HomeMy WebLinkAbout2025-1-23 Item 2AFrom:Juliana Freese
To:City Clerk
Subject:Warehousing Project Public Comment Letter
Date:Thursday, January 23, 2025 4:52:41 PM
Attachments:Public Comment Letter_Juliana Freese.pdf
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Please submit this comment for tonight's PS City Council meeting. Thank you.
Juliana Freese
01/23/2025
Public Comment
Item 2A
Juliana Freese
61115 Deronda Ave
Whitewater, CA 92282
(760)641-6820
julzfreese@gmail.com
I am writing to express my strong opposition to the proposed Palm Springs Fulfillment
Center project on Indian Canyon Dr and 19th Ave. As a native-born citizen of Palm Springs
and current resident of Whitewater, I have a strong connection to the beauty and unique
character of our local desertscape, and this project lies in direct opposition to this natural
beauty. My concerns over this proposed project are centered around the potential
environmental impact and a disturbing lack of evidence that the City of Palm Springs and
local residents will gain any worthwhile benefits.
As a child I recall the countless times I traversed the 1-10 corridor in our valley, taking
solace in the untouched wild nature around me. When I later attended College of the
Desert and took my first Natural Resources course, the wonders of our local ecosystem
were made clear to me. From our sand dunes to the many critters that inhabit our desert
flora, there is no place like the Coachella Valley - and our residents and tourists know that
our scenic beauty is worth preserving.
While reading through The General Plan (2007) for Palm Springs, I found repeating
language that highlights the city's original intention to focus future industrial plans for this
area on businesses that would "serve a regional population" (pg 2-9), envisioning wind
energy facilities and generation of energy resources and jobs as an "excellent example of
how the integration of compatible uses can provide multiple benefits." (pg 2-20) Being a
giant, ambiguous warehouse with no guaranteed tax windfalls (no defined function) or
jobs (undefined percentage of automated function), I find this project in opposition to
these stated goals. What benefits can our residents be guaranteed in the approval of this
project? I urge the city to note the original intent of The General Plan to preserve our
natural beauty and promote growth through the careful balance of regional benefits while
minimizing environmental disruption.
As listed in the comment letter by South Coast Air Quality Management District
(SCAQMD), the Draft Environmental Impact Report (DEIR) for the project is rife with
presumptions that are used to calculate greenhouse gas emissions. I am disturbed to
learn that a project which includes a two‐story, 739,360‐square‐foot structure for
industrial warehouse use could be approved without knowing what the building will
specifically be used for. The amount of truck traffic coming to and from the proposed site
is especially concerning to me because of the tremendous impact vehicle traffic has on
the production of Greenhouse Gas (GHG) emissions. The encapsulating topography of
our surrounding mountain ranges make the Coachella Valley especially susceptible to
adverse air quality if we invite infrastructure that brings GHG and ozone problems.
01/23/2025
Public Comment
Item 2A
All of us have felt the cruel touch of climate change through the effects of Hurricane
Hilary, altering our landscape and our lives through flooding and recurring massive dust
storms thereafter. Interrupting the delicate balance of our ecosystem through the
unsubstantiated increase of GHGs from this project will only add into the feedback loop of
climate change, further encouraging extreme weather events such as this.
I highly encourage the city to explore alternatives to this project that align with the values
of our desert community. Any projects that the city considers in the proposed location
needs to provide more guaranteed benefit and raise less environmental concerns to win
over our community. The spectacular views that exist along our highway are precious to
me, to longtime and newly settled residents, and to our many yearly tourists and visitors.
As this is the first giant warehouse proposal for our area, I believe it is our duty to look
with critical eyes before we allow this project to set a precedent in our community.
Juliana Freese
01/23/2025
Public Comment
Item 2A
From:City of Palm Springs
To:City Clerk
Subject:*NEW SUBMISSION* Submit Public Comment to the City of Palm Springs
Date:Thursday, January 23, 2025 4:09:39 PM
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Submit Public Comment to the City of Palm Springs
Submission #:3748536
IP Address:75.85.222.123
Submission Date:01/23/2025 4:09
Survey Time:7 minutes, 12 seconds
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Full Name/Nombre
Scott Connelly
City of Residence/Ciudad de residencia
Palm Springs,
Phone (optional) /Teléfono (opcional)
Email (optional/opcional)
scottdesert@gmail.com
Your Comments/Sus comentarios
I oppose the giant warehouse project due to the negative impacts on the quality of life for our residents and visitors.
Increased air pollution adding to our already delicate air quality will create severe health risks to our community.
Traffic congestion resulting in increased accidents and longer emergency response times. With the Blue Zone
project, Palm Springs aspires to be a haven of well-being, fostering environments that promote longevity and health.
The proposed warehouse stands in stark contrast to these ideals, introducing factors that undermine our city's
efforts to create a sustainable and health-conscious community. Tourism, will suffer. Visitors come to experience
the pristine natural beauty of our national monuments and parks, The long-term negative impacts on air quality,
health, traffic congestion, and tourism far outweigh any short-term economic gains.
Thank you,
City of Palm Springs
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01/23/2025
Public Comment
Item 2A
From:Bear Grass
To:City Clerk
Subject:City council meeting tonight at 5:30
Date:Thursday, January 23, 2025 4:01:05 PM
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Hi, I was given your info by a friend and colleague, David Snider, about tonight’s meeting.
Although I would like to speak on 2A at tonights meeting it is unlikely I can make it in person
as I have a 6:00PM prior engagement.
That said, my comments for submittal are below. Please let me know if I need to do anything
else to help what I think is a project site worth your consideration.
Hi everyone my name is Bear and I’m a local Palm Springs resident. I’m a residential landlord
in the area and the local economy is very important to me. For years our town has relied on
tourism which took a huge hit during covid and was very difficult for me and most businesses,
and I’m excited to see Palm Springs getting behind the warehouse development movement. I
understand not wanting these warehouses in our backyards, but this location is one that most
residents don’t even know is in Palm Springs and certainly rarely frequent. As big warehouses
go, this one seems to be on the more attractive side anyway. My understanding is that the
zoning in this area permits warehouses, and that the Planning Commission already approved
this project. I ask the Council to vote yes tonight so we don’t lose another great opportunity
for our community and the myriad jobs this might bring.
Thanks!
01/23/2025
Public Comment
Item 2A
From:Tiffani Lobue
To:City Clerk
Subject:E-Public Comment - say NO to building Warehouses in PS!
Date:Thursday, January 23, 2025 3:56:57 PM
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Hello Mayor DeHarte, City Council members,
My name is Tiffani LoBue. I have been a full time Palm Springs resident for almost 30 years.
I have seen many changes in that time, not just in Palm Springs, but the Coachella Valley.
I have an understanding of the need to keep moving forward and creating ways to support the
financial needs of a World Class destination. New hotels, restaurants, tourist attractions, etc.
but is a warehouse just 10 miles from the downtown area REALLY the answer to investing in
the community? I suspect jobs will certainly be created but job opportunities abound in the
greater Coachella Valley.
I respectfully ask- beg- the Council and planning commission to repeal this plan/idea. We can
do better.
Thank you
Tiffani LoBue
4028 E Paseo Luisa
Palm Springs 92264
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01/23/2025
Public Comment
Item 2A
From:City of Palm Springs
To:City Clerk
Subject:*NEW SUBMISSION* Submit Public Comment to the City of Palm Springs
Date:Thursday, January 23, 2025 3:56:05 PM
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unless you are sure the content is safe.
Submit Public Comment to the City of Palm Springs
Submission #:3748491
IP Address:47.176.126.205
Submission Date:01/23/2025 3:55
Survey Time:5 minutes, 45 seconds
You have a new online form submission.
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Full Name/Nombre
Erik Newland
City of Residence/Ciudad de residencia
Palm Desert,
Phone (optional) /Teléfono (opcional)
(760) 861-1002
Email (optional/opcional)
Your Comments/Sus comentarios
I grew up in the coachella valley and I support the 739,000 square foot warehouse. Young people have very few
job/career opportunities out here, especially opportunities that allow for home purchase. Many local young people
are struggling to find jobs that pay enough for a simple 1 bedroom apartment - the solution is to encourage
developers and businesses to come to the desert, not hamstring them with red tape. North Palm Springs is a very
convenient location for residents of Desert Hot Springs, another community in need of more jobs for its residents!
Thank you,
City of Palm Springs
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01/23/2025
Public Comment
Item 2A
From:Agne Rinna
To:City Clerk
Subject:To speak tonight on Item 2A
Date:Thursday, January 23, 2025 3:44:01 PM
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unless you are sure the content is safe.
Hi my name is Agne Rinna I’m a resident of Palm Springs and I’d like to speak tonight on
item 2A. Please see my remarks below
My name is Agne Rinna and I have a home in palm springs. I wanted to get on this meeting to
urge the city council to approve this well planned and well placed development. From what I
have seen of the renderings it looks much better than any warehouse I’ve seen and I applaud
the planning commission for making the developer up the game in terms of aesthetics. The
fact that the Sierra club in favor of this is very important to me. I think the developer should
be commended for working with those groups and agreeing to conditions that will help
mitigate impacts. This project will provide so many permanent jobs whether it’s a warehouse
or a fulfillment center, both are great opportunities for Palm Springs and will provide a much
needed big employer to the area. I am watching the Amazon building go up . They have
announced that they will be filling over 2000 positions later this year. wouldn’t it be great for
palm springs to have a building like that! this is a great opportunity that should not be
missed. Thank you
01/23/2025
Public Comment
Item 2A
From:Andrew Carson
To:City Clerk
Subject:Item 2A - PS Canyon LLC - I would like to speak
Date:Thursday, January 23, 2025 3:24:05 PM
Importance:High
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I would like to speak tonight at the hearing.
My name is Andy Carson. I have had a chance to watch this project go through the
process and to get to this point. I feel that the issue is rather simple. Palm Springs has
an opportunity to build a large building at the way north end of town that will bring tons of
jobs that are not seasonal or temporary. This will happen if it is a fulfillment center or a
distribution warehouse. I take the developer at his word that he will do whatever
possible to get a fulfillment center, but both provide much needed highly skilled
warehouse jobs and logistical tech and office jobs. This is an absolute a win. We should
embrace it wholeheartedly and help the developer get the best tenant. I looked at the
history of this and the city council asked for these kinds of buildings 2 or 3 years ago and
they were correct. I urge you to vote for this and let the jobs and all that come with them
begin!
Please confirm the time.
Andy Carson
216-533-1632
andy@carsonreal.com
01/23/2025
Public Comment
Item 2A
From:Judy Deertrack
To:City Clerk; David Ready; Ron deHarte; Naomi Soto; Grace Garner; Jeffrey Bernstein
Cc:Jane Garrison; Jarek Dallos
Subject:Comment Letter (Oswit Land Trust) / Appeal of PC on PS Fulfillment Center
Date:Thursday, January 23, 2025 1:49:39 PM
Attachments:Comment Letter- AN APPEAL OF THE PLANNING COMMISSION’S DECEMBER 4, 2024 DECISION TO CERTIFY A
FINAL ENVIRONMENTAL IMPACT REPORT (FEIR)(CASE 3.4361 MAJ)_Oswit Land Trust (01.23.25).pdf
EXHIBIT M_Petition_60 Organ._LT Newsom_2023.01.24_Asking for Warehouse Moratorium w. Maps_(EXCERPTS
22pp).pdf
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unless you are sure the content is safe.
City ClerkMembers of the City CouncilCity of Palm Springs, CA
Re: Appeal filed by Peter Moruzzi, PS Fulfillment Center / Agenda Item 2A / January
23, 2025 City Council Agenda
To Whom It May Concern:
Please accept and distribute the following comment letter and exhibits to the CityCouncil for tonight's meeting. The exhibits, in particular, have critical information on
local and regional impacts that nullify a Statement of Overriding Consideration as an
appropriate response to impacts of this project; particularly when regional cumulative
impact assessment has been severely deficient, leading to incremental damage to
public health and safety that has now reached a regional crisis level.
I will shortly deliver printed copies of the comment letter and exhibits to bedistributed to the City Council. Please feel free to post the comment letter andexhibits by link to the website for this issue.
EXHIBITS A-L_Comment Letter_Oswit Land Trus…
Thank you for your leadership and concern.
With regard,
Judy Deertrack, Consultant On Behalf of Oswit Land Trust, 501 (c) (3) Palm Springs, CA
01/23/2025
Public Comment
Item 2A
1
January 23, 2025
City Council
City of Palm Springs
Palm Springs, California
Re: AN APPEAL OF THE PLANNING COMMISSION’S DECEMBER 4, 2024 DECISION TO
CERTIFY A FINAL ENVIRONMENTAL IMPACT REPORT (FEIR) INCLUDING THE ADOPTION
OF A STATEMENT OF OVERRIDING CONSIDERATIONS AND THE APPROVAL OF A MAJOR
DEVELOPMENT PERMIT FOR A 739,360-SQUARE FOOT WAREHOUSE AT THE
NORTHWEST CORNER OF NORTH INDIAN CANYON DRIVE AND 19th AVENUE (CASE
3.4361 MAJ)
To Whom It May Concern:
Oswit Land Trust is a 501C3 non-profit land conservancy dedicated to preserving criIcal habitat for wildlife
corridors and sensiIve species. We achieve our goals through the acquisiIon of land and advocacy. We
are a proud member of the Land Trust Alliance and have over 3,000 acIve members who are residents
within the Coachella Valley and beyond.
Oswit Land Trust thanks the City of Palm Springs for your kind consideration of our concerns. We
ask that the City Council never break its commitment to balance the demands of a growing
population and economy with the need of sensitive stewardship of our remaining natural lands
and the purity of our air. Natural resources feed and define the strength of economic opportunity.
Those same resources have an independent right to survive the extremity of our demands upon
the land.
In the last two years, Oswit Land Trust has monitored Riverside County and Coachella Valley city
agendas for projects occurring within sensitive biological areas. In quick succession, personnel
discovered an explosion of industrial warehousing approvals covering tens of millions of square
feet of land, concentrated along travel routes. The characteristics of this phenomenon are
frightening. The approvals systematically violate community character, environmental justice, air
01/23/2025
Public Comment
Item 2A
2
quality maintenance, global warming initiatives, transportation access, and state climate control
objectives.
In our long careers, none of us have seen a precedent for this behavior. These approvals did
occur primarily during the panic and economic deprivation of COVID; they occurred when the
public was disengaged from community oversight; they occurred when the country was distracted
with a national emergency. The approvals were excused with an abuse of the California
Environmental Quality Act (CEQA) “Statement of Overriding Consideration” where economic
priorities ruled over the requirement that cities and counties balance development with Public
Health and Safety imperatives and remain accountable to California State Climate Objectives.
The second severe abuse of CEQA was the failure of localities and Riverside County to conduct
appropriate Cumulative Impact Assessment of warehousing impacts.
We are asking the City Council to take a leadership role on warehousing abuse through quick
action and regional leadership to commit to all or a portion of the above options. Please recall
that the tourism economy of this region depends upon the serenity, aesthetics, and health of the
region in order to endure.
(1) PROJECT DENIAL - Deny or delay approval of PS Fulfillment Center until the true regional
and cumulative impacts are understood and addressed.
(2) MORATORIUM - Enact a temporary moratorium on warehousing approval and study the
regional data on greenhouse gas emissions, air quality impacts, transportation gridlock, and
environmental justice, including review of the widespread public protest (on public record), which
includes warnings from the State Attorney General to Riverside County and San Bernardino
County on warehousing violations related to the California Climate Action Plan.
(3) GENERAL PLAN REVIEW - Cure the recent failure of the General Plan Update for Palm
Springs to address the issue or receive public input. Bring this issue back to public review!
(4) REGIONAL PLANNING - Contact the State of California Attorney General, CalTrans,
Southern California Air Quality Management District, CVAG, and other state and regional
authorities, and transform the public health and safety threats to a responsible regional planning
approach. The violations inherent in excessive warehousing cannot be addressed at the
development permit stage.
01/23/2025
Public Comment
Item 2A
3
Our request is reflected in the attachments to this comment letter and the following data:
EXHIBIT A – Governor Newsome finds warehousing assessments in violation of California
Climate Objectives. The State Attorney General, starting with SAG Kamala Harris, has issued
repeated warnings to the counties and cities of Riverside and San Bernardino that the excessive
warehousing approvals are in violation of state climate control objectives (Letter from DOJ dated
September 7, 2018, to Moreno Valley, California on the World Logistics Center – the size of 700
football fields)
EXHIBIT B – Sixty prominent organizations, particularly in the field of public health and safety,
protested to the State of California on January 24, 2023, asking for a state moratorium on
warehousing under the following criteria: (1) Over 1 billion square feet of warehousing is
pending or approved within the Inland Empire; (2) this generates over 50 million pounds of
carbon dioxide per day; (2) this results in over 200 million truck trips per day on our limited
Interstate Freeways and Highways; (3) this results in over 15 billion pounds of carbon dioxide
released per year into the Inland Empire alone.
EXHIBIT C – Public Record Review of Banning to Coachella along Interstate 10 reveals that over
70 million square feet of warehousing is planned or approved. Trip generation rates for one
project along (5 million square feet) will generate about 2,300 trip-ends per day. A modest
calculation of one-way trips for 70 million square feet results in over ¼ million entries on the
freeway ramps daily. This is completely untenable!
EXHIBIT D – Nasa Heat and Temperature Maps show the Air Pollution Zone as being extreme
in Southern California warehousing areas, which may lead to average temperatures being five or
six degrees above the state average. Given six weeks last summer when temperatures easily
exceeded 115 degrees, this poses extreme risks to the Coachella Valley. The report shows that
Ontario, California, warehousing headquarters, is at 98 percentile cancer risk from air
pollution.
EXHIBIT E & F – Environmental studies conducted in the Banning Pass and Moreno Valley show
an extraordinary infiltration of warehousing, that exceeds any previous known industrial activity.
Public records on the websites of the cities (Banning to Coachella along Interstate 10) show
70 million square feet of warehousing approved or pending.
EXHIBITS G, H,J,K & L – These exhibits are excerpts or related to a recent study conducted by
CalTrans and Western Riverside County Regional Conservation Authority, among other
01/23/2025
Public Comment
Item 2A
4
prominent governmental entities and NGO’s that demonstrate the Banning Pass contains one of
the most sensitive wildlife linkages in the United States, given the biology of our region is the third
most prominent biologically sensitive area in the Country. Massive warehousing along Interstate
10 poses a critical threat. US Fish and Wildlife has documented that California lists 306
endangered plants and animals when the national average is 48 per state! Warehousing can
lead to ecological collapse of the chain of wildlife between San Gorgonio and San Jacinto
Mountains that needs to migrate across Interstate 10.
EXHIBIT M – Sixty prominent organizations on public health and safety and the environment
petitioned Governor Newsom on January 24, 2024, asking for an immediate moratorium on
warehousing approvals because the Inland Empire warehousing approvals abandon and threaten
climate control objectives set by the State of California. The State of California has pending
legislation and is in the process of responding.
We ask the City Council to take a regional leadership position on behalf of its citizens. Given the
data on transportation gridlock, serious and life-threatening contamination of the air, and threats
to the biology and tourism economy of the region, immediate action is required. Since each city
is an incremental part of the problem, what is needed is strong leadership.
With regard,
Jane Garrison,
Execu4ve Director
ATTACHMENTS
01/23/2025
Public Comment
Item 2A
1
January 24, 2023
Governor Gavin Newsom
1021 O Street, Suite 9000
Sacramento, CA 95814
CC:
Attorney General Rob Bonta
Office of the Attorney General
1300 "I" Street
Sacramento, CA 95814-2919
Superintendent Tony Thurmond
California Department of Education
1430 N Street, Suite 5602
Sacramento, CA 95814-5901
RE: Over Sixty Organizations Urge Gov. Newsom to Declare a Public Health State of Emergency
in the Inland Empire
FMI:
rrc@pitzer.edu
admin@ccaej.org
Honorable Governor Newsom,
We write to you as representatives of environmental, labor, health, community, and academic
groups to urge you to declare a state of emergency for public health in California’s Inland
Empire (IE) due to the unchecked escalation of warehouse growth and an accompanying health
crisis within Inland communities. This letter summarizes a longer working paper entitled “A
Region in Crisis: The Rationale for a Public Health State of Emergency in the Inland Empire,”
which follows this letter.
In the Inland Empire, warehouse growth is one of the most critical environmental justice
issues of our time. The rise of e-commerce since the COVID-19 pandemic has brought
warehouse growth, decreased air quality, and health inequities into sharp focus. The distinctive
bowl shape of Inland geographies, combined with the Inland Empire’s role as a global logistics
hub, has led to increased rates of cardiac, respiratory, and reproductive health impacts, as well
as cancers, related to truck emissions.1
1 See Bailey, Diane, and Gina Solomon. "Pollution prevention at ports: clearing the air." Environmental impact
assessment review 24.7-8 (2004): 749-774; Palaniappan, Meena. "Ditching diesel: Community-driven research
reduces pollution in West Oakland." Race, Poverty & the Environment 11.2 (2004): 31-34; Wildberger, Sharon, and
Amanda Northcross. "Latino Communities, Diesel Exhaust and Environmental Justice in the United States: A
Systematic Review of the Literature." (2018).
01/23/2025
Public Comment
Item 2A
2
Approximately 90% of warehouse growth in the Southland has occurred in Inland counties
over the last decade.
The Inland Empire has approximately 1 billion square feet of warehouse space , with an
additional 170 million square feet currently approved or pending (see Appendix 1). Alarming
statistics accompany this footprint: pollution and carbon emissions, increased heat, traffic, and
health and safety issues both in the workplace and in our communities.
Figure 1: Partial map of the current warehouse footprint in Western San Bernardino and Riverside Counties. Courtesy of
Warehouse CITY. Robert Redford Conservancy and Radical Research LLC. https://radicalresearch.shinyapps.io/WarehouseCITY/
According to Warehouse CITY, the Inland Empire’s 4,000 warehouses generate:
● Over 600,000 truck trips per day;
● ~1,000 pounds of Diesel PM per day;
● ~100,000 pounds of NOx per day, and
● Over 50,000,000 pounds of CO2 per day.
Annually, this equals
● Over 200 million truck trips;
● Over 300,000 pounds of Diesel PM;
● Over 30 million pounds of NOx, and
● Over 15 billion pounds of CO 2 per year
01/23/2025
Public Comment
Item 2A
3
Warehouses are currently increasing at five times that rate of population growth. These
numbers are the opposite of what we need to be doing at this critical moment in human
history. Calculated at the established (low) rate of $51 per ton,2 the cost of carbon for Inland
warehouses is approximately $350,000,000 annually.
An additional 170 million square feet of warehouse space will yield a 10% increase in those
emissions over the next few years. By comparison, population growth is 0.55%. Fleet
electrification is not expected to be complete until 2045, and even that will not address health
and safety issues in the workplace, safe routes on the streets, the urban heat island effect, lack
of water percolation issues, noise, or traffic.
Please note that these numbers do not include other elements of goods movement
transportation (locomotives, ocean-going vessels, and cargo planes) or the direct health costs
to Inland communities, which disproportionately fall upon communities of color that are
already burdened by historic environmental injustices.
Figure 3. Western portion of SB and Riverside Counties demonstrating proximity of schools (purple) to warehouses (brown) and
overlaid with CalEnviroScreen data on Diesel Particulate Matter exposure (gray gradient). Courtesy Radical Research, LLC and
the Redford Conservancy, Pitzer College.
• Over 300 warehouses are 1000 feet or less from 139 Inland Empire schools; over 600
warehouses surround these same schools at 1500 feet.3
2 https://news.stanford.edu/2021/06/07/professors-explain-social-cost-carbon/
3 Courtesy of warehouse CITY school, Radical Research LLC.
01/23/2025
Public Comment
Item 2A
4
• Unhealthy air quality days in SB County rose from 14.8% in 2019 to 19.7% in 2020.4
• 20,000 children have missed 11 or more days of school in SB and Riverside Counties
within the last 12 months.5
• In 2010 337,445 of Inland Empire residents lived within ¼ mile of a warehouse; by 2022
this number grew by 30,000 to 367,584 individuals, roughly 60% of whom are Latino.6
● Some census tracts within SB County have close to a 20% asthma rate; in Riverside
County, some census tracts have over a 15% asthma rate.
● The Inland Empire has the highest concentrations of ozone in the country according to
the American Lung Association 7 and CalEnviroScreen 4.0’s most recent report.8
● Diesel exhaust is responsible for about 70 percent of the total cancer risk from air
pollution; cancer risk is in the 95th percentile near the Ontario warehouse gigacluster –
equaling 624 people per million, which is 95% higher than the rest of the basin.9
● The AQMD reports higher risks from PMs for people who live within a half mile of
warehousing facilities, where the asthma rate average is 56 per 10,000 individuals (64th
percentile) and heart attack rates are 9.2 per 10,000 individuals (65th percentile). This is
over ten percentile points higher than comparison areas.10
These are signs of an escalating health crisis. In addition to the above, Inland populations
suffered COVID-19 infection and mortality at higher rates, because people’s immune systems
were weakened due to chronic pollution exposure.11 Inland populations, especially children, are
also experiencing RSV hospitalizations at an increased rate for the same reason.12
4 Source: U.S. Environmental Protection Agency, Air Data (www.epa.gov/outdoor-air-quality-data)
5https://ask.chis.ucla.edu/ask/SitePages/AskChisLogin.aspx?ReturnUrl=%2fAskCHIS%2ftools%2f_layouts%2fAuthe
nticate.aspx%3fSource%3d%252FAskCHIS%252Ftools%252F%255Flayouts%252FAskChisTool%252Fhome%252Easp
x&Source=%2FAskCHIS%2Ftools%2F%5Flayouts%2FAskChisTool%2Fhome%2Easpx#/population
6 ESRI GIS data community summary statistics generated by the David Robinson, Robert Redford Conservancy.
These data should be considered preliminary.
7 American Lung Association State of the Air 2022 https://www.lung.org/research/sota/key-findings/most-
polluted-places
8 California Office of Environmental Health Hazard Assessment
https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40
9 Data from the Air Quality Management District’s (AQMD) MATES V data visualization tool.
https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23?views=view_38
10 SCAQMD, Second Draft Socioeconomic Impact Assessment for Proposed Rule 2305–Warehouse Source Rule-
Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program and Proposed Rule 316–Fees for Rule
2305.
11 Ober, Holly Poor Air Quality and warehouses linked to Inland Empire COVID-19 inequities UC riverside professors
call for intersectional approach to COVID-19 exposure interventions
https://insideucr.ucr.edu/stories/2021/06/02/poor-air-quality-and-warehouses-linked-inland-empire-covid-19-
inequities
12 Downey, David. RSV surge sending children to the emergency rooms in Inland Empire. November 6, 2022. San
Bernardino Sun.
https://www.pressenterprise.com/2022/11/06/rsv-surge-sending-children-to-emergency-rooms-in-inland-empire/
01/23/2025
Public Comment
Item 2A
5
These numbers are the cumulative result of decades of municipal decision-making. The current
“land rush” for warehouse space has artificially inflated the price of land, making alternative
land uses and employment opportunities impossible.
Diesel emissions related to warehouse projects disproportionately impact already
overburdened environmental justice communities, in violation of GOV § 65302(h)(1)(A), which
is meant to reduce pollution in disadvantaged communities.13 We can track trends to a degree,
but more refined and current data are needed. For example, CalEnviroscreen asthma and pm
data are from 2012-2017. In the period since, over 650 warehouses have been added to the
region, bringing with them an estimated 140k truck trips per day.
Warehouse-induced pollution has created a state of environmental injustice and a public
health crisis in San Bernardino and Riverside Counties. Environmental justice groups have
spoken out for decades against the health impacts warehouses have had on our communities.
Local leadership has failed to be accountable for these health impacts. Developers throughout
the region make donations to City Council elections that are significantly above AB 571 limits
(see Appendix 3). Organizing and litigation fail to halt projects whose outcomes seem
predetermined. Our struggles have become a string of losses with human life and health as
collateral damage. In the words of one Colton resident, “It's been very scary fighting all of this.
It feels like no one’s listening.”14
We know this because we and our families live this reality every day –dealing with asthma
attacks, bloody noses, hospitalizations, and coronary episodes. One Bloomington mom
described her situation, “I have asthma and my family has asthma. But lately my ast hma has
gotten so severe. Last night I had to take more inhalers, more puffs, than I normally do. My kids
are showing signs. I'm scared. I'm frightened they're going to have an asthma attack. One of
them has an inhaler, and one of them is too small to have one. I'm really concerned about the
safety of my children.”
Warehouse and union trade workers are also at risk. Warehouse jobs include temporary labor
within the logistics sector as well as trade union workers involved in warehouse and
infrastructure construction. Though they have different challenges, all workers, including
unionized trade workers, are exposed to airborne pollutants from poor air quality, and work-
related health and safety issues with both short term and long-term health consequences.
Government and corporate leadership, the public, economists, and public health advisors
must consider the net health and welfare compromises to the current workforce, and the
13 (A) Identify objectives and policies to reduce the unique or compounded health risks
in disadvantaged communities by means that include, but are not limited to, the reduction of pollution exposure,
including the improvement of air quality, and the promotion of public facilities, food access, safe and sanitary
homes, and physical activity.
14 All quotes from individuals cited in this document are from a conference held at Pitzer College called “The Right
to Breathe.” A short documentary of this film may be found at
https://www.pitzer.edu/redfordconservancy/ecodocumentaries/. Names have been omitted to protect residents.
01/23/2025
Public Comment
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6
viability of the future work force. Our working paper outlines these compromises, which
include high rates of respiratory illness, high or unaffordable health costs associated with labor
practices, poor schooling outcomes and educational under-attainment, and high worker
turnover due to acute and chronic health problems. Health risks to the people of the IE
threaten the nation’s supply chain reliability and are a leading indicator for health impacts at
a national level. Yet a false dichotomy continues to pit the need for good jobs against
environmental, economic, and health-related harms. In the words of AG Bonta, we should not
need to sacrifice one for the other.
Warehouses constitute a regulatory gray area. A regional moratorium–or temporary halt in
warehouse construction–is required to address the gaps in current legislation and statutes that
allow for continued building of warehouses despite significant health impacts that are currently
deemed unavoidable. Without such a pause, the health, efficiency, and viability of the IE
community health, environment, and economy are threatened.
Continued warehouse growth despite community harm and widespread neighborhood
opposition is environmental racism in its classic terms. We have attended hundreds of
meetings, sometimes registering thousands of comments opposing specific projects, only to
have our voices ignored in decision-making that simply rubber stamps projects. We have
litigated, educated, and raised awareness among civic leaders for years. Our city and county
leaders continue to make decisions that ignore science, public health, and the communities that
they represent. We have nowhere else to turn other than to our Governor and our state leaders
to ask for intervention and support for the solutions laid out in this request.
We ask for the following interventions:
1. Declare a regional warehouse moratorium of one to two years that allows time to
implement policy changes.
2. Identify communities of high exposure from warehouse and/or industrial land uses ;
create higher standards supported by the state for project approval in high exposure,
environmental justice, and disadvantaged communities.
o Mandate a higher-level of community engagement at the beginning stages of
any project independent of the developer.
o From a project’s inception, provide external oversight from a DOJ attorney, so
that disproportionately impacted communities are represented by legal counsel.
o Mandate mitigation plans that include quantifiable reductions in GHGs and
pollutants, including project reduction and demand-management strategies.
o Work collaboratively with schools and community groups to establish
benchmarks and funding streams for community health in impacted
neighborhoods.
o Mandate up-front mitigation of environmental harms, including but not limited
to
▪ green infrastructure/just energy transition elements
01/23/2025
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7
▪ community benefits agreements that include unionized labor
▪ mitigation for farmland, greenspace, residential, and habitat loss
▪ mitigation for health impacts—for example, a fair share fees health and
trade system wherein industrial and warehouse projects pay into a
healthcare and greenspace fund; can be used to expand healthcare, fund
green infrastructure, fund studies and tracking, and retrofit schools
adjacent to truck routes or warehouses, among other uses.
o Strengthen cumulative impact analysis to include all past, present, and future
industrial projects within a tiered radius consistent with the scoping plan of the
project, including travel routes.
o Tie warehouse project approval to real-time rather than projected fleet
electrification. Consider tiered options such that no further warehouse
construction is allowed in the SCAQMD basin until the fleet is 20% electrified,
and no further warehouse construction is allowed in environmental justice
communities until the fleet is 50% electrified.
o Mandate that city councils, planning commissions, SCAG board members, and
other relevant leaders undergo a training of at least forty hours on
environmental justice, community health, and the climate crisis to inform their
decision making.
3. Work collaboratively with the Office of Planning and Research, CARB, and impacted
communities to codify best practices resulting from guidance documents and
settlements that regulatory bodies, the Attorney General, or other litigants have
established for warehouse projects. These should include but not be limited to project
and fleet electrification, solar energy generation, siting truck, rail, and airplane routes
away from sensitive receptors, mitigation, limiting of vehicle miles traveled, community
benefits agreements, and setbacks from sensitive receptors. Authorize the Attorney
General to enforce these provisions within the Inland Empire.
o Mandate consideration of demand-management strategies among the tools to
decrease emissions and exposure at state and local levels; align future
warehouse expansion rates with population growth as opposed to distant
consumer demand.
o Explore and support project alternatives that would contribute to community
health and well-being, economy, and environmental benefit.
o Provide funding for a long-term cross-sectional health cohort study.
4. Expand or enforce existing regulations that are inconsistently enforced or unenforced at
a local level.
o Establish an oversight board for the SCAQMD 2305 indirect source rule to
monitor compliance.
o Formalize a state definition of sensitive receptors that protects those under this
definition; include penalties for those who violate this protection.
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o Enforce existing state limits for campaign contributions per AB 571, and prohibit
developer donations to city councils or other decision-making bodies within
three years of pending decisions.
▪ Perform a fiscal audit of Inland cities, beginning with Fontana, Ontario,
San Bernardino, and Moreno Valley, to determine any potential local
leaders' quid pro quo relationships with developers.
o Amend SB 352, which requires extra testing of air pollution sources within ¼ mile of
any schools to determine whether a new school within 500 feet of a heavily
trafficked road or industrial sites will pose a health hazard to students and teachers
due to air pollution. Amend to include the inverse: that the same rules apply to
warehouse siting in proximity to schools. Extend the distance to 500 meters, which
was the distance based on the original USC air pollution/health study.15
o Aligned with the 30x30 plan, earmark state funds to preserve Inland greenspace,
biodiversity, habitat, and farmland—all of which are linked to community health,
pollution remediation, carbon sequestration, and climate resilience.
For our part, we will continue to work on public health statistical data gathering and analysis to
empower our communities to make a difference with these data. To close, we cite one of many
IE residents who struggle with health, safety, and quality of life issues related to warehouses:
“It's not just about us. It's about everybody in the community. And it's not just about the city
that you live in. It's about the Inland Empire as a whole and beyond.”
We have a right to a life not impacted by asthma, heart disease, cognitive, and reproductive
problems related to pollution exposure. We have a right to not be made sick by the air we
breathe.
We therefore ask that the State of California issue a resolution declaring a state of emergency
and public health crisis in the Inland Empire. Sample language for such a resolution may be
found at the link below. Appendices with maps and charts follow the list of signatories. Thank
you for your consideration and time.
Sample Resolution Reference:
https://docs.google.com/document/d/1fb5QDh1Wm0M4U9axuBlp01K-
VIfbebOtha002w55xAg/edit?usp=sharing
Sincerely,
Amparo Muñoz, Policy and Special Projects Director
Center for Community Action and Environmental Justice
15 https://news.usc.edu/199179/usc-childrens-health-study-now-30-years-old-raises-nationwide-awareness-of-
pollutions-harms/
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Susan Phillips, Director
Robert Redford Conservancy for Southern California Sustainability
Professor of Environmental Analysis, Pitzer College
Mary Ann Ruiz, Chair
Sierra Club, San Gorgonio Chapter
Mike McCarthy, Founder
Radical Research, LLC
Jennifer Larratt-Smith, Representative
R-NOW-Riverside Neighbors Opposing Warehouses
Ana Gonzalez, Executive Director
Center for Community Action and Environmental Justice
Mario Vasquez, Organizer
Teamsters Local 1932
Victor Quito
United Auto Workers, Division 6
Marc Carrel, President & CEO
Breathe Southern California
Ivette Torres, Lead Researcher
People’s Collective for Environmental Justice
Tom Dolan, Executive Director
Inland Congregations United for Change
Carolina Sanchez, Co-Director
Just SB
Sheheryar Y. Kaoosji, Executive Director
Warehouse Worker Resource Center
Ana Carlos, Community Member
Concerned Neighbors of Bloomington
North End Pepper Neighborhood Watch
Cynthia Martinez, President
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South Fontana Concerned Citizens Coalition
Ron Cobas, Vice President
Clean and Green Pomona
Marissa Brash, Chair
Department of Public Health, Azusa Pacific University
Mirna Ruiz, Secretary
Chicano Latino Caucus of San Bernardino County
Joan Donahue, President
League of Women Voters, Riverside CA
Jhon Luna, Regional Policy Advocate
CHIRLA
Malissa McKeith, Founder and President
Citizens United for Resources and the Environment
Steve Bardwell, President
Morongo Basin Conservation Association
Paul Hawken, Executive Director
Project Regeneration
Randy Bekendam, Executive Director
Southern California Agricultural Land Foundation
Faraz Rizvi, Campaign and Policy Manager
Asian Pacific Environmental Network
V. John White, Executive Director
Center for Energy Efficiency and Renewable Technologies
Sky Allen, Executive Director
Inland Empire United
Ellie Cohen, CEO
The Climate Center
Gregory Stevens, NorCal Director
California Interfaith Power and Light
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Andrea Marpiller-Colomina, Sustainable Communities Program Director
GreenLatinos
Anthony Noriega, Director District 5
League of United Latin American Citizens de Inland Empire
Donna Lee, Regional Organizer
Climate Witness Project
Javier Hernandez, Executive Director
Inland Coalition for Immigrant Justice
Lois Sicking Dieter, Founder
Inland Valley Advocates for the Environment
Angela Miramontes, Outreach Coordinator
Amigos de los Rios
Bobbi Jo Chavarria, Volunteer Organizer
GROW Fontana
Najayra Valdovinos Soto, Youth Engagement Coordinator
Inland Empire Immigrant Youth Collective
Bobbi Jo Chavarria, Founder
Progressive Alliance of the Inland Empire
Nicolas Ratto, Transportation Lead
350 Bay Area Action
Diane Takvorian, Executive Director
Environmental Health Coalition
Marven Norman, Executive Director
Inland Empire Biking Alliance
Christy Zamani, Executive Director
Day One
Susan St. Louis, Climate Crisis Committee Chair
Courageous Resistance of the Desert
vonya quarles, Director
Starting Over, Inc.
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Dr. Sharon Mateja
Residents for Responsible Representation
Hallie Kutak, Staff Attorney | Senior Conservation Advocate
Center for Biological Diversity
Lolofi Soakai, Founder/Executive Director
MALO Motivating Action Leadership Opportunity
Julio Marroquin, Executive Director
Centro del Inmigrante
Nan Freund, Educational Therapist
Educational Services Associates
Jorge Herida, Executive Director
The Garcia Center for the Arts
Dr. Sunni Ivey, Assistant Professor UC Berkeley
Air Quality Modeling and Exposure Lab
Resa Barillas, Inland Empire Regional Organizer
California Environmental Voters
James Bloyd, Dr, PH, MPH, Coordinator
Collaborative for Health Equity, Cook County
Kris Lovekin, Coordinator
350 Riverside
Adrienne Thomas, President
SistersWe Community Garden Projects
David Marrett, Co-Chair
Climate Reality Projects, Riverside County Chapter
Andy Hettala, Co-Chair
Climate Reality Project, Los Angeles County Chapter
Lisa Swanson, Policy Chair
Climate Reality Project, Orange County Chapter
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Stafford Ocansey, Executive Director
Children’s Environmental Literacy Foundation (CELF)
Christian Shaughnessy
Inland Empire Democratic Socialists of America
Sharon Wilber, Climate Policy
Redlands Area Democratic Club
Hilda Cruz, IE Regional Program Director
Interfaith Movement for Human Integrity
David Matuszak, Coordinator and President
Friends of Live Oak Canyon Firewise Community
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14
Appendix 1. Chart of pending and approved warehouses in SB and Riverside
Counties
Project Size (sq ft) Location
World Logistics Center
40,400,400 Moreno Valley
Legacy Specific Plan - phase 2 14,625,000 Beaumont
Stoneridge Commerce Center 9,398,070 Unincorporated Riverside County
(Nuevo)
Merrill Commerce Center Specific Plan 7,014,000 Ontario
Speedway 6,600,000 SB County
Sunset Crossroads 5,500,000 Banning
South Ontario Logistics Center Specific Plan Phases 2 5,412,591 Ontario
West Campus Upper Plateau 4,500,000 March JPA
Hesperia Commerce Center II 3,745,429 Hesperia
Legacy Specific Plan Project 3,580,200 Beaumont
West Valley Logistics Center 3,439,197 Fontana
Project Viento 3,424,698 Desert Hot Springs
Bloomington Business Park 3,235,836 Bloomington (SB County)
South Ontario Logistics Center Specific Plan Phase I 3,172,780 Ontario
Apple Valley 143 2,628,000 Apple Valley
Renaissance Ranch Commerce Center 2,509,056 Horsethief Canyon (Riverside Co)
Northern Gateway Commerce Center 2,487,625 Menifee
South Perris Industrial Project 2350000 Perris
Veteran's Industrial Park 2,000,000 March JPA
Ontario Ranch 1,905,027 Ontario
I-15 Industrial Park 1,850,000 Hesperia
Meridian South Campus Buildings E, F, G, H, I, 1, 2, 3,
and a couple more
1,800,000 March JPA
Ontario Ranch subsequent 1,640,690 Ontario
Menifee Commerce Center 1,640,130 Menifee
Legacy Specific Plan - phase 2 cold 1,625,000 Beaumont
Banning Commerce Center 1,320,000 Banning
Altitude Business Center 1,313,000 Chino
Moreno Valley Trade Center 1,300,000 Moreno Valley
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Majestic Freeway Center 1,219,222 Unincorporated Riverside County
Beaumont Summit Specific Plan 1,213,235 Beaumont
I-15 Logistics Center (Lytle Creek) 1,170,820 Fontana
Chino Majestic Heritage 1,168,710 Chino
Rider and Patterson Business Center 1,167,000 Unincorporated Riverside County
Knox Business Park 1100000 Unincorporated Riverside County
9th & Vineyard Development 1,037,467 Rancho Cucamonga
Southern California Logistics Airport Lot 44 Distribution
Center
1,030,308 Victorville
Ottawa Business Center 996,194 Victorville
Beaumont Summit Spec Plan 985,860 Beaumont
Ramona Gateway 950,000 Perris
Chino Majestic Heritage 914,000 Chino
Heacock Commerce Center 874,000 Moreno Valley
OLC3 - Ramona Expwy & Perris Blvd. Commercial
Warehouse Project
774,000 Perris
Duke Warehouse 770,000 Perris
Dara Industrial 750,000 Hesperia
Oleander Business Park 710,000 Unincorporated Riverside County
CADO Menifee Industrial Warehouse 700,037 Menifee
Barker Logistics 700000 Unincorporated Riverside County
Speedway Commerce Center 650,960 Rancho Cucamonga
Mapes Commerce Center 650,000 Perris
Orchard Logistics 610,000 Beaumont
Sycamore Hills Distribution Center 603,100 Riverside
Potrero Logistics 577,920 Beaumont
First March Logistics Project 559000 Perris
United States Cold Storage Hesperia 515,334 Hesperia
Pepper Ave 485,000 Rialto
Harvill Business Center 434,000 Unincorporated Riverside County
Mountain View Industrial 420,937 Redlands
Legacy Specific Plan Project - cold storage 397,800 Beaumont
Nevada & Palmetto Commerce Center 381,000 Redlands (SB County)
Beaumont Summit Specific Plan 358,370 Beaumont
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Seaton Ave and Cajalco Rd. Industrial Project 350,000 Unincorporated Riverside County
Perris Valley Commerce Center 347000 Perris
Harvill and Rider 334,000 Unincorporated Riverside County
Redlands Ave West Industrial Project 334000 Perris
Perris Blvd. & Morgan St. Industrial Park Project 283000 Perris
Placentia Logistics 274,000 Unincorporated Riverside County
Duke Slover & Alder 259,481 Bloomington (SB County)
Redlands Ave East Industrial Project 254,500 Perris
Alere Property Group (Redwood Area) 245,000 Fontana
Muranaka Warehouse Project 239000 Unincorporated Riverside County
Ramona-Indian Warehouse project 232575 Perris
Durst Drive Warehouse 201,239 Rialto
Meridian D-1 Aviation Gateway 200,000 March JPA
Temescal Valley 181,495 Unincorporated Riverside County
Multi-Tenant Industrial Warehouse 179,400 Redlands
Ramona Expwy & Brennan Ave Warehouse project 165000 Perris
Moreno Valley Business Center 164,200 Moreno Valley
First Harley Knox Industrial 158000 Perris
Wilson Avenue Project 154000 Perris
Operon 148000 Perris
Harlex Knox Blvd. Industrial project 143000 Perris
Edgemont Commerce Center 142,000 Moreno Valley
Chartwell Warehouse 132,000 Perris
Old 215 Business Park Project 118,600 Riverside
Phelan Warehouse 109000 Perris
Sierra-Summit 102,380 Fontana
Marlborough Northgate Light Industrial Project 100000 Riverside
Seaton Ave and Perry St. Industrial Project 99,000 Unincorporated Riverside County
Kirschner company LLC 25,000 Fontana sphere of influence/SB C
Airport Gateway Specific Plan 9,271,000 SB County
EST TOTAL SQUARE FOOTAGE 170,965,873
Please note that this list is incomplete. Pending warehouse construction; pending approval within CEQA
https://ceqanet.opr.ca.gov/
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Appendix 2. Chart demonstrating the purposeful removal of AB 571 limits of
several Inland cities.
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Appendix 3. Additional maps demonstrating school proximity to warehouses.
Detail of schools and warehouses within Jurupa Valley-Fontana area, with schools shown in purple and
warehouses in brown. DPM percentiles are shown in gray and based on CalEnviroScreen data. Courtesy of Radical
Research, LLC and the Redford Conservancy, Pitzer College.
In purple, Val Verde High School and Val Verde Elementary School in Perris are surrounded by warehouses, which
are surrounded by 1000 ft and 3000 ft buffers in brown.
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Detail of Bloomington Phase 1. Once built out, the project will impact five schools. 90 homes will be razed for this
project. The school on the right is Zimmerman Elementary, which has now been bought by warehouse developers.
Brown shapes are warehouses with pollution buffer zones of 1000 and 3000 feet.
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Appendix 4: Logos of sign on organizations. Disclaimer: The views expressed in
this document are those of the authors and do not necessarily represent the views of Pitzer
College or any other entity whose logo appears on this document.
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01/23/2025
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01/23/2025
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Item 2A
From:Michael McCarthy
To:City Clerk
Subject:public comment letter on agenda item 2A for January 25th City Council Meeting - re: SCH# 2023080091 - Palm
Springs Fulfilment Center
Date:Thursday, January 23, 2025 12:39:02 PM
Attachments:PalmSpringFulfilment.pdf
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.
Good afternoon City Clerk,
Attached please find a public comment on agenda item 2A on the Palm Springs Fulfilment
Center for tonight’s city council meeting.
Please confirm receipt at your earliest convenient opportunity.
Mike McCarthy, PhD
01/23/2025
Public Comment
Item 2A
1
SENT VIA EMAIL
January 23, 2025
Brenda Pree, City Clerk
City of Palm Springs
Email: cityclerk@palmspringsca.gov
RE: Public comment for Item 2A – Appeal of Planning Commission’s decision to certify an
FEIR for the Palm Springs Fulfilment Center – SCH #2023080091
Honorable Councilmembers, Mayor, City Clerk,
Thank you for the opportunity to provide comments on appeal of the planning commission’s
decision to certify the Environmental Impact Report (EIR) on the Palm Springs Fulfilment
Center (the Project) – SCH# 2023080091.
My name is Dr. Mike McCarthy. I am an environmental consultant and community activist in
the City of Riverside. A warehouse project in my backyard inspired me to create the warehouse
CITY1 tool, which I have been using to track existing and under environmental review
warehouse projects in Southern California since 2022.
The Palm Springs Fulfilment Center is part of a growing trend of warehouse projects in the high
and low desert areas of Southern California. At the current moment, there are about 9,000 acres
of warehouse projects approved in Southern California, and another 13,500 acres under
environmental review. Cumulatively, that is half-a-billion square feet of additional warehouses
to be added to the roads in our region. These projects are never analyzed holistically within the
context of the largest warehouse concentration in North America, and instead are analyzed
piecemeal.
Current warehouse vacancy rates are 6.9% as of Q4 2024 in the Inland Empire, with significantly
higher rates of vacancy in 'hinterlands’ warehouses further from the ports2. Asking rents at
warehouses have dropped 25% since mid-2022 (from $1.63 psf to $1.16 psf)2 and there are 4,700
fewer jobs in the Warehousing, Transporation, and Wholesale Trade employment categories in
November 2024 than there were on November 20223. Recent layoffs of over 2,000 warehouse
workers in Moreno Valley, Bloomington, Perris, Apple Valley, and San Bernardino highlight the
continuing woes in this sector4.
Beyond the economics, I briefly reviewed the EIR and have significant concerns with the
transportation analysis and subsequent air quality and greenhouse gas emissions calculated for
the project. The project applicant identifies the project as a “High-Cube Warehouse” and the
project is described as a ‘fulfillment center’. The Institute of Transportation Engineers 11th Trip
Generation Manual provides multiple land-use category trip rates and is the standard reference
for assigning trip rates. Table 1 shows the trip by warehouse category.
1 https://radicalresearch.shinyapps.io/WarehouseCITY/
2 https://www.colliers.com/en/research/los-angeles/inland-empire-industrial-research-report-2023-q1
3 https://labormarketinfo.edd.ca.gov/geography/msa/riverside-san-bernardino-ontario.html
4 https://www.freightwaves.com/news/more-than-4500-freight-related-layoffs-slated-for-firms-nationwide
01/23/2025
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2
Table 1 – ITE 11th edition total trip rates and truck rates for warehouse land use codes.
Warehouse category
ITE land use
code
Total Trip Rate
per 1000 sf
Truck rates
per 1,000 sf
Warehousing* 150 1.71 0.6
High cube transloading 154 1.4 0.22
High-cube fulfilment (non-
sort) 155 1.81
0.26
High-cube fulfilment (sort) 155 6.44 0.19
High-cube parcel 156 4.63 0.58
High-cube cold storage* 157 2.12 0.75
This project should be assigned an ITE Land use code 155 trip rate for either non-sort or sort
fulfillment center. Instead the applicant used a TUMF High-Cube Warehouse Trip Generation
study analysis which is neither industry standard, nor fulfilment center specific for its trip rate
estimates.
The two types of fulfilment centers are sort and non-sort, which categorize whether the packages
are small (think Amazon and FedEx small packages) or bulk – such as appliances, fitness
equipment and other large packages. Fulfilment centers of the first variety have the highest trip
rate of any warehouse type, at 6.44 per 1,000 sq.ft; which is a factor of three higher than 2.13 trip
rate used by the project applicant. Given that this is speculative development with no tenant
mentioned, the most conservative estimate should be applied for trip rates. The GHG and air
quality impacts from the project are therefore significantly underestimated and need to
incorporate accurate values.
Thank you for your attention to these issues. The environmental impacts of the project are likely
underestimated, and the economic value of warehouses is rapidly declining. Please reconsider
and override the Planning Commission’s decision.
Sincerely,
Michael McCarthy, PhD
Email: mikem@radicalresearch.llc
01/23/2025
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Item 2A
3
Printed on Recycled Paper. ....To explore, enjoy and preserve the nation’s forests, waters, wildlife, and wilderness.
01/23/2025
Public Comment
Item 2A
From:Jeffrey Bernstein
To:City Clerk
Subject:FW: Warehouses
Date:Thursday, January 23, 2025 12:29:15 PM
Jeffrey Bernstein
Councilmember
City of Palm Springs
cell: 442-305-9942
Jeffrey.Bernstein@palmspringsca.gov
From: angie lafferty <angielafferty1901@gmail.com>
Sent: Wednesday, January 22, 2025 9:13 AM
To: Ron deHarte <Ron.deHarte@palmspringsca.gov>; Naomi Soto
<Naomi.Soto@palmspringsca.gov>; David Ready <David.Ready@palmspringsca.gov>; Grace Garner
<Grace.Garner@palmspringsca.gov>; Jeffrey Bernstein <Jeffrey.Bernstein@palmspringsca.gov>
Subject: Warehouses
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open
attachments unless you are sure the content is safe.
Dear Mayor Ron DeHarte and City Council members,
I am opposed to any and all proposed warehouses.
Palm Springs relies on tourism funds. One it's attractions is the scenic drive into Palm
Sprigs, the feeling you get when you come upon the vast Desert, one of the most diverse
Desert Ecosystems in the world. Palm Springs truly is a place of healing, it has been for
thousands of years. Do you want to be the one to contribute to the destruction of our
precious and delicate Desert?
2024 was the hottest year on record, and the heat will continue to rise as we contribute
01/23/2025
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to the rise with the enormous amount of additional ACs the Valley will need with all of
the current and planned construction. We will continue to loose tourism during the
summer...
https://www.smithsonianmag.com/smart-news/how-much-hotter-phoenix-az-nights-
are-because-c-180951393/
Warehouses contribute to the dangers of our roadways and freeways. Big-rig accidents
shutdown Freeway 10 at an alarming rate. How many lives have been lost to these
accidents? Big-rigs add to the dangerous levels of pollutants. Palm Springs wants to
create a Blue Zone, allowing warehouses is not "a healthy choice."
https://cdllife.com/2022/report-blames-big-rig-drivers-for-causing-more-wrecks-than-
their-numbers-would-suggest-in-coachella-valley/
Regarding the warehouse takeover on the 215 Freeway corridor: April 12, 2022 -
Riverside County Supervisor, Kevin Jeffries: "SCE told County Officials that-it can no
longer provide power to the warehouses"
City Officials are greenlighting warehouse and warehouses are built without accessible
power....Have you seen the 'For Lease' sign on numerous warehouses along the 10, 60
and 215 Freeways. 20 years ago there was no need for all of the warehouses, within 20
years there will no longer be a need for the overwhelming amount of warehouses
currently standing. We will be left with vacant heat islands.
https://www.pressenterprise.com/2022/04/15/new-warehouses-by-215-freeway-wont-
have-enough-power-riverside-county-official-says/
We live in one of the most diverse Desert ecosystems in the world and we are
destroying it by continuing to allow the development of heat islands.
https://www.newscientist.com/article/2464408-air-monitoring-station-records-biggest-
ever-jump-in-atmospheric-co2/
Thank you for your time,
Angie Lafferty
La Quinta CA
01/23/2025
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From:Tamara Diamond
To:City Clerk
Subject:Fwd: Air Quality
Date:Wednesday, January 22, 2025 2:06:30 PM
Attachments:AIR QUALITY MEETING 9-12-24.doc
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.
Hello Palm Springs City Clerk and City Council,
Kerry Berman asked me to forward his letter to you regarding air quality issues around the local large
warehouse industry. I put the most critical sentence in quotes here, which is an excerpt from his
attached letter.
---------- Forwarded message ---------
From: Kerry Berman <kerry@kerryberman.com>
Date: Mon, Dec 2, 2024 at 6:09 AM
Subject: Air Quality
To: Tamara Diamond <4tamaradiamond@gmail.com>
"With hundreds of warehouses throughout Riverside and San Bernardino using thousands
of diesel trucks, fires everywhere that funnel the particulate matter through the San
Gorgonio Pass the PM2 – PM10 is through the roof. (devastating to not only those who
have respiratory problems but to those who don’t)."
I hope the leadership puts more value on our quality of life versus $$$
------------------------
Kerry Berman
Certified Interpretive Guide
Conservation Ambassador - Sonoran Desert
California Naturalist
Published Author
(805) 298-4040
kerryberman.com
Get A Copy of My Books:
You're Not Alone: Our Journey ~ God’s Destination
Enchanted Valley: Palm Springs and Beyond
YOU MAKE A LIVING BY WHAT YOU GET,
YOU MAKE A LIFE BY WHAT YOU GIVE.
SERVICE TO HUMANITY IS THE BEST WORK OF LIFE
01/23/2025
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Kerry Berman’s
Desert Discovery Eco
Tours
kerry@kerryberman.com
www.kerryberman.com
805-298-4040
Air Quality in Coachella Valley
For over 40 years our local media; The Desert Sun and
Channel 3 News has consistently and accurately kept us informed
of the air quality and causes.
The fact that we are here today discussing the need to form
a new committee reminds me of the Salton Sea that is on the brink
of an environmental disaster which has been studied for over 60
years, and millions spent on investigative committees to find a
solution.
We know the air quality in the valley has not met acceptable
standards by the AQMD since the 90’s. Per their report of 2016
that explains in depth on chapter 7 entitled “Current and Future
Air Quality – Desert Nonattainment Areas SIP.
With hundreds of warehouses throughout Riverside and San
Bernardino using thousands of diesel trucks, fires everywhere
that funnel the particulate matter through the San Gorgonio Pass
the PM2 – PM10 is through the roof. (devastating to not only
those who have respiratory problems but to those who don’t).
Coupled with the problems at the Salton Sea as the
chemically laden dust blows north during the monsoonal season, it
is no wonder we have a problem.
01/23/2025
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WE DON’T NEED TO WASTE MORE MONEY, THE
CAUSES ARE QUITE OBVIOUS.
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From:angie lafferty
To:City Clerk
Subject:Fwd: Warehouses
Date:Wednesday, January 22, 2025 1:30:39 PM
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.
Obviously, this is a duplicate email. I realized that I needed to send the email to the City Clerk
as well.
Thank you,
Angie Lafferty
---------- Forwarded message ---------
From: angie lafferty <angielafferty1901@gmail.com>
Date: Wed, Jan 22, 2025 at 9:12 AM
Subject: Warehouses
To: <Ron.deHarte@palmspringsca.gov>, <Naomi.Soto@palmspringsca.gov>,
<David.Ready@palmspringsca.gov>, <Grace.Garner@palmspringsca.gov>,
<Jeffrey.Bernstein@palmspringsca.gov>
Dear Mayor Ron DeHarte and City Council members,
I am opposed to any and all proposed warehouses.
Palm Springs relies on tourism funds. One it's attractions is the scenic drive into Palm Sprigs,
the feeling you get when you come upon the vast Desert, one of the most diverse Desert
Ecosystems in the world. Palm Springs truly is a place of healing, it has been for thousands of
years. Do you want to be the one to contribute to the destruction of our precious and delicate
Desert?
2024 was the hottest year on record, and the heat will continue to rise as we contribute to the
rise with the enormous amount of additional ACs the Valley will need with all of the current
and planned construction. We will continue to loose tourism during the summer...
https://www.smithsonianmag.com/smart-news/how-much-hotter-phoenix-az-nights-are-
because-c-180951393/
Warehouses contribute to the dangers of our roadways and freeways. Big-rig accidents
shutdown Freeway 10 at an alarming rate. How many lives have been lost to these accidents?
Big-rigs add to the dangerous levels of pollutants. Palm Springs wants to create a Blue Zone,
allowing warehouses is not "a healthy choice."
https://cdllife.com/2022/report-blames-big-rig-drivers-for-causing-more-wrecks-than-their-
numbers-would-suggest-in-coachella-valley/
Regarding the warehouse takeover on the 215 Freeway corridor: April 12, 2022 - Riverside
County Supervisor, Kevin Jeffries: "SCE told County Officials that-it can no longer provide
power to the warehouses"
City Officials are greenlighting warehouse and warehouses are built without accessible
power....Have you seen the 'For Lease' sign on numerous warehouses along the 10, 60 and 215
01/23/2025
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Freeways. 20 years ago there was no need for all of the warehouses, within 20 years there will
no longer be a need for the overwhelming amount of warehouses currently standing. We will
be left with vacant heat islands.
https://www.pressenterprise.com/2022/04/15/new-warehouses-by-215-freeway-wont-have-
enough-power-riverside-county-official-says/
We live in one of the most diverse Desert ecosystems in the world and we are destroying it
by continuing to allow the development of heat islands.
https://www.newscientist.com/article/2464408-air-monitoring-station-records-biggest-ever-
jump-in-atmospheric-co2/
Thank you for your time,
Angie Lafferty
La Quinta CA
01/23/2025
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From:Brian ALLMAN
To:City Clerk
Subject:Palm Springs City Council: Warehouse Concerns
Date:Tuesday, January 21, 2025 6:30:07 PM
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.
Please distribute on my behalf to City Council et. al before Thursday Jan 23 meeting
Dear Palm Springs City Council,
I am writing to express my strong opposition to the proposed PS Fulfillment Center and
related warehouse developments north of Interstate 10. The scale of these projects is
staggering - with the initial 740,000-square-foot warehouse and three additional proposed
facilities totaling over 3.7 million square feet, these developments would dwarf the existing
150,000-square-foot FedEx facility. These massive concrete structures, reaching 50 feet in
height, fundamentally conflict with Palm Springs' commitment to environmental sustainability
and architectural excellence. The project's projected 102,000 annual truck trips would generate
significant air pollution that would blow directly into Palm Springs and neighboring
communities, severely impacting our air quality, tourism appeal, and quality of life.
Furthermore, the purported economic benefits of these warehouses are highly speculative and
potentially misleading. Without knowing the actual tenants, claims about sales tax revenue
cannot be verified, as many warehouses generate only minimal property tax revenue. The
promised 718 permanent jobs are also questionable, given the industry's increasing shift
toward automation and non-union labor. Palm Springs has consistently led the Coachella
Valley in environmentally conscious development, and we should maintain this standard by
pursuing more sustainable alternatives, such as traditional industrial parks with smaller, more
architecturally appropriate buildings that better serve our community's long-term interests and
preserve our commitment to environmental stewardship.
Respectfully,
Brian Allman
Palm Springs Resident and Concerned Citizen
310-529-6045
b.allman@verizon.net
"when things don't go right, turn left..."
01/23/2025
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From:Alisha C. Pember
To:Christopher Hadwin; Planning; Brenda Pree; City Clerk; Glenn Mlaker
Cc:Sheila M. Sannadan
Subject:Request for Mailed Notice of Actions and Hearings – First Palm Springs Commerce Center Project (SCH No.
2024010068)
Date:Tuesday, January 21, 2025 10:35:14 AM
Attachments:7733-001acp - First Palm Springs Commerce Center - CEQA Notice (01-21-25)_.pdf
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.
Good morning,
Please see the attached correspondence.
If you have any questions, please contact Sheila Sannadan.
Thank you.
Alisha Pember
Alisha C. Pember
Adams Broadwell Joseph & Cardozo
601 Gateway Boulevard, Suite 1000
South San Francisco, CA 94080
(650) 589-1660 voice, Ext. 24
apember@adamsbroadwell.com
___________________
This e-mail may contain material that is confidential, privileged and/or attorney work product for the sole
use of the intended recipient. Any review, reliance or distribution by others or forwarding without express
permission is strictly prohibited. If you are not the intended recipient, please contact the sender and
delete all copies.
01/23/2025
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January 21, 2025
Via U.S. Mail and Email Christopher Hadwin Director of Planning Services City of Palm Springs 3200 East Tahquitz Canyon Way Palm Springs, CA 92262
Email: christopher.hadwin@palmspringsca.gov; planning@palmspringsca.gov
Brenda Pree, MMC, CERA City Clerk City of Palm Springs 3200 E. Tahquitz Canyon Way Palm Springs, CA 92262
Email: brenda.pree@palmspringsca.gov; cityclerk@palmspringsca.gov
Via Email Only Glenn Mlaker, AICP, Associate Planner
Email: glenn.mlaker@palmspringsca.gov
Re: Request for Mailed Notice of Actions and Hearings – First Palm
Springs Commerce Center Project (SCH No. 2024010068)
Dear Mr. Hadwin, Ms. Pree, and Mr. Mlaker: We are writing on behalf of Californians Allied for a Responsible Economy (“CARE CA”) to request mailed notice of the availability of any environmental review document, prepared pursuant to the California Environmental Quality Act, related to the First Palm Springs Commerce Center Project (SCH No. 2024010068) (“Project”), proposed by First Industrial Realty Trust Inc. (“Applicant”), as well as a copy of the environmental review document when it is made available for public review. The Project proposes to develop two (2) warehouse buildings (“Building 1” and “Building 2”) with office spaces, truck docking areas and employee parking spaces in the in the City of Palm Springs, County of Riverside, California. Building 1 would approximate 1,516,174 square feet (SF), with 258 truck trailer docks, four (4) grade doors, 929 parking spaces for cars and trucks, of which 16 spaces would be for handicap parking, 25 bicycle parking areas, as well as external building and internal roadway lighting, landscaping, and trash enclosure areas. Building 2 would approximate 388,530 SF with 42 truck trailer docks, two (2) grade doors, 302
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parking spaces for cars and trucks, of which eight (8) spaces would be for handicapped parking, 14 bicycle parking areas, as well as external building and internal roadway lighting, landscaping, and trash enclosure areas. The approximate 91.97 acre proposed Project site is located north of the I-10 and east of SR 62, in the northern portion of the City of Palm Springs. The Project site is comprised of five (5) parcels, Assessor Parcel Numbers (APNs: 666-320-010, -011, -012, -015, and-019), and is bounded by 18th Avenue to the north, North Indian Canyon Drive tothe east, and 19th Avenue to the south. Karen Drive and Blair Road are to thewest.
We also request mailed notice of any and all hearings and/or actions
related to the Project. These requests are made pursuant to Public Resources Code Sections 21092.2, 21080.4, 21083.9, 21092, 21108, 21152, and 21167(f) and Government Code Section 65092, which require local agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.
Please send the above requested items by email and U.S. Mail to our South San Francisco Office as follows:
U.S. Mail Sheila M. Sannadan Adams Broadwell Joseph & Cardozo 601 Gateway Boulevard, Suite 1000 South San Francisco, CA 94080-7037
Email ssannadan@adamsbroadwell.com
If you have any questions, please call me at (650) 589-1660 or email me at ssannadan@adamsbroadwell.com. Thank you for your assistance.
Sincerely,
Sheila M. Sannadan Legal Assistant
SMS:acp
01/23/2025 Public Comment Item 2A
From:Howard Goldberg
To:City Clerk
Subject:Public comment on CASE 3.4361 MAJ
Date:Tuesday, January 21, 2025 10:22:19 AM
To the Council,
I am writing to oppose approval of the 739,360-foot warehouse at the NW corner of North Indian Canyon
Drive and 19th Ave.
As I live far south of there, don’t drive in that area often, and wish for more economic diversification in
Palm Springs, my instinct was to support the e-commerce development project. On further reflection, I am
not confident that the economic benefits outweigh the negative environmental impact for our region of a
giant warehouse with the resulting truck traffic. Any benefits in terms of jobs created and tax revenue are
too uncertain given the surprisingly vague proposal for the construction project. Everything I have read
about increasing robotics at fulfillment centers leads me to doubt many sustainable jobs will result.
Embracing this future for our city seems short-sighted.
Regards,
Howard Goldberg
1193 S La Verne Way
Palm Springs, CA 92264
917-692-5873
Howard@goldcat.net
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From:Cindy Cairns
To:Linda L. Holmes
Cc:CityManager; Llubi Rios; City Clerk
Subject:RE: Letter to City Council re: Opposition to PS Fulfillment Center
Date:Tuesday, January 21, 2025 8:50:28 AM
Hello Ms. Holmes – thanks for sharing your comments with us. We’ll ensure that your email is shared
with our City Council and is included as part of the official record related to this agenda item.
Kind regards,
CINDY CAIRNS | SPECIAL ASSISTANT TO CITY MANAGER
City of Palm Springs | Office of the City Manager
3200 E. Tahquitz Canyon Way, Palm Springs, CA 92262
t: 760.323.8211 | f: 760.323.8207 | cindy.cairns@palmspringsca.gov
Palm Springs City Hall is open 8 am – 6 pm Monday through Thursday, and closed
on Fridays
From: Linda L. Holmes <linholmes@aol.com>
Sent: Sunday, January 19, 2025 10:19 AM
To: CityManager <CityManager@palmspringsca.gov>
Subject: Letter to City Council re: Opposition to PS Fulfillment Center
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open
attachments unless you are sure the content is safe.
Dear City Manager:
Please forward my letter of opposition to the PS Fulfillment Center
which is on the January 23, 2025 City Council agenda.
At 740,000 square feet, the building is big enough for 12 football
fields. The project's 102,000 annual truck trips with emissions
blowing into Palm Springs will greatly negatively impact tourism and
our quality of life.
Two additional extremely huge warehouse projects are being
proposed for the same area, one at 1,516,174 square feet and the
other for 388,530 square feet, plus the adjacent First Palm Springs
Commerce Center at 1,089,747 square feet. The total of all these
proposals is 3,737,285 square feet. The gigantic concrete buildings
producing massive greenhouse gas emissions for non-union jobs will
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soon be replaced by robotics, and the estimated sales tax revenues
are extremely misleading. These projects are very damaging to the
environmental health of the citizens of Palm Springs, as well as to
the entire Coachella Valley.
Please deny the project and approve the appeal by the Committee to
Stop Warehouse blight.
Linda Holmes
501 N. Phillips Rd.
Palm Springs, CA 92262
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From:Cindy Cairns
To:James Miller
Cc:CityManager; Llubi Rios; City Clerk
Subject:RE: City Council: Opposition to PS Fulfillment Center et al
Date:Tuesday, January 21, 2025 8:49:02 AM
Hello Mr. Miller – thanks for sharing your comments with us. We’ll ensure that your email is shared
with our City Council and is included as part of the official record related to this agenda item.
Kind regards,
CINDY CAIRNS | SPECIAL ASSISTANT TO CITY MANAGER
City of Palm Springs | Office of the City Manager
3200 E. Tahquitz Canyon Way, Palm Springs, CA 92262
t: 760.323.8211 | f: 760.323.8207 | cindy.cairns@palmspringsca.gov
Palm Springs City Hall is open 8 am – 6 pm Monday through Thursday, and closed
on Fridays
From: James Miller <dnjinps@msn.com>
Sent: Sunday, January 19, 2025 11:07 AM
To: CityManager <CityManager@palmspringsca.gov>
Subject: City Council: Opposition to PS Fulfillment Center et al
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open
attachments unless you are sure the content is safe.
Dear City Manager, Scott Stiles:
Would you please forward our letter of opposition to the PS
Fulfillment Center which is on the January 23, 2025 City Council
agenda.
At 740,000 square feet, the building is big enough for 12 football
fields. The project's 102,000 annual truck trips with emissions
blowing into Palm Springs will greatly negatively impact tourism and
our quality of life.
Two additional extremely huge warehouse projects are being
proposed for the same area, one at 1,516,174 square feet and the
other for 388,530 square feet, plus the adjacent First Palm Springs
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Commerce Center at 1,089,747 square feet. The total of all these
proposals is 3,737,285 square feet. The gigantic concrete buildings
producing massive greenhouse gas emissions for non-union jobs will
soon be replaced by robotics, and the estimated sales tax revenues
are extremely misleading. These projects are very damaging to the
environmental health of the citizens of Palm Springs, as well as to
the entire Coachella Valley.
Please deny the project and approve the appeal by the Committee to
Stop Warehouse blight.
M / M James W Miller,
Shipley O "Donald" Todd, Jr
Village Racquet Club
469 Village Square West
Palm Springs, CA 92262-7832
760-861-3592 (mobile)
951-325-0089 (mobile 2)
760-408-5232 (automobile)
dnjinps@msn.com
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From:Eric Cunningham
To:City Clerk
Subject:1/23 City Council Meeting on Warehouse Approval
Date:Monday, January 20, 2025 4:51:06 PM
NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments
unless you are sure the content is safe.
Hi Palm Springs City Council,
I'm submitting this letter as a public comment ahead of the Jan 23rd Palm Springs
City Council meeting in regards to the debate over potential warehouse projects up
for approval.
Palm Springs has an excellent track record for thoughtful development and this
deserves more analysis. The desire for more high-paying jobs in the region is
admirable, but these fulfillment center-style warehouses and large-format commercial
centers are unfortunately unlikely to supply it.
Encouraging more home-grown entrepreneurship here in the Coachella Valley is the
way to do it. Instead of selling off large chunks of the city to the Amazons and
Walmarts of the world, it's time to invest in the small companies here in the valley that
will keep their profits here, instead of sending it to corporate headquarters elsewhere.
As a year-round resident here in the valley, I know there is literally nowhere else on
earth like Palm Springs, but this would be a big step to turn it into a copy of
every other boring mid-sized city.
-Eric Cunningham
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