HomeMy WebLinkAbout4 - Care CA
03/27/2023
VIA EMAIL ONLY
Rina Leung, Senior Planner
City of Fontana
8353 Sierra Avenue
Fontana, CA 92335
Email: rleung@fontana.org
RE: NOP Comments for Hemlock Warehouse Development Project
Dear Ms. Leung,
Thank you for providing Californians Allied for a Responsible Economy ("CARE CA") with the
opportunity to comment on the Notice of Preparation (“NOP”) for the Hemlock Warehouse
Development Project (the “Project”) Draft Environmental Impact Report (DEIR). The Project
will be a new 2-story warehouse building totaling approximately 882,000 square feet space. The
Project requires approval for a Tentative Parcel Map and Design Review.
The Initial Study identifies the Project’s potentially significant impacts under CEQA to include
air quality, greenhouse gas emissions, noise, transportation, tribal cultural resources, and
mandatory findings of significance. CARE CA respectfully requests complete analysis of these
impacts, imposition of all feasible mitigation and study of a reasonable range of alternatives.
In addition, we request that the City take into consideration the following comments:
a) According to the Initial Study, approximately 25 percent of the building square footage will
be cold storage. This means that trucks and trailers going in and out of the Project site would be
equipped with transport refrigeration units (TRU). The TRUs would emit large quantities of
diesel exhaust while operating within the Project site. The City should, therefore, model air
pollutant emissions from on-site TRUs in the DEIR and also include potential cancer risks to
sensitive receptors from on-site TRUs in a Health Risk Assessment.
In addition, the DEIR should also specify the type of refrigerant that will be used in the cooling
system. Different types of refrigerants have different impacts on GHG. As more cold storage
warehouses are built, the use of high global warming potential (GWP) refrigerants with potent
greenhouse gas emissions will further exacerbate global climate change. Next generation
refrigeration systems can reduce the contribution to climate change of high GWP refrigerants by
using natural refrigerant alternatives that have minimal climate impacts. The City should
embrace this shift by requiring use of natural refrigerant alternatives that would reduce the
Project’s impact on greenhouse gas emissions (GHG).
b) We are concerned about air quality impacts and public health. Assuming the industry
standard 24 hour a day, 7 days a week operation, hundreds and hundreds of heavy-duty diesel
trucks (some equipped with TRUs) will come in and out of the Project site on any given day.
The high daily volumes of truck traffic and on-site equipment (e.g. forklifts, backup generators
and yard tractors) will pollute the air with toxic diesel emissions and expose nearby
communities to toxic and cancerous air pollution. The DEIR must include a mobile source
Health Risk Assessment that includes both construction and operational diesel PM emissions
and cancer risk assessment. In addition, estimates of the significance of air quality impacts must
be consistent with current epidemiological studies regarding the effects of pollution and various
kinds of environmental stress on public health. Every effort must be made to ensure that public
health impacts are studied, quantified, and fully mitigated.
c) Mitigation measures must be effective and enforceable. Every effort must be made to
incorporate modern technology in the mitigation measures and MMRP. For example, a
requirement that all off-road equipment and trucks using the site during construction and
operations be zero emission, near-zero emissions or alternative-fueled vehicle would both
reduce and/or eliminate air pollution impacts and CO2 emissions.
d) Provide all sources and referenced materials when the DEIR is made available.
Thank you for the opportunity to submit NOP comments. CARE CA respectfully urges the City
to take this opportunity to protect the environment and the community to the maximum extent
feasible. We look forward to reviewing and commenting on subsequent environmental review
documents when these documents are released for public review.
Sincerely,
Jeff Modrzejewski
Executive Director