please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

Response to RAMSEY-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-735
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to RAMSEY-7
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to RAMSEY-8
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to RAMSEY-9
The comment is noted.

Hazards and Hazardous Materials
Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Additionally, as detailed in Section 3.9, Hazards and Hazardous Materials, of the Recirculated Draft PEIR, future discretionary projects would be required to implement MM HAZ-2a through MM HAZ2h to reduce potential impacts related to the reasonably foreseeable upset or accident conditions involving the likely release of hazardous materials into the environment. MM HAZ-2a through MM HAZ-2b include the requirement to conduct a Phase I Environmental Site Assessment (Phase I ESA), agency coordination, and remediation, as applicable.

Solid Waste
As detailed in Section 3.18, Utilities and Service Systems, new residential, commercial, mixed use, and public land uses in the Specific Plan Area would increase the amount of solid waste generated by residents and businesses. The increase in growth and development as a result of the implementation of the proposed Specific Plan would result in an increase of solid waste to transfer stations and landfills and contribute to an increased demand for solid waste services throughout the Plan Area.

Based on the estimated closure dates of the American Avenue Landfill in 2031 and the Clovis Landfill in 2047, there is a potential for additional landfill capacity needed to accommodate the additional development from this Specific Plan. Therefore, development under the proposed Specific Plan could result in a significant impact on landfill capacity. Implementation of the proposed plan would result in a total buildout of approximately 45,000 dwelling units and over 3,000 acres (130+ million square feet) of mixed use, commercial, office, retail, public, and open spaces throughout the Specific Plan Area. The proposed increase in development would result in a long-term increase in solid waste generation with each new land use.

To reduce the significant impacts associated with the solid waste disposal, the City will need to increase disposal capacity. The policies in the General Plan are designed to reduce the potential City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-736 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx effect associated with solid waste disposal including those associated with the proposed Specific Plan. The City is responsible for evaluating additional landfill locations to ensure adequate landfill capacity for future development, and MM UTIL-4 requires that the City shall not approve development that could contribute solid waste to a landfill that is at capacity until such additional capacity has been provided. All future development under the Specific Plan would be required to comply with State and local requirements for reduction of solid waste going to landfills. No further response is required.

Response to RAMSEY-10
The comment is noted. Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please also refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to RAMSEY-11
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

As discussed in Section 3.3, Air Quality, of the Recirculated Draft PEIR, the proposed project has the potential to exceed the SJVAPCD’s significance thresholds during construction and operation. Full build out of the proposed project would result in the generation of substantial long-term criteria air pollutant emissions that would exceed the SJVAPCD regional significance thresholds and would therefore not be considered consistent with the existing AQPs. MM AIR-1a, MM AIR-1b, MM AIR-1c, and MM AIR-1d would serve to reduce construction and operation-phase criteria air pollutant emissions; however, the mitigation measures would not reduce emissions to less than significant levels. Applicable SJVAPCD rules and regulations in addition to the proposed project’s policies and design guidelines would contribute to reducing long-term criteria air pollutant emissions to the extent feasible. However, due to the magnitude and intensity of development accommodated by the proposed project, impacts would remain significant and unavoidable.

As noted above, the proposed project is a policy-level document and does not propose any specific site development at this time. Future development associated with the proposed project would be required to undergo CEQA analysis on a project-by-project basis as necessary. As such, the mitigation measures identified above require future development in Plan Area to provide technical analyses as part of the project environmental review for construction, operational, and health impacts and mitigate the identified impacts in those technical studies to the greatest extent possible. The City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-737
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx mitigation measures also include potential mitigation strategies for future development to utilize to reduce air quality impacts. Future development in the plan area will still have to go through the appropriate level of environmental review where impacts to air quality will be evaluated against the suggested significance thresholds in Appendix G to the CEQA Guidelines, which is the City’s standard practice.

Additionally, please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area. No further response is required.

Response to RAMSEY-12
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR.

Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

THIS PAGE INTENTIONALLY LEFT BLANK
From: [email protected]
To: LongRangePlanning
Cc: District1; District2; District3; District4; District5; District6; District7; [email protected]; [email protected]; [email protected]; [email protected] Subject: Comments on Recirculated Draft PEIR for Fresno Southeast Development Area Specific Plan Project - Mark and Dale Reitz
Date: Monday, March 17, 2025 11:26:20 AM
Attachments: Comments to Recirculated Draft PEIR_SEDA Reitz 3-15-2025 Final.pdf External Email: Use caution with links and attachments
Attached are our comments to this Recirculated Draft PEIR for Fresno Southeast Development Area Specific Plan Project per the Notice of Availability dated February 7, 2025.

We appreciate your work and look forward to successful adoption of the Alternative 2, Consolidated Business Park Alternative as requested in our letters and past discussions with you and at the neighborhood meetings.

Please keep us on your list for notifications of further responses to comments and upcoming meetings.

Thank you,
Mark and Dale Reitz
[email protected]
[email protected]
REITZ

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1 City of Fresno March 15, 2025
Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, CA 93721
Email: [email protected]
Comments on Recirculated Draft Program EIR for Fresno Southeast Development Area Specific Plan Project
State Clearinghouse Number 2022020486 Comments by Mark Reitz and Dale Reitz We would like to congratulate and thank the city of Fresno for their work in preparing this significant document and moving towards adoption of a Specific Plan for the Southeast Development Area that has been discussed and anticipated since 2007. As long-time property owners of a family home and farm within this area for over 100 years at 1080 S. Temperance (east of Temperance between the Railroad and Church Avenues), we and our neighbors welcome the opportunity to provide input to this Plan and hopefully provide local perspective to responsible growth and for the benefit of the city of Fresno for years to come.

We have watched the city grow to the southeast over the past 50 years, and we are excited for a well-planned and responsible expansion of Fresno. Currently, there are three new major residential subdivisions directly across the street from our farm property on Temperance Ave as well as a new Sanger Unified High School at Jensen and Fowler and a planned new elementary school on the west side of Temperance Avenue just eighth of a mile south of our property.

We and our neighbors have attended numerous planning meetings and public presentations.

We have offered our written recommendations and alternative maps regarding land use planning in our area going back to 2007. These documents have been passed on to various members of the Fresno Planning Department staff who have been very gracious in reviewing them and providing further direction for us on how we should submit our recommendations and input. We were essentially told to follow the development of this PEIR and to provide our input to the original land use map that was proposed back in 2006 (almost 20 years ago) and no changes would be made to it during this preparation period and that we need to provide our input to the City Planning Department and to the Planning Commission and City Council during the adoption period.

Below are a few of the justifications we presented in our prior letters and documents for relocating a portion of the Land Use Plan Area bounded by Temperance Ave. to the west, REITZ

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2 Church Ave. to the south, the Briggs Canal to the east, and the Railroad to the north, from Flexible Research and Development/Regional Business Park to a mixture of Community Center, Mixed Residential, and Neighborhood Residential. We request this change or some version of it for the reasons outlined in the documents previously submitted and summarized below. Also, considering there is a serious shortage of housing in Fresno and California this change should be desirable.

The Sanger Unified School District has recently purchased and zoned a 15-acre parcel on the west side of Temperance about midway between the Railroad and Church Ave. This school as well as the new High School at Jensen and Fowler Avenue would benefit by having more residential homes and apartments closer to these schools to reduce car miles driven and allow walking to school.

A community center, a small commercial center, and similar job-creating uses at this site will serve the proposed residential and mixed residential areas as well as the very large residential areas (4 square miles) to the west of Temperance between Kings Canyon Road and Jensen Avenue. Currently there are no shopping/commercial areas for over 3 driving miles to the Kings Canyon/Clovis Avenue center. Adding a small community center/office/ commercial center and some mixed residential would greatly reduce trip miles, air pollution, and noise. These uses would not conflict with the large community center proposed at DeWolf and California Avenue and would complement it by reducing trip miles between shopping/office space needed in both areas. The proposed four-lane California Avenue would support both developments and conveniently connect the Temperance and DeWolf arterial streets for both bicycle and foot traffic.

There is significant pressure/demand on this area to develop employing these land uses due to the SR 180 Freeway completion. Temperance Avenue will be a major connector between SR 180 and Jensen Avenue for communities to the south and east such as Sanger, Del Rey, Reedley, Parlier, and Selma. There are no services, such as gas stations, grocery stores, drug stores, restaurants, etc., to serve this traffic volume. The streets and large community centers proposed over a mile to the east will not develop for 20 to 30 years or more and will not be able to serve the immediate needs. This inconvenient situation will create more trip miles, air pollution, and noise.

More jobs will be created by the uses we proposed compared to the Business Park/Flexible R&D land uses. If these proposed Business Park lands develop in this area in the distant future, it would be primarily warehouses, storage areas, or agricultural-related processing industries. There are already many large industrial areas in the Fresno area along Jensen Avenue to the west, at the Fresno airport only 5 miles away, and in Clovis. There is no demand in this area for such land use, and it would cause this area to develop last, if ever.

By making this area Flexible R&D, it will essentially stop or severely slow development of REITZ

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2 CONT
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this area and cause development to leapfrog over to areas east of the Briggs Canal. This would cause an expensive and undesirable situation for City services, such as roads, water, sewer, storm drainage, gas, and electrical, to be extended far to the east without development west of the Briggs Canal. Stranded areas of land development are sure to cause unnecessary environmental impacts, future inconvenience, and wasted money.

The industrial area to the north of the railroad at Temperance up to Butler Avenue is primarily an agricultural/wet industry (La Destria, formerly Bonner Packing). This is a significant industrial development that has existed for over 150 years at this large site.

Zoning of Business R&D may not be consistent with this existing use due to significant odors, noise, rail (double rail spur), truck traffic, and similar environmental impacts. We suggest that this entire area north of the railroad up to Butler Avenue be kept as industrial only. The railroad would provide a good buffer and transition to the community center/office/Mixed Residential uses we are proposing.

If it is necessary to have a certain number of Industrial or Business Park/Flexible R&D acres in the plan, we suggest moving this zoned area to south of Jensen Avenue and west of Temperance Avenue. The present plan shows some residential in these areas, which would be an environmentally unsound choice due to the heavy traffic noise, and air quality impacts created by a future six-lane roadway such as Jensen Avenue. An example of this undesirable situation can now be found on the north side of Jensen between Clovis and Fowler Avenues, where homes are being built adjacent to this busy highway.

As evidenced by our previously proposed application in 2008 for this modification, over 70 percent of the property owners (17 parcels) in this area do not want the Industrial/Flex R&D zoning in this area. These property owners have owned and paid taxes on these properties for many years, in some cases over 75 years. Many of the parcels are small (less than 10 acres) and are not conducive to developing the larger parcels necessary for Business Park/Flexible R&D, which would further hamper the sales and development of the area for these uses. This condition would promote further leapfrogging over this area.

The Phasing of Development shown as Exhibit 6 provided at the May 3rd 2022, public meeting showed our area to be developed third of four phases. We disagree with this phasing order and feel the area shown as third should be second and the area shown as second moved to third. The area south of Jensen is entirely agricultural now with no major roads completed other than Jensen Ave. There are also no utilities extended near this area.

Development of this area would be much more expensive and cause additional deleterious environmental impacts. The State Center Community College is no longer planned for this area, so there is no reason for the land to be developed before the area east of Temperance Avenue between SR 180 south to Jensen Ave. The latter area is already developing due to the new Freeway and the near future extension of Temperance Ave as a super arterial. Also, the new Southeast Fresno regional water treatment plant is just to the northwest and can REITZ

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be used to bring water to this area more economically. We would appreciate your consideration in this logical and environmentally sound change if phased development of the SEDA area is proposed.

In reading Chapter 5 of the Recirculated Draft Program EIR prepared by the City of Fresno, the city considered various Land Use Alternatives. One of these, listed as Alternative 2, Consolidated Business Park Alternative, is described as follows:

Under the Consolidated Business Park Alternative (Alternative 2), the SEDA Specific Plan would occur as planned, but this alternative maintains the Flexible Research and Development land designations from the General Plan for the area south of Jensen Avenue. It would accommodate approximately 42,900 homes and 36,000 jobs within the 9,000-acre planning area. This is approximately 2,100 fewer homes and 1,000 fewer jobs, when compared with the proposed project. Alternative 2 would have slightly less density of development than the proposed project. The area identified in the SEDA Specific Plan as Flexible Research and Development to the east of Temperance Avenue and north of Jensen Avenue would be developed as Neighborhood Residential and Mixed Residential with two community centers and five neighborhood centers. Additionally, this alternative would change the land use designations for the planned Mixed Residential and Neighborhood Residential, along with the Community and Neighborhood Centers south of Jensen Avenue. Under Alternative 2, that area would be designated as Flexible Research and Development and Offices. Please refer to Exhibit 5-1 for a visual representation of this alternative.

The Exhibit 5-1 Land Use Map is enclosed with this letter as well as Exhibit 1-1 which is the document that has been unchanged since the original work on SEGA plan was done in 2007.

The Alternative 2, Consolidated Business Park Alternative, essentially agrees with what we and our neighbors have been proposing since 2008, and we are extremely pleased that it was The results of this
analysis, as described in detail in Chapter 5, were determined to be an environmentally superior alternative
This determination was illustrated in Table 5-1 of the Recirculated Draft Program EIR and is enclosed with this letter. Below are excerpts from the Recirculated Draft Program EIR that reflect this determination as well as the project objectives related to new dwelling units and jobs.

5.2 - Project Objectives
As stated in Chapter 2, Project Description, the objectives of the proposed project are to:

Quantified Objectives
Accommodate between 40,000 and 45,000 dwelling units of varying types, sizes, densities, and affordability levels.

REITZ

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10CON
T
11 called the "Proposed Project" in this document. This "Proposed Project" is the same land use analyzed to the same degree as the "Proposed Project" in the Draft EIR. as compared to the "Proposed Project" when all aspects are considered . •
Accommodate between 30,000 and 37,000 jobs.

5.6 - Environmentally Superior Alternative
CEQA Guidelines Section 15126(e)(2) requires identification of an environmentally superior alternative. If the No Project Alternative is environmentally superior, CEQA requires selection of the the alternatives evaluated. The qualitative environmental effects of each alternative in relation to the proposed project are summarized in Table 5-1.

Land Use and Planning
Alternative 2 would have slightly less density than the proposed project. Alternative 2 would not physically divide an established community. This alternative would allow for planned development and growth and would increase connectivity and support, strengthen, and connect new communities. However, this alternative might reduce impacts to land use by consolidating Office Center and Flexible Research and Development land uses to the area south of Jensen Avenue.

Therefore, impacts to land use would be expected to be less than significant, similar to but slightly less than the proposed project.

5.6 - Environmentally Superior Alternative
The Consolidated Business Park Alternative is the environmentally superior alternative because it has similar, but slightly less, impacts as compared to the proposed project and meets the project Also enclosed as a separate attachment is a brief executive summary of the relevant discussions in Chapter 5 of the Draft Program EIR that reinforce our conclusions and recommendations.

In summary we wish to thank the city and city staff for allowing us and our neighbors to comment on the Recirculated Draft Program EIR. For the reasons stated above and also as stated in your own Recirculated Draft Program EIR, we request that the Consolidated Business Park Alternative (Alternative 2), be adopted as the preferred land use plan and be adopted as such. We hope that the City Planning Department and the City Planning Commission will make this recommendation to the City Council for adoption based on the desires of the property owners in this area as well as the analysis performed by their EIR consultant in accordance with the CEQA process. If you have any questions, you may contact me at the address and contact information below.

Sincerely
REITZ

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"environmentally superior alternative other than the No Project Alternative" among the project and II
objectives. 11

Page 7 of 11 ends

246 E. Denise Ave.

Fresno CA 93720
559-905-4523
Ma rkreitz [email protected]
y~t.~
Dale T. Reitz
405-818-7280
[email protected]
Enclosures
CC:

Annalisa Perez District 1 Council Member, [email protected] Mike Karbassi District 2 Council Member, [email protected] Miguel Arias District 3 Council Member, [email protected] Tyler Maxwell District 4 Council Member, [email protected] District 5 Council Member, [email protected]
Nick Richardson District 6 Council Member, [email protected] Nelson Esparaza District 7 Council Member, [email protected] Garry Bredefeld Distict 2 Supervisor, [email protected] Luis Chavez District 3 Supervisor, [email protected] Buddy Mendes District 4 Supervisor, [email protected] Nathan Magsig District 5 Supervisor, [email protected] REITZ

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SEDA PROPOSED LAND USE MAP
= Freewctt £:I Southeast OevelopmentArea
- Expressway t . Fresno Sphere of Influence
• Scenic Expressway - Major & local Roads
• Super Arterial -+ Railroads
-• Arterial
1-++ ScemcArtenal
.., ScemcOrive
- Collector
-•• Scemc CoMector
- Regional Town Center
- Community Town Center
• Neighborhood Town Center
- Office Center
r
Flexible Reseach & Development
Mixed Residential
Neighborhood Residential
Rural Residential
Rural Cluster Residential
Institutional
Map 2.5 SEDA Proposed Land Use
Source: City of Fresno. SEDA mustrahve Plan
o€fNed lrom rommunity and stakeholder meetings.

LL
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~ w
0 Southeast Development Area
3,000 6,000
----====Feet

0.5 1
----====Mi les
()

BELMONT
KINGS CANYOfiJ'---
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Southeast Development Area Specific Plan I 22
REITZ

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CONSOLIDATED BUSINESS PARK ALTERNATIVE
= Freeway
• Expressway
C Southeast Development Area Ill 4 Fresno Sphere of Influence ■■ Scenic Expressway - Major & Local Roads
• Super Arterial -1- Railroads
-• Arterial
t-+-t Scenic Arterial
..,. Scenic Drive
-collector
•••• Scenic Collector
Regional Town Center
Community Town Center
Neighborhood Town Center
Office Center
Flexible Reseach & Development
Mixed Residential
Neighborhood Residential
Rural Residential
Rural Cluster Residential
Park/Open Space/Flood Control
Source: City of Fresno
FIRSTCARBON a
SOLUTIONS™ W
-
I
I
t§~JJ:iff6 "
31680033 • 07 /2023 I 5-l_consolidated_business_park_alt.cdr Southeast Development Area
3,000 6,000 Feet
0 0.5 Miles
Source: City of Fresno, SEDA Illustrative Plan
derived from community and stakeholder meetings. 0
LJ..
_J
0 ~
w
0 BELMONT
KINGS CANYOrlJ
JENSEN
NORTH
Exhibit 5-1
Consolidated Business Park Alternative

CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
REITZ

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12 Comments on Recirculated Draft PEIR, SEDA Specific Plan Project #2022020486 After a review of the SEDA General Plan, Recirculated Draft PEIR Specific Plan, and the three Alternatives in Chapter 5, I believe the Consolidated Business Park Alternative 2 offers the best course of action to satisfy the PEIR Project objectives.

Alt 2 would maintain existing R&D land designations from the General Plan for the area south of Jensen Avenue but allow the area east of Temperance Avenue to be developed at Neighborhood and Mixed Residential with two community centers and five neighborhood centers (p. 5-6). This scenario would permit proper organized and phased development on potentially stranded land east of Temperance and west of the Briggs Canal. Consolidation of Flexible R&D land south of Jensen Avenue would offer the opportunity for synergies of planning and phased development in one contiguous area instead of two separate tracts.

Alt 2 would accommodate 42,900 homes and provide 36,000 jobs within the 9,000 ac planning area (p. 5-14). These estimates are 95% of the maximum in the range outlined in the project objectives of the SEDA Specific Plan (p. 5-7) and 97% of the maximum jobs in the range outlined in the Plan, while offering the benefit of slightly less development density and environmental impact.

Alt 2 would consolidate the proposed Office Center and Flexible R&D land uses to the area south of Jensen Avenue, thus preserving more undeveloped space (p. 5-15). Alt 2 would not physically divide an established community, allow planned development, and increase connectivity to support and strengthen new communities (p. 5-18).

Alt 2 would provide similar development to the proposed project, but with slightly less intense impacts to GHG emissions, agricultural, forestry, and biological resources (p.5-15). In fact, the 2025 Recirculated Draft Plan made no mention of any significant net increase in GHG emissions for Alt 2 (5-21). The previous 2023 Draft Plan had stated that "Alt 2 would still have a significant net increase in GHG emissions and would have a significant GHG impact per the City of Fresno GHG Reduction Plan Update (5-17).").

REITZ

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13 14
15 Alt 1, No Project Alternative, would use current land use and zoning maps from the General Plan. This alternative would include an estimated 17,900 homes and 29,600 jobs {p. 5-6). These numbers are below the range of homes and jobs identified as "quantified objectives" in the SEDA Specific Plan. Alt 1 would have similar, but slightly less, impacts than the proposed SEDA Specific Plan.

Alt 3, Farmland Conservation Alternative, envisions no future development or ground disturbing activities on specific farmland {648.61 ac) designated for conservation {p. 5-22). In addition, a Rural Cluster Residential Buffer {832 ac) on the east side of the Plan area would be excluded from development. Preserving this buffer farmland would reduce the transitional buffer and cause residential lands to be in closer contact with active agricultural land {p. 5-25). This unavoidable conflict of land use continuity would likely contradict the Specific Plan Policy UF-1.6 and create a significant environmental impact {Table 5-1). This land use conflict creates an incrementally greater environmental impact, rendering it inferior under CEQA Guidelines (p. 5-29).
"Alternative 1, the No Project Alternative, would not meet the project objectives. Alternatives 2 and 3 would meet many of the project objectives. The Consolidated Business Park Alternative is the environmentally superior alternative because it has similar, but slightly less, impacts as compared to the proposed project and meets the project objectives." {p. 5-29).

Thank you for your thoughtful consideration.

Dale Reitz and Mark Reitz
1080 S. Temperance Ave.

Fresno, CA. 93727
559-905-4523
405-818-7280
[email protected]
[email protected]

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-751
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Mark and Dale Reitz (REITZ)
Response to REITZ-1
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required.

Response to REITZ-2
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-3
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-4
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-5
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-752 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-6
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-7
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-8
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-9
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-753
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-10
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to REITZ-11
This comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. As discussed in Chapter 5, Alternatives, of the Recirculated Draft PEIR, the Consolidated Business Park Alternative would have similar, but slightly less impacts to the proposed project’s less than significant or no impacts associated with biological resources; cultural resources and Tribal cultural resources; energy; geology, soils, and seismicity; GHG emissions; hazards and hazardous materials; hydrology and water quality; land use and planning; mineral resources; public services; recreation; transportation; utilities and service systems; and wildfire. The significant and unavoidable impacts related to aesthetics, light, and glare; agriculture resources and forestry resources; air quality; and noise would remain significant and unavoidable. The significant and unavoidable impacts related to a conflict with the Valley Air District regional significant thresholds and a cumulatively considerable net increase in criteria pollutants would remain significant and unavoidable under the Consolidated Business Park Alternative.

Additionally, this alternative would not meet all of the project objectives. No environmental issues are raised, and no further response is required.

Response to REITZ-12
The comment is noted. Please refer to Response to REITZ-11. No further response is required.

Response to REITZ-13
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required.

Response to REITZ-14
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-754 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to REITZ-15
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required.

SEDA OBJECTIONS LETTER
Our names are Gregory J. Renna and Abbe J. Renna, we live within the City of Fresno’s proposed Southeast Development Area. We are writing to voice our objections to this plan for several reasons covered herein.

Section 3.2- Agricultural Resources and Forest Resources If approved, The SEDA plan could convert 9,000 acres of rural Fresno County Prime farmland into as many as 45,000 housing units. We have neighbors who are currently farming a variety of produce including fruits and vegetables. Our area includes the beauty of the blossom trail and views of our mountains, which we hope to preserve for generations to come.

The city plans to enforce restrictions on farmers outside their authority. As farmers in the Westlands Water District for a number of years, we learned first hand how government control of water can destroy farming. We were forced to sell our farm property in 2002, due to the environmental and governmental restrictions placed on us as farmers. The property on which we currently reside is excellent farmland and its loss would be devastating to the community as a whole. Once this land is taken over by homes there will be no turning back, this precious farmland will be gone for good. There are several areas in Fresno, where homes have been built near established orchards, and even though the home buyers knew they would be living in an agricultural area, they complained, and restrictions were put on the farmers. We do not believe this is the best use of our valuable rural farmland. The SEDA plan does not value the cultural role of agriculture in our valley.

With regard to forest resources, the SEDA plan does not account for the timber products that would be needed to build these new homes and facilities.

3.10 - Hydrology and Water Quality
California has already overtaxed its water systems. As was recently evidenced in the horrific wildfires in Southern California, water storage is well below what is needed to support our population, existing homes, schools, and farming. With no new dams or reservoirs under construction, how can the City of Fresno allow for more people, homes, and facilities to be built in our area.

As rural residents, we have to monitor the depth of our wells and be concerned with ground water recharge. We are the best stewards of our land and water resources. If the SEDA plan passes, we will have to condemn our wells and connect to city water at an exorbitant cost to each homeowner. Many of us have lived on our properties for decades, and have worked hard to pay off our mortgages. Now the City will require us to go into debt during our retirement years.

As the population grows, the use of pesticides, paint, oil, and other dangerous chemicals will grow exponentially. Scientists have found that many of the medications we take such as hormones and statins do not break down and therefore percolate into our water systems. Does the city have a plan to mitigate these pollutants?
RENNA

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Section 3.8 - Greenhouse Gas Emissions
Section 3.17 - Transportation and Traffic
The addition of up to 45,000 homes and the population increase which will accompany these homes will undoubtedly add to Greenhouse gas emissions in our area. In fact, the project is estimated to triple air pollution levels in Southeast Fresno, according to city documents.There is not currently any means of mitigation proposed. The SEDA plan does not show a budget or environmental impact report for “high quality transit.” In California, most homes house at least 2 adults. Many families require both adults to work.

Given this data, up to 90,000 jobs will be needed to support the influx of people to our area.

Obviously, many of the required jobs will be outside of our area, and will demand the use of cars, undoubtedly raising air and water pollution levels in the form of greenhouse gasses.

Section 3.15 - Public Services
We do not see any proposal for a budget to meet the increased need for public services. How can the city guarantee our safety while walking, biking, or driving in these newly developed areas? With more residents, more walking trails, and open areas planned for recreation, we know there will be a greater need for firefighters as well as police. We do not feel that we have enough public servants in our area currently. We have already seen an influx of homeless people in nearby neighborhoods, freeway on ramps, and empty lots. The City of Fresno has not been able to prevent these encampments from springing up. Our belief is that the City of Fresno is not prepared to add enough additional personnel to serve this expansion of homes and people.

RENNA

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-757
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Gregory and Abbe Renna (RENNA)
Response to RENNA-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Please also refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR.

Furthermore, as detailed in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR, the proposed project would not conflict with existing zoning for, cause rezoning of, or result in the loss of forest land and timberland. No further response is required.

Response to RENNA-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Additionally, please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

Response to RENNA-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-758 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

Response to RENNA-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

From: Maricela Reyes
To: LongRangePlanning
Cc: Andrew Janz; Annalisa Perea
Subject: SEDA public comment from District 1 resident Maricela Reyes Date: Monday, March 17, 2025 9:56:06 AM
External Email: Use caution with links and attachments
Dear Fresno Long Range Planning Team,
I am a City of Fresno District 1 resident writing in response to the new proposed SEDA Environmental Impact Report draft.

I strongly object to the SEDA plan described in the Recirculated Draft PEIR and urge all City leaders to wholeheartedly reject SEDA in full. SEDA will harm the City of Fresno, our neighborhoods, and Fresno residents.

The harm is likely to be profound and last for decades.

My objections include, but are not limited to, the following five key concerns:

The City of Fresno is in debt. Approving SEDA is fiscally irresponsible. Approving SEDA invites significant additional debt with no guarantee of future development to offset it. This debt will be a burden on city residents, tax payers, and businesses for years to come.

The SEDA plan is dangerously outdated, based on a wildly inaccurate presumed growth rate. This plan assumes a growth rate ten times greater than our current - and declining - growth rate.

SEDA will direct our clearly limited resources away from existing neighborhoods and their profound infrastructure needs. One example: the people in West Fresno have been working for years to get infrastructure changes described in the West Area Specific Plan to improve pedestrian safety, storm drainage, traffic flow, cyclist safety, and green space. I believe successfully implementing their West Area Specific Plan is more important than implementing SEDA - and we have every reason to believe approving SEDA will imperil this and similar plans in our existing neighborhoods.

SEDA will harm Fresno businesses. I hear business owners asking for improvements to sidewalks, parking, drainage, traffic flow, and lighting.

Thriving businesses support a thriving Fresno, and they deserve better.

Investing in SEDA without clear assurance that SEDA will NOT redirect the City's already minimal infrastructure attention away from our existing business districts will be a blow to our existing businesses.

SEDA will destroy existing communities of county residents who have no voice in this process. I have listened to the upset voices of people currently living in the area that would be transformed by SEDA.

REYES

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It’s not yet part of the City, so they have no council members to fight for them - or even listen to them. SEDA threatens their communities and their agricultural land without taking their interests into account.

I am urging all City leaders involved in assessing SEDA and its impact on the City of Fresno to reject this plan to protect us all from the harm it will bring - and to strengthen our capacity to improve and enhance our existing neighborhoods and communities.

With appreciation for your public service,
Maricela Reyes
4330 W. Saginaw Way
Fresno, CA 93722
REYES

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-761
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Maricela Reyes (REYES)
Response to REYES-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to REYES-2
The comment is noted. Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to REYES-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to REYES-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: Christopher Rocha
To: LongRangePlanning
Subject: SEDA EIR
Date: Monday, March 24, 2025 9:49:35 AM
External Email: Use caution with links and attachments
Approving SEDA would have long-term fiscal impacts on City services, diverting investments from existing neighborhoods already struggling with urban decay, missing infrastructure, and underfunded public services.

We must prioritize infill development, economic growth in Central and South Fresno, and equitable investments for all communities - not just new suburban expansions.

Thank you,
Chris Rocha
6076 N Tracy Ave, Fresno, 93722
District 2
ROCHA

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-765
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Christopher Rocha (ROCHA)
Response to ROCHA-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

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From: Martha Rodriguez-Torres
To: LongRangePlanning
Subject: Concerns regarding the SEDA Recirculated EIR
Date: Saturday, March 22, 2025 10:42:47 AM
External Email: Use caution with links and attachments
To:

Sophia Pagoulatos, City of Fresno Planning Manager
I am writing to you in regard to the recirculated EIR for the expansion of SEDA. I am not in agreement with this plan which will further create unwanted growth, noise and air pollution and reduction of farmland.

Why are you trying to annex 9000 acres to the city of Fresno when there are so many needs within the existing city boundaries?

3.3.4 Our air quality is one of the worst in the nation. We continue to suffer health problems (asthma, sinus infections, etc. ) and limited days of activity because of the poor air quality.

This will only exacerbate the situation.

3. 17 I currently live off Temperance and Lowe. The amount of traffic and noise has really made it difficult to sit and enjoy the outdoors. I do not like to stand in the way of progress, but no consideration was taken for the existing homeowners already dealing with the high speed of traffic heading towards the 180 Fwy. This was all farmland when I purchased my home, now it's a noise haven because of the people traveling to and from the freeway off ramp on Temperance.

4.1 The 9000 acres of farmland will be lost to the developers and contractors working to make a fast buck off of the land that feeds this country. How much of your plan will protect the people in our midst that can't afford homes? How will schools be built and funded? Where are the jobs coming from? All we will have are people interested in investing and making this area another Southern California and don't even live here or will come with their attitudes of big city living. This EIR was not updated. Please stop selling us out.

I oppose this plan.

Concerned citizen and homeowner,
Martha Rodriguez Torres
6952 E. Lane Ave. (Assessors parcel: 325 S. Temperance Ave.) Fresno, CA 93727
[email protected]
(209) 604-2804

RODRIGUEZ-TORRES

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-769
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Martha Rodriguez Torres (RODRIGUEZ-TORRES)
Response to RODRIGUEZ-TORRES-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to RODRIGUEZ-TORRES-2
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, future development within the Plan Area would be required to comply with applicable school development fees in order to mitigate the impacts on school facilities caused by future development within the City. Payment of applicable development fees would offset the construction and acquisition costs of required school facility improvements and additional staff to meet acceptable service levels. The provisions in Government Code Section 65996, which require developers to pay developer fees to the applicable school district, are deemed to provide full and complete school facilities mitigation related to the school district’s ability to accommodate enrollment. With payment of applicable developer fees, impacts on school facilities related to the proposed project would be mitigated to less than significant levels. No further response is required.

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Brian and Candice Ruck
1592 N Fancher Avenue, Fresno, Ca 93737
3/21/2025
City of Fresno Planning and Development Department Sophia Pagoulatos, Planning Manager 2600 Fresno Street, Room 3065 Fresno, CA 93721
[email protected]
CC:

District 1: Annalisa Perea: [email protected]
District 2: Mike Karbassi: [email protected]
District 3: Miguel Arias: [email protected]
District 4: Tyler Maxwell: [email protected]
District 5: Special Election on March 18th
District 6: Nick Richardson: [email protected] District 7: Nelson Esparza: [email protected]
City Clerk: Todd Stermer: [email protected]
Subject: Strong Opposition and Comments on Recirculated Draft Environmental Impact Report (EIR) for the Southeast Development Area (SEDA) Dear Ms. Pagoulatos and Fresno City Council Members,
We, Brian and Candice Ruck (the Ruck family), reside within the proposed Southeast Development Area (SEDA), specifically in the proposed "rural cluster" rezoning area. Our property consists of 2.18 acres currently serviced by a private water well and septic system. We strongly oppose this rezoning and submit detailed questions and concerns regarding specific sections of the Recirculated Draft EIR as outlined below:

Section 3.2 Agricultural Resources
Comment: We strongly oppose any potential restrictions or limitations placed upon our property concerning agricultural activities, water usage, pesticide and herbicide application, and other routine farm operations following rezoning. What authority does the city have to impose such restrictions, and 1 RUCK

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1 how will this impact our property rights and ability to pass the land to our children? Furthermore, we oppose any restrictions on farm animals, including pigs, sheep, goats, cows, horses, and chickens, currently permitted under our existing zoning.

Section 3.18 Utilities and Service Systems
Comment: We strongly oppose being forced to financially bear the significant costs of transitioning from private water wells and septic systems to city utilities, especially considering our property has two residential units. Please provide documentation supporting cost estimations, clarify whether property taxes will increase to finance these utilities, and disclose plans for funding this massive infrastructure build-out. Additionally, Policy RC-7-b indicates that all customers will be charged the true, full cost of their water supply. Does this mean existing homeowners will be required to immediately pay the full hookup cost to metered city water upon rezoning, and if so, when will this requirement take effect? Are there any financial assistance or phased-in payment plans available to mitigate the impact on property owners? How does the city intend to avoid destroying existing property values with these significant costs?
Additionally, we are concerned about potential impacts on trash services, recycling, and compost services. Currently serviced by a 3-yard dumpster, how will these services change, and who will service them once rezoned? Section 3.11 Land Use and Planning
Comment: We strongly oppose rezoning without clear documentation of how it will affect future property rights, zoning restrictions, and property tax implications, especially concerning inheritance by our heirs. Please provide official documentation and policy references for these impacts. 2 RUCK

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Section 3.1 Aesthetics
Comment: Given the city’s documented inability to enforce existing lighting regulations, we strongly oppose any lighting proposals that will negatively impact our rural atmosphere. What enforceable strategies does the city plan to use?
Sections 3.13 Noise and 3.17 Transportation
Comment: We strongly oppose the increased noise, traffic congestion, dust, and related disturbances resulting from the project, particularly traffic impacts from the Terry Bradley Education Center. How will the city effectively mitigate these impacts, reduce local road speed limits, and enforce traffic safety?
Social Equity and Trails: We strongly oppose plans to build walking and bike trails that cut through our front yard, increasing exposure to vehicle exhaust fumes directly at our front door and affecting many other homes. How does the city justify negatively impacting the health and quality of life of existing residents under the guise of social equity.

Sections 3.11 Land Use and 3.15 Public Services
Comment: We strongly oppose the trail system proposed along our property line due to concerns about security, maintenance, and management of homelessness, vandalism, and crime. Given the city's documented challenges with current parks and trails, how will the city address these serious safety concerns?
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6 Section 3.17 Transportation Road and Eminent Domain Concerns Comment: We strongly oppose taking parts of our front yard for road expansion. Specifically, how much land will be taken, and what is the projected traffic increase on Fancher Avenue? Additionally, since our property extends to the middle of Fancher Creek Canal, we strongly oppose and will not grant permission to build a trail through our private property. Given that legal easements require voluntary agreement or eminent domain, how does the city intend to justify or proceed with eminent domain without explicit property owner consent? Additionally, how will the legal status of any forced easements change if the property is sold or passed down to our children? Section 3.15 Public Services
Comment: We strongly oppose the project moving forward without detailed information on school infrastructure. When will schools be built, and who will pay for their construction and operation?
Emergency Services: We strongly oppose proceeding without clarity on the number of fire stations planned, response times, and funding sources for emergency services.

Sections 3.18 Utilities, 3.17 Transportation Fiscal Responsibility and Infrastructure
Comment: We strongly oppose forcing residents to bear financial burdens without transparency about spending on city officials, meetings, legal defense, and infrastructure. How will the city support an additional 45,000 homes without exacerbating current utility shortages?
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9 Section 3.11 Land Use Employment and Housing Concerns Comment: We strongly oppose rezoning plans that propose fewer jobs than households (.822 jobs per household), leading to increased commuting and traffic impacts. How does the city plan to address this? Sections 3.2 Agricultural Resources, 3.4 Biological Resources Environmental and Agricultural Impact
Comment: We strongly oppose converting prime farmland into urban development. What specific agricultural practices will be permitted in proposed buffer zones, and under whose regulatory authority? Section 3.3 Air Quality Health Impacts and Clean Air Act Compliance
Comment: Given the EIR explicitly states significant unavoidable air quality impacts, potentially violating compliance with the Clean Air Act, who will be held accountable for the adverse health effects on current residents? This proposed project represents severe sacrifices, financial burdens, and health risks on existing residents. The current plan contains hundreds of statements outlining ambitious goals and intentions, yet lacks clear explanations on how these will be practically implemented or financed. Our primary question is simple but essential: How exactly does the city plan to fund the numerous projects and commitments outlined in this extensive 800-page document? Without a transparent and realistic funding strategy, these promises risk becoming unfunded mandates that significantly burden existing residents.

Given Fresno’s documented history of questionable and unethical development practices, including investigations into permit approvals and regulatory violations, what assurances can the city provide to protect existing property owners' rights and 5 RUCK

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