Rancho Cucamonga City Council
May 7, 2025

or a waiver of that fee, based upon the absence of any reasonable relationship or nexus between the traffic impacts of that development and either the amount or the fee charged or the type of facilities to be financed.” This avenue is open to anyone disputing the transportation impact fee and generally would be facilitated by the following key considerations that are required by the Government Code:

Fee Challenges and Protest Procedures
Under Government Code § 66020, developers or property owners who disagree with the amount or validity of an imposed fee must follow a specific protest procedure. To preserve their right to challenge the fee:


The developer must submit a written notice of protest to the City at the time of fee payment or within 90 days after the fee imposition.

The protest must clearly outline the grounds for dispute, such as the lack of nexus between the fee and the development's impact or disagreement with the fee calculation method.

Failure to file a protest within this period waives the right to legally challenge the fee in the future. This is consistent with the Municipal Code as noted above.

Public Hearing for Disputes
If the dispute is not resolved at the local level, the developer has the right to seek judicial review. To initiate this process:


A lawsuit challenging the fee must be filed within 180 days of the fee being imposed or from the final decision issued by the City after the grievance process.

Judicial review focuses on whether the fee complies with the Mitigation Fee Act, particularly the essential nexus and rough proportionality tests established in case law (e.g., Nollan v. California Coastal Commission and Dolan v. City of Tigard).

DIF Nexus Study 35

Appendices

Appendix A – Resolution No. 20‐122

December 2, 2020

Appendix B – Completed DIF Projects List (Resolution No. 20‐122) Project ID Project
Freeway Interchanges
Freeway Interchanges
Freeway Interchanges
1 2
3 Base Line Road at 1-15 Freeway- Widen NB & SB On-Ramps Foothill Boulevard at 1-15 Freeway - Widen NB & SB On-Ramps Base Line Road at 1-15 Freeway - Interchange Improvements Railroad Grade Separations
and Crossings 1
4 Haven Avenue at Metrolink Crossing - Grade Separation Railroad Grade Separations
and Crossings Hellman Avenue at 8th Street - Upgrade Existing RXR Crossing Gates Bridges
Bridges
Streets
Streets
Streets
Streets
4 8
Banyan Street at Etiwanda Creek Channel - Bridge
Wilson Avenue at Etiwanda Creek Channel - Bridge
4 Banyan Street - Etiwanda Avenue to East Avenue - Widen North Side Banyan Street - East Avenue to Wardman Bullock Road - New Alignment East Avenue - Fire Station to Wilson - New
5 10
22 Haven Avenue - Base Line Road to 1-210 Freeway - Widen West Side Only Streets 25 Milliken Avenue - 5th Street to 700' S/O 5th Street - Widen West Side Only Victoria Street - East Property Line of Etiwanda High School to 1-15 Freeway - Improve Both ShouldersStreets 26
Streets 27
30 1
Vintage Drive - Etiwanda Avenue to 1,300' W/O Etiwanda Avenue - New Wilson Avenue - East Avenue to Wardman Bullock Road - New 4th Street at Richmond Place
Streets
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
2 4th Street at Utica Avenue
3 6th Street at Buffalo Avenue
4 6th Street at Cleveland Avenue
6 6th Street at Hellman Avenue
8 6th Street at Rochester Avenue
10 11
12 15
6th Street at Utica Avenue
Archibald Avenue at Banyan Street
Archibald Avenue at San Bernardino Road
Arrow Route at Center Avenue

Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
17 18
19 20
21 23
24 26
29 30
31 33
34 35
36 38
39 40
41 42
43 45
46 55
56 57
60 61
62 63
64 65
66 Banyan Street at Wardman Bullock Road
Base Line Road at San Carmela Court
Base Line Road at Shelby Place
Carnelian Street at Banyan Street
Carnelian Street at Wilson Avenue
Church Street at Elm Avenue (West)
Church Street at Mayten Avenue
Church Street at Terra Vista Parkway
Day Creek Boulevard at Madrigal Place
Day Creek Boulevard at Wilson Avenue
East Avenue at Miller Avenue
Etiwanda Avenue at Garcia Drive
Etiwanda Avenue at Whittram Avenue
Foothill Boulevard at Cornwall Court
Foothill Boulevard at East Avenue
Haven Avenue at Trademark Street
Haven Avenue at Valencia Avenue
Haven Avenue at Wilson Avenue
Hellman Avenue at 8th Street
Hermosa Avenue at Church Street
Milliken Avenue at 5th Street
Rochester Avenue at Jersey Boulevard
Spruce Avenue at Elm Avenue
Wilson Avenue at San Sevaine Road
Wilson Avenue at Wardman Bullock Road
Wilson Avenue at Canistel Avenue
Arrow Route at Etiwanda Avenue - Left Turn Phasing Upgrade Arrow Route at Red Oak Street - Left Turn Phasing Upgrade Arrow Route at White Oak Street - Left Turn Phasing Upgrade Banyan Street at East Avenue - Left Turn Phasing Upgrade Base Line Road at Mountain View Drive - Left Turn Phasing Upgrade Base Line Road at Spruce Avenue - Left Turn Phasing Upgrade Base Line Road at Valencia Avenue - Left Turn Phasing Upgrade

Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
Traffic Signal Improvements
67 68
69 70
71 72
73 74
Day Creek Boulevard at Silverberry Street - Left Turn Phasing Upgrade Day Creek Boulevard at Sugar Gum Street - Left Turn Phasing Upgrade Day Creek Boulevard at Victoria Park Lane - Left Turn Phasing Upgrade Milliken Avenue at Millenium Court - Left Turn Phasing Upgrade Milliken Avenue at Mountain View Drive - Left Turn Phasing Upgrade Milliken Avenue at Terra Vista Parkway - Left Turn Phasing Upgrade Milliken Avenue at Victoria Park Lane - Left Turn Phasing Upgrade Milliken Avenue at Vintage Drive - Left Turn Phasing Upgrade

Appendix C
DIF Cost Estimates and Soft Cost Assumptions
Adjustment for
Engineering,
Environmental &
Contingency (soft
costs)
Project
Construction Cost
Estimate
Project
Name/Location
Description/
Location
Quantity*
(Mile or Lane Mile)
Total Facility Cost in
Fee ProgramProject ID
Grove Avenue/ 4th
Street at Interchange
improvementF 1
R 1
-
-
$10,000,000
$3,719,000
20%
0%
$12,000,000
$3,719,000
1-10 Freeway
6th Street E/O Santa
Anita Avenue
RXR crossing
improvement
Widen existing
bridge or use prefab
bridge adjacent to
existing structure
6th Street at
Cucamonga Creek
Channel
B 1 - $3,750,000 50% $5,625,000
Arrow Route at
Etiwanda Ditch
Widen existing
bridgeB 2
B 3
B 4
S 1
-
-
$5,062,500
$3,750,000
$2,600,000
$3,000,000
50%
50%
50%
50%
$7,593,750
$5,625,000
$3,900,000
$4,500,000
Whittram Avenue at
Etiwanda Ditch Construct new Bridge
Construct new bridge
Complete Streets
Wilson Avenue at
Day Creek Channel -
Arrow Route Grove
Ave to Baker Ave 1.00
Widen west side of
Cherry Ave from
Wilson Ave to
Channel
Cherry Avenue
roadway wideningS 2
S 3

0.30 0.75
$450,000
$561,750
50%
50%
$675,000
$842,625Church Street
buffered bike lanes
From Ramona Ave to
Haven Ave

East Avenue roadway Widen from 1-15 to
S 4
S 5
widening north of I- Victoria Street at
bottleneck locations
- $1,325,000
$1,325,000
$1,200,000
50%
50%
50%
$1,987,500
$1,987,500
$1,800,000
15 East Avenue
extension north of
Wilson Ave
Wilson Avenue to
North Rim Way- New 1.00

0.30 Etiwanda Avenue
roadway widening
south of Arrow Rte
Widen 2 to 4 lanes
from Arrow Rte to
Whittram Ave
S 6**
Widen east side of
Etiwanda Ave from
Miller Ave to 850'
north of Miller Ave
Etiwanda Avenue
roadway widening
north of Miller Ave
S 7 1.00 $240,000 50% $360,000
Foothill Boulevard - Widen north side of
Hellman Avenue to
700' E/O Hellman
Avenue
Foothill Blvd from
Hellman Ave to 700'
east of Hellman Ave
S 8**
S 9**

0.30 1.00

0.30 $195,000
$1,325,000
$530,000
50%
50%
50%
$292,500
$1,987,500
$795,000
Foothill Boulevard -
Archibald Avenue to from Archibald Ave
Hermosa Avenue
Widen 4 to 6 lanes
to Hermosa Ave
Widen east side of
Grove Ave from 1 to
2 lanes between 9th
St and Tapia Via Dr
Grove Avenue
roadway widening
north of 9th St
S 10**
Widen east side of
Grove Ave from 1 toGrove Avenue
S 11**
S 12
roadway widening 2 lanes between San
south of Foothill Blvd Bernardino Rd and
Foothill Blvd

1.00 0.30
$195,000 50%
50%
$292,500
Wilson Avenue
extension west of
Day Creek Blvd
Wilson Ave extension
from Milliken Ave to
Day Creek Blvd
$2,650,000 $3,975,000

Wilson Avenue
extension east of
Etiwanda Ave
Wilson Ave extension
from Etiwanda Ave to
East Ave
S 13 1.00 $1,325,000 50% $1,987,500
(Backbone Only)
6th Street at
Pittsburgh AvenueINT 1
INT 2
INT 3
INT 4
INT 5
INT 6
INT 7
INT 8
INT 9
INT 10
INT 11
INT 12
INT 13
INT 14
New Traffic Signal
New Traffic Signal
New Traffic Signal
Roundabout
-
-
-
-
-
-
-
-
-
-
-
-
-
-
$750,000
$750,000
10%
10%
10%
50%
50%
50%
50%
50%
10%
50%
50%
50%
50%
50%
$825,000
$825,0006th Street at Santa
Anita Avenue
Archibald Avenue at
Victoria Street $750,000 $825,000
Banyan Street at
Rochester Avenue $1,500,000
$1,500,000
$1,500,000
$1,500,000
$1,500,000
$750,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$825,000
Church Street at
Ramona Avenue Roundabout
Civic Center Drive at
Red Oak Street Roundabout
Ridgeline Place at
Wilson Avenue Roundabout
East Avenue at
Highland Avenue Roundabout
Foothill Boulevard at
Malachite Avenue New Traffic Signal
RoundaboutMilliken Avenue at
Wilson Avenue $1,500,000
$1,500,000
$1,500,000
$1,500,000
$1,500,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
Spruce Avenue at
Mountain View Drive Roundabout
Spruce Avenue at
Red Oak Street Roundabout
Terra Vista Parkway
at Spruce Avenue Roundabout
Terra Vista Parkway
at Town Center Drive Roundabout

Town Center Drive at
Elm AvenueINT 15
INT 16
INT 17
Roundabout
Roundabout
Roundabout
-
-
-
$1,500,000
$1,500,000
$1,500,000
50%
50%
50%
$2,250,000
$2,250,000
$2,250,000
Wilson Avenue at
East Avenue
Wilson Avenue at
Etiwanda Avenue
4th Street at Golden
Oak Road - Left Turn
Phasing Upgrade
Traffic signal
modificationINT 18
INT 19
INT 20
T 1
-
-
$50,000
$50,000
10%
10%
50%
50%
$55,000
$55,000
Archibald Avenue at
Banyan Street - Left
Turn Phasing
Traffic signal
modification
Upgrade
Citywide traffic signal
communication
improvements
Signal Interconnect
System - $30,000,000
$632,500
$45,000,000
$948,750
Cucamonga Creek
Channel from Base
Line Road to Foothill
Boulevard
Trail improvements 1.1
Cucamonga Creek
Channel at Base Line
Road
Trail crossing
improvementsT 2
T 3
T 4
-
-
-
$750,000
$750,000
$750,000
10%
10%
10%
$825,000
$825,000
$825,000
Cucamonga Creek
Channel at Foothill
Boulevard
Trail crossing
improvements
Cucamonga Creek
Channel at Arrow
Route
Trail crossing
improvements
Cucamonga Creek
Channel at 9th Street
Trail crossing
improvementsT 5
T 6
-
-
$75,000 50%
10%
$112,500
$825,000Cucamonga Creek
Channel at 6th Street
Trail crossing
improvements $750,000

Deer Creek Channel
at Foothill Boulevard
Trail crossing
improvementsT 7
T 8
-
-
-
-
-
$750,000
$750,000
$750,000
$75,000
10%
10%
10%
50%
10%
$825,000
$825,000
$825,000
$112,500
$825,000
Deer Creek Channel
at Arrow Route
Trail crossing
improvements
Deer Creek Channel
at 6th Street
Trail crossing
improvementsT 9
Day Creek Channel at
Victoria Park Lane
Trail crossing
improvementsT 10
T 11 Day Creek Channel at
Base Line Road
Trail crossing
improvements $750,000
Archibald Avenue
Buffered Bike Lanes
and Ped
Base Line Rd to
Foothill Blvd, Arrow
Rte to 7th St
CRH 4 1.50 $690,000 $690,000
Enhancements
San Bernardino Road
Stripe Shoulders
Vineyard Ave to
Archibald AveCRH 5
CRH 6
- $122,000
$486,000
$122,000
$486,000
Church Street
Buffered Bike Lanes
and Stripe Shoulders
Pepper St to Ramona
Ave 1.10
See Connect RC App.

B. Cost Estimates
Include Soft Costs
For These Items
Hermosa Avenue
Buffered Bike Lane
and New Sidewalks
Base Line Rd to
Foothill BlvdCRH 11
CRH 14
E 1

1.00 -
$741,000
$191,000
$3,853,000
$741,000
$191,000
$3,853,000
Feron Boulevard Ped
Enhancements
Archibald Ave to
Hermosa Ave
Banyan Street Ped
Enhancements and to Wardman Bullock
Deer Creek Channel

3.70 Buffered Lanes Rd
Day Creek Boulevard
Buffered Bike Lanes Etiwanda Ave to SR-E 2 2.20 $1,144,000 $1,144,000and Ped 210 WB Ramp Enhancements

Etiwanda Avenue
Bike Route and Ped
Crossing
SR-210 to Banyan St,
Saddleridge Dr to
Victoria St
E 4
E 5

0.50 1.70
$274,000 $274,000
Enhancements
Day Creek Blvd to
Etiwanda Ave,
Wardman Bullock Rd
to Cherry Ave, Wilson
Ave at Bluegrass Ave
Wilson Avenue
Buffered Bike Lane
and Ped Crossing
Enhancements
$1,017,000 $1,017,000
Victoria Street Ped
EnhancementsE 6
E 7
East Ave and I-15 - $69,000 $69,000
East Avenue Buffered
Bike Lane and New Banyan St to Philly Dr
Sidewalks

0.40 $1,328,000 $1,328,000
Base Line Road Ped
and Bike
Enhancements
Wanona Pl to Shelby
PlE 8
E 9

0.27 -
$486,000
$258,000
$987,000
$42,000
$486,000
$258,000
$987,000
$42,000
Coyote Dr and
Duncaster Pl,
Stoneview Rd and
Duncaster Pl
Duncaster Place Ped
Enhancements
Etiwanda Creek
E 10
E 11
Channel Multi-Use PE Trail to Victoria St 1.80

1.90 Trail
Summit
Intermediate/
Etiwanda Creek Park
Connection
Etiwanda Creek
Parking Lot
Terra Vista Parkway
Ped/Bike
Enhancements
Terra Vista Pkwy to
Hampton PlCNE 1
CNE 2

1.90 -
$1,443,000
$589,000
$1,443,000
$589,000
Spruce Ave at Terra
Vista Pkwy, Mountain
View Dr, Elm Ave
Spruce Avenue Ped
Enhancements

Base Line Road
Buffered Bike Lane
and Deer Creek Trail
Crossing
Haven Ave to
Etiwanda AveCNE 8
CNE 9

3.00 -
$1,461,000
$49,000
$1,461,000
$49,000
Elm Avenue Crossing
Enhancements and
Sidewalk at Coyote
Canyon Elementary
Spruce Ave to
Church St
Church Street
Buffered Bike LanesCNE 10
CNE 11
CNE 13
Mayten Ave to I-15 1.80

1.90 -
$856,000
$688,000
$76,000
$856,000
$688,000
$76,000
Day Creek Boulevard
Buffered Bike Lanes
Highland Ave to
Foothill Blvd
Lark Drive New
Crosswalks
Lark Dr at Rochester
Ave, Matera Pl
Miller Avenue
Buffered Bike Lanes,
Sidewalks and Ped
Enhancements
CNE 14
CNE 15
CSS 2
I-15 to East Ave 0.50

0.60 1.00
$444,000
$212,000
$3,637,000
$444,000
$212,000
$3,637,000
Garcia Dr from
Etiwanda Ave toDolcetto Place and
Garcia Drive Buffered Dolcetto Pl, Colcetto
Bike Lanes Pl from Miller Ave to
Garcia Dr
Spruce Avenue and
Red Oak Street
Ped/Bike
Foothill Blvd to
Arrow Rte
Enhancements
6th St Cucamonga
Creek Channel to
Haven Ave
Bicycle Corridor
ImprovementsCRH 15
CCS 3

1.58 0.55
$1,027,000
$357,500
20%
20%
$1,232,400
$429,000Jersey Blvd Haven
Ave to Rochester Ave
Bicycle Corridor
Improvements

Foothill Blvd highway
to city centerDTRC 1
DTRC 5
Rochester to ECL -
-
$17,800,000
$750,000
25%
10%
$22,250,000
$825,000
boulevard
transformation
Day Creek Channel
Trail and Park Drive
(Foothill Blvd)
New signalized
crossing
crossing
Day Creek Channel
Trail
8th St to Future
Etiwanda HeightsDTRC 6
CC 1

3.4 -
$3,700,000
$87,500,000
$62,500,000
30%
25%
25%
$4,810,000
$109,375,000
$78,125,000
Foothill Blvd AT
transformation
Haven Ave to
Rochester Ave
Haven Ave AT
transformationCC 1.1 Foothill Blvd to 7th St -
Haven Ave to Mayten
Ave (east of Mayten
in Connect RC)
Church St buffered
bike lanesCC 2 1.43 $929,500 20% $1,115,400
Arrow Rte buffered
bike lanes
Hermosa Ave to
Rochester AveCC 2.1
CC 2.2

2.23 1.52
$1,449,500
$988,000
20%
20%
$1,739,400
$1,185,600Hermosa Ave
buffered bike lanes Foothill Blvd to 6th St
Devon St terminus to
Civic Center Dr
terminus
CC 3 Devon St extension 0.30 $397,500 50% $596,250
Rochester Ave
buffered bike lanesHART 2
HART 3
HART 4
Foothill Blvd to 6th St 1.32

1.46 0.88
$858,000
$1,934,500
$1,166,000
20%
50%
50%
$1,029,600
$2,901,750
$1,749,000
Azusa Ct terminus to
Acacia St terminusAzusa Ct extension
7th St extension Milliken Ave to
Haven Ave

Class IV bicycle
corridor and
complete streets
improvements
Foothill Blvd from
Haven Ave to WCLRH 6 -
-
$15,300,000
$7,500,000
25%
25%
$19,125,000
$9,375,000
Archibald AT
transformation with
buffered bike lanes
CTC 1 7th St to 4th St
9th St extension
(roadway)
Archibald Ave and
Hermosa AveCTC 6
SEIQ 2
SEIQ 2.2
SEIQ 3
SIEQ 6

0.74 1.25

0.72 1.46
-
$980,500
$812,500
50%
20%
20%
50%
23%
$1,470,750
$975,000Arrow Rte buffered
bike lanes
Rochester Ave to
Etiwanda Ave
6th St buffered bike Spur line to Etiwanda $468,000 $561,600lanes Ave Whittram Ave
extension
Etiwanda Ave to
Rochester Ave $9,869,0001
$119,875,000
$14,803,500
$147,675,000Etiwanda Grade
Separation (EGS)

1. Includes costs for I-15 undercrossing

DIF Project List and Project Cost Estimates
FutureNew Development
ContributionProject
Name/Location
Description/Locatio
n
Quantity*
(Mile or Lane Mile)
Total Project Cost
Estimate
Development
Contribution
Amount
Project ID
(Percentage)
Grove Avenue/ 4th
Street at Interchange
improvementF 1
R 1
-
-
$12,000,000
$3,719,000
100.0%
100.0%
$12,000,000
$3,719,000
1-10 Freeway
6th Street E/O Santa
Anita Avenue
RXR crossing
improvement
Widen existing
bridge or use prefab
bridge adjacent to
existing structure
6th Street at
Cucamonga Creek
Channel
B 1 - $5,625,000 100.0% $5,625,000
Arrow Route at
Etiwanda Ditch
Widen existing
bridgeB 2
B 3
B 4
S 1
-
-
$7,593,750
$5,625,000
$3,900,000
$4,500,000
100.0%
100.0%
100.0%

29.6%
$7,593,750
$5,625,000
$3,900,000
$1,332,000
Whittram Avenue at
Etiwanda Ditch Construct new Bridge
Construct new bridge
Complete Streets
Wilson Avenue at
Day Creek Channel -
Arrow Route Grove
Ave to Baker Ave 1.00
Widen west side of
Cherry Ave from
Wilson Ave to
Channel
Cherry Avenue
roadway wideningS 2 0.30 $675,000 100.0% $675,000
Church Street
buffered bike lanes
From Ramona Ave to
Haven AveS 3
S 4

0.75 -
$842,625 29.6% $249,417
East Avenue roadway Widen from 1-15 to
widening north of I- Victoria Street at $1,987,500 100.0% $1,987,500 15 bottleneck locations

East Avenue
extension north of
Wilson Ave
Wilson Avenue to
North Rim Way- NewS 5 1.00

0.30 $1,987,500
$1,800,000
100.0%
100.0%
$1,987,500
$1,800,000
Etiwanda Avenue
roadway widening
south of Arrow Rte
Widen 2 to 4 lanes
from Arrow Rte to
Whittram Ave
S 6**
Widen east side of
Etiwanda Ave from
Miller Ave to 850'
north of Miller Ave
Etiwanda Avenue
roadway widening
north of Miller Ave
S 7 1.00 $360,000 100.0% $360,000
Foothill Boulevard - Widen north side of
Hellman Avenue to
700' E/O Hellman
Avenue
Foothill Blvd from
Hellman Ave to 700'
east of Hellman Ave
S 8**
S 9**

0.30 1.00

0.30 $292,500
$1,987,500
$795,000
100.0%
100.0%
100.0%
$292,500
$1,987,500
$795,000
Foothill Boulevard -
Archibald Avenue to from Archibald Ave
Hermosa Avenue
Widen 4 to 6 lanes
to Hermosa Ave
Widen east side of
Grove Ave from 1 to
2 lanes between 9th
St and Tapia Via Dr
Grove Avenue
roadway widening
north of 9th St
S 10**
Widen east side of
Grove Ave from 1 to
roadway widening 2 lanes between San
south of Foothill Blvd Bernardino Rd and
Foothill Blvd
Grove Avenue
S 11**
S 12

1.00 0.30
$292,500 100.0%
100.0%
$292,500
Wilson Avenue
extension west of
Day Creek Blvd
Wilson Ave extension
from Milliken Ave to
Day Creek Blvd
$3,975,000 $3,975,000
Wilson Avenue
extension east of
Etiwanda Ave
Wilson Ave extension
from Etiwanda Ave to
East Ave
S 13 1.00
-
$1,987,500
$825,000
100.0%
100.0%
$1,987,500
$825,000
(Backbone Only)
6th Street at
Pittsburgh AvenueINT 1 New Traffic Signal

6th Street at Santa
Anita AvenueINT 2
INT 3
New Traffic Signal
New Traffic Signal
Roundabout
Roundabout
Roundabout
Roundabout
Roundabout
New Traffic Signal
Roundabout
Roundabout
Roundabout
Roundabout
Roundabout
Roundabout
Roundabout
Roundabout
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
$825,000
$825,000
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
$825,000
$825,000Archibald Avenue at
Victoria Street
Banyan Street at
Rochester AvenueINT 4 $2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$825,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$825,000
Church Street at
Ramona AvenueINT 5
Civic Center Drive at
Red Oak StreetINT 6
Ridgeline Place at
Wilson AvenueINT 7
East Avenue at
Highland AvenueINT 8
Foothill Boulevard at
Malachite AvenueINT 9
Milliken Avenue at
Wilson AvenueINT 10
INT 11
INT 12
INT 13
INT 14
INT 15
INT 16
INT 17
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
$2,250,000
Spruce Avenue at
Mountain View Drive
Spruce Avenue at
Red Oak Street
Terra Vista Parkway
at Spruce Avenue
Terra Vista Parkway
at Town Center Drive
Town Center Drive at
Elm Avenue
Wilson Avenue at
East Avenue
Wilson Avenue at
Etiwanda Avenue

4th Street at Golden
Oak Road - Left Turn
Phasing Upgrade
Traffic signal
modificationINT 18
INT 19
INT 20
T 1
-
-
$55,000
$55,000

29.6%

29.6%
100.0%

29.6%
$16,280
$16,280
Archibald Avenue at
Banyan Street - Left
Turn Phasing
Traffic signal
modification
Upgrade
Citywide traffic signal
communication
improvements
Signal Interconnect
System - $45,000,000
$948,750
$45,000,000
$280,830
Cucamonga Creek
Channel from Base
Line Road to Foothill
Boulevard
Trail improvements 1.1
Cucamonga Creek
Channel at Base Line
Road
Trail crossing
improvementsT 2
T 3
T 4
-
-
-
$825,000
$825,000
$825,000

29.6%

29.6%

29.6%
$244,200
$244,200
$244,200
Cucamonga Creek
Channel at Foothill
Boulevard
Trail crossing
improvements
Cucamonga Creek
Channel at Arrow
Route
Trail crossing
improvements
Cucamonga Creek
Channel at 9th Street
Trail crossing
improvementsT 5
T 6
T 7
T 8
T 9
-
-
-
-
-
$112,500
$825,000
$825,000
$825,000
$825,000

29.6%

29.6%

29.6%

29.6%

29.6%
$33,300
$244,200
$244,200
$244,200
$244,200
Cucamonga Creek
Channel at 6th Street
Trail crossing
improvements
Deer Creek Channel
at Foothill Boulevard
Trail crossing
improvements
Deer Creek Channel
at Arrow Route
Trail crossing
improvements
Deer Creek Channel
at 6th Street
Trail crossing
improvements

Day Creek Channel at
Victoria Park Lane
Trail crossing
improvementsT 10
T 11
-
-
$112,500
$825,000

29.6%

29.6%
$33,300
Day Creek Channel at
Base Line Road
Trail crossing
improvements $244,200
Archibald Avenue
Buffered Bike Lanes
and Ped
Base Line Rd to
Foothill Blvd, Arrow
Rte to 7th St
CRH 4 1.50 $690,000 29.6% $204,240
Enhancements
San Bernardino Road
Stripe Shoulders
Vineyard Ave to
Archibald AveCRH 5
CRH 6
- $122,000
$486,000

29.6%

29.6%
$36,112
Church Street
Buffered Bike Lanes
and Stripe Shoulders
Pepper St to Ramona
Ave 1.10 $143,856
Hermosa Avenue
Buffered Bike Lane
and New Sidewalks
Base Line Rd to
Foothill BlvdCRH 11
CRH 14
E 1

1.00 -
$741,000
$191,000
$3,853,000

29.6%

29.6%

29.6%
$219,336
$56,536Feron Boulevard Ped
Enhancements
Archibald Ave to
Hermosa Ave
Banyan Street Ped
Enhancements and to Wardman Bullock
Deer Creek Channel

3.70 $1,140,488
Buffered Lanes Rd
Day Creek Boulevard
Buffered Bike Lanes Etiwanda Ave to SR-E 2
E 4

2.20 0.50
$1,144,000
$274,000

29.6%

29.6%
$338,624
$81,104
and Ped 210 WB Ramp
Enhancements
Etiwanda Avenue
Bike Route and Ped
Crossing
SR-210 to Banyan St,
Saddleridge Dr to
Victoria StEnhancements
Day Creek Blvd to
Etiwanda Ave,
Wardman Bullock Rd
to Cherry Ave, Wilson
Ave at Bluegrass Ave
Wilson Avenue
Buffered Bike Lane
and Ped Crossing
Enhancements
E 5 1.70 $1,017,000 29.6% $301,032

Victoria Street Ped
EnhancementsE 6
E 7
East Ave and I-15 - $69,000 29.6%

29.6%
$20,424
East Avenue Buffered
Bike Lane and New Banyan St to Philly Dr
Sidewalks

0.40 $1,328,000 $393,088
Base Line Road Ped
and Bike
Enhancements
Wanona Pl to Shelby
PlE 8
E 9

0.27 -
$486,000
$258,000
$987,000
$42,000

29.6%

29.6%

29.6%

29.6%
$143,856
$76,368
$292,152
$12,432
Coyote Dr and
Duncaster Pl,
Stoneview Rd and
Duncaster Pl
Duncaster Place Ped
Enhancements
Etiwanda Creek
Channel Multi-Use PE Trail to Victoria StE 10
E 11

1.80 1.90
Trail
Summit
Intermediate/
Etiwanda Creek Park
Connection
Etiwanda Creek
Parking Lot
Terra Vista Parkway
Ped/Bike
Enhancements
Terra Vista Pkwy to
Hampton PlCNE 1
CNE 2

1.90 -
$1,443,000
$589,000

29.6%

29.6%
$427,128.0
$174,344
Spruce Ave at Terra
Vista Pkwy, Mountain
View Dr, Elm Ave
Spruce Avenue Ped
Enhancements
Base Line Road
Buffered Bike Lane
and Deer Creek Trail
Crossing
Haven Ave to
Etiwanda AveCNE 8
CNE 9

3.00 -
$1,461,000
$49,000

29.6%

29.6%
$432,456
$14,504
Elm Avenue Crossing
Enhancements and
Sidewalk at Coyote
Canyon Elementary
Spruce Ave to
Church St

Church Street
Buffered Bike LanesCNE 10
CNE 11
CNE 13
Mayten Ave to I-15 1.80

1.90 -
$856,000
$688,000
$76,000

29.6%

29.6%

29.6%
$253,376
$203,648
$22,496
Day Creek Boulevard
Buffered Bike Lanes
Highland Ave to
Foothill Blvd
Lark Drive New
Crosswalks
Lark Dr at Rochester
Ave, Matera Pl
Miller Avenue
Buffered Bike Lanes,
Sidewalks and Ped
Enhancements
CNE 14
CNE 15
CSS 2
I-15 to East Ave 0.50

0.60 1.00
$444,000
$212,000
$3,637,000

29.6%

29.6%

29.6%
$131,424
$62,752
Garcia Dr from
Etiwanda Ave toDolcetto Place and
Garcia Drive Buffered Dolcetto Pl, Colcetto
Bike Lanes Pl from Miller Ave to
Garcia Dr
Spruce Avenue and
Red Oak Street
Ped/Bike
Foothill Blvd to
Arrow Rte $1,076,552
Enhancements
6th St Cucamonga
Creek Channel to
Haven Ave
Bicycle Corridor
ImprovementsCRH 15
CCS 3

1.58 0.55
$1,232,400
$429,000

29.6%

29.6%
$364,790
$126,984Jersey Blvd Haven
Ave to Rochester Ave
Bicycle Corridor
Improvements
Foothill Blvd highway
to city centerDTRC 1 Rochester to ECL - $22,250,000 29.6% $6,586,000boulevard transformation
Day Creek Channel
Trail and Park Drive
(Foothill Blvd)
New signalized
crossingDTRC 5
DTRC 6
- $825,000 29.6%

29.6%
$244,200
crossing
Day Creek Channel
Trail
8th St to Future
Etiwanda Heights 3.4 $4,810,000 $1,423,760

Foothill Blvd AT
transformation
Haven Ave to
Rochester AveCC 1 -
-
$109,375,000
$78,125,000

29.6%

29.6%
$32,375,000
$23,125,000Haven Ave AT
transformationCC 1.1 Foothill Blvd to 7th St
Haven Ave to Mayten
Ave (east of Mayten
in Connect RC)
Church St buffered
bike lanesCC 2 1.43 $1,115,400 29.6% $330,158
Arrow Rte buffered
bike lanes
Hermosa Ave to
Rochester AveCC 2.1
CC 2.2

2.23 1.52
$1,739,400
$1,185,600

29.6%

29.6%
$514,862
$350,937Hermosa Ave
buffered bike lanes Foothill Blvd to 6th St
Devon St terminus to
Civic Center Dr
terminus
CC 3 Devon St extension 0.30 $596,250 100.0% $596,250
Rochester Ave
buffered bike lanesHART 2
HART 3
HART 4
Foothill Blvd to 6th St 1.32

1.46 0.88
$1,029,600
$2,901,750
$1,749,000

29.6%
100.0%
100.0%
$304,761
$2,901,750
$1,749,000
Azusa Ct terminus to
Acacia St terminusAzusa Ct extension
7th St extension Milliken Ave to
Haven Ave
Class IV bicycle
corridor and
complete streets
improvements
Foothill Blvd from
Haven Ave to WCLRH 6 -
-
$19,125,000
$9,375,000

29.6%

29.6%
$5,661,000
$2,775,000
Archibald AT
transformation with
buffered bike lanes
CTC 1 7th St to 4th St
9th St extension
(roadway)
Archibald Ave and
Hermosa AveCTC 6
SEIQ 2

0.74 1.25

0.72 $1,470,750
$975,000
$561,600
100.0%

29.6%

29.6%
$1,470,750
$288,600
$166,233
Arrow Rte buffered
bike lanes
Rochester Ave to
Etiwanda Ave
6th St buffered bike Spur line to Etiwanda
lanes AveSEIQ 2.2

Whittram Ave
extension
Etiwanda Ave to
Rochester AveSEIQ 3
SIEQ 6

1.46 $14,803,500 100.0% $14,803,500
Etiwanda Grade
Separation (EGS) - $147,675,000 60.0%*** $88,605,000
Total Program Costs: $587,872,000 $327,090,000
* Quantity of improved facilities in miles, or lane miles for roadways. ** Program Contribution cost shown for this project is the amount before deduction for deficiencies calculated and shown in Table 8 and deducted from DIF Program Contribution in Table 14.
*** Final project cost contribution by future development reduced by 40% in anticipation of future grant funding opportunities.

Appendix D
General Plan Level Of Service Assessment and Forecasting

DRAFT MEMORANDUM
Date:

To:

May 7, 2021
Jason Welday, City of Rancho Cucamonga
From: Jason Pack, P.E.

Delia Votsch, P.E.

Subject: City of Rancho Cucamonga General Plan Update – Roadway Level of Service OC21-0776
As part of the ongoing City of Rancho Cucamonga General Plan Update, Fehr & Peers has prepared roadway segment forecasts and have calculated the Level of Service (LOS) for those roadway segments. This memorandum presents those forecasts and LOS results. This information is integrated in the General Plan Environmental Impact Report air quality and noise analyses, however, is summarized here for City staff.

Roadway capacities used to evaluate roadway segments were developed in consultation with the City of Rancho Cucamonga staff, referencing HCM 6th edition.

Table 1: Roadway Level of Service Criteria
Roadway Type
2-Lane Collector
2-Lane Arterial
2-Lane Freeway
4-Lane Collector
LOS C
10,000
9,700
LOS D
13,000
17,600
35,700
20,200
LOS E
15,000
18,700
40,100
23,200
28,800
18,000
4-Lane Arterial, Undivided
4-Lane Arterial Bicycle Corridor 17,500 27,400 28,900
4-Lane Arterial, Divided
6-Lane Arterial, Divided
19,200
27,100
35,400
53,200
37,400
56,000
6-Lane Arterial, Divided
4-Lane Freeway
27,100
59,500
53,200
72,800
56,000
81,400
Source: Highway Capacity Manual 6 th Edition (Transportation Research Board, 2017), Fehr & Peers, 2021. 101 Pacifica | Suite 300 | Irvine, CA 92618 | (949) 308-6300 | Fax (949) 859-3209 www.fehrandpeers.com

Jason Welday
May 7, 2021

The roadway typologies presented in the Mobility Element of the proposed General Plan Update align with the roadway capacities presented in Table 1 as follows:

Freeways, which are under the juridiction of and operated by Caltrans, provide for interregional travel by automobile. They have high vehicle speeds and can provide access for transit vehicles (athough automobiles are prioritized). Bicycles and pedestrians are prohibited on freeways. Freeways in Rancho Cucamonga include SR-210 and I-15. Freeways have the roadway capacities of 2-Lane Freeway and 4-Lane Freeway Arterials provide for all modes of travel, but they acknowledge that the arterial is a primary link in the City’s vehicular transportation system. Oftentimes four to six lanes are provided with raised medians and higher vehicle speeds are anticipated. Arterials have the roadway capacities of 2-Lane Arterial, 4-Lane Arterial Undivided, 4-Lane Arterial Divided, 6-Lane Arterial Divided and 8-Lane Arterial Divided. Undivided arterials have no median (raised or striped), while divided arterials have a center median.

Transit corridors, including light rail (LRT), streetcar, and bus rapid transit (BRT), promote economic development around high-quality transit service while fostering a pedestrian scale in which walking, and biking actively complement public transit. Transit corridors have the roadway capacities of 4-Lane Arterial Divided, 6-Lane Arterial Divided and 8-Lane Arterial Divided.

Collectors are intended to connect neighborhoods together. They should provide accessibility for bicycles, pedestrians, and vehicles; however, speeds should be managed to ensure that all modes safely travel together. These corridors can substantially vary in terms of width. For example, Church Street is a four-lane roadway and would include bicycle lanes as well as raised medians. In contrast, segments such as Banyan Street, are similar to local streets with smaller rights-of-way. These narrower streets would have Class III ‘sharrows’ as well as street furniture in some areas to encourage pedestrian activity. Collectors have the roadway capacites of 2-Lane Collector and 4-Lane Collector.

Bicycle Corridors provide the main bicycle network for the City. Specifically, vehicle speeds should be managed to travel at 35 miles per hour or less and bicycle infrastructure should be maximized. This would typically include buffered bicycle lanes or separated bicycle lanes (otherwise known as a cycle track or Class IV bicycle facility) on the roadway (or, at a minimum, seven-foot bicycle lanes). Separation can be provided by plastic bollards, raised medians, and/or planters. Raised landscaped medians may also be included in some areas to further encourage slower speeds. Bicycle corridors have the roadway capacites of 2-Lane Collector and 4-Lane Collector.

Future year forecasts representing the buildout of the General Plan Update in 2040 were prepared for the EIR using the SBTAM model. Level of service with the buildout of the proposed General Plan Update are presented below in Table 2.

Jason Welday
May 7, 2021

Table 2: General Plan Roadway Level of Service
Existing
ADT
General PlanExisting
Typology
General Plan
TypologyRoadway Segment
Lanes V/C LOS Lanes ADT V/C LOS

1. Wilson Ave from Carnelian St to Archibald Ave

2. Wilson Ave from Archibald Ave to Haven Ave

3. Wilson Ave from Haven Ave to Milliken Ave

4. Wilson Ave from Milliken Ave to Etiwanda Ave

5. Wilson Ave from Etiwanda Ave to City Limits

6. Banyan St from Carnelian St to Archibald Ave

7. Banyan St from Archibald Ave to Haven Ave

8. Banyan St from Haven Ave to Milliken Ave

9. Banyan St from Milliken Ave to Etiwanda Ave

10. Banyan St from Etiwanda Ave to Wardman Bollock Rd

11. 19th St from Carnelian St to Archibald Ave

12. 19th St from Archibald Ave to Haven Ave
Arterial
Arterial
Arterial
Arterial
4 4
2 4
--
2 2
2 2
2 4
4 4,740
5,190
7,860
2,090
--

0.16 0.18

0.42 0.07
--
A
A
A
A
--
A
A
B
4 4
2 4
4 2
2 2
2 2
4 4
7,520
8,660

0.26 0.30

0.63 0.10

0.44 0.26

0.27 0.83

0.82 0.70

0.73 0.68
A
A
BArterial Arterial 11,770
3,030Arterial Arterial A
A
A
A
D
D
B
Arterial Arterial 12,730
3,870Collector
Collector
Collector
Collector
Collector
Arterial
Collector
Collector
Collector
Collector
Collector
Bicycle Corridor
Bicycle Corridor
3,470
3,900
9,690
10,530
8,210
17,050
15,630

0.23 0.26

0.65 0.70

0.55 0.59

0.54 4,050
12,480
12,340
10,550
21,260
19,700
B
A
A
A
C
BArterial

13. Base Line Rd from Carnelian St to Archibald Ave Arterial Bicycle Corridor 4 22,550 0.78 C 4 26,700 0.92 E

14. Base Line Rd from Archibald Ave to Haven Ave

15. Base Line Rd from Haven Ave to Milliken Ave

16. Base Line Rd from Milliken Ave to Etiwanda Ave

17. Church St west of Archibald Ave
Arterial
Arterial
Arterial
Collector
Arterial
Arterial
4 6
6 2
21,140
25,150
22,780
5,370

0.73 0.45

0.41 0.36
C
A
A
A
4 6
6 2
25,330
33,440
35,570
6,520

0.88 0.60

0.64 0.43
D
A
BArterial
Bicycle Corridor A

Jason Welday
May 7, 2021

Existing General PlanExisting
Typology
General Plan
TypologyRoadway Segment
Lanes ADT
9,060
V/C

0.48 0.45

0.51 0.50

0.26 LOS
A
Lanes ADT
13,810
22,740
24,310
20,020
12,610
V/C

0.92 0.79

0.85 0.69

0.44 LOS
E18. Church St from Archibald Ave to Haven Ave

19. Church St from Haven Ave to Milliken Ave

20. Church St from Milliken Ave to Day Creek Blvd

21. Church St from Day Creek Blvd to Etiwanda Ave

22. Church St from Etiwanda Ave to East Ave
Arterial
Arterial
Arterial
Arterial
Arterial
Bicycle Corridor
Bicycle Corridor
Bicycle Corridor
Bicycle Corridor
Bicycle Corridor
2 4
4 4
4 2
4 4
4 4
16,730
19,240
14,520
9,780
A C
A D
A B
A A

23. Foothill Blvd from City Limits to Carnelian St/Vineyard Ave Arterial
Arterial
Transit Corridor
Transit Corridor
6 4
32,820
31,300

0.59 0.84
A
D
6 6
39,400
47,410

0.70 0.85
B

24. Foothill Blvd from Carnelian St/Vineyard Ave to
Archibald Ave D

25. Foothill Blvd from Archibald Ave to Haven Ave

26. Foothill Blvd from Haven Ave to Milliken Ave

27. Foothill Blvd from Milliken Ave to Day Creek Blvd

28. Foothill Blvd from Day Creek Blvd to Etiwanda Ave

29. Foothill Blvd from Etiwanda Ave to City Limits

30. Arrow Rte from City Limits to Vineyard Ave
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Transit Corridor
Transit Corridor
Transit Corridor
Transit Corridor
Transit Corridor
Arterial
4 6
6 6
4 4
32,420
38,140
37,330
45,190
34,430
19,710

0.87 0.68

0.67 0.81

0.92 0.68
D
B
B
C
E
6 6
6 6
4 4
43,020
47,010
51,820
56,580
39,570
25,250

0.77 0.84

0.93 1.01

1.06 C
D
E
F
F
B 0.68

0.72 0.95

0.84 B
C
E

31. Arrow Rte from Vineyard Ave to Archibald Ave

32. Arrow Rte from Archibald Ave to Haven Ave

33. Arrow Rte from Haven Ave to Milliken Ave
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
4 4
4 22,570
26,340
24,300

0.78 0.91

0.84 C
E
4 4
4 26,850
35,500
31,520D D

Jason Welday
May 7, 2021

Existing
ADT
General PlanExisting
Typology
General Plan
TypologyRoadway Segment
Lanes V/C

1.34 1.08

0.59 LOS Lanes ADT
35,670
30,410
13,640

V/C LOS
Varies
from 4 to
2 34. Arrow Rte from Milliken Ave to Etiwanda Ave

35. Arrow Rte from Etiwanda Ave to City Limits

36. 6th St from City Limits to Archibald Ave
Arterial
Arterial
Arterial
Arterial
Arterial
25,000
20,140
10,940
F
F
4 4
4 0.95

0.81 0.47
E
D
A
3 Varies
from 4 to
2 Bicycle Corridor A
Varies
from 4 to
3 37. 6th St from Archibald Ave to Haven Ave Arterial Bicycle Corridor 15,080 0.81 C 4 19,190 0.66 B

38. 6th St from Haven Ave to Milliken Ave

39. 6th St from Milliken Ave to Etiwanda Ave
Arterial
Arterial
Bicycle Corridor
Bicycle Corridor
4 4
14,860
13,870

0.40 0.37
A
A
4 4
22,000
18,590

0.76 0.64
C
B
Varies
from 6 to
5 40. 4th St from Archibald Ave to Haven Ave

41. 4th St from Haven Ave to Milliken Ave

42. 4th St from Milliken Ave to Etiwanda Ave
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
17,780
26,570
32,760

0.48 0.47

0.88 A
A
D
4 6
6 23,270
36,960
36,810

0.62 0.66

0.65 B
B
B
7 Varies
from 6 to
4 43. Vineyard Ave from City Limits to Arrow Rte

44. Vineyard Ave from Arrow Rte to Foothill Blvd
Arterial
Arterial
Bicycle Corridor
Bicycle Corridor
4 4
25,820
25,160

0.89 0.87
D
D
4 4
31,350
31,440

1.08 1.09
F
F

45. Vineyard Ave/Carnelian St from Foothill Blvd to
Base Line Rd Arterial Bicycle Corridor 4 29,200 1.01 F 4 33,330 1.15 F

Jason Welday
May 7, 2021

Existing General PlanExisting
Typology
General Plan
TypologyRoadway Segment
Lanes ADT V/C LOS Lanes ADT V/C LOS

46. Carnelian St from Base Line Rd to 19th St Arterial Bicycle Corridor 4 24,790 0.86 D 4 28,060 0.97 E Varies
from 4 to
2 47. Carnelian St from 19th St to Wilson Ave Collector Collector 24,260 1.62 F 4 24,400 1.05 F

48. Archibald Ave from 4th St to 6th St

49. Archibald Ave from 6th St to Arrow Rte

50. Archibald Ave from Arrow Rte to Foothill Blvd

51. Archibald Ave from Foothill Blvd to Base Line Rd

52. Archibald Ave from Base Line Rd to 19th St

53. Archibald Ave from 19th St to Wilson Ave

54. Haven Ave from 4th St to 6th St
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
4 4
4 4
4 4
6 6
6 6
6 6
6 6
33,530
29,870
24,830
25,830
23,140
13,080
48,250
47,260
37,950
33,630
33,640
36,080
38,480
36,330

1.16 1.03

0.86 0.89

0.80 0.45

0.86 0.84

0.68 0.60

0.60 0.64

0.69 0.65
F
F
4 4
4 4
4 4
6 6
6 6
6 6
6 6
41,990
37,010
31,910
30,130
25,070
13,190
56,660
59,790
44,730
38,950
38,890
38,230
50,800
41,420

1.45 1.28

1.10 1.04

0.87 0.46

1.01 1.07

0.80 0.70

0.69 0.68

0.91 0.74
F
F
Arterial D
D
C
A
D
D
B
A
A
B
B
B
F
Arterial F
Arterial D
A
F
Arterial
Transit Corridor
Transit Corridor
Transit Corridor
Transit Corridor
Transit Corridor
Transit Corridor
Arterial

55. Haven Ave from 6th St to Arrow Rte

56. Haven Ave from Arrow Rte to Foothill Blvd

57. Haven Ave from Foothill Blvd to Base Line Rd

58. Haven Ave from Base Line Rd to 19th St

59. Haven Ave from 19th St to Wilson Ave

60. Milliken Ave from 4th St to 6th St
F
C
B
B
B
D
C61. Milliken Ave from 6th St to Arrow Rte Arterial

Jason Welday
May 7, 2021

Existing
ADT
General PlanExisting
Typology
General Plan
TypologyRoadway Segment
Lanes V/C LOS Lanes ADT V/C LOS
Varies
from 7 to
6 62. Milliken Ave from Arrow Rte to Foothill Blvd

63. Milliken Ave from Foothill Blvd to Base Line Rd

64. Milliken Ave from Base Line Rd to Wilson Ave

65. Day Creek Blvd from Foothill Blvd to Base Line Rd
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
Arterial
30,370
24,310
17,150
21,030

0.54 A 6 38,950 0.70 B
Varies
from 7 to
6 0.43

0.46 0.38
A
A
A
6 4
4 34,360
20,810
25,190

0.61 0.56

0.67 B
A
B
Varies
from 6 to
2 Varies
from 7 to
6 Varies
from 6 to
4 66. Day Creek Blvd from Base Line Rd to Banyan St

67. Etiwanda Ave from 4th St to 6th St
Arterial
Arterial
Arterial
Arterial
Arterial
Collector
Arterial
Arterial
Arterial
Arterial
Arterial
21,500
31,410
22,790
22,580
11,720
7,340

0.57 1.09

1.22 0.78

0.63 0.49
A
F
4 4
4 4
4 2
26,510
45,550
36,940
31,530
22,790
11,400

0.71 1.58

1.28 1.09

0.79 0.76
B
F
F
F
C
C
4 Varies
from 4 to
2 68. Etiwanda Ave from 6th St to Arrow Rte

69. Etiwanda Ave from Arrow Rte to Foothill Blvd

70. Etiwanda Ave from Foothill Blvd to Base Line Rd

71. Etiwanda Ave from Base Line Rd to Wilson Ave
F
4 C
B
A
Varies
from 4 to
2 Collector 2

Jason Welday
May 7, 2021

Existing
ADT
General Plan

ADT V/C
Existing
Typology
General Plan
TypologyRoadway Segment
Lanes V/C LOS Lanes LOS
Source: Highway Capacity Manual 6 th Edition (Transportation Research Board, 2017), Fehr & Peers, 2021.

Notes:

1. Roadways operating above capacity at LOS F are shown in bold.

2. Roadways with varying number of lanes across a segment are shown with the V/C ratio and LOS reflecting the capacity at the narrowest point of the roadway.

3. Roadways with an odd number of lanes are shown with the V/C ratio and LOS reflecting the capacity at the closest capacity. For example, roadways with 3 lanes are shown as having the capacity of a 2-lane roadway of that classification.

4. Italics indicates roadways where lane reductions could be considered.

Jason Welday
May 7, 2021

Roadway segments projected to have 20,000 ADT or less and are 4 lanes would be considered good candidates to consider for future road diets. Candidates for road diets would be:
• Wilson Avenue between Carnelian Street and Haven Avenue, and between Milliken Avenue and City Limits (note: Wilson Avenue is 2 lanes between Haven Avenue and Milliken Avenue).

Church Street from Etiwanda Avenue to East Avenue
6th Street from City limits to Haven Avenue
Archibald Avenue from 19th Street to Wilson Avenue
•
•
•
If you have any questions, please contact us at 949-308-6300.

Exhibit "B"
FY2024/25 Major Projects
Program Supplemental Project
Listing
ATTACHMENT 3
Activities
During Estimated Expenditures
Project Plan Period FY2024/25 FY2025/26 FY2026/27 FY2027/28 FY2028/29 FY2029/30 Transportation Impact Fee (124)
6th Street at BNSF Spur Crossing
Adv Traffic Mgmt System - Phase 2
Adv Traffic Mgmt System Program
Etiwanda East Side Widening
Etiwanda Creek Bridges Project
Whittram Extension - W/O Etiwanda
Wilson & Day Creek Channel Bridge
Wilson Extension W/O Day Creek Blvd
D, C
D, C
D, C
D, C
D, C
DEV
DEV
DEV
$46,600
$9,754,260
$302,500 $165,000
$5,000,000
$12,000,000
$403,500
$500,000
$1,370,000
$1,200,000
$5,000,000 $5,000,000
$5,000,000
$5,000,000
$15,000,000
$20,000,000
$4,300,000
$4,500,000
$14,203,500Totals $9,800,860 $3,372,500 $17,165,000

Exhibit "C"
Admin. Fee

2.5%
Residential, Single Family Detached SF $4.05 $0.101 $4.151 Residential, Single Family Detached - HQTA SF $2.84 $0.071 $2.911 Residential, Single Family Attached SF $4.55 $0.114 $4.664 Residential, Single Family Attached - HQTA SF $3.19 $0.080 $3.270 Residential, Multi-Family (Low-Rise) SF $4.26 $0.107 $4.367 Residential, Multi-Family (Low-Rise) - HQTA SF $2.98 $0.075 $3.055 Residential, Multi-Family (Mid-Rise) SF $2.87 $0.072 $2.942 Residential, Multi-Family (Mid-Rise) - HQTA SF $2.01 $0.050 $2.060 Senior Housing Bed $4,626.00 $115.650 $4,741.650
Nursing/Congregate Care Bed $2,372.00 $59.300 $2,431.300 Commercial/Retail KSF $19,466.00 $486.650 $19,952.650
Office/Business Park KSF $11,636.00 $290.900 $11,926.900 Industrial KSF $5,227.00 $130.675 $5,357.675
Warehouse KSF $6,913.00 $172.825 $7,085.825
Hotel/Motel Room $8,576.00 $214.400 $8,790.400
Elementary School Student $2,437.00 $60.925 $2,497.925
Day Care Student $4,390.00 $109.750 $4,499.750
Self-Storage KSF $1,556.00 $38.900 $1,594.900
Service Station Pump $90,471.00 $2,261.775 $92,732.775
Notes
Fees established by this resolution shall be adjusted annually, commencing on July 1, 2026, and each year thereafter, without further action of the City Council according to the percentage change in the Engineering News Record Construction Cost Index for the Los Angeles Area, for the 12-month period ending on December 31st of the immediately preceding year. If the Engineering News Record Construction Cost Index for the Los Angeles Area is discontinued, the replacement index in use and accepted as the industry and business standard for Souther California, as determined by the City Engineer, shall be used.

HQTA - High Quality Transit Area
Transportation - North Zone
Development Type Unit
Impact Fee
(Nexus Study)
Total Impact
Fee
ATTACHMENT 4

Exhibit "C"
Admin. Fee

2.5%
Residential, Single Family Detached SF $5.88 $0.147 $6.027 Residential, Single Family Detached - HQTA SF $4.12 $0.103 $4.223 Residential, Single Family Attached SF $6.61 $0.165 $6.775 Residential, Single Family Attached - HQTA SF $4.63 $0.116 $4.746 Residential, Multi-Family (Low-Rise) SF $6.18 $0.155 $6.335 Residential, Multi-Family (Low-Rise) - HQTA SF $4.33 $0.108 $4.438 Residential, Multi-Family (Mid-Rise) SF $4.17 $0.104 $4.274 Residential, Multi-Family (Mid-Rise) - HQTA SF $2.92 $0.073 $2.993 Senior Housing Bed $6,722.00 $168.050 $6,890.050
Nursing/Congregate Care Bed $3,447.00 $86.175 $3,533.175 Commercial/Retail KSF $28,284.00 $707.100 $28,991.100
Office/Business Park KSF $16,907.00 $422.675 $17,329.675 Industrial KSF $7,596.00 $189.900 $7,785.900
Warehouse KSF $10,044.00 $251.100 $10,295.100
Hotel/Motel Room $12,462.00 $311.550 $12,773.550
Elementary School Student $3,540.00 $88.500 $3,628.500
Day Care Student $6,379.00 $159.475 $6,538.475
Self-Storage KSF $2,262.00 $56.550 $2,318.550
Service Station Pump $131,457.00 $3,286.425 $134,743.425 Notes
Fees established by this resolution shall be adjusted annually, commencing on July 1, 2026, and each year thereafter, without further action of the City Council according to the percentage change in the Engineering News Record Construction Cost Index for the Los Angeles Area, for the 12-month period ending on December 31st of the immediately preceding year. If the Engineering News Record Construction Cost Index for the Los Angeles Area is discontinued, the replacement index in use and accepted as the industry and business standard for Souther California, as determined by the City Engineer, shall be used.

HQTA - High Quality Transit Area
Transportation - Central Zone
Development Type Unit
Impact Fee
(Nexus Study)
Total Impact
Fee

Exhibit "C"
Admin. Fee

2.5%
Residential, Single Family Detached SF $5.36 $0.134 $5.494 Residential, Single Family Detached - HQTA SF $3.75 $0.094 $3.844 Residential, Single Family Attached SF $6.02 $0.151 $6.171 Residential, Single Family Attached - HQTA SF $4.21 $0.105 $4.315 Residential, Multi-Family (Low-Rise) SF $5.64 $0.141 $5.781 Residential, Multi-Family (Low-Rise) - HQTA SF $3.95 $0.099 $4.049 Residential, Multi-Family (Mid-Rise) SF $3.80 $0.095 $3.895 Residential, Multi-Family (Mid-Rise) - HQTA SF $2.66 $0.067 $2.727 Senior Housing Bed $6,127.00 $153.175 $6,280.175
Nursing/Congregate Care Bed $3,142.00 $78.550 $3,220.550 Commercial/Retail KSF $25,782.00 $644.550 $26,426.550
Office/Business Park KSF $15,411.00 $385.275 $15,796.275 Industrial KSF $6,924.00 $173.100 $7,097.100
Warehouse KSF $9,156.00 $228.900 $9,384.900
Hotel/Motel Room $11,359.00 $283.975 $11,642.975
Elementary School Student $3,227.00 $80.675 $3,307.675
Day Care Student $5,815.00 $145.375 $5,960.375
Self-Storage KSF $2,061.00 $51.525 $2,112.525
Service Station Pump $119,826.00 $2,995.650 $122,821.650 Notes
Fees established by this resolution shall be adjusted annually, commencing on July 1, 2026, and each year thereafter, without further action of the City Council according to the percentage change in the Engineering News Record Construction Cost Index for the Los Angeles Area, for the 12-month period ending on December 31st of the immediately preceding year. If the Engineering News Record Construction Cost Index for the Los Angeles Area is discontinued, the replacement index in use and accepted as the industry and business standard for Souther California, as determined by the City Engineer, shall be used.

HQTA - High Quality Transit Area
Transportation - South Zone
Development Type Unit
Impact Fee
(Nexus Study)
Total Impact
Fee

On Thursday February 27, 2025, the City released drafts of the nexus studies prepared by NBS (Non-Transportation DIFs) and Fehr & Peers (Transportation DIF), proposed fee schedules for each DIF program, and the proposed Major Projects Program (CIP) amendment for the DIF programs as part of the 2025 Development Impact Fee (DIF) Program update process. In addition to statutory noticing in the Daily Bulletin, parties that had requested notification of fee updates were notified of the availability of the released drafts. During the April 2, 2025 public hearing on the DIFs, consideration of the Transportation DIF was continued to May 7, 2025 to allow for additional time to address questions and comments from stakeholders.

The City has received letters from the following interested parties:
•Desert Valley Builders Association dated (Non-Transportation) March 13, 2025 (DVBA- NT)
•Desert Valley Builders Association (Transportation) dated March 13, 2025 (DVBA-T) •Building Industry Association of Southern California dated March 17, 2025 (BIA) •Development Planning & Finance Group (Non-Transportation) dated March 17, 2025 (DFPG-NT)
•Development Planning & Finance Group (Transportation) dated March 17, 2025 (DPFG-T)
•LLG Engineers dated March 17, 2025 (LLG)
The comment letters designated DPFG-NT, DPFT-T, and LLG were submitted on behalf of the BIA. This memorandum provides a response to the comments and questions raised in these letters related to the Transportation DIF. The Non-Transportation related comments were addressed in the staff report and comment response memo for the April 16, 2025 public hearing on those DIFs. Since several topics overlap between the comment letters, staff has grouped comments into categories to aid in providing a clear and concise response.

DATE: May 7, 2025
TO: John R. Gillison, City Manager
FROM: Matthew R. Burris, Deputy City Manager – Community Development BY: Jason C. Welday, Director of Engineering Services/City Engineer Zack Neighbors, Director of Building and Safety
SUBJECT: 2025 TRANSPORTATION DEVELOPMENT IMPACT FEE PROGRAM

UPDATE COMMENT LETTERS FROM BUILDING INDUSTRY OF
SOUTHERN CALIFORNIA; DESERT VALLEY BUILDERS ASSOCIATION; DEVELOPMENT PLANNING AND FINANCE GROUP; AND LLG

ENGINEERS

MEMORANDUM
Community Development
ATTACHMENT 5

Transportation DIF
Request to Evaluate Existing Level of Service for Existing Facilities as Required by AB 602 (BIA; LLG)
The commentor suggests that the Fehr & Peers nexus study has not satisfied the requirement of AB 602 to evaluate the level of service for existing facilities to determine that the proposed new level of service is appropriate. Further, a second commentor specifically identifies bridge widening, traffic signals, and roundabout improvements as requiring Level of Service analysis.

However, the nexus study has satisfied the referenced requirement of AB 602 through the inclusion of data such as the existing Transportation DIF program (Resolution No. 20-122), a comparison of facility needs benchmarked to current population (e.g., roadway lane miles per person, length of trails per person, bike lane miles per person, etc.), and references to analysis performed in recent planning documents such as PlanRC (including the Memorandum dated May 7, 2021 by Fehr & Peers entitled City of Rancho Cucamonga General Plan Update – Roadway Level of Service on file with the City Engineer and included as an appendix in the revised nexus study dated April 30, 2025), ConnectRC, and the capital improvement programs that address existing infrastructure capacity and future needs. Further, it should be noted that Government Code Section 66016.5(a)(2) includes the phrase “when applicable”. This is important as the law references circumstances and components of fee programs not tied to capacity improvement such as Vehicle Miles Traveled (VMT) reduction improvements required by PlanRC and the Climate Action Plan and which are proportionately applicable to new development. Further, existing Level of Service deficiencies identified in May 7, 2021 Fehr & Peers memorandum, the City’s Southeast Industrial Quadrant Study, the previous nexus study, and various traffic studies completed by the City have been listed and costs associated with such deficiencies have been incorporated into the nexus study (e.g., see Table 8).

Request to Provide the Proposed CIP Amendment for All Projects Listed in the Fehr & Peers Study (BIA)
The commentor notes the requirements of AB 602 related to adoption of a Capital Improvement Program (CIP) with any DIF updates and is requesting a copy of the proposed CIP for all projects listed in the Fehr & Peers nexus study. The proposed CIP for the next 5-year cycle was posted along with the draft nexus studies and fee schedules on the City’s website on Thursday, February 27, 2025 and interested parties who had requested notification were notified of its availability. here is no requirement in State law to prepare a comprehensive multi-decade plan. Further, it would be speculative to project development cycles, revenue levels, and timing of construction for the program with any level of certainty. Furthermore, the Terner Center publication “Nexus Study and Residential Feasibility Calculation Templates in fulfillment of AB 602” supports the use of a 5-year CIP for nexus studies. Therefore, standard practice for local agencies is to project out five years for a CIP. Therefore, no additional CIP data is necessary to meet the requirements of the statute or standard practice.

Request for an Explanation for the Reliance on VMT as an Appropriate Metric for the Transportation DIF Nexus Study (BIA; LLG)
The commentor suggests that VMT is not a recognized metric for use in impact fee analysis but is more appropriate for analyzing greenhouse gas and other environmental impacts. A second commentor provided a similar comment related to applicability of VMT and specifically seeks to limit the contribution of new development to 0.1% of the program cost. We fundamentally disagree

on this point based on changes in State law relating to analysis of transportation related environment impacts (e.g., SB 743), use of the metric by other public agencies, and the practical effects that VMT introduced (or needing to be reduced) by development has on the need for new transportation infrastructure. There is no authority prohibiting the use of VMT as a metric for an impact fee analysis. A nexus study is required to establish a reasonable relationship between the improvements identified and the need for those improvements. PlanRC and the Climate Action Plan establish clear goals related to reducing greenhouse gas emissions which rely extensively on VMT reducing measures. As such, the DIF improvements related to VMT reducing measures are established using a VMT nexus based on the goals and policies of the general plan. This is consistent with other VMT-based nexus studies like the City of Orange nexus study and the Westside DIF in Los Angeles County. As well, as noted in the response above, the facility need based on capacity is only required, if the nexus is tied to a capacity issue. Since the VMT-based nexus is established through the adopted GHG reduction targets in PlanRC and Climate Action Plan, the capacity component of the nexus is not applicable. With respect to the comment seeking to limit the proportional share of the VMT-reducing improvements to 0.1%, the commentor has misunderstood the 0.1% listed in Table 12 of the nexus study (Fehr & Peers, 2025, p. 23). This percentage represents the balance of VMT reduction with the implementation of the projects included in the nexus study and not the proportional share of new development’s impact as discussed earlier in this paragraph. Finally, as outlined in the nexus study, new development is only responsible for its fair share of the VMT-reduction associated with new development as there is an existing deficiency, and the improvements will reduce VMT across the City.

Request to Remove the Zonal Approach to Assessing Fees Based on Estimated Trips Between Zones (BIA; DPFG-T)
The commentor suggests that assessing fees based on a zonal approach creates an unfair burden on the central and south zones. Further, the commentor implies that if a zonal approach is taken, the area east of I-15 should be separated into a separate zone. It should be noted that the zonal approach was requested by the BIA during conversations after the release of the prior draft nexus studies in October, 2024. Upon review of the comment from the BIA, staff agreed that a zonal approach is appropriate and revised the nexus study accordingly The zonal approach was developed to provide a more localized and accurate rough proportionality and reasonable relationship between the development and the facility needs. Applying the zonal approach ensures that local development within each zone bears the burden for provision of new infrastructure in proportion to the likely benefit from or impact facilities based on the geographic relationship between the development and facilities. The determination to utilize three zones as proposed was made with significant modeling and analysis by Fehr & Peers and the City Engineer’s staff to identify transportation sheds utilizing recognized major transportation corridors.

The selected zones align with the predominant east-west traffic patterns in the City and region as found in the countywide travel demand model and the SBCTA Travel Trends Community Profile for Rancho Cucamonga prepared by Fehr & Peers in 2022. Further, the analysis was performed in a manner that provides a distribution of cost between zones based on travel between the three zones to ensure that all new development is assessed its proportional share of costs for projects within the program. Staff met with BIA representatives as the approach was developed to share the proposed zones and did not receive any comments at that time. This approach establishes a more localized nexus than a citywide approach and achieves a heightened reasonable relationship. Further, it should be noted that while the central and southern zones bear a larger proportion of the program cost, this is a result of the majority of the program’s planned infrastructure being located within these zones to address the intensified and increased

development in these areas as outlined in PlanRC. With respect to the implied request for a fourth zone east of I-15, this approach is not recommended as it presumes that limited or no traffic crosses the I-15 freeway within the southern zone. Since the freeway does not serve as a fixed barrier to traffic, but rather is part of the overall transportation system, it is likely that trips will be made to and from this area within the zone as well as outside of the zone to serve not only industrial land uses but also residential and commercial uses (e.g., Foothill Marketplace, and residential developments along Foothill Boulevard and Arrow Route east of I-15) that currently exist or will be developed in the future. Finally, during discussions on this request with the BIA, a statement was made with respect to increasing costs for affordable housing development through the zonal approach since most of the new development will be in the central and south zones.

Staff reviewed this concern and determined that the nexus study and state law address this matter through fee reductions for eligible projects. Shifting costs from these zones to pre-emptively reduce the burden for affordable housing would be speculative as to the location and volume of such housing and would potentially shift the burden onto new development in other parts of the city violating the nexus and proportionality requirements of the Mitigation Fee Act. Therefore, staff does not recommend making such a change but rather considers the provisions for affordable housing in state law and the nexus study to sufficiently address this concern.Request for Explanation of Project Cost Estimates in Appendix C of the Fehr & Peers Study (BIA; DPFG-T; LLG)
The commentors states that the costs in Appendix C used to develop the program costs are inconsistent and inflated over documents referenced in the nexus study. Another commentor questions the veracity of the estimated cost of $750,000 for a traffic signal. Table 1, Note 1 of the nexus study states that the unit cost estimates listed do not reflect other costs associated with the project (contingency, environmental clearance, etc.) which can vary based on complexity, location, and type of the project. As such, the unit costs have been applied correctly but the total costs included in Appendix C have incorporated these other project cost components to capture the estimated total project cost. In the April 30, 2025 revision to the nexus study, a table has been provided that clarifies the assumptions made in estimating project costs with respect to contingency, environmental clearance, design, construction management and inspection, etc.

Further, where staff had more refined cost estimates, such as for projects already in the process of design or construction, these refined costs estimates were utilized to more accurately reflect anticipated program costs. One such type of more refined cost estimate is for traffic signals. While each location is different, the cost for construction of traffic signals in general has increased significantly in the past. The City’s most recent traffic signal for a 3-legged intersection on Foothill Boulevard received a construction bid of $650,000 which is generally similar in scope has 25% fewer approaches than the typical traffic signal in the program and thus slightly understates the anticipated construction costs. When design, inspection, management, and other costs are conservatively accounted for, the estimated cost is nearly $850,000, therefore it is reasonable to estimate future traffic signals will cost at least $750,000 in the nexus study.

Request to Reduce the Transportation DIF Program Cost Using Funding from the EIFD (BIA; DPFG-T; LLG)
The commentor is requesting that the program cost for the Transportation DIF be reduced based on funding generated through the City’s Enhanced Infrastructure Financing District (EIFD). The EIFD was formed in 2022 to provide enhanced infrastructure needed to serve future residents and businesses in the central area of the city. Based on the funding plan adopted for the EIFD, infrastructure included under the proposed DIFs would be ineligible to be funded from the district’s

proceeds as the funding is set aside solely for specific transit and parking related infrastructure which does not include the projects listed in the nexus study and CIP. Furthermore, the EIFD is not city-wide, includes only certain parcels, and was never expanded to add in the County. As a result, funds are extremely limited, currently are significantly under the original projects, and looking ahead at, an evaluation current funding capacity for the EIFD indicates that expansion of the planned list of eligible projects is infeasible to cover the requested offset of DIF Program costs.

Request to Consider Funding Sources Identified in ConnectRC When Calculating the Transportation DIF (BIA)
The commentor is requesting that the City consider possible funding sources identified in ConnectRC to reduce the fees assessed under the Transportation DIF Program. While this plan does include a list of potential State and Federal funding sources that may be able to fund certain active transportation projects within the Transportation DIF Program, without secured grant awards, the City cannot rely upon these funds to reduce the program cost. Additionally, since the fee program only funds 29.6% of the total project cost, these outside funding sources will be needed to fund the remaining 70.4% of the project cost. Assuming award of non-guaranteed, competitive grant funding from a future grant cycle that has not been applied for and most certainly is not secured, and applying such funding toward new development’s share of project costs, would be an abuse of the City’s fiduciary role and result in providing an inappropriate subsidy by existing development. The proposed approach to allocating future grant funding was addressed in the nexus study as follows:

Finally, the City seeks to defray the cost of construction for public infrastructure through alternative means such as grant programs. The City proactively pursues grants and other funding mechanisms; however, the City does not have the ability to guarantee a certain percentage of grant awards toward projects within this DIF program. In order to ensure that new development funds its fair share of the improvements in this program, applicable grant awards will be first used to offset the appropriate project cost share attributable to existing development and then remaining grant awards (if any) will be used to offset the cost borne by the fee program unless the grant award is specifically made to offset new development costs. Should new development costs be offset by grant or other funding mechanisms, such offset will be accounted for in the next major update to this nexus study. (Fehr & Peers, 2025, p. 6)
Request for Explanation on the Inclusion of Etiwanda Grade Separation in the Transportation DIF and Impacts from Residential Development (BIA; DPFG-T) The commentor states that the primary benefit of the Etiwanda Grade Separation Project (EGS) is to the industrial land uses in the area and that the City has received a TCEP grant in the amount of $60M that should be accounted for in the program costs. While the project lies along Etiwanda Avenue in the industrial zone, it cannot be presumed that it serves only industrial users. As the only north-south corridor east of I-15, it serves as part of the greater circulation of the south, central, and north zones included in the nexus study and proposed program. As mentioned above, the area east of I-15 consists of a combination of existing and future industrial, commercial, and residential developments. As this development increases, we anticipate that this sole corridor will be impacted by all users not just industrial users. The need for additional capacity on Etiwanda

Avenue was identified in the May 7, 2021 Fehr & Peers Memorandum. Based on an analysis by Fehr & Peers for this location, there is an existing deficiency in capacity of 5,190 average daily trips (ADT) (22,790 ADT [existing] – 17,600 ADT [capacity]) which represents 23% (5,190 ADT / 22,760 ADT) of the total anticipated growth in this segment of the corridor of 22,760 ADT (45,550 ADT [future] – 22,790 ADT [existing]) leaving a cost share for new development of 77% of the project cost after the 23% reduction for existing deficiencies. Given the active pursuit of grants by the City for this critical project, the City included a reduction in the program cost for EGS of 40% for alternative funding sources. This reduction exceeds the 23% reduction attributable to existing deficiencies at this location. With respect to the TCEP funding referenced by the commentor, while the City had received award of funds for the project in the amount of $60M, unfortunately due to factors outside of the City’s control (i.e., significant increases in real estate and construction pricing, and utility coordination delays during design), only $23.1M of this funding was able to be utilized toward the project and the majority of the funding was not able to be extended to complete the right-of-way and construction phases of the project. The funding that was successfully captured from the TCEP grant has been accounted toward the existing deficiency in line with the statement quoted in the response above. However, as mentioned above, the City continues to actively pursue outside funding sources in order to achieve the 40% level identified in the funding plan.

Request for Explanation for the Inclusion of the Signal Interconnect System in the Nexus Study at 100% Development Responsibility and Increase in System Costs (BIA; DPFG-T; LLG)
The commentors question the validity of allocating 100% of the cost for construction of the Signal Interconnect System (also known as the Active Transportation Management System or ATMS) to new development and for an explanation of the increase in costs from $10.6M to $75M. The ATMS project has been included in the Transportation DIF since 2005. As such, it has been recognized that the system is needed to address the increased congestion and system infrastructure for management of the traffic signal and interconnected transportation system as the city develops and more individuals need to move through the transportation network. Given the carry-over nature of this project and the fund balance credit provided toward the DIF Program costs in the nexus study, an allocation of 100% for new development is appropriate as prior development has already paid its share toward the ATMS infrastructure. The increase in the cost for the Signal Interconnect System can be accounted for in two ways. First, the amount included in previous versions of the DIF was based on escalation of the originally estimated amount from 2005. In 2018, the City completed the Traffic Signal Master Plan prepared by Albert Grover and Associates. However, the DIF was not updated to include the updated cost estimate as the updates to the program cost were generally based on the Caltrans Construction Cost Index (CCCI) in the intervening years. Second, when escalated by the CCCI and adjusted on a per location basis to account for traffic signals that were not listed in the master plan but will require integration to address impacts from development such as Caltrans interchange signals and new signals in the Civic Center Master Plan area, the amount listed in the nexus study of approximately $75M is reasonable. However, in an abundance of caution and to avoid overcollecting fees toward this project, staff re-evaluated and reduced the project cost listed in the nexus study. This reduction was based on elimination of the traffic signals not listed in the 2018 master plan from the estimate and analyzing the nexus study share for new development based on the proportion of residential units already constructed since 2005 (the beginning of the project’s inclusion in the DIF program) to all anticipated units from 2005 to 2040 as outlined in the nexus study resulting in a reduction of the project cost to 69% of the escalated total project cost from the 2018 master plan.

Request to Revise the Nexus Study to Expand Fee Reductions for Additional Types of Housing Developments Within ½ Mile of a Transit Priority Area (BIA) The commentor is requesting a revision to the nexus study and by extension the fee schedule to include all types of housing near Transit Priority Areas (TPAs). Given the type of residential units anticipated to be developed in the TPAs, the nexus study provided a line item in the fee calculation for typical high-density housing with the assumption that transit oriented development would be prominent in those areas (Table 18, Fehr & Peers, 2025, p. 29). However, the nexus study also anticipates that there may be development in the future that does not fall clearly into a particular land use category provided in the table and thus provides a mechanism for implementation in the section entitled, “Unique Land Use Categories”. Further, the nexus study acknowledges that changes in State law over time may statutorily provide for fee reductions for certain types of development as part of the State’s broader vision for increased housing production and states the following:

This nexus study anticipated all future development in the city without considering the potential applicability of any exceptions to the impact fees applied to such development. This is because, among other reasons, it is not possible to determine whether any particular project will qualify for an exception and then to what extent.

It is speculative to forecast that a certain amount of development expected in the city will be attributable to projects that qualify for exceptions. To be sure, the value of any potential exception was not re-allocated or re-distributed to other development projects. Therefore, no project will subsidize any lost revenue caused by a project that qualifies for an exception, and any shortfalls in funding for exempt or reduced fee projects will be made up through grants or other local discretionary funding sources. (Fehr & Peers, 2025, p. 6).

Since the baseline calculation does not re-allocate or redistribute program costs based on unknown future fee reductions and the nexus study provides mechanisms to address scenarios not specifically identified in Table 8, a revision to the nexus study is unnecessary. However, to provide for quicker evaluation of future residential development, the nexus study revision dated April 30, 2025, includes a line item for each residential land use category which calculates the reduction for use on eligible developments.

Request for Backup to Support the Total Future Trips Listed in Table 15 (DPFG-T) The commentor is requesting backup and calculations to support the total number of trips shown in Table 15 of the Fehr & Peers nexus study of 183,433 (Fehr & Peers, 2025, p. 27). The number of trips estimated comes directly from the trip assignment of the travel demand model used in PlanRC. Since the data and calculations are part of a computer model, the files are in the TransCAD model format. A request for the model files can be made to Fehr & Peers with a copy of the request to the City Engineer to provide permission for release of the data.

Request for Reduction of the Program Cost Allocated to New Development as Non- Proportional to Population Growth (i.e., 46% vs. 29.6%) (DPFG-T) The commentor includes this request in conjunction with a number of other comments, questions, and requests addressed above. In another comment, the commentor asks how only $3,943,600 of the $819,669,000 program cost is considered as existing deficiency. For the first comment, the

commentor states that that new development’s share of program costs should be based on population growth and not other factors of impact from development. However, this approach fails to recognize the complexity of transportation impact. For example, if the focus is only on roadways, the City currently has 1,152.2 lane miles of roadway or 4.333 lane miles of roadway per 1,000 people. If that same ratio to the identified growth is applied in the DIF nexus study, then the facility needs would be 1,493.7 lane miles of roadway (29.6% growth); however, the nexus study only includes 13.8 miles of roadway. It is clear that past development has delivered a lot of transportation infrastructure that benefits new development, reducing the overall program cost for new development as it was developed and paid for by others. To ensure nexus and proportionality in the nexus study, Fehr & Peers included a number of approaches specific to the geography, type, and need of the improvements included in the program. With respect to the comment related to existing deficiencies, reference is made to the response to the comment above related to existing Level of Service. Based on the analysis performed in the nexus study, further reductions to the nexus study calculation are unnecessary and would result in new development underfunding infrastructure needed to address its transportation impacts.

Request for Clarification on Whether Roundabouts, Trail Crossings, and Active Transportation Improvements are Beautification, Promotion of Active Transportation, and Safety Improvements (DPFG-T; LLG)
Similar to the comment above related to the use of VMT as a metric (reference is made to the response provided to that comment), the commentor is questioning the use of roundabouts, trail crossings, and active transportation improvements as mitigation for impacts of new development.

Another commentor questions the inclusions of improvements such as railroad crossings, grade separations, curb extensions, traffic signal left turn phasing, and road diets are not applicable to a DIF program. The commentor makes a similar statement related to the inclusion of active transportation improvements in the program with a reduction in facilities per service population.

For clarification, roundabouts are an intersection control implementation improvement (e.g. increased capacity) like a STOP sign or traffic signal and have been identified as a need to mitigate future intersection LOS degradation. In fact, several of the locations identified for construction of future roundabouts were previously identified for construction of traffic signals in the prior nexus study. After further evaluation, the safety benefits, long-term savings to the current and future residents and businesses of the city, and added capacity drove the decision to modify the recommended improvement at these locations. Since many of the project locations are carrying over from the prior DIF programs, the fund balance credit provided in the nexus study represents prior development’s contribution toward these improvements. Trail crossings and active transportation improvements are VMT reduction measures that help meet the City’s goals/policies form the General Plan and Climate Action Plan related to GHG reduction. In response to the comment related to service population, attention is directed to the analysis and conclusions drawn in the response to comment related to program cost allocation being non- proportional to population growth for the potential for significant increases in costs should the number of roadway miles per service population be included in the nexus study. Ultimately, the justification for inclusion of the types of improvements based on a wholistic approach to the transportation system and impacts of new development has been included in the nexus study and various responses in this memorandum. Further, it is noted that the cost for active transportation improvements has been allocated based on population growth and thus is proportional to the impacts of anticipated new development. With respect to presumed safety improvements identified by one commentor, reference is also made to the discussion of VMT reducing and capacity improving nexus discussed throughout this memorandum. Further, it should be noted that the nexus study does not include any finding related to safety. All of the referenced comments do improve safety, but many of them either reduce VMT or they improve capacity. Specifically,

grade separations improve capacity by removing delays at the grade separation. Left-turn phasing, depending on the traffic volumes, also can increase capacity. Active transportation improvements reduce VMT. These are all part of the nexus study and have a reasonable relationship to policies identified by city staff. As such, they are appropriate to include in the fee program.

Request for Status of the Grove Avenue / 4th Street at I-10 Freeway Project (DPFG-T) The commentor asks whether the Grove Avenue / 4th Street at I-10 Freeway Project is complete.

The presumption is that if it is completed, the commentor would request it be eliminated from the nexus study project list. These improvements were incorporated into the I-10 Express Lanes Project led by San Bernardino County Transportation Authority on behalf of the City of Ontario.

As part of the nexus study prepared for Measure I 2010-2040, the City was allocated a development share of the improvements based on projected traffic that would utilize the improvements. Based on Measure I policy and State law, the City is required to incorporate the costs into the City’s DIF program and must maintain the listing for the life of Measure I 2010-2040.

Continued inclusion also ensures that future development continues to pay its proportionate share of the improvements at this location. Therefore, this project should not be removed from the nexus study project listing.

Request for Clarity on Reimbursement for Improvements (DPFG-T) The commentor is requesting clarity on the rate of credit or reimbursement for improvements constructed in by developers as part of a development project. The nexus study includes a provision to allow for credit or reimbursement up to the amount identified in the nexus study. It should be noted that RCMC 12.08.040 requires the construction of frontage improvements related to a development to be constructed as a condition of approval. These improvements are identified in PlanRC and other adopted plans for the City’s built environment. The inclusion in the DIF Program and provision for reimbursement provides for reimbursement of the proportional benefit of new development in general toward construction at a specific location.

Further, the City has long recognized that for some development projects there is mutual benefit for the developer to construct public improvements that are part of the impact fee program’s list of capital projects. In accordance with the applicable provisions of the Rancho Cucamonga Municipal Code and other laws, the developer may be eligible for a credit against the amount of the relevant impact fee for the cost of the improvement when the development impact fee is calculated.

To ensure the sustainability and equity of the program, such credits are equal to the estimated value of the improvements and/or dedicated land as outlined in the nexus study, as adjusted and in effect as of the date the fees are calculated. (Fehr & Peers, 2025, p. 6).

Further, RCMC Section 3.28.050 provides a process for fee adjustments.

Request to Remove Roadway Extension Projects from the Nexus Study (LLG) The commentor states that the proposed roadway extensions should be removed or significantly reduced based on a purported lack of nexus analysis. By observation, it can be seen that existing development does not create the need for these identified roadway extensions as they do not exist today. The extensions are solely to facilitate new development and accessibility to new development and, as such, the nexus study creates that finding (e.g. that new development is

wholly responsible for the improvements). It is acknowledged that development through undeveloped land may be required to construct the extension as a project feature, but they serve other new developments that may need access sooner. As such, implementation through the fee program is logical. Should a developer construct infrastructure identified in the nexus study, reimbursement or credits are possible as outlined in the nexus study and discussed in this memorandum.

ATTACHMENTS
Desert Valley Builders Association (Transportation) dated March 25, 2025 Building Industry Association of Southern California dated March 17, 2025 Development Planning & Finance Group (Transportation) dated March 17, 2025 LLG Engineers dated March 17, 2025

ATTACHMENT 6

NBS Non-Transportation DIF Study

1. Based on the projected number of new residential units in the NBS study, a total of 75 acres of park land is required. According to Table 3.1 of the NBS study, the City has 68 acres, potentially 94 acres (see # 5 below) of undeveloped park land in inventory, yet the NBS study proposes the city charge new development $102,000,000 in fees to acquire 75 acres of new park land. Please explain why the new park land is required when the City has sufficient undeveloped park land in inventory to fully satisfy the park land requirements for new development.

2. The February 2025 NBS study arbitrarily removed 26 unimproved acres from inventory at Central Park citing the land was for non-public purposes. We believe these acres should be included in inventory as Central Park was dedicated to the City for public purposes.

3. As of June 2023, the City had over $26,000,000 of non-transportation development impact fee funds on hand. The Fehr & Peers study deducted the transportation funds on hand from the proposed transportation improvements, NBS did not. Government Code Section 66016.5 (a) (4) requires a municipality to evaluate the amount of fees collected under the original fee. Please explain why the non-transportation funds on hand are not being considered as a reduction when calculating the proposed fees.

4. The cost per acre ($989,000) of improving the dog park at central park was used to calculate the park improvement fees. This cost is far in excess of the typical improvements for a public park, potentially by as much as $350,000 per acre resulting in the park land improvement fee to potentially overstated by $26,250,000. Please provide reasonable evidence supporting the proposed cost of future park development.

5. The Resort project will be contributing 1.75 acres of land plus $11,000,000 to the City for construction of a Joint Use Public Facility. The total value of the contribution is approximately $13,100,000. Should the Community and Recreation Center Fee not be reduced by a like amount?

ATTACHMENT 7

Fehr & Peers Transportation DIF Study

1. Before implementing a new development fee (AB 602) Government Code Section 66016.5 (a) (1) requires a municipality to prepare and adopt a nexus study. Section 66016.5 (a) (2) requires the nexus study to identify the existing level of service for each public facility, identify the proposed new level of service and explain of why the new level of service is appropriate. Based on our review of the Fehr & Peers study, it appears these requirements have not been met. Please explain.

2. Government Code Section 66016.5 (a) (6) requires a large municipality adopt a Capital Improvement Plan as part of the nexus study. The City’s Major Projects Program (CIP) does not include a majority of the improvements proposed in the Fehr & Peers study. The Fehr & Peers study references the City has prepared a draft amendment to the CIP . Please provide a copy of the proposed CIP amendment which includes all of the projects in the Fehr & Peers study.

3. The Fehr & Peers study uses Vehicle Miles Traveled (VMT) to calculate the impacts of new development. VMT is not recognized as an appropriate metric in the context of an impact fee analysis, only for greenhouse gas and other environmental impacts. Please explain reliance on VMT as an appropriate metric for the transportation fee study.

4. A new concept in the February 11, 2025, Fehr & Peers report is the zonal approach to assessing fees based on estimated trip interactions between zones. This novel approach creates an unfair burden on the central and south zones with fees that are 58% higher than the north zone. Residential development in the central and south zones are being allocated a disproportionate 78% share of the cost of improvements to the industrial area east of Interstate 15 without any corresponding benefit. We do not concur with this approach.

5. The total project cost estimates in Appendix C of the Fehr & Peers study are not consistent with Table 1 of the study, the City’s Active Transportation Plan (Connect RC) and the City’s Major Projects Plan.

Please explain why the project cost estimates in Appendix C, used to calculate the Transportation Fees have been substantially inflated over the referenced documents.

6. In 2022 the City hired Kosmont to form an Enhanced Infrastructure Financing District (“EIFD”) with the expectation the City would raise over $255,000,000 over the life of the EIFD. The stated purpose of the EIFD is to fund, among other things, the cost of bridges, streets, parking facilities, parks and recreational facilities, sidewalks, streetscape improvements and bicycle lanes identified in the General Plan. The Kosmont report specifically identified the Foothill Corridor and the Cucamonga Station, Haven / Arrow focus area as potential priority projects at a cost of up to $100,000,000. Please explain why the future EIFD funds have not been taken into consideration when calculating the proposed transportation fees.

7. The City’s Connect RC, Active Transportation Plan (ATP) targets multiple regional, state and federal funding sources to address the financial needs of the projects identified in the ATP , yet none of these outside funding sources were considered in determining the proposed Transportation Fee. Please explain why these funding sources were not considered in calculating the proposed transportation fee.

8. In 2018 the City proposed the Etiwanda Grade Separation project to Etiwanda to invest in infrastructure specifically for the promotion and marketability of the industrial sector of the City. Etiwanda Avenue, at the site of the proposed Etiwanda Grade Separation currently operates at a level of service “F” per the City’s Project Baseline Agreement with the California Department of Transportation. This area of the City is known for vehicular collisions with trains and multiple traffic fatalities. The City has applied for and has been awarded significant SB1-TCEP construction funding ($60,000,000 or more) for the project.

Interstate 15 separates the project from residential areas of the city, yet the Fehr & Peers study proposes new residential development pay for the majority of the cost of the proposed improvement without any direct benefit. Please explain why the Etiwanda Grade Separation project is proposed to be included in the Transportation DIF and disproportionately assessed to residential development when it has historically been excluded?

9. The Signal Interconnect System in the Fehr & Peers Study is proposed to be allocated 100% to new development. In addition, the cost of the signal interconnect system was increased over 600% from $10.6 MM to $75.0 MM. Please explain the justification for the cost increase and allocating 100% to new development when the Signal Interconnect System has community wide benefits for existing residents and businesses.

10. The Fehr & Peers study limits the fee reduction for housing developments located within one-half mile of a transit priority area to multi-family (low-rise) and multi-family (mid-rise) units. Government Code Section 66005.1 applies to a “Housing Development”, not specific types of units, thus all housing developments meeting the criteria of Section 66005.1 shall be eligible for a fee reduction based on automobile trip generation rates. Request the Fehr & Peers study be revised accordingly.

Memorandum

To: Carlos Rodriguez, BIA Southern California Chapter
From: Peter Piller
Date: March 17, 2025
Subject: High Level Review of the Revised Rancho Cucamonga Transportation Development Impact Fee Study
CC: Nick Belshe

Carlos,

Per your request, we have prepared this memo summarizing our findings and results of our high- level review of the February 11, 2025, Revised Transportation Development Impact Fee Nexus Study (“Revised Transportation DIF Study”) prepared by Fehr & Peers for the City of Rancho Cucamonga (“City”). The purpose of the review of the Revised Transportation DIF Study is to verify and confirm the assumptions and calculations used in the study, and to make comments as necessary. The primary tasks for our high-level review of the study include the following:

• Confirm mathematical accuracy of schedules in the Revised Transportation DIF Study. • Identify initial issues and comments within the Revised Transportation DIF Study. • Prepare initial bullet point findings and present to BIA and stakeholders.

The observations and results of the tasks performed, and findings are outlined below.

1. Can backup be provided for how the total future trips of 183,433 (from Table 15) was calculated?

2. How can it be justified that new development is required to pay for 46.3% of the $819,668,000 in program costs (excluding DIF Account Balance) when new development only represents 29.6% of the service population at buildout? It seems many of the projects allocated to new development at 100% are either to mitigate an existing deficiency or are not increasing capacity or mitigating new development’s impacts and instead are for beautification or promoting the City’s desire to increase non-vehicle transportation (active transportation).
o As an example, aside from future grant funding, new development is effectively being required to pay for 100% of the Etiwanda Grade Separation Project ($111 million). Within the Revised Transportation DIF Study itself, there is text stating:
“The proposed grade separation of the railroad tracks at Etiwanda has been planned by the City for years. Additionally, it is identified in General Plan Policy ATTACHMENT 8

MA-4.5 which states, “Support the construction of grade separations of roadways and trails from rail lines.” This grade separation is needed to support the continuation of land use growth and associated traffic impacts, especially in the Southeast Industrial Quadrant (SEIQ), to maintain LOS goals in the area.” o If this is a project that has been in the works for years, how can it be fully attributed to new development? This project was initially anticipated to be completed by 2022, and while construction hasn’t started, it is still in process.

This seems to indicate that the project would be built even if no further development were to occur. Additionally, this improvement will especially benefit the SEIQ area as defined above, so why is residential development paying into it at the same rate as non-residential?
o Per a Project Baseline Agreement entered into between the City and the California Department of Transportation it is stated that as of July 2018 Etiwanda had a level of service rating of “F” and an ADT of 21,000 vehicles, and there had been 7 train/vehicular accidents resulting in 2 fatalities and injuries. Based on this, it seems like there is an existing need for this Grade Separation so how can the cost be allocated fully to new development?
o It is also our understanding that $60 million in State funding has already been acquired for this project, which doesn’t appear to be reflected in the study. The study also reflects approximately $74 million in “future grant funding”. Should the total grant funding be $134 million?
o Why is Project INT 20 (Citywide Traffic Signal Communication Improvements) being allocated fully to new development when it is a Citywide improvement that would benefit all residents and employees? At most, this project should be allocated to new development at 29.6%. Additionally, how were the costs for this project allocated to each zone?
o Are roundabouts, trail crossings, and buffered bike lanes mitigating the impacts of new development or are these improvements just for beautification and promoting active transportation?

3. It is our understanding that the City formed an EIFD to fund parking infrastructure and related improvements between Haven Ave and Day Creek Blvd along Foothill Corridor and transportation connectivity improvements linking Cucamonga Station and Haven/Arrow focus area in the amount of approximately $60-$100 million in 2022 dollars. Should there be a reduction/adjustment to the project costs to account for this funding? Specifically, projects DTRC1, CC1, CC1.1, and RH6, all of which are related to active transportation on Foothill and Haven

4. How is it possible that of the $819,668,000 in program costs, only $3,943,600 is considered an existing deficiency?
o As an example, and as referenced above, Etiwanda Avenue had a level of service rating of “F” in 2018. There are multiple projects along Etiwanda which leads us to believe that not only should the existing deficiency amount be higher, but that

it is likely there are also additional roadways that are below the desired level of service.

5. Would it make sense to add an additional Eastern zone for the industrial area east of the I-15?
o It is unlikely that residents living in the Southern zone will frequently travel east of the I-15 into the industrial area, yet the Southern zone is being allocated most of the costs for projects east of the I-15.

6. Per Table 10, there will be a reduction in quantity of facilities per 1,000 service population when compared to the existing standard for Roadways, Trails, and Sidewalk Facilities, with Bike Lanes being the only facility to see an increase. o How can it be justified that the proposed improvements are solely mitigating the impacts of new development and not just furthering the goals of the City to promote active transportation when most of the facilities are seeing a decrease compared to the existing standard?

7. Many of the project costs are inconsistent with estimates previously approved by the City and appear to have been largely inflated. Additionally, there is a disconnect in project costs between Table 1 and Appendix B.

8. Is the Grove Ave/4
th Street at I-10 Freeway project already complete? (Project ID F1)

9. If a new development project constructs one of the DIF improvements, how can it be guaranteed that the developer will receive credits/be reimbursed for the full cost of work? We recently ran into a situation where a jurisdiction is claiming they will only credit/reimburse a developer for the percentage of the project costs allocated to new development (29.6% in this case) as they won’t have the funds to reimburse for the remaining percentage of costs that are allocated to existing development, and if they were to do so, they would be taking credits away from other future projects. This effectively told us the jurisdiction is not funding existing development’s share as was stated they would do in the nexus study.

MEMORANDUM

To: Mr. Carlos Rodriguez
Business Industry Association
of Southern California, Inc.

Date: March 17, 2025
From: Keil D. Maberry, P.E., Principal
LLG Engineers
LLG Ref: 2.24.4893.1
Subject:

Peer Review of the Transportation Development Impact Fee (DIF) Program Nexus Study, Rancho Cucamonga

As requested, Linscott, Law & Greenspan, Engineers (LLG) is pleased to provide our review comments o f the Transportation Development Impact Fee (DIF) Program Nexus Study prepared by Fehr & Peers dated February 11, 2025. In particular, this review focuses to the appropriateness and reasonableness of the DIF Project List and Project Cost Estimates contained in Appendix C of the DIF Study and the resultant DIF Program Cost Total presented in Table 14 on Page 26 of the DIF Study. It should be noted, similar to our review of the October 23, 2024 Transportation Development Impact Fee (DIF) Program Nexus Study prepared by Fehr & Peers, it is our finding that this study provides no detailed quantitative nexus analyses associated with the list of DIF improvements contained in Appendix C , which is required by the Mitigation Fee Act.

Based on our detailed review of the DIF Study, we have the following comments with regards to the DIF Project List and Project Cost Estimates and resultant DIF Program Cost Total:
 Active Transportation (AT) related improvements by definition do not specifically improve level of service and do not measurably improve congestion levels to mitigate the impact of new development, which is a necessary nexus required for DIF improvements to be included in the DIF calculation process.

Conversely, the DIF Study does indicate that Active Transportation improvements improve vehicle miles traveled (VMT) within the City as a correlation for applicability to the DIF calculation. However, the relat ive measure of VMT in the DIF study was calculated for the entire City and not specifically for new development, which is contrary to the DIF requirement . Nonetheless, while it is likely that AT improvements would benefit existing and future development, the application of a fair share value would be reasonable in our assertion. With that said, based on the information provided in Table 12 of the DIF study, AT improvements will provide a 0.1 % Citywide VMT reduction upon implementation between 2024 and the 2040 Buildout condition commensurate with new development. Therefore, we would recommend that only a 0.1% fair share of the AT improvements be applicable to the DIF calculation. Nonetheless, it is our understanding that the City approved an Enhanced Infrastructure Financing District (EIFD) in 2022, which was intended to cover, among other ATTACHMENT 9

Mr. Carlos Rodriguez
March 17, 2025

things, the proposed AT improvements along Foothill Boulevard and Haven Avenue, such that these AT improvements should be eliminated from the DIF list.  Improvements related to safety, such as railroad crossing improvements /grade separations, buffered bike lanes, pedestrian enhancements, curb extensions, traffic signal left- turn phasing improvements , and road diets are not applicable to the traffic impact of new development as the traffic generated by new development does not directly impact traffic safety conditions, such that a nexus finding cannot be made between new development and these safety -related improvements and therefore should be removed from the DIF Study analysis.  The applicability between the proposed bridge widening improvements and enhanced capacity/improved level of service (LOS) therein must be presented in order for a nexus finding to be made, such that merely improving a bridge structure does not improve traffic conditions for new development.  With regards to roundabout improvements, it is not clear whether there is a enhanced capacity/improved level of service (LOS) improvement compared to the existing geometry, such that a nexus finding must be made in order for the proposed roundabout improvements to be applicable.
 The proposed new traffic signal improvements (four locations) are located at intersections with local side street roadways within built out areas, such that the presumed improved level of service from constructing the traffic new signals will not likely benefit new development and it is not clear whether the proposed traffic signals are even warranted under existing or future conditions. In the event that the City provides additional evidence to justify the possible inclusion of Traffic Signals in the “fair share” cost allocation, in our experience the cost estimate for a new traffic signal appears excessive at $750,000, and would recommend a cost of $500,000.
 Improvements related to trail enhancements and trail crossings are not applicable to the traffic impact of new development as the traffic generated by new development does not directly impact traffic safety conditions, such that a nexus finding cannot be made between new development and these safety -related improvements and therefore should be removed from the DIF Study analysis.  The DIF roadway extension improvements are not supported by any nexus analysis within the DIF study, such that it is not clear that any of the roadway extension improvements listed mitigate new development impacts solely because they provide additional roadway capacity within the City. Another factor to consider regarding the applicability of roadway extensions, is the fact that because

Mr. Carlos Rodriguez
March 17, 2025

the proposed roadway extensions are through or adjacent to undeveloped land, new development will be required to construct these roadway extension improvements as Project Features , thus eliminating the need to include them as DIF improvements. As a result, if not eliminated, at most these roadway extension improvement costs should be calculated at the 29.6% new development service population increase based on Table 3 in the DIF study.

 The Signal Interconnect System improvement designated as a Citywide traffic signal communication improvements, in our experience, has shown to marginally improve congestion levels, but is not substantiated in the DIF study. * * * * * * * * * * *
We appreciate the opportunity to provide these comments . Please call us at (949) 825-6175 if you have any questions.

Greetings Mayor Michael and City Council,
Regarding the upcoming 5/7 City Council meeting, please see the attached comment letters in opposition to the proposed Transportation DIF.

Public Hearing for Consideration of Resolution No. 2025-014, A Resolution of the City Council of Rancho Cucamonga, California, Approving a Development Impact Fee Nexus Study for the Transportation Impact Fee, Adopting a Capital Improvement Program as Part of the Nexus Study, Establishing the Fee Amount, and Making a Determination of Exemption Under CEQA. (RESOLUTION NO. 2025-014) (CITY)
Thank you for your consideration.

Best regards,
Carlos Rodriguez
Chief Policy Officer
Building Industry Association of Southern
California, Inc.
[email protected]
ph: (909) 641-4630 w: biasc.org
Mailing Address: 17192 Murphy Ave., #14445,
Irvine, CA 92623
Los Angeles/Ventura • Orange County • San
Bernardino County • Riverside County •
Coachella Valley
2025-05-07 - REGULAR MEETING - CORRESPONDENCE RECEIVED FOR PUBLIC HEARING ITEM G1

17192 Murphy Ave., #14445, Irvine, CA 92623

May 6, 2025

Honorable Mayor Dennis Michael and City Council
10500 Civic Center Drive
Rancho Cucamonga, CA 91730

RE: Opposition To Resolution No. 2025-014 adopting nexus study and capital improvement program and approving the impact fee for the updated Transportation Development Impact Fee (DIF) Program.

Dear Mayor Michael and City Council:

On behalf of the Building Industry Legal Defense Foundation (BILD) and the Building Industry Association of Southern California San Bernardino County Chapter (BIA), we write to express concern over the adequacy of the Fehr & Peers nexus study for the proposed Rancho Cucamonga Transportation Development Impact Fee (DIF) Program. This report raises several issues which requires further review.

By way of background, the Building Industry Legal Foundation (BILD) is a non-profit affiliate of the Building Industry Association of Southern California (BIA ). BILD provides legal support, research and litigation services dedicated to increasing the pr oduction of housing in response to the State’s overwhelming underproduction of housing. BIA represents the home building community of the entire Southern California region, working to achieve housing as the foundation of vibrant and sustainable communities.

BIA retained the services of the Rutan and Tucker law firm to provide a legal review of the proposed transportation impact fees brought forward by the City of Rancho Cucamonga. This analysis submitted finds that the proposed Transportation DIF conducted by Fehr & Peers fails to meet legal compliance standards.

These findings are further supported by the submitted technical review provided by engineering firm Linscott, Law & Greenspan Engineers (LLG) and a review by fee consultant Development Planning and Financ ing Group (DPFG) . The experts at LLG and DPFG also highlight several issues that need to be resolved before the City can justifiably rely on said study for the establishment of a fee system.

We appreciate your immediate attention to this matter and look forward to working with the City Council and staff to resolve the issues necessitating this letter.

Sincerely,

Adam S. Wood Carlos Rodriguez
Chief Administrator Chief Policy Officer
BILD BIA Southern California

David P. Lanferman
Direct Dial: (650) 320-1507
E-mail: [email protected]

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VIA E-MAIL AND FIRST CLASS MAIL
[email protected]
[email protected]
John R. Gillison
City Manager

CITY OF RANCHO CUCAMONGA
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
Matthew Burris
Deputy City Manager

CITY OF RANCHO CUCAMONGA
10500 Civic Center Drive
Rancho Cucamonga 91730

Re: Proposed [New] “Transportation Development Impact Fee Nexus Study” by Fehr & Peers, dated February 11, 2025
Legal Issues and Objections

Dear City Manager Gillison and Deputy City Manager Burris:

On behalf of the Building Industry Association of Southern California (“BIA”) we respectfully submit this letter updating and summarizing our comments on and objections to the revised – but still inadequate -- draft of the proposed new Transportation Development Impact Fee (TDIF) Program Nexus Study, as revised by Fehr & Peers in February 2025, and “updated” as of April 30, 2025 (the “Study”).1
It is our understanding that the City Staff is planning to present this version of the Study to the City Council on May 7, 2025, for public comment and Council consideration of possibly adopting new “transportation development impact fees” to be imposed on new development in the City (“TDI Fees” or “TDIF”).2

1 Since the April 30, 2025, “updated” version of the Study was only recently provided to BIA and the public (as an attachment to the Staff Report issued on May 5, 2025) – allowing little or no time for review and comment on this new document -- most of the comments in this letter are necessarily based on the February 2025 version of the Study. We also note that th e very late and untimely release of this new “update” less than ten (10) days in advance of the hearing violates the Mitigation Fee Act which requires that such information shall be provided to the public at least 10 days prior to the hearing, (Gov. Code §§ 66016, 66017, and 66019(b).)

2 This letter will refer to the proposed new transportation impact fees as “TDIF,” to distinguish them from the other non-transportation development impact fees referred to as “DIF.”

John R. Gillison
Matthew Burris
May 6, 2025

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Introductory Comments and Summary of Technical Objections We appreciate that it appears that the City Staff and the fee consultants have taken some of BIA’s previous comments and objections to heart , and have attempted to correct some of the issues that were previously raised in response to the October 2024 version of the proposed Study.

Nevertheless, this latest version of the T DIF Study (dated April 30, 2025), remains critically flawed, and continues to rely on unfounded assumptions and legally-inappropriate methodologies, despite the revisions.

We have focused our analysis on the legal issues raised by this Study. However, there are also serious technical issues raised by the Study which are called out in more detail by the accompanying critical analyses by Development Planning and Financing Group (“DPFG”) and by Linscott, Law & Greenspan, Engineers ( “LLG”). Those very serious technical issues and deficiencies include (without limitation) the following:
(a) Many of the new facilities included in this Study’s assumptions are not shown to be “needed” as a result of impacts caused by new residential development, i.e., no “nexus”; (b) Many of the proposed new facilities and improvements in the Study have little or nothing to do with mitigating impacts caused by new development, and are apparently sought for reasons other than increasing capacity to accommodate new traffic generated by new development, e.g. improvements desired by the City to improve aesthetics, or safety, or to meet new regulatory requirements – the costs of which cannot legally be foisted onto new development; (c) The Study fails to a ccurately identify the many existing deficiencies in the transportation network, and fails to exclude or accurately apportion the costs of addressing those existing deficiencies from its calculations of the proposed TDIF; (d) The Study fails to acknowledge (and credit) sources of funding other than development fees for some of the major street and overpass improvements erroneously included in the Study, and allocating full cost to new development; (e) The Study fails to accurately identify and fairly distinguish impacts caused by or reasonably attributable to new “non-residential” development, e.g., impacts from industrial, commercial, warehouse, educational, healthcare or governmental development activities and to allocate costs of mitigation accordingly;
(f) The Study also raises many questions regarding the inconsistent (and apparently- inflated) cost estimates for the proposed improvements used in the Study.

John R. Gillison
Matthew Burris
May 6, 2025

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LEGAL ISSUES AND OBJECTIONS
A city’s enactment of “development fees” no longer enjoy s any presumption of validity nor any judicial “deference” to the city ’s decisions. Especially following recent United States Supreme Court decisions in Sheetz v. County of El Dorado (2024) and Koontz v. St. Johns River Mgt. Dist. (2013), and the adoption of Propositions 218 and 26 by the voters of California, the City now bears a weighty constitutionally-imposed burden of proof – requiring the City to prove to the public and to the courts that its “development fees ” are justified and valid , and based on a preponderance of “substantial evidence.”
As the California Court of Appeal recently emphasized: “It suffices to state that having rate studies, and an expert who agrees with them, is not enough .” (Coziahr v. Otay Water Dist. (2024) 103 Cal.App.5th 785, at 803.)
With regard to the legal issues and deficiencies remaining in the current version of the purported Nexus Study, we highlight the following:

1. The Study still fails to demonstrate that the proposed new TDIF would comply with the federal constitutional requirements of Sheetz, Koontz, Dolan, and Nollan.

Most fundamentally, the new Study still fails to include evidence and analysis that carries the City ’s burden of proof to demonstrate that the proposed new T DIF would comply with constitutional requirements limiting development fees or exactions.3 The U.S. Supreme Court has set out a two-part test for such development fees, requiring the government to show that its fees as based on both (1) a causal connection (“nexus”) between new residential development and the City ’s perceived “need” to construct all of the costly new improvements, and (2) at least rough proportionality between the amount of the fees to be imposed on a new development and the estimated costs of the proposed new improvements the need for which is allegedly caused by quantifiable im pacts on public facilities reasonably anticipated from new development.

In April 2024, the U.S. Supreme Court’s decision in Sheetz v. County of El Dorado , 601 U.S. 267, made clear that all fees and exactions imposed as conditions of development approval – regardless of how they are enacted -- must be shown to meet both of these essential constitutional

3 Sheetz v. County of El Dorado (2024) 601 U.S. 267; Koontz v. St. John’s River Water Mgt.

Dist. (2013) 570 U.S. 595; Dolan v. City of Tigard (1994) 512 U.S. 374; Nollan v. California Coastal Comm. (1987) 483 U.S. 825.

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Matthew Burris
May 6, 2025

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requirements.4 Sheetz unanimously held that the County was constitutionally -obligated to demonstrate that its “transportation impact fees ” were calculated on a basis showing that the amount of the fee imposed on a particular residential building permit was roughly proportional to the alleged “impact” of that single-family home.

In a case challenging a county’s “transportation impact” exactions, the California Court of Appeal recently applied these constitutional requirements to hold that the exactions were invalid on their face. (See, Alliance for Responsible Planning v. Taylor (2021) 63 Cal,App.5 th 1072, 1084-86. “Laudable as traffic mitigation is, ‘there are outer limits to how this may be done.’” Despite its token acknowledgment of the “Nollan/Dolan” constitutional requirements (nexus and rough proportionality), the Study still fails to actually demonstrate compliance with those requirements, and the new TDIF based on the Study would fail to withstand judicial scrutiny if the proposed TDIF were to be adopted by Council and challenged in court.

2. The Study fails to show the required “nexus” between all the new transportation improvements and alleged impacts of new residential development.

Although the Study recognizes the City ’s burden to demonstrate “the direct link between anticipated growth ... and the necessity for transportation infrastructure improvements ” it fails to demonstrate that required direct causal link. The Study confuses the City’s “vision” for a “layered circulation network” with needs for new improvements that are “directly linked” to and caused by demands for increased capacity caused by new development. The Study fails to show that demands created by new development be ar any causal connection to the enhanced quality improvements envisioned in the general plan or to the extensive list of alleged “VMT-reducing” projects..

The Study compounds this error – wrongly assuming that a city planner ’s “vision” somehow provides the basis for a nexus or direct linkage to “needs caused by development” – by arguing that population growth causes a civic “need” for enhancements to the “quality” of the City’s transportation facilities. However, there is no legal authority, nor any evidence, demonstrating that the anticipated population growth justifies “safety improvements ” such as “modernized traffic controls” (“AT”), “intersection enhancements,” and protected bike lanes. The Study does not even attempt to provide any evidence or analysis to show that these costs for such new AT improvements or e nhanced levels of service are necessary to meet increased demands caused by new development.

4 As the Supreme Court explained in Sheetz: “A condition that requires a landowner to give up more than is necessary to mitigate harms resulting from new development has the same potential for abuse as a condition that is unrelated to that purpose.” (Emph. added.)

John R. Gillison
Matthew Burris
May 6, 2025

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To the contrary, the Study purports to show only that a large part of the revenue that would be generated by the proposed TDIF would be targeted solely to address costs of qualitative enhancements that address goals other than increasing system capacity to accommodate needs caused by new development.

Many of the proposed transportation improvements have no logical or causal relationship to any impacts actually attributable to growth. For example, as pointed out in the previously- provided Technical Memo by DPFG (3/14/2025), the City has long deemed the hugely expensive Etiwanda Grade Separation Project to be necessary to cure existing deficiencies. As such, it is clearly wrong for the revised Study to attribute a grossly disproportionate (60%) “share” of the costs of those improvements to new development and include them in the TDIF.

3. No showing of “rough proportionality” between the amount of the proposed TDIF and the estimated (inflated) costs of the enhanced transportation improvements.

The Study fails to address and demonstrate the “proportionality” of its fees in the manner required by the Supreme Court. Dolan and the cases following hold that the relevant “proportionality” is to be demonstrated based on the relationship between (a) the amount of the fee assessed to the particular development and (b) “the extent of the impact ” (i.e., the amount of cost or burden on the City to address or mitigate the impact reasonably caused by the development).

This revised Study, again, fails to make that demonstration, or to provide a basis for the City to make that determination in imposing the TDIF.5

5 Other recent appellate court decisions have similarly invalidated unjustified transportation impact fees and exactions based on the same type of flaws as this Study. E.g., Alliance for Responsible Planning, supra , [invalidating El Dorada County measure imposing transportation impact exactions]; Knight v. Metro. Gov't of Nashville & Davidson County (6th Cir. 2023) 67 F.4th 816 [The government required property owners “to either build useless ‘sidewalks to nowhere’ or pay for sidewalks miles away. These conditions do not look all that proportional to any specific harms from their homes, so the district court concluded that Nashville likely could not meet Dolan's rough-proportionality element.] In Board of Supervisors v. Route 29, LLC (Va. 2022) 872 S.E.2d 872, the Supreme Court of Virginia similarly upheld a developer’s challenge to the county’s demand for transportation in -lieu payments because the demands “ lacked an essential nexus to the impacts of the owner's commercial retail project as the commuter bus route which was established did not operate to deliver customers to the owner's commercial retail project and the payments under the transit proffer were not roughly proportional to the impacts of the commercial retail project.”]

John R. Gillison
Matthew Burris
May 6, 2025

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The Study (p. 2) asserts that its “assessed fees are proportional to the development ’s estimated increase to transportation demand, ....” This unfounded assertion reveals at least two (2) of the fatal flaws in the Study:
(a) First, the Study wrongly implies that the fees are proportional “estimated increase in transportation demand” in all cases. That is clearly false because at least in the case of the huge costs of the Etiwanda Grade Separation project the Study arbitrarily and inconsistently allocates 60% of those estimated costs to new development by way of the TDIF – without any attempt to link that allocation to any of the “formulae” used elsewhere in the Study. For example, the Study appears (rightly or wrongly) to largely rely on the formula (on page 1 8) of “increased demand/total future demand”. Using this formula, the percentage increase from new development in the average daily trip rate on Etiwanda Ave nue between 6th Street an Arrow Route is 38% (14,150 / 33,790). Elsewhere in the Study, it asserts that project costs should simply be allocated “proportionally” to the ratio of increased service population to the total service population, i.e.,

29.6% as shown in Table 3.
(b) Second, the Study wrongly implies that it allocated project costs “proportionally” to each individual development ’s estimated increase in demand ( “the development’s ... increase...) However, the Study does not purport to provide a basis for the City to make such “individualized determinations” of the relationship between the fees assessed and the impact of the particular proposed development. Instead, the Study merely purports to show gross “proportionality” between the amount of fee to be imposed and the type of land use classification the development is assigned (and there are only three overbroad “types” of land use classifications in the Study). This “one-of-three sizes fits all” approach is not consistent with the constitutional requirement explained in Dolan.6

6 Dolan, supra , 512 U.S. 374, at 391: “... the city must make some sort of individualized determination that the required dedication is related both in nature and extent to the impact of the proposed development.”

In Dolan, the Court rejected the City’s ‘nexus study’ with the following explanation:

The city estimates that the proposed development would generate roughly 435 additional trips per day. Dedications for streets, sidewalks, and other public ways are generally reasonable exactions to avoid excessive congestion from a proposed property use. But on the record before us, the city has not met its burden of demonstrating that the additional number of vehicle and bicycle trips generated by petitioner's development reasonably relate to the city's requirement for a dedication of the pedestrian/bicycle pathway easement. [Emph. added.]

John R. Gillison
Matthew Burris
May 6, 2025

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4. The Study fails to acknowledge, much less comply with, the requirements of the California Constitution for lawful fees and other charges.

The City has apparently failed to consider the constraints on all local governmental charges and fees imposed by the California Constitution, as amended by Propositions 218 and 26. The Study still fails to make any effort to carry the City ’s burden to demonstrate that its fees and exactions are not “taxes” in disguise, nor to demonstrate that these new fees fit into any “exception” to the constitutional presumption that these charges are “taxes.” The Nexus Study failed to address either the “aggregate cos t” requirement or the “reasonable allocation ” requirement now mandated following Proposition 26. Such failures are also fatal to the validity of the new “fees.” See, e.g. Zolly v. City of Oakland (2022) 13 Cal.5th 780, 785-86; Carachure v.

City of Azusa (2d. Dist. 4/15/25) __ Cal.App.5th ___, 2025 Cal.App. LEXIS 248; HJTA v.

Coachella, supra , 108 Cal.App.5th at 508 -09; Coziahr v. Otay Water Dist . (2024) 103 Cal.App.5th 785, 800.

5. The Study improperly uses unjustified and inconsistent methodologies.

The Study appears uses or mis -uses several, internally-inconsistent, approaches in attempting to justify the proposed new TDIF: (a) novel, and unauthorized, “zone-based” allocation of costs and fees; and (b) a hybridized version of the “existing standards” or “existing inventory” approach; and (c) inapt application of the “system plan” approach.

The new Study introduces a novel approach that it describes as “a zone-based fee program.” There is no legal authority, however, for this approach nor has any reported case ever approved of this type of “band approach” which purports to arbitrarily allocate the costs of new facilities to three bands based on their perceived “benefits” from the transportation improvements.

No evidentiary analysis supports that approach. Moreover, fees are required to be allocated proportionally on the basis of burdens or impacts generated, not on the basis of “benefits received.” Following Dolan and Sheetz, it may be appropriate and necessary to calculate TDIF on the basis of trips (or other chargeable “impacts”) generated by particular developments, or even on trips generated by specifically -described “types” of development (where the “types” are sufficiently narrowed and the type -specific TDIF are shown to accurately quantify impacts .) However, there is no basis for skewing the calculation of the new TDIF to unduly burden one part of the City with fees while unduly sheltering another part of the City from its fair share of the City-wide costs of new facilities that will be used by, and benefit, all residents – as well as non-residents who will “benefit” from the new facilities without being charged any fees.

The Study also appears to employ an unauthorized distortion of the “system plan ” approach, which would normally have new development pay its share of the costs of an integrated system of facilities and improvements by dividing the costs of that system by the combined demand from both existing users and planned future development.

John R. Gillison
Matthew Burris
May 6, 2025

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The various transportation projects upon which the Study is based are of two distinct types:
(a) projects allegedly needed to accommodate increased demand caused by new development; and (b) projects envisioned or desired by the City in order to address its desire to reduce overall VMT generated by the City, not necessarily attributable to needs caused solely by new development.

Using the Study ’s own assumptions about combined future demand (Table 3), the new TDIF fees on new development should not exceed 29.6% of the total project costs.7 Even if such “VMT-reducing” project could lawfully be included in the calculation of TDIF, using the City’s own projections of future VMT increases would mean that not more than

6.1% of the “VMT-reducing” project costs could be included in the calculation of TDIF

6. The Study fails to comply with the Mitigation Fee Act.

The Mitigation Fee Act (Gov’t Code §§ 66000 et seq.) establishes additional and specific requirements on development fees, beyond the broad constitutional requirements described above.

Again, the Study superficially acknowledges these statutory requirements but fails to substantively comply.

Gov. Code Section 66001(a) requires the City to show “how there is a reasonable relationship between the need for the public facility and the type of development project on which the fee is imposed.” The Study fails to satisfy this requirement . As described above (and in the accompanying technical memos from DPFG and LLG) the Study does not differentiate between improvements that are deemed “necessary” in order to provide increased capacity to accommodate new demands from new development and enhancements that may be deemed desirable merely in order to improve “aesthetics,” and to comply with health, safety, or environmental regulations.

This latter class of desired improvements, such as the AT and ‘multi-modal’ improvements, which do not mitigate increased demands on capacity caused by growth, are generally not the type of improvements that can be financed by imposition of development impact fees. (Gov. Code §§ 66001(a), 66001(g).)
The “need” – if any—for such new multimodal facilities would be driven at least in part by the existing community as well as new development, as well as the City’s desires to meet new environmental and regulatory standards – not needs caused by new development. New AT or

7 According to Table 1 4 in the Study, the total cost of constructing the proposed facilities included in the TDIF program is $588 million, with $327 million being allocated to new development, before credit for current TDIF account balances ($64 million) and existing deficiencies ($3.9 million) . Even assuming $ 588 M is an accurate estimate of total costs of all proposed improvements, the Nexus Study appears to impose a disproportionate share of all such costs on new private sector development (55.6%), and merely allocates just $ 3.9 million to the costs of correcting existing deficiencies (i.e., allegedly the existing community’s “fair share”).

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Matthew Burris
May 6, 2025

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multimodal facilities involv e an upgrade to the City ’s existing standards of transportation infrastructure, in violation of Gov. Code § 66001(g). Therefore, the costs of those new facilities cannot legally be foisted entirely upon new development.

Many of the costs of the new facilities appear to be for improvements in quality (not just capacity improvements to the existing road facilities - this creates benefits enjoyed by all users and should thus be allocated differently. Cf. Gov’t Code § 66001(g). Section 66001(g) of the Act expressly prohibits a fee from including any costs “attributable to existing deficiencies in public facilities, ….” (Bixel Assoc. v. City of Los Angeles (1989) 216 Cal.App.3d 1208.)

7. Failure to Account for Deficiencies or Surplus Existing Capacities.

The Study asserts that its analysis is intended to avoid calculating the fees on the basis of needed corrections to “existing deficiencies” in the transportation network – but still does not appear to consider or take into account the extent to which the existing network may include some, or many, segments that already provide adequate levels of service , or which may have “surplus capacity” available to maintain the existing levels of service. Fees may not be imposed on new development to reimburse the Cit y for its prior expenditures to provide infrastructure that is sufficient to continue to provide the same level of service ( “LOS”) as contemplated by the City’s established standard (LOS “D” as stated in the Study at p. 11). ( Home Builders Ass ’n v City of Lemoore (2010) 185 Cal.App.4th 554, 572.)
The Study reports, incredibly, that the costs of correcting the “existing deficiencies” in the selected elements of the City’s transportation facilities is only $ 3.9 million. That implies that the vast majority of the City’s facilities are already at or above the existing LOS. Such facilities that are currently operating at better than LOS D presumably have at least some excess capacity available to accommodate traffic from new development, before needing expansion.

One extremely egregious error, which taints the entire Study, is its failure to accurately account for the huge costs of correcting the admittedly “deficient” Etiwanda Grade Separation.

The City’s own consultant Fehr & Peers recognized that situation as an existing deficiency in their report to the City Engineer on May 7, 2021. As noted above, the Study wrongly allocates 60% of those costs to the TDIF program. In reality, no more than 29.6% (increased service population) or 38% (increased ADT) should be allocated to the TDIF – and probably far less than that if proper traffic studies were provided.

8. Failure to Comply with Requirements of AB 602.

The Study acknowledges that AB 602 amended the Fee Act, effective in 2022, but nevertheless fails to comply with several of those new requirements:

John R. Gillison
Matthew Burris
May 6, 2025

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(a) While the Study purports to identify the existing levels of service (“LOS”) as required by Gov. Code § 66016.5(a)(2) [as added by AB 602], it fails to “identify the proposed new level of service, and include an explanation of why the new level of service is appropriate” which is also required by the same section. (b) The Study fails to “review the assumptions of the nexus study supporting the City’s original [previous] transportation impact fee and evaluate the amount of fees collected under the original fee” as now required by § 66016.5(a)(4). (c) The Study refers to the City ’s separate Capital Improvement Plan but does not comply with the statutory requirement that the City “shall adopt a capital improvement plan as a part of the nexus study .” (§ 66016.5(a)(6).) A CIP must at least meet the requirements outlined in § 66002. The Study is not consistent with the current CIP, which does not include many of the proposed new transportation improvements that are listed in the Study. The inconsistencies between the Study and the CIP must be resolved. In addition, the CIP must demonstrate that the City has adequate and reasonable secure sources of funding to cover that portion of the costs of new facilities which cannot lawfully be attributed to “new” development paying DIF fees.
(d) AB 602 now makes clear that any “nexus study” must account for and analyze (Gov. Code § 66016.5, subd.(a)(4)) any previously accumulated facilities fees and other resources the City may have already acquired for the same purpose as the new fees being calculated (Boatworks, supra.). This Study fails to do so.

9. Unfounded Assumptions.

The Study still relies on many assumptions, that are not supported by evidence in the Study or by references to authoritative or qualified sources, e.g., its assumptions about anticipated future development, both residential and non -residential; the average size of new residential dwelling units; household ‘density’ (persons/household) and trip generation.

In particular, assumptions about the estimated costs of new transportation facilities and improvements appear to be largely unsourced, highly speculative, and frequently inconsistent with cost estimates in other City documents . The Fee Act requires that fees may not exceed the reasonably estimated costs of providing the identified public facilities for which they are imposed.

Gov. Code § 66006. The Study refers to unidentified “City sources” of information regarding the “cost estimates” used in the Study. However, there is no indication as to the qualifications or expertise of those sources which would be necessary to validate the cost estimates

John R. Gillison
Matthew Burris
May 6, 2025

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10. Improper Reliance on VMT as Justification for New Fees.

As we have previously pointed out, the Study’s reliance on VMT to calculate “impacts” of new development is of dubious validity. To the contrary, VMT is a metric appropriate in the context of CEQA analysis, for assessing GHG and other environmental impacts of vehicular travel, not demands for increased capacity to accommodate new development. VMT has not been recognized as an appropriate metric in the context of “impact fee” analysis. The Mitigation Fee Act, by contrast, has always addressed the anticipated “needs” for, or “impacts on,” transportation facilities in terms of comparative usage and trip generation ratios.

As noted above, however, to the extent that the City or its consultants may believe that the proposed new TDIF can be justified by using a VMT metric, it appears that those VMT-based calculations would not support allocating of estimated costs of the proposed new facilities as shown in the Nexus Study. See the Technical Memo by LLG Engineers, dated May 5, 2025, regarding possible limited application of VMT as a basis for allocating the costs of “VMT - reducing” traffic improvements, and concluding that new development would only increase 6.1% above the existing City -wide VMT. The proposed TDIF would need to be corrected and substantially reduced if the City could wants to use a VMT metric for those proposed new projects that are intended to be “VMT-reducing.”

11. Failure to Properly Account for Other Non-Fee Funding Sources.

The Study acknowledges (p. 6) that the City pursues grants and other external funding mechanisms, but cannot “guarantee” what percent or amount of the new transportation facilities might be funded by sources other than TIF. In reality, however, most of the assumptions used in the Study do not purport to be “guaranteed” – but such uncertainty did not appear to preclude the Study from reaching its conclusions about the recommended fees.

The Study thus fails to properly take into account – and credit – all other, non-TDIF, funding sources for the proposed facilities and improvements (e.g., State or federal grants; regional SBCTA funding, possible federal or State rail subsidies, etc.) Nor does the Study take into account or credit the probable new local tax revenues likely to generated for the City by new development, etc.) New development ultimately will be paying on -going local property, sales, and gasoline taxes, in addition to one-time TDIF fees.

The Study simply suggests that in the event such non -TDIF funding sources are received in the future, they would be “accounted for in the next major update to this nexus study. ” Any such future accounting and offset for non -TDIF funding received may be valuable prospectively to future T DIF fee -payers, but fails to provide any meaningful retroactive relief (as constitutionally-required) to current TDIF fee-payers who would have been “over-charged” by the Study’s absolute failure to anticipate, estimate, and include such non-TDIF funding sources in this Study and any fees that Council might adopt based on this Study.

John R. Gillison
Matthew Burris
May 6, 2025

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12. Other Issues and Comments.

This letter does not waive the various other legal issues raised by the City’s proposed action on these unjustified TDIF. Rather, we reserve the right to supplement our objections and comments based on the evidence, new developments, and the City Council’s actions.

For example, much of the purported Nexus Study is not based on “substantial evidence,” but rather relies on assumptions and unidentified sources whose competence and expertise is not demonstrated. This is not credible substantial evidence sufficient to justify any Council action on proposed new fees. While the City ’s consultant may have recognized expertise in certain disciplines (e.g. traffic engineering), the expert must still demonstrate that his or her opinions have sound evidentiary foundations, and are not based on speculation or inappropriate “sources.” “[E]ven when the witness qualifies as an expert, he or she does not possess a carte blanche to express any opinion within the area of expertise. For example, an expert’s opinion based on assumptions of fact without evidentiary support … or on speculative or conjectural factors … has no evidentiary value … and may be excluded from evidence .” (Olive v. General Nutrition Centers, Inc., (2018) 30 Cal.App.5th 804, 817.) Among other possible grounds for challenge to the City’s adoption of the new TDIF is the questionable assumption that adoption of the new Capital Improvement Plan along with the Nexus Study and TDIF should be “exempt” from CEQA compliance. CEQA includes a broad definition of “projects” that are subject to its requirements (Pub. Res. Code § 21065), and Guideline § 15378(b)(4) cited by the City only excludes “governmental fiscal activities which do not involve any commitment to any specific project ….” Since the adoption of a CIP and new development fees both involve the City’s commitments to the specific projects identified therein, it is inconsistent and inappropriate for the City to dismiss its obligations under CEQA.

CONCLUSION
These are just some of the most readily -apparent flaws or errors that remain, or that have been added to, this new version of Nexus Study. The City should require its consultant to revisit the Nexus Study and to make the substantial corrections and revisions that are necessary as a matter of law. Fees based on this flawed Study in its current form would likely be declared to be invalid if challenged in the courts.

John R. Gillison
Matthew Burris
May 6, 2025

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We welcome any questions from, or discussions with, the City Staff or the consultants in this regard. Thank you for your consideration of BIA’s concerns and objections.

RUTAN & TUCKER, LLP
Very truly yours,

David P. Lanferman

cc: BIA of So. California

MEMORANDUM

To: Mr. Carlos Rodriguez
Business Industry Association
of Southern California, Inc.

Date: May 5, 2025
From: Keil D. Maberry, P.E., Principal
LLG Engineers
LLG Ref: 2.24.4893.1
Subject:

Peer Review of the Transportation Development Impact Fee (DIF) Program Nexus Study, Rancho Cucamonga

As requested, Linscott, Law & Greenspan, Engineers (LLG) is pleased to provide our review comments o f the Transportation Development Impact Fee (DIF) Program Nexus Study prepared by Fehr & Peers dated February 11, 2025. In particular, this review focuses to the appropriateness and reasonableness of the DIF Project List and Project Cost Estimates contained in Appendix C of the DIF Study and the resultant DIF Program Cost Total presented in Table 14 on Page 26 of the DIF Study. It should be noted, similar to our review of the October 23, 2024 Transportation Development Impact Fee (DIF) Program Nexus Study prepared by Fehr & Peers, it is our finding that this study provides no detailed quantitative nexus analyses associated with the list of DIF improvements contained in Appendix C , which is required by the Mitigation Fee Act.

Based on our detailed review of the DIF Study, we have the following comments with regards to the DIF Project List and Project Cost Estimates and resultant DIF Program Cost Total:
 Active Transportation (AT) related improvements by definition do not specifically improve level of service and do not measurably improve congestion levels to mitigate the impact of new development, which is a necessary nexus required for DIF improvements to be included in the DIF calculation process.

Conversely, the DIF Study does indicate that Active Transportation improvements improve vehicle miles traveled (VMT) within the City as a correlation for applicability to the DIF calculation. However, the relat ive measure of VMT in the DIF study was calculated for the entire City and not specifically for new development, which is contrary to the DIF requirement . Nonetheless, while it is likely that AT improvements would benefit existing and future development, the application of a fair share value would be reasonable in our assertion. With that said, based on the information provided in Table 11 of the DIF study, the forecast growth in total VMT between 2024 and the 2040 Buildout condition is shown at 6.15%. Therefore, we would recommend that only a 6.15% fair share of the AT improvements be applicable to the DIF calculation.

Nonetheless, it is our understanding that the City approved an Enhanced Infrastructure Financing District (EIFD) in 2022, which was intended to cover,

Mr. Carlos Rodriguez
May 5, 2025

among other things, many of the VMT reducing improvements such that these VMT improvements should be eliminated from the DIF list.  Improvements related to safety, such as railroad crossing improvements /grade separations, buffered bike lanes, pedestrian enhancements, curb extensions, traffic signal left- turn phasing improvements , and road diets are not applicable to the traffic impact of new development as the traffic generated by new development does not directly impact traffic safety conditions, such that a nexus finding cannot be made between new development and these safety -related improvements and therefore should be removed from the DIF Study analysis.  The applicability between the proposed bridge widening improvements and enhanced capacity/improved level of service (LOS) therein must be presented in order for a nexus finding to be made, such that merely improving a bridge structure does not improve traffic conditions for new development.  With regards to roundabout improvements, it is not clear whether there is a enhanced capacity/improved level of service (LOS) improvement compared to the existing geometry, such that a nexus finding must be made in order for the proposed roundabout improvements to be applicable.
 The proposed new traffic signal improvements (four locations) are located at intersections with local side street roadways within built out areas, such that the presumed improved level of service from constructing the traffic new signals will not likely benefit new development and it is not clear whether the proposed traffic signals are even warranted under existing or future conditions. In the event that the City provides additional evidence to justify the possible inclusion of Traffic Signals in the “fair share” cost allocation, in our experience the cost estimate for a new traffic signal appears excessive at $750,000, and would recommend a cost of $500,000.
 Improvements related to trail enhancements and trail crossings are not applicable to the traffic impact of new development as the traffic generated by new development does not directly impact traffic safety conditions, such that a nexus finding cannot be made between new development and these safety -related improvements and therefore should be removed from the DIF Study analysis.  The DIF roadway extension improvements are not supported by any nexus analysis within the DIF study, such that it is not clear that any of the roadway extension improvements listed mitigate new development impacts solely because they provide additional roadway capacity within the City. Another factor to consider regarding the applicability of roadway extensions, is the fact that because

Mr. Carlos Rodriguez
May 5, 2025

the proposed roadway extensions are through or adjacent to undeveloped land, new development will be required to construct these roadway extension improvements as Project Features , thus eliminating the need to include them as DIF improvements. As a result, if not eliminated, at most these roadway extension improvement costs should be calculated at the 29.6% new development service population increase based on Table 3 in the DIF study.

 The Signal Interconnect System improvement designated as a Citywide traffic signal communication improvements, in our experience, has shown to marginally improve congestion levels, but is not substantiated in the DIF study.

 With respect to allocation of fair share values to the recommended DIF Improvements, it would be our recommendation to apply the 29.6% service population growth fair share to the “Capacity Enhancing” Improvements, such as street widening, traffic signals and roundabouts, for instance, and apply a 6.15% total VMT growth fair share to the “VMT Reducing” improvements, such as the new bike lanes and AT Projects, for instance. This would be the appropriate application of the nexus between the type of improvement and analysis metric , since both improvement types are represented in the analysis. Furthermore, It could be argued that all transportation projects included in the DIF Improvement list should be based on the 6.15% increase in total VMT between existing and Buildout conditions, since Table 1 in the City’s VMT Thresholds of significance (Resolution No. 2020- 056) explicitly states that Transportation Project impacts are based on total daily VMT.
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We appreciate the opportunity to provide these comments . Please call us at (949) 825-6175 if you have any questions.

Memorandum

To: Carlos Rodriguez, BIA Southern California Chapter
From: Peter Piller
Date: May 6, 2025
Subject: High Level Review of the Revised Rancho Cucamonga Transportation Development Impact Fee Study
CC: Nick Belshe

Carlos,

Per your request, we have prepared this memo summarizing our findings and results of our high- level review of the February 11, 2025, Revised Transportation Development Impact Fee Nexus Study (“Revised Transportation DIF Study”) prepared by Fehr & Peers for the City of Rancho Cucamonga (“City”). The purpose of the review of the Revised Transportation DIF Study is to verify and confirm the assumptions and calculations used in the study, and to make comments as necessary. The primary tasks for our high-level review of the study include the following:

• Confirm mathematical accuracy of schedules in the Revised Transportation DIF Study. • Identify initial issues and comments within the Revised Transportation DIF Study. • Prepare initial bullet point findings and present to BIA and stakeholders.

The observations and results of the tasks performed, and findings are outlined below.

1. Can backup be provided for how the total future trips of 183,433 (from Table 15) was calculated?

2. How can it be justified that new development is required to pay for 46.3% of the $819,668,000 in program costs (excluding DIF Account Balance) when new development only represents 29.6% of the service population at buildout? It seems many of the projects allocated to new development at 100% are either to mitigate an existing deficiency or are not increasing capacity or mitigating new development’s impacts and instead are for beautification or promoting the City’s desire to increase non-vehicle transportation (active transportation).
o As an example, aside from future grant funding, new development is effectively being required to pay for 100% of the Etiwanda Grade Separation Project ($111 million). Within the Revised Transportation DIF Study itself, there is text stating:
“The proposed grade separation of the railroad tracks at Etiwanda has been planned by the City for years. Additionally, it is identified in General Plan Policy

MA-4.5 which states, “Support the construction of grade separations of roadways and trails from rail lines.” This grade separation is needed to support the continuation of land use growth and associated traffic impacts, especially in the Southeast Industrial Quadrant (SEIQ), to maintain LOS goals in the area.” o If this is a project that has been in the works for years, how can it be fully attributed to new development? This project was initially anticipated to be completed by 2022, and while construction hasn’t started, it is still in process.

This seems to indicate that the project would be built even if no further development were to occur. Additionally, this improvement will especially benefit the SEIQ area as defined above, so why is residential development paying into it at the same rate as non-residential?
o Per a Project Baseline Agreement entered into between the City and the California Department of Transportation it is stated that as of July 2018 Etiwanda had a level of service rating of “F” and an ADT of 21,000 vehicles, and there had been 7 train/vehicular accidents resulting in 2 fatalities and injuries. Based on this, it seems like there is an existing need for this Grade Separation so how can the cost be allocated fully to new development?
o It is also our understanding that $60 million in State funding has already been acquired for this project, which doesn’t appear to be reflected in the study. The study also reflects approximately $74 million in “future grant funding”. Should the total grant funding be $134 million?
o Why is Project INT 20 (Citywide Traffic Signal Communication Improvements) being allocated fully to new development when it is a Citywide improvement that would benefit all residents and employees? At most, this project should be allocated to new development at 29.6%. Additionally, how were the costs for this project allocated to each zone?
o Are roundabouts, trail crossings, and buffered bike lanes mitigating the impacts of new development or are these improvements just for beautification and promoting active transportation?

3. It is our understanding that the City formed an EIFD to fund parking infrastructure and related improvements between Haven Ave and Day Creek Blvd along Foothill Corridor and transportation connectivity improvements linking Cucamonga Station and Haven/Arrow focus area in the amount of approximately $60-$100 million in 2022 dollars. Should there be a reduction/adjustment to the project costs to account for this funding? Specifically, projects DTRC1, CC1, CC1.1, and RH6, all of which are related to active transportation on Foothill and Haven

4. How is it possible that of the $819,668,000 in program costs, only $3,943,600 is considered an existing deficiency?
o As an example, and as referenced above, Etiwanda Avenue had a level of service rating of “F” in 2018. There are multiple projects along Etiwanda which leads us to believe that not only should the existing deficiency amount be higher, but that

it is likely there are also additional roadways that are below the desired level of service.

5. Would it make sense to add an additional Eastern zone for the industrial area east of the I-15?
o It is unlikely that residents living in the Southern zone will frequently travel east of the I-15 into the industrial area, yet the Southern zone is being allocated most of the costs for projects east of the I-15.

6. Per Table 10, there will be a reduction in quantity of facilities per 1,000 service population when compared to the existing standard for Roadways, Trails, and Sidewalk Facilities, with Bike Lanes being the only facility to see an increase. o How can it be justified that the proposed improvements are solely mitigating the impacts of new development and not just furthering the goals of the City to promote active transportation when most of the facilities are seeing a decrease compared to the existing standard?

7. Many of the project costs are inconsistent with estimates previously approved by the City and appear to have been largely inflated. Additionally, there is a disconnect in project costs between Table 1 and Appendix B.

8. Is the Grove Ave/4
th Street at I-10 Freeway project already complete? (Project ID F1)

9. If a new development project constructs one of the DIF improvements, how can it be guaranteed that the developer will receive credits/be reimbursed for the full cost of work? We recently ran into a situation where a jurisdiction is claiming they will only credit/reimburse a developer for the percentage of the project costs allocated to new development (29.6% in this case) as they won’t have the funds to reimburse for the remaining percentage of costs that are allocated to existing development, and if they were to do so, they would be taking credits away from other future projects. This effectively told us the jurisdiction is not funding existing development’s share as was stated they would do in the nexus study.

DATE: May 7, 2025
TO: Mayor and Members of the City Council
FROM: John R. Gillison, City Manager
INITIATED BY: Elisa C. Cox, Assistant City Manager
SUBJECT: Consideration to Approve the City Council's Mission, Vision, Values, and 2025 Goals. (CITY)
RECOMMENDATION:

Staff recommends the City Council reaffirm and approve its Mission, Vision, Values, and 2025 Goals.

BACKGROUND:

Each year the City Council engages in team building workshops to review and develop goals and to discuss related legislative matters. On April 8, 2025 the City Council discussed its mission, vision, values, and goals. The Council reaffirmed their alignment with the existing mission and vision, made some minor changes to their values statement, and made recommendations for their 2025 goals.

ANALYSIS:

The following results from the April 8, 2025 team building workshop are presented for formal approval:

Mission
Continuously ensure and advance the quality of life for the community through inclusive decision making.

Vision
To create an equitable, sustainable, and vibrant city, rich in opportunity for all to thrive by building on our foundation and success as a world class community.

Values
•Providing and nurturing an excellent quality of life for all •Promoting and enhancing a safe and healthy community for all •Building and preserving a family-oriented atmosphere
•Intentionally embracing and anticipating our future
•Creating equitable opportunity to prosper
•Working together cooperatively and respectfully with each other, staff, and all stakeholders
•Relentless pursuit of improvement
•Actively seeking and respectfully considering all public input

2 7
9 9
Goals
•By the end of October 2025, bring a project to add lights to the Garcia Sports Field to the City Council for consideration.
•By the end of December 2025, present to the City Council a plan and implementation strategy for workforce development pathways into public service. •By the end of December 2025, present to the City Council concept plans to modernize and expand the public safety facilities at the Civic Center. •By the end of June 2026, complete construction on Phase 2 of ATMS. •By the end of June 2026, finalize the site location and high-level concept design details for the 2nd RCMU substation.

FISCAL IMPACT:

None.

COUNCIL MISSION / VISION / VALUE(S) ADDRESSED:

Annually adopting goals and reviewing the City Council’s mission, vision, and values reflects Council’s commitment to intentionally embrace and anticipate the future.

ATTACHMENTS:

None.