Exhibit Q - Final Program EIR / Response to Comments — Fresno City Council, December 18, 2025 (part 5 of 7)

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-431
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 Steven Bruce (BRUCE)
Response to BRUCE-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. No further response is required.

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

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From: Cheryl Smith
To: LongRangePlanning
Subject: Opposition to SEDA
Date: Saturday, March 22, 2025 8:30:16 PM
External Email: Use caution with links and attachments
To Whom It May Concern,
I am writing to express my concern about SEDA. City money should e going toward existing neighborhoods, not new developments where the developers make a huge profit at the expense of those in the city that need attention and ongoing services. I live in the hIstoric Huntington area and Jackson Neighborhood. We need ongoing maintenance for our sidewalks, streets, lights, police presence, funding for school, etc. The city owes established neighborhoods their money and attention.

Thank you,
Cheryl Dueck Smith
559-270-9890
3863 E. Kerckhoff
Fresno, CA 93702
C. SMITH

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-435
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 Cheryl Smith (C. SMITH)
Response to C.S SMITH-1
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. 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.

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From: Albert Casares
To: LongRangePlanning
Subject: southeast Fresno’s proposed mega-development comment Date: Tuesday, March 4, 2025 2:38:31 AM
External Email: Use caution with links and attachments
Hello I’m Albert casares I have lived in southeast Fresno all my life and I have some comments about the current controversial mega project that I hope will happen soon because I think it’s a great project because there is many pros that many would have not think of such economic gain for the surrounding area from businesses to housing availability which benefits pretty much all of Fresno due to the lack of housing which would accommodate our growing population and demand of housing that we lack, even accessing more green spaces which is great for quality of life and I know things come into play such as concerns for the environment from water to our air quality which we can find a solution through grants to funding from the state and the tax revenue that we would gain from this development and I’m all for it I just don’t understand why others are against it how do they expect our city to grow and be more productive and have more job opportunities and all it takes is a well planned development that can optimize resources usage promote sustainable practices like public transportation and that would reduce per capita environmental impact alone and Fresno lacks infrastructure and I feel this project would improve that also, and a dense urban population has better access to public services from healthcare to educational institutions and more transportation options which all around is great which also a larger population base in a city would attract businesses leading to the job opportunities which creates higher income levels which is great because southeast Fresno is underprivileged than most of Fresno and has been for decades

CASARES

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From: [email protected]
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Luis Chavez; Garry Bredefeld; Nelson Esparza; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Mayor; Adrienne Asadoorian Subject: In opposition to SEDA. EIR comments.

Date: Monday, March 24, 2025 12:01:57 PM
External Email: Use caution with links and attachments
I. Quantified Objectives es-2.

A. The first objective documented by the SEDA-EIR is to "accommodate between 40,000 and 45,000 dwelling units". Between 2021 and 2023 he population of the State of California declined by close to 1 million people. Although California’s population grew slightly in 2024, the overall trend since 2019 has been downward. The slight increase in 2024 was attributed to “increased international immigration” which may not continue. The downward population decline was not forecasted. According to a June 2023 LA Times survey, 40% of the people in California are seriously considering leaving. While SEDA’s plans assumed 1.5% annual population growth, the California Department of Finance now projects Fresno County will grow by just 0.18% annually over the next 50 years — a difference that fundamentally erodes the project’s key assumption. The EIR and SEDA plan have failed to recognize the quickly changing current population statistics and need to be reconsidered in light of the potential for this trend to continue.

1. Have you accounted for an un-forecasted decline or flat population for Fresno per recent California Department of Finance projections?

2. What are the taxpayer and environmental costs of annexation on the key elements of the SEDA plan if Fresno's population declines or stays flat along with current California trend?

3. If Fresno's population does decline or stays flat, would this annexation still make sense? a. Would you allow massive housing development without the new people to fill it? b. Would it result in people abandoning city apartments for new housing? c. Might this cause Fresno home resale values to plummet and the inner city to crumble?
d. Could it result in abandoned housing projects spoiling our prime agricultural land....Like the old Running Horse project?

4. What alternatives like city infill have you considered should the population trend continue?

5. Would it be wiser to invest Fresno’s limited resources to improve infrastructure inside the current city limits instead of promoting this urban sprawl; potentially without the

CEDERQUIST

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2 population to support it?

6. Would it make better sense to postpone this plan for a few years to understand if the current population trends will continue?
Given the uncertainty about California's declining population trend, a massive city expansion via annexation is too risky. Ignoring this possibility and continuing with outdated population assumptions is simply irresponsible. It has the potential for a huge wasted investment that only benefits a few real estate developers at the expense of prime agricultural land, county property owners and residents, and the people of the City Fresno.

B. A second objective noted in the EIR and the SEDA Plan is also under the Quantified Objectives section. It is to “Accommodate between 30,000 and 37,000 jobs”. There are currently 643 properties including offices, retail, and industrial spaces available for sale or lease in Fresno County. There are 8,400 available, vacant acres within the Fresno City limits. The Caesar Chavez corridor features vacancy rates of 25 to 30% while Downtown Fresno is becoming a Ghost Town.

1. What is the actual plan to create these alleged new jobs?

2. If the city believes that simply annexing land and expanding Fresno’s boundaries can attract new businesses that employ tens of thousands of people, why can’t they wave that same magic wand and provide the incentives to bring businesses to areas of Fresno where there are vacant business properties and unemployed city residents who can immediately begin work….without any new infrastructure or land. Why not focus on fixing Fresno’s declining downtown and corridors of vacant businesses?

3. Noted economist Tim Bartik, a senior economist and researcher at the W.E. Upjohn Institute for Employment Research points out that “few Americans work in the neighborhood they live in”. Yet the SEDA EIR (3.3.4 - Impact Analysis, Mitigation Measures, and Level of Significance) assumes “policies that promote active transit, clean air measures, and support the reduction in average vehicle trip distances, which contribute to reducing overall per capita VMT in the region”. Isn’t it equally likely that the businesses that locate in the SEDA area will cause longer ‘average vehicle trip distances? Many would move to the SEDA area for low-cost housing and have to drive further to work in the city. Many others would live in the city and be forced to drive longer distances to work in the SEDA area. Assumptions made in terms of reduction of ‘average vehicle trip distance’ are clearly wrong.

Given the wild assumption of the ability to create tens of thousands of new jobs, the City of Fresno and its residents would be better served simply creating those jobs within the current confines of the city limits. Clean up downtown and declining business corridors and incentivize businesses to locate there instead of trying to expand and ignore the blight. Urban sprawl is not the solution to urban decay.

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II. Fiscal Responsibility:es-2.

C. A third objective noted in the EIR and SEDA plan is to make the SEDA project “self-financed 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”. It is important to note that After close to 20 years the City of Fresno has looked at growing to the South East, there is still no published City Infrastructure Cost Estimate, Financial Feasibility Study or Financing Strategy.

1. Fiscal Responsibility is touted as a key objective of the SEDA plan and is included as a part of the EIR. It has been reported that much of the infrastructure cost information was available in December 2024, yet it has been withheld from public view. FOIA requests have been made regarding the cost estimates yet they are delayed until after the comment period on the EIR. How can concerned citizens comment on the ‘fiscal responsibility’ of the SEDA plan if the costs have been hidden from public view?

2. Once the costs and financing strategy are officially published by the City of Fresno, will that information be included in the SEDA plan and the EIR comments re-opened to allow citizen comments?

3. How is it fiscally responsible to require current county residents to connect to city water and sewer at a potential cost of over $100,000? Shouldn’t the City or the developers pay for that?

4. As the City of Fresno struggles to find cuts for their 20-million-dollar budget deficit, why continue this project that some estimate will require investments of 1-2 billion dollars… but we really don’t know what it will cost.

Given the fact that cost estimates have been kept from public view, it’s not only irresponsible but just wrong to proceed with approval of the EIN that touts Fiscal Responsibility as a key objective.

Summary
Any plan is only as good as the assumptions that underpin its objectives. The objectives for SEDA as stated in the revised EIR are based on faulty or unproven assumptions such as:

1. Target housing levels of 40000-45000 units is based on incorrect estimates of population growth.

2. Adding 30,000 to 37,000 jobs is unrealistic and locating those jobs far from the current city limits will not reduce average vehicle trip distances.

3. The project cannot be considered fiscally responsible without actually providing any cost estimates, financial feasibility study or financing strategy.

Therefore, the SEDA plan and EIR are based on assumptions that are wrong or unproven and that undermine the viability of the project. Instead of spending more money on the dreams of local home builders, it’s time to reject the EIR, stop the SEDA project, focus on infilling within

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the current city boundaries and fix the real problems of the city.

Virtually every resident and property owner in the SEDA area is against the plan. Maybe it’s time to put the SEDA plan to a county-wide vote to see what the voters really think.

Alan Cederquist
735 N. Locan Ave
Fresno, CA

CEDERQUIST

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-445
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 Alan Cederquist (CEDERQUIST)
Response to CEDERQUIST-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. No further response is required.

Response to CEDERQUIST-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.

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 CEDERQUIST-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 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.

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

Please 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.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-446 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 also refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR.

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

No further response is required.

Response to CEDERQUIST-7
The comment is noted. Please refer to Response to CEDERQUIST-1 through Response to CEDERQUIST6. No further response is required.

From: Deborah Bigham
To: LongRangePlanning
Subject: Comments on EIR
Date: Monday, March 10, 2025 3:01:37 PM
External Email: Use caution with links and attachments
Section 3.19
With the easily spread of fires, how do you plan to protect those people in these high density housing areas due to their close proximity? As of the recent Palisades fires what is Fresno City’s plan to protect their occupants from this same thing happening here.

D. BIGHAM 1

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From: Deborah Bigham
To: LongRangePlanning
Subject: Comment to EIR
Date: Monday, March 10, 2025 3:41:03 PM
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Section 3.17 Transportation and Traffic
What is the proposed infrastructure cost for this project? What is your budget? It needs to be disclosed before the EIR is accepted. It has been reported that it will be figured out after the council approves the massive project. That is unacceptable and needs to be disclosed prior to any approval.

D. BIGHAM 2

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No further response is required.

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From: Deborah Bigham
To: LongRangePlanning
Subject: Comment to EIR
Date: Monday, March 10, 2025 4:52:36 PM
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Section 3.15 Public Services Question
Who’s paying for the massive bill to build schools to accommodate high density population located in Sanger district? Sanger Unified has real concerns and has replied in writing. What plan do have for funding the schools in this district. Why have estimated costs not been given? Is the concern that the truth would be detrimental to the project? This needs to be corrected before going forward. Asking tax payers to fund a blank check is wrong and needs to be corrected. How does your conscience not bother you. Are you so deceived that you can’t be upfront?
D. BIGHAM 3

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

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From: Deborah Bigham
To: LongRangePlanning
Subject: Comment to EIR
Date: Monday, March 10, 2025 5:00:38 PM
External Email: Use caution with links and attachments
Section 3.5 Tribal Cultural Resources
How will the loss of the Hmong culture revenue impact the Hmong culture? Please site the studies that support consideration for the Hmong farmers. Hurting a minority is unacceptable and needs to be addressed and must be corrected.

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No further response is required.

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From: Deborah Bigham
To: LongRangePlanning
Subject: Comment on EIR
Date: Monday, March 10, 2025 5:03:55 PM
External Email: Use caution with links and attachments
Section 3.19 Wildfire
With the easily spread of fires, how do you plan to protect those people in these high density housing areas due to their close proximity? As of the recent Palisades fires what is Fresno City’s plan to protect their occupants from this same thing happening here.

D. BIGHAM 5

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From: Deborah Bigham
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; [email protected]; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer
Subject: Comment onEIR
Date: Monday, March 24, 2025 3:39:10 PM
External Email: Use caution with links and attachments
Section 3.14 Population and Housing
SEDA’s original estimated annual population growth through 2050 was 1.5%. The revised population growth estimate is only .18%. Bigger than necessary for population growth is 8.3 X.

This alone undermines the entire basis of the SEDA project. How do you propose to make this feasible.

Section 3.14 Population and Housing
SEDA has planned for 44,000 units when
based on the latest population projections. The unit’s actually needed is 5,300. There is plenty of land within the City of Fresno. Why can’t these units be built on empty acres within city limits and save our farmland?
Section 3.15 Public Services
Who will be paying for the massive bill to build schools to accommodate the high density population located in the Sanger School District? Since Sanger Unified has replied to this Project in writing with great concern, please document the projected costs involved with the School district and the plan to fund these schools. Why have no estimated cost been revealed? Are you concerned that the truth would be detrimental to the project? Going forward with no plan to implement school growth is unacceptable and needs to be corrected. Asking taxpayers to fund a “blank check” is unacceptable and needs to be corrected.

Section 3.17 Transportation and Traffic
After close to 20 years, there is no City Infrastructure cost estimate, Financial feasibility study or Financing strategy. Why is that. There needs to be a cost estimate for accountability before moving forward.

Section 3.17 Transportation and Traffic
The potential SEDA Infrastructure Cost is $1,000,000,000 plus and some are guessing it will run as high as 2 billion. But we don’t know because no one seems to know. So, where is the money coming from? The Fresno
City budget Deficit for 2025 is $20,000,000. Fresno is struggling with potential budget cuts to balance the budget. So how is it feasible we can afford OVER 1 BILLION DOLLARS for D. BIGHAM 6

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3 SEDA infrastructure. It’s been reported that this will be ironed out after the council approves the massive project. Where’s the accountability? What is the infrastructure cost? The budget needs to be disclosed before the EIR is accepted. This needs to happen before prior approval.

This blank check is unacceptable.

Section 3.11 Land use and Planning
Fresno (City Limits) has 8,200 vacant Acres which = 134,000 Units. This vacant land already exists within the city limits and can accommodate all the growth anticipated through 2050 and beyond, without the billion plus infrastructure costs of SEDA. Why not start there then move out as needed. It doesn’t make sense unless you’re a home builder looking for cheap land and a City with taxpayers happy to provide a billion extra dollars to subsidize “your” dream development.

Section 3.18 Utilities and Services Systems
What will the long term impact on the environment be when expanding or relocating electric, natural gas, or telecommunications facilities for a project of this magnitude? Can you and will you site your studies? Not having this information is unacceptable and needs addressed.

Section3.19 Wildfire
Because of the close proximity of the high density housing, and therefore, the high wildfire risks of rapid spreading, what is your plan to protect the occupants from feared disasters such as the fires in Los Angeles this year. With no plan in place this is unacceptable and needs to be corrected.

Section 5.2 Project Objectives
On 3-7-25 A Public Records request was made for information on the SB2 Grant that funded the SEDA EIR. As of 3-23-25 documents have not been released. In an article in Fresnoland March 3, 2025 by reporter Gregory Weaver said, “Officials have yet to publicly disclose a cost estimate, despite consultants delivering one to City Manager Georgeanne White last December. Where is the fiscal responsibility in this. Until the cost estimate is released and the public is able to make comments the comment period for the RDEIR should be extended 30 days from the release of the cost estimate to the public.

3.3 Air Quality
On August 28, 2024 a publication authored by Gregory Weaver of FresnoLand titled “Development projects suddenly in limbo as Fresno scrambles in wake of court ruling” “City officials estimate that the 9,000-acre SEDA project will increase Fresno’s annual carbon emissions by 500,000 tons, effectively wiping out the city’s progress on climate goals for the next two decades.” According to city documents this project is estimated to triple air pollution levels in Southeast Fresno.” So why is this quantification of information published prior to the recirculated draft deliberately excluded from the EIR? There is currently not enough information to quantify emissions of specific project development that may occur under the proposed project.

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7 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-469
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 Deborah Bigham (Sixth Letter) (D. BIGHAM 6)
Response to D. BIGHAM 6-1
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. No further response is required.

Response to D. BIGHAM 6-2
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.

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 D. BIGHAM 6-3
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.

Response to D. BIGHAM 6-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to D. BIGHAM 6-5
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.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-470 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses.

Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

Response to D. BIGHAM 6-7
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.

Furthermore, as discussed in Section 3.18, Utilities and Service Systems, of the Recirculated Draft PEIR, impacts related to the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facility would be less than significant impact with mitigation incorporated. No further response is required.

Response to D. BIGHAM 6-8
The comment is noted. Please refer to Master Response 12, Clarifying Information on Wildfire Analysis, in Section 2, Master Responses. Master Response 12 elaborates on the methodology used in Section 3.19, Wildfire, of the Recirculated Draft PEIR. No further response is required.

Response to D. BIGHAM 6-9
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 D. BIGHAM 6-10
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.

City of Fresno
City of Fresno Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, California 93721
[email protected]
Re: "Recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486"
Dear Ms. Pagoulatos,
I contest Section 3.2 Agricultural Resources and Forest Resources for the following reasons:

1. Under the mitigation plan, MM AG-1, Fresno City has no plan to preserve farm land at a 1:1 ratio, so how will this mitigation be implemented and enforced? The alternative in MM AG-1 is unacceptable because it relies on the City to develop a Farmland Preservation Program by 2025. Since the plan is not in place, the environmental impact cannot be determined.

Therefore, this plan must not be accepted until a plan is in place and can be adequately evaluated. Having the plan in place with clear requirements provides predictability of the environmental impact.

2. In reference to MM AG-1, the City's General Plan Policy RC-9-c does not provide the sole legal basis for mitigation for the loss of farmland to urban development. As you are aware, the California Environmental Quality Act ("CEQA"), Pub. Res. Code 221000 et seq., requires agencies to analyze the significant environmental impacts of projects that they approve or carry out, and to mitigate those impacts, where feasible, to a less than significant level. The Legislature has declared that CEQA "plays an important role" in effectuating the important public policy of preserving agricultural lands within the state. Stats. 1993, ch. 812, 1, p. 4428.

Accordingly, CEQA's environmental analysis and mitigation requirements extend to farmland conversion. See San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal. App. 4th 713,ll 733 (EIR deficient due to an inaccurate assessment o the amount of prime farmland to be converted as a direct result of the development project); Citizens for Open Government v City of Lodi (2012) 205 Cal. App. 4th 296, p. 320-322 (EIR found conversion of 40 acres of farmland a significant impact even after purchase of conservation easements at a 1;1 ratio). Impact AG-1 states that there is "significant and unavoidable impact." This is not acceptable under CEQA mandates and must be corrected.

3. The EIR summarized the total of farmland that would be lost in this plan at 6,661 acres. The SEDA plan states that the Level of Significance After Mitigation (MM AG-1) is Significant and unavoidable. The plan does not conserve any farmland. Alternative 3 would D. RAMMING 1

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2 conserve only 648.61 acres. This is not acceptable. Farmland conservation at a 1:1 ratio does not save farm land from destruction in the SEDA area. This destruction reduces food production for feeding people as well as loss of income for families that farm in the area. Alternative 1 (No project alternative) would have the least impact on conversion of farmland to housing. The SEDA plan, plans for 45,000 homes compared to the 17,900 on the existing plan (Alternate 1).

Therefore, a large amount of farmland would not be converted to houses under the existing plan and the SEDA plan should be rejected. With the increase in this number of homes and residents, the number of jobs would only be increased from 29,600 to 37,000 jobs. This is unacceptable and will have an adverse on the environment of the planned area.

4. The City of Fresno's General Plan conceived of the development of SEDA in Growth Area II to occur after other infill initiatives, to give those time to gain momentum. The Project History in Appendix A of the EIR states "there is still ample residential capacity within the current city limits and in Growth Area I (which Southwest Fresno and the West Area Neighborhoods Specific Plan areas)." Also refer to 2013-2031 Fresno County MultiJurisdictional Housing Element Appendix 1-E Fresno. This mitigation measure has been completely ignored in the EIR and has not been addressed as a reasonable option. Therefore the SEDA plan must not be developed until the space within the current city limits and Growth Area I are utilized.

5. The plan has made no consideration at all for the social and economic impact on minority groups. A large number of Hmong and Southeast Asia descendants that farm in this area will lose their income and livelihood as their farms are converted to houses and nonagricultural industries. This is a social injustice and has to be addressed before this EIR can move forward.

6. There are no mitigation measures to conserve over 900 acres of agriculture land that is already within the Williamson Act. This is totally unacceptable under CEQA guidelines. This EIR cannot move forward until these lands are secured as agriculture land.

7. The public comment received during the EIR scoping period asking for an assessment of the impacts that the plan will have on current and future agricultural operations has not been adequately addressed. Housing, especially high density houses, is incompatible with farming.

Mitigation measures in these situations have not been adequately described so a full environmental impact cannot be made. Planning for only organic farming in the area is not adequate as organic sprays are governed at the same level as conventional pesticides and approved by the Environmental Protection Agency (EPA) and California Department of Pesticide Regulation. Therefore, to plan only for the use of organic pesticides will not provide home owners with peace of mind of safety.

8. Policy RC-5.2 Hazardous Materials. Prevent contamination of the ground water table and surface water resources and discourage all pesticide use for agricultural and landscaping uses D. RAMMING 1

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4 within the SEDA area. This policy is outside the jurisdiction of the City of Fresno. The use of all pesticides for agricultural and landscaping is under the jurisdiction of the Federal EPA and California Department of Pesticide Regulation. This policy is just another way to reduce the feasibility to farm in the SEDA plan area, forcing agriculture out so housing can be built without regard to preserving agriculture land. This policy is not consistent with CEQA's mandate to preserve agriculture land and reasonable measures must be shown how to mitigate hazardous materials in groundwater and surface water and still preserve agriculture land.

9. The measure to mitigate agricultural conversion, page 3.2-15 is stated as "To counter the effects of agricultural conversion, The Specific Plan includes a policy framework to support the integration of agriculture within the urban sphere. Programs that would be integrated into the Specific Plan may include school and neighborhood gardens, community orchards, agricultural education centers." This does not mitigate in any way the loss of agricultural land for production that feeds Fresno, California, and the United States. Community gardens are very limited in their production as well as their use. Limited plantings of nut and fruit trees are susceptible to pests, disease and bird damage without adequate pest control measures and will be a liability. These plantings will become reservoirs for pests and invasive species that could destroy all commercial agriculture in the San Joaquin Valley of California. Therefore, these measures are inadequate to satisfy CEQA mandates for preservation of farmland.

Based on these reasons, the Recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486 should not be accepted.

Please send me notices of any future hearing dates as well as any staff reports pertaining to this project.

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9 District 3: Miguel Arias: [email protected]
District 4: Tyler Maxwell: [email protected]
District 5: Special Election on March 18th
District 6: Nick Richardson: [email protected] District 7 Nelson Esparza: [email protected]
City Clerk: Todd Stermer: [email protected]
Mayor Jerry Dyer: [email protected]
D. RAMMING 1

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-475
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx David Ramming (First Letter) (D. RAMMING 1)
Response to D. RAMMING 1-1
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Please refer to Master Response 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.

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

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

Response to D. RAMMING 1-2
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. As discussed in Section 3.2, and consistent with the holding in the case cited by comment (Citizens for Open Government v. City of Lodi (2012) 205 CalApp4th 296), Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR, the proposed project would have a significant and unavoidable impact related to the conversion of farmland to nonagricultural uses and Williamson Act Contract land. MM AG-1 requires all future development in the Plan Area which would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural uses to evaluate and mitigate the potential loss of Farmland by utilizing the LESA Model and 1-1 conservation easements.

As the Court determined in the case cited by comment, Citizens for Open Government v. City of Lodi (2012) 205 CalApp4th 296, 323, a finding that there are no feasible mitigations measures will be upheld where it is supported by substantial evidence. Reviewing courts will ordinarily defer to an agency’s determination that a proposed measure will not provide mitigation. Notably, the comment does not identify any additional potential mitigation for consideration or disagree with the City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-476 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 conclusion in the Draft PEIR that impacts are significant and unavoidable with implementation of the project. Furthermore, no feasible mitigation is available that would reduce impacts to Williamson Act Contract land to less than significant, and impacts would remain significant and unavoidable. No further response is required.

Response to D. RAMMING 1-3
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.

Response to D. RAMMING 1-4
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. No further response is required.

Response to D. RAMMING 1-5
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.

Response to D. RAMMING 1-6
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.

Response to D. RAMMING 1-7
The comment is noted. As discussed in Section 3.9, Hazards and Hazardous Materials, the use of pesticides is regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-477
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 Specific Plan contains proposed policies that would further minimize risk of contamination from pesticides. For example, Policy RC-5.2 aims to prevent contamination of the groundwater table and surface water resources and discourage all pesticide use for agricultural and landscaping uses within SEDA through the use of signage, provision of pollution prevention information to SEDA residents and remediation actions. Additionally, project-specific pesticide use would be evaluated at the time of the project-specific CEQA analysis.

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 D. RAMMING 1-8
The comment is noted. As discussed in Section 3.9, Hazards and Hazardous Materials, the use of pesticides is regulated under FIFRA. Further, Section 3.10, Hydrology and Water Quality, provides analysis and mitigation measures associated with groundwater and surface water. Additionally, project-specific pesticide use would be evaluated at the time of the project-specific CEQA analysis.

Response to D. RAMMING 1-9
The comment is noted. 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.

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City of Fresno
City of Fresno Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, California 93721
[email protected]
Re: "Recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486"
Dear Ms. Pagoulatos,
I contest Section 3.10 Hydrology and Water Quality for the following reasons:

1. Impact HYD-2: States "The proposed project could substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin." The mitigation measure MM HYD-2d has not been adequately demonstrated in showing that the existing groundwater recharge facilities have produced adequate infiltration into the underground aquifers. Gallons of water input is shown but the real results would be revealed by the change in groundwater table near the basins. There is a large amount of water lost due to evaporation that has not been accounted for. Therefore, inadequate information is available to adequately assess the impact these basins are having. In addition, no studies are provided that show what the infiltration rate of proposed groundwater facilities in the SEDA area would be. The Fresno Irrigation District is building all its groundwater recharge facilities on the west side of its district as they feel the east side is less effective for groundwater recharge facilities. The United States Department of Agriculture, Agricultural Research Service, Stainable Agricultural Water Systems Research Laboratory at Davis, CA should be contacted and methodology they have developed be used to verify that the proposed sites for groundwater recharge facilities are indeed adequate to mitigate the overdraft of the North Kings Groundwater Basin. Even with the infiltration rate determined, theses recharge facilities are only functional when adequate water is available in "wet" rainfall years. Therefore, they are only adequate part of the time. Data is lacking needs to be developed to show how many recharge facilities would be needed on an average during wet and dry rainfall years to have no significant impact on the groundwater levels.

2. The hydrology and Water Quality Section 3.10 now completely ignores developing a plan, prior to exceeding existing water demands, and that the City shall pursue provision of adequate water supplies by securing additional water sources and shall not approve development per the Specific Plan for the Plan Area until additional water supply is provided. The city of Fresno is already using nearly all its allocation of surface water from the Fresno Irrigation D. RAMMING 2

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District (FID). The only way the city of Fresno can obtain additional water is by taking it away from other recipients. Agriculture is the main recipient of water from FID and reducing its water would have serious environmental impact. Important impacts would be: 1. Removal of agricultural land from production. 2. Reduction in the amount of food that could be produced.

3. Less water available for groundwater recharge basins in agricultural areas to replenish North Kings Groundwater basin that extends beyond Fresno City limits and sphere of influence.

3. Public comments received during the Draft Program Environmental Impact Report identified that groundwater overdraft is an issue in the City and requires that the Draft PEIR evaluates the SEDA Specific Plan's impact on groundwater resources. The recirculated EIR states in Impact HYD-2: The proposed project could substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. MM HYD-2d states the City shall develop new and expand existing groundwater recharge facilities to balance increased water demands resulting from the Project Area. The City's plan of reducing its reliance on wells and relying more on surface water, using more surface water to recharge the groundwater through recharge basins sounds great. However, the City of Fresno is already using the majority of its surface water allocation from FID. MM HYD-2c says the City of Fresno will seek additional water sources. No potential additional water resources are identified, therefore this EIR cannot be adequately evaluated based on unknown water sources.

4. Under Objective RC-6: Ensure that Fresno has a reliable, long-range source of drinkable , Policy RC-6-1, Natural Recharge. Support removal of concrete from existing canals and change the practice of lining new and existing canals with concrete to allow for natural recharge is unacceptable and is under the control of FID, not the City. Without concrete lining of canals: 1. Delivery of water to the city of Fresno and agriculture would be less efficient, meaning less water for both consumers at the city level and in agriculture. 2. The maintenance costs of the canals would be higher due to erosion of the banks and for weed control. There would be an increase in the soil particulates and contaminants in the water from the soil banks of the canal. 4. There will be damage to the canal banks by rodents and other animals, causing the loss of water from leaks and flooding. This policy and mitigation measure should not be implemented until the EIR is amended with a full report of impact on the environment and water quality.

5. Objective RC-6 "Ensure that Fresno has a reliable long-range source of drinkable water" is based on plans to be developed. Example: Policy RC-6-p Water plans. Adopt and implement ordinances, standards and policies to achieve... The effect of building in the SEDA area on the long range sources of drinkable water cannot be determined on plans that have yet to be developed.

D. RAMMING 2

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4 6. Impact HYD-5 The proposed project will impact the sustainable groundwater management plan by requiring more water for the increased population in the plan area. If increased surface water is used directly through water treatment facilities, it is not available for groundwater recharge, i.e. directly negatively affecting groundwater sustainability. Therefore mitigation measures are required.

7. Impact HYD-1. No support is given for the statement that "the proposed project would not ... degrade surface or groundwater quality." Industrial areas are incorporated in this plan and what they produce needs to be evaluated. What studies have been done that the oils in the asphalt roads will not be leached into the surface and groundwater? Based on these reasons, the recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486 should not be accepted.

Please send me notices of any future hearing dates as well as any staff reports pertaining to this project.

Very truly yours,
Dr. David Ramming
Retired Research Horticulturist, USDA/ARS
SEDA area property owner
Member Southeast Property Owner's Association
[email protected]
Please send CC to all City Council Members as they will be voting on this. cc: Sophia Pagoulatos, Planning Manager: [email protected] District 1: Annalisa Pera: [email protected]
District 2: Mike Karbassi: [email protected]
District 3: Miguel Arias: [email protected]
District 4: Tyler Maxwell: [email protected]
District 5: Special Election on March 18th
District 6: Nick Richardson: [email protected] District 7 Nelson Esparza: [email protected]
City Clerk: Todd Stermer: [email protected]
Mayor Jerry Dyer: [email protected]
D. RAMMING 2

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-483
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx David Ramming (Second Letter) (D. RAMMING 2)
Response to D. RAMMING 2-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

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.

Response to D. RAMMING 2-2
The comment is noted. Please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project.

Response to D. RAMMING 2-3
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 D. RAMMING 2-4
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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-484 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 D. RAMMING 2-5
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.

Response to D. RAMMING 2-6
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 D. RAMMING 2-7
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.

City of Fresno
City of Fresno Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, California 93721
[email protected]
Re: "Recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486"
Dear Ms. Pagoulatos,
I contest the following areas of the Recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486:

3.6 Energy. Impact ENER-1: The proposed project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. I disagree with this assumption because the plan specifies the addition of 45,000 housing units. This will increase the load placed on the electrical grid which is already stressed. For example, currently when we have extremely hot weather the power companies have implemented rolling blackouts to stretch energy as much as possible. This will only increase with the addition of 45,000 housing units and the estimated increase of 250,000 people in the plan area. This has to be addressed in the EIR. Where is all the necessary energy needed for this project to come from?

3.7 Geology, Soils, and Seismicity. Impact GEO-2: The proposed project would not result in substantial soil erosion or the loss of topsoil. I disagree with this statement for the following reasons. 1. The topsoil will be disturbed and impacted by the movement of soil to make the housing foundations and streets, disrupting the layers of soil then available for landscape around the houses. 2. The topsoil will be covered by houses and pavement so that it cannot be used for agricultural use including small family farms. 3. This essentially creates a loss of topsoil for use for vegetation which impacts the air quality and environment. This loss needs to be addressed as no mitigation measures are given and the level of impact is very significant.

3.9 Hazards and Hazardous Materials. Impact HAZ-7: The proposed project would not expose people or structures, either directly or indirectly to a significant risk of loss, injury or death involving wildland fires. I disagree with this statement, especially as we have seen this year, 2025, in the Los Angles area where wildfires = uncontrollable fires, have devastated housing and lives in many communities. Mitigation measures need to be taken so this does not happen in D. RAMMING 3

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the planned area. With the planned increase in the density of houses, this plan is setting up Fresno for disaster. Alternate plan 1 will reduce this problem and should be used instead. Impact HAZ-6: The proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. I disagree with this statement as the way the housing developments are being made with limited access and concrete block walls completely surrounding neighborhoods will limit emergency evacuation, endangering many lives. Mitigation measures need to be stated as the liability and loss of lives is significant. Alternate plan 1 will reduce this problem and should be used instead. Impact HAZ-5: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, the proposed project would not result in a safety hazard or excessive noise for people residing or working the project area. I disagree with the statement as we live in the planned area and the noise from aircraft approaching the airport is very disruptive when trying to hold conservations in person or on the phone, and while listening to audio entertainment. Even dual pane windows do not dampen the noise enough. Mitigation measures are required and the level of impact is Significant.

Section 3.8 Greenhouse Gas Emissions. Impact GHG-1: The proposed project would not generate direct and indirect greenhouse gas emissions, and these emissions would result in a significant impact on the environment. I disagree that no greenhouse gas emissions would be created or affected from the proposed plan. This plan will reduce vegetation which absorbs carbon dioxide, one of the leading greenhouse gases. Mitigation measures are required, none are stated and its impact level is significant. You even state in your impact statement that the project will not generate direct or indirect greenhouse gas emissions (I disagree and want to know what data and studies you have done to substantiate this statement), but add that there would be significant impact on the environment. Don t use this plan, instead use Alternate 1 to keep greenhouse gas concentrations lower.

Section 3.11 Land Use and Planning. Impact LAND-1: The proposed project would not physically divide an established community. This plan will divide our established rural communities, disrupting the rural way of life that is healthy for us and our children and grandchildren. Mitigation measures are required as levels of impact are significant.

Cumulative Impact: The project would have a less than significant cumulative impact on land use and planning. This project will have a very large and significant cumulative impact on land use as it will take over 6,000 acres of farm land out of production, changing the landscape of the whole community, affecting air quality, and affecting the balance of greenhouse gases. No mitigation measures are stated, even though the impact of this project is significant. This is unacceptable and this Recirculated Program Environmental Impact Report should not be accepted.

D. RAMMING 3

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Section 3.12 Mineral Resources. Cumulative Impact: The proposed project would have a less than significant cumulative impact on mineral resources. The project would have a great impact on the mineral resources of the soil that crops are grown on. The project limits the availability of the soil for the production of food and fiber for people and animals. The soil is the greatest mineral resource we have available to us and if it is covered by houses and roads as desired by this plan, significant loss of natural resources will happen. This is unacceptable and this Recirculated Program Environmental Impact Report should not be accepted.

Section 3.13 Noise. Cumulative Impact: The proposed project would have a significant and unavoidable impact regarding construction noise. The proposed project would have a less than significant impact with regard to all other noise and vibration impacts. The analysis of noise is incomplete as it only addresses noise and vibration impacts during construction. The increase in noise after construction due to road noise and increased population noise is not considered and it would be significant. This makes this Recirculated Program Environmental Impact Report incomplete and it should be rejected until this issue has been addressed.

Based on these reasons, the recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486 should not be accepted.

Please send me notices of any future hearing dates as well as any staff reports pertaining to this project.

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District 7 Nelson Esparza: [email protected]
City Clerk: Todd Stermer: [email protected]
Mayor Jerry Dyer: [email protected]
D. RAMMING 3

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-489
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx David Ramming (Third Letter) (D. RAMMING 3)
Response to D. RAMMING 3-1
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 D. RAMMING 3-2
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, as detailed in Section 3.7, Geology, Soils, and Seismicity, of the Recirculated Draft PEIR, compliance with mandatory NPDES permit requirements and the Municipal Code requirements and General Plan policies and proposed Specific Plan policies would minimize potential soil erosion impacts and loss of topsoil from construction-related soil disturbance for construction activities that occur pursuant to the proposed project. As such, potential impacts related to soil erosion and loss of topsoil would be less than significant. No further response is required.

Response to D. RAMMING 3-3
The comment is noted. Please refer to Master Response 12, Clarifying Information on Wildfire Analysis, in Section 2, Master Responses. Master Response 12 elaborates on the methodology used in Section 3.19, Wildfire, of the Recirculated Draft PEIR. No further response is required.

Response to D. RAMMING 3-4
The comment is noted. At the programmatic level, impacts to the Plan Area would be less than significant. Consistent with the General Plan and SEDA Specific Plan policies, individual development projects would be required to undergo project-specific environmental review, which may require additional site-specific or project-specific measures to reduce any potential impacts and ensure that impacts remain less than significant.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-490 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 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 D. RAMMING 3-5
The comment is noted. As described in Section 3.9, Hazards and Hazardous Materials, of the Recirculated Draft PEIR, Fresno Yosemite International Airport is located approximately 2 miles from the Plan Area, along East Clinton Way. According to the Fresno Yosemite International Airport Safety Compatibility Zones Map, a small portion of the Plan Area is located within the 60 dB CNEL contour.14 A Larger portion of the Plan Area is located within the Traffic Pattern Zone.15 The 2018 Fresno County Airport Land Use Compatibility Plan (ALUCP) is the plan that governs land use compatibility around Fresno Yosemite Airport. State law establishes that the Fresno County Airport Land Use Commission (ALUC) is one of the review authorities for new land use plans in the Airport Influence Area (AIA). Therefore, ALUC review of the Specific Plan is required. The ALUC advises the City on land use designations in terms of noise, safety, and airspace hazards. The ALUC found the proposed project to be consistent with the ALUCP on August 7, 2023. Therefore, at the programmatic level, impacts to the Plan Area would be less than significant. Consistent with the General Plan and SEDA Specific Plan policies, individual development projects would be required to undergo project-specific environmental review, which may require additional site-specific or projectspecific airport land use compatibility measures to reduce any potential impacts and ensure that impacts remain less than significant.

Response to D. RAMMING 3-6
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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-491
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 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.

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 D. RAMMING 3-7
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to D. RAMMING 3-8
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-492 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to D. RAMMING 3-9
The comment is noted. In the context of the CEQA, mineral resources are land areas or deposits deemed significant by the California Department of Conservation (DOC). Mineral resources include oil, natural gas, and metallic and nonmetallic deposits, including aggregate resources. Therefore, agricultural land is not considered a mineral resource under CEQA. No further response is required.

Response to D. RAMMING 3-10
The comment is noted. As detailed in Section 3.13, Noise, of the Recirculated Draft PEIR, includes an evaluation of both operational and construction noise impacts that could occur with the implementation of the proposed project.

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

From: beatrice deleon
To: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer; LongRangePlanning
Subject: EIR
Date: Wednesday, March 19, 2025 8:17:24 PM
External Email: Use caution with links and attachments
Section3.15 Public Service
Question: Who will pay for the massive bill to build schools to accomodate the high density population located in the Sanger Unified School District?
Since Sanger Unified has replied to this project in writing with great concern, please document the projects costs involved with the school district and the plan to fund these schools. Why have no estimated costs been given? Are you concerned that that truth would be detrimental to the project? Going forward with no plan to implement school growth is unacceptable and needs to be corrected. Asking taxpayers to fund a “blank check” is unacceptable and needs to be corrected also.

Section3.17 Transportation and Traffic
Question: How is the City of Fresno planning to pay for the infrastructure cost? It has been reported that this will be ironed out after the council approves the massive project. What is the proposed infrastructure cost? The budget needs to be disclosed before the EIR is accepted. This “blank check” is unacceptable and needs to be addressed prior to any approval.

Section 3.18 Utilities and Service Systems
Question: What will the long term impact on the environment be when expanding or relocating electrical, natural gas, or telecommunication facilites for a project of this magnitude? Please site your studies. No information concerning this is unacceptable and needs to be addressed.

Section 3.19 Wildfire
Question: Due to the close proximity of the high density, and therefore, the high wildfire risk of rapid spreading, please state your plan to protect the occupancy from disasters like what happened in Los Angeles this year. Without a plan in place, this plan is unacceptable and needs to be corrected.

Sent from my iPhone

DE LEON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-495
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 Beatrice De Leon (DE LEON)
Response to DE LEON-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.

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

Response to DE LEON-4
The comment is noted. Please refer to Master Response 12, Clarifying Information on Wildfire Analysis, in Section 2, Master Responses. Master Response 12 elaborates on the methodology used in Section 3.19, Wildfire, of the Recirculated Draft PEIR. No further response is required.

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Juliet Doty
1251 N. Fancher Avenue
Fresno 93737

2.24.25 City of Fresno Planning Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno 93721
559.621.8062
Dear Ms Pagoulatos,
I am writing to formally oppose the Revised Environmental Impact Report (EIR) for the Fresno Southeast Development Area (SEDA), particularly concerning the issues raised in Sections 3.2 and 3.3.
**Agricultural Resources and Forestry Resources (Section 3.2)** The impact of losing agricultural land, especially the income for Hmong farmers, is a significant concern. There is a pressing need for studies that specifically address this loss and offer solutions to mitigate the impact on this minority community. It is unacceptable to neglect the livelihoods of these farmers, and I urge the city to prioritize this issue.

Additionally, the City of Fresno has documented its intent to preserve Prime Farmland.

The current plan contradicts these goals, as overriding signed documents dedicated to preserving such land is not only irresponsible but should also be corrected before any further action is taken.
**Air Quality (Section 3.3)**
The proposed increase in the electrical grid’s capacity raises serious questions about its impact on Fresno. It is unacceptable to proceed without a thorough understanding of this effect. Furthermore, the projected substantial increase in air pollution emissions— potentially by 600% in some areas of Southeast Fresno—has not been adequately analyzed regarding its public health implications. The notion of addressing these concerns only after project approval is akin to providing a "blank check," which is wholly unacceptable and must be documented prior to any approvals. **Concerns Regarding Utility Connections and Costs**
The responsibility placed upon residents to connect to the city's water and sewer lines, coupled with the associated costs, is troubling. The potential financial burden— estimated to exceed $100,000 for water and sewer connections combined—could severely impact homeowners, particularly those on corner lots who would be liable for both sides of their property. Furthermore, the mandatory nature of these hookups and the imposition of a lien on properties for failure to comply are concerning.

DOTY

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The long-term implications of annexation for the rural lifestyle, including increased taxes to accommodate the projected population growth, are alarming. The transformation of prime agricultural land into high-density housing will negatively impact water supply, air quality, and property values, which cannot be overlooked.

In conclusion, the Revised EIR for the Fresno Southeast Development Area must be reevaluated in light of these critical concerns. I implore the Planning Department to consider the long-term impacts on our community, the environment, and the livelihoods of those affected.

Thank you for your attention to this important matter.

Sincerely,
Juliet Doty
DOTY

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5 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-499
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 Juliet Doty (DOTY)
Response to DOTY-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.

No further response is required.

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

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

Response to DOTY-3
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

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

Response to DOTY-4
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-500 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 DOTY-5
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide 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: Erika Leonard
To: LongRangePlanning
Cc: Annalisa Perea; Andrew Janz
Subject: SEDA public comment from District 1 resident Erika Leonard Date: Sunday, March 9, 2025 7:40:43 AM
External Email: Use caution with links and attachments
Dear Fresno Long Range Planning Team,
I am a City of Fresno District 1 resident writing in response to the new proposed SEDA Environmental Impact Report draft.

I strongly object to the SEDA plan described in the Recirculated Draft PEIR and urge all City leaders to wholeheartedly reject SEDA in full. SEDA will harm the City of Fresno, our neighborhoods, and Fresno residents. The harm is likely to be profound and last for decades.

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

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

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

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

SEDA will ham Fresno businesses. I hear business owners asking for improvements to sidewalks, parking, drainage, traffic flow, and lighting. Thriving businesses support a thriving Fresno, and they deserve better. Investing in SEDA without clear assurance that SEDA will NOT redirect the City's already minimal infrastructure attention away from our existing business districts will be a blow to our existing businesses.

SEDA will destroy existing communities of county residents who have no voice in this process. I have listened to the upset voices of people currently living in the area that would be transformed by SEDA. It’s not yet part of the City, so they have no council members to fight for them - or even listen to them. SEDA threatens their communities and their agricultural land without taking their interests into account.

E. LEONARD

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

With appreciation for your public service,
Erika Leonard
619 East Hedges Avenue
Cell 510-334-2242
E. LEONARD

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6 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-503
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 Erika Leonard (E. LEONARD)
Response to E. LEONARD-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 E. LEONARD-2
The comment is noted. Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

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

Response to E. LEONARD-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 E. LEONARD-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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

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E. RODRIGUEZ

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1 SEDA states that the plan intends to incorporate small scale agricultural operations to honor the heritage of the area. The plan neglects to mention the degradation of already existing agricultural land. SEDA's proposed project area crosses both North Kings Groundwater Sustainability Agency and Central Kings Groundwater Sustainability Agency (GSA) boundaries. (SEDA Draft Specific Plan & CA.Gov, 2025) Both of these GSAs are required by the Department of Water Resources (DWR) and State Water Resource Control Board (SWRCB) to implement groundwater sustainability plans (GSPs). The potential projects included in these plans are: incentivizing lower water use, constructing groundwater recharge facilities, improving pre-existing irrigation infrastructure, fallowing agricultural land for reduced water use, constructing habitat, etc. In order to fund these projects, DWR has awarded 139.5 million dollars to GSP development, implementation, modification, etc. The DWR has also allotted 176.5 million dollars to critically overdrafted basins specifically, which require a great deal more planning and work to reach groundwater sustainability goals, also for GSP implementation (CA.GOV, 2025). This may sound like a large sum of money awarded to GSAs, but with over 260 GSAs (CA.GOV, 2025), this money disappears quickly.

In order to cover costs for GSP implementation, GSAs have the authority to hold Proposition 218 votes. These votes are usually based on acreage ownership and result in an increase in the local tax to be invested in the GSPs planned projects (lao.ca.gov, 1996).

While Proposition 218 fees are required to be charged proportionally to the cost of services provided, this still goes against the benefits listed in the SEDA plan. New, lower-income residents would be required to contribute to the City of Fresno GSA assessment fees, with this being added as a property tax (if they own the property). If they do not, the owner of said property must cover the fees and will most likely charge the residents a higher rent in order to cover the disparity. Despite SEDA proposing that the new developments are intended to help new owners move into their own spaces, it does not seem that the negative effects SGMA requirements have on lower income/younger families has been discussed.

The SEDA plan also lists that the preservation of agriculture and farms is a high priority of theirs. However, the plan removes large swaths of land that would be contributing to both Central Kings and North Kings GSA Proposition 218 fees as well as irrigation fees (which do not require a Proposition 218 vote to be implemented). This increases the associated costs for all farms in their respective GSAs, but the smaller family farms suffer severely. An example of a sudden fee increase is Chowchilla Water District's recent fee increase to cover expenses related to the GSP projects they are responsible for in their section of the Chowchilla Sub basin. The district went from charging water users $110 an acre-foot to $165 an acre-foot for irrigation water. This means a small operation could have a sudden l .5x increase in their payments for water services alone, with a much E. RODRIGUEZ

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larger potential for a higher fee if there is less farmland to account for the charge. This does not account for the potential increase resulting from a Proposition 218 vote, which could be held in an attempt to raise funds for projects and potential result in farmers paying two "separate" entities at the same time for the same service.

I highly discourage the development of a new part of Fresno, specifically one that removes farmland from operation and puts unnecessary financial strain on residential areas intended to benefit from it.

Thank you, and I urge a reconsideration of how to best manage Fresno's need for integrated/affordable housing.

Erik Rodriguez
Citation:

California, S. of. (n.d.-a). Groundwater Sustainability Agencies. Department of Water Resources.
https:/ /water.ca.gov/Programs/Groundwater-Management/SGMA-Groundwater-Manageme nt/Groundwater-Sustainable-Agencies#:~:text=SGMA%20required%20Groundwater%20S ustainability%20Agencies,by%20SGMA's%20initial%20planning%20milestone California, S. of. (n.d.-b ). Sustainable Groundwater Management Grant Program.

Department of Water Resources.
https://water.ca.gov/work-with-us/grants-and-loans/sustainable-groundwater Sustainable Groundwater Management Act (SGMA) portal - Department of Water Resources. (n.d. ). https://sgma. water.ca.gov/webgis/index.j sp?appid=gasmaster&rz=true Understanding proposition 218. (n.d.).
https://lao.ca.gov /1996/120196 _prop_ 218/understanding_prop218 _ 1296.html City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-507
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 Erik Rodriguez (E. RODRIGUEZ)
Response to E. RODRIGUEZ-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: Connie Enns-Rempel
To: LongRangePlanning
Subject: SEDA
Date: Saturday, March 22, 2025 9:19:39 PM
External Email: Use caution with links and attachments
Hello! My name is Connie Enns-Rempel, and I have lived in the downtown Fresno area for over 50 years. I live in this area by choice, as I love the community, and I also love the larger city of Fresno. I am concerned that once again the city is spending its focus on expansion through housing developments rather than tending to the areas that are already established. We need our resources to go toward the care of the areas that already exist, to repair roads and sidewalks, tend to the street and freeway medians that are often neglected and littered up, clean up graffiti, repair lights, pay for fire and police. There are empty lots that could be filled in. There is much to be done to care for what we have. Please invest resources into tending to the wonderful but neglected areas of our beloved city, rather than once again add to the sprawl.

Thank you for your consideration.

My business phone number is 559-227-5449.

Sincerely,
Connie Enns-Rempel

ENNS-REMPEL

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-511
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 Connie Enns-Rempel (ENNS-REMPEL)
Response to ENNS-REMPEL-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.

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From: Linda Foster
To: LongRangePlanning
Subject: Concerns About the SEDA Recirculated EIR
Date: Sunday, March 23, 2025 11:59:55 PM
External Email: Use caution with links and attachments
Dear Ms. Pagoulatos.

Subject: I am Concerned about SEDA.

I do not believe that Fresno needs to rip up farmland in the southeast Fresno area to build more expensive, single family homes.

FRESNO'S REAL NEEDS
Invest in Fresno's Existing Communities.

What Fresno severely needs, is for truly affordable housing to be developed in already existing neighborhoods. Not more huge, single family houses built in the boondocks.

AFFORDABILITY
$400,000.00 is not affordable to people making $15.00 an hour. We need housing for waiters, care providers, shop clerks, and other regular people living here. Housing for the people who keep things running and working.

3.17 - TRANSPORTATION AND TRAFFIC
What we really need is housing that is small, centrally located, easy to maintain, and located on bus routes. We need single and multi-family housing that is reasonably priced, safe, well built, environmentally conscious, near shopping, jobs, and other services.

IDEAS
Convert older homes, vacant big box stores, Manchester Center, vacant lots, and go up, not out to the farmland. Small to moderate multiple unit, multiple story buildings. Tuck them in everywhere . Convert, repurpose, rethink, reuse, reinvent.

3.3.4 - AIR QUALITY ISSUES
Our air quality will suffer from all the extra miles driven by residents commuting from this former farmland. On top of the effects of destroying the farmland and losing the cleaner air from that area.

This is not a viable idea. It does not solve the actual housing issues we have here in Fresno. It will just add even worse issues and ramp up inequality.

FOSTER

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Submitted by:

Linda Foster
113 W. Palo Alto Ave.

Fresno, CA 93704
City of Fresno District 2
559-438-4235 cel/text
[email protected]
FOSTER

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-515
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 Linda Foster (FOSTER)
Response to FOSTER-1
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to FOSTER-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 FOSTER-3
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 FOSTER-4
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.

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From: [email protected]
To: LongRangePlanning
Cc: Nick Richardson
Subject: Concerns about the SEDA Recirculated EIR
Date: Friday, March 21, 2025 7:07:22 PM
External Email: Use caution with links and attachments
Friday, March 21, 2025
Dear Ms. Pagoulatos:

I am writing to express my concerns about the SEDA Recirculated Environmental Impact Report (EIR). These are some of the areas that alarm me:

Section 4-2: Growth-Induced Impacts
While the SEDA plan estimates that the population of Fresno will increase by 226,000 people by 2035, the most recent data from the State of California Department of Finance estimates a much smaller growth, 72,000 by 2035 and an additional 19,000 by 2070! The commitment to transform this agricultural land to an entirely new suburb could be a financial disaster for the City.

Section 3.3.4 Air Quality
Fresno already has some of the worst air quality in the U.S. The SEDA plan admits it will increase the levels of pollution. Knowing that, why would you pursue this development? Section 3.17 Transportation and Traffic
The report claims that the residents of this new suburb of Fresno, larger than the current population of Clovis, will drive only 5 miles per day. Experts estimate that is 80% less than what they will drive. It is inconceivable that the adult residents of this new suburb, possibly 70,000 people, will find employment within a 2-1/2 mile radius of their new home. And that does not even account for travel for shopping and leisure activities! I live near the Herndon/Cedar intersection. There are cars zooming everywhere, nearly 24 hours a day, in this Northeast quadrant of Fresno. I can’t believe your EIR is correct about how those new homeowners will hunker down in their new community. Fresno would be much better positioned as a desirable place to live if the City Council would energize itself around creating a 21st-century downtown. I cannot think of a major city in California that makes a worse impression than Fresno’s downtown does. That is the heart of the City. There are so many things the City Council can do to make Fresnoans proud. SEDA will take money from all those necessary investments.

Sincerely,
Bette Blythe Francis
2035 East Palo Alto Avenue
Fresno, CA 93710
Sent from my iPad

FRANCIS

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-519
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 Bette Francis (FRANICS)
Response to FRANICS-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. No further response is required.

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

Response to FRANICS-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 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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To: [email protected]
With copy to:

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

To Whom It May Concern,
I am writing in reference to the Environmental Impact Report (EIR) and the proposed implementation of the South East Development Area (SEDA) Plan. After a thorough review of the documentation, I have several concerns and questions regarding the rationale, feasibility, financial implications, environmental impact, and long-term effects on both the residents within the proposed development area and the broader Fresno community.

Housing vs. Employment Disparity
According to the EIR (Section ES-2, Quantified Objectives), the SEDA Plan intends to accommodate between 40,000 to 45,000 new dwelling units while only planning for the creation of approximately 30,000 to 37,000 jobs (Chapters 3.14 and 2.3, respectively). This raises a serious concern: What is the justification for building significantly more housing units than there are jobs to support future residents? Without adequate local employment opportunities, how are prospective homeowners expected to afford living in the area? What mechanisms will the City of Fresno implement to ensure this imbalance does not lead to increased economic instability, traffic congestion, or further strain on regional resources? Fiscal Responsibility and Transparency

GAMRADT

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The EIR claims that the SEDA Plan will be self-financing and will not detract from existing citywide resources, nor place a financial burden on residents outside the project area (Section ES-2, Fiscal Responsibility). However, the actual cost of the SEDA Plan and details surrounding its financing structure are conspicuously absent from both the EIR and the Plan itself. What is the projected total cost of the SEDA Plan? What mechanisms constitute this “self-financing,” and how reliable are they? If outside residents are not expected to shoulder the financial burden, does this mean those within the SEDA area will? If so, how much will taxes increase for SEDA residents? Without full transparency, the claim of fiscal responsibility remains unsubstantiated.

Neglected Alternatives: Adaptive Reuse of Existing Infrastructure Chapters 3.11 and 3.18, and again on ES-2, fail to consider the potential cost savings and sustainability benefits of adaptive reuse and renovation of existing structures. Adaptive reuse is widely known to be more cost-effective than large-scale new developments and would reduce the need for expensive new infrastructure such as roads, water, sewer, and power lines. Why has the City of Fresno not prioritized this option as a viable alternative? Contradictory Emissions Claims and Health Risks
The EIR (Section ES-2, Social Equity; Chapter 3.8) claims that the SEDA Plan will promote health by reducing harmful emissions. However, this fails to address the substantial environmental and health impacts during the construction phase. The use of heavy machinery and diesel-powered equipment will release hazardous pollutants into the air and soil. What specific steps will be taken to mitigate this impact during construction? How will the city protect the health of current and future residents, workers, and wildlife from prolonged exposure to fine particulate matter, diesel exhaust, and other toxic emissions known to increase the risk of cardiovascular disease, respiratory illness, and cancer? Loss of Agricultural Resources and Williamson Act Violations Section ES-5 (Impact AG-2; Chapter 3.2) outlines that the SEDA Plan will convert land currently under the Williamson Act into non-agricultural uses without any mitigation measures.

This directly contradicts the Act’s intended purpose. Has the City calculated the monetary penalties—potentially up to 25% of the market value of the land and 25% of the value of incompatible improvements? How will these penalties be paid, and will they fall on SEDA residents in the form of higher taxes? Why does the plan ignore the irreversible damage caused by eliminating thousands of acres of prime farmland when more sustainable, infill development options are available?
Water Resources and Infrastructure Concerns
Chapter 3.10 (Hydrology and Water Quality) presents no clear financial plan or resource management strategy for the enormous water requirements this project will demand. What is the projected budget for developing adequate stormwater systems, adjusting drainage patterns, and capturing runoff? Most importantly, where will the City of Fresno source the millions of gallons

GAMRADT

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of water needed to build and maintain 40,000–45,000 homes in a region already experiencing water scarcity?
Transportation and Transit Infrastructure
On page 2-18 and within Chapter 3.17 (Transportation and Traffic), the EIR mentions plans for “high-quality transit service,” yet there are no specifics on implementation, budget, timeline, or environmental impact. How will such transit systems be funded? Where is the corresponding environmental review? Without concrete details, these claims appear speculative and do not justify proceeding with such a large-scale development.

Public Safety and Emergency Services
Chapter 3.15 (Public Services) does not adequately address how the city plans to expand and fund critical emergency services—including police, fire, and medical response—to meet the demands of a significantly larger population and expanded infrastructure. How will Fresno ensure not just the maintenance but the improvement of emergency response times and safety outcomes? What is the budget, hiring plan, and timeline for scaling up these essential services? Ethics, Transparency, and Accountability
Given the scale and stakes of the SEDA Plan, transparency is non-negotiable. I ask directly: how much money or other benefits—financial or otherwise—are City of Fresno officials, developers, contractors, or consultants receiving in connection to this project? Taxpayers deserve to know whether public decisions are being influenced by private gain.

Environmental and Health Impacts from Hazardous Materials Chapter 3.9 (Hazards and Hazardous Materials) raises yet another serious concern. What measures will be taken to prevent accidental releases of toxic substances during construction and operation phases? What is the City’s mitigation plan to address the increased burden on landfills due to construction waste?
Permanent Loss of Prime Farmland
As stated in Chapter 3.2, the proposed development will irreversibly convert essential farmland into non-agricultural uses. No meaningful mitigation efforts are outlined. Why is Fresno choosing to sacrifice its agricultural heritage and economic base rather than explore higherdensity urban infill options? How does the city reconcile this with its commitment to sustainability and food security?
Air Quality Degradation
According to Chapter 3.3, the SEDA Plan will generate pollutant levels that exceed the thresholds established by the San Joaquin Valley Air Pollution Control District. This is particularly troubling considering the region’s long history of fighting air pollution. After

GAMRADT

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decades of progress, we now enjoy improved visibility and cleaner air—yet this plan threatens to undo all of that. What is the City’s plan to mitigate the increase in particulate matter, ozone, nitrogen dioxide, and diesel exhaust—pollutants known to cause asthma, lung disease, and cancer?
Vehicle Miles Traveled (VMT) and Commuting Realities
While the SEDA Plan emphasizes its goal to reduce vehicle miles traveled (VMT), it paradoxically proposes 40,000–45,000 housing units but only 37,000 local jobs (referencing Chapters 3.14 and 3.17). This means thousands of residents will be forced to commute outside the area for work—driving more, not less. With companies increasingly requiring employees to return to the office, this discrepancy will likely increase VMT, vehicle emissions, and health issues tied to prolonged traffic exposure. How does the City intend to square this contradiction? Conclusion
These questions and concerns merely scratch the surface of the numerous inconsistencies, oversights, and gaps in the SEDA Plan and EIR. Despite years of planning, it remains unclear how this project serves the best interest of the community at large. There are more equitable, sustainable, and fiscally responsible alternatives that would benefit all residents—not just elected officials, developers, and contractors. It is imperative that the City of Fresno halt approval of the SEDA Plan until it can offer clear, transparent, and comprehensive answers to these concerns.

Sincerely,
Joe Gamradt
2736 N De Wolf Ave
Fresno, CA 93737

GAMRADT

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-525
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 Joe Gamradt (GAMRADT)
Response to GAMRADT-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 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 GAMRADT-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 GAMRADT-3
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 GAMRADT-4
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

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

As noted above, the proposed project is a policy-level document and does not propose any specific site development at this time. Future development associated with the proposed project would be required to undergo CEQA analysis on a project-by-project basis as necessary. As such, the mitigation measures identified above require future development in Plan Area to provide technical analyses as part of the project environmental review for construction, operational, and health impacts and mitigate the identified impacts in those technical studies to the greatest extent possible. The City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-526 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx mitigation measures also include potential mitigation strategies for future development to utilize to reduce air quality impacts. Future development in the plan area will still have to go through the appropriate level of environmental review where impacts to air quality will be evaluated against the suggested significance thresholds in Appendix G to the CEQA Guidelines, which is the City’s standard practice. No further response is required.

Response to GAMRADT-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.

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.

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

Response to GAMRADT-7
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to GAMRADT-8
The comment is noted. 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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-527
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 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 GAMRADT-9
The comment is noted. 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 GAMRADT-10
The comment is noted.

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

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

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

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

To reduce the significant impacts associated with the solid waste disposal, the City will need to increase disposal capacity. The policies in the General Plan are designed to reduce the potential 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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-528 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 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 GAMRADT-11
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 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.

Response to GAMRADT-12
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

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 GAMRADT-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. No further response is required.

Response to GAMRADT-14
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.

GOTTSELIG

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1 March 23, 2025
City of Fresno
Long Range Planning
[email protected]
Re: Southeast Development Area Specific Plan
Dear City of Fresno Planning,
My name is Rebecca Gottselig and I am a resident of Fresno District 5. I am writing to you rather than my council member as my district does not currently have a representative. I would appreciate your time in answering some questions I have pertaining to the Southeast Development Area Specific Plan ("SEDA"). While I, like most people, am concerned with how SEDA while impact the quality of life in my own neighborhood, I also am writing with concern for the long-term health of Fresno as a whole. I have lived, worked, and been educated in many parts of Fresno and am hopeful none of our city will be negatively impacted by SEDA.

The main question I hope can be answered: Is SEDA an economically viable plan for the City of Fresno ("COF")?
For the developers, SEDA will undoubtedly be profitable. But what will SEDA cost COF, and can it be afforded without diminishing current services or raising taxes? If so, what information can be provided in support of that assertion?
There are established neighborhoods throughout Fresno with existing infrastructure needs. Will COF be able to address the present and forthcoming needs of existing infrastructure while also funding the infrastructure needed for SEDA? For example, in my own neighborhood, we have huge trees that provide beauty and shade for residents and visitors alike. The majority of these trees are in COF easements and ultimately the responsibility of COF. Many of the trees are aging and in need of regular maintenance or replacement that they don't receive. Multiple of these trees are in front of my own property. The loss of these trees would be a huge detriment to my own longstanding neighborhood in Fresno if infrastructure funds are diverted from current projects, or currently needed projects, to SEDA. These trees are lush, shade-giving, air-cleaning beauties - which are a huge asset COF possesses. These assets should be properly stewarded. If that can be done while also adding new infrastructure with SEDA - wonderful! But it would be a shame to have these assets deteriorate because COF can't fund both existing infrastructure and new, SEDA infrastructure. The same should be considered for all neighborhoods in Fresno: will SEDA financially require COF to neglect current assets in favor of newer prospects? Apart from physical infrastructure, will COF be able to afford the cost SEDA requires for first responders without loss of services to existing COF residents? I am so grateful for the Fresno Police Department ("FPD") and all they do to serve our community. I regularly call FPD to report non-emergency issues. Last year I called FPD with concern of someone who rang my doorbell at 4:00am. It quickly became apparent the individual was on drugs or mentally unstable.

GOTTSELIG

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While the issue didn't present immediate threat to my life, it could have quickly turned unsafe. I waited for over an hour to have an officer dispatched to my home to address the situation. All the while my children were asleep inside with a potentially harmful stranger on my property.

Thankfully this issue was resolved by FPD without harm to any party. However, I don't desire to live through the stress of that situation again, potentially for an even greater period of time, should the addition of SEDA overextend FPD resources.

Ultimately, I support growing our city if warranted, providing infrastructure to allow for that growth, and seeing economic returns for all involved in the process. However, I don't think that should be done at the expense of already existing neighborhoods and residents. If SEDA is not economically viable for COF, what alternatives can be proposed? For example, are SEDA developers open to discuss cost sharing with COF for the infrastructure needed that is above and beyond the capital deposit already being required?
I hope this question has already been thoroughly researched and thought through for those considering approving SEDA. And truly, I hope the answer is a clear "Yes, COF can afford SEDA without deferring funds from existing neighborhoods." With that, I will look forward to an exciting, profitable, new development that can create interest, health, and prosperity for our city. However, if answers are not available or clear, please consider postponing approval of SEDA until adequate answers can be available for all those affected by this huge decision.

Respectfully,
Rebecca Gottselig
[email protected]
3828 E Huntington Blvd.

Fresno, CA 93702
559-346-8733
City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-531
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 Rebecca Gottselig (GOTTSELIG)
Response to GOTTSELIG-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.

1. Groundwater Supplies
The majority of residents of the defined 9,000+ acres have their own sufficient water access via personal pumps: both residential and agricultural
--The EIR suggests that it will not approve any development plans until additional water capacity is provided through “…improvements…” in accordance with the City. I need to know who is going to pay for these improvements, what they may entail, if present residents can maintain their current water access and if not, who will subsidize the ENTIRE costs of upgrading or changing to city requirements.

2. Light, Glare, Noise, Fire
Presently, the proposed areas enjoy a less blatant exposure to the negative city atmosphere of street lights that permeate homes, glare that obliterates the evening skies, and incredible noise from hundreds and hundreds of homes, vehicles and properties that inevitably create excessive incursion into others private properties that will create disputes, hostilities and eventually complaints to law enforcement. Increased police and fire requirements will be vital for any area expecting this huge increase of population. Regulations and laws will have to be strictly enforced or it may be “handled” by established residents who find their lifestyles invaded and violated.

3. Agriculture requirements of crop fertilizers/pesticides/soil enhancements Will there be new restrictions on presently used and accepted crop airborne soil and crop solutions? Will there be controls/limitations tomorrow what is perfectly fine today?

4. Large and small animal ownership
Will there be new restrictions on the animals that many residents typically own but are not customary or approved to city residences, such as cows, sheep, goats, horses, chickens, pigs, etc.

5. Increase on present residential costs, such as sewer and water hook up? Agricultural pumps for water access? Any fencing changes for utility access? The present access to FID (Fresno Irrigation District) water canals? Fireplace usage for properties without access to natural gas hookup?
a. Who will cover the costs for these immense changes in utilities? b. Will there be property tax increases for the changes forced on the residents? c. Will there be increased costs for the access for police, fire, and emergency services?

GROSSMAYER

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2 d. What about the insurance cost increases create
d by companies who see fire dangers with so many homes so close together that can cause immediate need of emergency services?
e. Will the city still provide ditch tenderers, canal management and repair, weed abatement?
It seems like the City of Fresno already has a lot on it’s plate without this land grab. Who is this for… developers and political donors?
Property owners and residents in this area don’t want to be annexed into the City of Fresno. We don’t want Fresno to become another LA with this urban sprawl. If you care about the people who live here now, put it to a vote and let their voices be heard! Elizabeth J Grossmayer
735 N Locan Ave
Fresno, CA 93737
[email protected]

GROSSMAYER

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6 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-535
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 Elizabeth Grossmayer (GROSSMAYER)
Response to GROSSMAYER-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 4, Implications of Annexation, in Section 2, Master Responses.

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

Section 3.15, Public Services, of the Draft PEIR, discussed and analyzed the provision of public services within the Plan Area for the proposed project. Although the proposed project would increase the population of the Plan Area, and thus, increase the need for police services, the Specific Plan includes proposed policies related to police protection which would reduce impacts to police services. For example, the Specific Plan includes 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 FPD 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 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 pay any development fees applicable at the time site-specific development applications are received to offset the construction and acquisition costs of required police facility improvements.

Furthermore, 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. Therefore, future development under the City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-536 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 proposed project would not result in significant adverse effects related to police services and impacts would be less than significant.

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 Fresno Fire Department (FFD) 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 pay any development fees applicable at the time site-specific development applications are received in order to mitigate the impacts on fire protection facilities caused by future development within the City.

Payment of these development fees would offset the construction and acquisition costs of required fire facility improvements.

Additionally, future development within the Plan Area would be required to pay any development fees applicable at the time site-specific development applications are received to offset the construction and acquisition costs of required police facility improvements.

Furthermore, as the City receives development applications for subsequent development under the proposed project, those applications will be reviewed by the City for compliance with the policies and objectives of the General Plan to ensure that fire protection services keep pace with new development. In addition, the Fresno Municipal Code, which implements the City’s General Plan, would be reviewed when development applications are received. Therefore, future development under the proposed project would not result in significant adverse effects related to fire protection services and impacts would be less than significant. No further response is required.

Response to GROSSMAYER-3
The comment is noted. As discussed in Section 3.9, Hazards and Hazardous Materials, of the Recirculated Draft PEIR, the use of pesticides is regulated under FIFRA. The Specific Plan contains proposed policies that would further minimize risk of contamination from pesticides. For example, Policy RC-5.2 aims to prevent contamination of the groundwater table and surface water resources and discourage all pesticide use for agricultural and landscaping uses within SEDA through the use of signage, provision of pollution prevention information to SEDA residents and remediation actions.

Additionally, project-specific pesticide use would be evaluated at the time of the project-specific CEQA analysis. The comment does not raise any significant issues related to the adequacy of the Recirculated Draft PEIR. No further response is required.

Response to GROSSMAYER-4
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-537
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 analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

Response to GROSSMAYER-5
The comment is noted. 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.

Response to GROSSMAYER-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.

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From: Jeff Grunau
To: LongRangePlanning
Cc: District5; Nelson Esparza; Jerry Dyer; Launa Grunau; Adrienne Asadoorian; Rhonda Dueck Subject: SEDA Project Concerns
Date: Sunday, March 23, 2025 1:46:55 PM
External Email: Use caution with links and attachments
Good morning,
As I attended the Jackson Neighborhood Association meeting on Thursday night, we were informed of the SEDA project in District 5. I understand the push for more housing. Low inventory for rentals and houses for sale is pushing pricing up, making it difficult for many to afford to live without some major sacrifices.

First off, thank you for the Tulare Street project approval. It finishes the 109-yearold neighborhood where I live, and we finally have sidewalks surrounding the entire area! I also thank you for the progress toward the plans for the new park on Verrue between the 10th and 11th. I can't wait to see the plans after all of the neighbor's input. This leads me to believe the city council can listen to constituents when we bring concerns and ideas to the table.

I have some major concerns about the SEDA project.

Fresno is not known as a well-planned city. It has been developer-driven from day one. We are a case study on how not to plan a city. Our downtown has been struggling for decades now because our city government has followed the money rather than good long-term city planning. A friend of mine, Guido Periscone, the city planner for the City of Marina, is an AICP city planner with over 20 years of urban planning experience with a specialty in complex urban infill development that requires advanced knowledge of CEQA, and the Subdivision Map Act. He has said that Fresno does not do urban infill development well. We do urban sprawl that guts the older parts of the city in favor of chasing the developer's dollar. That is not a good way to be known around the state.

I also know there is a larger profit made for investors when developing new virgin acreage versus infill projects. My question to you is why is the profit for investors the highest priority? Why not put the existing constituents that live in Fresno above their profit margin?
We all see it. City Council is a stepping stone to higher government positions and in order to fund those campaigns, there needs to be big donors. Many of those GRUNAU

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donors are developers, and the majority of the constituents in Fresno get left in the dust, because we don't have the ability to lift you to the next level monetarily. It would be nice to lift you up with votes because of your integrity and knowing you fought for us. In this last D5 election, I had to choose between the outgoing D5 council member's wife (odd to keep politics in the same house), a person on the Sanger Unified School Board, and a person with low integrity who has fought for SE Fresno for decades. They were not great choices but they had to have money from somewhere to run their campaigns.

The SEDA project is porjected to cost between $1.2 and $4.2 billion dollars to extend the City's sphere of influence. Streets, storm drains, city water and swere lines all have to run out to the 9,000 acres waiting to be developed.

If you need places to spend $1-4 billion dollars in infrastructure, I can find a few places in Districts 5 and 7 that need help before spending that much extending the sphere of influence .

1. First Street from McKinley to Clinton got a wonderful repaving a few years ago! First and Fresno Street south of McKinley through Parallel could use repaving.

2. Huntington Blvd from 6th to Cedar has a few flooding spots and the roots from the Camphors have caused the road to buckle. I hear the trailers of different vendors rattle between 5:00-6:00 most weekday mornings over the raised parts of the street.

3. Speaking of camphors, the one in my front yard has pushed the curb out 4-5 inches into the road as it has grown. The asphalt is buckling from the root growth causing a small speed bump on the right shoulder. That could use a repair.

3. There are SEVEN undeveloped commercial lots on Cesar Chavez between First and Cedar that need businesses. One lot is an entire block between 7th and 8th Street. The new Farber Center between 9th and 10th is amazing! Keep the progress rolling! Incentivize businesses looking for infill spaces.

4. Using Google Maps I found 6 vacant lots in the Jackson neighborhood where houses have burned down and the house has not been rebuilt. The Jackson neighborhood is in an area of about 320 acres. How many infill projects are there in the city limits now that could alleviate the problem of the housing shortage without having to extend out to SEDA? The water and sewer, storm drains, and electrical grid are already in place. No need to spend $1 billion to get the services to these lots.

5. If affordable housing is the goal, is the city aggressively making ADUs GRUNAU

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3 accessible? That is a much cheaper option for the taxpayer. If 10,000 ADUs can be subsidized in the city limits it helps the housing crisis with very affordable options.

There are $7200-$8400 in fees that can be waived. It would take 119,047 ADUs with fees waived to be equal to the initial cost required for the SEDA project. That is a ton of affordable housing! Even the largest ADU is under $200,000 with building costs, permits and fees. Avalon Commins, the latest affodable housing project by the city was $42 million for 105 units (The Business Journal) That is $400,000 per unit. Again, why are we not pushing ADUs as in infill alternative for housing at half the cost. If the City is willing to spend $400,000 per unit, we could get TWICE to FOUR TIMES as many people into housing using ADUs on existing empty lots!

6. If you need more places to spend $1-4 billion dollars on existing residents, Mono, Balch, Platt, and Verrue all have poor street lighting in contrast to Huntington and Kerckhoff. The City could install the historic street lamps at 5 per block (vs the 2 per block currently in place) on the streets listed. We are the current taxpayers in an old neighborhood that could use the added historic feel for the entire neighborhood.

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mixed-use center hierarchy in the Plan Area, serving 40,000 to 60,000 households across the site and within the surrounding communities." This is not sustainable with the water and energy shortage in the state.

Where are the projections coming from for the need to build 60,000 households to make an area in SE Fresno the size of Clovis and attend CUSD schools? Have the projections changed since COVID? The news keeps telling us that people are leaving CA at a rapid pace, not moving to the Central Valley. It does not make sense for the City of Fresno to extend out and add 120,000+ residents if the demand from people moving here is not materializing. I have proposed other, cheaper options with much less risk.

Another reason to stop the SEDA project: In 2025 we had a $15 million budget deficit. The entire city budget is $2 billion and the SEDA project is projected to cost between $1.2 and $4.2 billion over the next 20 years. I do a monthly budget for my household and can see this is not wise management of funds. Especially since the city is taking a huge risk if the city builds it and they do not come.

Please STOP the SEDA project. Developers have hedged a bet on you to continue to poorly plan the city and follow them around waiving their money. There are enough blight and infill projects within the current city limits that need to be addressed before adding 9,000 more acres and 120,000+ people when it is proven the city can not manage what it already has.

GRUNAU

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Contact information:

Jeff Grunau
Jackson CDC Board Member
559.281.7909
4056 E Huntington Blvd, Fresno, CA 93702
--Thank you,
Jeff Grunau
GRUNAU

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-543
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 Jeff Grunau (GRUNAU)
Response to GRUNAU-1
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required.

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

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

Response to GRUNAU-4
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 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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-544 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 Furthermore, as detailed in Section 3.6, Energy, of the Recirculated Draft PEIR, the proposed project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. No further response is required.

Response to GRUNAU-5
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide 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.

H. RAMMING 1

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-547
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 Helen Ramming (First Letter) (H. RAMMING 1)
Response to H. RAMMING 1-1
The comment is noted. Please refer to Section 3.3, Air Quality, of the Recirculated Draft PEIR for a discussion of the methodology and analysis completed to show potential impacts related to air quality. No further response is required.

Response to H. RAMMING 1-2
The comment is noted. Please refer to Section 3.3, Air Quality, and Section 3.17, Transportation and Traffic, of the Recirculated Draft PEIR for a discussion of potential impacts related to trucks associated with the proposed project.

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

Response to H. RAMMING 1-3
The comment is noted. Please refer to Section 3.17, Transportation and Traffic, of the Recirculated Draft PEIR, as well as various other sections of the Recirculated Draft PEIR, including Section 3.3, Air Quality, Section 3.8, Greenhouse Gas Emissions, and Section 3.11, Land Use and Planning. These sections provide a detailed analysis of the proposed project’s consistency with State and local plans and policies, as applicable. No further response is required.

Response to H. RAMMING 1-4
The comment is noted. Please refer to Section 3.8, Greenhouse Gas Emissions, of the Recirculated Draft PEIR for a discussion of the proposed project’s consistency with AB 32. No further response is required.

Response to H. RAMMING 1-5
The comment is noted. Please refer to Section 3.3, Air Quality, of the Recirculated Draft PEIR for a discussion of potential impacts related to air quality, such as particulate matter.

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

Response to H. RAMMING 1-6
The comment is noted. Please refer to Section 3.3, Air Quality, of the Recirculated Draft PEIR for a discussion of potential impacts related to air quality, such as cumulative project impacts to criteria pollutant emissions.

Additionally, please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-548 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 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 H. RAMMING 1-7
The comment is noted. Please refer to Section 3.6, Energy, of the Recirculated Draft PEIR for a discussion of potential impacts related to energy usage. Please refer to Sections 3.3, Air Quality, and

3.8, Greenhouse Gas Emissions, for a detailed analysis of potential impacts on air quality and GHG emissions associated with the proposed project.

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

Response to H. RAMMING 1-8
The comment is noted. Please refer to Section 3.8, Greenhouse Gas Emissions, of the Recirculated Draft PEIR for a discussion of the proposed project’s potential impacts related to GHG emissions, including effects of global warming. No further response is required.

Response to H. RAMMING 1-9
The comment is noted. Please refer to Section 3.6, Energy, of the Recirculated Draft PEIR for a detailed analysis of potential impacts related to energy, including those associated with vehicle trips.

No further response is required.

Response to H. RAMMING 1-10
The comment is noted. Please refer to Section 3.8, Greenhouse Gas Emissions, of the Recirculated Draft PEIR for a discussion of the proposed project’s consistency with AB 32. No further response is required.

Response to H. RAMMING 1-11
The comment is noted. Please refer to Section 3.13, Noise, of the Recirculated Draft PEIR for a discussion of potential noise impacts associated with the proposed project. No further response is required.

March 23, 2025
Ms. Sophia Pagoulatos, Planning Manager
Ms. Adrienne Asadoorian, Planner
City of Fresno
2600 Fresno Street, Third Floor, Room 3065
Fresno, CA 93721
Re: "Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486.

Dear Ms. Sophia Pagoulatos,
Ms. Adrienne Asadoorian,
Comment in General: This plan is basically a "blank check" plan. No mitigation is allowed in the controversial areas. Also, over and over again, it is stated that once the plan is adopted, the various areas of contention would then be worked out. This reminds me what has happened at the Federal level when Congressmen stated we must pass the legislation and afterwards analyze it to see what it says. THIS IS WRONG and so very unfair to property owners as well as tax payers who will have to cover the expenses of a blank check! I find it very hard to understand how your department can endorse something that is so blatantly wrong.

I also find it difficult to understand why you promote a plan that you do not have concrete answers for.

At the Town Hall meetings we were given answers that were vague, indirect, seemingly deceptive, or contradictory. Considering how massive this plan is, how disruptive this is to hundreds of lives, how intrusive this is, and how it will ultimately change the dynamics of Fresno, residents should be entitled to clear answers from those who want to implement this plan. To be so unprepared with a project of this magnitude is inexcusable and offensive.

The first three words of the Constitution are "We the People". The way your organization is handling this portrays an abusive City Government with the "Almighty Dollar" taking priority. It is very disheartening, especially knowing that there are options besides taking the most fertile farmland.

The EIR is inadequate as it is based on ad hoc decisions to be made in the future and not on a set plan.

Therefore, it cannot be properly evaluated and should be abandoned.

I contest the following areas of the EIR for the following reasons:

PROJECT OBJECTIVES
ES-2 Fiscal Responsibility
Since you state that the goal of SEDA is to "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". then please answer the following question.

H. RAMMING 2

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Question: What is the budget that shows you are implementing this policy? To date you are not transparent with the cost and implementation of this SEDA project. Please give concrete data -- not a blank check policy.

ES-2 Fiscal Responsibility
Since you state you are planning "Holistically coordinate infrastructure to integrate efficiencies" Question: What is the estimated cost of the infrastructure since you are taking pride in fiscal responsibility? Do you have this information, and if so, why is it not made public? If not, you are asking us to approve of the costs with a blank check. The information costs need to be documented and made public.

ES-2 Fiscal Responsibility
Since you state the plan is to "Invest in resource conserving techniques for storm water systems, water supply, etc"
Question: What conserving techniques are you planning to implement and what is the estimated cost? Please document your information.

Cost Factors
Comment: The City of Fresno has not addressed the taxpayer's cost to implement this development. This "blank check" is unacceptable and needs to be addressed.

Climate Factors
Comment: The City of Fresno has not addressed the climate goals. This "blank check" is unacceptable and needs to be addressed.

Aesthetics, Light and Glare
Impact AES-4 (Project-level Light and Glare)
Comment: The Proposed Project states that there will be significant impact concerning the Light and Glare with lighting increased from streetlights etc. What are the significant impacts you are referring to? Please document them. What percentage of this proposed annexation will have streetlights? What is the estimated cost for implementing and maintaining this lighting system?
Section 3.2 Agriculture Resources and Forestry Resources Impact AG -1
Question: With the loss of the Ag land, please site the studies done to accommodate the loss of income for the Hmong Farmers. Hurting a minority is unacceptable and needs to be addressed and must be corrected.

MM AG-1
Question: Since the City of Fresno has documented their intent on preserving Prime Farmland, how can this plan be acceptable under the city's goals? Over riding signed documents of preserving Prime Farmland is unacceptable and must be corrected. Please site documentation H. RAMMING 2

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3 4
5 6
showing that Prime Farmland is being preserved with the equivalent type and quantity of land at a 1:1 ration.

Section 3.3 Air Quality
MM AIR 1b
Question: How will there be enforcement of these ideas be handled - especially over the long term?
MM AIR 1c
Question: How is the increase in the electrical grid going to affect Fresno? Not knowing the impact is unacceptable and needs to be addressed.

Question: The document states that air pollution emissions will increase substantially in Southeast Fresno (possibly by 600% in some areas). The public health impacts of this pollution on local residents has not been analyzed in the EIR. Apparently the City wants to deal with this after the Project's approval. This "blank check" is unacceptable and needs to be addressed and documented prior to approval.

Question: How will there be enforcement of these ideas be handled - especially over the long term?
Question: What is the cost of implementing the plan stated in MM AIR 1c? Section 3.5 Cultural Resources
Question: How will the loss of the Hmong revenue impact the Hmong culture? Please site studies that support no consideration for the Hmong farmers. Hurting a minority is unacceptable and needs to be addressed and must be corrected.

Section 3.8 Greenhouse Gas Emissions
Question: It is our understanding that the Greenhouse Gas Footprint will increase by 25% with this mega development. This plan is inconsistent with Fresno's climate change progress. What is the Greenhouse Gas Emissions goal of the City in this area and how will it be implemented in the SEDA development? The current plan is a "blank check" concerning climate change and is unacceptable until this is addressed in detail
Question: Fresno's goal was to reduce CO2 emissions by 559,000 tons a year by 2035. With SEDA, the emissions will increase by 510,000 tons a year. How do you account for this discrepancy and how do you plan to remedy this problem? Without this information, this plan is unacceptable and this "blank check" needs to be addressed and corrected.

Impact GHG-1 It is stated "The proposed project would not generate direct and indirect gas emissions and these emissions....." How can any statement be more contradictory? Please explain the contradiction.

H. RAMMING 2

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9 Section 3.11 Land Use and Planning
Impact LAND-2
Question: This plan contradicts Fresno's written policy of preserving prime farm land. Please explain how this plan is not in conflict with the preservation of prime farm land. Over riding signed documents of preserving Prime Farmland is unacceptable and must be corrected.

Section 3.14 Housing
Question: How much of the 45,000 homes will be affordable housing? Jennifer Clark has been reported as saying this detail would be worked out after the City Council approves the project.

This is a "blank check" and is unacceptable. This should be corrected and addressed prior to approval.

Section 3.15 Public Services
Question: In the high density areas, how are firefighters, police and first responders going to be able to help people without roads within the areas? Public safety is the number one concern. This plan is unacceptable and needs to be corrected.

Question: Who is going to pay for the massive bill to build schools to accommodate the high density population located in the Sanger School District? Since Sanger Unified has replied to this Project with great concern, please document the projected costs involved with the School district and the plan to fund these schools. Why have no estimated costs been given? Are you concerned that that truth would be detrimental to the Project? Going forward with no plan to implement school growth is unacceptable and needs to be corrected. Asking taxpayers to fund a "blank check" is unacceptable and needs to be corrected.

Section 3.16 Recreation
Question: We have been told at the Town Hall Meetings that Eminent Domain is not involved with the Project Plan. Please clarify. Does Eminent Domain occur only after the area is rezoned? Please state facts concerning the plans for Eminent Domain and Rezoning. The indirect answers we have been given are unacceptable. If Eminent Domain and rezoning will not occur, please give us a signed document stating such information.

Section 3.17 Transportation and Traffic
Question: What transportation will be available for the residents in the high density areas to obtain high paying jobs in other areas of town? If the 15 minute cities are designed to confine residents to the area without opportunities to pursue jobs on the North side of town, this is unacceptable and needs to be corrected.

Question: How is the City of Fresno planning to pay for the infrastructure cost? It has been reported that this will be ironed out after the council approves the massive project. This "blank check" is unacceptable and needs to be addressed prior to any approval.

H. RAMMING 2

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10 11
12 13
14 Section 3.18 Utilities and Service Systems
Impact UTIL – 1
Question 1: What are the significant environmental effects of constructing new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities? Please site the studies made and the data concerning the results of the studies. To accept this Plan without detailed information is endorsing a "blank check". This is unacceptable and needs to be corrected. Information and projected costs need to be published.

MMUTIL-1a
Question: What is the plan for additional water capacity? In the Town Hall Meetings we have not received any definite answers.

Comment: A definite plan should be in place prior to adopting the EIR as the water issue will be huge with the mega increase in the amount of people. The water issue will have a major impact on the city as a whole. To adopt the EIR without any plan in place is like giving someone a blank check to do whatever they want even if it was detrimental to the environment. The plan is unacceptable as is and needs to be corrected.

MMUTIL – 1b
Comment: The water supply system needs to be evaluated prior to the adoption of the plan. There is enough information in the plan to be able to be able to evaluate proposed water supply improvements as well as evaluate the environmental impact. To move forward without this information is unacceptable and needs to be addressed. Tax payers should not be endorsing a "blank check".

MMUTIL – 1d
Question: When you expand the wastewater system, are current property owners paying for hooking up to City Sewer? What will be the cost?
Comment: We have not received a clear answer at the Town Hall Meetings. However, we were told that the property owners were to pay for sewer hookup, the cost is around $30,000, a loan would be available, and if the owner were to sell a lien would be placed on the home to cover the costs. Please give us exact information as to what it will mean for connecting to the City Sewer System and site your source of information. Keeping information from the property owners is unacceptable and needs to be corrected.

MMUTIL – 1f
Question: What will the long term impact on the environment be when expanding or relocating electric, natural gas, or telecommunication facilities for a project of this magnitude. Please site your studies. No information concerning this is unacceptable and needs to be addressed.

Impact UTIL – 2
Question: The EIR states there are sufficient water supplies for this project and foreseeable future development. Please state your source and details to support this statement. Considering the water levels, the years of drought and the projected number of people you plan to accommodate, this is one of the most important issues that needs to be addressed. Stating that there are "sufficient water supplies" is totally unacceptable. This needs to be corrected and H. RAMMING 2

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15 addressed in detail as the ramifications of a limited water supply are huge! Allowing the Plan to address this after the Plan is adopted is endorsing a "blank check" for major problems ahead.

Questions:

1. Where are you drawing your water source from?

2. Is the Kings River considered a source even though it is already low? This project is huge and the lack of information is unacceptable.

Questions:

1. Once our wells run dry, we are not allowed to drill lower. How can you tell us that this will not impact our wells?

2. We have been told that if we are annexed into the City we have 5 years to hook up to City Water.

Our questions have been evaded and the answers given have been contradictory. This is unacceptable! This needs to be addressed and corrected! Questions:

1. Is the property owner responsible for the cost of connecting to City water? If so, is the cost between $30,000 - $50,000? If the property owner doesn’t have the money, is a loan required and is a lien put on the house if the owner intends to sell? We have not been given definite answers. This is unacceptable. A plan of this magnitude should have answers for the property owners.

2. We have also been told that if a property is on a corner, the owner is responsible for hooking up to water in two directions. Please clarify. If this is the case, this is unacceptable! Since when should the property owners be penalized for the developers' benefit? MM UTIL-2a
Question: The summary refers to the refined measures and standards that the city plans to use to reduce the per capita water use and implement water saving and conservation standards. What are they? Please give details. Without details this plan is unacceptable. Again, this is endorsing a "blank check". Please address and correct.

MM HYD -2C
Question: It is stated that "if it is determined that the development exceeds the water supply, the City will pursue the provision of adequate water supplies by securing additional water sources." What are the additional water sources you are referring to? How can you guarantee water when the water tables continue to drop?
Section 3.19 Wildfire
Impact WILD-1
Question 1: With the proposed high density housing plan, what is the emergency response plan? If there is no plan, there needs to be one prior to the development of the project for the safety of human life. Without an emergency response plan in place, this plan is unacceptable. This needs to be corrected.

Question 2: What is the emergency evacuation plan in the high density housing area? H. RAMMING 2

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16 Comment: If there is no plan, there needs to be one prior to the development of the project for the safety of human life. Without an emergency evacuation plan in the high density housing area, this plan is unacceptable and needs to be corrected.

Impact WILD 2
Question: Due to the close proximity of the high density housing, and therefore, the high wildfire risks of rapid spreading, what is the plan to protect the occupants from pollutant concentrations? Without a plan in place, this plan is unacceptable and needs to be corrected.

Question: Due to the close proximity of the high density housing, and therefore, the high wildfire risks of rapid spreading, what is the plan to prevent rapid spreading? Without a plan in place preventing rapid spreading of fire, this plan is unacceptable and needs to be corrected.

Impact – WILD 3
Question 1: Without the infrastructure of roads, fuel breaks, etc., what plans will be implemented to protect the safety of occupants in the high density areas during an emergency? Comment: If there is no plan, this is unacceptable and needs to be corrected. There needs to be a plan in place prior to the development of the project for the safety of human life.

Question 2: Without the infrastructure of roads, fuel breaks, etc. how will firefighters and rescue personnel be able to access various locations in the high density areas during an emergency? This needs to be addressed and corrected in the EIR or the plan is unacceptable.

Impact – WILD 4
Question 1: Should an unexpected potential threat develop from flooding, landslides, etc., what is the plan of evacuating people?
Comment: If there is no plan, this is unacceptable and needs to be corrected There needs to be one prior to the development of the project for the safety of human life.

Based on the above reasons, the EIR for the Fresno Southeast Development Area, Clearinghouse Number 2022020486 should not be accepted.

Please send me notices of any future hearing dates as well as updates concerning this project.

Sincerely,
Helen Ramming
SEDA area property owner
Member of Southeast Property Owner's Association
[email protected]
cc: City Council Members
Annalisa Pera
Mike Karbassi
Miguel Arias
H. RAMMING 2

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Tyler Maxwell
Nick Richardson
Mayor Jerry Dyer
H. RAMMING 2

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-557
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 Helen Ramming (Second Letter) (H. RAMMING 2)
Response to H. RAMMING 2-1
This comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. Master Responses 1 and 2 further detail why comments on Specific Plan policies are not further addressed in the Final PEIR. No further response is required.

Response to H. RAMMING 2-2
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 H. RAMMING 2-3
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.

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

Response to H. RAMMING 2-5
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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-558 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 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

As described in Section 3.1, Aesthetics, Light, and Glare, of the Recirculated Draft PEIR, the proposed project would include increased development in the Plan Area, leading to increased light from streetlights, exterior lighting from buildings, and vehicle headlights, compared to the current rural and agricultural land uses. Although the proposed project would comply with applicable policies and requirements and implement MM AES-4a through MM AES-4e, which would reduce impacts, impacts related to light and glare would remain significant and unavoidable.

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

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

Additionally, please refer to Master Response 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 H. RAMMING 2-7
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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-559
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 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.

Furthermore, as discussed in the Air Quality mitigation measures, future discretionary projects would be required to demonstrate compliance with the Air Quality mitigation measures contained within the Recirculated Draft PEIR prior to future discretionary project approval by submitting any documentation to the Director of the Planning and Development Department, or designee. No further response is required.

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

Response to H. RAMMING 2-9
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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-560 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 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.

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 H. RAMMING 2-10
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.

Response to H. RAMMING 2-11
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.

No further response is required.

Response to H. RAMMING 2-12
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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-561
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 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.

Response to H. RAMMING 2-13
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

Response to H. RAMMING 2-14
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, the proposed project has various policies related to the provision of public transit within the Plan Area, as well as transportation mitigation measures, which further provide for alternative transit within and connecting to the Plan Area. No further response is required.

Response to H. RAMMING 2-15
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 City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-562 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 with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Response to H. RAMMING 2-16
Please refer to Master Response 12, Clarifying Information on Wildfire Analysis, in Section 2, Master Responses. Master Response 12 elaborates on the methodology used in Section 3.19, Wildfire, of the Recirculated Draft PEIR.

From: docandblondie
To: LongRangePlanning
Date: Monday, March 24, 2025 10:06:53 AM
External Email: Use caution with links and attachments
Attn: Planning and Development Department
Sophia Pagoulatos, Planning Manager
Please read our concerns about the SEDA project.

EIR PLAN FOR SEDA
3:15 Public Service
Who is going to pay for the massive Bill to build schools to accommodate the high density population located in the Sanger School district? Please document the projected costs involved with the School Project and the plan to fund these schools.

Why no cost have been given? Going forward with no plan for school growth and cost is unacceptable and to be corrected. Asking taxpayers to fund a blank check is unacceptable also and needs to be corrected.

EIR Plan 3:17 Transportation and Traffic
How is the City of Fresno planning to pay for the infrastructure cost? It has been reported that this will be ironed out after the council approves the massive project. What is the proposed infrastructure cost? The budget needs to be disclosed before the EIR is accepted. This "blank check" is unacceptable and needs to be addressed prior to any approval.

There are many other areas of concern and we would appreciate hearing back from you.

Thank you
Dr. and Mrs. Douglas Hampson
Sent from my Verizon, Samsung Galaxy smartphone

HAMPSON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-565
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 Dr. and Mrs. Douglas Hampson (HAMPSON)
Response to HAMPSON-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.

Response to HAMPSON-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: Andy Hansen-Smith
To: LongRangePlanning
Subject: Concerns about SEDA Recirculated EIR
Date: Monday, March 24, 2025 12:43:09 PM
External Email: Use caution with links and attachments
Hello Sophia Pagoulatos, Planning Manager
3335 E. Kerckhoff Ave
Fresno, CA 93702
March 24, 2025
4-2 Growth-Induced Impacts
The SEDA plan relies on outdated population growth projections to justify its development.

The report claims Fresno will grow by 226,000 people by 2035, but new data from the California Department of Finance shows a much smaller growth of just 72,000 and only 19,000 more by 2070! There is no need to expand as suggested in the SEDA Plan when Fresno's population is
growing much slower than originally predicted.

Fresno needs to continue to increase density along our major corridors to induce more public transit opportunities and reduce our car-dependent infrastructure. SEDA will do very little for affordable housing, increase the use of vehicles for transportation as well as leave the current city's needs underfunded.

Thank you for you time,
Andy Hansen-Smith
HANSEN-SMITH 1

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-569
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 Andy Hansen-Smith (First Letter) (HANSEN-SMITH 1)
Response to HANSEN-SMITH 1-1
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. No further response is required.

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

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From: Tessa Hansen-Smith
To: LongRangePlanning
Subject: Concerns about SEDA Recirculated EIR
Date: Monday, March 24, 2025 4:31:24 PM
External Email: Use caution with links and attachments
To: Sophia Pagoulatos, Planning Manager
From: Tessa Hansen-Smith
3335 East Kerckhoff Avenue
93702, CA 93702
[email protected]
3/24/2025
4-2 Growth-Induced Impacts:

SEDA is using outdated information to base their need for housing on in order to accommodate for a growing population. The fact they are using old data that supports their desires for wealth shows they are not actually thinking of what’s best for the city or the people in it who will not be able to afford their new houses but will have to pay taxes to build it nonetheless.

3.3.4 Air Quality:

The Central Valley is ranked in the top 10 most polluted cities in the entire nation, according to the American Lung Association’s 2024 State of the Air report. The SEDA admits their plan for development will increase pollution, but try to soften it by saying everyone who will move there will only drive 5 miles at the most everyday. Meaning they assume everyone will work in that complex, go to school in that complex, and shop in that complex. It’s incredibly ridiculous. They assume in this job market people will give up their jobs and pay in hopes of getting a job in this development complex, when someone who is a professor at Fresno State wouldn’t feasibly do that. That’s just one of many examples of jobs people can’t magically relocate or find within this complex. 4-1 Impact AG-1:

The Central Valley and California as a whole are major contributors to produce and agriculture. The SEDA plans to destroy 6,700 acres of farmland. This will take jobs from farm workers, who are the backbone of this State and are already being unjustly targeted by the current Administration. Crops on farmland help to clean our air, feed not only Californians but much of the United States, and help foster certain ecosystems. Space is a finite resource. Natural, in development land is a finite resource. Houses don’t need to spread outwards, but instead should go towards and be affordable. Not just another new housing market for the wealthy to buy because their 10 year old house is too old for them.

3.17 Transportation and Traffic:

The SEDA claims the people who live in their complex will only drive 5 miles per day, which is 80% less than what experts predict. This is not due to them creating significantly improved public transport systems in their complex that spread to the rest of Fresno and Clovis, but because they naively think and ignorantly state that the new homeowners will HANSEN-SMITH 2

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just never leave. Fixing already established roads is projected to cost $500 million, and even though that never becomes a priority and roads get worse, somehow a $2-4 billion project is doable. Fixing roads will not only help people in Fresno, but people traveling through or to Fresno. It will help cars have less wear and tear, and can prevent accidents caused by potholes and roads being cracked open from roots.

I have lived in Fresno for nearly 2 decades, and see the same trends over and over.

Developmental properties continuously move outwards, costing money and adding pollution, taking away farmland and ecosystems for plants and wildlife. The houses created are rarely if ever Affordable Housing. Just new houses built poorly that are designed to last 10-15 years before the next major development starts and builds new houses for those people to flock to yet again. We need to stop creating new hotspots of comfortable living and leaving what proceeded it to become dilapidated. It is absolutely appalling this trend that is purely from a place of greed continues. Houses aren’t built to last anymore but to look shiny shortterm for those who can afford it. This likely won’t even help our local housing market, as many people have been buying second or third homes and renting them out at high prices as a way to pay for their new home’s mortgage. Worse, the houses remain empty even though people live on the streets, 5 people will share a 2 bed 1 bath apartment, and young adults are forced to live at home during or after college because they can’t afford a house of their own. Fresno needs to do better.

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5 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-573
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 Andy Hansen-Smith (Second Letter) (HANSEN-SMITH 2)
Response to HANSEN-SMITH 2-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 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 HANSEN-SMITH 2-2
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 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.

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-574 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 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 HANSEN-SMITH 2-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

From: [email protected]
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; [email protected]; Todd Stermer
Subject: [Possible Scam Fraud]Recirculated EIR for SEDA Date: Friday, March 21, 2025 5:20:35 PM
External Email: Use caution with links and attachments
------------------------------------------------------------------------------ WARNING: Your email security system has determined the message below may be a potential threat.

The sender may trick victims into passing bad checks on their behalf.

If you do not know the sender or cannot verify the integrity of the message, please do not respond or click on links in the message. Depending on the security settings, clickable URLs may have been modified to provide additional security. ------------------------------------------------------------------------------ ------------ Suspicious threat disclaimer ends here ------------ To: Sophia Pagoulatos, Planning Manager of Planning and Development From: Paulette Hiraoka, SEDA resident
Re: Recirculated EIR
Below you will find some selected aspects of the Recirculated EIR that are disturbing and will change my life. I wish I had the time and knowledge to address each and every section since the City Council wants to "take away" the rural way of life in southeast Fresno and make it an imaginary perfect future Fresno.

Since the city councils over the years have been unable to do it within the city limits, they want to take over southeast Fresno and try again when they have no pattern of success to prove that it is a wise decision and they are capable of succeeding. Urban sprawl is not the answer.

Section 3.1 Aesthetics, Light, and Glare
How can the City of Fresno expect that their plan for Southeast Fresno can be filled with "scenic" resources and landscaped "spaces?" Currently, areas that were already planned and approved by the city are run down and eye sores. City parks and play areas are neglected and in need of repair. The money has not been in the budget to maintain what has already been built throughout Fresno.

Section 3.2 Agricultural Resources and Forestry Resources How will taking 3,000 acres of farm land out of production for Regional Town Centers, residential structures (both mixed and neighborhood), and offices benefit Fresno's Way of Life? It impacts Fresno County, small farmers, air quality, noise pollution, and increases crime. It brings all of the negative aspects of city life to our rural community upon which Fresno County was built. Small farmers will lose their livelihood
Fresno County had their sneaky and quick meeting to approve the

HIRAOKA

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2 agreement with Fresno City to receive a bigger share of the taxes from SEDA but that, too, was purely money making based. The only negative vote was from our area representative.

Section 3.3 Air Quality
How will the city justify the "urban heat island" effect created by the SEDA plan?
The EPA states that there is up to a 7-degree temperature difference between urban and rural temperatures. European studies cite up to a 10-degree difference. Living in the valley, this will affect the air quality which the city is already penalized for not meeting federal goals.

Section 3.7 Geology, Soils, and Seismicity
Section 3.10 Hydrology and Water Quality
Who will pay for the existing home owners' connection to city sewer and water lines and the disposal of existing septic tanks and condemning our wells?
We have already paid to meet the requirements to build our homes.

Now, we are to carry the burden of a decision made by the City of Fresno to give them a larger tax base.

We built our home with land so my husband could have a small orchard with trees from his family ranch. I have fruit trees that his father had developed and are now found only on my property. Without my well, I would not be able to keep those trees alive and his father's legacy would be gone forever.

Section 3.13 Noise
How will the increase in noise level from traffic created by the hundreds of new residential homes/apartments and Town Centers/offices be measured?
It cannot because currently the area is rural. Our homes are surrounded by open areas where wildlife are the only sounds one hears.

The people who live in Southeast Fresno would have stayed in the city if we enjoyed the sounds of cars driving through our neighborhoods.

Adding 45,000 housing units, offices, and a shopping center will bring thousands of cars at all hours of the day.

Section 3.14 Population and Housing
How will existing homeowners afford to connect to city water and sewage? There have been estimates of $10,000-50,000 for each hook up depending upon the distance and the obstacles in our already established yards.

Home owners must pay to connect from the street to the dwelling which can be hundreds of feet under concrete driveways, landscaping, and the required drainage ponds we have on our properties. Septic tanks would have to be dug up and wells condemned. We have already paid thousands of dollars to have both installed so we could live in our dream home and area. Of course, that price will inflate by the time the city gets anything done. I am sorry but the city's track record for getting things accomplished in a timely manner is poor.

I am a widowed retired person living on my pension. My husband and I planned to live out our lives here. We paid off our mortgage! I maintain my home and myself off of one pension. To force me to take out a loan to pay for water and sewage connections to satisfy this imagined "Fresno future" is shameful.

Even trying to sell my home in the future would have the negative of having to disclose the added cost of a future connection cost. I

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would be paying the cost regardless which would result in a significant loss to me.

Section 3.14 Population and Housing
Why build 45,000 additional housing units when there are vacant areas in the City of Fresno?
The concept of "if you build it, they will come" will only empty more Fresno areas and make more eye sores. Property values will decline in Fresno and Fresno will have to deal with more vacant homes and break ins.

Section 3.15 Public Services
How will Fresno City protect an additional 9,000 acres of land? Currently, the Fresno County Sheriff's Department protects this area.

The Fresno City Police Department currently has a shortage of police officers. Three firehouses are being closed because of the over 15 million dollar deficit. Fresno City is having a challenging time protecting and serving the current city limits.

The EIR reads that additional police and fire stations could be built and maintained. What monies will you use to fund that? Why would you hope an additional city budget burden would be offset by earning some tax dollars with the SEDA project?
Section 3.16 Recreation
How will you be able to fund and maintain any regional/pocket parks? My husband and I had homes in Fresno. Over the years, I have taken children to Woodward Park and small area playgrounds and have watched them deteriorate. Presently, such expenses have to be put further down list of priorities as the city faces a 15 million dollar deficit. I travel roads to get to some of these places that are in need of repair. The city does not even have the money to maintain what already exists.

Leave Southeast Fresno alone and do not destroy the beauty of blossoming fruit trees and the beauty of Fresno County.

Sincerely,
Paulette Hiraoka
7788 E. Floradora
Fresno, CA 93737
Cc: District 1: Annalisa Perea
District 2: Mike Karbassi
District 3: Miguel Arias
District 4: Tyler Maxwell
District 5:

District 6: Nick Richardson
District 7: Nelson Esparza
City Clerk: Todd Stermer

HIRAOKA

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-579
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 Paulette Hiraoka (HIRAOKA)
Response to HIRAOKA-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 HIRAOKA-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 HIRAOKA-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.

Response to HIRAOKA-4
The comment is noted. The comment states that there will be an “urban heat island” effect created by the proposed project. However, the comment does not provide evidence, substantiation, or justification for this assertion. 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 HIRAOKA-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.

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 USOI- City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-580 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 144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

Response to HIRAOKA-6
The comment is noted. Section 3.13.4, Methodology, in the Recirculated Draft PEIR details the methodology for the analysis of potential noise and vibration impacts. No further response is required.

Response to HIRAOKA-7
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

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

Response to HIRAOKA-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 HIRAOKA-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.

From: Cheyenne J.

To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; District5; Nick Richardson; Nelson Esparza; Todd Stermer
Subject: Concerns About the SEDA Recirculated EIR
Date: Thursday, March 20, 2025 8:52:05 PM
External Email: Use caution with links and attachments
Dear Council Member & City Clerk,
I am writing to express my concerns about the SEDA Recirculated Environmental Impact Report (EIR). Below are the key areas that I find alarming and we Fresnonians, WANT ANSWERS:
#1: Section 4-2 Growth-Induced Impacts: The SEDA plan relies on outdated population growth projections to justify its development. The report claims Fresno will grow by 226,000 people by 2035, but the new data from the California Department of Finance shows a much smaller growth of just 72,000 and only 19,000 more by 2070. There is NO NEED to expand as suggested in the SEDA plan when Fresno's population is growing much slower than originally predicted. This projection does NOT support the representation of people in Fresno who need affordable housing! Stop building & take care of existing communities & buildings that are the history of Fresno. NO to "Fresnoland" and MORE FARMLAND!!! Revitalize Fresno! NO to "Fresnoland", NO to SEDA!
#2: Section 3.3.4 Air Quality: Fresno ALREADY has some of the worst air quality in the nation, and the SEDA plan admits it will create high levels of pollution. Why worsen our air when the project isn't even necessary? Many already have health issues and struggle in Fresno due to the air quality. Asthma, allergies and smog are among the many critical issues affecting Fresno citizens who did NOT VOTE for this nor approve of this! SEDA will make these issues worse, thus, lessening the quality of life for those living in Fresno. NO to "Fresnoland" and MORE FARMLAND!!! Revitalize Fresno! NO to "Fresnoland", NO to SEDA!
#3: Section 4-1 Impact AG-1 (Farmland Loss): The project will destroy 6,700 acres of farmland - land that helps clean our air and supports local agriculture. Replacing it with development will increase pollution and hurt our local economy. Again, stop building & take care of existing communities & buildings that are the history of Fresno. Not only will this save money but it will improve Fresno as a whole! NO to "Fresnoland" and MORE FARMLAND!!! Revitalize Fresno! NO to "Fresnoland", NO to SEDA! #4: Section 3.17 Transportation & Traffic: The report claims that by 2025, people in SEDA will drive only 5 miles per day -- 80% less than what experts predict. This assumption is unrealistic and ignores Fresno's existing car-dependent infrastructure. This is beyond the allocated $1-$4 billion SEDA plans to divert from resources of critical needs such as our broken roads, sidewalks and neighborhoods. Stop building & take care of existing communities & buildings that are the history of Fresno. NO to "Fresnoland" and MORE FARMLAND!!! Revitalize Fresno! NO to "Fresnoland", NO to SEDA! JENVEY

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This SEDA project is wrong on SO many levels in my personal opinion. Having lived here all my 47 years of life, I have watched my hometown, which I love, turn into the "next LA" which I HATE and many DO NOT WANT!!! Fresno is an agriculture town. Fresno is rich in its history. Fresno has many depleted areas of which the money proposed to SEDA could almost 'reinvent' Fresno in a MUCH BETTER way as the "next LA" than SEDA could ever do! What you are doing is completely wrong and this project will break Fresno entirely. This project will push out our farmers and force them elsewhere to farm. This project will NOT support the existing homeless issues and only increase the lack of affordable housing to the existing citizens of Fresno. Who are you building this for? Not those in the valley! SEDA is ONLY for outsiders, who will not spend & consume here but just sleep here and travel outside Fresno to work and consume elsewhere. SEDA plans need to be stopped and those in charge must look at the amazing opportunity right under your noses here in beautiful Fresno. Revitalize Fresno! NO to "Fresnoland", NO to SEDA! If you need to contact me, feel free. Mobile #: 559-360-1597. Thank you for your time! ~Live Vertically~
Cheyenne Jenvey
JENVEY

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5 City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-583
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 Cheyenne Jenvey (JENVEY)
Response to JENVEY-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. No further response is required.

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

Response to JENVEY-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.

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

Response to JENVEY-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: Bruce Jewell
To: LongRangePlanning
Subject: SEDA Proposal
Date: Friday, March 21, 2025 1:03:28 PM
External Email: Use caution with links and attachments
Bruce Jewell
6260 N. Palm Avenue, Unit 122
Fresno, CA. 93704
City of Fresno
Planning and Development Department
Attn: Sophia Pagoulatos Planning Manager
As a third generation Fresno resident who has seen the effects of poor planning erode the possibilities of creating a truly beautiful city, I am writing to express my concerns about the SEDA Recirculated Environmental Impact Report which I believe fails to present a realistic picture of the impact of the SEDA project. Among my many concerns the following stand out.

1. 4-2 Growth-Induced Impacts
The SEDA plan relies on outdated population growth projections to justify its. development. The report claims Fresno will grow by 226,000 people by 2035, but new data from the California Department of Finance shows a much smaller growth of 72,000 and 19,000 more by 2070. Thus there is no need to expand as suggested in the SEDA Plan when Fresno’s population is growing much slower than originally predicted.

2. 3.3.4 Air Quality
Fresno already has some of the worst air quality in the nation. The SEDA plan admits it create high levels of pollution. Why worsen our air quality for a project that isn’t necessary. The air quality is already so poor that we have the highest asthma rates in the nation. One might consider whether potential new residents will wish to expose themselves and their children to an already unhealthy climate.

3. 4-1 Impact AG-1 (Farmland Loss)
The SEDA Project will destroy 6,700 acres of farmland. This farmland helps clean are already dirty air and is foundational to the local economy. Replacing the farmland with a development that damages our health and economy cannot be called a rational decision.

4. 3.17 Transportation and Traffic
The report claims that by 2025 people in SEDA will drive only 5 miles per day—80% less than what experts predict. This is unrealistic and ignore Fresno’s car dependent infrastructure.

Speaking of our car dependency, the streets in my area of town, and I assume others, are full of potholes.which I try to dodge every day.

If we are going to float huge bonds to build roads for SEDA which taxpayers like myself will pay for should we not instead pay to have existing roads repaired and maintained instead? The City of Fresno should prioritize the current need of our city rather than moving forward with SEDA.

Sincerely,
Bruce Jewell
JEWELL

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-587
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 Bruce Jewell (JEWELL)
Response to JEWELL-1
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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

Response to JEWELL-3
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

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

Response to JEWELL-5
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 JEWELL-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

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From: Valerie Johnson
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer Subject: Concerns regarding SEDA
Date: Monday, March 24, 2025 4:41:50 PM
External Email: Use caution with links and attachments
Dear Ms. Pagoulatos,
I am writing to express my concerns about the SEDA Recirculated Environmental Impact Report (EIR). Below are key areas that I find alarming:
4-2 Growth-Induced Impacts
The SEDA plan relies on outdated population growth projections to justify its development. The report claims Fresno will grow by 226,000 people by 2035, but new data from the California Department of Finance shows a much smaller growth of just 72,000 and only 19,000 more by 2070! There is no need to expand as suggested in the SEDA Plan when Fresno’s population is growing much slower than originally predicted.

3.3.4 Air Quality
Fresno already has some of the worst air quality in the nation, and the SEDA plan admits it will create high levels of pollution. Why worsen our air when the project isn’t even necessary?
4-1 Impact AG-1 (Farmland Loss)
The project will destroy 6,700 acres of farmland—land that helps clean our air and supports local agriculture. Replacing it with development will increase pollution and hurt our local economy.

3.17 Transportation & Traffic
The report claims that by 2025, people in SEDA will drive only 5 miles per day—80% less than what experts predict. This assumption is unrealistic and ignores Fresno’s existing car-dependent infrastructure.

Invest in Fresno’s Existing Communities (an example)
I live near Fig Garden Village and there are terrible streets in that area, particularly on Shaw Ave and terrible sidewalks in disrepair on Delno where my daughter’s family lives. I would like the city to fix the streets and sidewalks instead of putting our money at risk for the SEDA Plan. I urge the City of Fresno to prioritize reinvesting in existing neighborhoods rather than moving forward with SEDA.

Sincerely,
Valerie Johnson
[email protected]
CC [email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]

JOHNSON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-591
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 Valerie Johnson (JOHNSON)
Response to JOHNSON-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. No further response is required.

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

Response to JOHNSON-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.

Response to JOHNSON-4
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 JOHNSON-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.

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From: Kevin Dueck
To: LongRangePlanning; Annalisa Jaquez; Mike Karbassi; Miguel Subject: I oppose SEDA!
Date: Sunday, March 23, 2025 9:03:20 PM
External Email: Use caution with links and attachments
Arias <[email protected]>,
Tyler Maxwell <[email protected]>,
Nelson Esparza <[email protected]>,
"[email protected]" <[email protected]>, [email protected],
[email protected],
Georgeanne White <[email protected]>,
Jennifer Clark <[email protected]>,
"[email protected]" <[email protected]>,
District1 <[email protected]>,
"[email protected]" <[email protected]>,
District3 <[email protected]>,
District4 <[email protected]>,
District5 <[email protected]>,
District6 <[email protected]>,
[email protected]
X-Mailer: Apple Mail (2.3826.400.131.1.6)
City council and City government
I am very concerned about SEDA! I am concerned about how the city thinks it will be able to afford this. I am concerned that the infrastructure needs of my neighbohood will be met if all these funds are going to this new development. I am concerned that this is being done instead of infill. I am concerned because there are many neighborhoods in Fresno that have been neglected and this action would further enhance the problem.

Please vote to end SEDA!
Kevin Dueck
3401E Hungington blvd
K. DUECK

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-595
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 Kevin Dueck (K. DUECK)
Response to K. DUECK-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. No further response is required.

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From: Nancy Klassen
To: LongRangePlanning; Rhonda Dueck
Subject: SEDA
Date: Sunday, March 23, 2025 7:40:44 PM
External Email: Use caution with links and attachments
I have just learned about a plan to build a huge new housing development in southeast Fresno.

This is an old area of Fresno with lots of history and character. I don’t want it to be indiscriminately cleared for new construction.

We DO need new housing nestled into available spaces in south Fresno - housing that could help alleviate stress on people who are paying such high rent prices now - and very low cost housing for people who are homeless and living in south Fresno.

Please use available funds to improve existing streets, sidewalks, bicycle pedestrian walk/exercise paths, improve and create parks, affordable homes integrated into our currently existing neighborhoods.

Please spend the available funding to improve the lives of southeast Fresno’s current residents.

Earnestly and sincerely,
Nancy Klassen
3704 E. Kerckhoff Ave
Fresno, CA 93702

KLASSEN

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-599
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 Nancy Klassen (KLASSEN)
Response to KLASSEN-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. No further response is required.

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From: Tim Kutzmark
To: LongRangePlanning
Subject: Concerns About the SEDA Recirculated EIR
Date: Monday, March 24, 2025 3:06:20 PM
External Email: Use caution with links and attachments
March 24, 2025
Dear Ms. Pagoulatos -
I have grave concerns about the SEDA Recirculated Environmental Impact Report, and I will highlight 2 (although I have many more concerns):

3.3.4 AIR QUALITY
Fresno has some of the most polluted air in the country, with great impact on the health of those who live in the city and county and beyond. The SEDA plan acknowledges that it will add even more pollution into the air we breathe, but says nothing about measures taken to mitigate that additional pollution. That is irresponsible and incomplete planning. 4-1 IMPACT AG-1 (Farmland Loss)
Agriculture provides employment and income for residents of the city and county. It also helps feed people in the city and county and far beyond. SEDA will destroy 6,700 acres of farmland that is currently serving the city and county, providing employment but also income.

Thank you.

Tim Kutzmark
2732 E Darlington Ct
[email protected]
Rev. Tim Kutzmark
Minister, Unitarian Universalist Church of Fresno
"May the longtime sun shine upon you,
all love surround you,
and the pure light within you
guide your way on."

KUTZMARK

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-603
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Tim Kutzmark (KUTZMARK)
Response to KUTZMARK-1
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

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

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L. LEONARD

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1 Dear Councilmember Arias,
Fresno City's Southeast Development Area Specific Plan raises multiple red flags that alarm me as a voter and taxpaying resident.

1. Your document presents a dreamscape of parks, trails, senior centers, libraries, recreation facilities, as well as new schools and medical facilities. There will also be sidewalks unbuckled by tree roots, tree-lined roads without potholes, and well-lighted neighborhoods.

Who will provide the infrastructure for all of these wonderful amenities? The city's existing infrastructure is in serious decay. While E Floradora recently received much needed speed bumps, (thank you!) the bumps were installed over a crumbing street. Each time I look at the deep cracks, I cringe thinking of the hapless bicyclist whose wheel gets caught in one of the deep crevices and goes headfirst over the handlebars. A lawsuit is waiting to happen, a life potentially ruined or lost. While the sidewalk in front of my house is perfect, the route I take to my daughter's home a few blocks away is fraught with tripping hazards, it's sidewalks buckled by tree roots. I'm 83 and I fear a fall that could permanently disable me - or kill me.

The City of Fresno, which is currently wrestling with a $20 million budget shortfall, appears to be in no position to assume such a speculative debt, especially in view of its inability to adequately maintain its existing infrastructure.

2. SEDA will use city money on 9,000 acres of new infrastructure outside city limits.

California's current population growth statistics indicate that it is questionable that enough people will want to move here to make this a viable investment. Furthermore Fresno already has enough vacant land within the city limits to accommodate nearly three times the population for SEDA.

Downtown Fresno is dead. West Fresno is in desperate need of sidewalks and other infrastructure repairs and upgrades.

Fresno should focus on the needs of its current neighborhoods. Existing neighborhoods need safe sidewalks, adequately maintained streets, parks, libraries, bike paths, and well-lighted streets.

Fresno can't afford to fantasize about a dreamscape; it needs to focus on the real citizens living here now, trying to make good homes for their families, not imaginary people who might live here five years from now.

3. The SEDA plan says that water infrastructure planning tasks will happen after SEDA is adopted.

The San Joaquin Valley is sinking because too much groundwater is being pumped. The state is cutting back on water supplied to farmers. Drinking water for people is a priority, but we also eat and farmers need water for their crops. We have good snow years and bad ones - we never know what next year will provide. The Colorado River is drying up, which affects Southern California, which then affects us. The weather is getting hotter and the hot weather is lasting longer.

Fresno MUST consider water BEFORE it adopts any plan for development. I hate to think how much money the city has spent to craft SEDA, but it's time to scrap SEDA and focus all efforts on making the existing City of Fresno the very best it can be. This city is rich in talented, creative people. Let's fix up what we have while making it a showplace. We can do that! Sincerely,
Lynda E Leonard
1501 N Wilson Avenue
Fresno, CA 93728

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-607
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 Lynda Leonard (L. LEONARD)
Response to L. LEONARD-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.

No further response is required.

Response to L. LEONARD-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.

Response to L. LEONARD-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.

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From: Paul Lake
To: LongRangePlanning
Subject: Concerns about SEDA
Date: Monday, March 24, 2025 3:51:29 PM
External Email: Use caution with links and attachments
To: Sophia Pagoulatos, Planning Manager
Yes… we need more AFFORDABLE housing, not more urban sprawl. SEDA will cause more pollution and cost local gov’ts too much money for new infrastructure to support this housing development that will come from diverting funds from fixing current infrastructure.

This is not NIMBYism. We need the right kind of new housing.

No on SEDA.

Respectfully,
Paul Lake
4513 E. Rialto Ave.

Fresno, CA 93726
Sent from Yahoo Mail for iPad
LAKE

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Fresno City CouncilDecember 18, 2025

Fresno City Council
December 18, 2025