Although the Producers Project DEIR says (regarding the silos) that “the building needs to be reevaluated for historic significance,” the City of Fresno refused to allow them to be reevaluated through a public process.

The DEIR found that the structures are eligible for historic designation under criterion i and iii:

Additionally, the J.B. Hill Company is potentially eligible for listing in the CRHR [California Register of Historic Resources]. The property is greater than 50 years of age and possesses integrity of location, design, materials, workmanship, feeling, and association (FMC 12-1607). The property is also significant under CRHR Criterion i/1 because it is associated with early 20th century industrial development along the railroad in Fresno. Further, the property is significant under CRHR Criterion iii/3 because it has distinction as an Industrial – Food Processing property type. (DEIR 3.3-21)

Despite the fact that Producers’ own DEIR supported reevaluation of the silos, the City claims the silos are not historic due to a decision that was made in 1980 (44 years ago) at a time when the silos were not 50 years old yet.

The City either cannot or will not produce additional information regarding that 1980 Council decision and therefore cannot substantiate why the decision was made. According to the DEIR, however, the decision was made because:

• 1) the property did not have an age of 50 years or greater at the time of consideration; and

• 2) it was argued that the historic designation would be an economic hardship for the property owner. (DEIR 3.3-21)

Neither of these conditions apply now because 1) the property is now 76 years old and 2) the property owner and nature of the site’s use has changed.

New qualifications for historic designation warrant new consideration.

The silos are a unique part of Fresno’s history that stand as testament to the city’s foundation in agriculture. The 1991 Tower District Specific Plan also recognized their enduring legacy, noting them as a visual landmark and resource of primary importance (TDSP 3-23).

A decision from 44 years ago cannot take into account the maturing of the landmark that has occurred to present day - this incurs new conditions and information that must be recognized and considered. The silos are now more than 50 years old and are supported in the Tower District Specific Plan and Producers Project EIR as being eligible for historic designation and should therefore have been reevaluated by the Historic Preservation Commission and City Council prior to any decision regarding demolition.

The demolition of the buildings are part of the project description for Producer’s Dairy DEIR SCH# 2020010298: 

The proposed project includes the construction and operation of a new truck parking facility located at 315/339 N. H Street. The project would include the following components and characteristics:

• demolition of all structures along H Street (north of Arroyo Avenue and south of N. Harrison Avenue);

• grading and new paved parking lot for diesel milk trucks; and

• closure and relinquishment of H Street from Belmont Avenue to Palm Avenue, which would result in rerouting of traffic onto other routes including Palm Avenue. The primary reroutes include rerouted traffic from: 

  • Northbound H Street north of Palm Avenue;

  • Southbound H Street south of Belmont Avenue; and

  • Southbound Weber Street south of Thomas Avenue

Approximately 3.69 acres (or 160,865 square feet) of land currently developed with a range of old, abandoned feed mill and silos…would be paved. See the Project Description in the Initial Study for additional project description details. (DEIR ES-2; emphasis added)

The demolition should be considered in the broader context of the overall project, as is described in the Producers DEIR. Producers intends to demolish the silos and associated buildings for diesel truck parking. The full impacts of the entire project should therefore be considered together. Without doing so amounts to illegal piecemealing of the project, especially when the Producers DEIR states that there are significant and unavoidable impacts related to the demolition.

The procedure permitting the demolition of the silos and associated buildings directly conflicts with a the Downtown Neighborhoods Community Plan Environmental Impact Report and is thus out of compliance.

Mitigation Measure CUL-2 of the DNCP EIR states: In accordance with Objective HCR‐3 (specifically HCR‐3‐a) of the Fresno General Plan, and in accordance with DNCP Chapter 6 Goal 6.1 (specifically Policy 6.2.1 through 6.2.7), all efforts should be made (within appropriate safest standards) to preserve, rehabilitate, and re‐use historic age structures (whether determined eligible or not). (DNCP EIR 5.5-41)

Pursuant to MM CUL-2, the City should have required efforts to preserve, rehabilitate, and reuse the silos and associated buildings. There are many examples from around the country (and world) that demonstrate the economically and culturally successful adaptive reuse of grain silos (see just a few examples here). An additional local example is the Old Administration Building at Fresno City College, which nearly faced a similar fate of being demolished due to neglect, but today there is widespread agreement that preserving and rehabilitating the OAB has been important and beneficial to the community.

Adaptive re-use, mothballing preservation, or event partial preservation are all options that should have been considered under the requirements set forth in the DNCP. Yet, as no efforts have been made to preserve, rehabilitate, nor re-use the silos, this mitigation measure is unfulfilled and therefore the approval of the demolition is in direct conflict with the DNCP EIR.