Executive Summary

Development Pipeline

Industrial Projects

> Additional projects are included in the Appendix below.

Entitlement Risk

Approval Patterns

• Industrial approvals are increasingly tied to "Community Benefit Agreements" which fund dedicated law enforcement, code enforcement, and park maintenance positions .
• Recent patterns show the County Board of Supervisors prioritizing projects that include infrastructure improvements, such as the undergrounding of electrical lines and street widening .

Denial Patterns

• Projects face significant setbacks if they fail to adequately address the proximity to sensitive receptors, particularly schools; a judge previously ruled a major industrial EIR deficient on these grounds .
• Growing skepticism exists toward developers who attempt to renegotiate previously agreed-upon mitigation funds, leading to unified opposition from the school district and community .

Zoning Risk

• The 2017 Valley Corridor Specific Plan is undergoing an update to better attract retail and multi-family residential, potentially signaling a regulatory shift away from pure logistics in specific sub-zones .
• Residents are actively advocating for a warehouse moratorium on Cedar Avenue and the creation of a "Cedar Avenue Specific Plan" to prevent further industrial encroachment .

Political Risk

• There is significant pressure on the Board of Supervisors to align industrial growth with community health; State Senator Eloise Gomez Reyes has authored legislation requiring stricter public input for industrial rezonings .
• The transition of project ownership (e.g., from Howard to Brookfield) introduces risk, as new developers may challenge existing community commitments, sparking political backlash .

Community Risk

• Organized groups like the Center for Community Action and Environmental Justice (CCAEJ) and People's Collective for Environmental Justice (PC4AJ) are highly active in challenging EIRs and demanding Spanish-language inclusivity in the planning process .
• Public sentiment is sharply against using residential streets for truck traffic, with specific opposition to designating Cedar Avenue as a primary truck route .

Procedural Risk

• AB98 Compliance: The county must adopt formal truck routes by year-end, which may limit future warehouse site viability based on proximity to designated paths .
• Litigation Exposure: The Colton Joint Unified School District (CJUSD) has explicitly stated its readiness to file CEQA challenges if industrial projects proceed without honoring school relocation funding .

Key Stakeholders

Council Voting Patterns

• The Board of Supervisors is seen as the primary authority, though they are often criticized by residents for approving warehouses despite community opposition .
• The Municipal Advisory Council (MAC) serves as a critical feedback loop, frequently requesting delays to ensure developers are held accountable in public forums .

Key Officials & Positions

• Supervisor Joe Baca Jr.: Central figure in negotiating community benefit agreements and directing industrial-funded reserves toward local parks and schools .
• Frank Miranda (CJUSD Superintendent): A high-leverage stakeholder who successfully negotiated a $44.5M mitigation deal and remains a vocal opponent of projects threatening student safety .
• Mo Sanchez (Senior Code Enforcement Officer): Key in managing the impact of "illegal" industrial activity, such as unpermitted truck yards .

Active Developers & Consultants

• Brookfield: Currently spearheading the Bloomington Business Park, though facing friction over previous financial commitments .
• Starboard Realty Advisors: Developing retail/QSR projects like the Cedar Orange project .
• Kimley-Horn: Consulting on site planning and traffic queuing for new commercial developments .

Analysis & Strategic Insights

Industrial Pipeline Momentum vs. Entitlement Friction

Industrial momentum in Bloomington is currently at an impasse. While major projects like the Bloomington Business Park represent significant investment, they are caught in a cycle of "recirculated EIRs" and litigation . The friction is primarily financial; the community now expects developers to cover the full cost of school relocations—currently estimated at $88.5M for a single elementary school .

Emerging Regulatory Signals

• Truck Route Tightening: The implementation of AB98 will likely create "winners and losers" in land value. Sites adjacent to Slover Avenue and Cedar Avenue are being prioritized for routes, while Santa Ana Avenue may see new weight restrictions to protect residential zones .
• Increased Enforcement: New funding ($75,000) specifically for unpermitted truck terminal enforcement indicates a move toward "criminal citations" for illegal industrial land use .

Strategic Recommendations

• Site Positioning: Avoid sites that require heavy truck movements through residential "Beat 2" reporting districts, which currently see the highest volume of community complaints and sheriff calls .
• Stakeholder Engagement: Proactive negotiation with the CJUSD is mandatory for any project near Zimmerman Elementary; attempting to bypass their $44.5M benchmark is likely to trigger immediate CEQA litigation .
• Entitlement Sequencing: Developers should align project timelines with the upcoming Valley Corridor Specific Plan updates (expected in 6–12 months) to ensure compatibility with the county’s new economic development vision .

Near-Term Watch Items

• Board of Supervisors (December 16th): Final hearings on the AB98 truck route designations .
• Zimmerman School Relocation: Whether Brookfield honors the $44.5M agreement or faces a formal opposition campaign from the district .
• Urban Land Institute (January 21st): Technical assistance panel results for Bloomington revitalization .