TO: CITY OF DETROIT

COUNCIL MEMBER FRED DURHAL AND THE HONORABLE DETROIT CITY COUNCIL

2 WOODWARD AVE, SUITE 1340
DETROIT, MI 48226

FROM: THE UNDERSIGNED RESIDENTS OF DETROIT’S SEVENTH DISTRICT (D7) DATE: JUNE16,2022
RE: AMC REDEVELOPMENT 14250 PLYMOUTH RD, DETROIT, MI

Dear Detroit City Council,

We, the undersigned residents of District 7, are sending this letter to ask that our Honorable Detroit City Council require that Northpoint, the developers of the Former AMC Headquarters site at 14250 Plymouth execute a voluntary “Community Benefits Agreement” prior to receiving any additional approvals for public resources and site plans. Although this project does not trigger the CBO, the investment total ($72.1M) is now just $2.9M shy of the required ($75M) minimum threshold and the public investment in this project is at least more than (13) thirteen times the minimum required by the ordinance. District seven residents need a community benefits process tied to this project so that we can have the opportunity to learn about the potential long-term impacts of this project, use this information to negotiate assurances for necessary off-site mitigation, and negotiate an equitable community benefits package.

While the notion of seeing a long-abandoned heavy industrial site in our backyards restored is exciting, it has become clear from the information provided at recent community meetings that the AMC Redevelopment Project has the potential to negatively impact the quality of life in our neighborhood. We make this point based on the following:

1. Nuisance allowances based on the proposed project zoning – M
   2, Restricted Industrial District
2. The lack of a community environmental assessment
3. The use of public money without a fair exchange of community value

Nuisance allowances based on the proposed zoning at the site – M2, Restricted Industrial District

According to the City of Detroit, the M2, Restricted Industrial District permits “minimum undesirable effects.” This statement is contrary to our reality, however, as the increased prevalence of these warehousing facilities is directly related to the very freight trucks that generate air pollutants, noise, pavement damage, and traffic safety threats while moving into and out of warehouses located throughout the community. Given that warehousing facilities are regarded as locally undesirable, they are disproportionately distributed in BIPOC (Black, Indigenous and People of Color) neighborhoods 1 link like ours.

Distribution center activity significantly impacts public health due to particulate pollution emitted by the trucks and trains that supply the huge warehouse buildings with goods in shipping containers. 2 link Industrial Development is a marriage, a lifetime commitment between the facility and the residents surrounding it. If residents will be essentially entering into a marriage with the impacts of this facility, we deserve well- thought mitigation strategies to protect our health and ensure our well-being.

The AMC Headquarters was once a site that provided hundreds of jobs and added economic value to the community. Stakeholders who approved this site before it opened in 1927 did not think that they were setting the stage for what would become an environmental hazard and a major eyesore in the heart of our community. Now, one hundred years later, we have an opportunity to make more informed decisions about how development of this nature should show up in community and prevent significant long-term harm. Although we cannot alter the incompatible industrial zoning designation set forth at this site, we can learn from the history of this site, the importance of executing an intentional development process, especially where zoning impact misaligns with community need. Given that the zoning ordinance specifies a broad range of uses allowable at the site and the developer has not yet specified what specific kinds of industrial activity will occur at the site, it is imperative that we negotiate and document accountability standards to reduce community harm to the greatest predictable extent.

The lack of a community environmental assessment

While the developers of this project have put forth a robust on-site environmental remediation plan, there is no public record that the developer has shown interest in, nor have they made any written commitments to educating or partnering with residents to ensure accountability for the potential health and environmental risks posed to neighbors because of construction and future operations at the site. In addition to the on-site remediation required by the City and State, the developer’s plan for environmental/pollution remediation and mitigation includes:

• Landscaping around the site perimeter; and
• Off-site tree planting and landscaping to create a visual “green buffer” between the facility and the community.

Superficial green infrastructure installations such as these cannot alone reduce the health disparities related to pollution impacts. Local, state, and federal environmental protections have not kept pace with the rapid growth of warehousing and landscape buffers do not account for operations that may result in negative community impacts such as:

Diesel Truck Pollution

• The concentration and proximity of diesel trucks and the warehousing facilities that service them threatens the health of people living and working near busy roads and logistics facilities. The trucks and trains that carry freight to be warehoused (and trucks idling engines at or near warehouse sites) pollute by emitting small toxic particles called particulate matter (PM) into the air.
• BIPOC children are disproportionately impacted by health problems related to diesel truck pollution, including but not limited to stunted lung development and asthma.
• Particulate emissions from diesel vehicles and equipment also contribute to health problems that disproportionately harms communities of color including cardiovascular problems, cancer, decreased lung function and capacity, reproductive health problems, and premature death.
• Local, state, and federal laws have not kept pace with the proliferation of warehouse facilities and as a result, there are little existing regulations for pollution from warehouse- related traffic.

Construction vibrations

• A known nuisance that can damage existing residential structures.
• Poses significant risk to Detroit’s aged housing stock and senior homeowners who already have a great existing need for home repair resources.

Quality of Life Impacts
Beyond health threats from the transportation of freight, warehouses are also associated with negative impacts on residents’ quality of life. Residents often feel a sense that they are losing their community to encroachment by warehouses and kept in the dark about what is being stored in facilities near their homes. Trucks servicing the facilities park and idle on public streets, sometimes using streets as “staging areas” because a warehouse property is over capacity or does not provide adequate on-site parking.

Impacts on Residential Roads
There are also safety concerns as residents share roads not originally designed for heavy vehicles with lines of trucks.

Misalignment with Community Need
Warehouse centers deprive local communities of land that could be used for future green space, schools and public buildings, and new residential, retail, and commercial centers. The gap in fair taxation for this business activity as a result of tax abatements and incentives well into the future means that the immediate economic benefits will accrues to the investors and owners of the business – while local residents bear the brunt of its negative impacts. Industrial entities do not generally show up as good neighbors in community and District 7 is already an unfortunate example of what happens to neighborhoods oversaturated by these facilities and their operations.

...among other quality of life impacts

Majority Black communities in 19 states (including Michigan) are 79% more likely to live with industrial pollution than majority white communities. This ratio is even higher for Detroiters where asthma prevalence for children and seniors is 3x higher in Detroit than the state as a whole and where these same vulnerable populations are twice as likely to experience asthma related fatalities. In 2017, a report from the NAACP showed that in Detroit, 2,402 Black children have asthma attacks due to natural gas pollution per year and miss 1,751 days of school as a result. 3 link  We know that no one on our Detroit City Council wants to continue exacerbating these statistics, but these are the results when we do not hold industrial developers accountable.

The green infrastructure investments proposed with this project need to align with other efforts to ameliorate pollution injustices. 4 link Tree planting does not:

• Educate the community about how to hold the developers accountable for harmful environmental impacts from this facility;
• Absorb noxious gasses and toxic chemicals from the air and ground water; or
• Ensure protections for residents who will be most affected by the project.

The use of public money without a fair exchange of community value

The city and the developer originally presented this project to Detroiters with an investment of $66 million but since then costs have continuously increased by 9.2% to a current $72.1 million. At this point, the project cost need only increase by an additional 4% to trigger the CBO – a likely outcome after site construction begins given the hefty demolition, site remediation, and construction required to redevelop this 60-acre site. Even if project costs do not increase beyond current figures, the public investment far exceeds the public tax requirement to trigger the ordinance. A community benefits process will allow us to get the most out of the public’s investment in this site.

AMC Project and the CBO Comparison
Community Benefits Ordinance Project Cost $75 Million Investment
Public Investment $1 Million Tax Credits and Subsidy

AMC Project
$72.1 Million Investment
$31 Million+ Tax Credits and Subsidy

Black residents are often expected to sacrifice health concerns on behalf of claims of economic benefits such as employment and job training opportunities. Recent studies show that there is no evidence that correlates higher polluting industrial facilities with increased job creation, and it is an even more unreasonable trade off given that often, the number of jobs for Detroiters rarely materialize as promised by developers who use our tax dollars.

Knowing this, if this Council approves the exchange of our tax dollars for this project anyway, without demanding proper environmental assessments and protections, you will be sending a clear message to residents, like me, who live near this facility that these short-term jobs and this developer’s profit are a fair exchange for my community’s health and quality of life.

Conclusion

We the undersigned residents submit this letter with the hope that we can, as stewards of our community responsible for protecting the most vulnerable residents, take the time to slow down and negotiate an environmental mitigation and remediation plan with Northpoint prior to approving the requested tax abatements from the very people in this community who will be harmed the most by the project.

We are concerned that if this project advances as is, it may do more harm to our already poor air, water, and overall living conditions during and after construction, than it does right now as a vacant eyesore.

We urge you Councilmember Durhal, and fellow City Council members to support our call to demand a community benefits process that guarantees more than trees, landscaping, and “potential” jobs in exchange for residents’ reduced quality of life and increased exposure to pollution and additional disruptions in our neighborhoods. This is not a hard ask. As a community, we are asking for this voluntary CBA so that residents can

• Receive proper education on the environmental, health, and overall quality of life risks we will likely face with the AMC project redevelopment;
• Execute a more intentional resident engagement process;
• Get adequate input from our elected officials and community leaders on the above mentioned and
• other additional quality of life considerations; and
• Ultimately obtain the necessary commitments to environmental impact assessments, mitigation,
• and remediation by the developer to reduce harm to the greatest extent in our community.

Thank you for your consideration in this matter.

Mr. Marvin Liddell and Mrs. Wendy Caldwell-Liddell
Detroit, MI 48204

ATTACHMENTS:

1. Petition Signatures from District 7, Impact Area Residents.