HomeMy WebLinkAbout11-09-2024 Letter to Planning Commission Warehouse EIR Approval. Item 2CFrom:Peter Moruzzi
To:City Clerk; Planning; Christopher Hadwin; Glenn Mlaker
Subject:Letter to Planning Commission Warehouse EIR Approval. Item 2C
Date:Saturday, November 9, 2024 4:22:27 PM
Attachments:Letter to planning commission.pdf
Map Graphic II.pdf
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Please distribute this letter to the Planning Commission.
Honorable Members of the Palm Springs Planning Commission,
Attached is my response to the Statement of Overriding Considerations you are being asked to approve this
Wednesday for the Palm Springs Fulfillment Center (Item 2C).
I've also attached a map showing this project and the two others recently submitted to the planning department.
Respectfully,
Peter Moruzzi
Former Planning Commissioner
Palm Springs Giant Warehouse Projects
Source: Committee to Stop Giant Warehouse Blight
1. PS Fulfillment Center
739,860 Sq. Ft.
Status: Final EIR
completed.
2. First Industrial 1
Bldg 1: 1,516,601 Sq. Ft.
Bldg 2: 391,077 Sq. Ft.
Status: Initial Study
comment period ended
3. First Industrial 2
1,089,747 Sq. Ft.
Status: Pre-Application
reviewed
TOTAL SQUARE FOOTAGE
3,737,285
1
Letter to planning commission
Item 2C – Certification of Final EIR and Adoption of Statement of Overriding Considerations
Today you are being asked to certify the Final EIR and adopt a Statement of Overriding
Considerations (SOC) for the 739,360 sq. ft. PS Fulfillment Center. The SOC is necessary
because “The EIR has determined that Greenhouse Gas (GHG) emissions and Transportation
will cause significant impacts to the environment that cannot be mitigated to a less than
significant level.” [Staff report pg. 18, Finding 10]
It is important to note that just because the developer can build by right doesn’t mean that you
are required to approve the EIR’s Statement of Overriding Considerations. You have the option
of not certifying the SOC for a variety of valid reasons as part of the environmental review
required under our ordinance.
Staff has concluded that “These unavoidable impacts are overridden by the project benefits set
forth in the Statement of Overriding Considerations.” [Staff report pg. 13, paragraph 1]
However, as I argue below, I do not believe the stated benefits outweigh the significant
impacts.
From the Statement of Overriding Considerations. Pgs. 120-121. The key benefits stated are:
1. Land Use Benefits:
- “The project will also provide 718 permanent jobs in the City.” [Statement of Overriding
Considerations. Pg. 120] My response: Without knowing the ultimate tenant/user of
the building (warehouse, fulfillment center, etc.) it remains unknown how many
permanent jobs there will be and what level of automation will exist.
- “The project’s location near the freeway and away from residential land uses will avoid
impacts of greenhouse gas emissions.” [Statement of Overriding Considerations. Pg.
120] My response: This is false because prevailing winds will blow emissions
throughout the valley.
Ultimately, an inconsequential “Mitigation Monitoring and Reporting Program (MMP) GHG-
1” is proposed to address GHG emissions consisting of “implement[ing] Screening Table
Measures within the project building plans.” [Staff report pg. 9] My response: These
measures in no meaningful way mitigate the significant impacts of GHG emissions.
2. To Meet Market Demands for Industrial Space:
- “Markets, including those in Los Angeles County, Orange, and San Bernardino counties
are running out of space to support more industrial facilities.” [Statement of Overriding
Considerations. Pg. 120] My response: Therefore, the Coachella Valley must become
the next Moreno Valley as a repository for future warehouses?
2
3. Economic and Fiscal Benefits:
- “Will increase annual property tax revenues.” [Statement of Overriding Considerations.
Pgs. 120-121] My response: Yes, but the main reason cited is an increase in sales tax
revenue, which is currently uncertain and can vary widely depending on the type of
tenant. Recall the dramatic drop in expected revenues from Amazon’s recent project
revision in Desert Hot Springs.
To reiterate, the stated benefits do not outweigh the significant impacts. Therefore, I request
that you do not approve the Statement of Overriding Considerations.
Peter Moruzzi
Former member of the Palm Springs Planning Commission