EIR No. 534 Must Account for the Total Cumulative Effects of Past, Present, and Future Projects to be Valid CEQA Document.
Libi Uremovic
P.O. Box 2894
Rancho Cordova, CA 95741
(702) 503-2022
January 17, 2017
Brett Dawson, Project Planner
Riverside County Planning Department
4080 Lemon St., 12th Floor
Riverside, CA 92501
Re: Environmental Impact Report No. 534 (EIR) for San Gorgonio Crossings which includes a Change of Zone (CZ) No. 7799, General Plan Amendment (GPA) No. 1079, Plot Plan (PP) No. 25337, and Parcel Map (PM) No. 36564. EA42179, SCH#20140110009
Mr. Dawson,
Please submit the following comments and documentation in Opposition to the San Gorgonio Crossing Change of Zone and General Plan Amendment.
I am the Accountant that performed the Forensic Audit on the City of Beaumont, which has produced Investigations by numerous State and Federal Agencies. Read the SEC Subpoenas, State Controllers’ Investigative Report, and D.A. Indictments on beaumontgate.org.
Although the Riverside District Attorney’s Office is currently Prosecuting the ‘Expendable Seven’ I am requesting that the State Attorney General’s Office take Lead Prosecution because of Riverside County’s involvement in Beaumont’s corruption as well as their own illegal activity in the Construction and Bond Industry. (Attachment A)
State and Federal Laws are established to protect the Citizens. A Forged Document is one that contains intentional Errors, False Statements, or the intentional Omission of Facts.
Submitting Fraudulent CEQA EIR Documents is a Felony under California State Law. Submitting Fraudulent CEQA EIR Documents for the purpose of illegally Acquiring Municipal Bond Funds is a Federal Felony.
The CEQA EIR No. 534 prepared by FirstCarbon Solutions is a Fraudulent Documents as it contains too many errors, false and/or omitted facts to be classified as ‘legal’.
SECTION 4: CUMULATIVE EFFECT OF PAST, CURRENT, AND FUTURE PROJECTS
EIR No. 534 Section 4: Cumulative Impact Analysis
CEQA Guidelines require: “. . .the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.”
EIR No. 534 lists a shocking 43 Future Developments with 22,340 Dwelling Units and 54.67 Million Sq. Ft. of Warehouses planned Future Development, but neglected to include the cumulative effect of Past Projects.
The City of Beaumont has built over 20,000 houses and grown from 8,000 to 45,000 people without submitting legal CEQA EIRs. (Attachment #B:)
An Audit comparing CEQA EIRs Filed with Developments Built reveals that there are 11 Developments with a total of 3,489 Houses that have no CEQA EIRs filed with the State Clearinghouse.
A Negative Declaration was filed for the Oak Valley Development with over 3,200 Houses.
Notices of Preparation or Determination were filed on four (4) other Developments with a total of over 4,600 Houses.
$400 Million in Bond Funds, Mitigation Fees, and Taxes were collected in the City of Beaumont to build a Recycled Water Facility, Fire Stations, and Roadways. Beaumont Staff and Council Misused and/or Embezzled all the Money and never built the Facilities.
Riverside County is fully aware that the City of Beaumont steals taxes. Beaumont now owes the Western Riverside Council of Government over $66 Million because the Beaumont City ‘Approved’ the Embezzlement of TUMF from the County.
- EIR No. 534 Must Account for the Total Cumulative Effects of Past, Present, and Future Projects to be Valid CEQA Document.
4.3.1. AESTHETICS:
EIR No. 534 claims: “Aesthetics, potential impacts would be less than significant.”
Incorrect. The fact that a Zone Change and General Plan are needed dictates that the change in Aesthetics can not be Mitigated.
Unincorporated Cherry Valley is a rural-residential community. The property is zoned for Rural/Residential Parcels of one (1) Acre or larger. This type of Zoning is so aesthetically more pleasing that it sustains and Increases the Community’s Property Values.
Warehouses are ugly, which is why no one builds expensive houses in warehouse districts.
- EIR No. 534 Must Change 4.3.1 Aesthetics to state “Significant Impact, Can Not Be Mitigated” to be Valid CEQA Document.
4.3.10 – Land Use and Planning:
EIR No. 534 claims: “…an ongoing trend toward urbanization along this part of Cherry Valley Boulevard…”
There is no ‘trend toward urbanization along Cherry Valley Boulevard”. The ‘trend’ is nothing more than an attempt to continue Beaumont’s Construction and Bond Scam with no regard to the Citizens and Community of Unincorporated Cherry Valley.
EIR No. 534 also claims: “..a land use change is appropriate and consistent with this setting…”
No, the land use change is not appropriate or consistent with the setting. The setting is rural-residential, which is desirably opposite from industrial. The Residents of Rural Cherry Valley chose the location to call home specifically because of the current zoning of rural-residential.
EIR No. 534 further claims: “.. the proposed project, in conjunction with other planned and approved projects, would not have a cumulatively significant impact related to land use.”
Incorrect. The change in land use from rural-residential to industrial will have a significant cumulative impact on the Community of Cherry Valley.
The Cherry Valley Boulevard Exit off Interstate 10 is the Residents of Unincorporated Cherry Valley’s ‘driveway’ to their homes. The Community was never intended for warehouse development. Citizens of Unincorporated Cherry Valley all purchased their property with the common purpose of using the land for rural residential.
- EIR No. 534 Must Change 4.3.10 – Land Use and Planning to state “Significant Impact, Can Not Be Mitigated” to be Valid CEQA Document.
4.3.14 PUBLIC SERVICES:
FIRE STATIONS:
The National Association of Fire Protection sets response time standards at four (4) minutes.
EIR No. 534 highlights the already hazardous Call Response Times by listing Calimesa Fire Station #21 with a total response time of 7 minutes 5 seconds, Cherry Valley Station #22 with a total response time of 7 minutes 43 seconds, and Beaumont Fire Station #66 with a total response time of 8 minutes 22 seconds.
The Riverside County Fire Protection Master Plan recommends one new fire station and/or engine company for every 2,000 new dwelling units and/or 3.5 million square feet of commercial/industrial occupancy.
Calfires has tried to get the City of Beaumont to build three (3) more fire stations to protect their Citizens, but Beaumont Staff and Council refuse. (Attachment #C)
Although this Project in itself does not necessitate an additional Fire Station; the Pass Area needs at least five (5) more Fire Stations to adequately protect the current Citizens BEFORE an additional drain on Fire Services can be responsibly Approved.
- EIR No. 534 Must Recommend a Minimum of Three (3) Operating Fire Stations to be Valid CEQA Document.
4.3.16 – TRANSPORTATION AND TRAFFIC:
EIR No. 534 states: “..these cumulative impacts are significant and unavoidable.”
They’re right about that.
Not only did Beaumont Staff and Council misuse/embezzle $42 Million in TUMF roadway fees; they also stole approximately $150 Million in Mitigation Fees collected by the City for local roadways. Beaumont also stole $13 Million under the guise of ‘Potrero Interchange’. These Funds were derived from Federal Municipal Bond Funds and are part of the SEC Investigation.
Roads and Expansions needed to accommodate Beaumont’s additional 40,000 vehicles were never built. Traffic buildup along the I-10 attempting to take the Cherry Valley Boulevard Exit can be up to 50 cars long during rush hour.
The Cumulative Impact of Beaumont’s 20 years of submitting Fraudulent Government Documents and Misusing/Embezzling Taxpayer Money has resulted in over $200 Million in Fire Stations and Roadway Infrastructure must be built to make the current Citizens whole BEFORE additional development can be considered.
- EIR No. 534 Must Recommend Mitigate the Cumulative Effect Traffic Congestion to be Valid CEQA Document.
APPENDIX J: FISCAL IMPACT ANALYSIS:
EIR No. 534 Appendix J lists the estimated tax revenue upon buildout of the Warehouses, but does not account for the deterioration of Property Values that will incur throughout the Pass Area Community when the Zoning is changed from Rural-Residential to Industrial.
Construction of 229 Million-Dollar Homes on One Acre Parcels would generate twice the Property Tax Revenue and increase the Community’s Property Values.
- EIR No. 534 Must Mitigate for the Community’s Decline in Property Values and the Loss of Property Values if a Warehouse is Built Instead of Houses per the Current General Plan and Zoning Ordinance to be Valid CEQA Document.
EIR No. 534 states: “Upon build-out and stabilization, ongoing operation of the Project is estimated by IMPLAN to generate approximately 748 jobs, $31.9 million in annual labor income, and $67.9 million in annual economic output.”
Because the use of the Warehouses is still unknown; job and revenue estimates are nothing more than guesses that have no value. Furthermore; including restaurant and store jobs in the ‘Warehouse Jobs’ summary is misleading. Warehouse jobs average $12/hr in the Region and will not provide the Employees with enough disposable income to justify hiring additional Staff.
EIR No. 534 Objective 2 states: “Provide local economic opportunities and reduce commute times and air pollution..”
The virtually all of Commuters in the Pass Area live in the City of Beaumont and live in the Development Areas. They can not pay Mortgages and Mello Roos Property Taxes with a low-wage Warehouse Jobs.
- EIR No. 534 Must Remove Job and Revenue Guesses to be Valid CEQA Document.
EIR No. 534 also states: “TSG Cherry Valley, L.P. (“Client”) is currently engaged in discussions with public entity and other stakeholders regarding feasibility and entitlements for its San Gorgonio Crossing Project (“Project”).”
I believe the EIR’s discussions of ‘feasibility’ and ‘entitlements’ is a reference to bond debt.
The Forensic Audit of the City of Beaumont has unveiled an illegal Municipal Bond Fraud and Construction Scam that is occurring throughout Riverside County and involves numerous Riverside County Government Agencies and many of the same Lawyers and Consultants that are used by Riverside County, Lake Elsinore, and in the preparation of EIR No. 534. (Attachment # D)
EXECUTIVE SUMMARY OBJECTIVE 7:
EIR No. 534 states: “Provide For A Reasonable Return On Investment Needed To Develop The Project.”
A Warehouse Project in this Area will not provide a Reasonable Return an Investment.
IF THE WAREHOUSE PROJECT CONTINUES:
The Environmental Law Firms will drag the San Gorgonio Crossing Warehouse Project to Civil Court. In the year it takes to get to Court I will have Audited the CEQA EIRs, Construction Records, and Federal Municipal Bonds in Lake Elsinore, Riverside County, and all of Shopoff’s Investment Properties in the State of California following a pattern of Federal Bond and Construction Fraud.
IF THE WAREHOUSE PROJECT IS DROPPED:
In the next year I will have Audited the CEQA EIRs and Federal Municipal Bonds in Lake Elsinore, Riverside County, and all the rest of Shopoff’s Investment Properties in the State of California following a pattern of Federal Bond and Construction Fraud.
Shopoff’s website lists a total of 1,485 Acres of Land of Beaumont. I don’t know if Shopoff made a poor choice or if someone set him up, but it’s all over now.
“Welcome to my Party.” said the Spider to the Fly