HomeMy WebLinkAbout2022.02.09 - Letter from Local 542 Teamsters - Item 5.1Jaime Vasquez
Secretary -Treasurer
Phillip Farias
President
Cliff Cunningham
Vice -President
Dwayne Garrett
Recording Secretary
Curt Olson
Trustee
Lynda Linville
Trustee
Don Mack
Trustee
TEAMSTERS, CHAUFFEURS,
WAREHOUSEMEN AND HELPERS
LOCAL UNION No. 542
San Diego and Imperial Counties, California
and the City of Yuma, Arizona
Affiliated with
INTERNATIONAL BROTHERHOOD OF TEAMSTERS
February 8, 2022
Sent to: Ms. Genevieve Hernandez, Senior Planner, Development Services
ghernandez@chulavistaca.gov, (619) 691-5255
Chula Vista Planning Commission
City of Chula Vista
276 Fourth Avenue
Chula Vista, CA 91910
RE: CASE NUMBER: DR21-0007 and VAR21-0001
APPLICANT: Rockefeller Group
SITE ADDRESS: Northwestern portion of the intersection
between Heritage Road and Energy Way
within the Otay Ranch Village 3 Business
Park (see map)
PROJECT DESCRIPTION: The Applicant is requesting approval of a
201,200 square -foot development consisting of three industrial shell
buildings for warehouse/office/ecommerce use. The proposed Project is
located on an existing, previously graded, vacant 11.6 -acre site, consisting
of three separate parcels. The site is within the Otay Ranch Village 3 Business
Park, zoned Industrial (1), with a General Plan Designation of Limited
Industrial (IL). The project is known as Heritage Industrial Center.
RECOMMENDED ACTIONS: Conduct a public hearing and adopt
Resolution No. DR21-0007 approving the Design Review for the project; and
Resolution No. VAR21-0001 for a Variance to allow an increase in height for
a portion of the proposed retaining wall, based on findings and subject to
conditions contained therein.
Dear Chair Zaker and Members of the Chula Vista Planning Commission:
These comments are being submitted on behalf of Teamsters Local 542 for the
Planning Commission hearing concerning the "Heritage Industrial Center." We
reserve the right to clarify and supplement these comments as permitted by law and
do not waive any issue or matter omitted herein as a result of error or omission by
the City of Chula Vista or the Applicant, to the extent permitted by law.
SAN DIEGO OFFICE: 4666 MISSION GORGE PLACE, SAN DIEGO, CA 92120 - (619) 582-0542
P.O. BOX 600507 - SAN DIEGO, CA 92160 - FAX (619) 582-0059
EL CENTRO OFFICE: 2298 MERRILL CENTER DRIVE, EL CENTRO, CA 92243 - (760) 352-6571
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Teamsters Local 542 represents over 6,000 warehouse, logistics, delivery, trucking and other workers in San
Diego County. Our members live and work in Chula Vista, including at Republic Services at 881 Energy Way,
which directly borders the western edge of the proposed project. As both residents and workers, they may
be adversely affected by the potential traffic, air quality, noise, public health, and other impacts caused by
the project.
We urge the Planning Commission to refrain from approving this project unless and until community
members have greater ability to weigh in on the project, which should include full CEQA review that
accurately and thoroughly analyzes the environmental impacts of this project.
Basic Description:
City documents describe the project:
Notice of Public Hearing: The Applicant is requesting approval of a 201,200 square -foot
development consisting of three industrial shell buildings for warehouse/office/ecommerce
use. The proposed Project is located on an existing, previously graded, vacant 11.6 -acre site,
consisting of three separate parcels. The site is within the Otay Ranch Village 3 Business Park,
zoned Industrial (1), with a General Plan Designation of Limited Industrial (IL). The project is
known as Heritage Industrial Center.
Planning Commission Staff Report: The proposed project includes three industrial shell
buildings for office and storage/warehouse/ecommerce uses, an outdoor seating area for
employees, and landscape improvements. The three industrial shell buildings are comprised
of, Building A with 104,900 square feet and 132 parking spaces, Building B with 55,700 square
feet and 92 parking spaces and Building C with 40,600 square feet and 63 parking spaces.
This Project Is Likely to Be An Amazon Last Mile Delivery Station:
Planning Department documents indicate that there is currently no known end user(s) or tenant(s) for the
project. Despite this, it seems likely that the project will be 1 or more Amazon last mile delivery stations:
The 3 industrial buildings contained in the project fit the parameters of a typical Amazon last mile
delivery station (approximately 100,000 sq. ft. of warehouse space or less, located within a densely
populated urban area, etc.).
Amazon is now the largest single developer of warehouses and logistics facilities in the United States.
Amazon has built about 500 last mile delivery stations since 2014. It plans to open at least another
250 last mile delivery stations in the U.S. over the next 2 years and reportedly plans to have a network
of 1,500 such facilities.'
The Applicant — the Rockefeller Group — has a significant pre-existing relationship with Amazon:
In September of last year, the Rockefeller Group signed Amazon as the tenant of the Airway Industrial
Park in Otay Mesaz, the company's first development in the south San Diego industrial market.'
10Edison in Edison, NJ was leased to Amazon last year while it was still under construction. The
Rockefeller Group and KSS Architects "worked seamlessly with Amazon's businesses, construction
1htts: www.irei htwaves.com news amazon-to-blanket-the-burbs-with-lots-of-delive -stations
z httos:Ilkidder.comlwp-contentlunloads/market report/industrial-market-research-san-dietto-2021-3o.odf
3 httos:/lrebusinessonIinexomlrockefeIler-group-breaks-ground-on-135623-sf-airway-industrial-nark-in-otay-mesa-caiiforni8l
SAN DIEGO OFFICE: 4666 MISSION GORGE PLACE, SAN DIEGO, CA 92120 • (619) 582-0542
P.O. BOX 600507 • SAN DIEGO, CA 92160 • FAX (619) 582-0059
EL CENTRO OFFICE: 2298 MERRILL CENTER DRIVE, EL CENTRO, CA 92243 • (760) 352-6571
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group, robotics group, startup team, and other consultants to integrate the ongoing building shell
construction efforts with Amazon's program to tailor the final project execution to Amazon's
specifications. A tight schedule required close collaboration from programming to design, and in the
field. Standardized components were adapted and customized to satisfy expectations while
maintaining the unique shell design, the construction of which was well underway upon engagement
with Amazon. A true spec -to -suit development, the project stands as a model for the typology,
exemplifying the value of local design vision blended with the project management of a global entity
with well-defined program requirements."'
• Last year, Amazon also signed a lease for a 400,000 -square -foot distribution center under
construction at 65 Baekeland Avenue in Middlesex Borough that is part of the Rockefeller Group
Logistics Centers
• The Rockefeller Group partnered with the Meridian Group on Phase 1 of The Boro mixed-use
development in Tysons, VA. In 2017, The Boro was submitted "as a prospect for Seattle -based
Amazon.com Inc.'s second headquarters."'
• Also in 2017, the Rockefeller Group's then CEO & Co -President Daniel Rashin was a signatory of a
letter urging Amazon to build its HQ2 project in New York City.
The likelihood that this project will be an Amazon last mile delivery station is significant: last mile facilities
generate significantly more traffic and other impacts than other warehouse types. The nature of last mile
facilities — which are the starting point of hundreds of daily deliveries into surrounding communities — also
means that such impacts travel far beyond the actual facility site.
The Project Should Go Through CEQp Review:
Despite the possibility of significant environmental impacts posed by e -commerce -related last mile facilities,
the Notice of Public Hearing argues that this project should not go through CEQA review:
The Director of Development Services has reviewed the proposed project for compliance
with the California Environmental Quality Act (CEQA) and has determined that the proposed
Project was adequately covered in previously certified Final Environmental Impact Report
(FEIR 13-01) (Sch No #2013071077) prepared for the Otay Ranch University Villages Project
Comprehensive SPA Plan Amendment and certified by City Council on December 2, 2014.
Thus, no further environmental review is required.
The Final Environmental Impact Report ("FEIR") certified in 2014 should not be used to evaluate the project
under review. It is focused on a fundamentally different type of project. The Otay Ranch University Villages
Project was primarily a residential development of 6,897 dwelling units, with other uses mostly servicing
those residences. In contrast, "industrial" uses accounted for only 2% of that project's acreage.' The FOR
contains virtually no discussion of the industrial component and only in regards to environmental impacts.
There is no mention of any potential e-commerce or warehouse usage. This is not surprising, given that such
e -commerce -related facilities were virtually non-existent in 2013 when the FEIR was being drafted. By
contrast, the Heritage Industrial Center is almost entirely an industrial, e -commerce -related warehouse
project.
4 httosalkssarchltects.com/designlour-work/lOedison-warehouse
s "New Jersey industrial market hits record -low availability at 3.4%," Indian Real Estate News, July 16, 2021.
e "Why this Tysons developer wants to be able to build more, not less office space," Washington Business Journal (District of Columbia) October 27,
2017.
' The project is 1,374.7 total acres, but only 28.6 acres is designated for industrial use.
SAN DIEGO OFFICE: 4666 MISSION GORGE PLACE, SAN DIEGO, CA 92120 • (619) 582-0542
P.O. BOX 600507 • SAN DIEGO, CA 92160 • FAX (619) 582-0059
EL CENTRO OFFICE: 2298 MERRILL CENTER DRIVE, EL CENTRO, CA 92243 • (760) 352-6571
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The FEIR is well over 7 years old and will not reflect current conditions. The FEIR's Notice of Preparation was
completed on July 7th, 2013, meaning the document was being written in early 2013 and possibly even during
2012 (or before). Amazon, the major pioneer in last mile e-commerce, did not begin a serious effort to create
its last mile infrastructure until the 2013 holiday season when Amazon was unable to meet delivery time
promises and many orders failed to make it to customers in time for Christmas."' This motivated Amazon to
invest heavily in building out its own last -mile delivery services. From 2014 to the first half of 2021, the
number of last mile delivery stations grew from just 8 to almost 450. In 2015, Amazon launched Amazon
Prime Now and created 58 delivery hubs across the US for 1-2 hours delivery and Amazon officially launches
its last mile delivery services with 'Amazon Logistics' in 2018."1 All of this likely happened after the FEIR was
written, so it cannot possibly account for environmental impacts related to e-commerce facilities. And even
if this project does not become an Amazon last mile facility, it will be an e-commerce facility for another
company.
Unique lm acts of Last Mile Delivea Stations:
A last mile facility has impacts that go far beyond its immediate vicinity. In the possible event that this project
will be a last mile delivery station, traffic, noise and pollution impacts will be particularly acute because they
will be spread by delivery vehicles that will travel through residential neighborhoods, bringing congestion,
noise and pollutants closer to children, seniors and other "sensitive receptors." Delivery to consumers in
neighborhoods means that trucks will be driving slowly and idling near homes, making frequent stops and
starts, and otherwise emitting greenhouse gases and other particulates not only at the warehouse, but
consistently throughout the day in residential areas that are otherwise not zoned to account for such
emissions. Currently, however, there is no accounting for the wider impacts inherent in last mile facilities.
This issue is especially salient for this project, because it is close to so many residential and other locations
where families will congregate. It is surrounded by hundreds of single-family residences south of Heritage
Road, as well as current or future residential buildings:
• 1152 Camino de Vida (apartment building)
0 The Residences at Escaya
• Brookfield Residential
• The Village of Escaya
Lennar at the Village of Escaya
Family-oriented businesses include:
• Creative Little Minds WeeCare (daycare)
a Escaya Village Center (shopping mall)
There are also numerous recreational parks:
• Borden Park
• Avenida Palomino Park
■ Escaya Linear Park
■ Strata & Flora Park
• Borden Park
• Santa Maya Park
B https•/1www bringg camlbloalloreistir sla-timel ine-of-amazons-shipping-evoIUtion
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9 htt s: un leworks.com how -amazon -levers es•last-mile-deIIve -For-its-logistic
SAN DIEGO OFFICE: 4666 MISSION GORGE PLACE, SAN DIEGO, CA 92120 • (619) 582-0542
P.O. BOX 600507 • SAN DIEGO, CA 92160 • FAX (619) 582-0059
EL CENTRO OFFICE: 2298 MERRILL CENTER DRIVE, EL CENTRO, CA 92243 • (760) 352-6571
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• Camino Aldea Park
■ The Residences Park
• Escaya Dog Park
Urban planner Daniel Flaming, president of the Economic Roundtable, a Los Angeles -based research non-
profit that provides transparent, data -driven policy analysis, notes that last mile facilities have several
negative impacts when situated near residential areas: "It would be horrific if you owned a home next to one
of these distribution centers. All those loaded trucks have significant road wear issues as well as congestion
issues, noise issues and pollution issues."10
This Project Merits a New Traffic Study:
The 2014 FEIR's traffic analysis is insufficient to assess an e-commerce facility, and especially Amazon last
mile facilities which are known to generate traffic problems. This was illustrated in 2019-2020 at an Amazon
last mile delivery station in Thousand Oaks:
In late March, officials in Thousand Oaks scrutinized Amazon's fleet of delivery vans on local
roadways after local residents complained about traffic congestion. Acrimony revolved
around a bottleneck of vehicles trying to enter Rexford Industrial -owned Conejo Spectrum
Business Park in Newbury Park -- where Amazon established a presence in 2018 when it
transformed a 55,000 -square -foot warehouse at 2405 Conejo Spectrum St. into an Amazon
Prime distribution center. According to Thousand Oaks Code Compliance Manager Geoff
Ware, who led an investigation of Amazon's driving practices since the first complaint was
filed in October, the backup has worsened in the past few months "with the numeric value
and types of traffic patterns involved with the Amazon location.... It was just an overload of
vehicles trying to access the site.""
In fact, last mile facilities generate significantly more traffic than typical warehouses (long-term storage
facilities), which are classified as Code 150 in the Institute for Transportation Engineers Trip Generation
Manual (ITE). The trip -per-unit figures for Code 150 is 0.19. The figures for distribution -focused warehouses
(such as last mile delivery stations), i.e., Codes 155 and 156 are 1.37 and 0.64 respectively. They represent
significantly higher trip generation characteristics respectively of 7+ times larger than Code 150 and 3+ times
larger than Code 150.
In fact, last mile delivery stations and distribution centers are more often evaluated as "high -cube"
warehouses with significantly higher trip generation characteristics. Importantly, even ITE Land Use Codes
155 and 156 are not typically treated as adequate, because of the unique nature of these e-commerce
facilities. In other California localities, e-commerce applicants have conducted bespoke studies based on
existing facilities in order to provide CEQA-compliant data for purposes of transportation analysis.
The City of Chula Vista needs to complete a new traffic study, rather than rely on an FEIR written 9 years ago
that clearly does not account for e-commerce facilities that arose after it was written.
11 Southland logistics; Amazon shifting to the fast lane. Redlands 6 U.S. Census Bureau. Time Series of California Intercensal Population Estimates by
County: April 1, 1990 to April 1, 2000.
11 "SPACE FOR E-COMMERCE: With the coronavirus crisis encouraging online shopping, companies from Amazon.com to local businesses are in the
market for warehouses (REAL ESTATE QUARTERLY: SPECIAL REPORT)," San Fernando Valley Business Journal, April 27, 2020.
SAN DIEGO OFFICE: 4666 MISSION GORGE PLACE, SAN DIEGO, CA 92120 • (619) 582-0542
P.O. BOX 600507 • SAN DIEGO, CA 92160 • FAX (619) 582-0059
EL CENTRO OFFICE: 2298 MERRILL CENTER DRIVE, EL CENTRO, CA 92243 • (760) 352-6571
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Parkin: Impacts:
Parking problems at Amazon facilities have been well documented:
• Insufficient parking spaces and the high volume of last mile delivery vans force workers servicing
them to look
for parking offsite, taking parking spaces that would otherwise be used by local residents."
Teamsters Union members and staff have observed these problems at numerous Amazon facilities.
The need to park offsite has led to conflicts with workers servicing Amazon warehouses:
o Several lawsuits filed against Amazon's subcontracted van companies that list Amazon as a
joint employer have previously alleged violations of wage & hour laws because they were
required to park and pick up their delivery vehicles offsite but Amazon did not compensate
them for the time spent traveling from their offsite parking locations to their workplaces.
o The issue was a central grievance that led to a 2019 walkout of workers in an Amazon
warehouse in Minnesota.-'
Despite these problems, the proposed project will only include 287 parking spaces — or 1 space per every 701
sq. ft. This stands in contrast to other Amazon last mile projects currently under development:
PROJECT LOCATION
Peabody, MA
SPACE PER SQ FT
1 space per 155 sq ft
PARKING SPACES
1,181
SQUAREFOOTAGE
183,000
Westbury, NY
1 space per 169 sq ft
237
40,113
Smithtown, NY
1 space per 207 sq ft
309
64,000
Garden City, NY
1 space per 583 sq ft
175
102,091
Chula Vista, CA
1 space per 701 sq ft
287
201,200
This Project May Not Create Goon Jobs:
A prime reason for supporting projects such as this one is the prospect of jobs for local residents. The Planning
Commission Staff Report notes that "industrial uses within Village 3 are intended to provide for a high-quality
working environment and to achieve a harmonious mixture of land uses.
Activities are intended to promote employment opportunities in manufacturing, service, research and
development, engineering, and wholesale trade." Chula Vista City officials, however, may be disappointed in
the type of jobs created, if this is an Amazon facility:
Negative Impact on Wages:
According to Bureau of Labor Statistics data for 68 counties where a large Amazon facility was
opened, the average compensation for the industry declined more than 6% in the two years after
opening. 1.4
A U.S. Government Accountability Office report from October 202015 cited in several articles found
that in the 9 states covered, more than 4,000 Amazon employees receive SNAP food assistance.
Pre -pandemic research found that warehouse workers in areas with an Amazon facility earned about
10% less than similar workers elsewhere."
11 "Online Spending to Hit a New Record," CBS News Transcript, December 2, 2019.
13 "News Watch," Labor Notes, September 1, 2019.
14 Bloomberg. Amazon Has Turned a Middle -Class Warehouse Job Into a McCareer. December 2020.
1s U.S. Government Accountability Office Report to the Ranking Member, Committee on the Budget, U.S. Senate. FEDERAL SOCIAL SAFETY NET
PROGRAMS: Millions of Full -Time Workers Rely on Federal Health Care and Food Assistance Program. httos://www.p,?o.goylassets/gao-21-45.od .
October 2020.
11 The Economist. What Amazon does to wages. January 2018.
SAN DIEGO OFFICE: 4666 MISSION GORGE PLACE, SAN DIEGO, CA 92120 • (619) 582-0542
P.O. BOX 600507 • SAN DIEGO, CA 92160 • FAX (619) 582-0059
EL CENTRO OFFICE: 2298 MERRILL CENTER DRIVE, EL CENTRO, CA 92243 • (760) 352-6571
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Iniury Rates Associated with Amazon Facilities:
• OSHA data for 2020 shows that the serious injury rate at Amazon warehouses — meaning workers
were hurt badly enough to miss work or be placed on light duty — was almost 80% higher than the
entire warehousing industry at 5.9 serious injuries for every 100 Amazon workers." "
• Despite touting millions spent on safety, internal data show that Amazon leaders went to great
lengths to hide an ongoing, and worsening, safety crisis at company warehouses across the U.S."
Amazon Employment Churn:
Data shows that when Amazon moves into a county, turnover rates for the entire county skyrocket — in just
2 years, a new Amazon facility increases the turnover rate for warehousing and storage employees an
average of 30%.20 In California, researchers found that the average turnover rate in "Amazon" counties for
warehouse workers more than doubled in the years between 2011 and 2017, from 38.1% to 100.9%.21
Conclusion:
For the foregoing reasons, we respectfully request that the Chula Vista Planning Commission refrain from
approving the project unless and until the community is allowed greater input into the project, and it goes
through the CEQA process.
Sincerely,
Sal Abrica
Political Coordinator
Teamsters Local 542
"The Washington Post. Amazon warehouse workers suffer serious injuries at higher rates than other firms. June 2021.
ie Strategic Organizing Center. Primed for Pain: Amazon's Epidemic of Workplace Iniurles. May 2021.
19 Reveal. How Amazon Hid its Safety Crisis. September 2020.
20 The New York Times. inside Amazon's Employment Machine. June 2021.
zi National Employment Law Project. Amazon's Disposable Workers: High Injury and Turnover Rates at Fulflilment Centers in California. March 2020.
SAN DIEGO OFFICE: 4666 MISSION GORGE PLACE, SAN DIEGO, CA 92120 • (619) 582-0542
P.O. BOX 600507 • SAN DIEGO, CA 92160 • FAX (619) 582-0059
EL CENTRO OFFICE: 2298 MERRILL CENTER DRIVE, EL CENTRO, CA 92243 • (760) 352-6571
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