Fresno City Council
December 18, 2025

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points made in each of those letters as well. The RDEIR should disclose and respond to all previously submitted comment letters on the DEIR.

The SEDA project would be a massive development project with extensive impacts that must be carefully planned and mitigated. It has been accurately described as follows:
[the project will] transform nearly 9,000 acres southeast of Fresno into a new Clovis on Fancher Creek.

The project up for the city council’s vote will be one of the biggest suburban sprawl projects in Fresno’s history. The Dyer administration’s plan includes 45,000 homes and up to 150,000 people, on a stretch of land that is currently a patchwork stretch of farmland, rural homesteads, two-lane country roads, and stop-signs.

Known as the Southeast Development Area (SEDA), the transformed community would rival the size of Clovis – 16 times the size of the Copper River project in northeast Fresno, and seven times as large as Riverstone and Tesoro Viejo, the major new communities across the San Joaquin River in Madera. (Weaver, Fresnoland, August 25, 2023, “Another Clovis, but in southeast Fresno? City moves forward on mega-development plans” , available at https://fresnoland.org/2023/08/25/city-of-fresno-eyes-seda/. ) Our understanding of tax sharing agreements that were reached between the City of Fresno and County of Fresno at the end of 20243 is that there would now be economic incentives to the City to encourage growth in the Southeast area of the City rather than in other areas where growth should be incentivized. The existence and effect of these tax sharing agreements should be disclosed and analyzed in the EIR. It has been reported in Fresnoland that “The agreement represents a sea change in city development policy, shifting financial incentives towards growth in the city’s southeast development area, called SEDA, with nominal changes to incentives to annex areas west of 99, formerly the city’s top growth priority.” (https://fresnoland.org/2024/12/20/fresno-countysupervisors-approve-tax-sharing-deal-as-southeast-rural-residents-questions-remain/.) As required by the California Environmental Quality Act (CEQA), the City of Fresno (City) must address the impacts of this massive project, along with its cumulative 3 https://www.fresnocountyca.gov/files/sharedassets/county/v/1/resources/press-releasedocuments/2024-press-releases/2024-12-20-county-city-tax-sharing-agreementannouncement.pdf

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impacts with other similar developments in the region. CEQA has been described as a bill of rights for an environmental democracy. It is intended to provide a “road map” and a “price tag” for proposed projects:

The CEQA process is intended to be a careful examination, fully open to the public, of the environmental consequences of a given project, covering the entire project, from start to finish. This examination is intended to provide the fullest information reasonably available upon which the decision makers and the public they serve can rely in determining whether or not to start the project at all, not merely to decide whether to finish it. The EIR is intended to furnish both the road map and the environmental price tag for a project, so that the decision maker and the public both know, before the journey begins, just where the journey will lead, and how much they-and the environment-will have to give up in order to take that journey.
(NRDC v. City of Los Angeles (2002) 103 Cal.App.4th 268, 271.) Unfortunately, the SEDA EIR falls woefully short of providing the public and decisionmakers with sufficient information to evaluate and mitigate the project’s impacts.

These deficiencies must be rectified and a legally adequate EIR recirculated for public review and comment.

A. Agricultural Resources and Forestry Resources Impacts are Not Sufficiently Mitigated.

The SEDA DEIR, in its Agricultural Resource and Forestry Resources section, identifies the amount of farmland threatened with conversion to urban uses. The Plan’s proposed development will effectively eliminate approximately 6,741 acres in agricultural production, which are specified as 2,475 acres of Prime Farmland, and approximately 1,352 acres of Farmland of Statewide Importance, 1,189 acres of Farmland of local importance, and approximately 1,725 acres of Unique Farmland. (DEIR p. 3.2-16.)
The prominent problem of the SEDA DEIR pertaining to agricultural resources is that its proposed farmland mitigation measures for these thousands of acres of farmland rely upon inadequate policies that have not been adequately implemented. When Fresno’s General Plan was adopted, farmland mitigation was perhaps the most contested and difficult policy of the entire document. Inevitably, after intense debate, the final 2014 Fresno General Plan contained key values and provisions that were structural in nature, including no sphere of influence extension, a prioritization of infill over greenfield development, and defining an easily implementable farmland mitigation policy.

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Specific to the structural land use policies promoting farmland conservation, the 2014 Fresno General Plan stated, “Policies in the Plan will help preserve farmland by incentivizing new development within and adjacent to already-urbanized land, only extending public utilities to new development that adheres to the Plan, and not expanding the City’s SOI.”4
So, the proposed development of the Southeast Development Area effectively punctures the previously agreed upon sphere of influence boundary and violates the integrity of the city’s hoped for revitalization as it re-initiates a historic pattern of sprawl development and proposes new annexation (RDEIR, p. 2-3 [project “requires” annexation]). LAFCO should have been notified and consulted about this proposal.5

The achievement of a farmland mitigation policy was another important outcome of the 2014 Fresno General Plan. Originally, this General Plan specified under policy RC-9-c that when farmland was converted to urban uses, the City of Fresno would “permanently protect an equal amount of similar farmland elsewhere through easement.” This simple, straightforward and implementable policy was consistent with other farmland mitigation programs that typically require mitigation at a 1:1 ratio on soils of similar quality under a conservation easement, however RC-9-c was later amended in ways that made it more muddled, less definitive and more difficult to implement.6

The Fresno General Plan policy RC-9-c (the amended portion in italics) states:
“Farmland Preservation Program. In coordination with regional partners or independently, establish a Farmland Preservation Program. When Prime Farmland, Unique Farmland, or Farmland of Statewide Importance is converted to urban uses outside City limits, this program would require that the developer of such a project mitigate the loss of such farmland consistent with the requirements of CEQA. The Farmland Preservation Program shall provide several mitigation options that may include but are not limited to the following: Restrictive Covenants or Deeds, In Lieu Fees, Mitigation 4 Fresno General Plan Adopted: December 18, 2014, Resource Conservation and Resilience Chapter, Farmland Section 7.6, pg. 7-42.
5 On March 9, 2022, LAFCO considered SEDA.
6 The hearing to consider General Plan Amendment Application No. P18-03553 and related Environmental Finding was initiated by the Fresno City Council on March 3, 2017 through Council Resolution No. 2017-61. The final resolution approved the General Plan Text Amendment No. P18-03553 amending Farmland Preservation Program RC-9-c.

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Banks, Fee Title Acquisitions, Conservation Easements, Land Use Regulations, or any other mitigation method that is in compliance with the requirements of CEQA. The Farmland Preservation Program may be modeled after some of all of the programs described by the California Council of Land Trusts.”7
After a decade, the 2014 General Plan’s originally clear farmland mitigation policy has been amended, diluted, and as yet remains unimplemented. Even worse, its explicit direction to establish a “Farmland Preservation Program” remains incomplete.

This reticence toward implementation erodes confidence that such measures will now be taken up within the Southeast Development Area’s Specific Plan.

Given the lack of compliance with earlier planning policy plans and directives related to farmland conservation, it is recommended that the City of Fresno institute a SEDA-specific urban growth boundary requiring fifty percent vote of city residents to all future proposed greenfield developments in the Plan Area. This would raise the level of planning diligence, democratic participation, and environment promoting policies as each future development project is considered. In addition, each future development proposal in the area should be authorized under a similarly constituted initiative process in authorizing community benefit agreements on each proposed development project to ensure its equity values can be programmatically achieved, such as in future apprenticeship programs and local hire mandates. Environmentally, community benefit agreements would better ensure that proposed “school and neighborhood gardens, community orchards, agricultural education centers and small farming operations in green belts and on the buffer edge” will be realized. (DEIR p. 3.2-17.) Both urban growth boundaries and community benefit agreements ensure resident-involved planning and democratic, participatory involvement through voter initiatives on each proposed future development projects within the Specific Plan area.

Specific to farmland mitigation, the SEDA DEIR inadequately identifies mitigation that can be expected to be meaningfully implemented. A proposed “Buffer District” is a much lesser threshold to breach in the future than an existing sphere of influence boundary in a general plan. Yet this is just the mitigation policy remedy being suggested in SEDA’s DEIR policy framework. (DEIR p. 3.2-17.) The proposed Buffer District is purely aspirational without explicit mechanisms to hold the line on future greenfield development and residential sprawl. Most troubling is that the SEDA EIR’s primary farmland mitigation policy proposal yet again relies upon the dormant 2014 7 Fresno General Plan Adopted: December 18, 2014, Resource Conservation and Resilience Chapter, Farmland Section 7.6, pg. 7-43.

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Fresno General Plan policy RC-9-c guiding farmland mitigation, and MM AG-1.1 that was supposed to establish a Farmland Preservation Program (FPP), now planned to be initiated by 2025. (DEIR p. 3.2-15.)
Given the past lack of planning policy follow through, the SEDA EIR makes contingencies, “because the FPP has not yet been developed, the proposed project would implement project-specific MM AG-2, which requires all future development to mitigate the loss of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, on a project-by-project basis before the initiation of construction or ground-disturbing activities.” (DEIR p. 3.2-17.) A project-by-project policy makes oversight of mitigation policy unworkable though it becomes necessary given the City of Fresno’s past reticence and resistance to mitigate for the loss of farmland.

Farmlands must be protected, including those that are contracted and uncontracted under the Willamson Act. The following maps are prepared by Greg Weaver. All parcels on this map must be accounted for in terms of how their protections will be maintained.

In order for the Williamson Act to succeed as a long term conservation tool, regulation of noncontracted lands cannot be overlooked. SEDA must account for their preservation.

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Agricultural Preserves and Williamson Act
Contracts in Fresno County
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The status and restrictions of the Williamson Act contracted lands must be considered and protected, as must the status of uncontracted lands. (See RDEIR, p. 3.2-

16.)

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B. Air Quality Impacts Would be Significant And are Insufficiently Mitigated

1. Fresno’s Current Air Quality Situation is Dire and Would be Worsened By the Project.

There is no dispute that the air quality in Fresno is abysmal. The prestigious American Lung Association’s annual report State of the Air 2023 lists Fresno as the fourth-most polluted city in the country for ozone8
, and the second most polluted for
short-term particulate pollution, and the third-most polluted city for year-round particle 8 The listing is for Fresno-Madera-Hanford, at https://www.lung.org/research/sota/cityrankings/most-polluted-cities; last visited 8/24/23.

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8 SEDA PROPOSED LAND USE MAP
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pollution9. The federal EPA classifies the San Joaquin Valley Air Basin, of which Fresno is a part, as in “extreme” nonattainment of the National Ambient Air Quality Standard (NAAQS) for ozone, and in “serious” nonattainment for fine particulates (PM2.5). The San Joaquin Valley is one of only two air basins in the entire country classified as in “Extreme” nonattainment for ozone. (EPA Green Book, at
https://www3.epa.gov/airquality/greenbook/jnc.html, last visited 8/24/23. Classification of the San Joaquin Valley as in “Serious” nonattainment of the federal standard for PM2.5 is at https://www3.epa.gov/airquality/greenbook/rnc.html, last visited 8/24/23.)) Fresno is an unhealthy place to breathe, and especially so for sensitive groups, including children, the elderly, and the sick.

Both state and federal law require air basins to comply with the health-based state and federal Air Quality Standards. [E.g., 42 USCA §7401, et seq.).] The San Joaquin Valley Unified Air Pollution Control Agency (APCD) has devised an Air Quality Management Plan (AQMP) to reduce the levels of health-damaging pollution in the air and make the air healthier to breathe. According to the DEIR, a new AQMP for ozone was due for submission to the EPA by August of 2022. There is no information in the DEIR as whether it was submitted or when an evaluation of the new AQMP by EPA might be expected; the fact remains that the Valley is in extreme nonattainment. A new plan for PM2.5 was submitted in June of 2020. (DEIR p. 3.3-25.) EPA has postponed the deadline for the Valley to meet the PM2.5 standard until 2024, but has not yet approved or disapproved the APCD’s new plan to meet the federal standard. The Valley remains in serious nonattainment for PM2.5. However, these facts appear to matter little, since the DEIR clearly and unequivocally states that carrying out the SEDA plan is not consistent with the Air Quality Management Plan now in operation to meet health-based federal and state Air Quality Standards, and would conflict with that Plan and with project significance thresholds established by APCD to prevent increases in ozone. (DEIR, pp.

ES-6, ES-14, 3.3-45.) The DEIR states at page 3.3-45:
[T]he proposed Specific Plan would generate long-term emissions of criteria air pollutants that would exceed the Valley Air District’s regional operationphase significance thresholds, which were established to determine whether a project has the potential to cumulatively contribute to the [San Joaquin Valley Air Basin]’s nonattainment designations. Thus, implementation of the proposed Specific Plan would result in an increase in the frequency or severity of existing 9 The listing is for Fresno-Madera-Hanford, at https://www.lung.org/research/sota/cityrankings/most-polluted-cities; last visited 8/24/23.

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air quality violations; cause or contribute to new violations; or delay timely attainment of the AAQS.
(DEIR, p. 3.3-45, emphasis added.)
The DEIR also states, at page 3.3-51, that the Project will cumulatively increase the airborne pollution to which Fresno residents are exposed daily:

The proposed project would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard. (DEIR, p. 3.3-51.)

2. Project Construction Emissions Would Be Significant For Every Pollutant Category.

The DEIR explains that, by itself, construction of the Project will cause emissions of every pollutant for which the Valley is in nonattainment in amounts that exceed APCD significance thresholds during each and every year of Project construction, 2023-2043, except the very last year. (DEIR, Table 3.3-8, p. 3.3-53.10) The DEIR makes no comparison between the emissions that Project construction will cause to the emissions provided for in the AQMP, a critical failure to provide the information that should be in the DEIR.11 It also asserts that it is “unavoidable” - if the SEDA plan is carried out – that “sensitive receptors” (e.g., children, the elderly, and people who already have respiratory illnesses) will be exposed not only to air that far exceeds the health-based state and federal Air Quality Standards, but they may also be exposed to toxic pollutant emissions, including carcinogens, during construction of the Project. Such carcinogens and other toxic chemicals are contained in diesel particulate emissions (commonly referred to as “DPM,” for diesel particulate matter”), an airborne soup of chemicals and small particles, 10 We note that, while the DEIR states that “[b]uildout of the proposed project would occur over approximately 25 years, or longer,” the Table showing pollutant emissions from construction goes out only 19 years. There will, apparently, be even more pollutant emissions than the Table shows.
11 Nor is Appendix B, the Air Quality Appendix, much help. It contains only the same Table (in a slightly different format) and the outputs of the computer model used to predict Project emissions (these cannot easily be read by laypersons). It does not compare Project construction emissions with the AQMP.

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many of which either are carcinogenic, or have carcinogens adhered to them, that are emitted by diesel trucks and diesel-powered construction equipment.12 The potential health impacts from diesel particulate emissions are quite significant, as the DEIR shows at page 3.3-17. The DEIR, at page 3.3-59, tersely acknowledges that “Project construction would involve the use of diesel-fueled vehicles and equipment that emit DPM, which is considered a [Toxic Air Contaminant].”13 The DEIR disclaims the ability to estimate DPM emissions from the Project, but it admits that, as to toxic emissions, especially DPM:
[I]t is possible that the proposed project would result in cumulatively significant impacts to sensitive receptors, even if individual projects were each less than significant.
(DEIR, pp. 3.3-60 to 61.). The DEIR’s inability to estimate the amount of DPM emissions the Project would cause is severely undercut by the DEIR’s ability to calculate the particulate emissions of the Project, both gross particulates and fine particulates, which should include many components of diesel particulate emissions. Some reasonable estimate should be possible, and it is a failure of information required by CEQA for the DEIR not to make a good-faith attempt to provide this information.

Overall, the DEIR concludes that air pollutant emissions attributable to the Project, even after all feasible mitigation is applied, would have a “significant and unavoidable” impact, including on sensitive receptors. (DEIR, p. 3.3-61.) In short, the DEIR demonstrates that carrying out the SEDA Project is a recipe for Fresno to continue having some of the very dirtiest, unhealthful air in the nation for decades into the future, and a blueprint for allowing the Project to dump more ozone-causing emissions and particulate matter into the air Fresno residents breathe every day. It is a plan for forcing another generation of Fresno’s children to grow up breathing air that compromises their lungs and may permanently harm their health. (See State of the Air 2023 Report, pp. 24- 25 [health effects of particulates] and 26—27 [health effects of ozone].)) 12 For context, the South Coast Air Quality Management District (SCAQMD) estimates that 50% of the risk of cancer from airborne carcinogens in the greater Los Angeles comes from exposure to DPM. (Multiple Air Toxics Exposure Study V, SCAQMD, 2021, page ES-7. (Available at https://www.aqmd.gov/docs/default-source/planning/matesv/mates-v-final-report-9-24-21.pdf; last visited 8/24/23.) 13 Diesel exhaust has been formally designated a Toxic Air Contaminant by the California Air Resources Board. (Cal. Code of Regs., title 17, section 19000.)

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3. The DEIR Does Not Show That it has Applied All Feasible Mitigation.

As set out above, the DEIR thus acknowledges that the Project would make Fresno’s already abominable air even worse, which creates significant impacts on the environment. It then asserts that:

No further measures to reduce operation-phase criteria air pollutant emissions are available beyond the applicable Valley Air District rules and regulations in addition to the proposed project’s policies and design46.) guidelines [as set out in the DEIR].
(DEIR, p. 3.3-46.) The DEIR asserts that there are no further feasible mitigation measures. In fact, the DEIR implies that the Project is too big for its air quality impacts to be feasibly mitigated (DEIR p. 3.3-46), a concept that is antithetical to CEQA’s purposes and requirements. Instead, the City should consider making the Project smaller, so that mitigation is feasible. CEQA requires that once significant impacts from a Project have been identified, the project should not be approved if there are feasible mitigation measures that would lessen or prevent such impacts. (Public Res. Code § 21002.) The City must re-think mitigation. The SEDA is a major project, one that will greatly expand the City’s population and infrastructure, and one whose construction will stretch out for a quarter-century, up to the time when California is committed to being carbon-neutral. (AB 1279; EO B-30-15.) Its operation will last much longer. The City is approving a Project that will define Fresno and its legacy for the rest of this century. If aggressive and effective mitigation for air pollutant emissions is not enacted now, when it will be most effective because it acts on a relatively blank slate, when will it be enacted? To avoid a future of decades of continued air that sickens Fresno’s residents, we urge the City to adopt additional mitigation measures now that are specific and effective, and not just aspirational. We believe that there are many mitigation measures set out in the DEIR that could be made more effective, that would reduce the pollutant emissions of the Project, and that are feasible. Below is a summary of the more prominent ones.

4. Mitigation Measures Already in the DEIR Must be
Strengthened.

The DEIR lists policies in the Fresno City General Plan and the SEDA plan as potentially lessening the air quality impacts of the Project. Many, if not most, of these policies are so conditional and aspirational as to be unenforceable. Examples include policies that include wording such as “support,” “promote,” “incentivize,” or “pursue.”

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(E.g.: Land Use Policies LU-2(b), LU 3(c;, HC 3.d; MT-2(c), (g) and m; Open Space Policy OS-10.5; Conservation Policies RC1.1, RC 1.3 (a) and (b), RC 1.4.) Particularly important are those mitigation measures listed as “Municipal,” which are under the City’s direct control and discretion (e.g., Conservation Policies RC 4 (f) and (j), and 8(j).) Where a mitigation measure is within the City’s direct control (such as setting energy efficiency standards for municipal buildings), and where the environmental impacts to be mitigated are as dire as violating the AQMP, the City must enact mitigation measures that are fully enforceable. (CEQA Guidelines §15126.4(a)(1) and (2).)
DEIR mitigation measures specific to the Project must also be made mandatory.

Specifically, MM AIR 2.1’s full list of controls for diesel-powered construction equipment should be made mandatory unless individual measures are proven infeasible under clearly defined standards, and MM AIR-3.1’s measures to control emissions of Toxic Air Contaminants should be mandated for use, not merely for identification.

In addition, many measures in the DEIR could be made enforceable by defining terms in the measures (such as “feasible” in MM AIR-2.1) or by setting schedules and enforceable deadlines for measures calling for the adoption of controls or plans, or for the setting of standards. (E.g., Resource Conservation Policies RC-4(b), 4(g), and 4(k), RC8(j), and others.) We also note that several mitigation measures that should be made mandatory for individual developers for projects within SEDA could also be used to provide offsets for their projects’ pollutant emissions, if also carried out outside SEDA. These include creation of off-site renewable energy projects, such as installation of solar panels on rooftops in existing Fresno neighborhoods, tree planting, and replacement of inefficient appliances in homes in existing neighborhoods, and installation and maintenance of electric vehicle charging stations in Fresno neighborhoods or at facilities like shopping centers and sports facilities.

5. Because The DEIR is Inadequate as an Informational
Document, Vital Information Must be Added, and the DEIR Recirculated.

The CEQA Guidelines require an agency to “use its best efforts to find out and disclose all that it reasonably can” in an EIR. (Guidelines § 15144.) The City has failed to do so here. Table 3.3-9, at page 3.3-55, which is the only table showing operational pollutant emissions from the Project, is an example of how uninformative the EIR is. It

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shows only a single year’s emissions total: 2050, the year of full build-out of the Project, and seven years after the last year (2043) for which construction emissions are projected.

Presumably, many individual SEDA projects, from housing developments to transportation facilities, will be completed in the years prior to 2050 but their emissions are undisclosed. This is a critical failure of the DEIR to provide full disclosure of environmental impacts from the Project; the public has no clue about operational emissions from the Project for 46 years prior to 2050. There is not even information as to when the first individual SEDA projects will begin to operate and will have operational emissions.

The SEDA projects’ expected operational emissions appear for the first and only time as they are expected to be in 2050. It is beyond credulity to assume to none of the SEDA component projects will emit any conventional pollutants until 2050, and that all of the individual SEDA projects will begin emitting at once, several years after construction emissions end. The DEIR states that “[r]egional construction and operational emissions reported in this analysis were modeled using CalEEMod using version 2020.4.0” (DEIR, p. 3.3-40), so the City presumably has at least some of this information. If it does not have it, the City must have, or must generate, this information to the extent it is feasible to do so, and the DEIR must provide it. The DEIR does state that, if climate change causes temperatures to rise, the number of days when ozone will form in the Valley will also rise:

If temperatures rise to the medium warming range, there could be 75 to 85 percent more days with weather conducive to ozone formation in Los Angeles and the San Joaquin Valley, relative to today’s conditions. This is more than twice the increase expected if rising temperatures remain in the lower warming range. This increase in air quality problems could result in an increase in asthma and other health-related problems.
(DEIR, pp. 3.8-9 to 10.) Further, the DEIR states:
[Fresno] temperatures are predicted to increase by 4.5°F (degrees Fahrenheit) under the medium emission scenario and 8.5°F under the high emissions scenario.

DEIR, p. 3.8-10.)
The increase in pollutant emissions and the increase in temperatures and number of days when ozone is likely to form add up to a potential public health crisis, necessitating the fullest information that can be provided. Further, since this information is essential to any understanding of the health impacts of the Project, the DEIR must be

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recirculated with that information prior to certification. (CEQA Guidelines § 15088.5.) It is imperative that the decision makers and the public have this information.

Further, Table 3.3-8, at DEIR page 3.3-53 shows projected unmitigated yearly emissions of conventional pollutants from construction over the life of the Project. In the first year, 2024, the Table shows 1770.60 tons of volatile organic compounds VOC), a precursor of ozone, projected to be emitted. In the second year, 2025, the figure drops by more than half, showing 668.30 tons of VOC projected to be emitted. After those two years, projected VOC emissions plummet, with the 2026 VOC emissions projected to be

30.45 tons. No reason is given for this remarkably high VOC emissions level and the subsequent drop-off and extreme drop-off, respectively, of the next two years’ VOC emissions. Clearly, there must be a reason for this weird pattern of VOC emissions that must be disclosed by the EIR.

The emissions of nitrogen oxides (NOx) from construction listed in the Table show a steady decline over the years, as do other pollutants. Notably, PM2.5, which almost certainly contains carcinogenic DPM from construction equipment and diesel trucks, remain fairly steady throughout the years, with 2024’s emissions and 2043’s emissions being within 6 tons per year of each other.

Possible explanations for the high early VOC numbers are that the City knows of specific projects planned for construction in 2024 and 2035 that emit high levels of VOC, or that the emissions modeling failed to accurately predict or report VOC emissions in the first two years of the Project. However, the City is not sharing those- or any - explanations with the public. This is a further failure of the DEIR to provide full information to the public.

Finally, the DEIR does not predict pollutant concentrations in the ambient air that will result from both construction and operation of the Project.

6. The DEIR does not Correlate Pollutant Emissions From the Project with Resulting Health Impacts.

The California Supreme Court, in Sierra Club v. County of Fresno (2018) 6 Cal.5th 502 (“Friant Ranch”), held that that the EIR on the Friant Ranch Project approved by the County of Fresno “fail[ed] to provide an adequate discussion of health and safety problems that will be caused by the rise in various pollutants resulting from the Project's development.” (6 Cal.5th 502, at 527.) The DEIR here also fails to comply with the requirements of the Friant Ranch decision.

We first note that the DEIR does describe some health effects of ozone and PM2.5. (DEIR, pp. 3.3-12 to 3.3-12.) However, its description of the health impacts of

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PM10 and PM2.5 fails to point out the disproportionate impact of airborne particulate matter on disadvantaged communities. The APCD stated in a 2021 letter to the California Air Resources Board:
“As recent research indicates, there is a disproportionate health impact of PM2.5 exposure to people of color, and the burden of mobile sources to the Valley contribute significantly to these health effects. The State’s CalEnviroScreen 3.0 tool indicates that a significant number of communities in the Valley are among the most disadvantaged in California for a number of indicators, including overall pollution burden, and diesel PM exposure (Figure 1). In fact, 20 of the top 30 most disadvantaged communities in California are within the San Joaquin Valley. As emissions from mobile sources contribute a significant portion to the overall pollution burden in these disadvantaged communities, achieving emissions reductions from mobile sources is paramount to improving the health of the most impacted residents in the State.”
(APCD Comment Letter on Revised Draft 2020 Mobile Source Strategy, May 14, 2021, footnotes omitted. [https; ww2.arb.ca.gov/sites/default/files/2021-05/8- SJVAPCD_Comment_RevisedDraft2020MobileSourceStrategy.pdf; last accessed 4/6/23.]) Here, the DEIR does not discuss the disparate effects air pollutant emissions increases may have on the disadvantaged communities within SEDA and elsewhere within the City.

In fact, the DEIR does not predict the impacts of its pollutant emissions on the ambient air at all, except to say that those emission will not be consistent with the AQMP. (DEIR, p. 3.3-45 [“implementation of the proposed Specific Plan would result in an increase in the frequency or severity of existing air quality violations; cause or contribute to new violations; or delay timely attainment of the AAQS.”]) Beyond that, the DEIR says nothing about the magnitude of the increase in frequency and/or severity its new emissions will cause. Instead, it says tersely: “Air dispersion modeling is not applicable at a program level.” (DEIR, p. 3.3-42.) No further explanation is provided.

However, the California Supreme Court in Friant Ranch was presented with a similar claim, and held that “if it is not scientifically possible to do more than has already been done to connect air quality effects with potential human health impacts, the EIR itself must explain why, in a manner reasonably calculated to inform the public of the scope of what is and is not yet known about the Project’s impacts.” (Friant Ranch, supra, 6 Cal.5th at p. 520.) Here, the DEIR has not done the analysis of the impact on human health of the Project’s new emissions (or even shown what all emissions are projected to be). Nor has the public been given an explanation of why it cannot provide that impact analysis, other

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than one short sentence saying it can’t be done. As the Supreme Court in Friant Ranch made clear, more explanation is required.

Further, such an analysis can be done. When Cal State San Diego proposed a master plan to develop a new community, it eventually certified an EIR that did perform a Friant Ranch analysis, correlating the project’s emissions with impacts on human health (although it acknowledged that the analysis was not perfect). That analysis is available at https://missionvalley.sdsu.edu/pdfs/feir/appendices/4-2-3-sdsu-mv-healtheffects-memo.pdf, and is hereby incorporated into this letter by reference. We also formally submit it into the administrative record for this Project by reference, as demonstrating that an analysis correlating emissions from a major project with impacts on human health is feasible.

The City has proposed a huge, multi-year Project that will transform Fresno. It must perform an analysis of the effects on human health of that Project’s pollutant emissions, with the degree of precision that is currently possible and has been demonstrated in practice. The DEIR must be recirculated with the analysis when it is completed. CEQA and the public health demand no less.

7. Project Construction Emissions Of GHG Are Underreported.

The RDEIR is extremely deficient in its analysis of SEDA’s potential greenhouse gas emissions. It states that construction emissions of greenhouse gases (“GHG”) are a one-time event, and as such, will not cause significant impacts. (EIR, p.3.8-42.) However, the RDEIR also acknowledges that GHGs stay in the atmosphere for very long periods of time, carbon dioxide (“CO”) emissions remaining for 50 to 200 years (RDEIR p. 3.8-4); hardly a one-and-done event. The EIR states at page 3.8-6 that “GHGs have long atmospheric lifetimes, several years to several thousand years. GHGs persist in the atmosphere for a long enough time to be dispersed around the globe.” Further, the RDEIR admits that certain Project construction emissions can cause significant impacts, saying of water supply and wastewater treatment:

GHG Emissions–Construction of utility facilities and treatment plants would result in the generation of GHG emissions. Construction emissions would occur only in the short-term; however, since the timing of the construction of the expanded and new facilities is not known, there could be more than one facility under construction at one time. Therefore, there is a possibility that a substantial amount of GHG emissions could occur. In addition, the operation of treatment plants and construction of other utility infrastructure (pipes, basins, etc.) could contribute to

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emissions associated with the buildout of the proposed Specific Plan. These emissions would be potentially significant.
(RDEIR, p. 3.8-55, emphasis added.) This is only one component of the Project; presumably, the whole will be greater than the sum of its parts, meaning that the GHG emissions from the construction of the entire project may be significant.

What is certain is that emissions from Project construction are not only not onetime events – construction would extend over nearly a decade (RDEIR, p.,3.3-48) – such emissions would be huge, totaling a whopping 2,316,578 metric tons of carbon dioxide equivalent emissions (“MTC02e”). For perspective, the total carbon dioxide emissions estimated in the City of Fresno’s Greenhouse Reduction Plan as being emitted by motor vehicles in the entire City under Business as Usual conditions in 2020 is 2,383,023 MTC02e. (City of Fresno –Fresno General Plan Update Greenhouse Gas Reduction Plan, p. 29, available at https://www.fresno.gov/wp-content/uploads/2023/03/F-2-GreenhouseGas-Reduction-Plan.pdf.) Construction of this single Project will cause the emission of nearly as much climate-changing pollution as all the cars and trucks in the entire City of Fresno. The EIR has presented no substantial evidence to support its conclusion that Project construction emissions of GHGs would not be significant.

8. Operational Emissions Will Be Significant.

Nor will the Project’s operational emissions be less than significant. The EIR presents information as to the Project’s operational emissions solely for its Buildout Year, at least a decade after construction begins, and after various measures will have been taken at the federal and state level to reduce GHG emissions from various sources, notably from motor vehicles. (RDEIR, pp. 3.8-47 to 48.) Even with such reductions, total operational GHG emissions from the Project are estimated by the EIR as 601,912 MTC02e per year, with transportation emissions accounting for over two-thirds of that total, at 432,219 MTC02e per year. (RDEIR, p. 3.8-43.)14 The total GHG emissions from the Project are not estimated in the body of the EIR; indeed, the lifespan of the Project is not estimated. However, the lifespan of a house extends over several decades, perhaps even as long as a century. (https://www.bankrate.com/real-estate/whats-the-life-span-of-ahouse/#:~:text=You%20can%20count%20on%20a,endure%20the%20test%20of%20time 14 The RDEIR makes an adjustment to the total of the GHG emissions by subtracting existing emissions, but since the RDEIR only does this for the total amount of Project operational emissions, not broken down by sector, we were unable to make such an adjustment for transportation emissions.

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.) However, multiplying the estimated annual GHG emissions of the Project, viz., 510,791 MTC02e per year, by ten, the Project can be estimated to emit over five million metric tons of C02e during each decade of its useful life. Once again, the RDEIR presents no substantial evidence that emissions of such magnitude will have less-than-significant impacts. In fact, the RDEIR makes no effort to provide substantial evidence as to the total time that the Project can be expected to be occupied and useful. CEQA Guidelines section 15144 mandates that an agency preparing an EIR “must use its best efforts to find out and disclose all that it reasonably can.”15 The RDEIR has failed to do so in estimating the total GHG emissions that can reasonably be expected from this Project.

9. FAX Transit Service Levels Are Not Substantiated.

The RDEIR’s vehicle miles traveled (“VMT”), air quality, and GHG calculations are based, at least in part, on the assumption that Fresno Area Express (“FAX”) will provide high-quality transit services to the SEDA as it develops. (See RDEIR Policy R1.2(a) at p.3.3-34 and 3.8-36.16) However, no bus lines currently serve the area (RDEIR, p. 3.17-6), and no portion of the RDEIR provides information on when bus transit services will be provided, the extent (e.g., hours, headway, or capacity of the services) or how they will be funded, despite the fact that FAX is a City agency and under City 15 CEQA Guidelines section 15145 provides that “[i]f, after thorough investigation, a lead agency finds that a particular impact is too speculative for evaluation, the agency should not its conclusion and terminate discussion of the impact.” However, the City does not present evidence that it made any attempt to estimate the useful life of the Project. 16 See, the generalized, non-specific assertion at RDEIR p. 3.17-7:

Transit Facilities
Fresno Area Express (FAX) is the local bus system for the City. Currently, there are no bus lines that run through the Plan Area. Bus Routes 1, 22, and 35 run on Clovis Street near the Plan Area but do not directly serve the Plan Area. There are plans to extend the Fresno bus rapid transit line (Route 1) into the Plan Area in the future and to add local transit routes to significant origins and destinations with the project area.

See, also, the generalized description of future FAX transit service in Appendix H, at page 16:

3.4 EXISTING TRANSIT FACILITIES
Fresno Area Express (FAX) is the local bus system for the City of Fresno. Currently, there are no bus lines that run through the Plan Area. Bus routes 1, 22, and 35 runs on Clovis Street near the Plan Area, but do not directly serve the Plan Area. There are plans to extend the Fresno bus rapid transit line (Route 1) into the Plan Area in the future and to add local transit routes to significant origins and destinations with the project area

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control. (https://www.fresno.gov/transportation.fax.history.)17 While the RDEIR depends on FAX services as mitigation for potential transportation impacts, no details whatsoever as to service timing or extent is provided (see, MMTRANS 1-d, RDEIR p. ES-50 [the entire text of this so-called Mitigation Measure is “MM TRANS-1d: Collaborate with Fresno Transit (FAX) to provide new transit services to the proposed project and within the proposed project area.”]) Without details of how the high-quality transit service upon which the EIR relies to reach various conclusions as to lack of significant impacts from the Project on air quality, climate change, and VMT will be provided – or funded - the conclusions reached by the EIR that rely on FAX’s future transit service to the SEDA area are speculative and unsupported by substantial evidence.18

9. No Substantial, Quantified Evidence Supports The RDEIR’s Conclusion That No Mitigation Is Required.

The RDEIR states that Legislature and the California Air Resources Board (“CARB”) have determined that local areas must reduce vehicle miles traveled (VMT”) by prescribed amounts; this will reduce GHG emissions. The RDEIR reports that:

Fresno County targets for SB 375 are a 5 percent per capita reduction by 2020 and a 10 percent per capita reduction by 2035 relative to 2005 levels. (SB 375 is implemented with the Fresno COG RTP/SCS).
(RDEIR, p.3.8-44.) The RDEIR goes on to assert:

The strategies included in the proposed Fresno SEDA Specific Plan are consistent with the measures included in the RTP/SCS [the transportation and sustainable community plan required by SB 375] and would serve to support a per capita reduction in VMT in the Plan Area after the implementation of the proposed project.
(Ibid.) This is a wholly qualitative analysis, providing no quantitative proof that the mandated VMT reductions will be met, either by the Fresno area as a whole or the 17 The EIR itself points out the importance of City control of polluting facilities. See EIR, p. 3.6- 14, regarding municipal facilities: “It is important to include greenhouse gas reductions and energy conservation at City facilities, over which the City has direct control and can allocate resources for this purpose.” Surely this control and ability to allocate resources is also true of City agencies like FAX, and can be used to devise and carry out mitigation. 18 CEQA Guidelines section15150 provides that references to material outside the EIR are permitted, but mandates that they do have to be locatable through citations or other means of identifying and finding the material. There are no such guideposts in the EIR to FAX’s future plans.

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Project. No calculation of the per capita reduction in VMT that the SEDA strategies would “support” is made.

Instead, the RDEIR takes the position that if SEDA does not openly and specifically contradict CARB’s Scoping Plan to meet the statutory GHG emissions reduction goals and the SB 375-mandated VMT reduction targets, that the Project will not have any significant adverse impacts on the State’s climate goals or the SB 375- required reductions, even as it will cause millions of metric tons of GHGs to be added to the atmosphere. (RDEIR, p. 3.8-44.) So long as Fresno does its unquantified “fair share” to not obstruct to the Scoping Plan through approving the SEDA Project, the RDEIR concludes that the Project will have no significant impact on the environment or the State’s attempts to meet its climate goals. (RDEIR, p.3.8-56.) No mitigation measures are proposed or adopted.

This analysis and the RDEIR’s conclusions of no significant impact and no significant cumulative impact are not supported by quantified analysis or specific, substantial evidence. They are invalid.

C. GHG/Climate Change Impacts Are Not Adequately Analyzed or Mitigated.

As with its analysis for conventional air pollutants, the DEIR’s analysis for greenhouse gas (GHG) emissions fails to provide the most basic information to the decision makers and the public. It also fails to adopt all feasible mitigation measures for the impacts of its emissions of climate-forcing gases, and it appears to be selfcontradictory as to what the standard is as to the significance of those emissions.

1. The GHG Analysis Fails as an Informational Document
While the DEIR bestows considerable attention on the existing legal framework of the federal and state laws and regulations applicable to GHG emissions, it is remarkably short on information as to the GHG emissions to be expected from the Project. Like its description of SEDA emissions of conventional and toxic pollutants, described above, the DEIR provides only very limited information on the GHG emissions to be expected from the Project, and downplays the significance of those it does acknowledge.

In Table 3.8-2, at page 3.8-44, the DEIR sets out the Project’s expected GHG emissions from construction. These are reported year by year for the years 2024 to 2043 (only 19 years from now, despite the DEIR’s statement that “[b]uildout of the proposed project would occur over approximately 25 years, or longer” at page 3.3-57).

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The emissions expected from construction total 2,316,578 tons of carbon-dioxide equivalent GHGs.19 The DEIR downplays the potential significance of this emission of over two million tons of GHGs by saying that “[s]hort-term construction GHG emissions are a one-time release of GHGs and are not expected to significantly contribute to global climate change.” (DEIR, p. 3.8-44.) This is nonsensical, since the fact that construction emissions are “one-time” for each individual project is somewhat meaningless, given that the DEIR has already shown that GHGs can remain in the atmosphere for decades or even centuries; carbon monoxide itself has a residency time of 50 to 200 years. (DEIR, p.

3.8-4.) It is their long period of residence in the atmosphere that enables GHGs emitted anywhere in the world able to affect the entire planet, as the DEIR observes at page 3.3-6 (“GHGs have long atmospheric lifetimes, several years to several thousand years. GHGs persist in the atmosphere for a long enough time to be dispersed around the globe.”) The DEIR itself states that “although it is unlikely that a single project will contribute significantly to climate change, cumulative emissions from many projects affect global GHG concentrations and the climate system.” (DEIR p.3.8-7.) The Project’s construction emissions cannot be made less than significant by calling them “one-time,” since their effects will last for many decades or even for centuries.

As it does with the Project’s expected emissions of conventional pollutants, the DEIR provides the Project’s expected operational GHG emissions for only one year:
2050. (DEIR, Table 3.8-3, at p. 3.8-45.) The DEIR reports a surprisingly low total:
515,791 tons of GHGs. (Id.) We note that 2050 is the time by which the state is expected to carry out its many programs to reduce GHG emissions, including mandating zeroemission cars, setting low carbon fuels, reducing the carbon footprint of transporting water, and mandating electricity that is mostly or exclusively produced by non-carbon, renewable sources. (DEIR, p. 3.8-49.) Therefore, the 2050 GHG figure is almost certainly not representative of the Project’s GHG emissions in all, or even most, of the years of its operation, before all the state programs have had full effect.

The DEIR is required to make a good-faith effort to discover and provide all the information it can. (CEQA Guidelines §§ 15003(i), 15144.) Here, the City had enough information to provide the expected total 2050 GHG emissions from operations. It also had enough information to provide the expected the GHG emissions from construction for each year between 2024 and 2043, showing that it has data on the expected year-by19 Because of the widely divergent longevity in the atmosphere of various GHGs, they are usually described in terms of the amount of their climate-forcing ability when compared with a single GHG, viz., carbon monoxide. This is called carbon monoxide equivalence. (DEIR, p. 3.8-

3.)

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year pace of construction and, by extension, on the pace at which SEDA projects would begin to operate. The DEIR used a widely accepted computer modeling system to predict the GHG emissions from the Project.

The short-term construction-related and long-term operational GHG emissions associated with future buildout of the Plan Area allowed under the proposed Specific Plan were estimated using California Emissions Estimator Model (CalEEMod) Version 2020.4.0. CalEEMod is a Statewide model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify GHG emissions from land use projects.

The model quantifies direct GHG emissions from construction and operation (including vehicle use), as well as indirect GHG emissions, such as GHG emissions from electricity use, solid waste disposal, vegetation planting and/or removal, and water use. Emissions are expressed in annual metric tons of CO2 equivalent units of measure (i.e., MT CO2e), based on the GWP of the individual pollutants.
(DEIR, p. 3.8-43, italics added.) CalEEMod would have given the City information on the operational GHG emissions from the Project. With all this information, the DEIR could -and should- have provided approximate figures on the Project’s operational GHG emissions year by year, giving the decision makers and the public a much better understanding of the amount of GHGs that would be emitted by SEDA. As it is, the DEIR has not performed a good-faith analysis and has not provided all the information it can. It does not comply with CEQA and cannot support the approval of the Project.

D. The EIR Fails to Address the Consequences of the City’s General Plan Deficiencies.

1. The City General Plan is Inadequate and its Deficiencies Preclude Approval of SEDA, Since Such Approval Relates to the General Plan’s Deficiencies.

The general plan is the “constitution for future development ... located at the top of the hierarchy of local government law regulating land use .... " (DeVita v. Napa (1995) 9 Cal. 4th 763, 773, internal citations omitted.) Government Code section 65300.5 requires that all general plan elements be consistent with one another. County and city zoning ordinances also must be "consistent with the general plan." (Gov. Code § 65860(a); San Francisco Tomorrow v. City and County of San Francisco (2014) 229 Cal.App.4th 498, 508-509.) If a city or county’s general plan is inadequate, it cannot support project approvals. (Camp v. Board of Supervisors (1981) 123 Cal. App. 3d 334, 352 [County could not approve subdivisions because some of its general plan elements were

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inadequate].) A permit may be challenged due to general plan inadequacy where the inadequacy is factually related to the characteristics or implications of the permit. (Garat v. City of Riverside (1991) 2 Cal.App.4th 259, 293.)

2. The General Plan Does Not Comply With AB 170.

AB 170, passed in 2003, enacted as Government Code section 65302.1 subdivision (b), requires that all cities and counties in the San Joaquin Valley amend their General Plans to add specific information on air pollution in their jurisdictions. This information must include “(1) A report describing local air quality conditions including air quality monitoring data, emission inventories, lists of significant source categories, attainment status and designations, and applicable state and federal air quality plans and transportation plans. (2) A summary of local, district, state, and federal policies, programs, and regulations that may improve air quality in the city or county. (3) A comprehensive set of goals, policies, and objectives that may improve air quality consistent with the strategies listed in paragraph (3) of subdivision (a). (4) A set of feasible implementation measures designed to carry out those goals, policies, and objectives.” (Govt. Code section 65302.1(c).) Government Code section 65302.1, subd. (e), set a deadline for compliance with GC 65302.1 of “no later than one year from the date specified in Section 65588 for the next revisions of its housing element that occurs after January 1, 2004.”
A publication by the San Joaquin Air Pollution Control District (bearing the revision date of 04/02/09) reads, “AB 170 requires cities and counties to comply no later than one (1) year from the date specified in Government Code Section 6588 for the next revision of the housing element after January 1, 2004 (Section 65302.1.e). Based upon the schedule outlined in the bill, jurisdictions in Fresno and Kern counties are required to adopt these amendments by June 30, 2009. Jurisdictions in Kings, Madera, Merced, San Joaquin, Stanislaus, and Tulare counties have until June 30, 2010 to comply.”] [Emphasis added.]. It appears the City has adopted no such amendment.

3. The City General Plan Has No Environmental Justice Element, an Element Mandated by SB 1000.

Effective January 1, 2017, SB 1000, codified as Government Code section 65302, subdivision (h)(2), required the adoption into cities’ and counties’ general plans of an Environmental Justice Element, or adoption of the objectives and policies of an Environmental Justice Element in other General Plan Elements, such Element to be adopted on the first occasion after January 1, 2018, when the city or county adopts or revises two or more general plan Elements. Until it actually adopts an Environmental

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Justice Element that fully complies with SB 1000, the City does not have an adequate General Plan, and may not approve development projects, including SEDA. The City claims to have adopted environmental justice policies (https://www.fresno.gov/wpcontent/uploads/2023/03/upload_temp_Consolidated-GP-10-13-2022_compressed.pdf, p. 1-11) but there is no environmental justice element in the General Plan nor specific identification of which policies the City claims address environmental justice issues.

4. The Project’s GHG Emissions Will Undercut the Effectiveness of Fresno’s Sustainable Communities Strategy.

Fresno's Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS), adopted in 2014 and updated in 2018 and 2022, was "intended to identify integrated land-use and transportation strategies that lower per capita GHG [greenhouse gas] emissions from cars and light-duty trucks, and foster communities that are more equitable, healthy, and sustainable."20 As required by SB 375, the Fresno RTP/SCS is based on assumptions about future development "that are consistent with adopted local general plans."21 And the RTP/SCS specifically relies on the City of Fresno's 2014 General Plan as a basis for changes in land use and transportation that will help meet state-mandated GHG reduction targets:

Scenario B [the basis for the land use projections in the 2022 RTP/SCS] was built primarily from existing local general plans, regional growth projections and insights from the REMI economic forecasting model. . . . The City of Fresno’s updated general plan calls for 50 percent of new growth in designated infill development areas and proposes no sphere of influence expansion through 2035, which will help rein in fringe development in a traditionally sprawling region. 22 Construction of thousands of acres of low-density development to the southeast of Fresno would vitiate these benefits, dramatically increase vehicle miles traveled, and make it impossible to meet state-mandated GHG reduction goals as contemplated in the RTP/SCS.
20 Fresno Council of Governments. 2022. Regional Transportation Plan & Sustainable Communities Strategy. Available at https://www.planfresno.com/sustainable-communitiesstrategies-fall-outreach/. 21 Fresno COG, 2022. 22 Fresno COG, 2022 (Emphasis added).

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E. The EIR’s Water Supply Analysis Is Inadequate.

The water supply for SEDA is only shown to be adequate up to 2035, and only if groundwater conditions do not change due to climatic changes or regulatory changes due to the Sustainable Groundwater Management Act.

The DEIR does not show that adequate water will be available to meet the anticipated demand from SEDA in addition to the demand from the rest of the City of Fresno past 2035, and not out to the purported build-out date (and the build-out date used in the Air Quality and Greenhouse Gas sections of the DEIR, as discussed earlier in these comments.)23
The City has long relied heavily on pumped groundwater to satisfy its water needs, as set out at DEIR, page 3-18-3. The DEIR states that prior to 2004, the City obtained 100 percent of its water from groundwater, but had reduced that by half in 2019 and 2020. (DEIR, p. 3.18-5.) However, the City is located over, and has been obtaining pumped groundwater from, the Kings River Subbasin, which has been designated as a critically overdrafted (i.e., over-pumped) basin. (DEIR, p. 3.18-4.) The Kings Subbasin is within the jurisdiction of the North Kings Groundwater Sustainability Agency (GSA), which is required under the Sustainable Groundwater Management (AB 1739 [Dickinson], SB 1168 [Pavley], and SB 1319 [Pavley]) to attain sustainability of groundwater basins by 2040. (DEIR, p. 3.18-3 to 4.)
Accordingly, the City has increased its purchases of surface water, obtaining surface water from the US Bureau of Reclamation (USBR)’s Central Valley Project and the Fresno Irrigation District (FID). The City is now attempting to recharge the Kings Subbasin, but the amount of water it can devote to recharge is less in dry years. (DEIR, p.

3.18-4 to 5.) The DEIR acknowledges that the water from the Central Valley Project is not always available, stating that “there have been extremely dry years in which no water is [sic] supplied”; this previously occurred in 2014 and 2015. (EIR, p. 3.18-6.) In those years, Fresno received only somewhat more than half of its usual Central Valley Project water.

The addition of 45,000 people in the SEDA Project will, of course, increase demand for water in Fresno. (DEIR, p. 3.18-7 [“Water supply for the Specific Plan Area 23 The DEIR is riddled with analyses that focuses on 2035 at the expense of analyzing to the 2050 horizon year. For example, see pages 3.14-13 (Land Use), 3.15-8 (Public Services), 3.15- 33 (also Public Services), p.3.17-32 (Transportation), and pages 2-5 and 406.

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will be met with existing supplies initially but will require additional supplies to meet buildout demands.”]) The DEIR acknowledges that additional pipe infrastructure will need to be planned, sited, and laid (DEIR, p. 3.18-10). Plans for doing so are sketchy, at best, and it is not clear that the air quality and GHG impacts of that construction were included in the emissions totals in Tables 3.3-8 and 3.8-2. If they are not so included, those Tables are incomplete and misleading, and must be revised in a recirculated DEIR.

The effects of supplying water in future years will impact other water users and must also be analyzed.

However, there is another, fundamental, problem with the DEIR’s analysis of water supply for the Project. The DEIR appears to analyze only the impacts of the Project on water supply to Fresno up to 2035 and not to 2050, when the full expected buildout and population of SEDA is expected. (Appndx. F, Water Technical Study, p.1.) The Fresno General Plan’s Horizon” date is 2035, although full buildout is not expected until 2050 or beyond. (Id.).

The DEIR analyzes water demand for SEDA only out to 2035. (Water Technical Study, pp. 24-25.) The analysis makes clear that the DEIR is not exact; many “reasonable assumptions” about demand have been made. (Water Technical Study, p. 19.) Still the most favorable (to the City and future developers) conclusion that the Technical Study can reach is that “existing City of Fresno water supplies could be sufficient to supply the future development in SEDA in addition to the existing demands.” (Water Technical Study, p. 24, italics added.). However, the Technical Study’s estimate of water supply to Fresno, including SEDA, bears the disclaimer that the conclusion is valid only “assuming groundwater characteristics are not altered due to climatic events or regulatory influences from SGMA.” (Water Technical Study, p. 24.) That same disclaimer appears in many discussions of groundwater in the main text of the DEIR (see DEIR, pp. 3.18-4, 5, 66, 67 and 68; RDEIR, p. 3.10-8, 9, 38, and 39).

The DEIR appears to base much of its analysis of groundwater availability on the premise that climate conditions will not change, and the North Kings GSA will not impose conditions that change the current situation. Given both the DEIR’s Table 3.8-2 (at p.3.8-11) showing the alarmingly high expected temperature increases in the Fresno area and the over-drafted condition of the Kings Subbasin together with the North Kings GSA’s legal mandate to restore over-drafted basins by 2040, it seems more than likely that the Kings Subbasin will experience changes that would not be in the DEIR’s favor.

The DEIR simply has not shown that water supply will be adequate for the Project to the buildout date of 2050, or even to the date most discussed in the Water Technical Study, 2035. The DEIR is both procedurally and substantively deficient as to water supply, and it should be revised and recirculated.

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F. The Final EIR Must Respond in Writing to Comments Made on the NOP and Draft EIR.

When the Notice of Preparation (NOP) was circulated for the SEDA project, you received various letter regarding the scope of the EIR. We request that you respond to each of these NOP comment letters as if they were a comment on the Draft EIR and RDEIR, especially the letters of the California Department of Fish and Wildlife and the California Department of Conservation.

Additionally, we specifically incorporate by reference the letter of Leadership Counsel for Justice and Accountability, CCEJN, Fresno Building Healthy Communities, and Fresno Barrios Unidos dated March 25, 2022. (https://www.fresno.gov/wpcontent/uploads/2023/07/Appendix-A-EIR-Noticing-and-Public-InvolvementCOMBINED.pdf, p. 70.) This letter rightfully comments as follows; we request that you respond to each of these points and every other point made in this letter:

First, given the significance of the SEDA to the future development of Southeast Fresno communities, it is of the utmost importance that the City proactively and meaningfully engage residents within and around the planning area. This means that the City must incorporate residents' input into the SEDA and EIR by revising land use designations to include community-led development like higher density housing, green space, affordable commercial and residential spaces, and so on. It must also have policies and implementation measures for active investment into Southeast Fresno neighborhoods by businesses and the City alike in essential infrastructure, services, amenities, and community greening. To do less is to perpetuate the long-held City practice of denying Southeast Fresno residents their rights to shape the future of their neighborhoods and access to opportunity on the same terms as other Fresno residents.

Below you will find additional comments in response to the Notice of Preparation:

I. The Proposed Land Use Map is Inconsistent with Local and State Climate, Housing, and Transportation Goals and Policies to Build Equitable Climate Resilient Communities

As previously noted, it is unclear and of significant concern to what extent authentic public participation took place during this process from over a decade ago. The former process took place at the tail end of the housing bubble when building single-family homes in the outskirts of the city limits was the priority and norm. This type of “leapfrog” development remains reflected in the SEDA land use map as a large portion of the 9,000 acres is zoned for low-density singlefamily housing. This is inconsistent with the current climate, housing, and transportation goals that aim to build communities with a variety of development

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and density to make them accessible to various incomes and for communities to get around by alternative modes of transportation.

Further, the second-largest land use is zoned for flexible research and development, which leaves space for more light industrial use, further industrializing south Fresno BIPOC [Black, Indigenous, and People of Color] communities. This current process is in stark contrast with other specific plans prepared and adopted by the City in recent years, which have emphasized resident self-determination in shaping their built environment, planning for complete and healthy communities, smart growth-promoting land use compatibility, and investment strategies and implementation measures designed to bring those plans’ vision to life. The City must not proceed with its efforts to further cement unjust and exclusive land-use patterns in City planning practices.

Fourteen years later, we have learned that this growth pattern is economically and environmentally unsustainable as the City now struggles to balance the need to build out the infrastructure and maintain public services in these communities while attending to decades of deferred maintenance in established neighborhoods.

This is reflected in the 2015 General Plan praised for limiting unsustainable sprawl growth and focusing on efficient infill development.
(Letter of Groups, pp. 1-2, available at https://www.fresno.gov/wpcontent/uploads/2023/07/Appendix-A-EIR-Noticing-and-Public-InvolvementCOMBINED.pdf, pp. 70 et seq of PDF.) G. Affordable Housing Must Be Promoted.

The RDEIR predicts that by 2050, approximately 31% of the City’s housing capacity -roughly one-third - will be located in the SEDA area. (RDEIR, p. 3.14-13.) Accordingly, it is vital to ensure that housing is available in the Project that is affordable to households of all income ranges. The Legislature has emphasized the importance of affordable housing in Government Code section 65580(f). While the RDEIR repeatedly states that the three principles around which the Project is organized are “fiscal responsibility, equity, and environmental sustainability” (see,e.g., RDEIR, pp. ES-1, 1-1, 2-7, 3.1-8, and elsewhere), the EIR itself reflects more of a commitment to rhetoric than to actual equity, at least as to affordable housing.

The actual Policies discussed in the RDEIR regarding affordable housing are overwhelmingly phrased as essentially aspirational, not mandatory. For example, Policies LU-2-b (concerning the potential creation of affordable housing incentives in infill areas) and Policy HC-2.2 (concerning the potential to use publicly owned land for affordable

SC-CVP-LWV

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March 24, 2025

housing through creation of a community trust to own such land for that purpose) both begin with “Consider,” making the execution of those policies voluntary and uncertain.

This tenuousness is even clearer in Policies UF-1-1 (regarding protection of “unique neighborhoods,” including those with affordable housing opportunities [at RDEIR pp.

3.1-4, 3.11-5]); LU-5-f (concerning designation of high-density neighborhoods to support [inter alia] affordable housing [at RDEIR pp. 3.3-28,3.11-8]); HC-2.3 (concerning the spreading of affordable housing throughout SEDA to avoid concentrations in any one area [at EIR, pp. 3.11-15,3.14-10]); and H-1-c ( concerning the development of affordable, special-needs housing near transit or smart-growth areas [at RDEIR, p. 3.14- 6, 3.14-10]). Each of these Policies begins with the word “Promote,” again making their execution difficult to monitor or evaluate.24
It appears that the City is more of a cheerleader than an actual leader in the effort to create additional affordable housing.

Conclusion.

The RDEIR must be revised and recirculated with proper instructions for commenting to the public and to public agencies.

Thank you for your consideration of these comments.

Sincerely,

Douglas P. Carstens
Michelle Black
24 Nor is this hesitancy to require action, not merely endorse it, limited to affordable housing. A word search showed the word “promote” was used 159 times in the RDEIR.

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25 CONT
City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-321
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 Sierra Club, Central Valley Partnership, and League of Women Voters (SC-CVP-LWV) Response to SC-CVP-LWV-1
The comment is noted. 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.

Response to SC-CVP-LWV-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.

Response to SC-CVP-LWV-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 SC-CVP-LWV-4
The comment is noted. Please refer to Response to SC-CVP-LWV-5 through Response to SC-CVP-LWV25. No further response is required.

Response to SC-CVP-LWV-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.

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.

Future development associated with the proposed project would be required to comply with applicable General Plan policies, as well as policies contained within the proposed Specific Plan. All future development in the Plan Area would require environmental review pursuant to CEQA and implement feasible mitigation, as necessary. No further response is required.

Response to SC-CVP-LWV-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.

Response to SC-CVP-LWV-7
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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-322 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 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.

As discussed in Section 3.2, Agricultural Resources and Forestry Resources, of the Draft PEIR, the proposed project would include a Buffer District, which would discourage expansion by clearly delineating the urban-rural edge, unlike the patchwork of rural ranchette development typically found at the rural outskirts of cities. Future development associated with the proposed project would be required to comply with applicable General Plan policies, as well as policies contained within the proposed Specific Plan. All future development in the Plan Area would require environmental review pursuant to CEQA and implement feasible mitigation, as necessary, and MM AG-1 requires mitigation for the potential loss of important farmland. No further response is required.

Response to SC-CVP-LWV-8
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.

The comments regarding pending legislation and regulations are noted, but do not have any relevance related to a CEQA level analysis which must provide evaluation against thresholds in place at the time of the NOP. The air quality impacts are fully disclosed in Section 3.3, Air Quality, of the Recirculated Draft PEIR. As noted in the comment, the analysis correctly identifies the impacts as being significant. Therefore, the analysis applied relevant mitigation in accordance with the projectspecific mitigation measures that would ensure future developer applicants must analyze projectspecific air quality emission impacts and identify mitigation measures to reduce impacts to less than significant. The analysis concluded that implementation of the Specific Plan could result in a significant and unavoidable air quality emissions impact. No further response is required.

Response to SC-CVP-LWV-9
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.

The Recirculated Draft PEIR fully analyzes project consistency with the Air Quality Plan (AQP) by demonstrating whether the proposed project would (1) conform to the growth assumptions in the AQP, and (2) comply with applicable control measures in the AQP. The City, as Lead Agency, has elected to utilize this industry standard approach for analyzing consistency with AQP because:
• AQP emissions inventories and attainment modeling are based on growth assumptions for the area within the air district’s jurisdiction.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-323
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 • AQPs rely on a set of air district-initiated control measures, as well as implementation of federal and State measures, to reduce emissions within their jurisdictions, with the goal of attaining the air quality standards.

The Valley Air District has prepared several plans to attain the National Ambient Air Quality Standards (AAQS) and California AAQS. Emission reductions achieved through implementation of the Valley Air District’s new source review (NSR) offset requirements are a major component of the Valley Air District’s AQPs. The established thresholds of significance for criteria pollutant emissions are based on the Valley Air District’s offset requirements for stationary sources. Therefore, projects with emissions below the thresholds of significance for criteria pollutants would be determined to “not conflict or obstruct implementation of the District’s air quality plan.” However, as discussed under Impact AIR-2, due to the size of the proposed development, the proposed project could locally exceed State or federal air quality standards and significantly contribute to cumulative nonattainment pollutant violations under cumulative conditions. Because the recommended Valley Air District significance thresholds are based on, and intended for, individual projects and not planning-level projects such as the proposed project, there is not mitigation available that would reduce the criteria pollutant emissions from the entire proposed plan’s construction or operation to less than significant levels in comparison to the Valley Air District’s project-level thresholds. Thus, the Recirculated Draft PEIR conservatively concluded that implementation of the proposed Specific Plan would result in an increase in the frequency or severity of existing air quality violations; cause or contribute to new violations; or delay timely attainment of the AAQS.

All future implementing projects subject to CEQA must adhere to MM AIR-1a through MM AIR-1d and MM AIR-4, which require construction and operational-level analysis for criteria pollutants and TACs, to reduce significant air quality impacts. This approach is consistent with Section 15152 of State CEQA Guidelines for preparing first-tier environmental documents.

The Recirculated Draft PEIR CalEEMod analysis evaluated the entire Specific Plan buildout and the entire construction schedule was normalized to a 6,874-working day (i.e., 26-year) schedule. This is consistent with the statement that buildout of the proposed project would occur over approximately 25 years or later. Because the analysis conservatively and reasonably assumes overlapping between future implementing projects, the entire construction duration reflected an overlapping schedule that would last from 2024–2043. If construction is moved to later years (e.g., buildout by 2050), this analysis would be considered even more conservative due to technological advancement in construction equipment such as phasing out of diesel equipment.

As identified in Section 3.3, Air Quality, of the Recirculated Draft PEIR, at a programmatic level, quantification of DPM from future project construction and operations would be speculative.

However, the analysis does appropriately identify that implementation of MM AIR-1a through MM AIR-1d, future development projects subject to environmental review under CEQA would be required to analyze potential TAC emissions and include mitigation as appropriate. However, the analysis concluded that even with implementation of these measures, cumulative operational emissions resulting from future development would likely exceed Valley Air District thresholds, City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-324 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 contributing to the nonattainment designation of the San Joaquin Valley Air Basin (SJVAB) for the health-based State and national AAQS. Therefore, the potential impacts from the proposed project to sensitive receptors would be significant and unavoidable. Therefore, the analysis meets the requirements under CEQA for evaluating programmatic level impacts and identifies measures to reduce those impacts at the project level.

The analysis in Section 3.3 Air Quality, of the Recirculated Draft PEIR, shows the quantification of construction emissions under full buildout conditions, and quantification of project operations, based on the level of detail available at the time of the preparation of this document. The analysis requires implementation of MM AIR-1a through MM AIR-1d to reduce air quality emission impacts to less than significant at the project level. The comment does correctly identify that the analysis in the Recirculated Draft PEIR concludes that even with implementation of project-specific mitigation measures, cumulative operational emissions resulting from future development would likely exceed Valley Air District thresholds, contributing to the nonattainment designation of the SJVAB for the health-based State and national AAQS. The potential impacts from the proposed project to sensitive receptors would be significant and unavoidable. Therefore, the analysis meets the requirements under CEQA for evaluating programmatic level impacts and identifies measures to reduce those impacts at the project level. No further response is required.

Response to SC-CVP-LWV-10
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.

The analysis in Section 3.3, Air Quality, of the Recirculated Draft PEIR, shows the quantification of construction emissions under full buildout conditions, and quantification of project operations, based on the level of detail available at the time of the preparation of this document. The analysis requires implementation of MM AIR-1a through MM AIR-1d and MM AIR-4 to reduce air quality emission impacts to less than significant at the project level. Therefore, the analysis meets the requirements under CEQA for evaluating programmatic level impacts and identifies measures to reduce those impacts to less than significant at the project level. No further response is required.

Response to SC-CVP-LWV-11
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.

The analysis in Section 3.3, Air Quality, of the Recirculated Draft PEIR requires implementation of MM AIR-1a through MM AIR-1d and MM AIR-4 to reduce air quality emission impacts to the greatest extent feasible at the project level. Section 21081.6 of the 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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-325
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 occurs during project implementation. The MMRP contains specific timing requirements and verification procedures to ensure enforceability of mitigation measures.

The Recirculated Draft 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 SC-CVP-LWV-12
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 described in the text preceding Section 3.3, Air Quality, Table 3.3-9 of the Draft PEIR, it “shows the net daily operational emissions for full buildout of the proposed project in 2050.” Thus, it is identifying the anticipated maximum annual operational emissions that would be expected to occur under full buildout of the proposed project. Thus, the analysis has provided full disclosure and identified the reasonable worst-case annual emissions associated with implementation of the proposed project.

The comment also erroneously implies that ozone impacts were not fully disclosed. However, as explained in Section 3.3, Air Quality, on page 3.3-47 of the Recirculated Draft PEIR, ozone is a secondary pollutant that can be formed miles from the source of emissions, through reactions of ozone precursors, such as reactive organic gas (ROG) and NOX emissions in the presence of sunlight.

The contribution of ozone precursors to a region’s ambient ozone concentrations is the result of complex photochemistry. Because of the reaction time involved, peak ozone concentrations often occur far downwind of the precursor emissions. Therefore, ozone is a regional pollutant that often affects large areas. In other words, because of the complexity of ozone formation, the pounds or tons of emissions from a proposed project in a specific geographical location does not equate to a specific concentration of ozone formation in a given area, because in addition to emission levels, ozone formation is affected by atmospheric chemistry, geography, and weather. Because Valley Air District attainment plans and supporting air model tools are regional in nature, they do not allow for analysis of the health impacts of specific projects on any given geographic location.

In contrast to attainment models, CalEEMod (one of the models used by the City in conducting air quality analyses) is designed to calculate and disclose the total emissions expected from the construction and operation of a proposed project (tons/year). The estimated emissions are then compared to Valley Air District significance thresholds, which are in turn keyed to reducing emissions to levels that will not interfere with the region’s ability to attain the federal and State ambient air quality standards. This protects public health in the overall region, but there is currently no methodology to determine the impact of emissions on concentration levels in specific geographic City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-326 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 areas. Neither the Valley Air District nor any other air district currently have methodologies that would provide lead agencies and CEQA practitioners with a consistent, reliable, and meaningful analysis to correlate specific health impacts that may result from a proposed project’s total emissions. Therefore, the analysis of direct health impacts due to emissions from future is not yet feasible.

In contrast to regional attainment models and techniques to calculate total emissions for projects, methodologies are available to prepare Ambient Air Quality Assessment (AAQA) and HRA evaluations of the health effects on a detailed, project-specific basis. These assessment techniques require a large amount of detail regarding a proposed site-specific project and nearby receptors, and the data necessary to scale up these types of analyses to a Plan Area-level would be infeasible and would involve an undue level of speculation regarding the detailed operations of future land uses and receptors.

Based on the foregoing, the City believes that the assumptions that would be used in the requested analysis would be unduly speculative, and that there are currently no emissions models or methodologies available that are consistent and reliable enough to prepare a meaningful analysis of the specific health effects from county-wide air emissions.

Therefore, the analysis meets the requirements under CEQA for evaluating programmatic level impacts and identifies measures to reduce those impacts to less than significant at the project level.

As stated on page 3.3-38 of the Recirculated Draft PEIR, analysis was performed consistent with the guidance and methodologies provided by the Valley Air District’s Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI). In addition, the modeling assumptions and input and output modeling data are all included in Appendix B of the Recirculated Draft PEIR. As shown in the modeling data, the drop in emissions is due to the CalEEMod default emission factors for construction equipment in future years accounting for State off-road equipment regulations that ensure cleaner fleets will be operating in future years. This information is fully disclosed in the Recirculated Draft PEIR, and the analysis meets the requirements under CEQA for evaluating programmatic level analysis. No further response is required.

Response to SC-CVP-LWV-13
The comment explaining recent case law and ARB recommendations is noted. The comment that the Recirculated Draft PEIR does not discuss the disparate effects air pollutant emissions increases may have on the disadvantaged communities within SEDA and elsewhere within the City 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.

Exceeding the Valley Air District’s project level thresholds does not constitute a particular health impact to an individual nearby because project-level thresholds are in tons/year emitted into the air, whereas health effects are determined based on the concentration of a pollutant in the air at a City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-327
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 particular location. Localized health impacts would be addressed at the project-level when future discretionary projects are being considered. In addition, the analysis does apply mitigation that would reduce health risk impacts on a project-specific level. For example, the analysis applies MM AIR-1c, which requires proposed industrial or warehouse projects prepare an HRA in accordance with policies and procedures of the most current State Office of Environmental Health Hazard Assessment (OEHHA) and the Valley Air District. This measure also includes a list of control technologies for toxins that could be used to reduce potential localized health impacts.

Therefore, the analysis meets the requirements under CEQA for evaluating programmatic level impacts and identifies measures to reduce those impacts to less than significant at the project level.

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 require CEQA analysis on a project-by-project basis as necessary. There are currently no emissions models or methodologies available that are consistent and reliable enough to prepare a meaningful analysis of the specific health effects from county-wide air emissions. Therefore, the analysis meets the requirements under CEQA for evaluating programmatic level impacts and identifies measures to reduce those impacts to less than significant at the project level. No further response is required.

Response to SC-CVP-LWV-14
The comment is noted. 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. 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 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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-328 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 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, 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. No further response is required.

Response to SC-CVP-LWV-15
The comment is noted. 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. 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 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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-329
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 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, 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. No further response is required.

Response to SC-CVP-LWV-16
The Recirculated Draft EIR is a program level analysis and, as such, does not include specific analysis of any specific future development. 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. The Fresno Clovis Metropolitan Area (FCMA) Short Range Transit Plan (SRTP) proposes specific recommendations for implementing the long-range objectives of Fresno County's 2022-2046 Fresno COG RTP/SCS and will guide the provision of transit services in the FCMA over the next 5 years. There are plans to extend the Fresno bus rapid transit line (Route 1) into the Plan Area in the future and to add local transit routes to significant origins and destinations. To implement these extension plans, MM TRANS-1d requires collaboration with the Fresno Area Express (FAX) to provide new transit services to the proposed project and within the proposed project area. The City may appropriately rely on the information in the SRTP in analyzing impacts associated with the proposed project. No further response is required.

Response to SC-CVP-LWV-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.

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. Additionally, please refer to Response to SC-CVP-LWV-14 and Response to SC-CVP-LWV-15. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-330 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 SC-CVP-LWV-18
The comment is noted. For informational purposes, the Recirculated Draft PEIR disclosed a worstcase scenario of GHG emissions resulting from construction of the described potential land use development all occurring at the same time. This high-level approach is consistent with the proposed project’s program-level environmental analysis that serves as a “first-tier” document to assess and document the broad environmental impacts of the Specific Plan with the understanding that more detailed site-specific environmental reviews may be required to assess future projects implemented under the program.

Further, the construction analysis is conservatively based on emissions from a baseline construction year that does not incorporate a year-by-year profile of the future truck emissions as new trucks are phased into the off-road fleet mix over the next 30 years. Trucks used for construction and operations would meet United States Environmental Protection Agency (EPA) and California Air Resources Board (ARB) regulatory requirements that would ensure there would be a higher percentage of alternatively fueled and clean trucks on the road. Quantifying these future reductions for inputs to the construction emissions would be speculative on a quantitative basis.

The analysis also identified that implementation of individual development project-specific mitigation measures presented in Section 3.3, Air Quality, of the Recirculated Draft PEIR would further reduce construction-related GHG emissions. For instance, MM AIR-1a would require the use of “Super-Compliant” architectural coatings during construction to reduce the generation of volatile organic compound (VOC) emissions, which are also GHGs with low global warming potential (GWP).

The analysis identified that with implementation of these project-specific measures, construction GHG emissions would be reduced to less than significant on an individual project-by-project development basis.

As explained above, the proposed project’s GHG significance is determined based on consistency with the applicable State, regional, and local plans and policies. Because the GHG construction emission quantification was presented for informational purposes only and future implementing projects would need to demonstrate consistency with the applicable plans and policies, the Draft PEIR appropriately disclosed GHG impacts, and no further analysis is needed.

Response to SC-CVP-LWV-19
The comment is noted. Please refer to Response to SC-CVP-LWV-20 through Response to SC-CVPLWV-22. No further response is required.

Response to SC-CVP-LWV-20
The comment is noted. This comment raises questions regarding the adequacy of the General Plan itself and does not raise any issues concerning the sufficiency of the Recirculated Draft EIR in identifying and analyzing the possible impacts on the environment or ways in which the project’s significant effects might be avoided or mitigated, especially specific alternatives or mitigation measures. See State CEQA Guidelines Section 15204. Comments regarding the sufficiency of the General Plan will be forwarded to the decision-makers; however, as they do not raise any environmental issues, no further response is necessary.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-331
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 SC-CVP-LWV-21
The comment is noted. This comment states that the General Plan does not include an environmental justice element. This comment does not raise any issues regarding the analysis or conclusions in the Recirculated Draft PEIR. CEQA requires an analysis of “the physical changes in the environment which may be caused by the project.” State CEQA Guidelines Section 15064(d). CEQA requires such an analysis irrespective of socio-economic status. The Recirculated Draft EIR evaluated potential impacts in accordance with the Public Resources Code and State CEQA Guidelines. 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. As discussed in this Master Response, the lead agency will consider these factors in making a decision on project approval; however, the scope of the Recirculated Draft PEIR focuses on potential adverse physical impacts to the environment associated with the proposed project. No further response is required.

Response to SC-CVP-LWV-22
The comment is noted. The proposed project’s consistency with the Regional Transportation Plan (RTP) prepared by the Fresno Council of Governments (Fresno COG) is discussed in Section 3.6, Energy, Section 3.8, Greenhouse Gas Emissions, and Section 3.17, Transportation and Traffic. As discussed in the Recirculated Draft PEIR, average VMT per capita under existing conditions for the City is 13.1 miles compared to 16.2 miles for the County of Fresno (approximately 19 percent less than the county average). Through the implementation of the General Plan, in 2035, the City VMT per capita (16.5 miles) is forecast to be 17 percent less than the County VMT per capita (19.9 miles).

Corresponding numbers for VMT per employee indicate that the City average is forecast to be 13 percent lower than the 2035 County average. This is a greater reduction in VMT than forecast by the Fresno COG in the RTP, a 12 percent reduction in VMT for the RTP project. The buildout of the proposed project would serve to further reduce VMT per capita in the region by locating highdensity housing near service amenities and jobs. As such, the proposed project is appropriately analyzed for consistency with the RTP. The buildout of the proposed project would serve to further reduce VMT per capita in the region by locating high-density housing near service amenities and jobs. Total VMT for the SEDA Specific Plan was calculated by multiplying daily volumes on the projected network by distance traveled. As described above and in the Recirculated Draft PEIR, the VMT per Service Population in the project area with the project built out in 2035 drops from 45.72 to

5.07 although total VMT is projected to increase due to population and employment growth. As such, the Recirculated Draft PEIR found a less than significant impact related to VMT in Impact TRANS-2.

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 SC-CVP-LWV-23
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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-332 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 SC-CVP-LWV-24
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. No further response is required.

Response to SC-CVP-LWV-25
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 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.

From: Brett Thompson
To: Brett Thompson; LongRangePlanning; Sophia Pagoulatos; Patience Milrod; Jerry Dyer; Mike Karbassi; Miguel Arias; Tyler Maxwell; Luis Chavez; Garry Bredefeld; Nelson Esparza; Thomas Esqueda; TJ Miller; Jeff Wabbit; helen ramming; Wes Bigham; Moses Deleon; Sandi Sandberg; Carol Bloesser; Daniel O"Connell; Marilyn Mathew; Jerry Prieto; Gene Branch; Lyle Nelson; Betty Cederquist; Deborah Bigham Subject: [WARNING: UNSCANNABLE EXTRACTION FAILED]SEPO Letter of Opposition to proposed SEDA plan Date: Monday, March 24, 2025 4:38:45 PM
External Email: Use caution with links and attachments
City of Fresno
Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street Room 3065
Fresno, Ca 93721
[email protected]
We the People of Southeast Fresno, specifically the Southeast Property Owners (SEPO) thank you for the opportunity to comment on the proposed Southeast Development Area (SEDA) plan’s Recirculated Environmental Impact Report.

We are writing to express our opposition to the City of Fresno’s Southeast Development Area (SEDA) plan, particularly due to the significant adverse environmental impacts it could have on our county and surrounding ecosystems. While the objectives of the plan to SEPO

SE 1
PO
promote energy sustainability are commendable, we believe the implementation as currently outlined may lead to unintended consequences that would negatively affect our environment, wildlife, and quality of life.

The City of Fresno proposed the SEDA plan to residents as:

Can Fresno grow in ways that equitably expand our economy and housing stock while protecting public health? Can “greenfield” growth occur that pays its own way and does not negatively affect existing neighborhoods? Can we build communities where schools, shopping, and parks are within walking distance of every student, worker, and resident? Can we attract and keep highly educated workers and raise collective potential of our diverse population? The City of Fresno Suggests “YES” while the Environmental Impact Report says “No” to most of these questions!

1. The proposed plan to expand our economy and housing stock would generate an estimated 500,000 TONS of Carbon Emissions subjecting residents to unhealthy breathing conditions.

2. Without an attached budget for the SEDA plan the City’s suggestion that this plan can pay it’s own way is a lie! Listed below are some of the many negative affects incited on existing neighborhoods through buildout of the SEDA plan:
following topical areas of concern:

Aesthetics, Light, and Glare
Agricultural Resources and Forestry Resources Air Quality Biological Resources
Cultural Resources and Tribal Cultural Resources Energy Geology, Soils, and Seismicity
Greenhouse Gas Emissions
Hazards and Hazardous Materials
Hydrology and Water Quality
Land Use and Planning Mineral Resources
Noise
Population and Housing Public Services
Recreation
Transportation and Traffic Utilities and Service Systems Wildfire SEPO

1 CONT
Mandatory Findings of Significance

3. The plan proposes building 45,000 housing units and providing 37,000 jobs. This calculation equals .822 jobs per household, this is without job competition from residents living outside the SEDA. How can residents walk to work if the plan doesn’t even propose enough jobs for a 1:1 (house to job) ratio?
A public trails plan has not been released to the public for the SEDA plan, how does the City propose a plan reliant on reducing vehicle miles traveled through citizens accessing jobs, school, shopping, and parks without proposing a plan for a trails system? First and foremost, the potential for increased urban sprawl is a major concern. As Fresno expands to accommodate new energy infrastructure, public utilities, and residential developments, this may result in the encroachment of your city into valuable natural habitats. These habitats are vital to preserving biodiversity, and further urbanization will fragment ecosystems, placing pressure on wildlife populations and reducing critical open spaces. The loss of these areas, particularly agricultural lands, could also diminish local food production, which is an already precarious issue given the state’s water and regulatory challenges.

To show the City of Fresno’s planning department lacks the ability to plan city expansion in a safe manner, we present to you the City of Fresno willful disregard to Southeast property owners health. The City of Fresno’s planning staff scheduled an informative event on July 24th 2023 at 5pm at the Hmong Alliance Church located at 8234 E. Belmont Fresno, Ca 93727. This event was part of a required 4 part seminar to present and educate residents of the City’s proposed SEDA Development Plan. City planning staff obtained a conference room to host their meeting at 5pm with weather conditions of extreme heat advisory (108degrees) without a working air conditioner to cool the room to safe standards, fans or air circulation devices were not available to comfort attendees. Doors were propped open to hopefully catch a draft. Residents who remained at the meeting used pamphlets and educational printouts as cooing aids by way of fanning our faces, many residents couldn’t bare the heat and were forced to leave the seminar due to health concerns of overheating, food was provided by City Planning staff and left exposed to unhealthy storage temperatures. Many of our residents are elderly and cannot sand for long periods of time.

Prior to the start of the event, Sophia was overheard instructing planning staff members to “stack chars behind information boards to prevent them from sitting and to keep them moving”
At two “drop in” events the grassroots group (SEPO), a group of homeowners currently living within the proposed SEDA, was told their educational literature could not be distributed on the grounds the meetings were hosted on: this was seen as an attempt to limit free speech. These events were hosted on publicly funded school sites further worsening City Planning Staff’s attempt of silencing opposition.

At “drop in” meetings hosted at Sequoia Elementary on July 27th 2023 and “drop in” meeting hosted at Young Elementary on August 12, 2023 City planning staff requested Fresno Police Department officers presence. These officers positioned their patrol car, with engine running at the entrance gate. Multiple Armed officers were positioned near the SEPO

2 3
4 entrance of the auditorium as a show of force by City of Fresno Planing Staff. Many residents were uncomfortable with armed personnel watching over the meeting some were observed entering the parking lot and leaving once they saw police presence. ***The City planning staff lacks the ability to plan a “healthy, safe and comfortable” informational meeting, while at the same time asking residents to trust City Planning Staff to develop a plan to expand their city limits with citizens health a priority? Budget,Budget Budget! We demand an estimated Budget and an extension to the public comment period for the Recirculated EIR a minimum of 30days past the release of the estimated Budget!
Dear Public Records Officer,
I am writing to formally request the release of documents related to the estimated budget for the SEDA plan that was delivered to City Manager Georgeanne White in December 2024.

This request is made under the California Public Records Act (Gov. Code § 7920.000 et seq.), which grants public access to government records in the interest of transparency and accountability.

According to a March 3, 2025, FresnoLand publication by Gregory Weaver, officials have yet to publicly disclose a cost estimate, despite consultants providing one in December 2024.

Additionally, during a December 13, 2024, meeting, Councilmember Arias referenced an estimated range between $500 million and $4 billion for the SEDA plan. City Manager Georgeanne White stated that a more specific figure would be released to the public within 90 days. As that timeframe has now passed, we request the immediate release of this financial estimate, as previously promised.

We acknowledge the City’s previous response citing the deliberative process privilege as a basis for withholding the requested records. However, we respectfully challenge this exemption as applied in this case. The budget estimate in question is a factual financial document rather than a pre-decisional deliberative record. The California Supreme Court has recognized that factual information contained within deliberative materials is not necessarily exempt from disclosure. In Times Mirror Co. v. Superior Court (1991) 53 Cal.3d 1325, 1338, the court ruled that the deliberative process privilege applies when disclosure would expose the decision-making process in such a way as to discourage candid discussion within an agency. However, it does not categorically shield all financial records or estimates from public scrutiny.

SEPO

4 CONT
5 Furthermore, under Evid. Code § 1040, the public interest in non-disclosure must clearly outweigh the public interest in disclosure. Given that public funds were used to generate this budget estimate, and considering the importance of transparency in government spending, we argue that the public interest in disclosure outweighs any speculative harm from release.

If certain portions of the requested records are deemed exempt, I request that any reasonably segregable portions be provided. If this request is denied in whole or in part, please provide a written explanation citing the specific legal basis for withholding the records, as required under the Public Records Act. We would appreciate a response within the statutory timeframe. You may reach us via the contact information provided.

A citizen has, through submission of a Public Records Request reference #R074276-030425 requested the release of the SEDA plan estimated budget as presented to City Manager Georgeanne White in December of 2024. The City of Fresno has delayed and refused release of this pertinent information.
***How can citizens reply with comment in full detail to the EIR “Fiscal Impact” section if the City is deliberately withhold the budget information? The City planning Department is proposing a massive development plan without releasing the estimated budget to citizens prior to the closure of the public comment period of the recirculated EIR. Taxpayer money was spent by government officials to hire an independent firm to quantify the estimated expense of this proposed project. We the People of Southeast Fresno demand the City extend the public comment period on the proposed Southeast Development Area EIR, a minimum of 30days past the release of the budget by city officials. We also demand all comment letters submitted against the Draft EIR along with comment letters submitted against the Recirculated EIR be included on any future revisions or releases to EIR documents. Silencing community input due to recirculation is unacceptable. Withholding important decision making information is not acceptable and inappropriate.

As proposed in the Recirculated EIR: Executive Summary-2 Fiscal Responsibility:
• Provide self financing for the development and ongoing maintenance of the SEDA that does not reduce City of Fresno resources dedicated to other areas of the City or burden Fresno residents outside of the SEDA.
• Holistically coordinate infrastructure to integrate efficiencies that piecemeal planning cannot.
• Invest in resource conserving techniques for stormwater systems, water supply, and trail and open space networks to save on infrastructure and mitigation costs.

This plan does not provide self financing as existing citizens within the SEDA have been told we would be required and responsible to hook to city water infrastructure at our expense, potentially costing in excess of $50,000. for city water hook up along with $50,000 or more to hook to city sewer infrastructure. These costs could also inflate due to demands to condemn our existing private utilities infrastructure.

Found on the Fresno.gov website under Frequent Asked Question:

SEPO

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What causes sand in my water?
“Although not harmful to your health, sand in the water can be a nuisance for customers, as well as City staff responsible for maintaining the water system. The geologic formations from which we pump our groundwater include layers of sand, gravel, and clay particles.

Older wells constructed without modern gravel filters and screens can periodically pump sand out from the formation.

Fresno has about 100 such wells, which we plan to replace as funds allow. Each new municipal well costs more than
$400,000.”
Through these statements the City OF Fresno acknowledges its infrastructure to supply current residents with potable water is failing and in need of repair. The statement “as funds allow” provides information that the City of Fresno does not have funds to maintain their existing infrastructure.

Repairs costing an estimated $40,000,000.00 “as funds allow” should be the city’s priority, rather than expanding the City’s footprint and taking on more citizens needs. Of the City’s existing 271 water wells, over 1/3 of the Citywide water wells need to be replaced to provide clean drinking water to existing City of Fresno residents. The City of Fresno shall fulfill its duty to provide services to existing residents before implementing expansion plans into Fresno County. The statement that sand is “not harmful to your health” is simply not true. Sand, along with sediment, and heavy metals can indeed cause heath effects to residents and their livestock who drink water contaminated water provided by the City. Sand and sediment in water supply can also cause damage to homeowner’s plumbing systems, appliances, and can stain clothes or dishes.
***If the SEDA plan is passed, how does the City of Fresno propose to fund and maintain new residents and existing residents within the SEDA with clean potable water, while postponing replacement of existing infrastructure?
City of Fresno Public Utilities representative - False information provided to citizens.

At a Drop in meeting hosted by The city of Fresno’s planning department on July 24, 2024 Peter Maraccini representing the public utilities department. presented information to Southeast property owners that is non factual when compared to the City Of Fresno’s water and sewage connection documentation. Mr Maraccini was documented on film stating :
“You are NOT required to be on city water, when a water main goes across, it’s your choice wether to connect or not. Majority of the water supplied will come from the Kingsriver, that goes to the surface treatment plant located on Armstrong” if you have an existing well we cannot impose a meter on you, but if you drill a new well, they will be metered.” This statement by Mr. Maraccini (recorded on video)
directly contradicts information emailed to a resident of Southeast Fresno prior to the “drop in meeting” on July 24, 2024. We suggest Mr. Maraccini deliberately provided false information to residents at the “drop in meeting” to falsely ease our concerns of required hook up to City of Fresno utilities. Below you’ll find the email sent on 8-2-2023 by Mr.

Maraccini of the City of Fresno’s Public Utilities Department:

From Peter Maraccini <Peter. [email protected]>
SEPO

5 CONT
Date Wed 8/2/2023 11:52 AM
To Jerry Prieto <[email protected]>
Cc Adrienne Asadoorian <[email protected]> Hi Jerry,
My apologies for the delayed response. The first part of the long email helps explain the timing of the connection. I then provide current rates at the end of the email.

Sewer Connection: Connection to a sewer once available is mandatory per Fresno Municipal Code and per Fresno County Ordinance Code, meaning annexation would not need to occur for the connection to be mandatory. Here are some excerpts for clarification:
• (If annexed) Fresno Municipal Code, Section 6-303: "If a sewer main has been constructed and is available for use in any public street, alley or right-of-way within 100feet for the first unit plus 50 feet for each additional unit, to be measured along such public street, alley or right-of-way from the nearest property line to the sewer main... buildings or structures connected to a septic tank.
shall be connected to the regional sewer system within three years after the regional sewer system becomes available"
• Exception: "In the R-A, AE-5, and AE-20 zone districts (County Designated Zones), on a lot at least two net acres in size, and provided the lot, if not served by a community water system, contains one dwelling unit or septic system per 2.0 acres, such connection may be deferred until the use of the land changes either through district amendment or special permit."
• (If not annexed) Fresno County Ordinance Code 14.12.030: "Buildings or structures connected to a septic tank or cesspool, at the time a public sewer becomes available, shall be connected to the public sewer within three years after the sewer becomes available and written notice thereof given by the county...Availability of a public sewer means a public sewer which has been constructed and is available for use in any public street, alley or rightof-way within one hundred feet of the first unit, plus fifty feet for each additional unit, to be measured along such public street, alley or right-of-way from the nearest point on the premises to the sewer."
• Exception: "The building official shall grant an administrative exception to the requirement of a public sewer connection if he determines that any one of the following conditions exist... Physical conditionsbetween the public sewer and the premises make it impractical to connect to the public
sewer" (only listed most likely of all reasons)
Water Connection: Unlike sewer, there are no City or County ordinances regarding mandatory connection. However, upon annexation, the Department of Public Utilities typically mandates thefollowing via the Extraterritorial Agreement and/or Annexation Agreement:

SEPO

5 CONT
• Upon annexation, the domestic water must be supplied by the City when the water main becomes available.
• For larger lots (2 acres or more) zoned for agricultural purposes, the City may allow the property owners to retain a well exclusively to be used for irrigation. In that case, the property owner will be required to install a meter on their well and pay a recharge rate as dictated by the Master Fee Schedule. The property owner will also have to install a backflow prevention device, which has its own associated fee and requires yearly checks by the City of Fresno Water Division. Should the land use change to something other than agricultural, the City would revisit this requirement.
• In all other cases where the property is not zone for agricultural purposes, the well must be properly destroyed.
• Property owners may protest the terms of the Annexation Agreement to the Director of Public Utilities.
• Note: The above stated requirements are internal policy set by the Department of Public Utilities and may change. Until the requirements are included in the Extraterritorial Agreement and/or Annexation
Agreement, nothing is final.

Who pays fort h e cost of the water and sewer connection? • The cost for connection is to be paid by the property owner. The City does offer loan programs to allow
repayment for the connection be included in monthly sewer and/or water statements over the course of several years (max 15-year term).
• Cost based on Master Fee Schedule: https://www.fresno.gov/wcontent/uploads/2023/06/MFS- Public-Utilities5 7 55 7 7CPI-UGM-ED-2023.07.01.pdf • The City cannot pay or provide loans for any private side improvements. This includes costs to build sewer or water lines from the home to the property line as well as destruction of the private well.

Current Rates for Water, Sewer, and Recharge:
• All rates are found in the Master Fee Schedule and my be updated periodically: https://www.fresno.gov/w-content/uploads/2023/06/MFS-PublicUtilities_575_577_CPI-UGM-ED-2023.07.01.pdf • For a single-family residence, the rates are:
• Sewer: $25.75 (Sewer Service) + $0.06 (Pretreatment) = $25.81 • Water (City service):

SEPO

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• Metered Service Rate is dependent on meter size- Typical for a single family residence would
be S13.50 (3/4-inch service to $20.80 (1 1⁄2-inch service) • Quantity Charge = $2.33 per 1,000gallons
of Wa t e r (private irrigation well):
• Quantity Charge = $0.29 per 1,000 gallons
• Backflow Prevention Program Fee= $2 per month (if you have a private well and receive separate City service, a backflow prevention device will be needed) • Rates apply upon connection to the City's water or sewer system.

Please let me know should you have any other questions.

Best Regards, Peter
Due to the many contradictory statements made by Public Utilities representative Mr.

Maraccini, both in person and via Email, we request the City correctly identify proposed costs and regulations to be placed on existing neighborhoods prior to moving forward with the SEDA plan.

Expanding City boundaries comes with property owners loss of rights not mentions in the EIR:

Through city boundary changes, citizens will loose the right to discharge firearms on their property. “No shoot zones” are established within certain distances of City boundaries.

Changes of boundaries will also affect territory that citizens can currently legally take wildlife utilizing firearms. Studies of how restrictive hunting rights will affect wildlife populations have not been completed.

Through zoning and boundary changes, Existing citizens will have limitations laced upon their properties which will limit animal husbandry rights. Loss of these rights will subject property owner to not only change how property owners keep animals, the loss of rights will affect future property values upon resale by existing homeowners .

While Fresno County lays out guidelines for “Rural Residential Zoning” the City of Fresno included a light green section of their proposed SEDA map identifying properties within their SEDA plan as “Rural Residential”. The City of Fresno Planing website does not currently identify “Rural Residential” as a Zoning section or give specific guidelines for “Rural Residential”. Many lots of property within the proposed SEDA map are located within the “Rural Residential” designation. Some of these lots are less than 2 acres, supplied with FID services and / or currently use existing private water wells for irrigation. In communications from City of Fresno’s Public Utilities Department lots less than 2 acres would loose their right to continue use of private water wells for irrigation purposes and be forced to irrigate using water provided by City of Fresno water connections. These loss of rights are unacceptable and costly to residents needing to irrigate their small farms.

SEPO

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6 7
Stated in the recirculated Draft in the executive summary section Impact Land-2 “The proposed project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding mitigating an environmental effect”.

Many properties within the SEDA are under contract with the Williamson Act. Changing these properties would absolutely have an adverse effect on the environment when these properties are changed from Restricted to Ag use to develop of homes, industrial, parks, trail, or green space.

Stated in the recirculated Draft EIR Executive Summary - Impact GHG-1 “The proposed project project would NOT generate direct and indirect Greenhouse Gas emissions with NONE mitigation required”
Level of significance after mitigation N/A
This statement is simply not true when compared to information contained in the draft EIR:

Impact GHG-1
“The proposed project WOULD generate direct and indirect Greenhouse Gas emissions” with no feasible mitigation : significant and unavoidable impact” In section cumulative impact within the executive summary of the recirculated draft : The proposed project would have a less than significant cumulative impact on Greenhouse Gas emissions with no required mitigation
While the draft EIR cumulative impact states:
“The project would have a significant and unavoidable cumulative impact on Greenhouse Gas emissions: no mitigation avoidable with a significant and unavoidable impact.” Subjecting residents of the Central Valley to an additional 500,000 TONS of carbon emissions annually due to the buildout of the SEDA plan is unhealthy.

Air pollution fines from these increased carbon emissions estimated at $25,500,000.00 annually puts an undue financial responsibility on a City with an estimated $20,000,000.00 budget deficit. These fines, when coupled with infrastructure costs for upgrades to the city’s current infrastructure, make the SEDA plan an unviable option to move forward with.

Power Grid demands: With PG&E as the primary source for Fresno county residents to receive electrical utilities, their power grids are already stressed and often not in working condition during extreme weather including hot months in the summer and cold months in the winter. The proposed SEDA plan will subject existing power grid infrastructure to additional stressors potentially causing more power outages: leaving residents in vulnerable and unhealthy situations. How does the City propose to protect new and existing neighborhoods from power grid overloads? The SEDA plan and EIR fail to answer this question.

SEPO

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8 9
10 11
Water / hydrology Impacts:

Existing residents within the City of Fresno are to follow mandatory watering schedules to conserve water. Subjecting existing neighbors to these regulations whom currently provide themselves with water through private wells takes away our rights and places a financial burden on existing residents.

We The people of Southeast Fresno determine the SEDA plan and EIR to be a failure by the planning department, this plan only benefits the builders and investors of income properties.

This plan fails to protect public health and resources. We urge City Council Members, The County Board of Supervisors, Mayor Jerry Dyer and Planning Staff to HAULT this plan before any more pubic funds and public resources are spent on continued planning of SEDA!
Signed,
The Southeast Property Owners (SEPO)
Brett Thompson - Communications Officer of SEPO
SEPO

12 From: Brett Thompson
To: LongRangePlanning
Subject: Edit to public comment provided by Brett Thompson and SEPO Date: Monday, March 24, 2025 10:25:48 PM
External Email: Use caution with links and attachments
Please edit 2 dates included in the comment letter submitted against the Recirculated Draft EIR on March 24th, 2025 these dates should be changed from 2024 to 2023. My apologies for the errors. See attachment for the location of the Errors in question.

SEPO

13 < Please edit ... h II e wq _
_ date~---to read 20 3_ I
At a Drop in meeting hosted by
1 The city of Fresno's planning
department on July 24, 2024
I Peter Maraccini representing the
public utilities department.
presented information to
Southeast property owners that is
non factual when compared to the
I City Of Fresno's water and sewage
connection documentation. Mr
Maraccini was documented on film
stating : "You are NOT required to
be on city water, when a water
main goes across, it's your choice
wether to connect or not. Majority
of the water supplied will come
from the Kingsriver, that goes to
the surface treatment olant
SEPO

13 CONT
I l~~at~d ~~-An~-stro-ng",-if-y~u have
an existing well we cannot impose
a meter on you, but if you drill a
new well, they will be metered."
This statement by Mr. Maraccini
(recorded on video)
directly contradicts information
emailed to a resident of Southeast
, Fresno prior to the "drop in
meeting" on July 24, 2024. We
suggest Mr. Maraccini deliberately
provided false information to
residents at the "drop in meeting"
I to falsely ease our concerns of
required hook up to City of Fresno
I utilities. Below you'll find the email
sent op §-2-2023 by Mr,
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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-347
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 Southeast Property Owners (SEPO)
Response to SEPO-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 SEPO-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.

Additionally, 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 SEPO-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.

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 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 SEPO-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.

Response to SEPO-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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-348 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 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 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 SEPO-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.

Response to SEPO-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.

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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-349
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 As discussed in the above master responses, potential conflicts with existing Williamson Act Contracts are discussed in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to SEPO-8
The comment is noted. The Executive Summary and Section 3.8, Greenhouse Gas Emissions, have been edited in Section 4, Errata, of this document to clarify the impact findings. No further response is required.

Response to SEPO-9
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, 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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-350 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 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.

Furthermore, the Executive Summary and Section 3.8, Greenhouse Gas Emissions, have been edited in Section 4, Errata, of this document to clarify the impact findings. No further response is required.

Response to SEPO-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 SEPO-11
The comment is noted. As detailed in Section 3.18, Utilities and Service Systems, electricity and telecommunications utilities respond to increased demands in various ways. These may include temporary stoppages or rolling blackouts, extension of existing infrastructure, or construction of new facilities.

Each of these utility providers prepares long-range plans to accommodate projected growth in their service areas. For example, PG&E provides annual sustainability reports that outline strategies to accommodate future growth and ensure reliability of electrical service. As indicated in the 2021 Corporate Sustainability Report, PG&E requested approval for 387 megawatts of additional energy storage from six projects. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” These planning efforts take into account growth projections, including the growth under the proposed project.

Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or expanded electricity facilities beyond those already planned. Impacts would be less than significant.

No further response is required.

Response to SEPO-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 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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-351
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 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 SEPO-13
The comment is noted. However, no environmental issues are raised, and no response is required.

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From: Jeannine Raymond
To: LongRangePlanning
Cc: Joanne Clark; [email protected]; Robert Boro; [email protected]; Wendy Carroll; Daniel & Karen Zack; Aaron Kelley
Subject: SEDA needs to stop!!!!
Date: Friday, March 14, 2025 9:19:34 AM
External Email: Use caution with links and attachments
Fresno Long Range Planning,
The message below was also sent to the City Council Members representing our neighborhood and areas around it. We are eager to see that you take our concerns seriously and that you will reconsider the effort to expand Fresno beyond what our resources can sustain. Instead, you will come up with a long-range plan to redirect resources to support the infrastructure of existing neighborhoods.

Respectfully,
Jeannine Raymond
Wilson Island Neighborhood Group (WING), Chair
Members of the WING are copied here
---------- Original Message ----------
From: Jeannine Raymond <[email protected]>
To: 'Miguel Arias' <[email protected]>, 'Annalisa Perea' <[email protected]>
Cc: Joanne Clark <[email protected]>, "[email protected]" <[email protected]>, Robert Boro <[email protected]>, "[email protected]" <[email protected]>, Wendy Carroll <[email protected]>, Daniel & Karen Zack <[email protected]>, Aaron Kelley <[email protected]>
Date: 03/13/2025 12:24 PM PDT
Subject: SEDA needs to stop!!!!
Council Members,
After reading the SEDA plan, I have a question and a comment...

What is the wisdom behind expanding the footprint of Fresno by investing in SEDA when...
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the Fresno budget is in the tank,
our water supply is limited by ongoing droughts,
and the infrastructure of numerous residential areas is in need of repair? To the latter point, the Wilson Island has been waiting for a year for the City's response to our traffic calming issues. We have recently been told street enhancements and repairs have been delayed, again, until summer. Late spring if we're lucky. Potholes in our streets, insufficient lighting, and an influx of the homeless are current issues. Need I mention the recent activities that have attracted a noticeable police presence.

Is it asking too much for you to turn your attention to existing issues rather than creating new ones???
Respectfully,
Jeannine Raymond
Wilson Island Neighborhood Group, Chair
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3 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-355
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 Wilson Island Neighborhood Group (WING)
Response to WING-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 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 WING-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 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 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 WING-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 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: MyEmail
To: LongRangePlanning
Subject: 3.10 Hydrology
Date: Monday, March 17, 2025 9:58:43 AM
External Email: Use caution with links and attachments
How will the city support the demand for water and sewage, I doubt the Fowler trunks line can support the demand for thousand of new homes and busineses. Thirty five years ago the water tabel was thirty feet at Clinton and Locan, now it is pushing ninety feet. On top of the demand for water and sewage the demand for electricy will increase to support the water and sewag infracture, and all the new homes. You need to look into the cost of electricy, read your PG&E bill from what was a few years ago to what it is today.

3.6 Energy
Where will all the electrical energy come from, there are no new electrical plants being built. Canada can cut a portion of our power supply the next time Trump pissses Canada off. In case you don't understand everything you are proposing depends on a secure source energy. What happened to all the Biomass powerplants that were bilt in Fresno County that are no longer in operation.

ANON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-359
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 Individuals
Anonymous (ANON)
Response to ANON-1
The comment is noted. First, 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.

Water
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.

Wastewater
As detailed in Section 3.18, Utilities and Service Systems, the City would be required to increase wastewater treatment capacity and obtain revised and/or new waste discharge permits. The policies included in the General Plan and the Wastewater Master Plan would reduce the potential impacts associated with increased wastewater generation and treatment requirements; however, these improvements will need to be reevaluated given the projected increase in wastewater generation in the Plan Area, and the City will need to update the Wastewater Master Plan. The implementation of the proposed Specific Plan will result in the need for expansion of the existing wastewater treatment facilities, and new wastewater collection and treatment facilities to serve future land uses in the Plan Area. MM UTIL-1c and MM UTIL-1d would require the City to evaluate the wastewater system and wastewater collection system at the time that discretionary projects are submitted for approval by the City, and the City shall not approve development that would exceed the capacity of a facility until additional capacity is provided.

Electricity
As detailed in Section 3.18, Utilities and Service Systems, electricity and telecommunications utilities respond to increased demands in various ways. These may include temporary stoppages or rolling blackouts, extension of existing infrastructure, or construction of new facilities.

Each of these utility providers prepares long-range plans to accommodate projected growth in their service areas. For example, PG&E provides annual sustainability reports that outline strategies to accommodate future growth and ensure reliability of electrical service. As indicated in the 2021 Corporate Sustainability Report, PG&E requested approval for 387 megawatts of additional energy storage from six projects. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” These planning efforts take into account growth projections, including the growth under the proposed project.

Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or expanded electricity facilities beyond those already planned. Impacts would be less than significant.

No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-360 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 ANON-2
The comment is noted. As detailed in Section 3.18, Utilities and Service Systems, electricity and telecommunications utilities respond to increased demands in various ways. These may include temporary stoppages or rolling blackouts, extension of existing infrastructure, or construction of new facilities.

Each of these utility providers prepares long-range plans to accommodate projected growth in their service areas. For example, PG&E provides annual sustainability reports that outline strategies to accommodate future growth and ensure reliability of electrical service. As indicated in the 2021 Corporate Sustainability Report, PG&E requested approval for 387 megawatts of additional energy storage from six projects. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” These planning efforts take into account growth projections, including the growth under the proposed project.

Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or expanded electricity facilities beyond those already planned. Impacts would be less than significant.

No further response is required.

AVILA

1 Teresa Pineda Avila
4004 E. Verrue Avenue
Fresno, CA 93702

NOTO-SEDA

SOUTHEAST DEVELOPMENT AREA
I often wonder how much love there is for Fresno ... and ... what of respect for her? What is loved, is not abandoned nor neglected.

It's been said, anything worth having, is worth fighting for. Sometimes the fighting becomes a battle comparable to that of, David and Goliath .... mortals vs presumed gods ... citizens vs city council vs supervisors vs developers ... as appears to be the case with SEDA.

SEDA- who is pushing this plan? Appearances and numerous, past city council votes would indicate that developers build and expand when and where THEY choose ... too often given free reign by local government.Tell the developers something they don't hear very often- NO! Ignorance of city government is not to be confused with stupidity. I, and others, have lived long enough, have seen enough, to know what many times drives decisions proposed by those who know that- MONEY TALKS. Yes, when there is the need for growth and development, call in the cavalry of developers. However, now is not the time to develop outward when the interior is bleeding, and crying out to be tended to.

Fresno ... at 74 years of age, I have infinite memories of my beloved place of birth. I am a lifelong resident, born in the GOLDEN WEST SIDE- borrowing a phrase from, HAPPY HAROLD (local rhythm and blues radio DJ).

At the age of 12, our family moved to the EASTSIDE of town- bordered by streets: BELMONT & OLIVE, CEDAR & ROWELL. I was 43 years of age when I became a first-time homeowner of a house that I had "eye-balled" since 6th grade! Living in my once dream house (streets:TULARE & VENTURA, CEDAR & FIRST) has given me an education that neither Roosevelt High School nor Fresno State could have. I have lived and worked (Rowell School) in this area, and the historic Huntington Boulevard region, the major portion of my life. I cannot fathom, nor entertain the thought of living ANYWHERE ELSE IN THE WORLD!!!
What of these lessons learned? That despite the present and past mayor(s) wishing aloud of a ... ONE FRESNO ... the opposite is true. As I see, as I have experienced, there are 2 Fresnos:
the NORTH and the SOUTH ... much like the CIVIL WAR One Fresno? Certainly ... one divided and fractured. The Fresno City Council demonstrates this with it's shenanigans and clear, full display of whom they are beholden to ... very recent example- the city council vote regarding smoke shops. Despite the sinful amounts of money spent on TV & radio ads, print, etc. promising voters the Sun, Moon and Stars, we voters are often left with a, "bag of chips, no soda"!!! You will,(most candidates) (pinky finger promise) "work for us, your constituents" .. . a time-worn and laughable utterance. There's a saying in Spanish: "Con AVILA

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dinero baila el perro". Literally: "With money, the dog dances". Figuratively: "Money talks". To win an election, money must be spent. Small sums donated by the average citizen pale, seem paltry, in comparison to ... say ... a developer with deep pockets and fatter wallets .. . and influence.

THE ELEPHANT IN THE ROOM: it's a part of life in politics ... like taxes and death. We mere mortals cannot compete monetarily with the developers who dictate votes ... and policy. Without developer money, how else to pad the ladder to higher office? l'M GENERALIZING. Feel offended ONLY if the shoe fits.

Sorrowfully, the center of Fresno is being neglected, parts left to deteriorate and die. Will prayers and a miracle resurrect our city? I've heard many a city leader, council member and supervisor invoke the name of God. Heaven has yet to rain money down on us. But we humans are blessed with a heart, a brain, common sense, and judgement to guide us in making sound, ethical and moral decisions.

Southeast Fresno is a great and grand lady. From time to time she receives a manicure, a pedicure, a little lipstick now and then. And IF she should be sooo lucky ... have her hair done! Bandaids. Her knees cry out for a replacement, her arthritic limbs struggle to keep her upright.

Do we watch, do we stare, do we lament her forthcoming demise? She fights a gallant battle to survive, to stay standing. Her eyes still luster; they sparkle with hope. Her heart is broken ... but still beats with blood infused with love and respect from those loyal to her.

Our STREETS are at the worst that they have EVER been. Riding down these streets rattles cars and nerves. CRACKED SIDEWALKS with tree roots raising walkways ... with many a person tripping and/or falling. TREES DYING, or dead. Their withered limbs a ghostly reminder of neglect and abandonment. Infrastructure ... LACK of BUS BENCHES with SHELTER to shield waiting bus patrons (MANY ELDERLY) from the winter cold and rain. I've helped a few seniors who fell and slipped in the mud as they exited a bus stop ... a stop where dirt awaited the disembarking ... dirt-unleveled and full of weeds. Our famous/infamous summer heat bakes into the skin of those waiting for city transportation. I CHALLENGE, I DARE, EVERY city council member to shop and wait with several, filled shopping bags (standing- and in the open) for an entire month to personally experience what is expected of us who rely on the bus system for transportation ... I suggest the southeast corner of Tulare Street. For the adventurous, there are many more locations to consider ... no seating, no shelter and a frustrating and disrespectful situation. With our air pollution, the investment in promoting clean air (via public transport) is a given.

Our weather. Our fickle rainy season. Where is the SERIOUS plan to deal with energy costs and water usage? To many, Fresno is a laughingstock to those living in or out of the city ... the joke is that Fresno doesn't know what it wants to be. We can .. . ,we should be ... a MODEL of how to remedy, INTELLIGENTLY, a better way of life for it's citizens.

AFFORDABLE drough-tolerant trees and landscaping ... aggressively advocated, financed and implemented. There are households, parts of SE Fresno where income makes these improvements impossible to adopt. Our weather, our limited water resources, expensive energy AVILA

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4 costs- glaringly cry out for sane and effective remedies ... want to spend money? HERE'S THE SPOT. .. ONE OF MANY!!!
Our homes, located in the older part of Fresno makes them aged ... many not so gracefully. A developer's dream, I imagine, is to develop and build. Start here. Our homes, this area is a majestic and beautiful blend of styles and architecture not to be replicated anywhere in Fresno ... much like Southwest Fresno and the Tower District. It's people proud and welcoming ... be it with small talk, conversation, community involvement and sharing of food ... all are welcome to our table. Yes, crime exists ... as it does in ALL parts of Fresno. Security is welcomed, for our homes and neighborhood. Invest in us, our young and our old ... those working ... those retired ... those struggling ... those homeless. Our schools and churches and organizations welcome the investment ... does the city council welcome and embrace them? Don't TELL US- SHOW US!!! "Las palabras se las lleva el viento ... Words are gone with the wind ... words are hollow".

Fresno has given birth to countless numbers of children, and received many who've chosen to adopt her. Cities- much like mothers ... are loved and respected. Others are neglected and abandoned. How we esteem Fresno ... or not. .. is telling of who we are ... what example we set for future generations to either emulate ... or cringe at the thought of how we chose to take care of this lady named, Fresno. Building outward is akin to leaving this, "Older Woman" for a younger mistress whose "youthful buildings" may console those," blinded by youth" ... offering a false sense of rejuvenation. How is Fresno rejuvenated when internally, central Fresno is left ailing and alone ... occasional and spotty "make up/lipstick" won't do ... we require more than patchwork and excuses.

There are BILLIONS of dollars to be spent. SE Fresno has MILLIONS of projects yet to be addressed ...

No apologies for this lengthy and perhaps rambling rant. I LOVE FRESNO!!!!! With all her, pimples, warts and scars (which ALL cities bear) she remains a beautiful place to live. Fresno- a region that feeds much of the country and world- should be held in high esteem ... more so those parts of her- older and historic ... alive and fighting a valiant battle to be appreciated and valued.

We don't want nor (in the future) wait to be razed. We want to rise and prosper. What cannot be saved, what is burned or thoroughly destroyed, can be replaced with what fits our character and spirit. Too costly?! But to expand outside of our area is rarely a financial burden ... excuses are infinite.

We are SOUTHEAST FRESNO ...

WE MATTER

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-365
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 Teresa Pineda Avila (AVILA)
Response to AVILA-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 AVILA-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.

Response to AVILA-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 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.

Additionally, as detailed in Section 3.18, Utilities and Service Systems, electricity and telecommunications utilities respond to increased demands in various ways. These may include temporary stoppages or rolling blackouts, extension of existing infrastructure, or construction of new facilities.

Each of these utility providers prepares long-range plans to accommodate projected growth in their service areas. For example, PG&E provides annual sustainability reports that outline strategies to accommodate future growth and ensure reliability of electrical service. As indicated in the 2021 Corporate Sustainability Report, PG&E requested approval for 387 megawatts of additional energy storage from six projects. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” These planning efforts take into account growth projections, including the growth under the proposed project.

Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-366 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 expanded electricity facilities beyond those already planned. Impacts would be less than significant.

No further response is required.

Response to AVILA-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.

From: Heather Balcom
To: LongRangePlanning
Subject: SEDA Public Comment from District 3 resident Heather Balcom Date: Saturday, March 22, 2025 8:27:50 PM
External Email: Use caution with links and attachments
Dear Fresno Long Range Planning Team,
I am a resident of the City of Fresno District 3. I am writing in response to the new proposed SEDA Environmental Impact Report draft.

The SEDA plan as currently described will harm the city of Fresno. SEDA is expensive and the plan does not explain how the city proposes to pay for it while meeting its existing obligations. Population growth has slowed, but Fresno will be responsible for paying for the development, regardless of if lots sell.

The good ideas from SEDA, such as increased green space and new affordable housing, can be implemented within current city limits at much lower cost. These are improvements that existing residents and businesses have been asking for and which the communities of county residents in the area that would be transformed by SEDA have clearly indicated that they do not want.

I submitted a public records request for the city's assessment of infrastructure repair and improvement needs in my neighborhood on February 23rd and have yet to receive the response. The city should identify and meet its existing obligations before considering taking on new ones.

Please reject SEDA and protect the City of Fresno from the long term negative impacts it would bring.

Sincerely,
Heather Balcom
1270 N Thorne Ave
BALCOM

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-369
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 Heather Balcom (BALCOM)
Response to BALCOM-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 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 BALCOM-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.

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From: William Beekman
To: LongRangePlanning
Cc: Jerry Dyer; Todd Stermer; Nelson Esparza; Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson
Subject: SEDA EIR Comment Response Ref.3436, William A Beekman 7791 E. Carmen, Fresno, 93737 Date: Monday, March 24, 2025 3:48:35 PM
External Email: Use caution with links and attachments
City of Fresno
Planning and Development Department
Sophia Pagoulatos, Planning Manager, City of Fresno, Planning and Development Dept

3.2 Ag Resources
William Beekman, resident 7791 E. Carmen Ave. 2.5 Acres Property. Presently grows 2 Acres of producing Oranges. With a dense population around we can no longer function as an income ( approx. $ 8000 to 12000 wholesale yearly) producing farm. Spraying of Insecticides & Herbicides, Beehive Honey gathering, gifting oranges to neighbors, loss of labor income (approx. $3000) for local HighSchool Children and Farm Laborers,

3.3 Air Quality
With the more dense population air quality will suffer tremendously! This is evidenced by the already heavy population increase north of us. We are experiencing smog now that prevents us from seeing the mountains. I can even smell the food being cooked 1/2 mile away from us.

Coming in via air you can really notice the smog emitting from the new more dense population areas near us! I am sure this affects our health.

3.6 Energy, Need study to determine what Electrical Resources are needed? Would there be enough?

3.8 Greenhouse Gas Emissions,
Unable to to plant enough trees to offset the Greenhouse gas emissions

3.9 Hazards and Hazardous Materials. Garbage disposal increase would be tremendous. We do not have appropriate locations to dump this stuff.

3.10 Hydrology and Water Quality.

Probably the most difficult impact caused by a large increase in population would be the shortage of water!! We are already overdrafted with ground water levels. There is not enough water to be transported from the already river water shortage!! Where will all the sewage be disposed of? Present facilities already at Max.

3.11 Land Use and Planning
Many hundreds of acres of valuable agricultural land will be gone! Believe there is a law preventing this!!

3.13 Noise
Already with population increase north of us, we have a high increase in sirens from police and fire departments and general traffic noise. WHERE IS OUR OLD SILENT COMMUNITY!! I must close our bedroom window about 6-7 AM to keep out the noise so I can sleep.Will have much more noise with population increase.

3.14 Population and Housing
This is Rural suburban farmland and not meant to be a heavily populated area. An increase in crime is already happening here in our community. It will only increase with a greater population.

BEEKMAN

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3.15 Public Services,
In our location Taxation costs for these services have risen tremendously. We are paying about $260 per year increase in school taxes from year 2008 for more schools that new people's children need, Sure to be more with population increase. Too bad the Housing Developers are not paying for this!

3.17 Transportation and Traffic
Road Transportation Conveyance increase in our area is TERRIBLE! It will become worse with more housing. Presently we avoid the rush hour traffic due to long waits at our stop signs and lights. It now takes us 10-15 minutes longer to get into town in non rush hour traffic due to the many new stop signs and traffic lights. Roads here are continually torn up with new utilities being buried. Traffic must be rerouted. Something drastic needs to be done to solve this problem. Contractors make millions from new home building and we suffer!!

3.18 Utilities and Service Systems.

We already have our own 3 HP well pump for water service. Also have our own sewage disposal system. Mandatory connecting fees for the City of Fresno estimated to be as high as $30K for each service and in addition to Monthly usage charges is not acceptable. We have a Solar Array size large enough to omit electric power costs. We are retired and need to have reduced living costs.

William(89) & Marjory(83) Beekman, 7791 E. Carmen Ave. Fresno, Calif. 93737- Built home 1977 on 2.5 acres. Raised family here in Clovis School District.

BEEKMAN

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13 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-373
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 William Beekman (BEEKMAN)
Response to BEEKMAN-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 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 BEEKMAN-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 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 BEEKMAN-3
The comment is noted. As detailed in Section 3.18, Utilities and Service Systems, electricity and telecommunications utilities respond to increased demands in various ways. These may include temporary stoppages or rolling blackouts, extension of existing infrastructure, or construction of new facilities.

Each of these utility providers prepares long-range plans to accommodate projected growth in their service areas. For example, PG&E provides annual sustainability reports that outline strategies to accommodate future growth and ensure reliability of electrical service. As indicated in the 2021 Corporate Sustainability Report, PG&E requested approval for 387 megawatts of additional energy storage from six projects. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” These planning efforts take into account growth projections, including the growth under the proposed project.

Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or expanded electricity facilities beyond those already planned. Impacts would be less than significant.

No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-374 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 BEEKMAN-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.

Response to BEEKMAN-5
The comment is noted. 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 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 BEEKMAN-6
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 BEEKMAN-7
The comment is noted. As detailed in Section 3.18, Utilities and Service Systems, the City would be required to increase wastewater treatment capacity and obtain revised and/or new waste discharge permits. The policies included in the General Plan and the Wastewater Master Plan would reduce the potential impacts associated with increased wastewater generation and treatment City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-375
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 requirements; however, these improvements will need to be reevaluated given the projected increase in wastewater generation in the Plan Area, and the City will need to update the Wastewater Master Plan. The implementation of the proposed Specific Plan will result in the need for expansion of the existing wastewater treatment facilities, and new wastewater collection and treatment facilities to serve future land uses in the Plan Area. MM UTIL-1c and MM UTIL-1d would require the City to evaluate the wastewater system and wastewater collection system at the time that discretionary projects are submitted for approval by the City, and the City shall not approve development that would exceed the capacity of a facility until additional capacity is provided. The comment is noted.

Response to BEEKMAN-8
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 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 BEEKMAN-9
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 BEEKMAN-10
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 BEEKMAN-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.

Furthermore, as discussed in Section 3.15, Public Services, of the Recirculated Draft PEIR, future development associated with the implementation of the proposed project would be required to pay all applicable development fees, which would offset costs for new public service facilities. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-376 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 BEEKMAN-12
The comment is noted. 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 BEEKMAN-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.

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.

SOUTHEAST DEVELOPMENT AREA

DRAFT EIR COMENT LETTER
The proposed EIR for the Southeast Development Project addresses the loss of farmland (AG1 and AG2) by delaying any mitigation plan and handing off that responsibility to the developers of individual projects within the area. Delaying any attention to mitigation is inappropriate given that the entire area is specifically being planned and organized as a conversion of ag land into housing.

This plan requires some mitigation for the loss of that land in this EIR.

There seems to be inconsistencies in the document. On ES -5 where it lists significant and unavoidable impacts, in reference to Williamson Act lands (but also relevant to other adjacent ag land), that the conversion of land to non-agricultural uses does not have any available mitigation.

While saying this, it lists possible mitigation approaches that might be taken by individual project developers. Again, the effort here is to avoid the clear responsibility for enunciating a plan for this development area.

Richard and Kay Bertken

BERTKEN

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-379
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 Richard and Kay Bertken (BERTKEN)
Response to BERTKEN-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.

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 BERTKEN-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.

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.

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From: [email protected]
To: LongRangePlanning
Cc: [email protected]
Subject: SEDA
Date: Sunday, March 16, 2025 2:12:33 PM
External Email: Use caution with links and attachments
I am a homeowner in the area of Temperance and Olive. In recent years, many new housing tracts have popped up in the area, causing traffic jams, accidents and additional noise from traffic.

Additional housing in this rural neighborhood is already interfering with my right to quiet enjoyment of my home.

This is an agricultural neighborhood, that's why we moved out here, to enjoy the peace and quiet.

I am also upset at the idea of having to be forced to hook up to a city sewer line. I have a well and septic I've already paid for, why should I pay for a sewer?
Fresnos budget is short 20 million short of current needs, fix that first.

Patti Bibb
7315 E Dennett Ave
Fresno CA 93737
BIBB

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-383
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 Patti Bibb (BIBB)
Response to BIBB-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: Gerry Bill
To: LongRangePlanning
Cc: Nelson Esparza
Subject: SEDA Recirculated EIR
Date: Sunday, March 23, 2025 7:43:30 PM
External Email: Use caution with links and attachments
March 23, 2025
From:

Gerald Bill
708 E Beverly Way
Fresno, CA 93704
[email protected]
To:

City of Fresno
Planning and Development Department
Attn: Sophia Pagoulatos, Planning Manager
Subject: SEDA Recirculated EIR
Dear Ms. Pagoulatos,
I am deeply troubled by the way the recirculated EIR for the Southeast Development Area (SEDA) is being handled, and specifically with some of the provisions contained within it.

Section 3.17 Transportation & Traffic
There is a claim in EIR Section 3.17 that by 2035, people living in SEDA would, on average, drive only five miles per day. That seems way off base, and is clearly an overly-optimistic projection. The SEDA development will not resemble a place like New York City, with an extensive subway system connecting all parts of the city. Realistically, in the SEDA, people are going to drive, not walk, and go to various locations in the city proper, not limited to the development area. The wildly exaggerated claim about how few miles people are likely to drive undermines the credibility of the report, which appears to be based on excessively rosy assumptions designed to hide the true negative impacts of the SEDA project.

Section 3.3.4 Air Quality
The huge increase in miles driven will further pollute the air. We live in one of the three worst areas of the state for dirty air, and the SEDA project is going to make our air even worse. There is no way around that if such a large number of households is added to our city in outlying areas. This sort of urban sprawl development will produce far more air pollution than would alternatives based on infill, rather than sprawl.

Worsening our air in this way will be harmful to people's health, and it is not necessary.

Section 4-2 Growth-Induced Impacts
One reason the SEDA project is not necessary is that it is based on false assumptions about the likely population growth. The growth projection it uses, 226,000 population growth by 2035, is roughly three times higher than the newest projections from the California Department of Finance. Again, the SEDA BILL

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3 project is trying to cherry-pick its numbers to try to justify the plan, even if better population projections are now available. Again, this undermines the credibility of the plan, and puts misleading figures into the EIR.

There are Better Ways to Use City Resources to Plan for the Future I have many other objections to the Draft Recirculated EIR for the SEDA project, including its failure to adequately address its impact on existing Fresno neighborhoods. The SEDA plan fails to address the financing of the infrastructure for the SEDA. With no financing plan in place, the massive cost of infrastructure for SEDA is likely to drain resources from existing neighborhoods in the City that will be needed for infrastructure maintenance, repair and improvements in those neighborhoods. I live in the area sometimes described as the Greater Tower District, bordering on Old Fig Garden. Public transit in my area is poor. I need to walk approximately half a mile to the closest bus stop. There are many streets in the area without curbs and gutters, leaving storm water to collect and partially cover some of the streets near me. Just two blocks from me, within the City Limits, there is a street that floods after every heavy rainstorm, and it is not possible to walk down that street without walking through water and getting one's feet wet (there are no curbs, gutters or sidewalks on that street). There are many other places in the City where this is going on. If SEDA is adopted, it is likely that City money will go there, instead of to improvements in City infrastructure in existing neighborhoods. It would be much better to improve infrastructure in existing neighborhoods and create more infill housing than to divert our precious resources to SEDA.

Sincerely,
Gerald Bill
[email protected]
BILL

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4 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-387
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 Gerald Bill (BILL)
Response to BILL-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 BILL-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.

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 BILL-3
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 BILL-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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BLOESSER 1

1 :from tfie 'Desk of
'Dr. Caro{ '.B{oesser
March 17, 2025
7843 E. Carmen Ave.

Fresno, CA 93737
[email protected]
These are comments regarding the SEDA EIR along with the marked reference:

3.1 Aesthetics. Lioht, and Glare

3.2 Agricultural Resources and Forestry Resources

3.3 Air Quality

3.4 Biolooical Resources
LI 3.5 Cultural Resources and Tribal Resources

3.6 Energy

3.7 Geoloov, Soils, and Seismicitv

3.8 Greenhouse Gas Emissions

3.9 Hazards and Hazardous Materials

3.10 Hvdroloov and Water Quality

3.11 Land Use and Plannino

3.12 Mineral Resources

3.13 Noise

3.14 Population and Housino

3.15 Public Services

3.16 Recreation
Transportation and Traffic

3.18 Utilities and Service Systems

3.19 Wildfire
X Mandatorv Finds of Sionificance
In the entire EIR, I see no financial impact statement. All EIR's must have budget projections.

The educated estimate is that the cost for infrastructure will run over 4 billion dollars. How will the city afford this when budget figures show that the city is in a deficit financial mode. I also saw from your Utilities Director who was on line to say that the city needs at least 100 new wells because many wells are pumping sand. In addition, a report estimates millions of dollars to repair sidewalks and potholes. Are you going to abandon existing neighborhoods and their needs to create urban sprawl?

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-391
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 Carol Bloesser (First Letter) (BLOESSER 1)
Response to BLOESSER 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.

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BLOESSER 2

1 :from tfie 'Desk of
'Dr. Caro{ '.B{oesser
7843 E. Carmen Ave.

Fresno, CA 93737
[email protected]
March 19, 2025
These are comments regarding the SEDA EIR along with the marked reference:

3.1 Aesthetics. Lioht, and Glare

3.2 Agricultural Resources and Forestry Resources

3.3 Air Quality

3.4 Biolooical Resources
LI 3.5 Cultural Resources and Tribal Resources

3.6 Energy

3.7 Geoloov, Soils, and Seismicitv

3.8 Greenhouse Gas Emissions

3.9 Hazards and Hazardous Materials
X 3.10 Hvdroloov and Water Quality

3.11 Land Use and Plannino

3.12 Mineral Resources

3.13 Noise

3.14 Population and Housino

3.15 Public Services

3.16 Recreation
Transportation and Traffic

3.18 Utilities and Service Systems

3.19 Wildfire
Mandatorv Finds of Sionificance
The Fresno Irrigation District has written about all the changes that must be made to the canals for water for 45,000 homes. There is not enough water to support all the new homes and their residents even with changes to the canals. Madera is already having to carry in water to a couple of their new developments. Is this what Fresno wants to do? In the EIR water is glossed over as though it is not a problem. That is certainly not true.

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-395
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 Carol Bloesser (Second Letter) (BLOESSER 2)
Response to BLOESSER 2-1
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.

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From the Desk of Dr. Carol Bloesser
7843 E. Carmen Ave.

Fresno, CA 93737
[email protected]
March 19, 2025
These are comments regarding the SEDA EIR along with the marked reference:

3.1 Aesthetics. Light, and Glare

3.2 Agricultural Resources and Forestry Resources

3.3 Air Quality

3.4 Biological Resources
u 3.5 Cultural Resources and Tribal Resources

3.6 Energy

3.7 Geology, Soils, and Seismicity

3.8 Greenhouse Gas Emissions

3.9 Hazards and Hazardous Materials

3.10 Hydrology and Water Quality

3.11 Land Use and Planning

3.12 Mineral Resources

3.13 Noise
X 3.14 Population and Housing

3.15 Public Services

3.16 Recreation
Transportation and Traffic

3.18 Utilities and Service Systems

3.19 Wildfire
Mandatory Finds of Significance
The population of California is diminishing. The population of Fresno is not growing at the rate that it was when this plan was first initiated. In fact, it is growing little. There is enough land and housing within the City of Fresno to last until 2035 and probably longer. Why take valuable farmland and create urban sprawl when it is unnecessary? The EIR does not prove the need for the 45,000 houses indicated in this plan.

BLOESSER 3

1 JFr01ffriL the 'Desi ef
'Dr◊ CarifJ{ 'B~esser

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-399
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 Carol Bloesser (Third Letter) (BLOESSER 3)
Response to BLOESSER 3-1
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.

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.

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From the Desk of Dr. Carol Bloesser
7843 E. Carmen Ave.

Fresno, CA 93737
[email protected]
March 23, 2025
These are comments regarding the SEDA EIR along with the marked reference:

3.1 Aesthetics. Light, and Glare

3.2 Agricultural Resources and Forestry Resources

3.3 Air Quality

3.4 Biological Resources
u 3.5 Cultural Resources and Tribal Resources

3.6 Energy

3.7 Geology, Soils, and Seismicity

3.8 Greenhouse Gas Emissions

3.9 Hazards and Hazardous Materials

3.10 Hydrology and Water Quality

3.11 Land Use and Planning

3.12 Mineral Resources

3.13 Noise

3.14 Population and Housing
X 3.15 Public Services

3.16 Recreation
Transportation and Traffic

3.18 Utilities and Service Systems

3.19 Wildfire
Mandatory Finds of Significance
In reading the EIR, I see no provision for fire stations or police stations. There is not even a suggestion of how many of each would be needed. This EIR is totally incomplete. It provides no estimate of a budget and many important things are not covered in this EIRE.

BLOESSER 4

1 JFr01ffriL the 'Desi ef
'Dr◊ CarifJ{ 'B~esser

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-403
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 Carol Bloesser (Fourth Letter) (BLOESSER 4)
Response to BLOESSER 4-1
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, Section 3.15, Public Services, provides a detailed analysis of the need for the construction of new or expanded fire protection or police protection facilities. Implementation of the proposed project would result in an increased demand for fire protection services. The Specific Plan includes a number of proposed policies related to fire protection, including Policy OS-11.2 which requires that fire services are provided in the Plan Area in accordance with the General Plan; and Policy OS-11.3 which requires that the City of Fresno Planning and Development Department work with the Fire Department as appropriate to promote safe environments throughout the Plan Area and ensure that services can be provided in a manner that is sensitive and responsive to the needs of the community. Coordination with the FFD would address design features for safety, siting of fire stations, and facilitation of citizen involvement processes. Implementation of the proposed Specific Plan policies would ensure that fire protection services are expanded to meet the needs of the intensified development and population increase in the Plan Area. Additionally, future development within the Plan Area would be required to comply with development fees or other funding mechanisms adopted for the proposed project in order to mitigate the impacts on fire protection facilities caused by future development within the City. Payment of the applicable development fees would offset the construction and acquisition costs of required fire facility improvements.

The Specific Plan includes proposed policies related to police protection, including Policy OS-11.1 which requires that police services are provided in the Plan Area in accordance with the policies of the General Plan; and Policy OS-11.3 which requires that the City’s Planning and Development Department work with the Police Department as appropriate to promote safe environments throughout the Plan Area and ensure that services can be provided in a manner that is sensitive and responsive to the needs of the community. Coordination with FPD would address design features for safety and crime prevention, siting of police stations, and facilitation of citizen involvement processes. Implementation of these proposed Specific Plan policies would ensure that police services are expanded to meet the needs of the intensified development and population increase in the Plan Area. Additionally, future development within the Plan Area would be required to comply with development fees or other funding mechanisms adopted for the proposed project in order to mitigate the impacts on police protection facilities caused by future development within the City.

Payment of the applicable development fees would offset the construction and acquisition costs of required police facility improvements. No further response is required.

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From: Whitney Wall Bortz
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
Cc: Rhonda Dueck
Subject: Concerned about the Southeast Development Area Specific Plan (SEDA) Date: Saturday, March 22, 2025 9:36:16 PM
External Email: Use caution with links and attachments
Dear Representatives,
I am writing to you as a resident, employee, parent and tax payer in District 5. I live on Huntington Blvd. between 3rd and 4th with my husband and 3 kids who all attend Fresno Unified Schools.

We are very concerned about SEDA. We already notice that there is significant neglect in this neighborhood and those surrounding us with much need for infrastructure, repairs and the availability of law enforcement. We fear that this development will remove further attention from these neighborhoods in which many families live, and neglect of these areas may drive families out of this region. Please let me know what you are doing to ensure that this development does not lead to negative consequences for others in this area.

Best,
Whitney Bortz
540-998-1255
3338 E. Huntington Blvd. 93702
[email protected]
[email protected]
BORTZ

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-407
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 Whitney Bortz (BORTZ)
Response to BORTZ-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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1 Sophia Pagoulatos
Planning Manager
City of Fresno
2600 Fresno Street, Third Floor, Room 3043
Fresno, CA 93721
Subject:

Dear Ms. Pagoulatos,
is .
-
- A. The process clearly conflicts with the Fresno General Plan’s framework and policies regarding the sequencing of development in “Growth Areas”
- ed in Chapter 12 of the General Plan and as - -13.

BRANNICK

1 Comments on Recirculated Draft EIR for City of Fresno's Southeast Development Area (SEDA) Specific Plan (State Clearinghouse # 2021100443)
Presented in this letter are comments on the Recirculated Draft EIR for the Southeast Development Area {SEDA) Specific Plan. Despite the geography of the plan's name, it has become increasingly clear that SEDA poses multifaceted issues of Citywide concern. Your consideration of these comments appreciated
Sincerely,
Daniel Brannick

1. The City's primary narrative in pushing for the expeditious approval of SEDA is "to create more housing supply at all income levels" (Specific Plan p. 5), however, the SEDA EIR admits "there is ample residential capacity within the current city limits and in Growth Area 1 {which includes Southwest Fresno and the West Area Neighborhoods Specific Plan areas)" (RDEIR p. 2 1).

In addition to its own admission that there is ample housing capacity elsewhere, there are additional problems with this would be justification to move forward with SEDA.

Permitting the development of SEDA, which is in Growth Area 2, prior to the development of land in Growth Area 1 violates the sequencing of development prescribed by policy and Figure IM 2 of the Fresno General Plan. Furthermore, the City has never established a tracking method to monitor development in infill areas and Growth Area 1 to determine an appropriate time to allow for development in Growth Area 2, as discuss
tied to the requirements of Policies UF 12 and UF
The EIR admits that moving forward with SEDA now is to place the sequencing out of order:
"Located in Growth Area II, SEDA was intended to be developed once other infill initiatives were given time to gain momentum." Given that there are multiple projects underway in Growth Area 1 with "ample residential capacity" still undeveloped, there is no basis to state that the City 2 B. The SEDA Plan as proposed is not consistent with the Housing Crisis Act of 2019 1 , open
of the state.

Furthermore,
ting urban areas
- - C. Advancing SEDA in the manner and timing proposed undermines the City’s obligation to Affirmatively Further Fair Housing
2 3, 4, 1
2 -and- - -furthering-fair-housing
3 - - -- 4

BRANNICK

1 CONT
2 3
should open Growth Area 2 to development. Rather, the City should continue to focus development in infill areas and Growth Area 1.

The lack of housing units to meet demand is not just an issue in Fresno, but in California broadly.

However, even the Housing Crisis Act would recognize that SEDA is not the best solution to address the crisis. The Act notes that "(12) The housing crisis also harms the environment by doing both of the following: (a) Increasing pressure to develop the state's farmlands space, and rural interface areas to build affordable housing, and increasing fire hazards that generate massive greenhouse gas emissions (B) Increasing greenhouse gas emissions from longer commutes to affordable homes far from growing job centers." (emphasis added).

The Act later states: (c) The Legislature also recognizes that premature and unnecessary development of agricultural lands for urban uses continues to have adverse effects on the availability of those lands for food and fiber production and on the economy it is the policy of the state that development should be guided away from prime agricultural lands: therefore, in implementing this section, local jurisdictions should encourage. to the maximum extent practicable, in filling exis . (emphasis added).

As there is "ample residential capacity within the current city limits and in Growth Area 1," allowing development to occur in SEDA which contains more than 2,475 acres of Prime Farmland, 1,352 acres of Farmland of Statewide Importance, 1,189 acres of Farmland of Local Importance, and 1,725 acres of Unique Farmland (totaling 6,741 acres) would be a violation of state policy, as written in the Housing Crisis Act.

AB 686 "requires all state and local public agencies to facilitate deliberate action to explicitly address, combat, and relieve disparities resulting from past patterns of segregation to foster more inclusive communities."
Fresno has a documented history linking urban sprawl to inner city decay and the creation of racially or ethnically concentrated areas of poverty. 5 As the City permits more outward https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill id=2019202005B330 https://www.hcd.ca.gov/planning community development/affirmatively https://www.sutori.com/en/story/fresno bhc timeline wGb27reQQeEt6ZoHvlqgPZfx https://storymaps.arcgis.com/stories/eb1233cfb60048df8a02ba8b83998da7 5 https://www.fresnobee.com/news/local/article243247596.html#storylink=cpy 3 – es from infill areas and
- eing
adopted.
-1- - - -
- d upon for mitigation.

BRANNICK

3 CONT
4 5
6 7

2. expansion, existing neighborhoods are drained of resources and amenities including access to healthy food, health care providers, etc. Despite this evidence, SEDA would perpetuate the disparities that result from past land use decisions, draining resourc Growth Area 1, and potentially exacerbate existing segregation patterns.

At a global level, it is unclear to what degree the EIR accounts for potential adverse environmental impacts that could result from the re sequencing of development to prioritize development within SEDA over other parts of the City and Plan Area. Notably, the EIR appears to take very limited account of two large planning efforts that were initiated prior to SEDA: the West Area Neighborhood Specific Plan and the Central Southeast Area Specific Plan. Both of these plans were initiated prior to the SEDA plan b resurrected, and both would increase housing and residential capacity in the City's Growth Area 1 and/or infill areas. The West Area is mentioned exactly one time in the aforementioned text from the Executive Summary, and the Central Southeast Specific Plan is mentioned only in footnotes. These projects must be considered in the context of cumulative demands on services and infrastructure to properly disclose how SEDA will impact the environment in the scenario that these plans are also

3. The City is not being transparent about the cost to build out public infrastructure and services for SEDA, which may indirectly violate General Plan Policies LU e and ED 5 b that speak to the need for revenue neutral annexations. While developers (or residents) may pay into a CFD, these do not cover all costs that are associated with new development, such as major roads. The approval of the Specific Plan and EIR would essentially require the City to subsidize development in Growth Area 2. As City resources are scarce and the City faces a budget deficit, this would further the offense to the General Plan by removing resources from infill areas and Growth Area 1.

4. The EIR quotes a number of policies from the SEDA Specific Plan and states that compliance with the policies will aid in reducing impacts. If the policies are subsequently altered, then the EIR must re evaluate the effectiveness of the policies to be relie

5. At a broad level, the EIR relies on policies and ideas in the General Plan and SEDA Specific Plan to ostensibly mitigate potential environmental impacts. However, in a number of instances, the EIR does not provide any meaningful evidence to substantiate a) whether or not the General Plan policies have been successfully implemented and thus can be cited as effective for mitigation, orb) whether or not the Specific Plan policies are based in any sense of reality.

For example, the EIR frequently discusses how the Specific Plan will be served with "convenient and frequent transit service" but provides no information to prove that FAX has "major transit lines" planned, funding available, etc. to make this a reality. Similarly, it says that "nearly all homes [are] to be 4 -
to its boundaries. The Blossom Trail Route
Farmland to nonbound
- of energy. The energy demands (not to mention

BRANNICK

7 CONT
8 9
10 11
located within walking distance of a Neighborhood Town Center" but does not show any maps or data that prove or meaningfully substantiate this statement.

6. The Plan has missing or outdated information. The Urban Form chapter does not include a series of exhibits that showcase the Land Use vision. The Housing Choice and Affordability Chapter does not discuss availability of housing in the City nor the challenges associated with providing housing affordability. The Greenhouse Gas Reduction and Conservation Chapter references the 2021 GHG Plan.

There is no Implementation Chapter.

7. The EIR says there are additional project components, but they are not available for public review. This includes a Phasing Plan, an Infrastructure Financing Plan, and a General Plan Amendment and Development Code Change. These components must be made available to the public with an appropriate public review period prior to any formal consideration of this project. Failure to do so undermines the informed decision making and meaningful public participation mandated under CEQA.

8. The Aesthetics section does not address potential impacts on the Blossom Trail. Segments of the Blossom Trail are located along Clovis Avenue, Jensen Avenue, Armstrong Avenue, and North Avenue, which is located within the Plan Area or immediately adjacent is formally designated as a scenic roadway by Fresno County, and it is well recognized in the local public consciousness as an important and significant scenic resource.

The EIR already discloses that significant and unavoidable impacts will result due to the conversion of agricultural use and the adverse alteration of visual character by increasing the intensity of development in many areas that are primarily agricultural. However, the potential for particularized impacts to the Blossom Trail segments within or in proximity to SEDA are not addressed.

As such, the EIR should include measures to protect the Blossom Trail segments located within the SEDA aries and those in close proximity to the Blossom Trail. Protective measures could include heightened review requirements for projects within the Blossom Trail Corridor areas and tree preservation requirements along Blossom Trail Corridor roadway frontage areas. Through such measures, it seems readily apparent that impacts to the Blossom Trail could be avoided or reduced without substantially impeding SEDA's general development framework or its goals and objectives.

9. Impact ENER 1 should be revisited and updated. Because there is enough housing capacity within infill areas and Growth Area 1 that are already served by infrastructure and services, SEDA would appear to result in inefficient, wasteful, and unnecessary use
dollar costs) associated with constructing and maintaining infrastructure in SEDA's undeveloped greenfield areas are substantially higher than those for infill areas and Growth Area 1. Furthermore, the energy goals. -
-
-12 as
- – share of property – -
-9 as history does not
-
full area
beyond the boundary of the plan
- arlier this

BRANNICK

11 CONT
12 13
added distances and commutes {which are likely to occur unless and until SEDA's optimistic full buildout is achieved) will lead to increased fuel consumption, which is averse to achieving California climate and

10. The El R's conclusion under Impact LAND 2 disregards that implementation of SEDA as proposed conflicts with policy Figure IM 2 and related policies pertaining to the prioritization of development in infill areas and Growth Area 1. This project cannot be found consistent with UF it would expand the city by 9,000 acres and include a population equal to neighboring Clovis exclusively to Growth Area 2. In light of the recently updated City County tax sharing agreement under which the City will receive a greater taxes for development within SEDA than it will for development happening anywhere else within the City or its SOI it is reasonably foreseeable that the City will seek to reallocate and direct resources to SEDA in an attempt to realize higher tax revenues {which could foreseeably be wiped out by exorbitant costs associated with serving and maintaining the new development). As such, the Plan is in conflict with LU 4 as it will pull resources away from existing neighborhoods and spread resources thinner across a larger urban footprint. For the same reason, it is in conflict with LU support the assertion that it will somehow avoid pulling resources away from downtown.

11. In the EIR's Transportation section, the El R's evaluative approach to Vehicle Miles Traveled {VMT) is misleading, if not flawed. In demonstrating an "80% reduction" in VMT, the EIR utilizes a "VMT per service population" metric which involves a comparison of VMT using the existing population of the SEDA geographic area. Given the rural nature and relatively limited population capacity within the SEDA boundaries, it is not surprising that existing VMT per capita within the SEDA geographic area is relatively high (under both existing conditions and 2035 No Project conditions). However, the problem here is that this limited geographic area is not reflective of Fresno's region wide VMT conditions {which are much lower per capita), and the VMT effects associated with SEDA will not be isolated to the Specific Plan's geographic boundaries. In order to provide an accurate and meaningful comparison of VMT impacts, the EIR must present the project's VMT in a broader context.

The 2018 OPR SB 743 Technical Advisory provides: "[A]gencies should analyze VMT outcomes of land use plans across the over which the plan may substantively affect travel patterns, including or jurisdiction's geography .... " (emphasis added) (p. 18). The Fresno County SB 743 Implementation Regional Guidelines similarly provides: "[T]he recommended methodology for conducting VMT assessments for land use plans is to compare the existing VMT per capita and/or VMT per employee for the region with the expected horizon year VMT per capita and/or VMT per employee for the land use plan of the jurisdiction." (p. 39 40). It is also noted that the Recirculated DEIR for the West Area Neighborhoods Specific Plan {which was released e month) compares Plan Area VMT to countywide VMT averages as part of its analysis of Transportation impacts.
5 6
- 30,000 to 60,000 households.
- 6
-
-
6 -southeast-fresnos-proposed-mega- -be-denser-than- -
-

BRANNICK

13 CONT
The SEDA EIR seems to take the approach that future residents of SEDA will live in a bubble in the Specific Plan Area, without traveling frequently to other parts of town or without having people travel into SEDA. Yet, this is contradicted by the description of land uses in the Project Description. The two Regional Town Centers will be able to serve 80,000 to 120,000 households (considerably more than the planned 45,000 homes to be built in the Plan Area). These centers will "host major cultural attractions" in addition to being mixed use employment centers and retail destinations. There are also other Centers that will influence VMT, i.e., the various Community Town Centers which would purportedly support Aside from the VMT per Service Population issue, the El R's projected "Year 2035 With Project Conditions VMT" is so low that it cannot help but invite skepticism. Local media coverage of SEDA reflects this sentiment, including questions seeking explanation of how SEDA's buildout and policy framework will "somehow" make SEDA's future residents "even less car dependent than downtown San Franciscans, ... and even New Yorkers. " At best, the El R's analysis appears to only consider the best case scenario for achieving such a low level of VMT. There are no mechanisms to ensure that the assumptions underpinning the Transportation evaluation will be achieved or implemented; particularly, development of infrastructure is to occur on a per project basis, so the multimodal circulation system will have gaps. https://fresnoland.org/2025/03/03/will
york city/
development new
City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-415
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 Daniel Brannick (BRANNICK)
Response to BRANNICK-1
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. No further response is required.

Response to BRANNICK-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.

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 BRANNICK-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 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 BRANNICK-4
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.

Each topical section of the Recirculated Draft PEIR details the relevant geographic scope of the cumulative impact analysis for that topical area. As described in Section 3.15, Public Services, the geographic scope for the analysis of cumulative impacts related to public services generally includes the Plan Area, the rest of the City, and any other communities served by the public service providers.

Cumulative impacts would be less than significant because public service providers conduct a regular budgeting process where future facility and staffing needs are identified and addressed, and all cumulative projects would be required to comply with applicable Municipal Code, General Plan, and Specific Plan policies and provisions that address public services, including payment of applicable development fees.

Section 3.18, Utilities and Service Systems, of the Recirculated Draft PEIR also provides the geographic scope for each utility. It further describes that the purpose of the SEDA Specific Plan is to identify and develop utilities and service systems within the project area, and to generally eliminate cumulative impacts outside of it. The impacts of anticipated development and projects resulting City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-416 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 from the Specific Plan have been analyzed in this Recirculated Draft PEIR. Most impacts are localized and would occur at different times as the Specific Plan is built out. The proposed project would comply with all State and local regulations related to utilities. Therefore, the proposed project would generally not combine with other projects to result in a cumulatively considerable contribution to cumulative impacts. Where there are regional impacts, they would occur on a scale and of a difficulty that cannot be addressed within a Specific Plan and are being addressed with long-term planning by regional groups and State agencies.

Furthermore, Section 3.14, Population and Housing, states that cumulative impacts related to population and housing would be less than significant because the general plans and other planning documents prepared by the jurisdictions within Fresno County would be required to develop land use plans that comply with State law and that would accommodate the existing and forecasted population, similar to the long-range planning guidance included in the proposed project. Consistent with State law, these planning documents would be required to provide adequate housing to accommodate forecasted numbers of people within the jurisdiction, and displaced development, if any, would be replaced primarily within the jurisdiction. Further, new development would be required to address potential environmental impacts as part of individual project review. No further response is required.

Response to BRANNICK-5
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 BRANNICK-6
The comment is noted. 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. No further response is required.

Response to BRANNICK-7
The comment is noted. The Specific Plan is a self-mitigating document, such that mitigation for its environmental effects is incorporated into and carried out by General Plan and Specific Plan policies.

Because the Recirculated Draft PEIR is a program-level analysis, specific development proposals would be required to demonstrate compliance with General Plan and Specific Plan policies when they are considered by the City. It would be entirely speculative, and therefore outside the requirements of CEQA, to evaluate how a specific policy would be implemented for a specific, as yet unknown, development proposal. In the event that future development proposals would result in impacts related to consistency with applicable policies, those potential project or site-specific impacts would be addressed in accordance with the requirements of CEQA at the project level.

Additionally, the proposed project and future development associated with implementation of the proposed project would be required to implement MM TRANS-1a, MM TRANS-1b, and MM TRANS1d, which require providing options for shorter trips by encouraging vertical mixed uses and locating residential uses in walking distance to retail and employment uses, providing pedestrian and bicycle City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-417
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 network improvements to connect complementary uses, and collaborating with FAX to provide new transit services to the proposed project and within the Plan Area.

Please also 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 BRANNICK-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 address why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to BRANNICK-9
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 BRANNICK-10
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 discussed in Master Response 5, future development projects would be required to analyze potential impacts to scenic resources, such as the Blossom Trail, and implement any feasible mitigation as necessary. Approval of the proposed project does not approve or entitle any development that could modify or impact the Blossom Trail without further environmental review. No further response is required.

Response to BRANNICK-11
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 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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-418 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.

As detailed in Section 3.6, Energy, of the Recirculated Draft PEIR, future development under the proposed project would be required to comply with the City’s latest adopted energy efficiency standards, as well as applicable policies of the General Plan and SEDA Specific Plan. Furthermore, compliance with the mitigation measures for Air Quality would reduce energy usage from the proposed project by requiring energy efficiency measures that go beyond the Title 24 and CALGreen standards. Therefore, impacts would be less than significant. No further response is required.

Response to BRANNICK-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.

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 BRANNICK-13
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.

Furthermore, as described in Impact TRANS-2 of the Recirculated Draft PEIR, the City of Fresno CEQA standards for land use plans, such as SEDA, state that the project should compare the base year existing VMT per capita and/or VMT per employee with the horizon year with project VMT per capita and/or VMT per employee. If the horizon year with project VMT is higher than the base year, then there will be an impact. The proposed project generates fewer VMT per capita and VMT per employee in the horizon year, and thus the impact would be less than significant.

For existing conditions VMT, the Plan Area was overlaid on top of the Fresno County Council of Government’s (Fresno COG) Activity Based Travel Demand Model (FresnoABM) loaded vehicle assignment network. Total VMT for the SEDA Specific Plan was calculated by multiplying daily volumes on the model’s loaded network by distance traveled. In addition, VMT per Service Population (which is the sum of population and employees) was calculated using the FresnoABM’s land use database. The same methodology was used to calculate VMT per Service Population at the Year 2035, both with and without project conditions. As described above and in the Recirculated Draft PEIR, the VMT per Service Population in the project area with the project built out in 2035 drops from 45.72 to 5.07 although total VMT is projected to increase due to population and employment growth. No further response is required.

BRIMMER

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2 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 23, 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 and have the following questions regarding the proposed implementation of the SEDA Plan and the EIR:

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 selffinancing 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 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

BRIMMER

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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

BRIMMER

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14 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.

The above questions barely scratch the surface in the number of holes and inconsistencies when trying to understand why the SEDA Plan is still trying to get approved after all these years. The City of Fresno continually attempts to make it make sense, but it never does. There are other alternatives that would benefit all residents, not just the sub-mediocre elected officials, land developers, builders and contractors. It is clear that the best interests of the community have not been considered.

Regards,
Stephanie Brimmer

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-423
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 Stephanie Brimmer (BRIMMER)
Response to BRIMMER-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.

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 BRIMMER-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 BRIMMER-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 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 BRIMMER-4
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, City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-424 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 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 would still have to go through the appropriate level of environmental review where impacts to air quality would 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.

Response to BRIMMER-5
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 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 the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly states 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 BRIMMER-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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-425
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 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 BRIMMER-7
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 BRIMMER-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 BRIMMER-9
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 BRIMMER-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 BRIMMER-11
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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-426 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 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 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 BRIMMER-12
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 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 BRIMMER-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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-427
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 and analysis related to air quality are discussed in Section 3.2, Air Quality, of the Recirculated Draft PEIR. No further response is required.

Response to BRIMMER-14
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.

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From: Steven Bruce
To: LongRangePlanning
Subject: Concerns about SEDA Recirculated EIR
Date: Monday, March 24, 2025 2:00:36 PM
External Email: Use caution with links and attachments
2250 Myrtle
Sanger, CA 93657
[email protected]
3/24/25
To whom it may concern,
It has come to my attention that the City of Fresno is planning development in the southeast area of the city. This replacement of farmland with housing is very concerning to me. It is a lot of homes rapidly being built with the expectation that they will be quickly filled. However, with recent data from the California Department of Finance suggests that Fresno is growing at a much slower pace than these houses would accommodate.

In my lifetime I have already seen this sort of excitement building back in the 2008 recession.

In which cities like Fresno and Sanger quickly built houses in a similar economic climate.

Only for them to have to be abandoned, leaving homes half-built and unoccupied.

Being the center of the county, Fresno has an obligation to stand as an example to the surrounding cities. This will have an effect, as it has in the past, of encouraging the same behavior in our smaller cities. Building 45,000 homes without any consideration for affordable housing is how the City of Fresno continuously keeps individuals like myself out who are both outgrowing our small towns as well as already commuting to Fresno for work and spending most of our money in Fresno. One day I would like to be able to afford housing in Fresno but developments like this keep on pricing me out.

It's also my understanding that there will be no affordable housing available. I am already a citizen of Fresno in everything but my home address. I work in Fresno, I shop in Fresno, and I spend my disposable income going to the theaters, bars, and other establishments. It is frustrating consistently being priced out of actually living in Fresno so I do not need to spend extra gas, which causes extra pollution, driving to Fresno daily. -- Steven Bruce Community Organizer
(559)999-5706
He/Him/His
BRUCE