THE COUNCIL OF INDUSTRIES
P.O. BOX 70088
Pt. Richmond, CA 94807
(510)215-9325 office (510)215-9029 fax
www.councilofindustries.org
October 29, 2014
BY EMAIL:
Richard Mitchell, Planning Director
Hector Rojas, Senior Planner
Planning Department
City of Richmond
450 Civic Center Plaza
Richmond, CA 94804
Re:
Notice of Preparation of Environmental Impact Report for Richmond South
Shoreline Specific Plan
This letter is being submitted on behalf of the Council of Industries’ (COI) businesses in
response to the City’s request for public input on scoping issues regarding the
Environmental Impact Report (EIR) for the Richmond South Shoreline Specific Plan (the
“Plan”).
The foremost concern is that the COI and other impacted businesses have not seen the
draft Plan. This was promised to be delivered to the participants by August, 2014.
What was delivered were maps and definitions given to some of the businesses at an
October 14, 2014 meeting – but, which were not included in the presentation given to
the public on October 16, 2014. It is concerning that the City is asking for public input to
identify the environmental impacts of the plan on land-use decisions that could impact
current businesses future and future businesses interest in locating to the City when no
plan has been presented for review.
In regards to the minimum information that has been presented:
1) The Plan’s land use map indicates that the 23rd Street and the Safeway rail yards,
and, the Siberia Lead which serves them, have been removed and converted into parks
– these need to be placed back onto the maps as the rail companies have not
relinquished these properties to the City for rezoning, nor are they considering
relocating these yards.
(a)The maps indicate the rail yards have been replaced with a park, surrounded
by residential. The replacing a working rail yard with a park is a lesser
economically valued use of the land. This impact needs to be reviewed. It also
portrays an inaccurate picture of potential property development based on
unknown future market demands.
(b) With the City of Richmond private and public Port being noted in the General
Plan for increased goods movement, removing two of the three switching yards
for three railroads- BNSF, Union Pacific and Richmond Pacific Railroad is
contrary to the General Plan. This is also being considered before a Goods
Movement Plan has been prepared.
(c) Consideration of locating residential adjacent to rail yards requires a thorough
review of the impact that noise, vibrations, lights, etc. would have on local
residents.
(d) A covenant – noting the presence of the railroad traffic and its impacts should
be required with all commercial and residential development adjacent to the rail
yards.
(e) Economic impacts on the City need to be studied regarding replacing current
and increased goods movement with residential.
2) The Connectivity Plan should only be adopted after a Goods Movement Plan has
been completed. Increased Port business, rail and truck service to the Port businesses
and on the local roads must be included in the Connectivity Plan and could potentially
result in street relocations and/or restrictions.
3) The General Plan supports the protection and growth of the Arts and local artisans,
yet in Sub Area 1 and Sub Area 3 & 4 we find local renowned artists who will be
impacted by locating residential near their light industrial businesses. This could result
in their relocating to other areas of Richmond or leaving the City.
4) Those businesses – including the Artisans – who are rezoned from light industrial (M1 and M-2) to residential and mixed use will result in several issues:
(a) Inability to expand their business on their own property as it would be a
nonconforming use.
(b) Inability to expand their business by purchasing property for the same reason
as stated in (4)(a).
(c) Increases in insurance due to changes in zoning.
(d) Increases in cost of loans or inability to obtain loans due to the rezoning of
property.
(e) The zoning map shows parcels – including that of Allied Propane – that are
dissected into two different and conflicting land use zones – how does this impact
the owners in regards to the same issues noted in (4)(a-d)?
(f) The General Plan calls for the entire Plan area to be zoned light industrial but
the Plan has no light industrial. This conflicts with the General Plan.
(g) Residential and mixed use is being placed directly adjacent to light industrial
uses without consideration of any buffer zones. This includes zoning adjacent to
artisans whose businesses include a foundry, warehouses, and manufacturers of
solar equipment. What would the impact be on residential uses in regards to
proximity to truck and forklift traffic, noise, odors, etc.?
(h) Should these business relocate to another city – what is the economic impact
on the City of Richmond regarding – property taxes, sales taxes, use taxes, etc.
And – how will these changes impact the cost of utilities and City services to this
area?
(i) The UCB and LBNL plan provides for a working R&D center which would not
be compatible adjacent to residential or mixed use – as LBNL has stated in
several meetings.
(j) The same plan provides for much needed light industrial areas to support
incubator manufacturing and supporting start-ups as seen in the San Francisco
Mission Bay plan, however, the Plan is replacing light industrial with residential /
mixed use.
(k) The Plan needs to include the impact of manufacturing leaving this area and
relocating to other parts of the City or to other cities.
5) In previous presentations, the City described a phase-in plan whereby development /
zoning is changed based on the market demands. We would like to see this included
with review benchmarks to determine if the City is in alignment with the market and the
UCB/LBNL development phases. What is the impact on the environment without such a
plan? Planning for increased residential that the market doesn’t support leaves vacant
property which was once a viable light industrial or artisan business area that provided a
tax base for the area.
6) The overlay zone was discussed by City Staff and was promised for review by the
impacted businesses but to-date has never been presented. Staff has stated that their
intent is to maintain the current zoning of M-1 for current businesses - which would also
allow for the City’s revenue to be protected. To-date, there is no clear language in the
Plan supporting the continuation of allowed manufacturing and industrial use through
overlay zoning, or a definition of what overlay zoning includes. In addition, staff has
presented draft “acceptable uses” in specific zones, but these were not included in the
draft Plan for public review, or, the NOP for the EIR at the public meeting that was held.
Overall, the Plan does not provide any analysis of protection of manufacturing, goods
movement, port development and the artisan community, as well as the potential impact
that limiting, eliminating or relocating these businesses will have on other areas of the
City, or I they left the city entirely.
The COI businesses and the businesses located in the area would like to stress their
continued commitment to work with the City on ensuring that the SSSP is developed
with consideration and input from all those that reside in the area – business,
community, artisans, UCB, LBNL, etc.
With regards,
Katrinka Ruk
Executive Director
Cc:
COI Board of Directors
RSSSP Business Community
Ruth Vasquez, Richmond Chamber of Commerce
Michael Davenport, President, Richmond Chamber of Commerce