Agenda packet — Yucaipa City Council, August 25, 2025 (part 4 of 5)

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Santa Monica and Santa Ana populations, with estimated effective population sizes of 6 and 4, respectively, are likely to become extinct within 50 years if gene flow with other mountain lion populations is not improved (Benson, Mahoney, et al., 2016; Benson et al., 2019; Gustafson et al., 2018). This is detailed in the Center's petition to the California Fish and Game Commission to protect Southern California and Central Coast mountain lions under the California Endangered Species Act (Yap et al., 2019).

The Project area is located between the San Gabriel/San Bernardino (SGSB) population and the Eastern Peninsular Range (EPR) population, and the Santa Ana Mountains (SAM) population is nearby to the southwest. Scientists have documented physical and reproductive signs of inbreeding depression in local mountain lions (from the EPR and Santa Ana mountains, as well as the nearby Central Coast South [i.e. Santa Monica Mountains]) due to being boxed in by roads and development (Huffmeyer et al., 2021). Researchers have found that, of the California mountain lion subpopulations, the SGSB population has the smallest effective population size and the smallest area of available habitat (Dellinger et al., 2020; Gustafson et al., 2021). Scientists suggest that the SGSB population "may be approaching levels of genetic drift and inbreeding similar to the well -monitored and genetically depauperate Santa Ana and Central Coast South populations (Ernest et al., 2014; Gustafson et al., 2017; Riley et al., 2014)" (Gustafson et al., 2021), which are predicted to have a 99% chance of becoming locally extinct within 50 years if inbreeding depression continues. (Benson et al., 2019). This emphasizes the importance of protecting the remaining SGSB population, specifically through maintaining and enhancing connectivity among and between the subpopulations.

Numerous studies highlight the impacts of human activities on mountain lions. For example, Shilling et al. (2019) reported 299 observed roadkill mountain lions throughout the state from 2015 to 2018, but these deaths are likely underreported. Former CDFW biologist Justin Dellinger estimates there could be 200 puma deaths on roads every year (Price, 2020).

And a recent UC Davis special report identified a 58% reduction in mountain lion road mortalities after a 71% decrease in road use due to COVID-19 pandemic "stay-at-home" orders (Nguyen et al., 2020). This report highlights how roads and traffic are deadly barriers to puma movement and gene flow.

In addition to causing direct mortality in pumas, human activities also alter these large carnivores' behavior in ways that likely further impede important movement and gene flow. For example, Smith et al. (2017) found that mountain lions are so fearful of humans and noise generated by humans that they will abandon the carcass of a deer and forgo the feeding opportunity just to avoid humans.' The study concluded that even "non -consumptive forms of human disturbance may alter the ecological role of large carnivores by affecting the link between these top predators and their prey" (Smith et al., 2017). In addition, mountain lions have been found to respond fearfully upon hearing human vocalizations, avoiding the area and moving more cautiously when hearing humans (Smith et al., 2017; Suraci et al., 2019).

Other studies have demonstrated that mountain lion behavior is impacted when exposed to other evidence of human presence, such as lighting or vehicles/traffic (Smith et al., 2015; Wang et al., 2017a; Wilmers et al., 2013). In addition, preliminary results from a study by researchers at UC Davis and University of Southern California, as well as those by other 1 See also Sean Greene, "How a fear of humans affects the lives of California's mountain lions," Los Angeles Times (June 27, 2017), available at https://www.latimes.com/science/sciencenow/la-sci-sn- pumas-human-noise-20170627-story.html
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researchers, suggest that the light, noise, and other aspects of highways can have negative impacts on wildlife numbers and diversity near the highways (Shilling, 2020; Vickers, 2020). The researchers found a significant difference between species richness and species type (mammals, including mountain lions), with lower richness and fewer species at crossing structures compared to background areas 1 km away from the roads (Shilling, 2020). They also found that as traffic noises surpassed 60 dBC, the number of visits by small to large mammals decreased and most of the species in their study avoid traffic noise (Shilling, 2020). It is clear that different species have variable sensitivities to noise and light associated with development and transportation infrastructure; this can lead to changes in species distributions near roads and development, which can have ecosystem -level impacts (e.g., Suraci et al. 2019). Thus, roads, traffic, and development have negative impacts on puma survival and behavior, which can reduce the genetic health of populations and ultimately diminish their chances of long-term survival.

Yovovich et al. (2020) further documented the impacts of human activities on mountain lions in the Santa Cruz Mountains, specifically on communication and reproductive behaviors important for their survival. Males use scrapes to delineate territories as well as attract potential mates (Allen et al., 2015, 2016), and the males in the study preferred to use relatively flat areas away from human influence as scrape habitat (Yovovich et al., 2020). Similarly, when nursing females (with kittens less than 8 weeks old) shrank their home ranges to an average of 9 km2 while their young were most vulnerable, they also selected undeveloped lands away from human disturbance, opting for habitat with protective cover and sufficient water and prey availability (Yovovich et al., 2020). The loss of adequate undisturbed communication and nursery habitat could disrupt important communication and reproductive behaviors that facilitate social structure and overall survival. The authors predicted that future development within the Santa Cruz Mountains could reduce nursery and communication habitat by 20% and 50%, respectively, while further fragmenting the landscape. Such patterns likely extend to other regions within the proposed Southern California/Central Coast ESU.

Other studies document nuanced sensitivities of California mountain lions to human presence, activities, and infrastructure while also providing glimpses of how humans and mountain lions can safely coexist. Pumas in the Santa Cruz Mountains were found to less likely occur in areas with higher development densities (i.e., areas with greater road and/or building densities) (Nickel et al., 2020). This aligns with other studies that have demonstrated that mountain lion avoidance behavior increases with greater development densities (Smith et al., 2015, 2019; Wang et al., 2017a; Wilmers et al., 2013). In addition, Nickel et al. (2020) found that in open space areas where recreational activities are allowed (e.g., hiking, biking), mountain lions generally avoided human presence and became more nocturnal as human presence increased. Similar shifts in puma behavior in response to human activities have been documented in other studies (Lucas, 2020; Smith et al., 2017; Suraci et al., 2019; Wang et al., 2015, 2017a). There is often a cost of these behavioral shifts, such as increased energy expenditure that could potentially reduce fitness. Studies have found that pumas expend more energy by increasing their kill rates in high housing density areas (Smith et al., 2015) and having higher nighttime activity in developed areas (Wang et al., 2017b). This is further supported by a study that found mountain lions increased movement efficiency during the Covid-19 shutdown, which suggests that they incur energetic costs by increasing movement and space -use when avoiding human activity (Benson et al., 2021).

In a study conducted from 2002 to 2019 in the Santa Monica Mountains, (Benson, Sikich, et al., 2020) found high human -caused mortality rates in puma adults and high 08/25/2025 City Council Agenda
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intraspecific mortalities among subadults. Most known causes of death among adults and subadults (14/20) were directly human -caused: vehicle strikes, rodenticide poisoning, poaching, and wildfire. The remaining six known causes of deaths were intraspecific killing (Benson, Sikich, et al., 2020). And while intraspecific killings have been documented to naturally occur in mountain lion populations, it was likely exacerbated in the Santa Monica Mountains with the presence of significant movement barriers that prevent subadults from being able to adequately disperse, which likely led to increased conflicts with territorial males (Benson, Sikich, et al., 2020; Riley et al., 2014). The Santa Monica Mountains puma population is relatively small, extremely isolated, and geographically limited. Demographic and environmental stochasticity and high mortality rates increase the risk of local extinction, particularly when combined with small population size, low density, female -biased sex ratios, and skewed male reproductive success (Benson et al., 2019; Benson, Sikich, et al., 2016; Ernest et al., 2014; Gustafson et al., 2018; Riley et al., 2014; Vickers et al., 2015). Increased human -caused mortalities of adult males could lead to occasional male extinctions, which have been documented in the Santa Ana Mountains puma population (Beier & Barrett, 1993). Lack of breeding males would disrupt reproduction and could severely limit the short- and long-term viability of a population (Beier, 1993; Benson, Mahoney, et al., 2016; Benson et al., 2019; Benson, Sikich, et al., 2020). This highlights the need to reduce human -caused mortalities, in part, by improving connectivity.

There are numerous scientific studies that provide insights on the profound impacts human activities and infrastructure have on mountain lion survival, and they emphasize the need to adequately assess and mitigate impacts to these CESA candidate species in the Project area. These studies add to the accumulating evidence that mountain lions require a habitat mosaic that provides sufficient room to roam away from human -disturbed areas and connected to expansive, intact, heterogeneous habitats (Beier et al., 1995; Dickson et al., 2005; Dickson & Beier, 2002; Kertson et al., 2011; Zeller et al., 2017). Continued construction of roads and development in mountain lion habitat with little regard for their movement and behavioral needs has direct and indirect lethal and sublethal impacts that threaten the persistence of Southern California and Central Coast puma populations.

Mountain lions are a key indicator species of wildlife connectivity and healthy ecosystems. As the last remaining wide-ranging large carnivore in the region, the ability to move through large swaths of interconnected habitat is vital for genetic connectivity and their long- term survival. Local extinction of mountain lions in the region could have severe ecological consequences. Many scavengers, including many raptors, foxes, and numerous insects, would lose a reliable food source (Barry et al., 2019; Elbroch et al., 2017; Ruth & Elbroch, 2014). Fish, birds, amphibians, reptiles, rare native plants, and butterflies could potentially diminish if this apex predator were lost (Ripple et al., 2014; Ripple & Beschta, 2006, 2008). Loss of this ecosystem engineer and important predator -prey dynamics could have cascading effects on other plant and animal species, potentially leading to a decrease in biodiversity and diminished overall ecosystem function (Ripple et al. 2014; Elbroch et al. 2017; Barry et al. 2019; Benson et al. 2020b).

C. The 2005 EIR for the Project Do Not Address the Project's Impacts to Mountain Lions.

Virtually all of the studies cited above regarding the extinction vortex faced by mountain lions in Southern California were conducted and released after the EIR was certified for the Project in 2005. As such, the 2005 EIR does not —and cannot —adequately analyze or mitigate impacts of the Project on mountain lions, a CESA provisionally -listed species. This fact alone 08/25/2025 City Council Agenda
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necessitates recirculation of a new EIR before the City undergoes any approvals or extensions of approvals on the Project. Here, a supplemental EIR for the Project can and should contain analysis of how the Project can improve wildlife movement by removing obstacles to wildlife movement (e.g., by restoring or enhancing culverts, implementing overcrossings and/or underpasses, and conserving, restoring, and adaptively managing in perpetuity land adjacent to such areas). The supplemental EIR must also consider alternatives to the Project that do not cause impacts on mountain lions, and adopt all feasible mitigation measures to reduce impacts.

D. Conclusion
Ensuring regional wildlife connectivity and protecting local mountain lions will require cooperation from conservation groups and state and local officials. As noted in our recent report entitled California Connections: How Wildlife Connectivity Can Fight Extinction and Protect Public Safety, a lack of adequate crossing infrastructure harms both people and wildlife (Yap et al., 2021). But preserving existing connectivity and building wildlife crossings to enhance connectivity at existing barriers will help protect California's rich biodiversity while making ecosystems and human communities more resilient to climate change.

We respectfully urge the City to conduct a thorough assessment of the Project's impacts on mountain lions and wildlife connectivity and incorporate sufficient mitigation measures.

Sincerely,
J.P. Rose
Senior Attorney & Policy Director, Urban Wildlands
Center for Biological Diversity
Irose(a�biologicaldiversity.orq
Tiffany Yap, D.Env/PhD
Wildlife Corridor Advocate
Center for Biological Diversity
tyap(a�biologicaldiversity.orq
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References
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Barry, J. M., Elbroch, L. M., Aiello-lammens, M. E., Sarno, R. J., Seelye, L., Kusler, A., & Quigley, H. B. (2019). Pumas as ecosystem engineers: ungulate carcasses support beetle assemblages in the Greater Yellowstone Ecosystem. Oecologia, 189, 577-586.

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Beier, P., & Barrett, R. H. (1993). The cougar in the Santa Ana Mountain Range, California - Final Report Orange County Cooperative mountain lion study.

Beier, P., Choate, D., & Barrett, R. H. (1995). Movement patterns of mountain lions during different behaviors. Journal of Mammalogy, 76(4), 1056-1070.

Benson, J. F., Abernathy, H. N., Sikich, J. A., & Riley, S. P. D. (2021). Mountain lions reduce movement, increase efficiency during the Covid-19 shutdown. Ecological Solutions and Evidence, 2(3), 1-14.

Benson, J. F., Mahoney, P. J., Sikich, J. A., Serieys, L. E. K., Pollinger, J. P., Ernest, H. B., & Riley, S. P. D. (2016). Interactions between demography, genetics, and landscape connectivity increase extinction probability for a small population of large carnivores in a major metropolitan area. Proceedings of the Royal Society B: Biological Sciences, 283(1837), 20160957.

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Benson, J. F., Sikich, J. A., & Riley, S. P. D. (2016). Individual and population level resource selection patterns of mountain lions preying on mule deer along an urban-wildland gradient. PLoS ONE, 11(7), 1-16.

Benson, J. F., Sikich, J. A., & Riley, S. P. D. (2020). Survival and competing mortality risks of mountain lions in a major metropolitan area. Biological Conservation, 241, 108294.

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Dickson, B. G., & Beier, P. (2002). Home -range and habitat selection by adult cougars in Southern California. The Journal of Wildlife Management, 66(4), 1235-1245.

Dickson, B. G., Jennes, J. S., & Beier, P. (2005). Influence of Vegetation, Topography, and Roads on Cougar Movement in Southern California. Journal of Wildlife Management, 69(1), 264-276.

Elbroch, L. M., O'Malley, C., Peziol, M., & Quigley, H. B. (2017). Vertebrate diversity benefiting from carrion provided by pumas and other subordinate, apex felids. Biological Conservation, 215, 123-131.

Ernest, H. B., Boyce, W. M., Bleich, V. C., May, B., Stiver, S. J., & Torres, S. G. (2003). Genetic structure of mountain lion (Puma concolor) populations in California. Conservation Genetics, 4, 353-366.

Ernest, H. B., Vickers, T. W., Morrison, S. A., Buchalski, M. R., & Boyce, W. M. (2014). 08/25/2025 City Council Agenda
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Fractured genetic connectivity threatens a Southern California puma (Puma concolor) population. PLoS ONE, 9(10).

Frankham, R., Bradshaw, C. J. A., & Brook, B. W. (2014). Genetics in conservation management: Revised recommendations for the 50/500 rules, Red List criteria and population viability analyses. Biological Conservation, 170, 56-63.

Gustafson, K. D., Gagne, R. B., Buchalski, M. R., Vickers, T. W., Riley, S. P. D., Sikich, J. A., Rudd, J. L., Dellinger, J. A., LaCava, M. E. F., & Ernest, H. B. (2021). Multi -population puma connectivity could restore genomic diversity to at -risk coastal populations in California. Evolutionary Applications.

Gustafson, K. D., Gagne, R. B., Vickers, T. W., Riley, S. P. D., Wilmers, C. C., Bleich, V. C., Pierce, B. M., Kenyon, M., Drazenovich, T. L., Sikich, J. A., Boyce, W. M., & Ernest, H. B. (2018). Genetic source -sink dynamics among naturally structured and anthropogenically fragmented puma populations. Conservation Genetics, 20(2), 215-227.

Gustafson, K. D., Vickers, T. W., Boyce, W. M., & Ernest, H. B. (2017). A single migrant enhances the genetic diversity of an inbred puma population. Royal Society Open Science, 4(5).

Huffmeyer, A. A., Sikich, J. A., Vickers, T. W., Riley, S. P. D., & Wayne, R. K. (2021). First reproductive signs of inbreeding depression in Southern California male mountain lions (Puma concolor). Theriogenology, 177, 157-164.

Kertson, B. N., Spencer, R. D., Marzluff, J. M., Hepinstall-Cymerman, J., & Grue, C. E. (2011).

Cougar space use and movements in the wildland - urban landscape of western Washington. Ecological Applications, 21(8), 2866-2881.

Lucas, E. (2020). Recreation -related disturbance to wildlife in California -better planning for and management of recreation are vital to conserve wildlife in protected areas where recreation occurs. California Fish and Wildlife, Recreation Special Issue, 29-51.

Nguyen, T., Saleh, M., Kyaw, M.-K., Trujillo, G., Bejarano, M., Tapia, K., Waetjen, D., & Shilling, F. M. (2020). Special Report 4: Impact of COVID-19 Mitigation on Wildlife -Vehicle Conflict.

Nickel, B. A., Suraci, J. P., Allen, M. L., & Wilmers, C. C. (2020). Human presence and human footprint have non-equivalent effects on wildlife spatiotemporal habitat use. Biological Conservation, 241, 108383. https://doi.org/10.1016/j.biocon.2019.108383 Price, A. (2020, May 29). How the West is Learning to Live with Mountain Lions. Bitterroot Magazine.

Riley, S. P. D., Serieys, L. E. K., Pollinger, J. P., Sikich, J. A., Dalbeck, L., Wayne, R. K., & Ernest, H. B. (2014). Individual behaviors dominate the dynamics of an urban mountain lion population isolated by roads. Current Biology, 24(17), 1989-1994.

Ripple, W. J., & Beschta, R. L. (2006). Linking a cougar decline , trophic cascade , and catastrophic regime shift in Zion National Park. Biological Conservation, 133, 397-408.

Ripple, W. J., & Beschta, R. L. (2008). Trophic cascades involving cougar, mule deer, and black oaks in Yosemite National Park. Biological Conservation, 141, 1249-1256.

Ripple, W. J., Estes, J. A., Beschta, R. L., Wilmers, C. C., Ritchie, E. G., Hebblewhite, M., Berger, J., Elmhagen, B., Letnic, M., Nelson, M. P., Schmitz, O. J., Smith, D. W., Wallach, A. D., & Wirsing, A. J. (2014). Status and ecological effects of the world 's largest carnivores. Science, 343(6167), 1241484.

Ruth, T. K., & Elbroch, L. M. (2014). The carcass chronicles : carnivory, nutrient flow, and biodiversity. Wild Felid Monitor, 14-19.

Shilling, F. M. (2020). Wildlife Behavior in Response to Traffic Disturbance Wildlife Behavior in Response to Traffic Disturbance.

Shilling, F. M., Waetjen, D., Harrold, K., & Farman, P. (2019). 2019 Impact of Wildlife -Vehicle Conflict on California Drivers and Animals.

Smith, J. A., Duane, T. P., & Wilmers, C. C. (2019). Moving through the matrix: Promoting 08/25/2025 City Council Agenda
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permeability for large carnivores in a human -dominated landscape. Landscape and Urban Planning, 183, 50-58.

Smith, J. A., Suraci, J. P., Clinchy, M., Crawford, A., Roberts, D., Zanette, L. Y., & Wilmers, C.

C. (2017). Fear of the human `super predator' reduces feeding time in large carnivores.

Proceedings of the Royal Society B: Biological Sciences, 284(1857), 20170433.

Smith, J. A., Wang, Y., & Wilmers, C. C. (2015). Top carnivores increase their kill rates on prey as a response to human -induced fear. Proceedings of the Royal Society B: Biological Sciences, 282(1802).

Suraci, J. P., Clinchy, M., Zanette, L. Y., & Wilmers, C. C. (2019). Fear of humans as apex predators has landscape -scale impacts from mountain lions to mice. Ecology Letters, 22(10), 1578-1586.

Traill, L. W., Brook, B. W., Frankham, R. R., & Bradshaw, C. J. A. (2010). Pragmatic population viability targets in a rapidly changing world. Biological Conservation, 143, 28-34.

Vickers, T. W. (2020). Project Title: Santa Ana Mountains to Eastern Peninsular Range Conservation Connectivity Infrastructure Planning Project for Interstate 15 and Closely Associated Roadways.

Vickers, T. W., Sanchez, J. N., Johnson, C. K., Morrison, S. A., Botta, R., Smith, T., Cohen, B.

S., Huber, P. R., Ernest, H. B., & Boyce, W. M. (2015). Survival and mortality of pumas (Puma concolor) in a fragmented, urbanizing landscape. PLoS ONE, 10(7), 1-18.

Wang, Y., Allen, M. L., & Wilmers, C. C. (2015). Mesopredator spatial and temporal responses to large predators and human development in the Santa Cruz Mountains of California.

Biological Conservation, 190, 23-33. https://doi.org/10.1016/j.biocon.2015.05.007 Wang, Y., Smith, J. A., & Wilmers, C. C. (2017a). Residential development alters behavior, movement, and energetics in a top carnivore. PlosOne, 1-17.

Wang, Y., Smith, J. A., & Wilmers, C. C. (2017b). Residential development alters behavior, movement, and energetics in a top carnivore. PlosOne, 12(10), e0184687.

Wilmers, C. C., Wang, Y., Nickel, B., Houghtaling, P., Shakeri, Y., Allen, M. L., Kermish-Wells, J., Yovovich, V., & Williams, T. (2013). Scale dependent behavioral responses to human development by a large predator, the puma. PLoS ONE, 8(4).

Yap, T. A., Rose, J. P., Anderson, I., & Prabhala, A. (2021). California Connections: How Wildlife Connectivity Can Fight Extinction and Protect Public Safety.

Yap, T. A., Rose, J. P., & Cummings, B. (2019). A Petition to List the Southern California/Central Coast Evolutionarily Significant Unit (ESU) of Mountain Lions as Threatened under the California Endangered Species Act (CESA).

Yovovich, V., Allen, M. L., Macaulay, L. T., & Wilmers, C. C. (2020). Using spatial characteristics of apex carnivore communication and reproductive behaviors to predict responses to future human development. Biodiversity and Conservation, 29(8), 2589- 2603.

Zeller, K. A., Vickers, T. W., Ernest, H. B., & Boyce, W. M. (2017). Multi -level, multi -scale resource selection functions and resistance surfaces for conservation planning: Pumas as a case study. PLoS ONE, 12(6), 1-20.
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No to the proposed Warehouse off Live Oak Canyon Road
Deepak Gopalakrishnan
Mon 8/26/2024 1:31 PM
To:Public Comment
Hi,
Being a resident of Beaumont, I reject this proposal of opening a new warehouse off Live Oak Canyon Road.

The roads are already saturated with traffic in the rush hours and adding new warehouses that will increase the number of trucks on 110 is unimaginable.

Until and unless the roads are expanded to solve the current congestion, new load on the existing road infrastructure is going to cripple the traffic for the office goers like me and in turn affect our health and safety as we will be forced to start earlier than now.

Kindly consider our requests.

Regards,
Deepak
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Opposition to to the 2 million sq. ft. warehouse in Live Oak Canyon Kathleen
Mon 8/26/2024 1:38 PM
To:Public Comment
Dear Yucaipa City Council,
I oppose the proposed use of land at Live Oak Canyon for warehouse use. I implore the council to take a stand for future generations and to even seek seeing the mouth and entrance of the canyon put into a land conservancy or state park for open land conservation. The fact is that with the encroachment of development onto the remaining open space our area still has, thoughtful open land preservation needs to happen.

It is noted nationally that warehouse development needs have steeply declined and that vacancies in our area are rapidly growing. This would involve putting this beautiful open space at the mouth of a historic and scenic canyon at risk to see it developed in a manner that may or may not add to the economy decades down the road. Open land is one of the greatest assets our area has as people move here seeking open vistas and open space to hike and breathe. The traffic and concrete from the warehouses has hurt our air quality and driven temperatures up. I am a lifelong local area resident who cannot even recognize our IocaI communities anymore, however, the Toss of the natural beauty of Live Oak Canyon would be travesty of travesties if this development is allowed to take place. I am not a Yucaipa resident, but live in Redlands. We have seen the harm that these warehouses have done to our IocaI natural beauty and I implore you to not make the same mistakes.

I urge the council to reject the proposal and stand up for its citizens and the land for which we are only temporary stewards before it is passed along to the next generations who will wonder why we didn't stand up for them.

Thank you,
Kathleen Beall
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Public comment - 08/26/2024 re: freeway corridor plan
Brooke's Yahoo
Mon 8/26/2024 1:32 ....

To:Public Comment
Good evening, members of the City Council,
My name is Brooke Allert, and I have been a proud resident of this small town for 34 years; I have chosen to stay in this town to raise my family and three young children. I am here to voice my concerns and opposition to the proposed freeway corridor plan in our community. As someone who deeply cares about the future of our town, I believe this development poses several significant risks that outweigh its potential benefits.

Firstly, our town is already struggling with insufficient infrastructure. We all know our streets are not designed to handle the increased traffic that would come with new warehouses and duplexes. The additional trucks and vehicles would lead to congestion, increased wear and tear on our roads, and a heightened risk of accidents. We need to prioritize upgrading our existing infrastructure before considering any new developments.

Secondly, our schools are already overcrowded. Adding more duplexes means more families and more children, which would strain our education system even further. Our current schools are not equipped to handle this increase in student population, which could result in larger class sizes and diminished educational outcomes.

Instead of building new housing, we should be focusing on improving and expanding our educational facilities to meet the current demand.

Moreover, the introduction of warehouses could significantly alter the character of our small town. Warehouses often bring noise, pollution, and increased truck traffic, which would negatively impact our residents' quality of life. Our town's charm and appeal lie in its quiet, residential nature. Allowing such developments would detract from what makes our town special and could lead to a decline in property values and the well-being of our residents.

Additionally, the environmental impact of constructing new warehouses and duplexes cannot be ignored. These developments would require significant land use changes, potentially damaging local ecosystems, increasing stormwater runoff, and affecting our town's natural beauty. We need to consider sustainable growth that respects our environment and maintains our community's character.

Finally, we must think about the long-term vision for our town. What kind of community do we want to be? Do we want to preserve the small-town feel that attracts residents and visitors, or do we want to transform into a hub of industrial and high -density residential developments? I believe that with careful planning and thoughtful consideration of our community's needs, we can find a balance that supports growth while preserving the unique qualities that make our town a great place to live.

In conclusion, I urge the City Council to reconsider these developments and explore alternatives that align with our community's needs and values.

Thank you for your time and consideration.
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(No subject)
gideon crandell
Mon 8/26/2024 1:48 PM
To:Public Comment
I oppose the proposed warehouse plan
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New developments proposed for the Live Oak Canyon corridor Erica Serrao
Mon 8/26/2024 1:59 PM
To:Public Comment
Cc:Kim J Metzler, CMC, CPM
Staff and Honorable Councilpersons of Yucaipa:
am writing to you to express my opposition to any construction that would adversely affect the rural nature of Live Oak
Canyon.

There are many known cultural resource sites in the Canyon within both Redlands and Yucaipa boundaries. I presently work with Redlands Conservancy and would greatly appreciate if Yucaipa would work collaboratively with Redlands to preserve open space
and the rural character of lands South of 1-10 in Live Oak Canyon and what is known as the Serengeti in the cycling community.

As someone who was born and raised in Redlands and has been living in Live Oak Canyon for 15 years, the proposed construction would detrimental to Live Oak Canyons open spaces, wildlife and residents. The road is already extremely dangerous and busy as it is used as short cut for commuters. Because of this, the speed limit is not being honored and there are monthly car accidents due to the overuse of this windy road.

Yucaipa has done a spectacular job revitalizing their historic downtown and preserving the Crafton Hills in collaboration with Redlands and the county. I invite the city of Yucaipa to work with Redlands and develop an extension of Herngt 'Aki' Preserve in adjacent lands within Yucaipa. This will preserve the character of Live Oak Canyon, provide Yucaipa residents living South of Crafton Hills access to a network of hiking, cycling and equestrian trails that connect us all to our history and protect a critical wildlife corridor used by endangered Southern California Mountain Lions and other threatened and endangered species.

Erica Serrao
Administrative Assistant
Redlands Conservancy

REDLANDS

CONSERVANCY
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oppose the Freeway Corridor Specific Plan Update
mb
Mon 8/26/2024 2:21 PM
To:Public Comment
I am pleading with you to oppose the Freeway Corridor Specific Plan Update. I live on I was raised in this area of Yucaipa, have raised my children here and have grandchildren growing up in this area as well.

Sincerely,
Mary Brown
08/25/2025 City Council Agenda
752

Large warehousing
Lisa Long
Mon 8/26/2024 2:22 PM
To:Public Comment
Please, no more large warehousing in the area. The freeways are terrible and congested and don't we already have enough?
Sent from my iPhone
08/25/2025 City Council Agenda
753

Public Comment Council Meeting 9-26-2024
Lucinda Brinks
Mon 8/26/2024 2:25 rivi
To:Public Comment
August 26, 2024
Yucaipa City Council members,
I write to you today pleading with you to deny the changes to the General Plan and Freeway Corridor Specific Plan and vote no on the updated Freeway Corridor Specific Plan including the Pacific Oaks Commerce Center.

My first concern is the poor/unhealthy air pollution it will cause. This is not a "might" cause, it is a WILL cause.

Our air quality is already poor, adding 1,100 daily diesel truck trips is estimated to increase diesel particulate matter by nearly 30% and generate 2,808 tons of greenhouse gases per year. These identified polluting gases cannot be mitigated. The noise pollution cannot be mitigated as well. Please don't sacrifice the health of Yucaipa citizens for this warehouse project.

My second concern is the traffic it will generate. City Council recently approved a year round use permit to the Pumpkin Patch. The horrible traffic at Interstate 10 and Live Oak Canyon Road will no longer be limited to the fall and early winter. Can you imagine trying to cross the street with youngsters while big rigs zoom past? It is a tragedy in the making. Will you feel guilty? Will the city be sued yet again? This area is beautiful agricultural land. A two million square foot warehouse does not belong in our rural city. It certainly doesn't "create a place that reflects the unique character Yucaipa and ultimately supports the community's need into the future." Why not move the "wine country" here? The rolling hills could be covered in grape vines and the wineries, tasting rooms, restaurants and B&B's could be easily accessible from the freeways without driving through residential streets.

The Planning Commission voted NO on the approval of this plan. The city's stance that they made "no recommendation" is misleading. The majority of Commissioners voted against recommending the project.

I hope you were able to read and digest the 600+ pages in the agenda packet. Ask the hard questions.

Councilman Venable, do not disappoint your constituents who live in the area. I hope you all realize the proper vote is NO. Please, do not approve this monstrous and unhealthy project. 08/25/2025 City Council Agenda
754

Lucinda Brinks
District 1.
08/25/2025 City Council Agenda
755

warehouse houses on wildwood canyon
Bonnie Parker
Mon 8/26/2024 2:45 PM
To:Public Comment
I cannot attend meeting this evening regarding buildings being proposed off wildwood canyon Road. NO! NO! 08/25/2025 City Council Agenda
756

Proposed Warehouses in Live Oak Canyon
Steven T. Spillel
Mon 8/26/2024 2:46 PM
To:Public Comment
Dear Mayor and Members of the Yucaipa City Council,
The proposed warehouse project by Pacific Industrial is a slap in the face of local communities who treasure Live Oak Canyon and what it has to offer in its present, semi rural agricultural and natural state. We have seen too often where one warehouse begets more and more of the same. One only has to drive down the 1-10 and see what has happened in Redlands and other communities in the Inland Empire. Traffic, air pollution, noise, and the elimination of treasured spaces for concrete monoliths with no redeeming value. 1 urged you to reject Pacific Industrial's proposal.

Sincerely,
Steven T. Spiller
Redlands, CA
08/25/2025 City Council Agenda
757

URGENT - Proposed Warehouse off Live Oak Canyon Road
Joanne Morse
Mon 8/26/2024 2:4. ....

To:Public Comment
Yucaipa City Council Members:

I am opposed to the proposed warehouse off of Live Oak Canyon Road that comes before you tonight.

As someone who has grown up in this area and lives along San Timoteo Canyon, I have witnessed the impact on the open space, traffic, wildlife, quality of life, and beauty of the area that comes along with each added warehouse built.

The Live Oak and San Timoteo Canyons are historic to our area and should be protected and preserved. There are efforts underway by conservancy groups to protect these special places for generations to come to enjoy them. San Timoteo Canyon has already become very congested and impacted by commuter and big rig traffic. This proposed warehouse would only compound what is already a large issue.

I ask the council to seriously consider the long-term impact of your decision. Do your part to protect us from out -of -control warehouse building and destruction of our history and quality of living that are the very things that have brought and kept people in this beautiful area for generations.

You have the responsibility to protect us. I sincerely hope you vote NO.

Thank you for your consideration.

Joanne E. Morse
08/25/2025 City Council Agenda
758

Honorable Mayor Beaver
City Council Members
City of Yucaipa
Re: FREEWAY CORRIDOR SPECIFIC PLAN &FSP UPDATE
Public Comment for August 26,2024 Meeting

FOR THE RECORD
Dear Mayor and Council:

I vehemently oppose this Plan it its entirety and ask that you work with the Yucaipa Conservancy and Redlands Conservancy's to preserve all of the grasslands and grazing lands on both sides of the 1-1 freeway. These canyon lands and precious hillsides are rare across the State of California and are your community's link to early California history. This is all we have left of Yucaipa's cultural landscape that tells generations who was here, why they came here, and the contributions they made. This is not now or ever will be a sustainable place for logistics and housing.

No one wants to live alongside the most traveled and congested freeway in the United States. Sound walls do not mute the constant thundering roar, the sirens, or continuous accidents from Ford Street to County Line Rd. The air pollution will not be controlled, no matter how you think this impact, alone, can be mitigated. The land vibration is felt across my property hourly. The sky glow from the parking lot lights, though aimed downward, will still create a gray canopy over this area to completely wipe out the view of the night sky. All of this upheaval of the natural environment will destroy the perfectly balanced ecosystem and destroy the many wildlife habitats and corridors you don't see. I lived in the canyon and on West County Line Rd. We rode our horses down to the Pumpkin Patch land and beyond through the Palmer ranch.

The future cannot promise you econonical gains and financial stability! The people here and now are your future and no out of county developers who care not an Oak tree or leaf about your community's quality of life, health, or happiness --or why the love the rural life here.

Please say NO to this desperate measur. No problem is so big that not a reasonable and more beneficial solution cannot be found.

Sincerely,
Pamela Smyth
08/25/2025 City Council Agenda
759

Redlands with Yucaipa shared boundary lines
0 08/25/2025 City Council Agenda
760

Freeway Corridor specific plan update
Scott Quinnell
Mon 8/26/2024 3:00 PM
To:Public Comment
Hi,
I object to the building of wherehouses on Live Oak Canyon. The increase in truck traffic at the freeway ramps mixing with residential traffic will be unbearable to those of us who live here and use the Interchange. The impact on natural resources, wildlife, increased light glare, and scenic views will be adverse and forever changed. No mitigation will alleviate the permanent impact to Yucaipa.

Thank you,
Scott Quinnell
Sent from my T-Mobile 5G Device
Get Outlook for Android
08/25/2025 City Council Agenda
761

FW: 24-044/GPA/SPA and Pacific Oaks Commerce Center Case No.21-196 Ana Sauseda, MMC
Mon 8/26/2024 3:05 PM
To:Tara Davis
Ana Sauseda, MMC
Director of General Services/City Clerk
City of Yucaipa
City Hall • 34272 Yucaipa Blvd • Yucaipa, CA 92399
Office: 909-797-2489 Ext. 230
www.yucaipa.gov
Original Message
From: SUSAN BLAS
Sent: Wednesday, August 21, 2024 4:U2 PM
To: Ana Sauseda, MMC
Subject: 24-044/GPA/SPA and Pacific Oaks Commerce Center Case No.21-196 I oppose the warehouse and Pacific One Commerce Center projects to be located off Live Oak Canyon Road and outer Hwy 10 in the City of Yucaipa.

Susan Blas
08/25/2025 City Council Agenda
762

August 26, 2024
City of Yucaipa — Planning Division
34272 Yucaipa Blvd
Yucaipa, CA 92399
RE: Proposed revisions to the Freeway Corridor Specific Plan.

Dear City Council,
West Coast Entitlement, on behalf of Robinson Ranch, is formally requesting that the Freeway Corridor Specific Plan (FCSP) update be postponed until the September 23, 2024, City Council meeting, Robinson Ranch is the majority landowner within the FCSP area, encompassing more than 560 total acres. In its current configuration, Robinson Ranch does not support the FCSP; however, if certain changes were made to the FCSP, then Robinson Ranch would be in support of the FCSP update, On July 16th, West Coast Entitlement and City Staff held a meeting to discuss the disagreement the Robinson's had toward the plan and some potential solutions to resolve that disagreement with the main limiting factor being the Environmental Impact Report (EIR) for the FCSP. On August 13th, another meeting was held where West Coast Entitlement presented a list of proposed changes to City Staff to which the City was mostly agreeable and offered some alternatives. On August 22,,, West Coast Entitlement submitted the Robinson's Errata Sheet along with accompanying exhibits. Prior to the aforementioned meetings, the Robinson's had not been contacted or consulted by the City for the proposed changes, regardless of their status as majority landowner. It was not until West Coast Entitlement reached out to the Robinson's to offer their services that the Robinson's became aware of the upcoming changes. There simply has not been enough time to work through the valid issues and concerns raised by the Robinson's and an additional 30 days is necessary to assure every stakeholder within the FCSP Area has been adequately and appropriately represented in this matter.

Specifically, the Robinson's are requesting:

1. The City revise the FCSP to identify a suitable water tank location on city -owned property (APN: 0318-181- 21), adjacent to the Hoover Egg Ranch.

2. The City shall vacate unused portions of Right -Of -Way (ROW) near the intersection of Oak Glen Road & Calimesa Blvd. Additionally, ROW owned by the City in front of APN: 0301-221-09 shall be vacated back to the Robinson's; however, if ROW is owned by CalTrans, then the City will offer a letter of support to vacate this area.

3. The FCSP shall include language that provides a mechanism for a City and developer to enter into a cost - sharing agreement for any environmental review costs and waiver of application review fees to develop Open Space & Conservation areas.

4. The FCSP Land Use Plan shows the development potential of the area with Hillside Overlay District requirements applied; however, when a development is submitted, this area will change depending on the developer. The City shall update the FCSP Land Use Plan to remove the pre-emptive application of the hillside requirements.

5. The City shall re -distribute Commercial area from the water -company -owned property (APN: 0318-111-02) to the Robinson's property directly west (APN: 0318-071-07).

6. The City shall re -distribute approximately 6-7 acres of Business Park Zoning from elsewhere within the FCSP to BPS. Potential locations that could involve redistribution are BPI, BP2, & BP3. 543 W. County Line Road
Calimesa, CA 92320
909.335.1665
08/25/2025 City Council Agenda
763

The City Manager as of this morning, August 26, 2024, has verbally agreed to items 1-3; however, West Coast Entitlement nor the Robinson's have received any documentation from City staff other than an updated errata sheet received at 2:13pm this afternoon. The City should make the changes and have them reviewed and agreed to by the Robinson's prior to any decision being made by the City Council. Further, items 4-6 are important to assure the Robinson's are not affected by inverse condemnation as the changes being made to the FCSP significantly hinders the development potential of the Robinson -owned properties. The Freeway Corridor is one of the last great opportunities in the City of Yucaipa as this is a statement piece for those traveling through town, and it is imperative that this plan be reviewed meticulously and not rushed through the system. It is my understanding that an additional 30-days will not impact the warehouse project — other than delay — so this request for additional time to work through these issues will not prevent the pending project.

Sincerely,
Craig Hems
Managing Member
West Coast Entitlement
(909) 335-1665
Cc: Chris Mann, City Manager
Steven Graham, City Attorney
Councilman Matt Garner
Councilman Bobby Duncan
Councilman Jon Thorp
Councilman Chris Venable
Mayor Justin Beaver
Benjamin Matlock, City Planner
543 W. County Line Road
Calimesa, CA 92320
909.335.1665
08/25/2025 City Council Agenda
764

FW: Proposed warehouse off Live Oak Canyon Road
Public Comment
Mon 8/26/2024 3:54 PM
To:Tara Davis
This one was on time but in the junk folder.

City of Yucaipa
• • , CA
Office:
www.yucaipa.gov
From: Juli Spiller
Sent: Monday, August 26, 2024 2:41 PM
To: Public Comment
Subject: Proposed warehouse off Live Oak Canyon Road
I am disturbed to hear of yet another proposed warehouse in this area. This would create multiple problems for the surrounding areas, especially since this is being proposed for an area so inappropriate.

We have had worsening air quality, extreme additions of truck and other vehicle traffic with a multitude of new warehouses. This is impacting our communities in a negative manner.

I understand there will be parking for 1100 trucks and 986 cars. This obviously will involve that number if vehicles not only "parking" but traveling these roads. This seems an extreme number of additional vehicles added to already heavily traveled roads.

Our communities are becoming a nightmare of huge cement complexes lining our roads and Hillside much less causing extreme traffic and wear on our roads. Our air quality had significantly improved since I moved here in 1969. Now it seems it is published and common knowledge that we have the worst air quality.in the country?
These warehouses must stop being approved. We need to keep our open areas and stop polluting our communities.

Please DO NOT approve yet another warehouse! Vote for the people, not the $.

Juli Spiller
08/25/2025 City Council Agenda
765

J Outlook
Your vote on the outter highway corridor 9/23/24
From Diane Elmore
Date Wed 9/18/2024 2:35 PM
To Public Comment ; Justin Beaver ; Matt Garner
; Bobby Duncan ; Chris Venable ;
Jon Thorp
Cc Bob Warner Abbey Elmore
Gentlemen, I have been watching the resident's comments on the subject of the "Outter Highway Corridor" behind the Pumpkin Patch, between Live Oak and County Line Road, and find that the majority of them DO NOT WANT warehouses and a mass amount of houses placed there.

Personally, I wished you would re -think this issue and find other land somewhere else to create tax dollars for the city.

Obviously, you see that I am against this project, not because Yucaipa needs the money, but rather because of the erasure of a natural rural existence that Yucaipa is/was known for.

Thank you,
Diane Elmore
08/25/2025 City Council Agenda
766

Outlook
Fwd: Delivery Status Notification (Failure)
From Jon Flick
Date Thu 9/19/2024 9:29 AM
To Public Comment
Forwarded message
From: Mail Delivery Subsystem
Date: Tue, Sep 17, 2024 at 5:30AM
Subject: Delivery Status Notification (Failure)
To:
1 Message blocked
Your message to [email protected] has been blocked. See technical details below for more information.

The response from the remote server was:
550 permanent failure for one or more recipients ([email protected]:550 5.4.1 Recipient address rejected: Access denied.[DS1PEPF00017E08.namprd09.prod.outloo...) 08/25/2025 City Council Agenda
767

Forwarded message
From: Jon Flick
To: [email protected]
Cc: [email protected], Save Canyon
Bcc:

Date: Tue, 17 Sep 2024 05:30:06 -0700
Subject: My childhood canyon home
To whom it may concern,
The Oaks we called them as kids. My next door neighbor's dad Ralph would pilot his old Ford and feed the cattle hay. We boys would strap canteens of Goofy Grape Kool-Aid over our shoulders and head down to our childhood playground to play army. Back in the sixties, we caught snakes, put them in potato sacks and sold them to Van Dyke's Pet Shop in Redlands. There is a spiritual presence in this tranquil valley. I felt it as a child and still feel it as a senior citizen when I traipse in the canyon where the Native Americans once moved. Many of the Oak trees have withered and collapsed from the lack of rain but one remains from my youth. As kids in the sixties my pal Mike and I carved our initials on the trunk. Mike has been gone for many years now, but when my book was published in 2014 I left my desert home in Arizona to return to Live Oak Canyon. I returned to the tree and knelt at its base and said a prayer for Mike and yes, the book, The Bogus Buzz, I wrote about coming of age in Redlands and the canyon I lived above on Club Drive. As soon as the prayer left my lips, I heard a cry and a red tail hawk hovered over me, craned his neck, to give me a glance and headed over the fire road. We need not warehouses, whose trucks pollute that magnificent bird's sky. Let the Red Tail Hawk hover.

Sincerely,
Jon Flick
Pen Name Glen Keough .
08/25/2025 City Council Agenda
768

0u.ok
.• Oak Canyea 13.k cover
OMe 11,,/19/202111"5
, COmm,,Pki,cCommerlIff,uapa gov,
08/25/2025 City Council Agenda
769

Outlook

YUCAIPA WAREHOUSE PROJECT
From abby harned
Date Thu 9/19/2024 12:25 PM
To Public Comment
Cc Kim J Metzler, CMC, CPM
To: Yucaipa City Council
As organic farmers in neighboring San Timoteo Canyon, we strive to use sustainable practices to reduce our impact on the land.

Since purchasing our 20 acre property in 2002, we have witnessed UNSUSTAINABLE LEVELS OF HOUSING and WAREHOUSE DEVELOPMENT
all around us in Moreno Valley, Beaumont, Calimesa, Cherry Valley and Redlands.

Unsustainable development has UNMITIGATED impacts to the land with regard to WATER SUPPLIES,

WILDFIRE, RUNOFF & EROSION, TRAFFIC,
AIR QUALITY, LIGHT POLLUTION and LOSS OF OPEN SPACE & WILDLIFE HABITAT.

Every fall, the public flocks to the Pumpkin Patch for a chance to spend time outdoors, engage with their community, connect with a seasonal tradition and learn about nature and farming.

For many families, visiting a pumpkin patch is an annual ritual that has been passed down for many generations.

Developing this land and its surrounding hills would be a shameful loss of some of the LAST REMAINING AGRICULTURAL LAND and natural open space IN OUR REGION! Let's see a plan that includes SUSTAINABLE AGRICULTURE and ENCOURAGES growers to return to the area and bring back its RICH AGRICULTURAL HERITAGE.
urge the city council to vote NO on this SHORT-SIGHTED proposal.

The Inland Empire already has more warehouses than anywhere else ON THE PLANET (they can be seen from OUTER SPACE) as well as THE WORST AIR QUALITY! Vacant warehouse space is on the rise and the logistics industry is seeing a downturn.

Please have the FORESIGHT to develop SUSTAINABLY and thoughtfully with SMART GROWTH 08/25/2025 City Council Agenda
770

and PROGRESSIVELY PLANNED COMMUNITIES that encourage walking and bicycling, AGRITOURISM and ECOTOURISM.

Support the HEALTH of your neighbors and listen to the community who voted you into office.

Thank you,
Abby and Jason Harned
Three Sisters Farm, Redlands
08/25/2025 City Council Agenda
771

From: Angela Moskow
To: Public Comment
Cc: Janet Cobb; Chris Mann; Benjamin Matlock; Susan Phillips; Subject: Freeway Corridor Specific Plan Subsequent Environmental Impact Report, State Clearinghouse Number 2006041096
Date: Thursday, September 19, 2024 3:13:06 PM
Attachments: CaliforniaWildlifeFoundationLetterPacific0aks9 24.pdf Greetings,
Please find attached and please verify receipt of the attached letter on the Freeway Corridor Specific Plan Subsequent Environmental Impact Report, State Clearinghouse Number 2006041096. With gratitude to you for sharing this letter with Mayor Beaver and his fellow members of the City Council.

All my best,
Angela
Angela Moskow
Oak Program Director
California Wildlife Foundation/California Oaks
201 University Avenue
Berth H-43
Berkeley, CA 94710
www.californiaoaks.org
Telephone: (510) 763-0282
08/25/2025 City Council Agenda
772

CALIFORNIA WILDLIFE

FOUNDATION
California Wildlife Foundation/California Oaks, 201 University Avenue, H-43 Berkeley, CA 94710, (510) 763-0282 September 19, 2024
Mayor Beaver and fellow members of the City Council
City of Yucaipa
34272 Yucaipa Blvd.

Yucaipa, CA 92399
Transmitted via e-mail to Mayor Beaver and members of the City Council via [email protected]
Re: Freeway Corridor Specific Plan Subsequent Environmental Impact Report, State Clearinghouse Number 2006041096
To the Honorable Mayor Beaver and fellow members of the City Council:

The California Oaks program of the California Wildlife Foundation works to conserve oak ecosystems because of their critical role in sequestering carbon, maintaining healthy watersheds, providing plant and wildlife habitat, and sustaining cultural values. California Wildlife Foundation/California Oaks (CWF/CO) is writing this letter at the request of a San Bernadino County resident who is concerned about the Freeway Corridor Specific Plan project. We commend the Planning Commission for not advancing the project and urge the City Council to follow suit.

This letter's focus is on the proposed project's impacts on native California oaks growing at the site, specifically an inconsistency between the proposed project and the Yucaipa General Plan, the conclusion that environmental impacts to oak habitat would be less than significant after mitigation, and a number of issues with the Oak Tree Protection Ordinance.

Inconsistency between the proposed project and the General Plan: PR 4.4 of the Yucaipa General Plan calls for preservation of "the City's heritage oak trees through adherence to the Oak Tree Conservation regulations in the Yucaipa Municipal Code, proper tree care and maintenance, and other efforts." The word "heritage" is important because it refers to mature trees. Trees should be kept standing to the greatest extent possible. Specifically, as discussed below, oaks are vital habitat for many of the sensitive plant and animal species discussed in the environmental documentation for the project.

The conclusion that environmental impacts to oak habitat would be less than significant after mitigation is not supportable because many of the vulnerable animal and plant species listed in Tables 5 and 6 of the Biological Resources Technical Report of the Draft Subsequent Environmental Impact Report are oak -associated or oak -dependent. The conclusion that the oak mitigation will render the impacts less than significant is merely speculative without a clear understanding of the trees proposed for removal and the specific mitigation plan, especially because the impacts to oaks will also impact plants and animals that utilize oak habitat.
www.cnlilorni,[ mkw.nrg
08/25/2025 City Council Agenda
773

CWF/CO issued a report in 2021 on oak -dependent terrestrial and amphibian vertebrate and oak -associated plant and invertebrate species that are federally and/or state designated as endangered or threatened (listed) (including state fully protected vertebrates) or as candidates for listing. The report was prepared with lists of sensitive species dependent upon or associated with oaks provided by California Depaitiiient of Fish and Wildlife (CDFW). Vertebrate data were derived from the California Wildlife Habitat Relationship (CWHR) information system.

The CWHR query focused on species that utilize Quercus (oak) species or Notholithocarpus densiflorus (tanoak) for reproduction, cover, or feeding, and are thus dependent upon oak habitat. Plant and invertebrate tables on oak -associated species were created through a cross- reference of California Natural Diversity Database (CNDDB) occurrence records of rare plants and animals with the oak (Quercus) woodland dataset in CDFW's Areas of Conservation Emphasis system. The CWF/CO report focused on listed species, so these databases were consulted for non -listed species discussed in this letter.

Eight of the nine plants from table 5 of Appendix E, Biological Resources, are oak -associated:

Nevin's barberry (Berberis nevini, federally and state endangered), smooth tarplant (Centromadia pungens ssp. laevis, 1B.1), Parry's spineflower (Chorizanthe parryi var. parryi, 1B.1), slender -horned spineflower (Dodecahema leptoceras, federally and state endangered), California satintail (Imperata brevifolia, 2B.1), Hall's monardella (Monardella macrantha ssp. hallii, 1B.3), salt spring checkerbloom (Sidalcea neomexicana, 2B.2), and San Bernardino aster (Symphyotrichum defoliatum, 1B.2).

The amphibian in Table 6, western spadefoot (Spea hammondii, Species of Special Concern), is oak -dependent, as are six of the seven bird species in Table 6: Golden Eagle (Aquila chrysaetos, state fully protected), Burrowing Owl (Athene cunicularia, Species of Special Concern), white- tailed kite (Elanus lecurus, state fully protected), Bald Eagle (Haliaeetus leucocephalus, state fully protected and endangered), Loggerhead Shrike (Lanius ludovicianus, Species of Special Concern), and Yellow Warbler (Setophaga petechia, Species of Special Concern). The invertebrate, Crotch bumble bee, (Bombus crotchii, state candidate, threatened) is oak - associated.

Two of the six mammals identified in Table 6 as potentially occurring at the site are oak - dependent: western mastiff bat (Eumops perotis californicus, Species of Special Concern) and American badger (Taxidea taxus, Species of Special Concern). Additionally, mountain lion (Puma concolor, state candidate, threatened), discussed later in the report as potentially occurring at the site, is also oak -dependent.

Three of the six reptiles in Table 6 are oak -dependent: California glossy snake (Arizona elegans occidentalis, Species of Special Concern), red diamondback rattlesnake (Crotalus Tuber, Species of Special Concern), and Blainville's horned lizard (Phrynosoma blainvillii, Species of Special Concern).

Mitigation requirements are vague and the provisions for encroachment on oak root protection zones will harm oaks and biological communities dependent upon them. The scope and scale of impacts to oaks by the proposed project are not detailed. Instead, the environmental documentation simply refers to the city's oak protections, indicating that the proposed project will adhere to the protections and allow disturbance of up to 50 percent 2 08/25/2025 City Council Agenda
774

encroachment within the dripline of trees to be handled via administrative processing rather than through review by the Planning Commission. The root protection area, which is half again as large as the area from the trunk to the dripline of an oak, is critical to oak tree health. The proposed allowance of such incursion will harm oaks. Care of California's Native Oaks provides additional information.

The city's oak protections do not provide information on how mitigation is calculated, but the provision that a violation of the ordinance may result in a requirement for "the donation of or by replanting two or more oak trees of reasonable equivalent size and value to the tree damaged or removed" suggests that a lower replacement rate would be required for those who comply with the regulations. This will result in net loss of oaks in the project site due to mortality of replacement trees as well as diminished habitat function because of the disturbance of the environment.

When oaks are removed, they should be replaced at a level that will offset the lost biomass and canopy of the removed trees and the substantial temporal loss of growth habitat structure and diversity. Trees planted need to be spaced in a manner that promotes their long-term growth and restores the area that has been damaged.

PR-5.7 Mitigation Program, of the General Plan states: "Develop, periodically update, and implement a community -wide mitigation program to preserve and enhance sensitive biological resources and associated habitats in Yucaipa." A question that arose in the preparation of this letter caused CWF/CO to learn that the city's Oak Tree Preservation Ordinance was written almost 30 years ago. Since that time threats to oaks have grown and best management practices, including understanding that the root protection area should not be disturbed, have developed. As part of the update, the City of Yucaipa should enhance oak protections and do everything in its power to protect its arboreal heritage.

Thank you for your consideration of our comments. It is unfortunate that a project with the word "oaks" in the title is an oak -removal project.

Sincerely,
Janet Cobb
Executive Officer, California Wildlife Foundation
[email protected]
at_i,o__T/447),(-0,D
Angela Moskow
California Oaks Program Director
[email protected]
cc: Chris Mann, City Manager, City of Yucaipa, [email protected] Benjamin Matlock, Deputy Director of Community Development/City Planner, City of Yucaipa, [email protected]
Susan Phillips, Associate Dean, Pitzer College, and Director, Robert Redford Conservancy for Southern California Sustainability, [email protected] Mary Ann Ruiz, Chair, San Gorgonio Sierra Club Chapter
3 08/25/2025 City Council Agenda
775

From: carol edwards
To: Public Comment
Subject: re: Freeway Corridor Specific Plan/Pacific Oaks Commerce Center Date: Friday, September 20, 2024 8:16:08 AM
September 20, 2024
Yucaipa City Council Members:

I'm beyond dismayed to hear of the above mentioned proposal being pushed for a vote by the Council members of Yucaipa. If I wanted to live in Orange County I would move there. Judging by the growth in Yucaipa over the last decade it looks as though people are moving to Yucaipa to enjoy the lifestyle of a semi -rural area and to get away from the warehouses, the congestion and the pollution but then they expect all the amenities that go with an urban lifestyle —you can't have it both ways.

So my request to you council members is this —please don't add to the congestion, pollution, and the wear - and -tear on our community by passing this proposal and allowing these projects to swamp our community.

The freeway and the surface streets in Yucaipa are already overwhelmed with traffic; even though there are constant street repairs going on, it seems the city crews can't keep up with maintenance on our existing streets; it's almost impossible to get across or thru town (5 - 10 miles) during peak traffic periods in less than 20 - 25 minutes; the twice daily traffic -crush around all the schools is unbelievable; and the on -going building of new businesses and new homes which bring in new people with their vehicles to pollute and congest our rural lifestyles. I cannot begin to imagine why are you entertaining the idea of building more homes and traffic inducing warehouses in this area. Please stop.

So what's our area going to look like with additional trucks coming and going all day and all night? The Live Oak Canyon/Outer Highway 10 intersection is fairly new but was apparently poorly planned because large trucks have difficulty making turns without almost taking out vehicles in other lanes. I've had to back up numerous times to allow pushy truck drivers the room to make the turn to get where they want to go. I'm not sure Live Oak Canyon Road can be made wide enough to allow a constant stream of truck and trailer rigs to navigate safely. The Yucaipa Planning Commission has already denied this warehouse proposal so why are you revisiting it?
Every year when fall rolls around and I see the Pumpkin Factory gearing up for another banner year I get depressed. This business has negatively impacted the I-10 freeway, Outer Highway 10, Live Oak Canyon, as well as the 16th St & 17th St areas for years. The byways around this business grind to a halt and anything resembling egress and ingress come to a dead halt —the freeway offramp at Live Oak Canyon literally comes to dead stop and the line to get off is at least a mile long and is often backed up beyond Yucaipa Blvd offramp, just ask anybody who has tried to enter Yucaipa from Live Oak Canyon during pumpkin season. We have been trapped in our area because Outer Highway is in gridlock with vehicles occasionally double parked and hundreds of pedestrians walking on the street [effective 2023, thanks to the Sheriff's Department for blocking off most of Outer Highway 10 so the people who live or work here can go about their lives with a semblance of normality]. I can only imagine the loss of life if the Pumpkin Factory was open for business and a major fire started in the canyons where the warehouses are proposed to be built. There would literally be NO WHERE for the Pumpkin Factory customers to go —gridlock and panic would kill thousands and that would be on the owners of the Pumpkin Factory and YOU, as a governing body of the City of Yucaipa, that allowed this proposal to go through.

And then there are the wild creatures which inhabit this entire area: numerous coyotes, mountain lions, hawks of all kinds, weasels, snakes, all which help keep the rodent populations in check, and 40+ years ago (before all the developments and the Pumpkin Factory), badgers and deer. The presence of so many humans and all their pollution inhibit these wild animals from living in this area. 08/25/2025 City Council Agenda
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So please consider voting NO to these proposals and maintaining our beautiful views of the natural canyons, mesas and ravines (already damaged by that abomination/warehouse built on the Yucaipa side of County Line Rd), helping preserve the wildlife in this area and allowing the current residents the opportunity to live their lives in peace without turning into another Orange County, City of Calimesa, City of Beaumont, City of Banning or City of Ontario.

Thank you for your time and consideration on this matter.

Carol Edwards
08/25/2025 City Council Agenda
777

From: Helen Waitz
To: Public Comment
Cc: Kim J Metzler, CMC, CPM
Subject: Live Oak Canyon Warehouse Proposal/Development Date: Friday, September 20, 2024 12:40:45 PM
I am greatly against the proposal to build a warehouse and development in Live Oak Canyon . It would destroy the charm and wildlife of the area that we have enjoyed since 1957.

Helen Waitz
Sent from my iPhone
08/25/2025 City Council Agenda
778

From: Walter Noon III
To: Public Comment
Cc: Kim J Metzler, CMC, CPM; Tim Watson MD
Subject: Pacific Oaks Commerce Center and Freeway Corridor Date: Saturday, September 21, 2024 2:52:24 PM
I am writing to express my strong opposition to the proposed Pacific Oaks Commerce Center and Freeway Corridor Specific Plan update, which would add over 5 million square feet of development to the Live Oak Canyon area.

This project poses serious threats to public health, quality of life, and the environment.

This development would irreparably harm the rural nature of the area, disrupting views, increasing noise and light pollution, and destroying critical wildlife habitats, including those for endangered species like the Southern California mountain lion.

Furthermore, this development borders protected areas such as the Herngt 'Aki' Preserve, which offer rare opportunities to experience wild nature.

I urge the council to prioritize the preservation of Live Oak Canyon and protect this beautiful habitat for so many.

Sincerely,
Walt Noon
08/25/2025 City Council Agenda
779

From: Mary Ann A Baker
To: Public Comment
Cc: Kim J Metzler, CMC, CPM
Subject: The Dangerous Warehouse Proposal
Date: Saturday, September 21, 2024 2:58:52 PM
My husband Vaughan Shoemaker and 1 moved to Live Oak Canyon in 1988. We were both physiologists and professors at UCR. We loved to hike and ride horses in the hills behind our home and planned to preserve our land for animal habitats and riding/hiking trails.

Vaughan died in 1999 and 1 have continued to live here in the Canyon after retiring from the university. Despite the motorcycle traffic, the hills bordering the canyon provide a great environment for native animals and a quiet retreat for human hikers. If the proposed warehouses and housing developments are approved, vehicle traffic and noise in the canyon will destroy the peace and beauty of this special place and will have a serious negative impact on the native animals.

Dr. Mary Ann Baker
08/25/2025 City Council Agenda
780

From: joanne lessard
To: Public Comment; Kim J Metzler, CMC, CPM
Subject: Freeway Corridor Specific Plan Update and Pacific Oaks Commerce Center Date: Saturday, September 21, 2024 10:09:53 PM
Attachments: Highvays and wildlife.docx
Honorable Council Members and City Staff,
Regarding Agenda Item #21. SUBJECT: FREEWAY CORRIDOR SPECIFIC PLAN UPDATE (CASE NO. 24- 044/GPA/SPA) & PACIFIC OAKS COMMERCE CENTER
I would like to make the following proposal:

Live Oak Canyon is obviously a wildlife corridor as proven by recent videos of mountain lion and bear in the area, and as witnessed by neighbors who also see deer, coyote and bobcat.

Because of recent warehouse, housing and commercial development in Calimesa and Beaumont, Live Oak Canyon is now a more important corridor for wildlife than it was previously. It is probably the only wildlife corridor remaining between the San Bernardino Mountains and the natural open space areas and mountains of Riverside and San Diego Counties. It is even more important because of the recent fires in the mountains. It is threatened by proposed warehouse and commercial development
Funds are available to remediate this situation through the Department of Fish and Wildlife and the Department of Transportation. We thus request these funds to be paid the Palmers and Robinsons if they so wish, in conjunction with conservation easements to a local conservancy or group of conservancies such as the Wildlands Conservancy, Redlands Conservancy, Two Canyons Conservancy.

Please see the attachment. I would like to draw your attention in particular to the following sections:
(E) Areas where wildlife is known to cross more frequently than other nearby areas, including riparian corridors. canyon bottoms. ridges. or open -space corridors. (G) Areas where habitat of adjacent lands is currently in good condition. (I) Linkages that could facilitate range shifts due to climate change, including areas that connect lower to higher elevations
(B) The ease or capability of facilitating necessary land acquisitions to provide an ecological buffer. (3) Whether the implementation of wildlife passage features would do any of the following:
(A) Substantially increase climate -resilient wildlife connectivity. (C) Contribute to the survival or recovery of any species or population of a species, including, but not limited to:
(i) Species listed as a threatened species or endangered species pursuant to the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.).
08/25/2025 City Council Agenda
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(ii) Species listed as a candidate species, threatened species, or end (c) The department may use compensatory mitigation credits approved pursuant to Section 1957 of the Fish and Game Code to satisfy the requirements of this section if the Department of Fish and Wildlife concurs with the use of those credits.
(b) Upon appropriation of funds by the Legislature, the department shall develop a program of projects that support the remediation and improvement of wildlife connectivity across transportation systems, including the state highway system, in accordance with this section. (5) Implementing the Transportation Wildlife Connectivity Remediation Program pursuant to Section 158.4.

Joanne Lessard 31543 Highview Drive, Redlands, CA 92373 phone 909 499n3157 08/25/2025 City Council Agenda
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Subject: FW: Yucaipa project violates this Street and Highway Code

STREETS AND HIGHWAYS CODE - SHC
DIVISION 1. STATE HIGHWAYS [50 - 897]
( Division 1 enacted by Stats. 1935, Ch. 29. )
CHAPTER 1. Administration [50 - 227.1]
( Chapter 1 enacted by Stats. 1935, Ch. 29. )
ARTICLE 3.8. Barriers to Wildlife Movement [158- 158.5] (Article 3.8 added by Stats. 2022, Ch. 964, Sec. 2. )
158.

For purposes of this article, the following definitions apply:
(a) "Connectivity area" includes any of the following:
(1) An area identified by any federal or state agency that meets the needs for a special status species pursuant to the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.) or the California Endangered Species Act (Chapter 1.5 (commencing with Section 2050) of Division 3 of the Fish and Game Code). (2) An area identified by the Department of Fish and Wildlife as important for ecological connectivity for fish or wildlife between natural landscape areas based on consideration of the following factors:
(A) Important landscape linkages identified in regional connectivity studies or habitat protection plans.
(B) Known ungulate migration routes, including those identified in response to the federal Secretarial Order 3362, issued on February 9, 2018, by the federal Secretary of the Interior, and any subsequent updates to the order.
(C) Important movement corridors for sensitive species according to species -specific studies, genetic studies, or published recovery plans.
(D) Known areas of high wildlife mortality due to transportation infrastructure. (E) Areas where wildlife is known to cross more frequently than other nearby areas, including riparian corridors, canyon bottoms, ridges, or open-spacecorridors. (F) Areas where wildlife approach and refuse to cross highways, as identified by wildlife behavior data.
(G) Areas where habitat of adjacent lands is currently in good condition. (H) Highways with identified barriers where lands adjacent to all approaches to the highway have conservation protections.
(I) Linkages that could facilitate range shifts due to climate change, including areas that connect lower to higher elevations or connect to northern habitats. (3) An area identified by the department with known or potential transportation barriers to wildlife connectivity, as determined by the department. (b) "Fish" means fish as defined in Section 45 of the Fish and Game Code. (c) "Natural landscape area" means a natural, intact habitat area with high ecological integrity that provides core habitat for wildlife and supports native biodiversity. 08/25/2025 City Council Agenda
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(d) "Permeability" means the ability of a feature, improvement, or facility to provide for passage of wildlife and improve connectivity to natural landscape areas or other habitat. (e) "Wildlife" means wildlife as defined in Section 89.5 of the Fish and Game Code. (f) "Wildlife passage features" means culverts, underpasses, overpasses, bridges, directional fencing, barrier breaks, wildlife monitoring devices or detection systems, elevated highway segments, or other features, supported by a functional or potentially functional ecological buffer of habitat on multiple approaches to a highway that encourage use of the feature and are designed to be managed or restored using the best available science to improve the ability of wildlife to safely traverse transportation infrastructure. (Added by Stets. 2022, Ch. 964, Sec. 2. (AB 2344) Effective January 1, 2023.) 158.1.
(a) It is the intent of the Legislature that the department review the full extent of the state highway system, as currently maintained, in consultation with the Department of Fish and Wildlife and with opportunities for the public to provide data input for consideration, to develop a comprehensive approach to address wildlife connectivity needs throughout the state with the goal of implementing measures that protect, conserve, and improve the state's unique wildlife, landscapes, and natural resources. (b) In consultation with the Department of Fish and Wildlife and other appropriate agencies, the department shall establish an inventory of connectivity needs on the state highway system where the implementation of wildlife passage features could reduce wildlife -vehicle collisions or enhance wildlife connectivity. In establishing the inventory of connectivity needs, the department, in consultation with the Department of Fish and Wildlife and other appropriate agencies, shall consider all of the following factors:
(1) The ability of wildlife passage features to enhance connectivity and permeability within a connectivity area or natural landscape area.
(2) The logistics surrounding implementation of wildlife passage features, including, but not limited to, all of the following:
(A) The cost effectiveness of implementing wildlife passage features through associated transportation projects.
(B) The ease or capability of facilitating necessary land acquisitions to provide an ecological buffer.
(C) Public support for associated transportation projects. (D) The ability of wildlife passage features to facilitate continued functional wildlife movement or improved public safety outcomes into the future. (3) Whether the implementation of wildlife passage features would do any of the following:
(A) Substantially increase climate -resilient wildlife connectivity. (B) Substantially decrease the likelihood of collisions between wildlife and vehicles. (C) Contribute to the survival or recovery of any species or population of a species, including, but not limited to:
(i) Species listed as a threatened species or endangered species pursuant to the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.). 08/25/2025 City Council Agenda
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(ii) Species listed as a candidate species, threatened species, or endangered species pursuant to the California Endangered Species Act (Chapter 1.5 (commencing with Section 2050) of Division 3 of the Fish and Game Code).
(iii) Species at risk from highways and habitat fragmentation. (4) Any other relevant considerations, as determined by the department. (c) No later than July 1, 2024, the department shall develop and publish, on its internet website, the inventory and a list of funded transportation projects with wildlife passage features that address wildlife connectivity needs. The department shall update the inventory and the project list biennially, at a minimum, and may update the inventory or the list more often, as needed.
(Added by Stets. 2022, Ch. 964, Sec. 2. (AB 2344) Effective January 1, 2023.) 158.2.
(a) (1) Except as provided in subdivision (b), for any project on the state highway system located in a connectivity area beginning the project initiation phase on or after July 1, 2025, that adds a traffic lane or that has the potential to significantly impair wildlife connectivity for target species in the connectivity area based on criteria developed in collaboration with the Department of Fish and Wildlife, the department shall perform an assessment, in consultation with the Department of Fish and Wildlife, before commencing project design and continuing through the development of the project and into implementation, to identify potential wildlife connectivity barriers and any needs for improved permeability. (2) As part of the assessment, the department shall consider factors affecting wildlife connectivity that provide scalable solutions for all defined species needs, as determined by the department, in consultation with the Department of Fish and Wildlife. (3) The assessment may incorporate relevant guidelines and standards in applicable habitat conservation plans approved pursuant to Section 1539 of Title 16 of the United States Code and natural community conservation plans approved pursuant to Chapter 10 (commencing with Section 2800) of Division 3 of the Fish and Game Code. (4) The department shall submit the assessment to the Department of Fish and Wildlife and, if any structural barrier to wildlife connectivity exists or will be added by the project for target species in the connectivity area based on criteria developed in collaboration with the Department of Fish and Wildlife, the implementing agency shall remediate barriers to wildlife connectivity in conjunction with the project. A project subject to this requirement may incorporate relevant assessments, guidelines, and standards in applicable habitat conservation plans approved pursuant to Section 1539 of Title 16 of the United States Code and natural community conservation plans approved pursuant to Chapter 10 (commencing with Section 2800) of Division 3 of the California Fish and Game Code. (5) The department shall publish on its internet website a list of all of the transportation projects that require remediation pursuant to paragraph (4) and information regarding whether wildlife passage features are included in those projects or if mitigation credits are applied to the project pursuant to subdivision (c). The department shall update the project list biennially, at a minimum, and may update the list more often, as needed. (b) The requirements of subdivision (a) shall apply to the following types of projects only where feasible, practicable, and cost effective, as determined by the department:
08/25/2025 City Council Agenda
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(1) Emergency projects.
(2) Safety -focused projects that meet the criteria provided by the State Highway System Management Plan, that would reduce fatal and serious injury collisions on the state highway system, that are included in the highway maintenance program or the State Highway Operation and Protection Program, and that do not add a passing lane, turning lane, or auxiliary lane exceeding one mile in length.
(c) The department may use compensatory mitigation credits approved pursuant to Section 1957 of the Fish and Game Code to satisfy the requirements of this section if the Department of Fish and Wildlife concurs with the use of those credits. (Added by Stats. 2022, Ch. 964, Sec. 2. (AB 2344) Effective January 1, 2023.) 158.3.

On or before July 1, 2025, the department shall update appropriate design guidance, including the Highway Design Manual, to incorporate design concepts for wildlife passage features and related standard plans and specifications as appropriate. (Added by Stats. 2022, Ch. 964, Sec. 2. (AB 2344) Effective January 1, 2023.) 158.4.
(a) The Transportation Wildlife Connectivity Remediation Program is hereby established to be administered by the department, in consultation with the Department of Fish and Wildlife, for the purposes of improving wildlife connectivity across transportation systems in connectivity areas.
(b) Upon appropriation of funds by the Legislature, the department shall develop a program of projects that support the remediation and improvement of wildlife connectivity across transportation systems, including the state highway system, in accordance with this section.
(c) (1) The department, in concurrence with the Department of Fish and Wildlife, shall develop guidelines for the implementation of the program, following one or more public workshops and an opportunity for the public to provide written comments. The guidelines for the program are exempt from the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code). (2) The guidelines for the program shall establish selection criteria including the factors set forth in subdivision (b) of Section 158.1 with consideration given to funding wildlife connectivity improvements as standalone projects or funding those improvements on the department's planned projects, including, but not limited to, maintenance and operations projects, to achieve efficiencies in addressing wildlife connectivity needs identified pursuant to subdivision (d).
(d) A project funded by the program shall address a wildlife connectivity need identified in the inventory of connectivity needs for the state highway system established pursuant to Section 158.1 or another documented wildlife connectivity need across transportation infrastructure in a connectivity area.
(e) A project funded by this program may include, but is not limited to, any of the following:
(1) The placement of exclusion and directional fencing. 08/25/2025 City Council Agenda
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(2) The use of advanced technology to improve the safety of wildlife crossing transportation infrastructure.
(3) The construction of wildlife -friendly underpasses, overpasses, culverts, and elevated sections of road in key wildlife connectivity areas.
(f) The department may receive compensatory mitigation credits pursuant to Section 1957 of the Fish and Game Code for the implementation of a project in this program if the Department of Fish and Wildlife concurs with the creation of those credits. (Added by Stets. 2022, Ch. 964, Sec. 2. (AB 2344) Effective January 1, 2023.) 158.5.
(a) The department shall submit a report to the relevant policy committees and the budget committees of the Legislature, in compliance with Section 9795 of the Government Code, on or before July 1, 2028, on the implementation of this article. The report shall include recommendations for this article and describe the status of the department's progress in doing all of the following:
(1) Developing an inventory of wildlife connectivity needs on the state highway system pursuant to Section 158.1.
(2) Assessing transportation projects in connectivity areas for wildlife connectivity impacts pursuant to Section 158.2.
(3) Implementing wildlife connectivity improvements on transportation projects pursuant to Section 158.2.
(4) Updating appropriate design guidance, including the Highway Design Manual, to incorporate design concepts for wildlife passage features and related standard plans and specifications pursuant to Section 158.3.
(5) Implementing the Transportation Wildlife Connectivity Remediation Program pursuant to Section 158.4.
(6) Funding wildlife connectivity improvements, including total funding amount by fund source for these improvements and a list of improvements that have been funded since the enactment of this article.
(b) The report shall also include information regarding both of the following:
(1) A description of the consultation and concurrence process between the department, the Department of Fish and Wildlife, and other appropriate entities. (2) Significant accomplishments or obstacles to meeting the objectives of the article. (c) Pursuant to Section 10231.5 of the Government Code, this section shall become inoperative on July 1, 2032, and, as of January 1, 2033, is repealed. (Added by Stets. 2022, Ch. 964, Sec. 2. (AB 2344) Effective January 1, 2023. Inoperative July 1, 2032, by its own provisions. Repealed as of January 1, 2033, by its own provisions.) 08/25/2025 City Council Agenda
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From: Kristie Renee" Sepulveda-Burchit
To: Kim J Metzler, CMC, CPM
Cc: Public Comment; Educate. Advocate.

Subject: City Council Public Comment re: No warehouses
Date: Sunday, September 22, 2024 11:43:28 AM
My family enjoys walking in the preserved park areas in the city of Redlands. We appreciate the open space and room to roam. We have a son with special needs and there are limited places we can safely take him to walk and roam. Additionally we have a monthly walking group for families with special needs through our nonprofit organization Educate. Advocate. and we frequently take families to the parks such as these in Redlands. These parks are vital for the well-being of our families. We ask that you oppose the housing development and keep these lands open for public enjoyment.

We ask that you do not ruin Life Oak Canyon. We do not need further traffic, increased runoff into the riverbed that is eroding, further air pollution. We need our wildlife and wild open spaces to remain untouched and free to roam!
During the shutdown/lockdown our family and our families were very limited to where they could go and enjoy open space and room to roam. Lands preserved such as these were a lifeline to our family and so many we serve so I hope you will consider this.

Thank you.

Kristie Sepulveda-Burchit, Aaron Burchit and Aidan Burchit CC [email protected]
Educate. Advocate.
http://educateadvocateca.con
08/25/2025 City Council Agenda
788

From: Jim and Bonnie Comazzi
To: Public Comment
Subject: Proposed Pacific Oaks Commerce Center
Date: Sunday, September 22, 2024 12:19:41 PM
Attachments: September 22.docx
September 22, 2024
PUBLIC COMMENTS @ YUCAIPA.GOV
Yucaipa City Council
Re: Pacific Oaks Commerce Center
Dear Council Members:

We oppose the Pacific Oaks Commerce Center project proposed for the junction of 1-10 and Live Oak Canyon Road. As local residents living in the environment surrounding the proposed project our family will have decreased quality of life by this commercial project in a rural residential area. It will also affect animal habitat.

We are daily in contact with automobiles rushing along the Live Oak Canyon Road at an unsafe speed, cutting corners and forcing bicyclists into the ditch or the hospital ER. It has happened to our family and friends. The traffic is already congested, with long delays at various times of the day, and there are many dangerous multicar accidents including accidents with the trains at the Live Oak Canyon/San Timoteo Canyon Road Intersection. Increasing traffic flow would worsen these problems making an already awful situation worse.

It will destroy habitat which includes other documented wild species.

The warehouse trucks add air pollution to the already marginal air quality of the area. This is obvious to all of us that have spent time around the various warehouses in other areas of the county while walking or bicycling.

The warehousing will result in truck noise and disruption all hours of the day and night, which is inappropriate for this rural residential area. It was not zoned for this kind of project.

In Summary:

1. Trucks will significantly use narrow, curvy, 2 lane, Live Oak Canyon and San Timoteo Road to travel to southern areas of the County and bypass bumper to bumper 1-10. It is already lethal!

2. The 1-10 freeway will be further impacted with worsened slowing and congestion from increased traffic due to the incline of eastbound 1-10 freeway with more resulting accidents including train/auto accidents.
08/25/2025 City Council Agenda
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3. Wildlife will suffer. Pristine habitat will be lost. Air quality, already poor, will deteriorate.

4. Accidents will increase. More injuries/deaths.

5. Inland Empire warehousing and storage jobs are shrinking. That will cause unemployment.

James Comazzi MD
Bonnie Comazzi BSN, MFT
08/25/2025 City Council Agenda
790

September 22, 2024
PUBLIC COMMENTS @ YUCAIPA.GOV
Yucaipa City Council
Re: Pacific Oaks Commerce Center
Dear Council Members:

We are daily in contact with automobiles rushing along the Live Oak Canyon Road at an unsafe speed, cuffing corners and forcing bicyclists into the ditch or the hospital ER. It has happened to our family and friends. The traffic is already congested, with long delays at various times of the day, and there are many dangerous multicar accidents including accidents with the trains at the Live Oak Canyon/San Timoteo Canyon Road Intersection. Increasing traffic flow would worsen these problems making an already awful situation worse.

It will destroy habitat which includes other documented wild species.

The warehousing will result in truck noise and disruption all hours of the day and night, which is inappropriate for this rural residential area. It was not zoned for this kind of project.

In Summary:

1. Trucks will significantly use narrow, curvy, 2 lane, Live Oak Canyon and San Timoteo Road to travel to southern areas of the County and bypass bumper to bumper 1-10. It is already lethal!

3. Wildlife will suffer. Pristine habitat will be lost. Air quality, already poor, will deteriorate.

4. Accidents will increase. More injuries/deaths.

5. Inland Empire warehousing and storage jobs are shrinking. That will cause unemployment.

James Comazzi MD
Bonnie Comazzi BSN, MFT
08/25/2025 City Council Agenda
791

From: 1a
To: Kim 3 Metzler. CMC CPM
Cc: Mifven Norman (EDfla 1EBIke oral. public commegt
Subject: Re: Oppose any warehouses or distribution center projects in live Oak Canyon -1-10 Corridor specific plan is out of date.

Date: Sunday, September 22, 2024 2:18:44 PM
Attachments: T8za1oorndnnlmO0
Honorable Councilpersons of Yucaipa
I am writing you again to request that you deny this proposed warehouse project with over 5 million square feet of hardscape in Live Oak Canyon. In addition to the reasons I previously submitted prior to the August council meeting, I would like to call your attention to some additional issues which should compel you to agree with your planning commission and deny this project. First I would like to call your attention to a map below which overlays the proposed warehouses upon the current approved Freeway Corridor Specific Plan (FCSP) from 2008. Below the image I will list some major impacts this project creates from its incompatible use (industrial vs. open space and housing), wildfire risks, storm water pollution, to endangered Southern California Mountain Lion wildlife corridor impacts, to immense congestion added to Live Oak Canyon road (a historic, rural 2 lane roadway), and massive negative air quality impacts in a non -attainment area plagued by smog for over 60 years!
CS AC rem—,ss
.

L
General Plan Land Uses
R-1 - Rural Ling
R-2 - Single Residential
R-4 Single Resdential
_ R-8- Single or Multiple Residential
▪ R-24 - Multiple Residential
— PUB- Public Faunas
▪ BP- Business Park
CR- Regional Commercial
▪ 0s2-Open Space
MO PC
113
Existing FCSP Land Use Map
Your planning commission was absolutely correct in their denial of this project, please support them. Here are the details from the list above:

1. INCOMPATIBLE USE: The existing FCSP land use map specifies this area is to be open protected open space and low density residential housing. Warehouses are completely incompatible with this use designation. Changing the FCSP on the same night that an incompatible land uses is proposed for approval runs counter to the will of your constituents and the planning process.

2. WILDFIRE RISK: There is only one four lane arterial route exiting to a two lane rural roadway. This creates one way out of this project which is said to eventually employ 1400 people and puts those people's lives at risk should one of many frequent wildland fires erupt within San Timoteo or Live Oak Canyon. There is no way to effectively evacuate that many people onto Live Oak Canyon Road if the fire comes up from the canyon. Recent extreme heat events and accompanying wildfires place this risk at top of mind for everyone.

3. STORMWATER FLOWS and POLLUTION: The stormwater flows from over 5 million square feet of both asphalt (storing thousands of motor vehicles and diesel trucks) and 2 million square feet of warehouse rooftop as well as the 4 lane asphalt arterial cul-de-sac will create immense stormwater flows which will deposit pollutants and additional stormwater in a creek that already has closed Live Oak Canyon road from canyon wall erosion. Live Oak Canyon Road is already threatened in Redlands from increases in stormwater flows. Presently the land is permeable in its entirety and absorbs winter rains exceptionally well. Please keep it that way!

4. ENDANGERED SOUTHERN CALIFORNIA MOUNTAIN LION: Neither Freeway Corridor Specific Plan nor the proposed warehouse project addresses the fact that Live Oak Canyon is a major wildlife corridor for California Mountain Lions and as recently as late August these Mountain Lions have been photographed in the canyonlands area adjacent to Redlands' Hemgt 'Aki' Preserve. Mountain Lion footprints have been found in Yucaipa Creek and within the last year, Redlands Conservancy has closed the Sahatapa Trail because of multiple sightings of mountain lions by hikers. A bone cache has also been found less than 1000 feet from the warehouse project. This land south of I-10 serves a vital purpose as a refuge for mountain lions when other regions are on fire.

5. TRAFFIC IMPACTS: I-10 is already bumper to bumper gridlock most evenings and Live Oak Canyon is a rural road serving farms and ranches and needs to remain that way. This warehouse project's 356 loading docks, 1,058 Semi Truck Parking Stalls (2) 1 million square foot warehouses and 986 car parking lots with a new 4 lane "commercial collector highway" all dumping onto a 2 lane, rural Live Oak Canyon Road. This project is a cul-de-sac filled with 1000 semis and almost 1000 cars with workers too. There is no way that could be evacuated in an emergency, and would only further gridlock Outer Hwy 10, Yucaipa Blvd, I-10 and Live Oak Canyon Road for hours at a time every time there is a shift change.

6. SMOG: Cities throughout the Inland Empire have placed moratoriums on warehouse projects and Banning has recently banned them. The idling emissions from thousands of semis waiting to get in and out of this cul-de-sac project will add unacceptable air pollution to an area which has some of the worst air quality in the nation! For this reason alone, I wish Redlands and the county doughnut hole had never been deforested for the sake of warehouses and would hope that Yucaipa has the wisdom not to follow this misguided path.

Yucaipa Councilpersons you have the responsibility to reject this proposal and we are all counting on you to agree with your planning commission and reject this warehouse project.

Thank you.

Jonathan Baty
member: Friends of Live Oak Canyon
On 8/24/24 2:12 PM, J B wrote:

Staff and Honorable Councilpersons of Yucaipa:

I am writing you to express my steadfast opposition of any construction projects that would adversely affect the rural nature of Live Oak Canyon. In this case, a 08/25/2025 City Council Agenda
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distribution center just does not make sense! There are many known cultural resource sites in the Canyon within both Redlands and Yucaipa boundaries. I presently volunteer as co -manager of the Herngt 'Aki' Preserve in Redlands and would greatly appreciate if Yucaipa would work collaboratively with Redlands to preserve open space and the rural character of lands South of 1-10 in Live Oak Canyon and what is known as the Serengeti in the cycling community. As a cyclist I can attest to the fact that Live Oak Canyon road cannot handle any additional traffic, and placing a massive warehouse at the mouth of the canyon would adversely affect traffic flows in the canyon in ways that are unsustainable. As a resident of Redlands I can tell you that de-foresting our citrus groves to put up warehouses in the doughnut hole was probably the worst decision city and county officials have made in the history of Redlands. The traffic, congestion, pollution, road damage, minimal job creation etc. all go unmitigated and burden the Inland Empire with ever worsening pollution and congestion. Yucaipa has done a spectacular job revitalizing their historic downtown and preserving the Crafton Hills in collaboration with Redlands and the county. I invite the city of Yucaipa to work with Redlands and develop an extension of Hunt 'AU Preserve in adjacent lands within Yucaipa. This will preserve the character of Live Oak Canyon and provide Yucaipa residents living South of Crafton Hills access to a network of hiking, cycling and equestrian trails that connect us all to our history.

Thank you.

Jonathan Baty
member: Friends of Live Oak Canyon
P.S. updated Yucaipa public comment email to use correct email address for public comments, email on the notice is incorrect. 08/25/2025 City Council Agenda
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From: Amanda Frye
To: Public Comment; Kim J Metzler, CMC. CPM; [email protected]; [email protected]; Sentinel Sbc; [email protected]; [email protected] Subject: 9/23/2024 Specific plan update and Warehouse commerce center agenda items.

Date: Sunday, September 22, 2024 7:40:22 PM
Attachments: Yucaipa Area, California U.S. Geological Sury y_(1).html Yucaipa Bad Specific Plan.pdf
2023-01-24 GFL Comments to Planning Commission.pdf
Live Oak Canyon Road created.pdf
Live Canyon road and no bridge.pdf
When I looked at the previous email sent there appeared to be some issues with the formatting. The following should be a correct copy with a pdf attachment of the letter and files.

Amanda Frye
Redlands, CA 92373
Yucaipa City Council
Yucaipa, California
September 22, 2024
Re: Yucaipa Freeway Corridor Specific Plan and Update/ Proposed Commerce Center plan Dear City Council Members and Staff:

Please vote against Freeway Corridor specific plan/update and Commerce Center filled with warehouses that converts agricultural lands to non -agriculture uses that negatively impacts the environment and the entire region. There are many flaws and this is a horrific plans for Yucaipa, the region and California.

1. Federal requirements have failed to be considered. Since this project entails changes to Federal freeway transportation interchanges then all Federal requirements would need to be considered including National Environmental Policy Act (NEPA) and EPA requirements. Since Federal Freeway issues with I-10 NEPA will be required https://dot.ca gov/programs/environmental-analysis/environmental-management/neroa-ceqa which are not the same as California Environmental Quality Act (CEQA) Public Resources Code § 21000-21189 California Code of Regulations § 15000-15387 and (Public Resources Code Section 21095).

2. All CEQA laws and requirements will never be met with this bad plan and there is no mitigation for this plan, update or proposed commerce center with warehouses.

3. The Division of Land Resource Protection (DLRP) reviews, comments, and provides technical assistance to state and federal agencies, local jurisdictions, and the public regarding the multiple facets of the CEQA process. Where is this in Yucaipa's proposal?

4. Furthermore, Federal Transportation Department wildlife considerations are not made. https://www.fhwa.dot.gov/clas/ctip/wildlife_crossing structures/ch 2.aspx.

5. Live Oak Canyon Road is a Historic and Scenic Road dating back to 1913. The Yucaipa Freeway Specific plan fails to consider the historic and scenic qualities of Live Oak Canyon Road and the horrific negative impact this will have on the historic road site.

6. Warehouse demand is saturated and documented as shrinking according to recent Wall Street Journal reports. https://www.wsj . com/articles/warehousing-demand-is-starting-to-shrink-19c5feaa2 .

7. Live Oak Canyon Creek is a waterway of extreme importance especially during the rainy season. Warehouses and Yucaipa's current and proposed specific plan will cause major damage to creek and downstream users including flooding and erosion.

There appears to be no filings with the Califomia Water Board nor Army Corp of Engineers. The proposed built structures will most likely alter the natural water course increasing risk of flooding and debris flow downstream.

8. USGS shows several earthquake faults that would appear to impact the project area. https://www.usgs.gov/media/images/yucaipa-area-california . (See Attachment)

9. Regional planning and land use fails to be considered in this plan. The Rural communities of Live Oak Canyon and land use are integral to two counties (Riverside County and San Bernardino County). The project borders Redlands Open Space and Residential lot which are required to be considered. There is no mitigation for altering the environment and rural nature of 08/25/2025 City Council Agenda
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surrounding communities. There appears to be no regional climate change impacts pursuant to PRC 71352.

10. The proposed land in this specific plan entails known and documented Native American sites.

11. Climate Change impacts of converting natural agriculture land to this built structures have not been considered. Nor has there been the consideration of climate change on fauna and flora and surrounding environments been considered. Failed to follow PUBLIC RESOURCES CODE - PRC 71154

12. Climate Change vulnerability and major impact have failed to be considered and can not be mitigated as environment is changed from rural environment plant, grass and tree rich environment to paved urban heat sink. There appears to be no consideration for the required wildlife climate change impacts. https://wildlife.ca.gov/Data/Analysis/Climate

13. Water use change from agriculture to urban does not appear reported. There is no mitigation.

14. This area is a connector for wildlife and wildlife corridors from the Mountain to Valley and neighboring Redlands and Riverside County Reserves and parklands. This wildlife corridor is extremely important including endangered and threatened fauna and flora such as Monarch butterflies and Mountain lions and other native bees and more.

15. Negative economic factors have failed to be considered as destroying agriculture lands, diminishing tourism, and hindering neighboring Redlands residents as myself from shopping in Yucaipa as this plan would create so much traffic. What person going down the Freeway stops to see houses and warehouses. Rural tourist attractions such as cattle, pumpkin patch, Christmas Trees, apples etc are why people come to the Yucaipa area and spend their money buying rural products, gas, food etc.

16. Historical significance of this area has not been considered. Live Oak Canyon has been documented to have many historical significance to Native Americans, Mission era, Pioneers and agriculture significance which characterizes Yucaipa. There appears to be no state and national historical archive search included in this project. The proposed specific plan has negative impacts which are not considered and cannot be mitigated.

17. New California wildlife corridor laws and regulation appear to be ignored.

New CA wildlife corridor law.
https://www.pewtrusts . org/en/research-and-analysis/articles/2022/ 10/20/new-California-law-protects-wildlife-corridors-and-a- lot-more

1. The Live Oak Canyon area is a prime specimen of California biodiversity which has not been considered and cannot be mitigated.

2. Warehouse demand is saturated and shrinking. httns:// www.wsj,.com/articles/warehousing-demand-is-starting-to-shrink- 19c5feaa

3. Agricultural soil can not be made. Destroying Agriculture land has a major impact on the region, California, and the United States of America. The Division of Land Resource Protection (DLRP) reviews, comments, and provides technical assistance to state and federal agencies, local jurisdictions, and the public regarding the multiple facets of the CEQA process. For Lead Agencies, the Department recommends the following discussion regarding agricultural resources. From https://www.conservation . ca. gov/dlrp/Pages/CA-Environmental-Quality-Act-(CEQA)-. aspx • "Type, amount, and location of farmland conversion resulting directly and indirectly from implementation of the proposed project.
• Impacts on any current and future agricultural operations in the vicinity; e.g., land -use conflicts, increases in land values and taxes, loss of agricultural support infrastructure such as processing facilities, etc. • Incremental impacts leading to cumulative impacts on agricultural land. This would include impacts from the proposed project, as well as impacts from past, current, and likely future projects. • Proposed mitigation measures for impacted agricultural lands within the proposed project area. • The project's compatibility with lands within an agricultural preserve and/or enrolled in a Williamson Act contract.

The conversion of agricultural land represents a permanent reduction in the States agricultural land resources.

Conservation easements are an available mitigation tool and considered a standard practice in many areas of the State. As such, the Department advises the use of permanent agricultural conservation easements on land of at least equal quality and size as partial compensation for the direct loss of agricultural land. Conservation easements will protect a portion of those remaining land resources and lessen project impacts in accordance with CEQA Guidelines § 15370. The Department highlights this measure because of its acceptance and use by lead agencies."

1. Air Quality is negatively impacted by this proposal with no mitigation possible creating increase risk for Yucaipa and neighboring citizens. This is not acceptable.

2. Significant impact on Aesthetics of Specific Plan and Updated Specific plan as negatively impacts scenic vistas of Live Oak Canyon and surrounding area.

3. Significant and irreversible damage to scenic and visual rural landscape of Live Oak Canyon including damage to historic Live Oak Canyon Road and Bridge created in 1913. The outcroppings, trees and rolling hill grass lands would be destroyed. The scenic and historic nature of Outer Highway 10 , the Interstate 10 freeway and Live Oak Canyon Road and surrounding neighborhoods and streets are destroyed by the Yucaipa Freeway Specific plan and update.

4. Character and Quality of life and site and surrounding area are destroyed by Yucaipa's Freeway Corridor and Specific Plan and 08/25/2025 City Council Agenda
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Update including Pacific Oaks Commerce Center would irreversibly negatively impact Live Oak Canyon, Surrounding communities and Yucaipa. This plan destroys Yucaipa's asset and would be gone for future generations.

5. The plan negatively, substantially and irreversibly degrades existing bucolic visual and rural character and quality of the site and its surrounds.

6. The plan creates unavoidable substantial light and glare that adversely affect day and nighttime views of the area that would not be mitigable.

7. Agricultural resources are negatively and significantly impacted including water supply, wildlife corridor and resources for grazing and raising crops. Carbon cap -sure is lost as major pollutants and carbon sources are created by the plan and building on the site. Erosion and watercourse destruction are unavoidable as a result too.

8. Converts prime and unique farmland to warehouses and residential and commercial property that destroys farmland and future agriculture opportunities. The one thing America and every single person on earth needs is food. There is no new land being made. Agricultural land and soil cannot be made.

9. Yucaipas Freeway corridor specific plan and update absolutely conflict existing agriculture zoning and use as change is to non - agriculture use. Impacting even agricultural tourism and freedom to Farm.

10. Significant and harm is caused by changes in the existing environment with Yucaipa's specific plan, water use, and updates as farmland is changed to non-agricultural use and way of life for everyone near the site and the surrounding communities.

11. Negative Air Quality impacts are unavoidable as agricultural grasslands are destroyed, trees ripped down as builidings, pavement, trucks and traffic replace agriculture lands. More pollution to back up into the mountains and create unmitigated air quality hazards. Obstructs any climate change or improvement in air quality.

12. The Inland Empire and Yucaipa/ Redlands already are burden with terrible air quality. The 10 Freeway and Yucaipa's specific plan, update and warehouse commerce development only obstruct any improvement or viable alternative. There will me no way to meet air quality standards, violating all existing and projected air quality standards resulting in major pollutant and violations.

Federal and state requirements for air quality can never be met or achieved with Yucaipa's Freeway specific plan, update or commerce warehouse development. Carbon capture is diminished and so destroying trees and grasslands results in a negative and non -attainment for any pollutant goals as this plan only destroys carbon capture and increasing emissions exceeding any possible threshold increasing carcinogenic and unhealthy pollutants to all residents and surrounding communities. Objectionable odors from vehicles and emissions will be unmitigated.

13. Destroys urban wildlife corridors and is in conflict of US and State Fish and Wildlife laws protecting corridors, habitats and endangered and protected species. The area is surrounded by open space and land that preservers and protects corridors and endangered and threatened species. Substanial and adverse effects of this project are devastating to mountain to valley wildlife corridors negatively impacting fauna and flora to a point of no return.

14. Conflicts with habitat conservation of surrounding preserves and parks that are interconnected part of the wildlife corridor.

Including Redlands Oakmont park and Live Oak Canyon.

15. Live Oak Canyon Road is a historic and scenic road developed in 1913.

16. The entire area is documented hunting grounds and sites for many Native American Tribes.

17. The rolling hills and other natural features would be destroyed.

18. The Live Oak Canyon Creek will be ruined and waterway and riparian habitats negatively impacted.

39. Agricultural soil cannot be made. This plan ruins all agricultural soil.

40. USGS maps show multiple earthquake faults running near and through this area including the Banning Fault and other unnamed projected and located faults running through or near the project area. See attached USGS map.

41. Greenhouse gas emissions from truck, car and building exhaust is a major and unmitigated issue with the plan conflicting with climate change and green house gas emission laws and standards. Replacing grass with leaked gasoline, diesel, oil, building materials creates more hazardous waste known and unknown sources creating significant hazardous impact to public and environment.

42. The project is next to residential agricultural zoning with few houses and not overdevelopment. Trying to evacuate the proposed specific plan would be impossible in case of a major disaster.

43. Water is a major issue as potable water supply for specific plan, water tank, and use will hurt the already water distressed region and state.

44. The Live Oak Canyon Stream will be negatively impacted impacting all downstream waterways.

45. Drainage will be altered as natural landscape is replaced with hardscape. Erosion and stream bed alteration are unavoidable.

Drainage patterns will be impacted at a substantial rate degraded land and water quality with storm drain polluted run off exposing people and structures to possible injury and harm with increased risk of mudflows as hardscape increases water flow during rain.

46. The plan physically destroys established rural lifestyle of surrounding and neighboring communities and is in conflict with rural lifestyle lands, Canyon conservation efforts and neighboring zoning with unavoidable negative unmitigated environmental effects. The plan is in conflict with neighboring Redlands Live Oak Conservation efforts and plans.

47. The noise produced from this project would be immense with trucks cars and noise producing impacts as Redlands noise ordinance would be violated especially those properties abutting the specific plan area.

48. This project adversely affects the walkers, bicyclists and equestrian activities in Live Oak Canyon and surrounding area.

49. Traffic on Outer Highway 10, the Interstate 10 Freeway and Live Oak Canyon Road and supporting bridges would make this area unlivable and evacuation in case of a disaster impossible. Emergency access would be limited with increase traffic and trucks etc.

50. State laws encouraging alternative transportation for a healthier lifestyle and community would never be met by the plan.

51. Significant impacts would be made on region water and wastewater facilities and expansion of water demands would cause major environmental damage and shortfalls.

52. The cumulative impacts are so considerable that the future of the entire region is jeopardized. Cumulative impacts to wildlife corridors are so severe major loss in populations would be expected. Human life is so negatively impacted by this plan that death rate 08/25/2025 City Council Agenda
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and illness especially to children should be expected through pollution or traffic accidents. The children's future to see agriculture in their communities will be extinguished. Their water supply harmed.

53. Traffic in the area is horrible and this project only makes it worse. Increasing an already distressed and disrepair Freeway and roadway system. Expect more fatalities in the area and liability as a result.

What is the goal of Yucaipa? Is the goal to destroy life and a vindictive ruin for a few greedy people's gain? Vote no on the Specific plan and update. Vote no on the ill conceived Commerce Center and Warehouses. Why destroy the future and assets of Yucaipa and the region?
Sincerely,
Amanda Frye
Attachments:

USGS Earthquake Fault map
Greenfire Law letter regarding Live Oak Canyon
Historic Live Oak Canyon Road Articles (2)
letter pdf file
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GREENFIRE

LAW, PC
January 24, 2023
Via Electronic Mail
To: Planning Commission Chair and Commissioners
([email protected])
Brian Foote ([email protected])
City Clerk ([email protected])
Yvette Abich Garcia ([email protected])
Ariel Strauss, Of -Counsel
2748 Adeline Street, Ste. A
Berkeley, CA 94703
510-900-9502 x 702
[email protected]
www.greenfirelaw.com
RE: Comments on January 24, 2023, Agenda Item 4.A (Consider an Extension of Time for Tentative Tract Map No. 18845 and Conditional Use Permit No. 1036) Dear Planning Chair and Commissioners:

On behalf of Amanda Frye, I am writing to identify serious deficiencies in the resolution to approve the extension of time for Tentative Tract Map number 18845 and CUP 1036.1 Additionally, Government Code, section 66463.5(c), does not permit a further one-year extension.

Pursuant to Municipal Code Section 17.07.120 and Government Code, section 6643.5(c), the Commission has a duty to exercise its discretion to only extend the tract map if the proposed development will comply with the City's ordinances, General Plan and CEQA. (See Gov. Code, § 6647(a), (b); see also, Soderling v. City of Santa Monica (1983) 142 Cal. App.3d 501, 508 (map properly denied for failure to comply with city's smoke detector requirement).) 1 In addition to the comments herein, I note that Numerous residents submitted comments to the January 10, 2023 meeting identifying a wide range of new and worsening environmental impacts that necessitate a supplement to EIR, including but not limited to failure to confer with affected Native American tribes pursuant to under Public Resources Code § 21080.3.1, strong evidence of ancient rock art on the project site, destruction of aesthetically and biologically significant natural resources, failure to consider a no project option wherein the site is purchased by conservationists, pollution and degradation of adjacent watersheds, inadequate water service, excessive traffic and light pollution.
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According to U.S. Census data, between 2000 and 2020, the population of Redlands has increased by about 10,000 residents (or approximately 14%), with half the grown occurring since 2010. The population of the City of Yucaipa, just across Highway 10 from the project site, increased by nearly 30% (almost 13,000) in the same 20-year period. Over the 17 years since the Environmental Impact Report (EIR) was issued, numerous significant changes have occurred in the surrounding environment, including increases in baseline traffic on nearby roadways, habitat fragmentation placing added strain on listed and non -listed species, worsening light pollution, decades of drought exacerbating pressure on municipal water sources, and new wildfire hazards.

I. The City Must Supplement the EIR in Light of Significant Changes and New Information.

The Staff Report states that staff have:
analyzed the existing conditions at the time the tentative map was approved compared to present conditions using Google Earth aerial imagery (2015 to present). The topography and extent of development on the tentative map site remains unchanged. Also, the parcels adjacent to the project site remain unchanged. There have not been any changes to environmental conditions in the surrounding area, or the discovery of new significant environmental issues under which the project will be undertaken, that would require revisions of the previously -certified Environmental Impact Report.

However, this narrow, focus on the surface features of the site and adjacent sites is entirely inadequate. Moreover, the EIR was approved in 2005, not 2015. The Staff Report's CEQA checklist similarly offers no description of any analysis that formed the basis for the check boxes and provides no backup documentation. Notably, beneath each of fifteen categories of potential environmental impact listed in the checklist is a row for "Issues and Supporting Information Sources" with an option for "yes" or "no." And for each category, neither option is selected. This presents a clear record that no supporting information was consulted.

A supplemental EIR is required when "[s]ubstantial changes occur with respect to the circumstances under which the project is being undertaken which will require major revisions in 2 For instance, in 2013 The Reserve at Crafton Hills in Yucaipa, a few miles to the north, developed 35 acres of nature into a single-family subdivision.
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the environmental impact report"; or "[n]ew information, which was not known and could not have been known at the time the [EIR] was certified as complete, becomes available." (Pub. Res.

Code, § 21166.) The new information must show the "project will have one or more significant effects not discussed in the previous EIR" (CEQA Guidelines, § 15162(a)(3)(A)), or "[s]ignificant effects previously examined will be substantially more severe than shown in the previous EIR" (Id., § 15162(a)(3)(B)). Plainly, the circumstances under which the project is being undertaken has significantly changed and critical new information regarding impacts has come to light.

A. Greenhouse Gas -Driven Climate Change is New Information that Must be Evaluated.

While scientists have been aware of the notion of the greenhouse effect for many years, knowledge of the tangible harm and pace of climate change impacts in California are dramatically "more severe" than what could have been competently anticipated in 2005.3 The EIR adopted in April 2005 (released in November 2004) makes no mention of greenhouse gas (GHG) emissions or climate change whatsoever. At the time that it was approved, there were no California GHG reduction targets and there were limited tools for even assessing emissions.4 In 2007, SB 97 first required analysis of GHG emissions under CEQA. The City of Redlands only adopted a Climate Action Plan in December 2017. While new legal standards do not necessarily apply retroactively, the multifarious suite of climate change -related laws that became applicable in the years since the EIR was adopted are strong evidence of the discovery of new information that the project would cause much "more significant effects," which was entirely unexamined in the EIR.

A first step in determining whether GHG emissions are significant is assessing a threshold. CEQA Guidelines, section 5064.4(b) explains that a "project's incremental [GHG] contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national or global emissions." The San Bernardino County Air Quality Management District has not established thresholds of significance for residential land use projects but 3 See, Office of Attorney General, Climate Change Impacts in California, https://oag.ca.gov/environment/impact . 4 The first California GHG emissions targets were set by Executive Order S-3-05 in June 2005. 3 08/25/2025 City Council Agenda
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recommends consideration of approaches of other agencies, such as the Bay Area Air Quality Management District. The BA AQMD has proposed minimum design standards, which include no natural gas piping, no wasteful or unnecessary energy usage, project -generated vehicle -miles travelled (VMT) at least 15% below the regional average and compliance with off-street electric vehicle charging standards.5 Notably, the site is not in a 15% below average VMT area and the EIR does not set any standards for vehicle charging nor does it restrict natural gas infrastructure.

To the contrary, it anticipates that the site will be served by Southern California Gas Company (EIR at 4.12-5 (consumption of 19,282 cu.ft./day at original project size); Table 4.2-7.) The Redlands Climate Action Plan sets a 2030 per capita per year GHG emissions target of 6.0 metric tons.6
To assess this project's emissions, the City must tally the area sources (consumer products, architectural coatings and landscape equipment), energy usage from natural gas and electricity consumption, mobile sources (primarily vehicle commuting), waste, water, construction and habitat destruction. Having failed to generate any record of having considered the issue, the City cannot in good faith assert that the EIR remains valid. In fact, it is probable that the project exceeds the City's Climate Action Plan significance thresholds. It is patently unreasonable for the City to continue to entirely ignore GHG impacts now that the importance of this issue is known. Moreover, independent of CEQA, as discussed below, the City's General Plan requires similar analysis and mitigations, which also have been ignored. 5 BA AQMD, CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans, p. 2 (April 2022) available at https://www.baaqmd.gov/— /media/files/planning-and-research/cega/ceqa- thresholds-2022/justification-report-pdf.pdf?la=en.
6 City of Redlands, Climate Action Plan, 3-2 (Dec. 5, 2017), available at https://www.ca-ilg.org/sites/main/files/file- attachments/final redlands cap with appendices 011718.pdf?1591222345. 7 See, Air Quality, Global Climate Change and Energy Impact Analysis for Terracina at Redlands, p. 76 (Aug. 16, 2021), available at https://www.cityofredlands.org/sites/main/files/file-attachments/appendix_a_-_aq-ghg-hra- energy.pdf?1661443947 (5.81 MTCO2e per capita annually for a single-family project involving GHG mitigations and less habitat destruction).
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B. Sufficiency of Water Access must be Reevaluated in Light of Drought Conditions.

California has faced the most severe period of drought in its recorded history, making it the driest 22-year period since 800 CE.8 In light of the extreme drought the Commission must consider whether the project will be an excessive strain on local utility, which presently has not provided a will -serve letter.9 Significant population growth in the project area also necessitates supplemental assessment of the adequacy of local aquifers that will provide water for the site.

C. Fire Hazards in the Surrounding Areas are Significantly More Severe than Anticipated in 2005.

The 2017 General Plan update recounts the well -recognized fact, mentioned by numerous comments submitted on January 10th, that the severity of wildfire risks has materially increased in recent years. The Fire Hazards section of the General Plan was added pursuant to SB 1241, which required mitigation measures to be implemented in high fire risk areas, such as the project area. The General Plan states that "the highest fire risk areas are in San Timoteo and Live Oak Canyons where the threat from wildfire is the highest... Prolonged droughts coupled with high winds and dry vegetation during the summer time creates the highest fire risk in these areas.. .

Most of the city's large wildfires have occurred in these areas. In the last 20 years, there were 30 fire perimeters captured. These fires damaged 14 structures, 75 properties (parcels), and a total of 452 acres." (General Plan, p. 7-21.) In 2013, the City's firefighting resources were downgraded from the second highest rating to the third -place rating (Id.).

Human activity, such as operating motor vehicles, gas -powered or potentially -sparking tools and BBQs10 and the smoking of cigarettes, to list but a few examples, are the overwhelming cause of wildfires in California." Severe weather conditions have even pushed Southern 8 Paul Rogers, "Current drought is worst in 1,200 years in California and the American West, new study shows", Mercury News, Feb. 14, 2022; see also https://datacentral.press-citizen.com/drought/california/san-bernardino- county/06071/ (National Drought Mitigation Center data). 9 Minutes from the most recent regular meeting posted to the website of Western Heights Water Company notes that the "state has mandated water shortage cutbacks." https://westernheightswater.org/wp-content/uploads/07-2022- Minutes.pdf
1° Note that BBQs are advertised at The Reserve ( https://theharris.group/yucaipa-real-estate/the-reserve/) . 11 See W. Cornwall, Overwhelming Cause of California Wildfires: Humans, National Geographic (May 17, 2014). 5 08/25/2025 City Council Agenda
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California Edison to cut power during high wind events, particularly in high fire hazard zones.12 Unfortunately, the use of generators during more frequent outages has further increased fire risk.13 Supplemental CEQA analysis is needed on account of the heighted burn risk.

The City has a responsibility to implement mitigation measures under the General Plan and CEQA. The Staff Report includes a Fire Department Conditions letter from May 1, 2015, which states that the "conditions are subjection change with adoption of new codes, ordinances or when building permits are not obtained within twelve (12) months." (p. 2.) Yet, the Staff Report does not document any conferral with the Fire Department to ensure that the project as designed will be is in compliance with current codes and the 2017 General Plan update.

Approval of the extension must not be undertaken without such analysis.

D. The City Must Confirm that Mitigations Required by the MND are Enforced and Effective.

The EIR identified potential impacts to several endangered species including the California gnatcatcher (CAGN). Mitigation BR-1 required that a survey "shall be conducted by a U.S. Fish and Wildlife permitted biologist each breeding season (February 15-August 15) that the property remains in an undeveloped state to confirm the continued absence of CAGN [California gnatcatcher]." The site has remained in an undeveloped state for seventeen years since the EIR yet the Staff Report does not identify whether this occurred and any results from this survey. Mitigations must be enforceable and enforced. (Pub. Rec. Code, § 21081.6(b) (mitigations measures must be "fully enforceable").) "Mitigation measures are not mere expressions of hope." (Sierra Club v. Cnty. of San Diego (2014) 231 Ca1.App.4th 1152, 1167.) Failure to enforce mitigations makes them ineffective. The City must confirm compliance with the MND or determine whether the CAGN is present on site and that effective mitigations are in place.
12 Alejandro Cano, Power shut off due to PSPS impacting 4,700 southern California residents, Redlands Community News, Oct. 10, 2019, https://www.redlandscommunitynews.com/news/power-shut-off-due-to-psps-impacting-4- 700-southern-california-residents/article_29ed6206-eb8b-11 e9-a34b-5320cfff5l b0.html. 13 Mallory Moench, "During PG&E outages, generators caused fires, carbon monoxide poisoning", San Francisco Chronicle, Nov. 13, 2019.
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E. The Commission Must Consider Threats to Listed and Candidate Species.

The endangered San Bernardino Merriam's Kangaroo Rat (EIR at 4.4-9) "sage scrub and chaparral" habitat (63 Fed. Reg. at 3836 (Jan. 27, 1998)) has been harmed by development in the Redlands area and is a biome that is present on the site (EIR at 4.4-10). The City must continue to confirm, in light of the length of time that has elapsed, other development in the surrounding area and habitat loss from climate change and wildfires, that this species is not impacted by the project. This consideration applies to the other species of potential concern listed in the EIR (see Tables 4.4.1 and 4.4.2).

The City has further neglected to consider that, subsequent to completion of the EIR and project approvals in 2015, the Monarch Butterfly has become a candidate species14 and the Little Brown Bat is under review by the U.S. Fish and Wildlife Service.15 Both of these species are known to exist in the project region16 and Monarchs have been directly observed in Redlands by residents. The record contains no indication that the City even considered whether any supplement is required in light of these impacted species. The presence of newly at -risk species constitute significant new information and changed project circumstances.

II. The Development is Inconsistent with General Plan Environmental and Safety Requirements.

The Commission must not ignore the 2017 updates to the General Plan enacted subsequent to the 2015 project approvals. The following General Plan Policies and Action Items Apply to the project but are totally ignored in the Staff Report and proposed resolution:17 • 8-A.21 Support the development of distributed energy resources (DER), such as combined heat and power (CHP) from micro -turbines, fuel cells, etc., to assist in local energy security.
• 8-A.37 Promote design in new development that incorporates space for recycling containers and other waste diversion facilities.
14 See https://www.fws.gov/press-release/2020-12/endangered-species-act-listing-monarch-butterfly-warranted- precluded.
15 https://fws.gov/species/little-brown-bat-myotis-lucifugus . 16 https://ecos.fws.gov/ecp/report/species-listings-by-current-range-county?fips=06071 . 17 Note: Action item 7-A.100, "Require that all projects proposed in areas that are at risk from wildfire adhere to requirements under Redlands Fire Department Prevention Standard 'Fire Safety Modification Zones 1 and 2"' was considered at the time of approval of the tract and CUP in 2015 but the substantive Department standards have since changed.
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• 8-P.8 Promote sustainability by reducing the community's greenhouse gas (GHG) emissions and fostering green development patterns — including buildings, sites, and landscapes.
• 7-A.94 Avoid, where feasible, approving new development in areas subject to high wildfire risk. If avoidance is not feasible, condition such new development on implementation of measures to reduce risks associated with that development. • 7-A.96 Ensure that all-weather access is provided for all new development, with adequate clearance for emergency vehicles, designed in accordance with the California Fire Code, and ensure that all roads, streets, and major public buildings are identified in a manner that is clearly visible to fire protection and other emergency vehicles.

Even if the EIR did not need to be updated under CEQA, similar analysis of GHG emissions must be undertaken pursuant to General Plan Policy 8.P.8. However, it is totally neglected. The site must also be designed to corporate DER and "space for recycling containers and other waste diversion facilities." The Commission must also decline to extend the tract map pursuant to Action 7-A.94 to "avoid ... approving new development in areas subject to high fire risk." The record lacks any consideration of compliance with any of these General Plan requirements.

III. The Tract Map Fails to Provide Required Emergency Access.

The General Plan mandates that "Subdivisions must have two points of vehicular ingress and egress from streets, one of which may be used for emergency purposes only." (General Plan, p. 7-23.) Tentative Tract No. 18845 attached to the Staff Report shows only a single entrance from Highview Dr. that terminates in two cul-de-sacs (see copy of tract map below). 8 08/25/2025 City Council Agenda
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This is in plain violation of the General Plan.

IV. Conclusion
The Commission must take a serious look at the environmental conditions affecting the site today and ensure full compliance with CEQA and the City's General Plan and ordinances.

The current record demonstrates clear failure by the City to do so. As a result, the Commission cannot approve an extension to the tract map without supplementing the EIR and ensuring conformance with the City's laws.

Sincerely,
rie trauss
9 08/25/2025 City Council Agenda
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Newspapers The Yucaipa Record (Yucaipa, California) Sat, May 3, 1913 Page 1 by +I ancestry
https://www.newspapers.com/image/835001752/
Downloaded on Sep 22, 2024

OAK GLEN ROAD IS

GIVEN A NEW TURN
Lynn Ranch Route Is Now Finished,
Though Still Soft for Regular
Travel
1►n;1cttn:ist''r Clyde has completed
the cutting through of the new route
l,f the [Orel; (11 tl road, at the Lynn
place. At the foot of the 1►. nc'h hill.
where formerly the road tool: a fairly
strai,ht r•cmrse to tho low hill at the
ltnt tlwast, the line has ttet n made 1• r-
!•erily !-=t r,ai::ht to the hed of the
stream. .\h'nr this w'at►'r course, on
the south lank, the new road runs t.i
ai junction with the old line above the
O'ntrance to the laytin place. It is the
itlt Ent iot1 to make an ornamental en-
trance to this estatty soon.

Live Oval: Canyon will soon have a
fine roadway from this valley to the
Bart TiT11 't(10 canyon highway. The
rn;ld is the ho+lndary line between this
count;Ind Riverside, and the super-
visors of the two a.re worhing in bar
Zt ony to tlt;li;e the route a fine one, :1
liri[1g4' has heen thrown across the ;'at -
ter course, and the road at eith►'r end
graded and level. c1.
.111 of the roads in the vicinity oil
the t i\► n have been put into ;[lo(i
slat' recently. tho ha\ int
been ruin ovvr them and the Lzlltters
1)111 into good shape.

Live Oak Canyon Road created.

Clipped By:

Sep 22, 2024
Copyright © 261,24517twywapiemggn.ANLaights Reserved.
807

News The Yucaipa Record (Yucaipa, California) • Sat, May 10, 1913 • Page 1 by ancestry
https://www.newspapers.com/image/835001769/
Downloaded on Sep 22, 2024

LIVE OAK CANYON NOW

HAS ROAD BUT NO BRIDGE
1 (ht(I11ta; tPr Clyde has completed
tho road iti Live oak Canyon from
die t'UHIIPCI 't)11 with the valley and
d
('tiovv Canyon roads, to the (it`.i sin
cif tl�� stl`uat11, where a hritigvi will he
pm in. 'l1his work it4 HOW under u in ,
tract, and the outlook is for s t't'(11
completion of this part of Hill thor-
oughfare. This road Is part in .►at'ht
county. forming the lime between
th' , and will he a great convenience
1o1. 1i1 residents; or the canyon and'
SUU# 1111 esI section of the va lle .

Live Canyon road and no bridge
Clipped By:

Sep 22, 2024
Copyright ©
451)ftly w{egy.Aghts Reserved.
808

From: Ann Balderrama
To: Public Comment
Subject: Proposed project
Date: Sunday, September 22, 2024 5:48:30 PM
I oppose the development of warehouses along the 10 freeway in Yucaipa.

Ann Balderrama
Redlands Resident
08/25/2025 City Council Agenda
809

From: Ron Simmons
To: Public Comment
Subject: Live Oak Canyon: Please save it!
Date: Sunday, September 22, 2024 6:39:20 PM
Live Oak Canyon: Please save it as open space
Inbox
Ron
Simmons
to publiccomment, keverts
111
6:34 PM (2 minutes ago) U
Dear Yucaipa City Council:

Please save Live Oak Canyon as open space. The native trees, plants and animals there are priceless. Please don't destroy the town where I grew up (YHS class of '63). Further --please reconsider or scale back the housing development on Oak Glen Rd. -- and save the old olive grove as well.

These two areas are what is left of the special place Yucaipa was --and can still be. But the Council must adopt a new attitude -- and put clean air, open space --and yes the beauty of natural surroundings --before unneeded warehouses and towering electric billboards.

The Billboards at 1-10 Yucaipa Exit need to be taken down as the first step of a new attitude. Leave our town room for walking, biking, and hiking --and enjoying the views of the mountains.

Thank you,
Ron Simmons
Desert Center, CA
08/25/2025 City Council Agenda
810

From:

To: Public Comment; Kim J Metzler, CMC, CPM
Cc: PAMELA SMYTH
Subject: Yucaipa I-10 Corridor Freeway Specific Plan & Update Agenda Item for City Council Meeting September 23, 2024 Date: Sunday, September 22, 2024 9:34:39 PM
Attachments: Letter to City Council re FSPUpdate September 23.docx Dear Ms. Everts:

Attached please find my letter of opposition to this project. Please see that the council members receive a copy of this prior to the meeting this evening. Thank you for your assistance, as always.

Pamela Smyth
08/25/2025 City Council Agenda
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Dear Mayor Beaver and Council Members:

Let me begin with this: "That which already has been, and what is to be already has been; and God sees what has been driven away." Ecclesiastes 3:15.

And, at your backs are these words: "In God We Trust," this nation's official motto signed into law by President Dwight D. Eisenhower in 1956. This is your declaration of faith in guidance for good decision making that relies not soley on your own understanding, but on a level of understanding that comes from a greater source of strength, reliance, and power. No man is greater than God, we are reminded by Proverbs 3:5 and 3:7 when we hear, see, and speak these words: "Trust in the LORD with all thine heart; and lean not unto thine own understanding," followed by, "In all thy ways, acknowledge Him and He shall direct thy paths." Your city manager says there is no other way to rescue the City of Yucaipa from the present financial and economic downturn. But I, and hundreds of others, believe otherwise; we also believe in the nation's motto: In God We Trust. But what does Trust mean? One definition says, "To believe that someone is good and honest and will not harm you, or that something is safe and reliable." Another says, "Reliance on the integrity strength, ability, or surety of a person or thing; confidence."
The City Manager's recent video tells us that the city seeks to preserve the rural character of the Yucaipa valley. Later, we get to the heart of the problem, how the city arrived at and is now at a crossroads. Since no viable solutions came from public discussions, he explains that the most judicious and expedient way out this financial and economic dilemma is an either-or proposition:
to cut funding to community services and public safety or to sell the vacant lands along the I-10 to developers for the purpose of bringing increased revenue to the city through a massive housing development on both sides of the I-10, a large industrial/commercial business park along the southern end of Outer Hwy 10, and by bringing two large warehouses to the entrance of Live Oak Canyon.

Curiously, your own planning commission recommends that you deny this Plan; perhaps it would be wise to lean not on your own understanding, but to wait on this decision. The word, "weight" appears throughout the summary of the Plan; perhaps more weight deserves to be given to what the people say —the people who place their trust in you. Yes, there's that word again-- Trust.

One time, a high school student came to me and said, "You listen to us you listen to our complaints and our concerns —our problems —and you help us get through them. You take care of us like a good parent, but who takes care of you?"
As a city council, you are placed in that same position —one of trust, responsibility, and reliability to do the right thing as best you can do with what you are given like good parents, but who takes care of you? When we read the words behind you in reverse, they tell us: Trust first. 08/25/2025 City Council Agenda
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Then We. Then God. Then In. What that says to me is that you first recognize that the decisions you make are made in the spirit of trust —to rely on that which is not seen. To me, the We means all of you working as one body. God, to me, means that you lean not on yourselves or on your city's administrators, staff members, or hired consultants to direct your paths, but on a higher authority. They are all good at what they do as is each of you; but as my colleague would say, "They are good, but they are not God!" And then comes the word, In. To me that means within the sphere of your community and includes all of us who call this place home. The bible also tells us, in essence: "To whom much is given, much is expected." That means the weight of the world can rest upon your shoulders, but God has given you not more than you can handle and the abilities to see beyond simply business, city governance, and financial management. Rather, that means that you also are given the insight and ability to see further into the hearts and souls of the people for whom your work is being done. From them may come your solution and answers.

While this Plan's solution looks like the "be all and end all" of solutions, do not be led into thinking there will be no adverse or negative impacts on your city and on the people of Redlands, Calimesa, Cherry Vallely and beyond, who have come together in a unified manner to oppose this Plan, especially, the warehouses.

Calimesa residents are, on this same night, battling the prospects of four more warehouses that will choke and suffocate their community beyond imagination. Calimesa will all but disappear behind a sea of industrialization and commercialization as will Yucaipa. As a song from the past once asked, "Is that all there is?"
If you give up and give in and approve this Plan, there will be no "green valley" that even now is barely visible from Yucaipa Blvd. If this kind of excessive and unwanted development is forced upon us, those who shop in Yucaipa, as I do, who support your local businesses, as I do, and strive to protect and defend the rural way of life from Outer Hwy 10 south to Oak Glen, on both sides of the I-10, and up the grade to Calimesa, as I do, may rightfully and willfully desert you and take their business elsewhere as some have said.

I have read from beginning to end the Plan, which makes all of it sound and look like an extension to a Disney World theme park and something Walt Disney would eagerly accept and applaud if it were designated for some area of Florida or Texas with nothing but wide- open spaces and relatively far from small communities and jam- packed trucking lanes and freeways.

The writers and CEQA consultants have clearly, precisely, and carefully negated every potential adverse impact that could
be found to ensure that not one point of concern raised by opponents can be refuted in their "ideal world" that is written on paper, here. In the real world, that will be quite a different story. 08/25/2025 City Council Agenda
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As we know, China has razed much of its farmland to encourage logistics and industrialization; now, they face a food shortage. Poland, France, the United Kingdom, and Canada are now fighting back against this take over of parts of their countries being trampled by the logistics industry. This is not only a local concern but a global concern. Does Yucaipa bow down to the gods of logistics and commercial real estate now, as well? Has China's economy flourished as predicted with the holding of more warehouses in the world than any other country? No.

While many of us can appreciate this glorified look an at idealized future for Yucaipa in all respects defined, described, and justified as beneficial to everyone in every conceivable way, the reality is that not even your most brilliant market forecasters and predictors of the future can guarantee that there will be water, power, and affordable housing available for residential and commercial development in these areas, let alone the elevated costs of mandated homeowners and fire insurance. Nor can "they" predict the future of the logistics industry and a far-off promise of jobs that are mainly low wage earning and "at will" jobs with mostly inferior working conditions.

What we can be assured of is the irreplaceable loss of the natural habitats, the scenic vistas and viewsheds, and the destruction of Live Oak Canyon Road and horrendous impact on Outer Hwy. 10 South and the entire I-10 corridor from Ford Street in Redlands to West County Line Rd. in Calimesa. The perceived creation of the Oak Glen Rd. and Live Oak Canyon "Gateway to Yucaipa" interchanges are incomprehensible to me and to many who have come to join you in this meeting, whether by physical presence or by written communications.

Simply put, perception is not reality.

The highest and best use of these natural and historically agricultural canyon landforms and grazing lands is not commercial or residential development; this land would better serve Yucaipa if it were put in a conservation trust and given to the State of California that actively encourages private landowners to create such conservation easements to preserve what is left of grazing lands and scenic viewsheds. From what I have read, property owners can profit from this in various ways, as well.

People looking to buy homes are not going to be drawn to subdivisions along trucking lanes and in an area where homeowners insurance may not even be viable, let alone fire insurance. People do not want to live walled in. They are moving from those kinds of developments to the outskirts and to small towns like Yucaipa and Calimesa to escape the confines of city and urban life; do this to Yucaipa and they will move on to the Midwest, the South, the North, and to the East.

Is this going to provide by then the so-called "affordable" housing? Mr. Mann states, "If you build it, they will come," borrowing from the film, Field of Dreams. 08/25/2025 City Council Agenda
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Well, if you build it there, they will NOT come. Not one of you lives a stone's throw from the trucking lanes; not one of you witnesses and calls in the accidents, car fires, truck fires, and explosions I see, hear, and report now on a routine basis.

Not one of you lives with the thunderous roar and shaking of your home to the foundation when the trucks are backed up from Redlands to Beaumont with the grinding to a halt stops and starts, the downshifting of gears, the honking of horns, and screeches of brakes due to accidents or road work ahead on the I-10 east. Not one of you knows that the sound walls do NOT buffer the traffic noise and land vibrations; instead, they often serve to reverberate like handball courts the noise levels that are most often above the 8.0 decibel levels that makes living near the freeway deafening and having a normal conversation outdoors nearly impossible. This, Mayor Beaver, Planning Director Matlock, City Manager Mann, and Council members is the reality you choose to create. Can each of you live with that?
The concerns brought before you are those of reasonable people. Your duty is to provide them with a reasonable outcome, not an unrealistic and unreasonable Plan for the future. As we are told, the future will take care of itself. We are not the author of the future; we cannot predict outcomes. We can, however, take steps to protect and defend our greatest assets: the people who live here now, who work here now, who depend on you now. But the greatest asset lies in the land they love and that brings them peace of mind, reduction of stress and strain, silent beauty and hope for green hills and verdant pastures —of cattle and horses grazing that they can pull off the road to admire and share with their children and grandchildren. This is Yucaipa's other asset beyond Oak Glen.

Will you sacrifice the health and quality of life of your own people to the gods of logistics and commercial real estate? Do we all become the sacrificial lambs of those false gods? Though we do not see this as a possibility right now, I encourage you to find a better and healthier way to protect your city from this colossal disruption of these natural resources and the lives of so many good and caring people who have come this night and other nights to ask that you not allow this kind of drastic measure to bring certain harm to their quality of life. They ask that you bring no harm to the natural wildlife corridors and habitats. They ask that you bring no more harm to those who travel this already over -burdened Interstate freeway now more fraught with accidents due to increased traffic, unsafe lane changes, and unsafe speeds as drivers try to get around and ahead of two lanes of often bumper -to -bumper big rigs headed for the area warehouses. They ask that you bring no more harm to Live Oak Canyon Road and Oak Glen Road.

City Council
September 22, 2024

Page 5 ends

you are not pressured into fast -track decision making out of desperation, which is what the property owners and their real estate representatives are pushing for immediately, and for their mutual benefit. While they have a right to profit from inheritances left them from their respective families and hard-working ranchers, primarily Mr. Palmer and Mr. Robinson, they and you might consider these statements before you "rush to judgment" as they say. From the Wildlands Resources Committee, Subcommittee on Water Oceans and Wildlife, United States House of Representatives in October, 2019 comes this statement:
"Protecting wildlife supports the United States economy. Protecting wildlife across the United States is an important component of ensuring a resilient and diversified national economy. Direct economic impacts from various wildlife related industries are important to overall national GDP and especially important to many rapidly diversifying rural economies across the country. Estimates place the economic contribution of outdoor recreation at $412 billion per year (or 2.2 percent of GDP)iv, including hunting and angling at over $200 billion per year; bird watching at $41 billion per year.vi The economic value of ecosystem services related to wildlife habitat and behavior are hard to quantify, but similarly important to both national economic productivity and quality of life. Protection of wildlife, on an individual, population -level and habitat basis, is necessary to preserve dependent economic and business opportunities and associated standards of living across communities within the United States." The largest conservancy, The Nature Conservancy, says this:
"Together, We Can Make a Difference
The Nature Conservancy —which owns 500,000 acres of U.S. grazing lands and has helped to conserve millions more through easements and collaborative management —has worked for years to develop strong, trusting relationships within the ranching community and the beef supply chain. We use our lands to work with and support neighboring ranchers and to develop and test cutting -edge, science -based management practices.

Food companies and other supply chain stakeholders are seeking TNC's expertise to achieve sustainability goals while driving accountability within the industry, positioning our staff to help guide national initiatives that have the potential to make a lasting impact.

We are at a critical moment in time. Grazing has the largest footprint of any agricultural activity, making it imperative that we manage these lands for clean water, climate benefits, global food security and vibrant rural communities.

Together, we can help safeguard an enduring part of America's heritage while protecting natural resources and ensuring a sustainable future for a growing world."
As you can see, the taking of our wild habitats and wildlife corridors is not the answer to bettering the economy or prospering a city. I challenge you to reach out to these 08/25/2025 City Council Agenda
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organizations to see what they can do to help you and the property owners financially, while keeping your rural areas intact and protecting the environment from greater harm that will surely come from this wrongful use of the canyon lands and terrain —and soils not meant for this kind of weight and watershed loss or erosion." From the World Economic Forum:

URBAN TRANSFORMATION
How to make our cities greener, healthier, wilder and fairer Aug 5, 2021
It is a traditionally held view that cities are generally devoid of any biodiversity, but that is not the case. Recent studies suggest that the world's cities, including spaces in old parking lots, roof gardens, parks and created wetlands, offer important refuges for plants and animals — even for some more threatened and endangered species.

It is not only biodiversity that is important in cities, but the relationship between people and nature. The more that can be done to connect people to nature in cities, the more city dwellers will come to appreciate the natural environment and the benefits it provides, whether that is for its intrinsic value or its function — from
flood attenuation to shade or as spaces for play and exploration. If we can foster this conservation spirit in cities, it will likely have benefits everywhere.

Finally, what does Pope Francis say about the environment? Here is a summary of His Holiness' statements made in the papal document, "Laudato Si' Encyclical Letter," which I read in its entirety several years ago when another area of Live Oak Canyon was to be developed against great opposition.

1. Interconnectedness of Creation: In "Laudato Si'," Pope Francis stresses that all elements of creation are interconnected. He argues that environmental degradation affects not only nature but also human life, particularly the poor and marginalized who are often most impacted by ecological crises. This interconnectedness calls for a holistic approach to environmental issues.

2. Critique of Consumerism and Overdevelopment: Pope Francis critiques rampant consumerism and overdevelopment, which he believes lead to environmental destruction.

He highlights how excessive exploitation of natural resources contributes to climate change, loss of biodiversity, and pollution. The encyclical urges individuals and societies to reconsider their lifestyles and prioritize sustainability over short-term economic gains.

3. Call for Action: The Pope calls for urgent action against climate change and advocates for policies that promote renewable energy sources, conservation efforts, and sustainable agricultural practices. He emphasizes the need for global cooperation to address these challenges collectively.
08/25/2025 City Council Agenda
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4. Moral Responsibility: Pope Francis frames environmental stewardship as a moral responsibility rooted in faith. He encourages believers to see caring for the Earth as an integral part of their spiritual lives, linking ecological concerns with social justice issues.

5. Advocacy for the Poor: The Pope consistently highlights that environmental degradation disproportionately affects the poorest communities worldwide. He argues that protecting the environment is essential not only for ecological health but also for social equity.

6. Sustainable Development Goals (SDGs): In his addresses at various international forums, including the United Nations, Pope Francis has endorsed the Sustainable Development Goals (SDGs) as a framework for addressing global challenges such as poverty, inequality, and climate change through sustainable practices.

7. Role of Education: Education is another critical aspect emphasized by Pope Francis in fostering an ecological mindset among future generations. He believes that educating people about environmental issues can empower them to take action towards sustainability.

8. Spiritual Reflection on Nature: The Pope encourages spiritual reflection on nature's beauty and fragility, urging individuals to develop a deeper appreciation for creation as part of their faith journey.

9. Global Dialogue: Finally, he advocates for dialogue among nations regarding environmental policies and practices, emphasizing that collective action is necessary to combuat global warming and protect ecosystems.

In summary, Pope Francis articulates a comprehensive vision regarding the preservation of the natural environment that combines ethical considerations with practical actions aimed at combating overdevelopment and promoting sustainability.

While I realize you have no "real time" to read this lengthy letter, I hope at some time you will.

For now, it goes into the Record for future consideration.

Thank you all for your hard work, dedication to the betterment of the City of Yucaipa, whose boundaries I share on three sides of my Redlands rural -residential property, and whose businesses provide for 95% of my survival. May you not be pressured into hasty decision making by realtors, lawyers, or others who would push you toward what could become "jumping the gun" and decisions that may result in unanticipated consequences in the years ahead.

Yours sincerely,
t cIM'telav L. Smyth/
Pamela Smyth
Redlands, CA
08/25/2025 City Council Agenda
818

From:

To: Kim J Metzler, CMC, CPM
Cc: Public Comment
Subject: City Council Public Comment re: No Warehouses
Date: Sunday, September 22, 2024 10:59:39 PM
Dear Yucaipa City Council Members,
As a lifelong resident of Live Oak Canyon, there are many aspects of the proposed Freeway Corridor Specific Plan update and the Pacific Oaks Commerce Center which concern me. The development would cause increased safety hazards, destruction of property, pollution of the environment, and irrevocably change the nature of the community.

Live Oak Canyon Road cannot withstand the increased traffic that the warehouses will bring. Many tragic accidents already occur, far too frequently. The road exists in both San Bernardino and Riverside County. Emergency responses are often delayed, as the county line creates jurisdictional confusion. Likewise, road maintenance is poor as cooperation between counties is difficult, and there is always at least one section of the road in dire need of resurfacing. Even higher traffic will increase the risk of accidents to both local residents and the many Yucaipa citizens for which Live Oak Canyon is part of their daily commute.

The development will result in over 5 million feet of impermeable surfaces, and plans even allow for the grading of designated open spaces, increasing runoff and disrupting natural watershed. Erosion poses a further risk of increased flooding, landslides, and loss of property for those bordering the canyon itself. The environmental impact report found that "the Project would continue to result in a significant and unavoidable environmental impact for Air Quality, Greenhouse Gases, and Noise." Mitigation procedures have been proposed, but I ask, why mitigate that which can be prevented? No amount of carbon credits can offset the impact on the local environment.

The Inland Empire warehouse industry is currently in a downturn. Building more warehouses is not a solution to the problem. Additionally, warehouses are increasingly turning to AI and Automation. Whatever jobs these businesses may provide now are an unemployment liability in a near future where technological advancements prove to be more efficient than human labor.

The proposal claims to be designed to protect the perception of a rural small-town community, but it is only concerned with keeping this perception, and not as a reality. While it may not be visible from the highways, the development will be readily visible from the nearby Herngt Aki preserve and Gateway Ranch hiking trails adjacent to the site. These are not only wonderful recreation areas for the community but also part of a valuable wildlife corridor connecting to Mt. San Jacinto, of which this site is also a link. The endangered Southern California Mountain Lion and a diversity of native species rely on this habitat, which once lost, results in their demise or pushes them into human contact for survival. Easy access to outdoor recreation and a connection to nature is one of our community's most valuable assets. We need to foster the idea that land is more than just buildable space. Nature is necessary for the physical and mental well-being of our community. Developing this area would be short -sited.

Once the land is used, there is no reverting back. It will forever be polluted and destroyed. We need to create a plan with greater emphasis on conservation, instead of one that just lines the pockets of a few at the expense of many, in current and future generations.

This land needs to retain its agricultural designation and be conserved rather than developed. Please reject the warehouse proposal, as it does not reflect the best interest of our community, now or in the future.

Sincerely,
Seana Countryman
08/25/2025 City Council Agenda
819

From:

To: Public Comment; Kim J Metzler, CMC, CPM
Subject: Development Project at Live Oak Canyon and 10 freeway Date: Monday, September 23, 2024 8:19:18 AM
To Whom It May Concern:

Please do not allow these development projects to proceed in our community. These developments will directly impact my ability and my family's ability to safely exit San Timoteo Canyon in case of an emergency. Increased traffic will make a tenuous situation even more dangerous for us as well as other families and individuals living in Live Oak and San Timoteo Canyons. We have large animals that require trucks and trailers to evacuate in emergencies quickly and safely.

My commute times for work have increased with increased housing density at Oak Valley and 10 fwy exit. Live Oak is my quickest and safest route for commuting and evacuation. Traffic conditions on the canyon roads has increased and we are having increased accidents. Train traffic and incidents like last Friday's train vs. vehicle and last year's train vs. pedestrian greatly impact our ability to enter/exit canyons roads.

The impact of a warehouse development and subsequent housing developments will negatively and dangerously impact the safety of your citizens and those of us in the Canyon areas, as well as negatively impact the health and welfare of all of us.

Sincerely,
Dorre Yamashiro
08/25/2025 City Council Agenda
820

From: Dan Hill
To: Public Comment; Kim J Metzler, CMC, CPM
Subject: Yucaipa Warehouse Project @ I-10 and Live Oak Canyon Road Date: Monday, September 23, 2024 9:48:28 AM
Really bad Idea...

Dangerous traffic area -Freeway already overtaxed by new housing/new warehousing at live Oak.

Known wildlife corridor..

Quality of current rural life style- noise, air pollution from Diesel trucks idling on overcrowded freeway...won't even handle current traffic due to housing situation/overbuilding...

Current warehousing in Highland/San Bernardino/off 60 freeway near Marino Valley corridor — Sitting unused -way overbuilt...

Don't care of tax dollar/building permit, etc. money. You will destroy our quality of life and health -the reason we live here.

I am 5th generation to Redlands/Yucaipa area. My two kids live here-6th generation- Redlands/Yucaipa. I did not move to downtown L.A.-nor will I live there Harold Daniel Hill
Please don't destroy our surroundings and way of life 'Him HiI Thank you for hearing me and my Family
08/25/2025 City Council Agenda
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From: Ana Sauseda, MMC
To: James Dodaro
Cc: Tara Davis
Subject: RE: Letter in favor of Southwestern Warehouse project Date: Monday, September 23, 2024 9:42:00 AM
Attachments: COYSECONDARY3 7916fdb3-bec5-493a-b982-1609ace2deba.pnq Good Morning,
Your letter has been received and will be provided to the City Council.

Ana Sauseda, MMC
Director of General Services/City Clerk
City of Yucaipa
City Hall • 34272 Yucaipa Blvd • Yucaipa, CA 92399
Office: 909-797-2489 Ext. 230
www.yucaipa.gov
From: James Dodaro
Sent: Sunday, September 22, 2024 12:21 PM
To: Ana Sauseda, MMC
Subject: Re: Letter in favor of Southwestern Warehouse project To whom it may concern,
Please find attached my updated letter in support of the Pacific Oaks Commerce Center Development project. Please submitted this document to the project packet being delivered to the Yucaipa City Counsel and the associates currently dated for the hearing on September 23, 2024.

Previously I sent in a document in support of the Pacific Oaks Commerce Center Development but I could not find the specific name of the project on the Yucaipa web site it is the hearing on Sept 23, 2024.

I plan on attending the hearing and speaking to encourage the City to recognize the economic value and opportunities Warehouse job roles can provide young unskilled individuals with a solid foundation for building a career in warehouse and logistics operations and opportunity to pursue college to advance to advanced career choices..

Thank you for your time.

Sincerely,
08/25/2025 City Council Agenda
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Tames F. Dodaro
On Friday, September 20, 2024 at 04:17:45 PM PDT, James Dodaro wrote:

To whom it may concern,
Please find attached my letter in support of the South Western Warehouse project.

Since I could not find the specific name of the project on the Yucaipa web site it is the hearing on Sept 23, 2024
The only reference I could associate is CASE NO: 24-044/GPA/SPA: Freeway Corridor Specific Plan Update.

Thank you for your time.

James F. Dodaro
08/25/2025 City Council Agenda
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From: Ana Sauseda, MMC
To: Doua Palmer
Cc: Tara Davis
Subject: RE: Please VOTE IN FAVOR of the Freeway Corridor Specific Plan Update and the Pacific Oaks Commerce Center Date: Monday, September 23, 2024 9:43:43 AM
Attachments: COYSECONDARY3 7916fdb3-bec5-493a-b982-1609ace2deba.pnq Good Morning,
Your letter has been received and will be provided to the City Council.

Ana Sauseda, MMC
Director of General Services/City Clerk
City of Yucaipa
City Hall • 34272 Yucaipa Blvd • Yucaipa, CA 92399
Office: 909-797-2489 Ext. 230
www.yucaipa.gov
From: Doug Palmer
Sent: Thursday, September 19, 2024 8:42 PM
To: Ana Sauseda, MMC
Subject: Please VOTE IN FAVOR of the Freeway Corridor Specific Plan Update and the Pacific Oaks Commerce Center
Dear Mayor and City Councilmembers:

I am writing to express my strong SUPPORT FOR your approval of the Pacific Oaks Commerce Center and Yucaipa Freeway Corridor Specific Plan Update.

I care about Yucaipa. I have property interests in Yucaipa and an engineer for ESRI while living here. I've carefully considered both sides of the issues and concerns of these proposals and believe they are in fact good for Yucaipa.

You have the important and difficult responsibility of deciding what is best for all citizens and what will shape a good future for Yucaipa. I hope my review of the issues and concerns will help you with your decision. I'm confident these proposals can preserve the unique character of Yucaipa while providing needed jobs and economic growth.

Below are some key reasons these proposals deserve your support. 08/25/2025 City Council Agenda
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1. Balanced Growth That Preserves Yucaipa Charm
Concern: "The warehouse project will destroy Yucaipa's rural lifestyle." Facts:

The Pacific Oaks project is strategically located south of the freeway which will minimize disruption to residential and rural areas.

The project is hidden from view and preserves the hillsides.

This project concentrates growth where it makes sense, preserving the character of Yucaipa's neighborhoods and agricultural zones. It's a practical solution that allows for new jobs and revenue without sacrificing the lifestyle of Yucaipa. This is about smart, managed growth that respects what makes Yucaipa special.

2. Local Jobs for Local People
Concern: "The jobs won't benefit locals."
Facts:

The project provides 1,000s of much -needed local employment, reducing the need for residents to commute out of town.

The Jobs are diverse, including, management, tech, logistics, construction, maintenance and general employment — roles that match the skills of many Yucaipa residents.

By offering local employment opportunities, Yucaipa can keep its citizens close to home, benefiting both families and the local economy.

3. New Revenue Without Burdening Residents
Concern: "This development will increase costs and traffic." Facts:

The Pacific Oaks project provides a net positive increase in revenue to the city — unlike residential which is a cost to the city. The revenues generated can fund city services and infrastructure improvements, while reducing the burden on local taxpayers.

The revenues from this project allow Yucaipa to address pressing infrastructure needs without raising taxes on residents. It's a proactive solution that ensures the city more resources to invest in roads, schools, and public services without putting extra pressure on homeowners or small businesses. Supporting this project is a way to help future -proof our city's finances.
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4. Planned Infrastructure Upgrades
Concern: "Development will overwhelm our roads and infrastructure." Facts: The project will provide significant infrastructure improvements, including roads, road widenings, modern signalization and traffic handling, water systems, sewer systems, utilities and more. The improvements have been designed by professionals to manage the impacts of the project while planning for the community now and in the future.

These enhancements will address existing issues while preparing the city for future growth. Rather than overburdening the system, the project is part of the solution.

5. A Plan that Reflects Community Input
Concern: "This plan ignores residents' concerns."
Facts: The project has incorporated significant feedback from the community, ensuring it aligns with local values.

The project shows that the developer has demonstrated a willingness to listen and adapt the project based on feedback from city leaders, residents, and environmental consultants.

Their thoughtful approach has resulted in a plan that includes natural and landscaped opens spaces, preservation of hillsides and natural features, and other features that reflect Yucaipa's priorities. It's clear that this is not a one -size -fits -all development but a tailored solution for Yucaipa.

6. Protecting Residents from Higher Taxes
Concern: "Small businesses alone can fuel Yucaipa's needs and growth." Facts: Larger developments like Pacific Oaks are an important part of our modern society, serving the needs of most citizens in Yucaipa. It provides essential strength and longevity meet the needs of Yucaipa and to diversifying our tax base and reducing the need for higher taxes on residents.

Without projects like this, the financial burden on residents will grow, especially as the city expands. By approving Pacific Oaks, you're ensuring a steady stream of revenue that helps cover rising costs without forcing homeowners or small businesses to shoulder the load.

In summary, the Pacific Oaks project offers Yucaipa a path forward that provides local jobs, preserves our rural character, and strengthens our city's finances. I've looked closely at both sides and am confident that supporting this project is the right decision 08/25/2025 City Council Agenda
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for the future of Yucaipa.

Thank you for your time and thoughtful consideration of this important issue.

Sincerely,
Doug
Software Engineer and Analyst
08/25/2025 City Council Agenda
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From: Sandra Thompson
To: Public Comment
Cc: Sandra Thompson
Subject: Fwd: Freeway Corridor Specific Plan update and the Pacific Oaks Commerce Center Date: Monday, September 23, 2024 10:10:28 AM
To the City Council:

We have been residents of Live Oak Canyon since 1978 before Yucaipa became a city. We established a veterinary practice in Yucaipa in 1978 to help care for the needs of the equine community and small animals of the surrounding neighbors and residents of the local communities. We have watched Yucaipa grow from the small rural and peaceful town filled with horses, sheep, chickens, turkeys, and pets to what it is today. It was safe, quaint, and friendly. With development, many changes have occurred and it has become ever increasingly difficult to maintain the flavor of the community that we all enjoyed being a part of. We do have a chance to maintain the quality of life that was once the drawing point of living in Yucaipa. By carefully choosing what type of sales tax businesses that are allowed to build in and near this beloved community we can strive to maintain a high quality of life for our residents.

A similar matter was referred to the voters in 2000, Measure O. Although it was a time when uptown was struggling, the community of Yucaipa unanimously agreed and valued the small town atmosphere of the commercial district. The people spoke and sales tax revenues were not the primary decision for development of their city. Bigger commercial developments went elsewhere and mom and pop businesses were able to survive thanks to the bold statement about quality of life and the dream to remain rural in a time of over -running development.

A warehousing development is a poor choice for a way to gain revenue for the city. Not only is the warehouse industry already in decline, but the congestion, poor air quality, noise and light pollution and traffic congestion that the trucks will bring will most certainly deter visitors to our city and businesses. The Live Oak Canyon freeway ramps are already overburdened with vehicles --cars are lining up a good mile to get off of the freeway in the daily commute.

The trucks traveling up and down the Yucaipa grade are causing slow downs that contribute to the congestion and accidents that we face all too frequently. Trucks that don't want to fight the traffic from the 60 freeway to Beaumont and the I 10 now travel through San Timoteo Canyon and come up and down Live Oak Canyon Road. This scenario will be a common occurrence should the warehouse intersection be built on Live Oak Canyon Rd. There have been numerous deadly accidents involving motorists and cyclists on Live Oak Canyon and more vehicles on this road in the planned area will cause even more lethal scenarios.

Besides the obvious congestion and pollution concerns, has anyone asked about the environmental impact on our beautiful canyons and one of the last vestiges for wildlife in the San Timoteo and Live Oak Canyon? Endangered species, habitat corridors, open spaces for native species of animals and plants? The Redlands Conservancy has been active in setting aside land for that reason and there is a State Park In San Timoteo Canyon slowly being developed, and there is a movement to support agri-tourism in the rural areas. Wouldn't it be nice to develop our beautiful areas for the benefit of healthy families and an outdoor lifestyle for Yucaipans to enjoy and share with others? Development will adversely affect what is left 08/25/2025 City Council Agenda
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of our open spaces. People flock to these areas for hiking and will visit Yucaipa's restaurants and businesses and that is why the quality of life issue is so important to Californians as we are losing forever habitat for rural needs all throughout the state. Does Yucaipa want to cherish what we have left or just grow the same type of blight that we are observing in other urban populations?
This proposed development will adversely affect EVERY citizen of Yucaipa and to say that the increased traffic is not an issue is absurd. As we have pointed out, there are many reasons to come up with a better way to finance the city's coffers than a business model that does nothing to help the citizens of the Inland Empire, and especially those in Yucaipa.

This decision to approve this development will have catastrophic consequences to the town of Yucaipa forever. The city council needs to honestly look at the needs and wants of the voters that pay their salaries, not developers interests, most of whom are not and will not be living in Yucaipa or the surrounding communities.

In conclusion, we object to the warehouse development due to:

1. Truck and congestion affecting all routes near Yucaipa, the I 10, Live Oak Canyon Rd., San Timoteo Canyon Rd. Yucaipa Blvd.

2. Habitat loss to wildlife, plants, and humans. A negative environmental impact and degradation of existing preserves and wildlife corridors.

3. Worsening air quality. We have the worst air in the nation that has become even further polluted since the warehouse industry began in the Inland Empire and Redlands.

4. Safety --increase in vehicles on the roads and in front of our homes and businesses. Increase in accidents.

5. The Warehousing industry is on the decline. Why invest our last vestiges of open land to an eyesore business model that does nothing to bring anything positive to the community and just brings a small number of low paying commuter jobs.

Sincerely,
Sandra Thompson
08/25/2025 City Council Agenda
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From: Sandra Thompson
To: Public Comment; Ward Thompson; Sandra Thompson
Subject: Freeway Corridor Specific Plan?Pacific Oaks Commerce Center Date: Monday, September 23, 2024 10:19:06 AM
To the City Council of Yucaipa,
I have resided and practiced as a veterinarian in the Yucaipa -Redlands area for more than 42 years.

During this period I have watched with no little dismay as productive fertile farmland along 1-10 in Redlands has given way to industrial growth and the erection of warehouses. Now there is a proposal to bring that sort of enterprise to Yucaipa, specifically the pristine pasture lands in and adjacent to Live Oak Canyon.

I appeal to you to deny this plan for many reasons:

1. The quality of warehouses as a business does not provide quality employment. Minimum or near minimum wage jobs will be the norm. Perhaps consider attracting industry that fosters high tech employees like that of Sorenson Engineering, a homegrown quality business with a large quality worker roster.

2. Truck traffic is undesirable. There is already too much traffic congestion on the 1-10 freeway as it is. Live Oak Canyon, narrow and windy, will become an unwitting unsafe bypass for trucks proceeding to Highway 60. Air and noise pollution especially microparticulates will affect nearby residents and businesses.

3. The proposed project will adversely affect wildlife in the area. This area is part of a wildlife corridor and species including the endangered mountain lion will have their livelihoods disrupted.

4.The esthetic quality of life for Yucaipa residents and passers-by will forever be negatively altered.

You will never be able to replace nature's beauty by a man-made project with any amount of revenue.

Yucaipa does not have to destroy its inherent beauty for the fast buck.

So, I believe that Yucapa's future is in your hands. Do you have the integrity to do what is right for its citizens? Or will you cave to outside interests for money that might solve a few short term problems only to create a myriad of future problems with no remedy and sacrifice the unique quaint beauty of Yucaipa? Sincerely,
Ward Thompson
8J ( Reply ) ( Forward )
08/25/2025 City Council Agenda
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From: S Gordon, MD
To: Public Comment
Cc: S Gordon, MD; Kim J Metzler, CMC, CPM
Subject: Respectful Opposition to the proposed Yucaipa Corridor Plan Date: Monday, September 23, 2024 12:08:15 PM
Good day!
My sincere thanks to you for allowing me to comment on the proposed Yucaipa Corridor Plan to which I am OPPOSED.

I am in full agreement that an owner of property has every right to sell their property. I am also aware that the descendents of the original purchaser of this property have their many and varied reasons to sell as I'm sure they view this property as their rightful inheritance. I have no argument with that point.

I ask the following of the City Council Members: Could this project please be tabled until a mutually agreeable solution that would NOT involve warehouses and high density housing be proposed?
My concerns include the tangibles and the intangibles:
• The Redlands -Yucaipa I-10 corridor currently has high density traffic on a daily basis. Eastbound traffic on I-10 starts a massive slow down on most days around 1400 hours. Westbound traffic on I-10 each morning in this corridor is highly congested. The project as currently proposed has the potential to further worsen this situation.
• Noise pollution
• Light pollution
• Significant change in our quality of life along this corridor that will not only affect us now, but for FUTURE GENERATIONS to come
• bestruction of wildlife habitat. This housing and warehouse proposal will directly abut the beautiful Herngt "Aki" Preserve. The argument that these warehouses cannot be seen from I-10 is a false equivalency • bestruction of KNOWN wildlife corridors in this area adding further stress upon wildlife resulting in their incursion into populated areas. In most instances, it is the wildlife who suffer the most from this incursion as there are very few avenues for rehabilitation elsewhere. This is more pronounced this year given the mass destruction due to the recent wildfires in our area.

This beautiful region has provided a respite for ALL OF US from the noise, light pollution, and polluted air from cities further west of us. Our air is already stressed. One need only look at what happened to the city of Bloomington when they allowed warehouses and trucking to consume their city. Bloomington is forever changed.
08/25/2025 City Council Agenda
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I very respectfully ask the members of the council to put their heads together to find a solution that will PRESERVE the beauty of our area. I am asking you to please preserve our QUALITY of life. Again, I understand why the descendents of the original purchaser of this property want to sell, but I sincerely hope that in selling this property that they consider a better way to be stewards of this land.

The financial reward from the sale of this property will allow them to leave and not face the high density housing and warehouses. PLEASE. Please consider another workable solution that will preserve quality of life for all.

Thank you for your consideration of my concerns.

Respectfully,
Susi Gordon, Mb
biplomate, The American Board of Radiology/Radiation Oncology Redlands, CA
08/25/2025 City Council Agenda
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23 September2024
Dear Members of the Yucaipa City Council:

Please vote to deny the update of the Freeway Corridor Specific Plan (FCSP) and any related developments, including the Pacific Oaks Commerce Center; the related Subsequent Environmental Impact Report (SEIR); and the related Conditional Use Permit (CUP), all referred to below as the "proposed project."
I strongly urge you to deny the proposed project because it would create disastrous conditions for the residents of Yucaipa, the adjacent City of Redlands; and the region.

Following are 12 reasons to deny the proposed project:

1. After careful review, Yucaipa's own Planning Commission denied the proposed project.

2. The proposed project's SEIR (see Yucaipa City Council agenda packet from 8/26/24) reported that air quality impacts and greenhouse gas emissions from the project cannot be mitigated. Our region suffers some of the worst air quality in the nation.

Increased air -quality impacts put the health and well-being of Yucaipa residents — and those of surrounding communities —at risk.

3. Diesel fumes contain known human carcinogens; increasing by thousands the number of idling diesel trucks in Yucaipa and adjacent Redlands will create a public health hazard. (See the American Cancer Society's website:
https://www.cancer.org/cancer/risk-prevention/chemicals/diesel-exhaust-and- cancer.html#)

4. Daily traffic is already unmanageable in the area of the proposed project. Adding thousands more cars and diesel trucks on I-10—and on local roads already damaged by flooding —will create serious safety issues and a traffic nightmare for local residents.

5. Thousands of your constituents in Yucaipa and residents in adjacent southeast Redlands do not want this project to go forward because it would damage their health and their quality of life.

6. The proposed project's SEIR (see Yucaipa City Council agenda packet from 8/26/24) did not mention or address impacts on endangered Southern California mountain lions, whose habitat and travel corridors include the project area. Thus, the SEIR is flawed and needs to be amended.

7. The proposed project is in a high -risk wildfire zone; building such a massive commercial and residential development in this zone would put thousands of residents and employees at unnecessary risk.
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8. Climate change has already created more intense rainstorms, flooding and runoff in Yucaipa Creek and other local waterways. Adding more than 5 million square feet of impermeable surfaces to this area will create a flooding nightmare on this creek, which is already undercutting Live Oak Canyon Road, a regional artery. Projected repair costs for this road already run into the millions of dollars.

9. The proposed project would irreparably damage ecological integrity and vistas in City of Redlands' nature preserves adjacent to the project. These preserves, including Herngt'Aki' and the Sahatapa Trail at Gateway Ranch, provide opportunities for improving physical and mental health to thousands of visitors annually, from across Southern California.

10. The projected financial benefits of the project are unlikely to accrue, because the warehouse economy in the Inland Empire is facing a downturn. (See 2024 articles in the Wall Street Journal: https://www.wsj.com/articles/warehousing-demand-is- starting-to-shrink-19c5feaa and the Los Angeles Times:
https://www.latimes.com/business/story/2024-02-21/inland-empires-logistics- warehouse-trucking-economy-layoff-downturn.)

11. Updating a specific plan; certifying a related SEIR; and approving a CUP with a single public hearing and a single vote is procedurally, and possibly legally, questionable.

12. Attorneys argue that many aspects of the project do not fall within the bounds of CEQA and other laws (see included pdf below: public comments to the Yucaipa Planning Commission from Blum, Collins & Ho LLP, excerpted from Yucaipa City Council agenda packet from 8/26/24).

Once again, please deny the proposed project. It is bad for the health, safety, and environment of local residents and the region —and it will not bring the promised economic boon to the area.

Thank you for considering these reasons, and all the other public comments you have received, in making your decision. You have the power to make a positive impact on the health and well-being of your constituents by denying this proposed project.

Sincerely,
Carol L. Blaney, MS botany, MS resource interpretation
Inland Empire resident
08/25/2025 City Council Agenda
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BLUM, COLLINS & HO LLP

ATTORNEYS AT LAW

AON CENTER
707 WILSHIRE BOULEVARD
SUITE4880
LOS ANGELES, CALIFORNIA 90017
(213) 572-0400
March 25, 2024
VIA EMAIL TO:
[email protected]
Subject: Comments on Freeway Corridor Specific Plan Subsequent SIR (SCH NO. 2006041096) Dear Mr. Matlock,
Thank you for the opportunity to comment on the Subsequent EIR (SIR) for the proposed amendments to the Freeway Corridor Specific Plan. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance (GSEJA). Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

1.0 Summary
The project proposes amendments to the existing Freeway Corridor Specific Plan (FCSP). The proposed project would result in a total of 2,472 residential units and 5,093,265 square feet of nonresidential uses (3,992,503 square feet of Business Park (industrial) uses and 1,100,761 square feet of Regional Commercial uses). The proposed project results in an increase of 25 residential units, 2,786,461 square feet of Business Park (BP), and a reduction of 2,278,976 square feet of Regional Commercial (RC) existing FCSP.

The proposed project also includes the construction and operation for buildout of the Pacific Oaks Commerce Center (two fulfillment center warehouse buildings totaling 2,054,000 square feet in area) in plamling areas BP 2 and BP 3 of the proposed FCSP. Building 1 proposes 1,032,500 square feet of warehouse are and 20,000 square feet of office use, for a total of 1,052,500 square feet of building floor area. Building 2 proposes 981,500 square feet of warehouse and 20,000 08/25/2025 City Council Agenda
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Mardi 25, 2024

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square feet of office use, for a total of 1,001,500 square feet of building area. Each building also would allow up to 25 percent of the building square -footage for cold -storage uses.

Each warehouse building provides 178 truck docking bays for a total of 356 truck docking bays in the project area. Building 1 provides 410 truck parking stalls and 515 passenger car parking spaces.

Building 2 provides 326 truck parking stalls and 475 passenger car parking spaces. Building 2 is also connected to an additional parking lot that provides 322 truck/trailer parking stalls in a tandem and triple tandem configuration. This parking lot would be on a separate parcel and would be used either for overflow parking or as a standalone use. As a result, the Pacific Oaks Commerce Center would provide for a total of 1,058 truck parking stalls and 986 passenger car parking spaces.

The following discretionary actions are necessary to implement the proposed project:

1. Adoption of the proposed amendments to the Freeway Corridor Specific Plan.

2. General Plan Amendment to change the Land Use Map to correspond to the updated FCSP land use plan and Hillside Overlay.

3. Certification of the SEIR.

4. Approval of a Tentative Tract Map (TTM) 20533 for the Pacific Oaks Commerce Center Project.

5. Adoption of the Findings of Fact and Statement of Overriding Considerations due to the project's significant and unavoidable impacts to Air Quality, Greenhouse Gas Emissions, and Noise.

6. Adoption of the Mitigation Monitoring Program.

5.3 Air Quality, 5.6 Energy, and 5.8 Greenhouse Gas Emissions Please refer to attachments from SWAPE for a complete technical commentary and analysis.

The EIR does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. The EIR provides general information about the census tract's Calenviroscreen scores but does not provide meaningful analysis regarding the health impacts and effects of severe pollution rates. This is especially significant as the surrounding community is highly burdened by pollution. According to CalEnviroScreen 4.01, Ca1EPA's screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed projects census tract (6071008500) ranks worse than 80% of the rest of the state in overall pollution burden. The proposed project's census tract and surrounding community bears the impact of multiple sources of pollution and is more 1 Ca!EnviroScreen 4.0 https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 08/25/2025 City Council Agenda
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polluted than average on several pollution indicators measured by Ca!EnviroScreen. For example, the project census tract ranks in the 100th percentile for ozone burden, the 53rd percentile for PM

2.5 burden, the 55th percentile for diesel particulate matter burden, and the 69th percentile for traffic impacts. All of these environmental factors are attributed to mobile source emissions from passenger cars and heavy truck/trailer activity in the area, which will increase as part of the proposed project. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure2. The very small particles of diesel PM can reach deep into the lung, where they can contribute to a range of health problems. These include irritation to the eyes, throat and nose, heart and lung disease, and lung cancer3.

The census tract ranks in the 76th percentile for contaminated drinking water and 60th percentile for groundwater threats. Poor communities and people in rural areas are exposed to contaminants in their drinking water more often than people in other parts of the state. People who live near contaminated groundwater may be exposed to chemicals moving from the soil into the air inside their homes5.

The census tract also ranks in the 78th percentile for hazardous waste facility impacts. Hazardous waste generators and facilities contribute to the contamination of air, water and soil near waste generators and facilities can harm the environment as well as people6.

The census tract also bears more impacts from cleanup sites than 58% of the state. Chemicals in the buildings•,'soil, or water at cleanup sites can move into nearby communities through the air or movement of water. The census tract also ranks in the 45th percentile for toxic releases. People living near facilities that emit toxic releases may breathe contaminated air regularly or if contaminants are released during an accident8.

The State of California lists three approved compliance modeling softwares9 for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. Ca1EEMod is not listed as an approved 2 OEHHA Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-guality-ozone 3 OEHHA Diesel Particulate Matter https://oehha.ca.gov/calenviroscreen/indicator/diesel-particulate- matter
4 OEHHA Contaminated Drinking Water https://oehha.ca.gov/calenviroscreen/drinking-water S OEHHA Groundwater Threats https://oehha.ca.gov/calenviroscreen/indicator/groundwater-thce ats 6 OEHHA Hazardous Waste Generators and Facilities
https://oehha.ca . gov/calenviroscreen/indicator/hazardous-waste-generators-and-facj lities 7 OEHHA Cleanup Sites https://oehha.ca.gov/calenviroscreen/indicator/cleanup-sites 8 OEHHA Toxic Releases https://oehha.ca.gov/calenviroscreen/indicator/toxic-releases-facilities 9 California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca.gov/programs-and-topics/pro grams/building-energy-efficiency-standardsJ2m2- building-energy-efficiency-1
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software. The Ca1EEMod modeling does not comply with the 2022 Building Energy Efficiency Standards and under -reports the projects significant Energy impacts and fuel consumption to the public and decision makers. Since the EIR did not accurately or adequately model the energy impacts in compliance with Title 24, it cannot conclude the project will generate less than significant impacts and a finding of significance must be made. A revised EIR with modeling using one of the approved software types must be prepared and circulated for public review in order to adequately analyze the projects significant environmental impacts. This is vital as the EIR utilizes Ca1EEMod as a source in its methodology and analysis, which is clearly not an approved software.

5.11 Land Use and Planning
The SEIR provides a statement that, "Since the EIR was certified, the City has updated its General Plan (2016), which now includes the land uses in the Approved Project. As a result, the Approved Project and Proposed Project would be consistent with the land uses in the 2016 General Plan and its policies pertaining to land use and planning for residential and nonresidential uses." This statement is nonsensical, erroneous, and misleading to the public and decision makers. The proposed project is clearly not consistent with the land uses of the 2016 General Plan. This is illustrated by Table 3-6 Project Approvals Needed that states the proposed project requires an "Amendment of the General Plan Land Use Map to correspond to the updated FCSP land use plan and Hillside Overlay." The EIR has not provided any meaningful discussion of the proposed land use changes or the project's inconsistency with the existing Land Use Map.

The EIR is inadequate as an informational document and a revised EIR must be prepared with a consistency analysis with all General Plan goals and policies, including the following:

1. Housing Element Strategy 4: Freeway Corridor Specific Plan

2. Housing Element Program 11: Freeway Corridor Specific Plan

3. Goal HN-2: Housing Sites. Adequate sites through General Plan land use designations and specific plans that provide opportunities for a range in type, tenure, and affordability of housing in appropriate locations.

4. Policy CDL-1.1 Places to Live. Provide sites for a range of housing types, locations, and densities in a variety of neighborhood settings equipped with amenities that support a high quality of life.

5. Policy CDL-1.2 Places for Commerce. Provide sites for a range of commercial uses, including shopping, dining, entertainment, and offices that provide a strong employment base and offer local services; improve commercial properties along I-10 through infrastructure, aesthetics, and development strategies.
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6. Policy CDL-7.2 Housing. Expand the range of housing opportunities (single, multiple -family, and/or mixed -use housing) to meet the needs of a variety of household types, sizes, and income levels.

7. Policy CDL-7.4 Safe and Efficient Circulation. Ensure a safe and efficient circulation system that adequately supports the anticipated level of traffic in and around the specific plan area.

8. Policy CDL-7.6 Adjacent Development. Comprehensively plan the area with consideration of other contiguous areas to ensure compatible and complementary development, circulation patterns, infrastructure, and services.

9. Policy CDL-7.7 Rural Character. Comprehensively plan the area so that the important rural community character and sense of place is retained, as reinforced by significant views to open space and hillsides.

10. Policy CDL-7.8 Hillside Development. Ensure that the plan and subsequent development complies with the City s development code related to hillside development; protect ridgelines and scenic views. CDL-7.9 Area Resources. Protect and preserve sensitive wildlife habitat, watelways, wildlife corridors, cultural and paleontological resources, and other assets in accordance with state and federal law.

11. GOAL CDL-10: DESIGN QUALITY Thoughtfully designed projects and buildings evidenced by creative site design, quality architecture, integration with the natural environment, and sensitive land use transitions.

12. Policy CDL-10.6 Parking. Design parking lots and structures to be functionally and visually integrated and connected with the comprehensive project design; off-street parking lots should not dominate the street scene.

13. Policy CDL-10.8 Safe Community Design. Require the use of CPTED principles (Crime Prevention Through Environmental Design), including creating opportunities for eyes on the street" and clearly distinguishing between public and private spaces to enhance community safety.

14. Policy CDL-10.9 Building Materials. Use high -quality, natural building materials that evoke a sense of quality and permanence, such as stucco, plaster, stone, and wood; natural colors and textures are preferred.

15. Policy CDL-10.10 Building Massing. Reduce the bulk and perceived size of large buildings by dividing their mass into smaller parts, stepping down to adjacent structures, recessing openings for doors/windows, and using pedestrian -scale features; single -plane massing is discouraged.

16. Policy CDL-10.12 Architectural Detail. While recognizing sensitivity to budget, require publicly visible sides of a building to contain architectural detail and fa9ade articulation, strong patterns of shade and shadow, and integrated architectural detail; blank walls are discouraged. 08/25/2025 City Council Agenda
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17. Policy CDL-11.2 Land Use Change. Where opportunities for land use changes arise, seek input from property owners, the surrounding neighborhood or district, and other stakeholders during the consideration process so as to determine appropriateness or inform strategies.

18. Policy CDL-11.3 Project Compatibility. Strive to ensure appropriate transitions in scale, density, and intensity between residential and nonresidential uses; between adjacent residences or uses within a defined neighborhood; and within areas of different densities.

19. Goal ED-3: Freeway Corridor. A fully developed Freeway Corridor that provides office -based employment, accommodates large folmat retailers, and attracts consumer spending from the region while maintaining and enhancing a unique sense of place in Yucaipa.

20. Goal ED-4: Fiscal Balance. A fiscally well-balanced City that generates sufficient revenues to continuously reinvest in public facilities, infrastructure, and community services that support the premier quality of life in Yucaipa.

21. Policy ED-4.1 Fiscal Return of Land Use and Development. Ensure that shorter -term actions and longer -term development patterns result in a mix of land use and types of development that will generate 10 percent more in municipal revenues than they will demand in costs for public facilities and services.

22. Policy T-1.1 Roadway Buildout. Complete the circulation system by constructing or ••• • improving roadways consistent with Figure T-1; allow modified standards where appropriate to allow for transit, bicycle facilities, sidewalks, and on -street parking to be sensitive to adjacent land uses, districts, and roadway users.

23. Policy T-2.1 Level of Service. To promote the safe and efficient movement of vehicular traffic, maintain a minimum level of service (LOS) Con all intersections and road segments except for two conditions: 1)At roadway intersections where traffic movements are controlled by roundabouts, LOS D shall be acceptable (e.g., average control delay of 30 seconds per vehicle or better). 2) On roadway segments where a roundabout controls at least one of the intersections at the ends of the segment, the lower half of LOS D shall be acceptable (e.g., V/C ratio of 0.849 or better).

24. Policy S-6.3 Noise Insulation and Vibration Standards. Require new projects to comply with noise insulation and vibration reduction standards in local, regional, state, and federal regulations, as applicable.

25. Policy S-6.5 Development Patterns. Locate new development in areas where noise levels are appropriate for the use. Limit development of noise -producing uses adjacent to noise -sensitive receptors and require that noise producing land uses have adequate mitigation.

26. Policy S-6.6 Land Use -Noise Compatibility. Require mitigation of exterior and interior noise to the levels in Table S-1. Encourage the use of building design, site plamling, landscaping, and other features to reduce noise levels.

27. Goal S-7: Air Quality and Climate Change Clean and healthful air resources that promotes public health, protects the natural environment, and mitigates local impacts to climate change. 08/25/2025 City Council Agenda
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28. Policy S-7.1 Integrated Planning Integrate air quality planning with land use, economic development, and transportation -related planning to allow for the control and management of air quality.

29. Policy S-7.3 Sensitive Land Uses. Protect residents from health risks by avoiding the placement of sensitive uses and land uses generating high levels of pollutants within close proximity to one another. Appropriate distances shall be determined based on best available knowledge.

30. Policy S-7.6 Greenhouse Gas Reductions. Reduce community -wide greenhouse gas emissions locally through the implementation of Yucaipa s Climate Action Plan; actively support regional efforts to reduce greenhouse gases throughout the county.

Table 5.11-1 2020-2045 RTP/SCS Consistency Analysis provides a misleading and erroneous consistency analysis with SCAG's 2020-2045 Connect SoCal RTP/SCS. Due to errors in modeling, modeling without supporting evidence (as noted throughout this comment letter and attachments), and the EIR's conclusion the project will result in significant and unavoidable cumulatively considerable impacts to Air Quality, Greenhouse Gas Emissions, and Noise, the proposed project is directly inconsistent with Goal 5 to reduce greenhouse gas emissions and improve air quality, Goal 6 to support healthy and equitable communities, and Goal 7 to adapt to a changing climate. Additionally, the table provides other misleading analysis such as concluding the proposed project is consistent with RTP/SCS Goal 9 to encourage development of diverse housing types because the project is consistent with the City's 6th Cycle Housing Element, even though the proposed project is directly inconsistent with the Housing Element and RHNA sites inventory as described in the Population and Housing discussion below. The EIR must be revised to include a finding of significance due to these direct inconsistencies with SCAG's 2020-2045 Connect SoCal RTP/SCS.

Further, the EIR omits discussion and analysis regarding the project's inconsistency with other land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. For example, the project will have a significant and unavoidable cumulatively considerable impact to Air Quality because it will exceed the assumptions in the AQMP and generate construction and operational -source emissions that exceed the applicable thresholds. The project will also have a significant and unavoidable cumulatively considerable impact to Greenhouse Gas Emissions because the operational emissions will exceed the applicable thresholds and will impede long-term GHG reduction goals of various plans at the State and Regional level (e.g., for 2030 and 2050) adopted for the purpose of reducing GHG emissions. The Land Use and Planning analysis omits any discussion regarding inconsistencies with the AQMP and California s statewide GHG reduction goals for 2030 and 2050. The EIR must be revised to 08/25/2025 City Council Agenda
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include these significant and unavoidable cumulatively considerable impacts for analysis and include a finding of significance.

The EIR does not include any information regarding the buildout conditions of the City's General Plan in order to provide an adequate and accurate environmental analysis. The EIR must be revised to provide the horizon year of the City's current adopted General Plan, the total developable building floor area analyzed within the Industrial land use designation, and cumulative development since adoption of the General Plan to ensure that the proposed project is within the General Plan EIR's analysis, particularly since the EIR tiers from the General Plan EIR. For example, Table CDL-2: Yucaipa Buildout Summary of the General Plan indicates that the entirety of all Industrial land use designations will accommodate 1,1 00,000 square feet of building area. The proposed project's 3,992,503 square feet of Business Park (industrial) building area exceeds the entirety of the planned industrial growth for the entire incorporated City area by nearly four times.

Table CDL-2 also states the the entirety of all Industrial land use designations will generate 1,203 jobs, and the proposed project's 2,682 jobs is more than twice the identified growth. The growth generated by the proposed project was not accounted for by the General Plan or its EIR as the project requires a GPA to proceed. The growth generated by the proposed project was not anticipated by the City's General Plan, RTP/SCS, or AQMP. A revised EIR must be prepared with a finding of significance.

5.14 Population and Housing
The project faces two significant inconsistencies with statutory requirements. The first is inconsistency with State Housing Element Law. Pursuant to Government Code Section 658631°, a jurisdiction shall ensure that its housing element sites inventory "can accommodate, at all times throughout the planning period. its remaining unmet share of the regional housing need allocated pursuant to Section 65584" and "at no time... shall a city, county, or city and county by administrative, quasi-judicial, legislative, or other action permit or cause its inventory of sites identified in the housing element to be insufficient to meet its remaining unmet share of the regional housing need for lower and moderate -income households." Further, this Section states the following:
"No city, county, or city and county shall, by administrative, quasi judicial, legislative, or other action, reduce, or require or permit the reduction of, the residential density for any parcel to, or allow development of any parcel at, a lower residential density, as defined in paragraphs (1) and (2) of subdivision (g), unless the city, county, or city and county makes written findings supported by substantial evidence of both of the following:
10 Government Code Section 65863
https://leginfo.legislature.ca.gov/faces/codes displaySection.xblml?lawCode=GOV&sectionNum=65863 08/25/2025 City Council Agenda
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(A) The reduction is consistent with the adopted general plan, including the housing element. (B) The remaining sites identified in the housing element are adequate to meet the requirements of Section 65583.2 and to accommodate the jurisdictions share of the regional housing need pursuant to Section 65584. The finding shall include a quantification of the remaining unmet need for the jurisdictions share of the regional housing need at each income level and the remaining capacity of sites identified in the housing element to accommodate that need by income level." The City's HCD Certified Housing Element' 1 identifies multiple parcels within the project site with residential land use designations as part of its identified sites inventory to accommodate its RHNA allocation in Table 4-6: Summary of Housing Sites. Notably, one parcel within the proposed project proposes changes that are not consistent with the requirements of the Housing Element:

Housing Element
APN 030120135
Size: 10.0 Acres
RHNA: 200 Lower Income units (Extremely low, very low, and low income) Proposed Project
PA 8
98DU

4.1 Acres
PA9
91 DU

3.8 Acres
C2

7.7 Acres
The parcel 030120135 is identified as part of the City's RHNA sites inventory to accommodate 200 lower income units. This corresponds to proposed project areas PA 8, PA 9, and C2. The residential areas of the parcel are significantly smaller (7.9 acres) than the area identified in the 11 https://yucaipa.gov/wp-
content/uploads/dev svcs/housingelement/Yucaipa HousingElement Final October6 2022.pdf? t=1665 101647
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Housing Element. They also accommodate fewer dwelling units (189 units assumed to be market rate as the EIR has not provided any affordability analysis) than the Housing Element's identified 200 lower income units.

The EIR does not state that the proposed project will provide any lower income housing units, including the required capacity for 200 lower income units on parcel 030120135. Additionally, Table 4-7 Summary of Credits toward the 2021-2029 RHNA within the Housing Element states that Site Strategy #4: Freeway Corridor Specific Plan will provide for the development of 390 Lower Income Units. The EIR has not provided any information stating the project site will comply or facilitate development of 390 lower income (extremely low, very low, and low income) dwelling units. The EIR has not provided any analysis to demonstrate that the remaining sites identified in the Housing Element are adequate to meet the requirements of Government Code Section 65583.2 and to accommodate the jurisdictions share of the regional housing need pursuant to Government Code Section 65584 through the end of the 2021-2029 planning period, including the lower income RHNA. The EIR has not demonstrated that the City's Housing Element can accommodate at all times throughout the planning period its remaining unmet share of the regional housing need. The EIR must be revised to include a finding of significance e ause it has not demonstrated that the City can continue to accommodate its RHNA following the potential approval of the proposed project.

Additionally, the proposed changes to the RHNA sites inventory of the Housing Element due to the proposed project necessitate a General Plan Amendment application with required review and approval by HCD. The revised Housing Element must be submitted to HCD for review and certification prior to adoption of the proposed project in order to demonstrate the project will have less than significant impacts.

Further, the EIR has not demonstrated compliance with the Housing Crisis Act (HCA) of 2019/Senate Bill (SB) 33012/SB 813. Government Code Section 66300.5 and 66300.6 requires that all existing on -site housing (the EIR is deficient and misleading in that it does not state the actual quantity of residences on the project site and only provides a statement that the site includes "a limited number ofresidences") be replaced. Replacement housing must be offered to the existing occupants, and the replacement units must be affordable to lower income households. The EIR must be revised to demonstrate compliance with the Housing Crisis Act/SB 330/SB 8 in its entirety.
12 Housing Crisis Act of 2019/SB 330
https://leginfo.legislature.ca . gov/faces/billTextClient.xhtml?bill id=201920200SB330 13 SB 8 https://leginfo.legislature.ca.!!ov/faces/billTextClient.xhtml?bill id=202120220SB8 08/25/2025 City Council Agenda
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The EIR states that, "the Proposed Project would create 1,709 jobs (not including employment from the Pacific Oaks Commerce Center project). With the inclusion of the Pacific Oaks Commerce Center project, the total proposed employment of the FCSP would be 2,682 jobs." However, it does not discuss the methodology that resulted in this calculation. This does not comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). A revised EIR must be prepared to include detailed information on the methodology for quantifying the project's operational jobs for review, analysis, and comment by the public and decision makers in order to provide an adequate and accurate environmental analysis. There is also no quantification of construction employees required during the construction of the proposed project, or the areas from which construction/operational employees are traveling from. The EIR must be revised to include this information for analysis.

SCAG s Connect SoCal Demographics and Growth Forecast14 notes that the City will add 6,800 jobs between 2016 - 2045. Based on the EIR's calculation of 2,682 jobs for buildout of the entire project site, the project represents 39% of the City's job growth over 29 years. A single project accounting for this amount of the projected employment growth over 29 years represents a significant amount of growth. The EIR has not provided a cumulative analysis discussion of projects approved since 2016 and projects in the pipeline" to determine if the project will exceed SCAG s employment growth forecast or the City's General Plan growth projections.

5.17 Transportation
The EIR is misleading to the public and decision makers in its conclusion that the proposed project will have less than significant VMT impacts. For example, Table 5.17-4: Project Generated VMT Comparison of the Proposed Project to the Approved Project concludes that the proposed project will generate approximately 2.7 VMT (baseline year) and 6.1 VMT (horizon year) less than the existing FCSP, indicating less than significant impacts. However, this is nonsensical as it is essentially comparing the project to itself as the applicable threshold in lieu of comparing it to Citywide VMT. The EIR states that the Citywide VMT/SP threshold is 30.1 VMT. The proposed project's 31.2 VMT (baseline year) and 32.4 VMT (horizon year) per SP exceed this threshold and a finding of significance is required.

The VMT analysis has also underestimated the significance of the proposed project's VMT generation. The EIR has not analyzed the project's truck/trailer/delivery van activity. A revised 14 SCAG Connect SoCal Demographics and Growth Forecast adopted September 3, 2020 https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal demographics-and-growth- forecast.p_df? 1606001579
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EIR must be prepared to include all truck/trailer/delivery van activity for quantified VMT analysis.

The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution centers to smaller industrial parks and then to their final delivery destinations. Once employees arrive at the proposed project for work, they will conduct their jobs by driving truck/trailer/delivery vans across the region as part of the daily operations as a warehouse, which will drastically increase project - generated VMT. The project's truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. A revised EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity.

The EIR has not adequately analyzed the project's potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the project's potential to result in inadequate emergency access. There are no exhibits adequately depicting the available maneuvering and queueing space for trucks/trailers at the intersection of the project driveways and the adjacent streets. There are also no exhibits adequately depicting the onsite turning radius available for trucks maneuvering throughout the site. Notably, several areas for conflicts between passenger cars and trucks/trailers exist throughout the entirety of the proposed amendment to the FCSP and at the Pacific Oaks Commerce Center. For example, Figure 3-12 - Pacific Oaks Commerce Center Site Plan depicts the truck/trailer parking stalls on the west side of Building 2 in a tandem configuration within the truck/trailer loading dock coml. _ These parking stalls may be in use at any time and restrict movement on the site during maneuvering, particularly to accommodate the tandem configuration. The same is true for the the truck/trailer parking stalls on the north and south sides of Building 1 and the additional truck/trailer parking lot site to the west of Building 2, which includes parking stalls in both tandem and triple tandem configurations.

Additionally, the EIR has not provided any analysis of the available horizontal and vertical sight distance at the intersection of the project driveways and adjacent streets. Sight distance is the continuous length of street ahead visible to the driver. At unsignalized intersections, corner sight distance must provide a substantially clear line of sight between the driver of the vehicle waiting on the minor road (driveway) and the driver of an approaching vehicle. A revised EIR must be prepared with this analysis based on the American Association of State Highway and Transportation Officials (AASHTO) Stopping Sight Distance requirements.

7.0 Alternatives
The EIR is required to evaluate a reasonable range of alternatives to the proposed project which will avoid or substantially lessen any of the significant effects of the project (CEQA § 15126.6.) 08/25/2025 City Council Agenda
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The alternatives chosen for analysis include the No Project (Approved Project) Alternative (existing FCSP alternative), Reduced Warehousing Intensity Alternative, and the Increased Open Space -Conservation Alternative. The EIR does not evaluate a reasonable range of alternatives as only two alternatives beyond the required No Project alternative are analyzed. The EIR does not include an alternative that meets the project objectives and also eliminates all of the project's significant and unavoidable impacts. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed decision making (CEQA § 15126.6). This could include alternatives such as development of the site with a project that reduces all of the proposed project's significant and unavoidable impacts to less than significant level, and/or a mixed -use project that provides affordable housing and exclusively local -serving commercial uses that may reduce VMT, GHG emissions, and improve Air Quality.

9.0 Significant Irreversible Environmental Changes due to the Proposed Project and 10.0 Growth Inducing Impacts of the Proposed Project
A revised EIR must be prepared to include an accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. The EIR does not include any information regarding the buildout conditions of the City's.General Plan in order to provide an adequate and accurate environmental analysis. The EIR must be revised to provide the horizon year of the City's current adopted General Plan, the total developable building floor area analyzed within the Industrial land use designation, and cumulative development since adoption of the General Plan to ensure that the proposed project is within the General Plan EIR's analysis, particularly since the EIR tiers from the General Plan EIR. For example, Table CDL-2: Yucaipa Buildout Summary of the General Plan indicates that the entirety of all Industrial land use designations will accommodate 1,100,000 square feet of building area. The proposed project's 3,992,503 square feet of Business Park (industrial) building area exceeds the entirety of the planned industrial growth for the entire incorporated City area by nearly four times. Table CDL- 2 also states the the entirety of all Industrial land use designations will generate 1,203 jobs, and the proposed project's 2,682 jobs is more than twice the identified growth. The growth generated by the proposed project was not accounted for by the General Plan or its EIR as the project requires a GPA to proceed. The growth generated by the proposed project was not anticipated by the City's General Plan, RTP/SCS, or AQMP. A revised EIR must be prepared with a finding of significance.

The EIR does not discuss its own conclusion that implementation of the proposed project and required GPA will result in significant and unavoidable cumulatively considerable Air Quality, Greenhouse Gas Emissions, and Noise impacts. The EIR must be revised to include a finding of significance due to the project's significant and unavoidable Greenhouse Gas Emissions (cumulatively considerable), and Noise impacts and direct contribution to climate change. 08/25/2025 City Council Agenda
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The EIR does not adequately discuss or and analyze the commitment ofresources is not consistent with regional and local growth forecasts (AQMP, General Plan, SCAG, etc) and does not address the EIR's own conclusion that the project will result in impacts (Air Quality, GHG) that exceed with the forecasts of the applicable plans (AQMP, 2030/2050 GHG reduction goals). As noted throughout this comment letter, the project represents a significant amount of growth in the City and exceeds the developable Industrial building area anticipated by General Plan buildout and exceeds the City's employment growth forecast for a 29 year period. This is especially notable as the project requires a GPA to proceed, indicating the proposed project was not anticipated in any General Plan buildout projection or SCAG growth forecast. The EIR has not provided an adequate or accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting.

For example, the project represents 39% of the City's job growth over 29 years. This number increases exponentially when the City's other industrial and commercial development activity is added to the calculation. A revised EIR must be prepared to include an accurate cumulative analysis on this topic and include a finding of significance.

Conclusion
For the foregoing reasons, GSEJA believes the EIR is flawed and a revised EIR must be prepared for the proposed project and recirculated for public review. Golden State Environmental Justice Alliance requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

Sincerely,
Gary Ho
Blum, Collins & Ho LLP
Attachments:

1. SWAPE Technical Analysis
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i SWAP E I Technical Consultation, Data Analysis and
Litigation Support for the Environment
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhaaemannBswaoe.com
Paul E. Rosenfeld, PhD
(310) 795-2335
prosenfeldaswaoe.com
March 20, 2024
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
Subject: Comments on the Freeway Corridor Specific Plan Project (SCH No. 2006041096) Dear Mr. Ho,
We have reviewed the February 2024 Subsequent Environmental Impact Report ("SEIR") for the Freeway Corridor Specific Plan Project ("Project') located in the City of Yucaipa ("City"). The Project proposes to construct 2,472 residential units and 5,093,265-square-feet ("SF") of nonresidential uses on the 1,238-acre site.

Our review concludes that the SEIR fails to adequately evaluate the Project's air quality, health risk, and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. A revised Environmental Impact Report {"EIR") should be prepared to adequately assess and mitigate the potential air quality, health risk, and greenhouse gas impacts that the project may have on the environment.

Air Quality
Failure to Implement All Feasible Mitigation to Reduce Emissions The SEIR estimates that the Projects construction -related and operational emissions would exceed the applicable South Coast Air Quality Management District ("SCAQMD") thresholds. Specifically, regarding the Projects construction -related impacts, the SEIR states:
"Construction of the Pacific Oaks Commerce Center would exceed the South Coast AQMD regional significance thresholds. As shown in Table 5.3-23 above, implementation of Mitigation Measure AQ-6 would reduce voe emissions to below the regional significance threshold.

However, construction activities associated with the Pacific Oaks Commerce Center would 08/25/2025 City Council Agenda
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continue to generate NOX and CO emissions that exceed the respective South Coast AQMD regional significance thresholds. Therefore, Impact 5.3-2 as it pertains to the Pacific Oaks Commerce Center project would be significant and unavoidable" (p. 5.3-68) Furthermore, regarding the Project's operational impacts, the SEIR states:
"Long-term operation of the Pacific Oaks Commerce Center project would exceed the South Coast AQMD regional significance thresholds. Table 5.3-25, Pacific Oaks Commerce Center Maximum Daily Regional Operational Emissions: With Mitigation, shows the maximum daily operational phase emissions with implementation of Mitigation Measures AQ-2 and AQ-4, and AQ-7 through AQ-11. As shown in the table, though mitigation would reduce emissions, the regional significance thresholds for voe and NOX would still be exceeded. Impact 5.3-3 would be significant and unavoidable for the Pacific Oaks Commerce Center project" (p. 5.3-69) As discussed, the SEIR concludes that the criteria air pollutant impacts associated with both construction and operation of the Project would be significant -and -unavoidable. While we agree that the Project would result in significant air quality impacts, the SEIR's assertion that this impact is significant -and - unavoidable is unreliable. According to California Environmental Quality Act ("CEQA") Guidelines § 15096(g)(2):
"When an updated EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment."
The SEIR is required under CEQA to implement all feasible mitigation to reduce impacts to the maximum extent feasible. While the SEIR implements Mitigation Measure ("MM") AQ-1 through MM-AQ-11, the SEIR fails to implement all feasible mitigation (p. 1-28 -1-32, Table ES-5). Therefore, the SEIR's conclusion that Project's air quality emissions would be significant -and -unavoidable may be unsubstantiated. To reduce the Project's air quality impacts to the maximum extent possible, additional feasible mitigation measures should be incorporated, such as those suggested in the section of this letter titled "Feasible Mitigation Measures Available to Reduce Emissions." The Project should not be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to the maximum extent feasible.

Disproportionate Health Risk Impacts of Warehouses on Surrounding Communities Upon review of the SEIR and associated documents, we have determined that the development of the proposed Project may contribute to disproportionate health risk impacts on community members living, working, and going to school within the immediate area of the Project site. According to SCAQMD:
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"Those living within a half mile of warehouses are more likely to include communities of color, have health impacts such as higher rates of asthma and heart attacks, and a greater environmental burden."'
In particular, the SCAQMD found that more than 2.4 million people live within a half mile radius of at least one warehouse, and that those areas not only experience increased rates of asthma and heart attacks, but are also disproportionately Black and Latino communities below the poverty line.2 Another study similarly indicates that "neighborhoods with lower household income levels and higher percentages of minorities are expected to have higher probabilities of containing warehousing facilities."3 Additionally, a report authored by the Inland Empire -based People's Collective for Environmental Justice and University of Redlands states:
"As the warehouse and logistics industry continues to grow and net exponential profits at record rates, more warehouse projects are being approved and constructed in low-income communities of color and serving as a massive source of pollution by attracting thousands of polluting truck trips daily. Diesel trucks emit dangerous levels of nitrogen oxide and particulate matter that cause devastating health impacts including asthma, chronic obstructive pulmonary disease (COPD), cancer, and premature death. As a result, physicians consider these pollution - burdened areas 'diesel death zones.-4
It is evident that the continued development of industrial warehouses within these communities poses a significant environmental justice challenge. However, the acceleration of warehouse development is only increasing despite the consequences on public health.

In April 2022, the American Lung Association ranked San Bernadina County as the worst -for. ozone pollution in the nation.' This year, the County continues to face the worst ozone pollution, as it has seen the highest recorded Air Quality Index ("AQI") values for ground -level ozone in California.6 The U.S.

Environmental Protection Agency ("EPA") indicates that ozone, the main ingredient in "smog," can cause ' "South Coast AQMD Governing Board Adopts Warehouse Indirect Source Rule." SCAQMD, May 2021, available at: htto:// www.aamd.gov/docs/default-source/news-archive/2021 /board-adopts-waisr-may7-2021.pdf?sfvrsn=9. 2 "Southern California warehouse boom a huge source of pollution. Regulators are fighting back." Los Angeles Times, May 2021, available at: https://www.latimes.com/california/storv/2021-05-05/air-aualitv-officia Is-taraet- warehouses-bid-to-curb-health-damaaina-truck-pollution. 3 "Location of warehouses and environmental justice: Evidence from four metros in California." Metro Freight Center of Excellence, January 2018, available at:
https://www.metrans.ora/assets/research/MF%201.1a Location%20of%20warehouses%20a nd%20environmental %20iustice Final%20Report 021618.pdf, p. 21.
4 "Warehouses, Pollution, and Social Disparities: An analytical view of the logistics industry's impacts on environmental justice communities across Southern California." People's Collective for Environmental Justice, April 2021, available at:
https:liearthiustice.ora/sites/default/files/files/warehouse research report 4.15.2021.pdf, p. 4. 5 "State of the Air 2022." American Lung Association, April 2022, available at:
httos://www.lu na.ora/research/sota/kev-fi nd inas/most-polluted-places. 6 "High Ozone Days." American Lung Association, 2022, available at:
https://www.luna.ora/research/sota/citv-rankinas/states/cahfornia . 3 06/25/2025 aty Coufflt Agend@
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several health problems, which includes aggravating lung diseases and increasing the frequency of asthma attacks. The U.S. EPA states:
"Children are at greatest risk from exposure to ozone because their lungs are still developing and they are more likely to be active outdoors when ozone levels are high, which increases their exposure. Children are also more likely than adults to have asthma.!' Furthermore, regarding the increased sensitivity of early -life exposures to inhaled pollutants, the CARB states:
"Children are often at greater risk from inhaled pollutants, due to the following reasons:

Children have unique activity patterns and behavior. For example, they crawl and play on the ground, amidst dirt and dust that may carry a wide variety of toxicants. They often put their hands, toys, and other items into their mouths, ingesting harmful substances. Compared to adults, children typically spend more time outdoors and are more physically active. Time outdoors coupled with faster breathing during exercise increases children's relative exposure to air pollution. • Children are physiologically unique. Relative to body size, children eat, breathe, and drink more than adults, and their natural biological defenses are less developed. The protective barrier surrounding the brain is not fully developed, and children's nasal passages aren't as effective at filtering out pollutants. Developing lungs, immune, and metabolic systems are also at risk.
• Children are particularly susceptible during development. Environmental exposures during fetal development, the first few years of life, and puberty have the greatest potential to influence later growth and development."'
A Stanford -led study also reveals that children exposed to high levels of air pollution are more susceptible to respiratory and cardiovascular diseases in adulthood.9 Given that children are more susceptible to the negative health impacts of air pollutants, and that warehouses release more smog - forming pollution than any other sector, it is necessary to evaluate the specific health risk that warehouses pose to children in the nearby community.

According to the above -mentioned study by the People's Collective for Environmental Justice and University of Redlands, a half mile radius is commonly used for identifying sensitive receptors. There are 640 schools in the South Coast Air Basin that are located within half a mile of a large warehouse, most of "Health Effects of Ozone Pollution." U.S. EPA, May 2021, available at: httos:// www.eoa.aov/around-level-ozone- oollution/health-effects-ozone-pollution.
8 "Children and Air Pollution." California Air Resources Board (CARB), available at:
httos://ww2.arb.ca.aov/resources/documents/children-and-air-pollution. 9 "Air pollution puts children at higher risk of disease in adulthood, according to Stanford researchers and others." Stanford, February 2021, available at: https://news.stanford.esiu/2021/02/22/air-pollution-impacts-childrens- health/.
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them in socio-economically disadvantaged areas.10 According to the SEIR, Mesa View Middle School is located 0.27 miles south of the Project site (p. 5.9-12). The location of a school within half of a mile of the Project site poses a significant threat because, as outlined above, children are a vulnerable population that are more susceptible to the damaging side effects of air pollution. If approved, the Project would contribute to the detrimental short-term and long-term health impacts that warehouses pose on local children.

A revised EIR should be prepared to evaluate the contribution to the disproportionate impacts that warehouses pose on the community adjacent to the Project, including an analysis of the impact on children and people of color who live and attend school in the surrounding area. In order to evaluate the cumulative air quality impact from the several warehouse projects proposed or built in a one -mile radius of the Project site, the analysis should prepare a revised cumulative health risk assessment ("HRA") to quantify the adverse health outcome from the effects of exposure to multiple warehouses in the immediate area in conjunction with the poor ambient air quality in the Project's census tract. This recommendation is consistent with guidance provided by the California Department of Justice ("DOJ")." Diesel Particulate Matter Emissions Inadequately Evaluated The SEIR concludes that the proposed Project would result in a less -than -significant health risk impact based on a quantified construction and operational HRA, as detailed in the Health Risk Assessment Report ("HRA Report"), provided as Appendix D to the SEIR. Specifically, the SEIR estimates that the maximum cancer risk posed to nearby, existing residential sensitive receptors associated with construction and operation would be 4.4 in one million, which would not exceed the SCAQMD significance threshold of 10 in one million (see excerpt below) (p. 5.3-75, Table 5.3-29).

Table 5.3-29 Pacific Oaks Commerce Center Operation Plus Construction Health Risk Results: With Mitigation
Rtc,nlnr
CancerRisk
ID«millionl
Chronic Hmrdlndex
Maxirrv..rm Exposed Indi.-idual R - tructon

0.8 0.003
Ma.'limum Ei IIhfW."1ses,,..,..t
However, the SEIR's evaluation of the Project's potential health risk impacts, as well as the subsequent less -than -significant impact conclusion, is incorrect. 10 "Warehouses, Pollution, and Social Disparities: An analytical view of the logistics industrys impacts on environmental justice communities across Southern California." People's Collective for Environmental Justice, April 2021, available at:
httos://earthiustice.orci/sites/default/files/files/warehouse research report 4.15.2021.pdf p. 4. 11 "Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act." State of California Department of Justice, September 2022, available at:
https://oaa.ca.aov/system/files/media/warehouse-best-Dractices.pdf , p. 6. 5 08/26/2024 City Cottttdl Agmth
8,8

The SEIR's operational HRA underestimates the Fraction of Time At Home ("FAH") values for the third trimester, infant, and child receptors. Specifically, the HRA Report utilizes an FAH value of 0.85 for the third trimester (age -0.25 to 0) and infant (age Oto 2) receptors, and an FAH value of 0.72 for the child receptors (age 2 to 16) (see excerpt below) (Appendix D, p. D-20).

Age Groups
BR/BW (L/kg-cfayl ED ASP EAU
TI:u.rd trimester 361 0.25 10 1 0.85
0-2 age group 1,090 2 10 0.85
2-9 age group 861 7 3 0.72
2-16 age group 7-1-5 14 3 0.72
16-30 age group 335 14 1 0.73
However, the FAH values used for the third trimester, infant, and childhood receptors are incorrect, as SCAQMD guidance clearly states:
"For Tiers 1, 2, and 3 screening purposes, the FAH is assumed to be 1 for ages third trimester to

16. As a default, children are assumed to attend a daycare or school in close proximity to their home and no discount should be taken for time spent outside of the area affected by the facility's emissions. People older than age 16 are assumed to spend only 73 percent of their time at home."12
Per SCAQMD guidance, the HRA Report should have used an FAH of 1 for the third trimester, infant, and child receptors. By relying on incorrect FAH values, the SEIR underestimates the cancer risk posed to nearby, existing sensitive receptors as a result of Project operation. As such, the Project's HRA cannot be relied upon until the necessary changes are made in accordance with SCAQMD guidance.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The SEIR estimates that the Project would generate net annual GHG emissions of 48,775 metric tons of carbon dioxide equivalents per year ("MT CO2e/year"), which would exceed the no -net -increase threshold (0 MTCO2e/year) for GHG emissions (see excerpt below) (p. 5.8-32, Table 5.8-8). 12 "Risk Assessment Procedures." SCAQMD, August 2017, available at: htto:// www.aamd.aov/docs/default- source/rule-book/Proaosed-Rules/1401/riskassessmentarocedures 2017 080717.adf. p. 7. 6 O /25/2025 aty Couffll And
8,4

Table 5.8-8
Pacific Oaks Commerce Center GHG Emissions Inventory, With Mitigation Source
Building 1(BP 2)
MTCO,e
Building 2 & Trailer
Periling (BP 3)
MTCO,e
Total
MTCOie
Percent of Total
Mobiles
2,610
3,047
5,657
12%
Mobile - Truckss
7,685
23,445
31,130

64.0 Alea2
0 0
0 0%
Energy
2,286
2,239
4,525
9%
Water
82 97
179
<1%
Solid Waste
2,127
2,514

4.641
10%
Refrigerants
1,161

1.105

2.266
5%
Off -Road Equipmentl
0 0
0 0%
Transport Refrigeration Units;
0 0
0 0%
Amortized Constructions
nfa
nla
377
1%
Total Emissions
15,952
32,446
48,775
100%
Exceeds No Net Increase Threshold?
Yes
Yes
Yes
-
Source: CaIEEMod v.2022.1.(See Appendix C)
Nole: NA= not applicable;0= negative value
1 Based on calendar year 2026 GalEEMod default vehicle emiMI011s data. Vehicle fleet mix for the Proposed Project based on default CalEEMod vehicle fleet nn adjusted to vehicie fleet mix provided by Tronslulions for the proposed warehousing. 2 Implementation of Mitigation Measure AO-H would require use of e!ecilic-poweredland,cap<ng eq 11 pment only 1 Implementation or Mitigation Measure AO-7 would require use or only e!ectric-po\\'erad o"•road equipment.

T Implementation of Mitigation Measure A0-8 would require usa of EIS TRUs rnnclmolinn PmiIcinn ara amnr5, ,I nvPr a'In-\'n -OleCt felime Der recommended South Coast AOMO met hodnlnaY (South Coast AOMO 2009) However, the SEIR states that with the implementation of mitigation measures, the Project's GHG emissions will be reduced to less than significant levels:
"The Proposed Project would be potentially inconsistent with CARB's 2022 Scoping Plan unless it achieves the three priority areas for ensuring carbon neutrality. Implementation of Mitigation Measures GHG-1 and GHG-2 would ensure that development projects accommodated under the FCSP comply with the CALGreen voluntary Tier 2 EV parking standards in addition to buildings designed to be all electric. Thus, with mitigation, the Proposed Project would be consistent with the transportation electrification and building decarbonization priority areas of the Scoping Plan. Therefore, Impact 5.8-2 would be reduced to less than significant" (p. 5.8-33).

As discussed, the SEIR claims that through the implementation of Mitigation Measures GHG-1 and GHG- 2, the Project would comply with the CALGreen voluntary Tier 2 EV parking standards and consequently result in a less -than -significant GHG impact. However, while the SEIR concludes that the Project would not generate GHG emissions that would have a significant effect on the environment, the SEIR fails to quantify the Project's GHG emissions whatsoever. Until the SEIR provides a quantitative analysis regarding the Project's GHG emissions, the SEIR's claim that the Project would result in a less -than - significant GHG impact is unsubstantiated.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project would result in potentially significant air quality, health risk, and GHG impacts that should be mitigated further. In an effort to reduce emissions, the Project should 7 06/25/2025 aty Couffil And@

consider the implementation of the following mitigation measures found in the California DOJ Warehouse Project Best Practices document. 13
• Requiring off -road construction equipment to be hybrid electric -diesel or zero emission, where available, and all diesel -fueled off -road construction equipment to be equipped with CARB Tier IV -compliant engines or better, and including this requirement in applicable bid documents, purchase orders, and contracts, with successful contractors demonstrating the ability to supply the compliant construction equipment for use prior to any ground -disturbing and construction activities.
• Prohibiting off -road diesel -powered equipment from being in the "on" position for more than 10 hours per day.

Using electric -powered hand tools, forklifts, and pressure washers, and providing electrical hook ups to the power grid rather than use of diesel -fueled generators to supply their power.

Designating an area in the construction site where electric -powered construction vehicles and equipment can charge.
• Limiting the amount of daily grading disturbance area. • Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.
• Forbidding idling of heavy equipment for more than three minutes. • Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications.
• Conducting an on -site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts. • Using paints, architectural coatings, and industrial maintenance coatings that have volatile organic compound levels of less than 10 g/L.
• Providing information on transit and ridesharing programs and services to construction employees.
• Providing meal options onsite or shuttles between the facility and nearby meal destinations for construction employees.
• Requiring all heavy-duty vehicles engaged in drayage to or from the project site to be zero - emission beginning in 2030.
• Requiring all on -site motorized operational equipment, such as forklifts and yard trucks, to be zero -emission with the necessary charging or fueling stations provided. • Requiring tenants to use zero -emission light- and medium -duty vehicles as part of business operations.
• Forbidding trucks from idling for more than three minutes and requiring operators to turn off engines when not in use.
13 "Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act." State of California Department of Justice, September 2022, available at:
httos://oaa.ca.aov/system/files/media/warehouse-best-oractices.odf, p. 8 -10. 8 06/25/2025 aty Couffll Agend@

• Posting both interior- and exterior -facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to CARB, the local air district, and the building manager.
• Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building's projected energy needs, including all electrical chargers.
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible. • Constructing zero -emission truck charging/fueling stations proportional to the number of dock doors at the project.
• Running conduit to designated locations for future electric truck charging stations. • Unless the owner of the facility records a covenant on the title of the underlying property ensuring that the property cannot be used to provide refrigerated warehouse space, constructing electric plugs for electric transport refrigeration units at every dock door and requiring truck operators with transport refrigeration units to use the electric plugs when at loading docks.
• Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. • Constructing and maintaining electric light -duty vehicle charging stations proportional to the number of employee parking spaces (for example, requiring at least 10% of all employee parking spaces to be equipped with electric vehicle charging stations of at least Level 2 charging performance)
Running conduit to an additional proportion of employee parking spaces for a future increase in the number of electric light -duty charging stations.

Installing and maintaining, at the manufacturer's recommended maintenance intervals, air filtration systems at sensitive receptors within a certain radius of facility for the life of the project.

Installing and maintaining, at the manufacturer's recommended maintenance intervals, an air monitoring station proximate to sensitive receptors and the facility for the life of the project, and making the resulting data publicly available in real time. While air monitoring does not mitigate the air quality or greenhouse gas impacts of a facility, it nonetheless benefits the affected community by providing information that can be used to improve air quality or avoid exposure to unhealthy air.
• Requiring all stand-by emergency generators to be powered by a non -diesel fuel. • Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. • Requiring operators to establish and promote a rideshare program that discourages single - occupancy vehicle trips and provides financial incentives for alternate modes of transportation, including carpooling, public transit, and biking.
• Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking. 9 06/25/2 2 aty Coufflt And
852

• Designing to LEED green building certification standards. • Providing meal options onsite or shuttles between the facility and nearby meal destinations. • Posting signs at every truck exit driveway providing directional information to the truck route. • Improving and maintaining vegetation and tree canopy for residents in and around the project area.
• Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB-approved courses. Also require facility operators to maintain records on -site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request. • Requiring tenants to enroll in the United States Environmental Protection Agency's Smar:tWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
• Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

These measures offer a cost-effective, feasible way to incorporate lower -emitting design features into the proposed Project, which subsequently, reduce emissions released during Project construction and operation.

As it is policy of the State that eligible renewable energy resources and zero -carbon resources supply 100% of retail sales of electricity to California end -use customers by December 31, 2045, we emphasize that the energy mix that will charge the batteries and power electrical equipment must be 100% renewable energy resources. Until the feasibility of charging the batteries with renewable energy resources only is evaluated, the Project should not be approved.

A revised EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality, health risk, and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to the maximum extent feasible. The revised EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project's potentially significant emissions are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.
10 O /25/2025 aty Cooefit And@
858

Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Attachment A: Matt Hagemann CV
Attachment B: Paul Rosenfeld CV
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Attachment A
•swAP E I Technical Consultation, Data Analysis and
Litigation Support for the Environment
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
2656 29' Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhaaemannCa)swaoe.com
Geologic and Hydrogeologic Characterization
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
Industrial Stormwater Compliance
CEQAReview
Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

Professional Certifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:

Matt has 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA's Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions.

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 - present); • Geology Instructor, Golden West College, 2010 -2104, 2017; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003); 08/2 /2024 City COMM Agenda
Vv�

• Executive Director, Orange Coast Watch (2001-2004);
• Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989- 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998-2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 - 1998);
• Instructor, College of Marin, Department of Science (1990 -1995); • Geologist, U.S. Forest Service (1986 -1998); and
• Geologist, Dames & Moore (1984-1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt's responsibilities have included:
• Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities.
• Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. • Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.

With Komex H2O Science Inc., Matt's duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel.

Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
2 08/2 /2024 City Council Agra

• Expert witness testimony in a case of oil production -related contamination in Mississippi. • Lead author for a multi -volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hvdrogeologv:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:

Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.

Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted 3 08/2 /2024 City Council Agra
802

public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote "part B" permits for the disposal of hazardous waste. • Conducted RCRA Corrective -Action investigations of waste sites and led inspections that formed the basis fo significant enforcement actions that were developed in close coordination with U: S.

EPA legal counsel.

Wrote contract specifications and supervised contractor's investigations of waste sites.

With the National Park Service, Matt directed service -wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:

Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants • Conducted watershed -scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high -levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co-authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation- wide policy on the use of these vehicles in National Parks. • Contributed to the Federal Multi -Agency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9.

Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA's national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPA's scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region's 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific 4 08/2 /2024 City Council Agoa
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principles into the policy -making process.
• Established national protocol for the peer review of scientific documents.

Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year -long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.

Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017.

Invited Testimony. Reports. Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).
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Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter -Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.
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Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.

Hagemann, M.F., and VanMouwerik, M., 1999. _ .Potential Water Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP-61.

Hagemann, M.F., 1994. Groundwater Characterization and Cleanup at Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL- contaminated Groundwater. California Groundwater Resources Association Meeting_. 7 08/26/2024 City C®UIAeil AgetAtia
804

Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009-2011.
8 08/2 /2024 City Council A
$07

Attachment B
swA P E I Technical Consultation, Data Analysis and
Litigation Support for the Environment

SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 20I
Santa Monica, Califomia 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: nrosenfeld(alswanc.coul
Paul Rosen/eld, Ph.D.

Chemical Fate and Transport & Air Dispersion Modeling
Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Focus on wastewater treatment.

Professional ExJ!erience
Dr. Rosenfeld has over 25 years of experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr. Rosenfeld has evaluated and modeled emissions from oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.

Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion.

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, creosote, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr.

Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at sites and has testified as an expert witness on numerous cases involving exposure to soil, water and air contaminants from industrial, railroad, agricultural, and military sources.

Paul E. Rosenfeld, Ph.D.
08/24/2O24 City Cumitiili Artiba

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SOS

Professional HistolT,:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amee), San Diego, 2000-2000; Remediation Project Manager Bechtel; San Diego, California, 1999 - 2000; Risk Assessor King County, Seattle, 1996 - 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pollution. 233, 171.

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Indushy, Amsterdam: Elsevier Publishing.

Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL. Procedia Environmental Sciences. 113-125.

Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum lndustly. Amsterdam: Elsevier Publishing.

Paul E. Rosenfeld, Ph.D.

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Yucaipa City CouncilAugust 25, 2025

Yucaipa City Council
August 25, 2025