revisions required to satisfy the relevant LAFCO Resolution that governs these matters, which were intended to address potentially significant environmental impacts of the SEDA Plan area development. We hope you will take the time to do so and that those efforts help to secure broader public support for this endeavor.
Protecting the West Area Specific Plan Development, the Urban Core and Existing Neighborhoods.
It is important that your Council consider the concerns raised by the public . They recognize that the SEDA Specific Plan is an important step forward in the long-term planning of the community. The public is being asked to support a SEDA Specific Plan on the immediate heels of other important planning actions, specifically the recent adoption of the West Area Specific Plan. The public has raised concerns about whether the City has evaluate d its ability to concurrently develop both the West Area and the SEDA territory, while maintaining appropriate focus on the core Downtown and existing neighborhood. These are concerns your Council should seriously address.
The community also raised substantial concerns about the preservation of rural residential housing, and ag land preservation, which are not adequately addressed in the Plan documents. They are also concerned that the financing arrangements for the public infrastructure required for the Plan’s implementation will lead to disinvestment in the existing City neighborhoods.
Missing Programs and Policies Needed to Meaningfully Address Environmental Impacts.
The County participated in the CEQA process that the City has administered. That is because the CEQA process was the most robust aspect of the City’s outreach .
Unfortunately, the recently distributed Response to the CEQA Comments that the City Staff and its consultants prepared, simply avoided the need to address many of the issues of public concern. They did this by inaccurately classifying a wide range of comments as not relevant to potential environmental impacts.
For all the comments deemed to not address environmental impacts, the sole response was that the concern would be included in the record provided to the City for its review as part of the consideration of the proposed Project as a whole. To make good on that commitment, we recommend that your Staff compile all of the comments where this reply was provided, into a single document. In that fashion, you would have the tool necessary to effectively consider and deliberate on those concerns that the Staff believes are not relevant to the CEQA process it has administered.
Several of our comment s in the CEQA process focused on the fact that the Specific Plan, and its implementation arrangements thus far made available for public review ,
Fresno City Council
December 17, 2025
Re: SEDA
do not satisfy the requirements of LA FCO Resolution USOI -144. We assumed that when the City committed to expend considerable public funds and conduct significant public engagement on the Specific Plan, it did so on the basis that the intended Specific Plan, and its related implementation arrangements, would satisfy the requirements of that LAFCO Resolution.
If the City had incorporated the analysis and programs the LAFCO Resolution requires to be included in the Specific Plan, it may have alleviated many of the concerns raised by the County and the general public about details missing from the City’s proposed SEDA implementation . Those concerns include the current lack of any committed phasing plan, the lack of a master service delivery plan (including a relevant financing plan), the lack of a program for preservation of rural residential neighborhoods, and the failure of the Specific Plan to address Williamson Act Contract s. All of these matters are required by the LAFCO Resolution before any annexations can commence.
Despite the Responses to the CEQA Comments provided by the City ’s Staff and its consultant, these matters directly relate to potentially significant environmental impacts of the SEDA Specific Plan. Without those materials, the EIR document fails to address several potentially significant impacts. Deferring them on the basis that no annexations are presently being conducted, or that the EIR relates to a Program versus a Project, are simply inadequate to address both the mandates of CEQA and the concerns of the public.
The Lack of a Rural Residential Neighborhoods Preservation Program In the Specific Plan.
A program for preservation of rural residential neighborhoods is specifically required by LAFCO Resolution USOI-144 to be included in the Specific Plan. That Program was confirmed as necessary to address "logical and reasonable development, discourage urban sprawl, preserve open -space and prime agricultural lands, and efficiently provide for government services and encourage orderly development."
The LAFCO Resolution further makes clear that the program concerning rural residential neighborhood annexation “should emphasize the retention of characteristics that make the neighborhood desirable places to live, while making provision for appropriate improvements needed to incorporate s uch characteristics into the urban landscape . The program should include an outreach effort demonstrating to residents that annexation into the City would provide for an enhanced living environment preferable to staying in an unincorporated enclave, surrounded or substantially surrounded by the City.”
Such a program is nowhere in the Specific Plan . We are instead told that the City’s existing ordinances (at Municipal Code sections 15 -404 and 15 -405) provide for an
Fresno City Council
December 17, 2025
Re: SEDA
Annexed Rural Residential Transitional Overlay District and that this is sufficient for the need. It is not.
Despite City staff’s assurance, allocating existing Rural Residential land uses into a “legal nonconforming use” status (as provided for by that Transitional Overlay) will create difficulties with lenders and buyers of property . Imposing those constraints are not consistent with protecting the maintenance of such rural residential uses. It will also hinder appropriate expansion of existing legal nonconforming structures that may be reasonable and desirable to maintain thriving rural residential neighborhood s. The City’s Transitional Overlay does allow some expansion in single family residential structures. However, similar expansion of other ancillary structures is not permitted except with the attainment of subsequent entitlements. In addition, expansions of single-family residential structures requires that the improvements conform to the standards of the newly allocated Base District. (Municipal Code Section 15-405-E-1).
The City has also not adequately dealt with the significant costs that the City intends to impose on existing rural residential homeowners when the City subsequently mandates that they connect to City water and sewer systems. The offer of 5-year financing for these substantial costs does not satisfy the standards that the LAFCO Resolution requires for the intended the rural residential neighborhood preservation program.
The Lack of Policies in the Specific Plan to Address Williamson Act Contracts and the Requirements of Government Code section 56426.6.
LAFCO Resolution USOI -144 also requires that the Specific Plan include policies concerning Williamson Act Contracts sufficient to address the requirements of Government Code section 56426.61. This has also not been done. In fact, the Specific Plan makes no reference to Williamson Act Contracts.
At the Planning Commission, the presentation by the City Staff reflected a lack of knowledge about the basics of the Williamson Act program. They advised the Planning Commission that such contacts expire at the end of 10 years, unless they are renewed at the end of that period . In fact , such contracts have evergreen clauses that automatically renew each year to maintain a 10-year term of the contract, unless and until a notice of nonrenewal is issued. At that time, and only after a nonrenewal notice is issued, does a Williamson Act Contract terminate at the end of 10 years.
The City has included, in the EIR supporting the Specific Plan, a discussion of fact that the Specific Plan conflicts with the Williamson Act Contracts. However, this does not
1 LAFCO Resolution USOI -144 includes an apparent scrivener’s error in that it refers to Government Code section 56426.5, when in fact the standards for annexation that address impacts to Williamson Act Contracts is set forth in Government Code section 56426.6.
Fresno City Council
December 17, 2025
Re: SEDA
address the fact that LAFCO Resolution USOI -144 requires that the Specific Plan include policies to address Williamson Act Contracts.
The City’s consultants provided a response to the County’s Comment on the EIR regarding this matter. That response inaccurately states that the “Specific Plan Policy CF-1.4 directly addresses the City’s comm itments to parcels with Williamson Act Contracts in that it will not facilitate early termination of such contracts. ” In fact, Policy CF -1.4 makes no reference to Williamson Act Contracts. In addition , a commitment by the City (assuming one is made) to not facilitate early termination of Williamson Act Contracts does not address any of the issues intended to be addressed by Government Code Section 56426.6, as required by the LAFCO Resolution.
The City also asserts that the issue of complying with Government Code section 56426.6 is something that can be deferred and addressed when an actual annexation of lands that include a Williamson Act Contract is intended. That approach, however, is directly in conflict with the requirements of LAFCO Resolution USOI -144, which requires that the Specific Plan include policies that will guide the process of the City in complying with Government Code section 56426.6 in its subsequent annexation activities.
Lack of Certainty Regarding Land Use Designations.
Even the land use designations that are central to the SEDA document are not adequately detailed. Those land use designations are provided with a caveat that the actual uses and densities of development detailed in the Specific Plan will be overridden by the terms of a future amendment to the City’s Development Code. (See Specific Plan at page 39). We are told that it is appropriate for us to await those development standards until the later amendment of the City’s Development Code , because the EIR is only evaluating the Specific Plan at a programmatic level. However, the failure to provide meaningful details of those standards in the Specific Plan fails to address these important aspects of the Specific Plan's intended scope of development, and results in an inadequate CEQA evaluation of its environmental impacts , even at a programmatic level.
Further Council Deliberations and Directions.
At the time of this writing, we do not know with any certainty what the City Council intends to evaluate (or potentially adopt ) at the meeting scheduled for December 18, 2025. However, we are led to believe that City Staff intends to focus the Council’s deliberations on providing the Staff with direction on the Specific Plan proposals, including addressing the revisions hastily recommended at the conclusion of the Planning Commission meeting. We therefore presently understand that no actions of adoption (or EIR Certification) are intended at that meeting.
From: Darren Rose
To: Clerk
Subject: Fresno City Council Meeting Agenda ID 25-1641
Date: Wednesday, December 17, 2025 12:41:09 PM
Attachments: BIA SEDA 12.18.25 Fresno City Council.pdf
External Email: Use caution with links and attachments
Darren Rose
President/ CEO
Building Industry Association of Fresno/ Madera Counties
California Code-Section 815 in part states the "Legislature finds and declares that the preservation of land in its natural scenic, agricultural, historical, forested, or open space condition is among the most important assets of California." Los Angeles County was the number 1 agricultural county in the nation from 1910 - 1950.
Don't repeat their fate. Reject
the SEDA Specific Plan as presented!
Additional concerns with the SEDA Specific Plan:
majority of cost will be borne by residents and not by the City or developers School Bonds covering a minimum of sixteen schools in the Sanger School District alone Increase in taxes to cover the cost of police protection due to increased crime loss of property for trails
metered water usage for ag wells
increase in taxes for infrastructure
increase taxes for fire protection
reduction in tax revenue for the Fresno County Fire Department cost of plan is prohibitive
don't let the Clovis School District and developers dictate where development occurs The West Area Neighborhood Specific Plan is approved and shovel ready. Over 50% of area is within the City limits
increase in taxes to pay for utilities
loss of property rights - hunting and shooting
traffic increase
loss of wildlife habitat
loss of property through Eminent Domain
farming that will be forced out due to complaints about cultural practices residents have received limited, vague, incorrect, and conflicting answers no true public involvement; holding public information meetings where we are told how it is, does not equal public engagement
loss of rural lifestyle
current surface water supply for project may not be adequate loss of flood irrigated crop land will reduce groundwater recharge Approval of the SEDA Plan will further delay the initiation and completion of development in the already approved specific plan areas of the City.
Don't let developers dictate the direction
of growth! We oppose the SEDA Plan and so should you.
Sincerely,
Jerry Prieto Jr.
From: Greg Terzakis
To: Clerk
Subject: CAA"s SEDA Support Letter
Date: Wednesday, December 17, 2025 12:53:19 PM
Attachments: CAA SEDA Letter.pdf
External Email: Use caution with links and attachments
CAA Greg Terzakis
Senior Vice President
California Apartment Association
[email protected] • (559) 663-6018
516 W. Shaw Avenue, Suite 200, Fresno, CA 93704
caanet.org • Compliance • Advocacy • Education • Insurance • Ethics
Thank you for your consideration.
Sincerely,
Greg Terzakis
Senior Vice President
From: District3
To: Clerk Agendas
Subject: FW: Please Vote NO on SEDA Project
Date: Wednesday, December 17, 2025 1:57:59 PM
For agenda item, ID 25-1641 4:30 p.m.
-District 3 Office
From: Andy Hansen-Smith <[email protected]>
Sent: Wednesday, December 17, 2025 12:15 PM
To: District3 <[email protected]>
Subject: Please Vote NO on SEDA Project
External Email: Use caution with links and attachments
Dear Councilmember Arias,
Please vote NO on ID-25 1641 (the SEDA project)
Thank you,
Andy Hansen-Smith
Fresno, CA 93702
From: District3
To: Clerk Agendas
Subject: FW: SEDA
Date: Wednesday, December 17, 2025 2:18:53 PM
For agenda item, ID 25-1641 4:30 p.m.
-----Original Message-----
From: Bob Hooke
Sent: Wednesday, December 17, 2025 2:17 PM
To:
Subject: SEDA
External Email: Use caution with links and attachments
Fresno City Council members,
I urge you to approve the EIR and SEDA Plan.
I'm sure it has been well thought out by the professionals on the planning staff and the Planning Commission.
Please don't be distracted by the media hype suggesting that it is being put forward by developers and will be built out quickly. Ultimately market demand will determine what gets built and when.
FUSD objections are irrelevant. Enrollment will shrink regardless of adoption of the SEDA Plan. People with young children no longer wish to live in the small houses of the inner city. They want more space. --
Bob Hooke
Fresno CA 93726
From:
To: Clerk
Subject: No on SEDA
Date: Wednesday, December 17, 2025 2:30:43 PM
External Email: Use caution with links and attachments
Hello,
As a previous Fresno Unified teacher and a south east resident, I am emailing to express my dissent against development in my community. Taking away equitable access to south east students by closing schools to benefit land developers is detrimental to our community. Is it time to stop putting the needs of children and families aside so rich companies can become more rich.
Do the right thing,
Racheal Moni
From:
Subject: Public Comment - December 18, 2025, Item ID 25-1641 Date: Wednesday, December 17, 2025 3:27:10 PM
External Email: Use caution with links and attachments
Dear Mayor and Members of the Fresno City Council,
I am writing as a District 3 resident and small business owner to urgently oppose the Southeast Development Area (SEDA) plan as it is being advanced to you on December 18.
District 3 already bears the consequences of decades of sprawl: limited transit access, disconnected neighborhoods, and small businesses struggling to remain reachable to the communities they serve. In our first year of operation as a brick-and-mortar, one of the most consistent complaints we receive is how difficult it is to reach our location without a car.
Customers regularly cite the lack of nearby bus routes and the distance between neighborhoods—conditions that are the direct result of Fresno’s outward expansion.
Advancing SEDA will worsen these inequities. Research shows that sprawling development drains public resources, increases infrastructure and service costs, and deepens environmental and public health harms while failing to serve existing neighborhoods (Resnik, 2010). For District 3 residents and business owners, this will mean fewer resources for transit, street
maintenance, public safety, and neighborhood investment, even as development dollars are pushed farther away.
What is especially troubling is the contradiction between this plan and the administration’s repeated promise of “ONE Fresno.” In meetings and public forums focused on Chinatown and Downtown—both within District 3—residents are told that revitalization and equity are priorities. Yet SEDA represents the opposite: greenfield expansion that benefits developers and real estate interests while leaving core and historic neighborhoods behind.
Labor, environmental, and community advocates have already raised serious concerns about SEDA’s fiscal viability, lack of clear alternatives, and absence of updated studies. Even the Administration has acknowledged that the plan, as proposed, is financially unsustainable.
Moving forward without transparent analysis places District 3 at particular risk, as we are consistently asked to do more with fewer resources. This new plan is a slap in the face to myself and the fellow businesses doing our best to serve while constantly being told to wait our turn.
I urge the City Council to reject the SEDA plan as presented and direct staff to return with clearly defined, fully studied alternatives that prioritize:
Investment within existing city limits
Transit-accessible, high-quality job creation
Fiscal responsibility and long-term sustainability
Meaningful reinvestment in District 3 and other established neighborhoods The decisions you make on December 18 will shape Fresno for decades. District 3 residents are paying attention, and we are asking you to choose reinvestment, equity, and accountability over continued sprawl.
Sincerely,
Ashley Marie Mireles-Guerrero
District 3 Resident & Small Business Owner
Reference
Resnik, D. B. (2010). Urban sprawl, smart growth, and deliberative democracy. American Journal of Public Health, 100(10), 1852–1856. https://doi.org/10.2105/AJPH.2009.182444