April 20, 2023
BY USPS First Class and EMAIL
Shelby Maples, Associate Planner
Development Services – Planning
311 Vernon Street
Roseville, CA 95678
RE: Proposed Roseville Industrial Park Draft Environmental Impact Report
Dear Ms. Maples:
The Sun City Roseville Community Association Board of Directors appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) that the City of Roseville has circulated for its proposed Roseville Industrial Park Project. Sun City Roseville is a senior community of 3110 homes in West Roseville. As discussed below, Sun City residents will be directly affected by the substantial impacts that this project will have if it is developed as proposed.
The City’s process is flawed. The City proposes a project contrary to its approved General Plan. The type of use proposed for this project is listed in the City’s General Plan as “incompatible” with residential uses; yet the project is proposed to be located in a completely residential neighborhood. The proposed project would undermine the security and integrity of the residential neighborhoods that the City has previously approved in West Roseville by inserting an industrial development into their midst. The proposal should be denied.
Sensible and coherent land use planning requires that planning come before development. If the City wanted to develop an industrial facility it should haye required it to be placed in an area already planned and zoned for that use. If instead the City wanted to change the allowable uses of its Reason’s Farm property, it should have begun a planning process for a General Plan amendment. The City’s failure was to begin with the specific development that it wanted, hoping later to conform its General Plan to the project. But this is not proper planning; it is backwards. Appropriate planning would have revealed the problems with placing an industrial project in the proposed West Roseville location.
Indicative of the City’s planning failure is that the proposed project is in conflict with the Attorney General’s Guidelines for Best Practices and Mitigation Measures for Warehouse Projects. These Guidelines were developed because of the significant adverse impacts these types of projects have upon the communities in which they are placed. The Guidelines advise “proactive planning” that “allows jurisdictions to prevent land use conflicts before they materialize and direct sustainable development” into appropriate areas. For example, the Guidelines state that “establishing industrial districts near major highway and rail corridors but away from sensitive receptors can help attract investment while avoiding conflicts between warehouse facilities and residential communities”.
Here, the City proposes the exact opposite: locating huge warehouse facilities on an environmentally sensitive parcel in a residential neighborhood that is many miles away from necessary major highway and rail corridors. It is hard to imagine a worse location for this proposed development, or one that is less compatible with the City’s General Plan. Most of the impacts discussed in the DEIR, including traffic and circulation, air pollution, greenhouse gas emissions and noise are directly caused or significantly exacerbated by this initial failure to properly locate the project in the community. These include the impacts to “sensitive receptor” communities such as Sun City Roseville that are along the routes that must be traveled by the heavy trucks going to and from the proposed project location to the major highway corridors of State Route 65 and Interstate 80.
The failure of the City’s planning process is also made clear by the extremely limited alternatives identified in the DEIR. These alternatives do not support a General Plan Amendment, which should precede the project. Beginning with the location for which the amendment is being considered, the proposed amendment and its EIR should consider alternative possible uses for that location, how those possible land uses serve the needs of the community, and how those alternative uses are or could be made consistent with the other elements of the General Plan. The current DEIR, limited by its project description, avoids this problem by ignoring it. An EIR addressing the General Plan amendment cannot simply skip over the broad scope of land use alternatives required for such an amendment, including uses that might better serve the needs of the growing, entirely residential community of West Roseville. It should certainly address the obvious alternative for the City, on this land which it, not the developer owns, to implement some version of the Reason’s Farm Environmental Preserve, for which it has developed a Conceptual Master Plan, when open space and recreational uses are needed in West Roseville.
Even as a project-specific DEIR, it is fatally flawed. It is totally inconsistent with the General Plan for the location where it is proposed. Further, it completely fails to consider alternative locations that might be more suitable. The applicant, Panattoni Development, is an international leader in the field of industrial warehouse development.
A developer of such expertise and reach is unusually well-qualified to locate potential sites for new industrial development projects, including sites consistent with the Attorney General’s Guidelines. It is inconceivable that such a qualified applicant could not identify a wider range of more suitable sites in Roseville or in the greater Sacramento area for a project of the magnitude described in the DEIR (almost 2.5 million sq. ft. of warehouse footprint). The DEIR fails even to consider any other suitable site for this proposed development.
The significant impacts to the Sun City Roseville community all are caused by this attempt to force a project into an area where it does not belong. Because the proposed industrial project is not properly located, the DEIR estimates that it will generate 1140 heavy truck trips per day, most of these on Blue Oaks Blvd. past Sun City, to get those trucks to and from the major transportation corridors of State Route 65 and Interstate 80. In fact, because of the restrictions of federal and California law, all of the longest, heaviest trucks that produce the most noise, traffic hazard risk, and air pollution and greenhouse gas emissions, will be required to travel on Blue Oaks Blvd. past Sun City, first to reach their destination and then to return to the SR65/l-80 major transportation corridors. Yet the DEIR does not appear even to have identified or analyzed any project impacts east of Fiddyment Road. This failure must be corrected.
Sun City residents will be significantly impacted by the proposed project. Although the DEIR states that automobile delay from traffic congestion is no longer considered a CEQA impact, the hazards created by this increase in vehicle miles traveled are highly impactful to Sun City residents. For example: the left turn lane from westbound Blue Oaks Blvd. onto Del Webb Blvd., a main entrance to Sun City, already sometimes backs up into the left through-traffic lane of Blue Oaks Blvd. This causes vehicles to stop in the left through-traffic lane, and/or to change lanes to divert around stopped vehicles. The significant increase in projected trips, especially the heavy truck trips, will increase the risk of serious accidents at that and similar problematic intersections along Blue Oaks.
In addition, the increase in vehicular traffic, particularly heavy truck traffic, will affect Sun City residents by increasing the impacts from air pollution and noise. Again, the DEIR neither identifies, nor analyzes or proposes to mitigate these impacts. With respect to noise, consider just the heavy truck traffic. 1140 heavy trucks passing Sun City on Blue Oaks Blvd. amounts to almost one heavy truck per minute, 24 hours a day, seven days a week. This assumes that the estimates are not low, nor the traffic more concentrated. Because the trucks will tend to use air compression brakes, which are loud, to reduce speed, and then accelerate back up to speed at the signalized intersection at Del Webb Blvd., the sound impacts will be intensified in that area. Although sound walls are discussed with respect to some of the communities west of Fiddyment Road., no impacts are discussed nor is any mitigation proposed for ‘residents along Blue Oaks Blvd. east of Fiddyment Road, including Sun City residents, despite the fact that all the heavy trucks must continue on Blue Oaks to reach SR 65 and Interstate 80. These noise impacts will significantly affect Sun City residents.
Sun City, as a community of senior citizens, is a “sensitive receptor” site for air pollution impacts. Because Sun City residents are recognized as being particularly susceptible to localized air quality impacts, these impacts are of particular concern to them. Heavy truck traffic produces toxic air contaminants from diesel engine emissions, including ozone, nitrogen dioxide and respirable particulate matter, all of which are· known to cause acute health effects. Many Sun City residents have medical conditions such as chronic obstructive pulmonary disease that make them especially vulnerable to these toxic pollutants. The DEIR is fatally flawed because it does not even identify, much less analyze or propose to mitigate these harmful impacts to Sun City residents. Finally, although Sun City residents are not differentially affected by greenhouse gas emissions, we strongly believe that they should be reduced and avoided wherever possible, and note that siting the project near the major highway corridors of SR 65
and Interstate 80, a feasible alternative, would reduce them significantly.
The project discussed in the Draft EIR is not suitable for the location in which it is proposed. Nor are there any meaningful “overriding considerations” that are more important than the health, welfare and neighborhood integrity of the West Roseville residential communities that will be degraded by this misconceived proposed project. Most of the harmful impacts of the proposed project can be avoided by following the advice of the Attorney General’s Office on locating warehouse/distribution projects: namely, establish industrial districts near major highway and rail corridors, and away from sensitive receptors and residential communities.
For all of these reasons the Draft EIR should not be certified. Instead, the proposed project should be abandoned or denied at this time. If the City intends to propose uses on the Phillip Road site that are different than what is in the approved General Plan, it should initiate an open planning process for that area, engaging the residents of the surrounding neighborhoods in a community dialogue regarding the best uses of the more than 1700-acre Reason’s Farm Environmental Preserve property that the City purchased.
Sincerely,
David Lamon
Board President
Sun City Roseville Community Association
