Following is a working draft of a letter by Joshua Tree stakeholder Celeste Doyle to the County regarding Dynamic Development’s proposal to locate a Dollar General store in Joshua Tree. Thank you, Celeste, for sharing this with us.
San Bernardino County
Land Use Services Dept., Current Planning Division
Ernest Perea, Contract Planner
385 North Arrowhead Avenue, First Floor
San Bernardino, CA 92415-0182
Re: APN 0603-204-04 Dynamic Development, LLC (Project #P201100357/CIP)
I am writing to request that the above-referenced application to establish a 9100 square foot Dollar General retail store on 1.45 acres at the northwest corner of Highway 62 & Sunburst Ave in Joshua Tree be denied. The project is inconsistent with Goals and Policies in the Joshua Tree Community Plan, and it will take money from our community and existing businesses without improving our tax or employment base. A Dollar General store in Joshua Tree would undermine the hard work of many in the community to build a unique, downtown district that is based on eco-tourism and outdoor recreation. A Dollar General store in Joshua Tree would also harm our local economy by taking business away from our three, non-profit thrift stores, our small, independent grocery store and other small businesses in the area.
CEQA requires that these economic impacts be analyzed and reviewed as part of the decision-making process on this application. The County’s review of this application must also address applicable provisions of the General Land Use Plan, the Joshua Tree Community Plan, and the Development Code. After conducting the required analyses and review, the County will find that the project will bring negative economic impacts that would ripple through the Morongo Basin, and that the project does not comply with applicable Plan and Code provisions. For these reasons, the County should deny the application.
Negative Economic Impacts
According to the Dollar General Store Corporate website, its stores carry inexpensive products and prepared, non-perishable food items. The corporation currently portrays itself as the largest low-end retail chain in the country. It says it owns and operates nearly 10,000 stores nationally. The proposed Joshua Tree store is one of fifty planned for the State of California, including three here in the Morongo Basin: The plan calls for a new Dollar General store in Yucca Valley, one in Twentynine Palms, and one in Joshua Tree. The three stores will extract money from the Morongo Basin and send it to the Dollar General Store Headquarters in Tennessee. The Store in Joshua Tree will not add jobs or sales tax revenues, and may lead to urban blight in our small downtown district.
A Dollar General Store in Joshua Tree will take business away from our three non-profit thrift stores, which benefit the Morongo Hospice, needy and homeless women and children, and the local public hospital:
1) The Morongo Hospice is a non-profit organization that provides care and comfort to those who are dying and to their families.
2) The Unity Home is a non-profit organization that helps needy and abused women and children with food, clothing, medical care, housing and counseling.
3) The Hi-Desert Medical Center Thrift Store benefits our local, public hospital, which recently reported it is operating in the red: Many Morongo Basin residents are uninsured and can’t otherwise afford healthcare, so they use the Emergency Room, where they can’t be turned away even if they can’t pay. The next closest hospital is an hour away in Palm Springs.
A Dollar General Store in Joshua Tree will also likely take business away from Sam’s Market, our local, independent grocery store, and the JT Trading Post, both of which already sell much of what Dollar General says it has to offer.
A Dollar General Store will not increase the sales-tax or employment base in Joshua Tree, because it will not add retail sales or jobs. Rather, it will only take sales away from the Thrift Stores and other locally-owned businesses. This shift will lead some of these local stores and businesses to close: They will no longer pay sales taxes, they will lay-off their employees, and they will empty their buildings. Net retail sales in Joshua Tree will not increase and the net number of jobs in Joshua Tree will not increase, but the number of empty storefronts will increase.
If the Thrift Stores close, these long-standing, local non-profits will lose income vital to the critical services they provide to our community and surrounding areas. If they lose their storefronts, they will also lose much of their local visibility, further hampering their long-term fund-raising abilities. Furthermore, the closed storefronts will likely stand empty for a very long time, degrading the town’s appearance and vitality, inviting vandalism and leading to urban blight.
Though Dollar General says it wants to bring its store to Joshua Tree for the convenience of local shoppers, it is really all about making money. Joshua Tree residents can already purchase much of what Dollar General will offer in local markets. What can’t be found at these local shops can be found only 4 miles away on Highway 62 in Yucca Valley. Just a five-minute drive, or a ten-minute bus-ride gets Joshua Tree residents to the intersection of Hwy 62 and Balsa Ave, where they routinely shop at a large grocery store (Stater Brothers), a Walmart, a Walgreens and a Dollar Tree Store, as well as a J.C. Penny and several, smaller retailers. Only another mile down the road, and just a few bus-stops away, is a large, new Rite-Aid, a Vons Supermarket and other retailers.
The CEQA review for this application must analyze and address these negative, economic impacts. Because of these negative impacts, and because the project is inconsistent with, and even contrary to, specific provisions in the Joshua Tree Community Plan, the application should be denied.
The Joshua Tree Community Plan and Development Code
The introduction to the Joshua Tree Community Plan (JTCP or the Plan) establishes the context for interpreting and applying applicable Goals, Policies and Code provisions. The JTCP declares that its primary purpose “is to guide the future use and development of land within the Joshua Tree Community Plan area in a manner that preserves the character and independent identity of the community. By setting goals and policies for the Joshua Tree community that are distinct from those applied countywide, the Community Plan outlines how the County of San Bernardino will manage and address growth while retaining the attributes that make Joshua Tree unique.”
The Plan says that Joshua Tree residents “are concerned about the conversion of open space to development, particularly to a type of development that detracts from the natural setting and rural character currently enjoyed by the community. Residents have expressed their desire to retain their community character based on the following principles: to be vigilant about the preservation of the natural environment, and to create a central downtown core to enhance their tourist-based economy, without tarnishing the natural beauty of their community.”
In the Economic Development Section, the Plan explains the community’s vision and objectives in more detail, further clarifying and defining the context for applying and interpreting substantive provisions:
“As has been repeated throughout the various elements included within this community plan, one of the most important goals of the Joshua Tree Community is to enhance the community’s economic and cultural opportunities while maintaining the natural desert surroundings. It will be important to ensure that future development protects and enhances the natural resources, scenic beauty and character in order to continue to appeal to both residents and visitors. Joshua Tree National Park is a popular destination that offers opportunities for camping, rock climbing, nature viewing, etc. The National Park is a driving force in the economy of Joshua Tree. The community’s goal is to preserve and protect that asset as key to an expanded eco-tourism and recreation-based economy that also serves local needs. A growing community of artists, musicians and others drawn to the natural beauty of Joshua Tree is another key element of the local economy, attracting new residents and thousands of visitors to local events. In input gathered from residents, there is a strong desire to see the commercial areas, particularly the downtown area enhanced. As a gateway community to the National Park, Joshua Tree is perceived as ideal for establishment of additional recreation facilities, visitor services, including lodging, food service, fuel and automotive, emergency services and visitor information. Many of the residents in Joshua Tree would like to enhance the availability of goods and services oriented to both local needs and that of visitors. However, residents want to ensure that future development is unobtrusive and complements the character of the community. In addition to protecting the National Park and other natural resources including desert landscapes and vistas, the community’s economic plan relies on a small central business district that is pedestrian-friendly and includes community spaces for small gatherings, public displays of art, picnicking and other recreational opportunities.”
Among the particular Plan Goals and Policies that apply to the matter at hand and that must be addressed as part of the review of this application are the following:
“Goal JT/LU 2 Support development of the existing downtown commercial area of Joshua Tree as a focal point and core activity center within the community.
“JT/LU 2.1 Support revitalization of the existing downtown commercial area by encouraging tourist services and recreation-oriented retail uses that retain the natural desert character.” (page 24)
A Dollar General Store would not support existing downtown development in Joshua Tree, but instead would detract from and degrade the area. It would take sales away from existing Joshua Tree retailers, which may lead some of them to close, leaving empty store fronts and leading to urban blight.
“Goal JT/LU 3 Enhance commercial development within the plan area that is compatible in type and scale with the rural desert character, is located appropriately, and meets the needs of local residents and visitors. (page 24)
“JT/LU 3.5 Encourage the development or expansion of commercial uses that are compatible with adjacent land uses and respect the existing positive characteristics of the community and its natural environment, and that provide buffering from environmentally sensitive areas.
“Goal JT/ED 1. Preserve and protect Joshua Tree’s unique and evolving community atmosphere, artistic base and natural surroundings while providing jobs and improving its tax base.
“JT/ED 1.1 Promote diverse architectural styles and alternative construction methods that complement the local landscape and vistas.
“JT/ED 1.2 Encourage small commercial footprints that maintain open space areas on site.
“JT/ED 1.3 Encourage and support small independent businesses.
“JT/ED 1.4 Support commercial development that is of a size and scale that complements the natural setting, is compatible with surrounding development and enhances the rural character by incorporating natural desert landscape elements.”
The Dollar General Store plan calls for a 9,000 sq. ft. (+/-) block building fronted by a parking lot. Neither the scale nor the type of this development project is consistent or compatible with character of Joshua Tree.
“JT/CI 1.1 Ensure that all new development proposals do not degrade Levels of Service (LOS) on State Routes and Major Arterials below LOS C.”
In 2004, Highway 62, in between Yucca Mesa Road and Sunfair Road, was operating at level of service (LOS) C. (Table 4, page 31, Joshua Tree Community Plan.) It is projected to operate at LOS D by 2030. (Table 4, page 31, Joshua Tree Community Plan.) The intersection of Hwy 62 and Sunburst was operating at LOS C in 2004. (Table 4, page 31, Joshua Tree Community Plan) Sunburst Avenue between Crestview and Highway 62 operated at LOS B in 2004, (Table 4, page 31, Joshua Tree Community Plan.) Joshua Tree Community Plan Policy (Circulation) (Page 33.)
Since 2004, the Mojave Sands Hotel has opened near the southeast corner of the Sunburst/Hwy 62 intersection, increasing the overall volume of traffic at this intersection and in slowing and turning traffic entering and exiting the Highway less than 100 feet from the traffic light and intersection.
Increased vehicle traffic, bus activity, pedestrian and bicycle traffic drawn by the new store will necessarily and unavoidably affect the neighborhood, the highway and the intersection at Highway 62 and Sunburst Ave. Because these new burdens will unavoidably degrade the Level of Service (LOS) at the Sunburst/Hwy 62 intersection, the project should be denied as contrary to the above-quoted Joshua Tree Plan Provision. If the project is approved, it must be conditioned to require the retailer to reduce these negative effects by limiting access in and out of the Dollar General parking lot to Mountain View Drive only (the side street on the west side of the subject property).
The Joshua Tree Community Plan says that “Public transit is provided by the Morongo Basin Transit Authority. The downtown area is lacking in transit amenities such as centralized bus stops, shelters and benches that also recognize the use of mobility devices and senior needs.” (page 32)
To address this finding, as well as in recognition that a substantial portion of Dollar General’s clientele are the disabled, the elderly and the poor, any approval should include a requirement that the applicant construct or pay for a new MBTA stop to serve the store. The stop should be adjacent to the Dollar General Store’s property on Mountain View, or in its parking lot, or as a pull-out from Hwy 62 near the existing bus stop. The new stop should be located and oriented to allow access to the entrance to the Store over the shortest distance possible without having to walk in or across the parking lot. At a minimum, the applicant should be required to contribute to improvements to the existing MBTA stops on the north and south sides of Highway 62 near Sunburst, by adding benches, shelters, and by providing paved access from the new building to the bus stop on the north side of the Highway.
The Joshua Tree Community Plan and the County Development code require new development be pedestrian and bicycle friendly. The Americans with Disabilities Act and the County Plan and Code require site and building access accommodate disabled, provide for bicycle parking. If approved, the project must be conditioned on the developer providing adequate and safe pedestrian facilities and access, and bicycle parking and access.
The building should be located and oriented close to the highway and the MBTA bus stop to allow pedestrian/disabled/bicycle access without these patrons having to enter or cross the parking lot, thus avoiding pedestrian/vehicle conflicts – the parking lot should be on the west side of the building with ingress/egress onto Mountain View Street only (not to Sunburst, not to Hwy 62, and not to Commercial).
Other Plan and code provisions that must be addressed include the following:
JT/ED 1.11 Balance economic development with preservation of open space by maintaining requirements for new and expanded developments to provide landscaped areas and buffers as needed to screen more intensive land uses.
JT/CO 1.3 Require future development to utilize water conservation techniques. P 48
Goal JT/CO8. Preserve the dark night sky as a natural resource to be enjoyed by residents and visitors to Joshua Tree. page 50
JT/ED 4.1 Commercial development shall be compatible with the rural environment, and shall protect the quality of residential living.
San Bernardino Development Code 83.01.080 Noise
This Section establishes standards concerning acceptable noise levels for both noise-sensitive land uses and for noise-generating land uses. Since the property is next door to existing homes in the densest neighborhood in Joshua Tree, any approval must limit deliveries to specified, daytime hours on weekdays, and arrange the site plan to eliminate, or at least minimize any need for trucks to back-up. The Dollar General website says its site criteria require room for delivery trucks with 53-foot trailers – too big for the site and the neighborhood and deliveries should be restricted to a time and manner that limits conflicts with existing residences as much as possible. The site plan should be altered to eliminate any vehicle access to the site from Commercial Street.
San Bernardino Development Code 84.24.040 Storage Areas for Nonresidential Uses
Nonresidential uses shall provide refuse and recyclable material storage areas in compliance with the following requirements. Requirements apply to each individual structure. Areas are measured in square feet. Require installation, maintenance of trash & recycling receptacles – require donation/support of Joshua Tree Clean Team, which regularly picks up trash at/near the Sunburst/Hwy 62 intersection –
San Bernardino Development Code 83.01.090 Vibration
(a) Vibration standard. No ground vibration shall be allowed that can be felt without the aid of instruments at or beyond the lot line, nor shall any vibration be allowed which produces a particle velocity greater than or equal to two-tenths (0.2) inches per second measured at or beyond the lot line.
Please enter this letter and attachments into the record of this Dollar General application. Please notify me of any hearings, or any other action on this application.
Celeste J. Doyle
61707 29 Palms Hwy.
Joshua Tree, CA 92252