Redlands City Council
February 1, 2022

7.2-12 Lot Consolidation Encourage lot consolidation
to promote affordable
housing development.
10/1/2021 Ongoing The City uses its 5th Cycle
inventory to identify opportunities
for lot consolidation. There are no
dedicated implementation actions
other than maintaining the sites
inventory for lower-income sites.

Continued Appropriateness: Modify
The program was modified to
include more specific actions. See
Program 1.1-9.

7.2-13 Incentive for Private
Land Assembly
Provide an additional
incentive beyond that
provided by the state-
required density bonus.
2/1/2015 City does not have resources
to provide additional
incentives.

No accomplishments. The City was
unable to appropriate or identify
resources to implement this
program.

Continued Appropriateness:

Remove

7.3-1 Continue to Work
with Nonprofit
Organizations to Identify
the Need for Group Homes
and Community Care
Facilities for Individuals
Unable to Live
Independently
Assist in identifying
appropriate sites under the
City's zoning code.
2/1/2015 Ongoing. The City has a list
of sites that it can provide to
service providers.

Implemented.

Continued Appropriateness:

Remove. This is part of standard
operating procedure, code
implementation and standard
business operations.

7.3-2 Continue the Use of
Federal Funding for Very
Low- and Low-Income
Senior and Handicapped
Housing
Assist nonprofit developers
to identify programs and
provide technical assistance
in obtaining funding.
10/1/2021 Ongoing. No accomplishments. It is not clear
that this has been accomplished, or
that there has been interest in this
program. The City has engaged in
an on-call planning consulting
contract that includes grant writing
and application support.

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Continued Appropriateness:

Remove.

7.3-3 Encourage
Congregate Housing
Ensure City policies and
zoning do not hinder such
development.
10/1/2021 Ongoing. No accomplishments. It is unclear if the zoning code would preclude this
type of housing, or if modifications
are necessary to implement this
program.

Continued Appropriateness:

Remove
Unless mandated by state law.

7.3-4 Encourage Single-
Room Occupancy Housing
Encourage the maintenance
and development of single-
room occupancy housing.
10/1/2021 Ongoing No accomplishments. The program
calls for identifying existing
structures and sites, discussing with
developers, and establishing
incentives. It is not clear that these
actions have been taken.

Continued Appropriateness:

Remove

7.3-5 Assist Nonprofits in
Providing Emergency
Shelter Services and
Transitional Housing
Provide emergency shelter
and transitional housing
support.
10/1/2021 As a Participating Jurisdiction
(PJ) in the County of San
Bernardino's Urban County
CDBG program, the City
allocated funds to both
Inland Temporary Homes and
Family Service Association of
Redlands for the purposes of
preventing homelessness
during this reporting period.

Implemented.

Continued Appropriateness: Modify.

See Program 1.2-1. Continued
general support is part of standard
operating procedure, code
implementation and standard
business operation.

In November 2021, the City
approved a contract with two
nonprofits to convert the Good Nite

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Inn, a motel, into a supportive
housing facility.

7.3-6 Continue to
Investigate Participation in
the Permanent Housing for
the Handicapped, Homeless
(PHH) Program
Consider programs in
Redlands.
10/1/2021 City will work with applicants
if an application is received.

Other outreach efforts have
not taken place due to lack of
staff resources.

No accomplishments.

Continued Appropriateness:

Remove.

7.3-7 Promote Housing and
Services for Persons with
Developmental Disabilities
Inform families in Redlands
about housing and services
available for persons with
developmental disabilities.
2/1/2016 Delayed due to lack of staff
resources.

No accomplishments.

Implementation of this program
was affected by staff turnover.

Continued Appropriateness:

Remove

7.3-8 Assess and Address
the Housing Needs of Large
Families and Overcrowded
Households
Determine if overcrowding
is being underreported and
better assess conflicting
information.
8/1/2015 Not completed due to lack of
staff resources.

No accomplishments.

Implementation of this program
was affected by staff turnover.

Continued Appropriateness:

Remove

7.4-1 Update the Zoning
Ordinance to Include
Standards for Congregate
Housing in Medium Density
Areas Designated on the
General Plan Diagram
Give more emphasis and
greater point value to
projects that include
housing affordable to
extremely low-, very low-,
and low-income
households.
10/1/2015 Delayed due to lack of staff
resources.

No accomplishments.

Implementation of this program
was affected by staff turnover.

Continued Appropriateness:

Remove

7.4-2 Continue Giving More
Points to Affordable
Development in the
Residential Development
Allocation Process
Give more emphasis and
greater point value to
projects that include
housing affordable to
extremely low-, very low-,
10/1/2021 Completed and ongoing. The City continued to prioritize the point-based system to lower-income
households until the
implementation of SB 330. Note: SB
330 has invalidated the City’s
Residential Development Allocation

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and low-income
households.
process, both the limitation on
annual permits and the competitive
points process. Barring an
extension by the state, the City’s
RDA process would resume in 2025
and is therefore still relevant to the
6th Cycle Housing Element update.

Continued Appropriateness:

Remove

7.4-3 Evaluate
Development Fees
Give more emphasis and
greater point value to
projects that include
housing affordable to
extremely low-, very low-,
and low-income
households.
02/2015,
ongoing,
biennial
basis.

Completed and ongoing. The City continues to update the impact fees to reflect the current
fair share cost of infrastructure and
services. They were last updated in
2019.

Continued Appropriateness: Modify.

See Programs 1.2-6 and 1.2-14.

The City should consistently
evaluate the existing fees for fair
share costs and consider ways for
fees to be reduced.

7.4-4 Participate in
Establishment of Building
Code
Help ensure unnecessary
costs are not added while
criteria are incorporated to
assist those with special
housing needs.
10/1/2021 Completed and ongoing. The City has adopted the state code building code by reference.

Continued Appropriateness:

Remove
This program can be removed
unless the City makes any
modifications to the code
requirements for the purpose of
making new housing construction
more affordable.

7.4-5 Continue One-Stop
Permit Processing
Streamline the development
process.
10/1/2021 Improvements/enhancements
to the One-stop Permit
Processing are evaluated
The City continues to use its one
stop process.

Continued Appropriateness:

Remove

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annually as part of the
budget process.

This program represents typical
business at the City, and could be
combined with other programs that
encourage permit streamlining.

7.4-6 Maintain Current
Planned Residential
Development Standards
Allow flexible open space
and setback standards.
10/1/2021 Ongoing. Ongoing program; no
accomplishments.

Continued Appropriateness:

Remove
The process of maintaining and
enforcing existing code
requirements should not be
considered a housing program.

7.4-7 Continue to Allow
Mixed Use Zoning
Provide additional incentives
to create housing.
2/1/2017 Ongoing. Staff is currently developing the
Transit Villages Specific Plan, which
will replace the Downtown Specific
Plan.

Continued Appropriateness:

Combine
Combine all programs involving the
Transit Villages/downtown area into
a single program. Recommend
identifying and listing the incentives
referenced. See Programs 1.1-3 and

1.2-12.

7.4-8 Mitigate Finance Costs
for Low-Income Projects
Promote programs that
reduce costs for low-income
projects
10/1/2021 Ongoing. No accomplishments. This program
proved too vague to implement.

This City is implementing multiple
programs to reduce costs for
housing development.

Continued Appropriateness: Modify.

See Program 1.5-10.

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7.4-9 Maintain a Large
Supply of Available Sites to
Maintain Competitive Land
Costs
Ensure competition among
landowners to help maintain
lower land costs.
10/1/2021 Ongoing. The City has maintained sites in
excess of the RHNA requirement.

Continued Appropriateness: Modify.

The City is required by SB 166 to
maintain sites in excess of the
remaining RHNA requirement. The
City has a no net loss program. See
Program 1.1-5.

7.4-10 Continue to Operate
a Fast-Track Development
Process
Reduce processing time by
being flexible on submittal
dates and overlapping
processes.
10/1/2021 Ongoing. Staff continues to implement this
program.

Continued Appropriateness:

Remove.

7.4-11 Evaluate and Revise
Zoning Standards
Reflect current needs. 10/1/2021 Ongoing. Several
amendments were approved
in 2017 and 2018.

Several amendments were made to
the code in the last cycle.

Continued Appropriateness: Modify.

City is implementing a suite of
development constraint removal
programs under Programs 1.2-.

7.4-12 Continue to Evaluate
the Necessity of Amending
the Zoning Code to Raise
the Threshold of Multi-
Family Dwelling Units for
Establishing the
Requirements of a
Conditional Use Permit
Make sure the Conditional
Use Permit (CUP)
requirement does not cause
a potential impediment to
achieving housing goals.
2/1/2016 The City has evaluated this
and has determined that the
CUP requirement has not
been an impediment to multi-
family development.

The evaluation consisted of a
review of all applications for
Multi-Family projects. It was
determined that projects that
proceeded beyond the
completeness review were
unaffected by the
requirement to obtain an CUP
and were subsequently
This has been completed. Staff
determined that the CUP
requirement does not impede multi-
family development.

Continued Appropriateness: Modify.

Addressed in Program 1.2-13
Remove CUP Requirement.

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approved. No multi-family
projects requiring a CUP were
denied.

7.4-13 Change Zoning
Ordinance to Allow Group
Homes of Six or Fewer
Residents (Zoning
Ordinance Change)
Amend the current zoning
ordinance to reflect state
law.
2/1/2016 In process. Implemented.

Continued Appropriateness: Modify.

Program 1.2-5 will review standards
for large group homes of 7 or more
persons.

7.4-14 Socio-Economic
Cost-Benefit Study
Ensure socioeconomic cost-
benefit studies (SECBS) are
not used as a basis for
denying a development
project consistent with the
General Plan and Zoning
Ordinance.
10/1/2021 Ongoing. Implemented. No projects have
been denied on the basis of the
SECBS studies. SECBS standards
are objective.

Continued Appropriateness: Modify.

Program 1.2-8 will review and
revise the SECBS standards for
consistency with SB 330 regarding
objective standards.

7.5-1 Continue Community
Development Block Grant
(CDBG) Program
Be able to support a variety
of programs supporting low-
and moderate- income
households and
neighborhoods.
10/1/2021 During this reporting period
the City was a Participating
Jurisdiction (PJ) in the City of
San Bernardino's Urban
County CDBG and ESG
Programs in order to
continue supporting low- and
moderate-income households
and neighborhoods.

The County implements the
program directly by setting CDBG
funding priorities and creating an
annual strategy.

Continued Appropriateness: Modify.

Program 1.5-10promotes awareness
of available funding.

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7.5-2 Continue Adaptive
Reuse of Single-Family
Homes
Balance the need for more
affordable housing and
housing choice with the
need to preserve Redlands’
traditional appearance and
atmosphere.
10/1/2021 Ongoing. Completed. RMC refers to the
conversion of housing to
commercial uses.

Continued Appropriateness:

Remove.

7.5-3 Continue
Condominium Conversion
Ordinance
Prohibit condominium
conversions unless City
zoning and housing code
standards are met.
10/1/2021 Ongoing. This is an existing code requirement and staff continues to implement it.

Continued Appropriateness:

Remove
Chapter 17.25 of the RMC governs
condominium conversions. The
program essentially results in the
enforcement of the existing
ordinance, which is considered
standard business and not a
housing element program.

7.5-4 Continue Senior and
Handicapped Housing Grant
Program
Use CDBG funding to
provide repair grants to
handicapped people.

None
identified
Ongoing. Discontinued. This program falls
under the category of
Shelter/Transitional Housing in City
records. A total of 168
individuals/households received
shelter/transitional housing
assistance from CDBG funds during
the 5th Cycle. The City will review
Housing Element programs in the
6th Cycle to build and prioritize a
projects list that would be funded
by CDBG.

Continued Appropriateness: Modify.

Program 1.5-10 promotes
awareness of available funding.

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7.5-5 Continue CDBG Rental
Rehabilitation Program
Provide CDBG loans with
deferred repayment for
rehabilitating rental units.

None
identified
Ongoing. City records have been obtained for
CDBG expenditures during the 5th
Cycle. Assistance under the
category of Emergency Food/Rental
Assistance was provided to a total
of 2,442 individuals/households
during the 5th Cycle. See Program

1.5-10.

7.6-1 Buy-Out Assistance
for HUD-Financed Projects
Help prevent below market
rate units threatened with
conversions to market rate.
2/1/2016 Ongoing. It is unclear from City records if this program was utilized. The City
assisted 2,442
individuals/households with
emergency food/rental assistance,
and 169 individuals/households with
shelter/ transitional housing. It is
not known if Program 7.6-1 is
included in those statistics.

Continued Appropriateness: Modify.

Program 1.5-10 promotes
awareness of available funding

7.6-2 Continue to
Implement Regulations to
Promote Mobile Homes
To retain existing mobile
home parks and encourage
new mobile home parks and
subdivisions.
10/1/2021 Ongoing. Implemented. RMC allows new
mobile home parks.

Continued Appropriateness: Modify.

Continue to implement Program

1.5-9 Mobile Home Rent Control
ordinance.

7.7-1 Continue Fair Housing
Counseling
Provide landlord-tenant
mediation and fair housing
counseling.
10/1/2021 The City is a Participating
Jurisdiction (PJ) in the County
of San Bernardino's Urban
County CDBG, HOME, and
ESG Programs. Landlord-
tenant mediation and fair
housing services are available
to Redlands residents from
Implemented via County contract
with the fair housing service
provider, Inland Fair Housing
Mediation Board. City records
indicate 403 households were
assisted.

Continued Appropriateness:

Continue Programs 1.5-7 and 1.5-2.

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the Inland Fair Housing and
Mediation Board.

7.7-2 Disseminate Fair
Housing Information
Conduct public outreach. 10/1/2021 Fair housing and landlord- tenant mediation resource
materials are available at a
variety of public counters at
the City Hall, as well as at the
A.K. Smiley Public Library,
Senior and Recreation
Centers, and City website.

Implemented.

Continued Appropriateness: Modify.

See Programs 1.5-3 and 1.5-4.

7.8-1 Implement
Subdivision Ordinance
Continue subdivision map
review to be consistent with
2002 ordinance
requirements to reduce
residential energy use.
10/1/2021 Ongoing. This program reflects standard
implementation of state law.

Continued Appropriateness:

Remove
Recommend removal because this
is a state requirement.

7.8-2 Encourage Land-Use
Patterns and Densities to
Facilitate Energy Efficient
Public Transit Systems in
New Development Areas
Encourage land-use
patterns and densities to
facilitate energy-efficient
public transit systems in
new development areas.
10/1/2021 This planning concept was
incorporated in the City's
recent General Plan Update
and implementation is in
process. One example is the
Transit Villages Specific Plan
that the City is developing for
the land areas surrounding
three future train stations in
the City.

This program was completed during
the comprehensive General Plan
Update.

Continued Appropriateness:

Remove

7.8-3 Encourage
Neighborhood Services
Retention and Development
Reduce energy consumption
and promote neighborhood
identity.
10/1/2021 Ongoing. It is unclear if the City has adopted revisions to its land use plans to
facilitate and allow for
neighborhood level commercial that
is considered walkable. The General

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Plan does show that there are a few
properties zoned for neighborhood
commercial in single family areas.

Continued Appropriateness:

Remove.

7.8-4 Pursue Energy
Efficient/Alternative Energy
Funding
Increase efficiency and
pursue alternative energy
opportunities.
10/1/2021 Ongoing. The City
participates with the
California Enterprise
Development Authority
(CEDA) and the California
Statewide Communities
Development authority
(CSCDA) and their affiliated
financing partners in offering
multiple programs for
financing energy upgrades
and improvements to
commercial and residential
property owners.

The City offers multiple programs
for financing energy upgrades and
improvements to commercial and
residential property owners.

Continued Appropriateness: Retain.

See Program 1.7-3.

7.9-1 Augment Density
Bonus
To consider incentives
beyond state law.
8/1/2015 Not completed due to lack of
staff resources.

No accomplishments.

Continued Appropriateness:

Remove.

7.9-2 Evaluate Allowing
Residential Uses in C-1
Neighborhood Stores and C-
2 Neighborhood
Convenience Centers
District
Allow residential uses as a
permitted use subject to a
CUP in the C-1 and C-2
zones.
2/1/2016 Delay due to lack of staff
resources.

No accomplishments.

Continued Appropriateness: Modify.

See Programs 1.2-12 and 1.2-13.

7.9-3 Explore Mixed-Use
Development Possibilities
for Redlands Metrolink
Stations
Amend the zoning code to
add residential uses as a
use permitted subject to a
CUP in the C-1 and C-2
zones.
2/1/2017 In progress as part of the
Transit Village Specific Plan
project.

In progress.

Continued Appropriateness: Modify.

See Program 1.1-3.

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7.9-4 Evaluate Initiating a
Ballot Measure to Allow
Carryover of Unused
Building Permit Allocations
from Year to Year
Consider an amendment to
Measure N.
2/1/2017 Not completed. A referendum to modify portions of Measure N failed in the March 2020
primary.

Continued Appropriateness:

Remove

7.9-5 Continue Use of the
Mills Act
Allow for agreements that
provide for reduction in
property taxes in exchange
for continued preservation
of a property.
10/2021 Ongoing. Implemented.

Continued Appropriateness:

Remove. Not relevant to housing
production goals and policies.

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7 AFFIRMATIVELY FURTHERING FAIR HOUSING

7.1 INTRODUCTION
Assembly Bill (AB) 686 requires housing elements to analyze any barriers in access to opportunity and to administer its programs and activities relating to housing and community devel opment in a manner to affirmatively further fair housing. AB 686 asks that a housing element describe population trends and how they may reveal fair housing issues, document trends regarding available housing itself such as year built or overcrowding, and describe improvement goals both for housing condition and for issues relating to fair housing in the population such as patterns of segregation.

7.2 OUTREACH

7.2.1 Outreach Activities
The public participation program engaged community members and stakeholders using the following methods:
 Project website
 Social media postings
 Ads on the Redlands Daily Facts
 Online community survey (in English and Spanish)
 Stakeholder interviews
 Focused AFFH surveys to stakeholders and service providers  Two virtual community workshops
 Two study sessions with the Planning Commission
 One study session with the City Council
The City experienced difficulty in obtaining responses from local stakeholders and service providers.

Repeated calls and emails to the Inland Fair Housing Mediation Board (the County’s contracted fair housing service provider that serves Redlands) over the course of many months provided limited information. Other local providers, including those that receive CDBG funding, have yet to respond to the City’s AFFH focus survey after three separate requests. However, open-ended questions were included in the public housing needs survey, to which the City received over 300 responses. Some of the respondents commented on discrimination or housing challenges experienced by the mselves or people they know.

This feedback was used in the identification of issues in the community and the creation of the City’s proposed Housing Programs.

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City staff maintain a mailing list of individuals interested in the Housing Element update to inform them of all outreach activities. Additionally, City staff continues to maintain a comprehensive Housing Element update web page and answer inquiries that arise regarding the H ousing Element update, including participating in ongoing discussions with a ffordable housing developers who may be interested in pursuing projects in the City. The full summary of community engagement activities and outcomes of outreach and survey results are included in Appendix C.

The City provided a community update on the revised housing draft before the Planning Commission hearing on December 14, 2021, and accepted public testimony . The draft element was made public on December 21, 2021, prior to resubmitting to HCD and prior to adoption by the City Council in February 2022.

7.2.2 Organizations Contacted and Consulted
 San Bernardino County Transportation Authority (SBCTA)  Inland Fair Housing and Mediation Board
 California Department of Fair Employment and Housing
 Office of Fair Housing and Opportunity
 Redlands Unified School District
 San Bernardino County - Homeless Partnership Interagency Council on Homelessness  Redlands Area Interfaith Council
 Northside Redlands Visioning Committee
 Family Service Association of Redlands
 East Valley Association of Realtors
 Building Industry Association
 Inland Housing Solutions
 Inland SoCal United Way
 University of Redlands Facilities Management
 Redlands Chamber of Commerce

7.2.3 Summary of Comments
Those who attended the community workshops described five of the most prominent issues pertaining to housing in the City as:
 Cost of housing

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 Insufficient housing supply
 Homelessness
 Ability to purchase a home
 Proximity to jobs
The public requested transit accessibility and housing near rail stations, extending beyond the university.

This desire for increased transit accessibility also made evident a desire for more density.

Industry stakeholders identified churches, malls, and the “donut hole ” as potential sources for infill and land to increase low -income and affordable housing. 19 Density may require rezoning to multifamily residential or the use of unique housing accommodations like accessory dwelling units (ADUs). There is also a continued request for increased density near transit stops, as well as for housing to be built not just anywhere, but in underserved communities so people may continue to live in their community and not have to leave to gain access to affordable housing. Stakeholders had some concern with public perception of infill, but the public involved in the engagement opportunities agreed on the need for increased density to meet housing needs.

The respondents identified low -moderate income person(s), families with children under the age of 18, homeless persons, disabled persons, and people of color as the most vulnerable populations. The public also identified the following programs that they would consider most beneficial to the City:
 Permit streamlining.
o The following programs improve permit streamlining:
o 1.1-4 By-Right Approval, 1.1-8 Development on Non-Vacant Sites; 1.1-9 Lot Consolidation and Small Site Development; 1.2-8 and 1.2-9 Ballot Measures; 1.2-10 Objective Design Standards; 1.2-12 Mixed-Use in Commercial Zones; 1.2-13 Remove CUP Requirement for Height; 1.2-14 Waive preapplication fee for affordable projects.  Preapproved ADU plans.
o Programs 1.6-1 through 1.6-4 include pre-approved plans and other incentives.  Inclusionary housing.
o Program 1.3-2 addresses development of an inclusionary housing program.  Reduced parking and landscape requirements.
o Programs 1.1-9 and 1.2-7 addresses revisions to the parking standards.  Financial resources such as down payment assistance and rental assistance.

19 The “donut hole” refers to a well- known area within the City limits that is entirely unincorporated and under the land use authority of the County of San Bernardino.

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o Program 1.5-10 regarding notice of funding availability for nonprofit housing development
 Placement of affordable housing near amenities (i.e., grocery stores, transit, community and emergency services).
o Programs 1.1-1 RHNA Rezoning, 1.1-3 Transit Villages Specific Plan both recommend new high density and affordable housing in areas with excellent access to transit, services, public and private institutions, employment and existing and planned urban amenities.

A more in-depth summary of comments received is available in Appendix C.

7.2.4 Public Participation
The multifaceted community engagement process had meaningful input and guidance from a broad cross section of the Redlands community. This began with a new page on the City website detailing the Housing Element update, followed quickly by an online survey in both English and Spanish. One -on-one stakeholder interviews provided a venue for detailed and insightful discussion and recommendations from a broad spectrum of perspectives including service providers, building industry, housing advocacy groups, community service organizations, real estate agents, and educational institutions. These stakeholders also effectively drove constituents to the online survey. There were nearly 300 respondents to the online survey before the first virtual community workshop in April 2021. Survey respondents had high rates of completion of questions including housing needs, constraints, and recommended actions and programs. A second virtual community workshop was held in May 2021.

Due to the COVID -19 pandemic, the two community workshops were held virtually, which may have increased access for those who no longer had to commute to engage, but also may have caused a barrier to access for those with limited computer access or knowledge. To this end, the City provided toll -free call-in numbers for those who may not have ready access to a smart phone or computer. Workshops were hosted on weekdays at 6 :00 p.m., which may have overlapped with work hours for some community participants. Concern about the rapidly spiking pandemic may have also overshadowed the Housing Element update. Another significant factor is the relative broad satisfaction and lack of concern over housing issues among the majority of Redlands residents. The vast majority of households in Redlands own single-family homes, are not suffering significant housing burdens, and are therefore less likely to participate in workshops that do not affect their needs directly. This is evident in the nature of the comments received from participants in the workshops, survey, and stakeholder interviews.

Additionally, the City has performed regular social media postings to inform residents about the Housing Element. The City also maintains a mailing list of interested individuals. Members of the mailing list were notified prior to each community, Planning Commission or City Council meeting. The City has also been fielding questions about the Housing Element from the public and from affordable housing developers throughout the duration of the Housing Element update process.

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7.3 ASSESSMENT OF FAIR HOUSING

7.3.1 Fair Housing Enforcement and Outreach Capacity
The City of Redlands works with the nonprofit Inland Fair Housing and Mediation Board (IFHMB), which provides information, investigation, education, conciliation, and referral of housing discrimination complaints as it relates to fair housing. Enforcement comes overall, with assistance from IFHMB, from the national Office of Fair Housing and Opportunity (FHEO) and the California Department of Fair Employment and Housing (DFEH). The City refers all fair housing concerns to the IFHMB. 20 There have been 17 total inquiries with 2 fair housing complaints forwarded to FHEO, 0 fair housing complaints forwarded to DFEH, and 0 fair housing complaints forwarded to IFHMB. Of the two complaints, one was on the basis of disability and one was on the basis of national origin. One case was not pursued further and the other was ruled to have no valid basis. Redlands’ local fair housing agency, IFHMB, provides fair housing services, landlord/tenant and mobile home mediation, housing counseling, alternative dispute resolution, and senior services. Over the 5
th Cycle planning period, the agency responded to 127 complaints within the City of Redlands. Of these, 99 were on the basis of disability, 6 were each on the basis of race, sex, and familial status, 3 were on the basis of age and income, 2 were each on the basis of national origin or were arbitrary. The IFHMB conducted 292 engageme nts throughout the City during the 5 th Cycle planning period.

The agency is available for contact by phone or email. In-person office visits are closed due to the COVID- 19 pandemic. As of 2018, IFHMB employs 22 staff members who receive updated fair housing training on a quarterly basis with 5 staff members who are heavily trained on HCD AFFH requirements to maximize capacity to respond to fair housing needs. The IFHMB is funded by Community Development Block Grants, donations, and sponsors.

The City provides Fair Housing information on its website including information on the HOME Affordable Housing Program, Tenant -Based Housing Choice Voucher Program, Project -Based Voucher Program, Term-Limited Lease Assistance Program, and Home Ownership Assistance Program. The City provides contact information for the Housing Authority of San Bernardino County and contacts for emergency housing assistance.

The City’s Police Department also periodically conducts Crime -Free Multi -Housing/Rental Property Training programs. This is an eight -hour course that focuses on education and reducing crime in apartments, condominium complexes, and single -family rental housing throughout the City by emphasizing communication with property managers, tenants, and police. Since 1995, the Redlands Police Department has participated in the San Bernardino County Crime -Free Multi -Housing program. The opportunity exists to integrate Fair Housing information into these trainings.

20 The City of Redlands has made several attempts between May and August 2021 to obtain data from the IFHMB and has notified HCD of the difficulty in obtaining this data. The IFHMB has acknowledged the request, but no data has been transmitted at the time this AFFH appendix was authored.

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7.3.2 City and Sites Overview
AB 686 also requires that the Housing Ele ment distribute sites identified to accommodate the lower - income RHNA in a manner that furthers fair housing and does not concentrate them in low-resource areas.

For a complete assessment of the City’s obligation to affirmatively further fair housing, an analysis of the RHNA sites and their impact on fair housing conditions is provided. RHNA sites are shown on a selection of maps by their income level. Additionally, a comparison of the RHNA units by their income level is provided against that of the whole City acreage. Note that these bar graphs do not include pending projects. The City anticipates its above- moderate RHNA units to be satisfied using entirely pending projects, so the bar graphs show the few additionally identified above moderate sites. This does cause a skew in the appearance of the graphs as they show all the identified moderate and lower income units.

While this helps to illustrate fair housing patterns across the City, not all land in the City is suit able for additional housing. Specifically, much of South Redlands (generally, south of Highland Avenue) is located within and adjacent to a Very High Fire Hazard Severity Zone coupled with steep slopes (in excess of 15% cross slope) that are regulated by t he Hillside Development District (This district is discussed in detail in Section 4.1). This area also lacks sidewalk infrastructure and public transportation connectivity due to the topographical constraints. This increased risk of fire hazards combined with poor mobility options results in this portion of South Redlands not being suitable for higher density development. The area of South Redlands north of Highland Avenue is generally flat terrain developed within a traditional street grid complete with s idewalks and some public transportation connectivity, particularly along Barton Road/Brookside Avenue/Citrus Avenue. The City has encouraged the adaptive reuse of large Victorian era homes in this area as apartment conversions through the application of the R-2 (Multi-family residential district) in the core of this northern portion of South Redlands.

The sites inventory was developed to maximize opportunities for households of all income levels while recognizing and accounting for environmental constraints. The City has prioritized sites in areas served by existing infrastructure, with access to employment centers such as Esri, the University of Redlands, public and private K-12 schools, Loma Linda University Medical Center and the industrial/warehouse district in northwest Redlands. As discussed in the Sites Inventory, RHNA sites can be analyzed in four general clusters, the TVSP Area, EVCSP Area, Tri-City Center Development, and other sites.

Figure 7-1 shows the census tracts in Redlands and divides the City into four geographic regions with similar trends for the purposes of the AFFH analysis. The accompanying Table 7-1 displays the census tracts and their given region. A brief overview of geographic trends and sites within each geographic area are discussed in the breakdown below.

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FIGURE 7-1: CENSUS TRACTS, RHNA SITES, AND CITY REGIONS

Source: American Community Survey 2019 5-Year Estimates

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TABLE 7-1: CENSUS TRACTS AND CITY REGION
Census Tract Region
6071007604 North/West
6071007800 North/West
6071008100 North/West
6071007302 South (rural)
6071008200 South
6071008301 South
6071008302 South (hills)
6071008403 South
6071008500 South (hills)
6071007904 North/East (open space)
6071008001 North/East
6071008401 North/East
6071008402 North/East
6071008601 North/East
6071008602 North/East
6071008706 North/East
6071008002 Downtown/Central
6071008404 Downtown/Central
Source: American Community Survey 2019 5-Year Estimates

7.3.2.1 Northwest and Census Tract Outliers
The northwest area of the City includes three census tracts around the “donut hole” in the City. The “donut hole” is the unincorporated area surrounded by the City. This includes census tract 06071007800, which is shown in detail in Figure 7-2. This large census tract covers the northwest corner of the City that repeatedly shows up in maps as an outlier. However, this tract is fully developed for warehouse and industrial uses to the north of Interstate 10. This tract also includes the western portion of the City, on the south side of I -10, where there are existing non -conforming single -family residences, several apartment complexes, townhomes, and small lot subdivisions. As there is little to no housing in significant portions of this census tract, mapped data may be skewed.

The EVCSP consists of a large portion of this census tract and portions of the ones to the east. RHNA sites identified in this area are within the EVSCP. The sites are largely vacant, underutilized, or agricultural uses which are candidates for rezoning to accommodate capacity for low and moderate income sites. Sites in the EVCSP were selected due to their location near to regional job centers and the future Metrolink/Arrow light rail stations.

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FIGURE 7-2: CENSUS TRACT 06071007800 AND THE EVCSP

Source: City of Redlands

7.3.2.2 South Redlands
The southern portion of the City comprises predominantly single-family homes and a significant amount of open space. Demographically this part of the City is 21-40 percent non-white. These tracts have many large lots and a significant amount in the southerly hills. Older neighborhoods to the south of downtown are more dense than hilly neighborhoods further to the south. This area has positive TCAC scores with a high number of higher-income, married family households. There are some above moderate-income sites in South Redlands. Large portions of the area do not have access to adequate sewer and are located in a very high fire hazard zone. South Redlands has very few underutilized and appropriately sized sites that meet state criteria for lower- income, multi-family residential RHNA sites . Program 1.6-1 is included to incentivize and encourage ADU and SB 9 development within these areas.

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7.3.2.3 Downtown and Central North Redlands
The downtown/central area of the City includes the University of Redlands and the area of high segregation and poverty. The tract is highly developed but has poor TCAC scores and the highest number of adults living alone with no children. This area will benefit the most from the TVSP which covers 931 aces and is shown in Figure 7-3. Sites of all income levels are included in the TVSP area. The TVSP is an opportunity to increase regional access to transit and provide transit-oriented development within the plan area. The new transit opportunities connect the region to downtown Los Angeles and with the rest of the Los Angeles metropolitan area and serve as critical smart growth opportunities. The plan will provide significant investment to the lower-resource areas in the City.

The City is already seeing developer interests in this area as a result of the rail stations nearing completion, with the following projects having been submitted:
• Redlands Mall Redevelopment: A proposal to redevelop the Redlands Mall site on approximately

11.15 acres with a mixed -use project that includes residential and commercial uses within five new multi-tenant buildings, to include the following:
o Demolish existing on-site buildings and improvements. o Construct five mixed-use buildings up to four (4) stories high. o Construct up to 681 multifamily dwelling units (apartments and condominiums), to include studio, one -bedroom, two -bedroom, and three -bedroom, and live/work units ranging between 475 and 1,500 square feet each.
o Construct a 6,000 square-foot recreational amenity building including pool. o Construct up to 73,000 square feet of commercial floor area on ground floors to include retail and restaurant uses, as well as a rooftop restaurant. o Construct up to 12,222 square feet of office space on upper floors. o Construct a pedestrian plaza totaling approximately 22,742 square feet on Third Street. o Construct a five-level aboveground parking structure with 780 spaces. o Construct two subterranean parking garages.
o Construct public and private open space areas to include landscaping, shade trees, street trees, and pedestrian improvements; and
o Construct related site improvements to include sidewalks, driveways, landscape, lighting and streetlights, storm drains, flood prevention features, and public and private utility connections.

• The Grand Apartments: A proposal to:
o Merge 14 existing parcels into one parcel, approximately 1.48 acres in size. o Construct a 149 -unit multi -family apartment complex, with 25,964 square feet of common open space area.
o Amendment to the existing Specific Plan to allow for height averaging, when determining the maximum building height, and amend the parking requirement for multi -family residential uses to 1 space per unit and 1 guest space for every 4 units.

• City Center Apartments : The project is a proposal to construct a mixed -use development consisting of a 138 -unit apartment complex and three restaurant buildings. All three restaurant pads are approximately 3,500 square feet in area and located in the southeast corner of the

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property. As proposed the apartments are four stories tall and constructed over two floors of parking. One floor of parking is below the ground surface.

In addition to the above proposed residential projects, the City has realized significant commercial and quality of life investments in the area surrounding the downtown rail station. The following projects have either been recently constructed, are under construction, or have received entitlement approval:

• Redlands Food Hall: The rehabilitation and adaptive reuse of the Mutual Orange Company Packing Plant to establish a multi- tenant food hall including food retail, farmer’s market, restaurants, demonstration kitchen, and similar retail uses.

• Escape Craft Brewery: The rehabilitation and adaptive reuse of the City Transfer and Storage Company Warehouse to establish a locally owned and operated craft brewery and restaurant.

• J. Riley Distillery : The construction of a new restaurant building and adaptive reuse of a former auto repair shop into a distillery to house a locally owned and operated distiller.

• Redlands Garage: The construction of a four -deck parking garage to service the Metrolink platform and nearby businesses. The parking garage includes a ground floor retail component, public art installations, common open space, and electric vehicle charging.

• 3
rd Street North Retail Building: Construction of a three-story retail/office building adjacent to the rail line and Redlands Garage. The building is connected to the garage by two pedestrian bridges on the second and third floors.

• Santa Fe Depot and Old Chamber of Commerce Buildings: The restoration of the Santa Fe Depot as the Arrow light rail downtown station. The adjacent Old Chamber of Commerce building is undergoing adaptive reuse as a food retail concept with outdoor common open space.

• 3
rd Street South Retail Buildings: Construction of two single-story retail buildings adjacent to the rail line and the Santa Fe Depot as part of a transit-oriented development concept.

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FIGURE 7-3: TVSP AND RHNA SITES

Source: City of Redlands

7.3.2.4 Northeast Redlands
The northeast area is generally high resource and has similar trends to the south area of the City. It consists of mostly single-family homes that are slightly denser than the southern region, with some commercial nodes along primary corridors. Program 1.6-1 is included to incentivize and encourage ADU and SB9 development within these areas. There are two moderate and two lower income sites in the southwest portion of this area. The northernmost portion of the City is open space and is constrained by the Redlands municipal airport. The area south of that contains a brand new, recently constructed subdivision, leading to increased incomes and housing prices in this area.

7.3.2.5 Findings from 2020 Regional Analysis of Impediments to Fair Housing Choice The City of Redlands participated in the San Bernardino County Analysis of Impediments to Fair Housing Choice (AI) for program years 2020-2025. The AI provides an analysis of the regional fair housing landscape focusing on four main issues of integration and segregation, areas of poverty, access to opportunity, and

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housing need. The AI process included significant public outreach across jurisdictions in San Bernardino County. As a result of the analysis, the AI identified five impediments to fair housing, their contributing factors and recommended actions to take to address them. 21 The housing impediments identified by the
AI include:
 Disparate access to opportunity impacts people of color o Low school proficiency disproportionately impacts Black, Latino, and Native American Residents
 Insufficient affordable housing in areas of high opportunity disproportionately impacts protected classes
 Levels of residential segregation are increasing
 Community education on fair housing is a continuing need  People with disabilities have limited housing options

7.3.3 Integration and Segregation Patterns

7.3.3.1 Race and Ethnicity
The City of Redlands has seen a growth in the overall non- White population, as the City has grown since the previous Housing Element cycle. Figure 7-4 displays the racial and ethnic groups that make up the majority of the population by census tract. Most of the City is majority White by a slim or sizable gap, with the exception of three census tracts that have a non -White Hispanic majority. As the City is 32% non - White Hispanic, this indicates a concentration of the Hispanic population in the downtown census tracts.

The tracts with a s lim or sizeable gap that are majority Hispanic are located in the central and northern area of the City. These areas are identified in the City’s 2035 General Plan Figure 1 -3: Planning Subareas as Lugonia (area east of Highway 210) and West End (area west of Highway 210).

In the 1960s, the central area that is now the downtown area of Redlands had the most racial diversity.

Racial covenants maintained the south and east of the City as majority White. The southeast city still has a predominant white majority.

Regionally, most of San Bernardino County’s population is heavily concentrated in the southwest corner of the County. While most of the County has a majority non-Hispanic White population, the western areas of the County have a similar profile to the City of Redlands with areas that are majority non-White Hispanic population clustered among the majority White areas. The County experienced growth in the overall non- White population. The distribution of the White and Hispanic populations throughout the I nland Empire is relatively even, while the High Desert and Morongo Basin have a larger White population. Redlands has a slightly lower non -White Hispanic population than the Co unty, at 32 percent and 42 percent respectively. The AI found that changes in racial and ethnic composition across the County since 1990

21 San Bernardino County Analysis of Impediments to Fair Housing Choice. Pg. 150.

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have resulted in a more diverse but less integrated population countywide.22 The areas with the sizeable Hispanic popula tion also have the most housing choice voucher use and a lower environmental opportunity score. Alternatively, predominantly white areas have higher incomes, education opportunity scores, and economic opportunity scores.

FIGURE 7-4: RACIAL AND ETHNIC MAJORITY, 2010, REDLANDS

Source: HCD AFFH Mapping Tool.

Figure 7-5 shows the RHNA sites and the percentage of each census block group that is non -White. The figure shows that the minority populations have increased over time. There is no specific block group that saw a disproportionate increase in minority populations compared to others. The northern and western areas see higher concentrations of minorities than the eastern and southern parts of the City.

Trends in Redlands align with regional trends in San Bernardino County of increases in non -White populations. The 2020 San Bernardino County Analysis of Impediments to Fair Housing Choice reports

22 San Bernardino County Analysis of Impediments to Fair Housing Choice, pg. 36:
http://www.sbcounty.gov/uploads/cdh/reports/SanBernardinoCountyAI_Final_0410%20with%20Appendix.pdf.

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that the Hispanic population in the County increased in population share by 20 percent in the last two decades.23
RHNA sites are spread throughout the City and there are sites of each income level in areas with a higher minority concentration. The sites are focused in areas with the capacity and potential for growth.

23 San Bernardino County Analysis of Impediments to Fair Housing Choice:
http://www.sbcounty.gov/uploads/cdh/reports/SanBernardinoCountyAI_Final_0410%20with%20Appendix.pdf.

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FIGURE 7-5: RHNA SITES AND NON-WHITE POPULATION (2010 AND 2018)

Source: HCD AFFH Mapping Tool.

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The accompanying chart in Figure 7-6 displays the comparison of RHNA units by income level and the total City acreage that is in each quartile. The sites are generally dispersed by income level across categories. The lower income sites are not concentrated in any one category. About 80 percent of RHNA units are in areas where there are 40–80 percent non-White populations. Currently, Redlands is 72 percent White and 32.7 percent Hispanic. While there is a disparity between sites and acreage in areas with 20-40 percent non-White population, large portions of this land are open space and not suitable for future development, including the 200-acre San Timoteo Nature Sanctuary and Herngt ‘Aki’ Preserve.

FIGURE 7-6: RHNA UNITS BY INCOME AND CITY ACREAGE COMPARISON BY NON -WHITE

POPULATION

Source: HCD AFFH Mapping Tool and City of Redlands
One metric used to quantify segregation is the dissimilarity index. The dissimilarity index measures th e distribution of two groups in a city and assigns a score between 1-100. Level of segregation is determined by assessing what percentage of residents of a census block would have to move for each block to have the exact same population of said group. The City’s goal is a low dissimilarity index which indicates high integration. The formula for this calculation is provided by HCD’s AFFH Guidance Document.24 The categories for a dissimilarity index (shown as percentages) as defined by HCD are as follows:
 < 30: Low Segregation
 30-60: Moderate Segregation

24 AFFH Guidance for All Public Entities, pg. 67
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
20-40% 41-60% 61-80% 81-100%
% of RHNA Units or City Acreage
% of the Population that is non-White
Lower Moderate Above Moderate City Acreage

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 > 60: High Segregation
Table 7-2 shows the dissimilarity index between the White, non-Hispanic population and various minority populations in the City in 2013 and 2019. The table indicates that the dissimilarity index is decreasing or static over time except for the index for the Black, non -Hispanic and White non- Hispanic groups. This decrease in the segregation index for other populations is likely in part due to the increasing Hispanic population in the City. The index for the Non -White, non -Hispanic and Hispanic/White, non -Hispanic populations is 35. This is slightly lower than the index for San Bernardino County, which is at 40.

TABLE 7-2: DISSIMILARITY INDEX, RACE, 2013 AND 2019
Group 1 / Group 2 2013 2019
Non-White/White 39 35
Hispanic/White 43 39
Black/White 53 58
Asian /White 45 45
Source: American Community Survey 2013 and 2019 5-Year Estimates (B03002).

When comparing the Hispanic and White populations using the dissimilarity index, the result is a score of 39 in 2019, which is a moderate level of segregation. This result is explained by the existence of the high segregation and poverty neighborhood with a sizeable Hispanic majority in the northern area, as shown in Figure 7-4. The sizeable Hispanic majority area continues beyond the City boundary into the area surrounding the San Bernardino Airport.

The indexes of dissimilarity for Black and White populations and Asian and White populations are 58 and 45, respectively. This equates to an upper moderate level of segregation between Black and White populations and a moderate level of segregation between the Asian and White populations. Redlands’ Black and Asian populations respectively only make up 5.4 percent and 8 percent of the total population.

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7.3.3.2 Income
In 2019, the m edian income in the City of Redlands was $74,839. In 2019, the median income in San Bernardino County was $63,362. While the median income for the City trends similarly to the County, the higher-income southern tracts of Redlands skew the median income slightly higher than in the surrounding region.

FIGURE 7-7: MEDIAN INCOME, 2015 - 2019

Figure 7-8 displays the RHNA sites by their income level and the percentage of residents in each census block group that falls into the low- and moderate-income category. The areas with the highest populations of low to moderate income have a variety of sites in each income category. The income groups in the City of Redlands are relatively segregated, with the lowest percentage of low- to moderate-income located in the southeast swath of the City, where there is a country club / golf course, and high number of single - family homes. The sizes of homes and lot sizes in the south region tend to be larger th an those in the north/east and downtown/central regions of the City, and the cost of housing in the south region tends to be higher compared to the north/east and downtown/central regions. The south region is also the same area that has a predominant White majority.

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The area with the highest percentage of the population in the low- to moderate-income range is the census tract in the northwest corner (this tract is discussed in Section 7.3.2 as an outlier), where there are also a number of agricultural jobs supporting Redlands’ citrus industry, however, it is important to note there are nearly no housing units in the area north and west the “donut hole” (unincorporated County pocket). There is some housing south of the donut hole, the only area in this tract zoned for residential use is south of I-10 on the western edge of the City.

The westernmost part of this upper corner has a slim White majority, but in the more central edge of the northwest corner the map shows an area of high segregation and poverty, where 50 -75% of the population is in the low - to moderate-income range. This area’s income demographic is comparable to other areas in the City of San Bernardino, especially around the airport, but is ultimately relatively isolated compared to its surroundings. T he area around the donut hole is almost exclusively industrial or commercial, with very few people living there. Therefore, the area surrounding the donut hole does not have a concentration of people as the map suggests.

The accompanying chart in Figure 7-9 displays the percentage of RHNA units by income level compared to the City acreage by block group of the percentage that is low to mo derate income. The low- and moderate-income units are largely divided between the 25 –50 percent and 51–75 percent categories.

Many of the areas shown as < 25% low -moderate income are within the very high fire hazard severity zone or constrained by the Redlands Regional Airport. Over 60 percent of RHNA units are in areas where 25–50 percent of the population is low to moderate income.

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FIGURE 7-8: RHNA SITES AND LOW-MODERATE INCOME POPULATION (2011-2015)

Source: HCD AFFH Mapping Tool.

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FIGURE 7-9: RHNA UNITS AND CITY ACREAGE BY BLOCK GROUP COMPARISON BY LOW TO

MODERATE INCOME

Figure 7-10 displays the percentage of households whose incomes are under the federal poverty level in each census tract from 2010-2014 and 2015-2019. Redlands has low levels of poverty throughout the City except in the central census tract, which has poverty levels from 30 percent to 40 percent. In San Bernardino County, 13.3 percent of the population is below the poverty line. The change over time shows that poverty in the western and north- central census tracts has decreased, while the rest of the City mostly stayed in the same category. Using the dissimilarity index to compare low - to moderate -level incomes with above-moderate incomes in the City yields a result of 41. This level of segregation is likely due to the divide between the southern and northern halves of the City. The southern half of the City has a high-income population with less than 25 percent of residents falling in the low - to moderate-income category. This area also contains hillside preservation areas and other conserved open space and single - family homes. The northern half of the City varies in income level, with s ome downtown areas reaching 50 to 75 percent of the population being in the low - to moderate-income category. This area surrounds downtown and the university. The difference in demographics between the north and south contributes to the income dissimilarit y index of 41. This indicates a moderate level of segregation among high - and low-income levels in Redlands. The dissimilarity index comparing low - to moderate-income with above- moderate income in the Co unty yie lds 21 .7, indicating a low segregation of inc omes and revealing Redlands’ higher levels of income segregation compared to the region as a whole. The presence of the University of Redlands likely provides an explanation for much of the lower -income clustering in these tracts. Many university students are not employed full time or are employed in lower-paying jobs ; the high concentration of university students is a reason that these tracts have more low- moderate households. Additionally, areas around the university have a zoning designation of R -1-D (Single Family Residential). This designation permits lots of a certain depth to have two primary residences ; however, because of lot configuration, these units tend to be smaller than typical primary residences.

While increasing lower-income housing in the southern areas of the City would lower the dissimilarity index, the southern, suburban area of the City is not the most accessible place for low income or

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affordable housing to be. There is a lack of transit in this area, and the suburban neighborhoods make the development of low-income housing difficult and expensive.

FIGURE 7-10: POVERTY STATUS, 2010-2014 AND 2015-2019
Source: HCD AFFH Mapping Tool.

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The housing choice voucher program is the federal progr am for assisting very low -income, elderly, and disabled families and individuals in affording decent housing by subsidizing rent costs and paying landlords directly for a portion of the rent. Eligibility is based on family size and whether income is less t han 50 percent of the area’s median income.

Figure 7-11 reveals trends in where housing choice voucher recipients reside in the City of Redlands. The map reveals a concentration of housing choice voucher users north of downtown above I -10 with some use downtown and in the area of high segregation and poverty.

Housing choice vouchers make up a higher percentage of rental units in these areas as well, in addition to some presence in the southwest corner of the City. Higher use of vouchers in these areas is due to the availability of appropriate housing types like affordable rental units maintained by private owners. There are three housing developments partially managed by the Housing Authority of San Bernardino County that are located north of I -10: Redlands Housing Community, Vista Del Sol, and Valencia Grove. This relative concentration may explain the increased prevalence of housing choice voucher use in central Redlands.

The areas with little to no identified use of housing choice vouchers are predominantly single -family homes. Countywide, similar trends are found where denser areas have more rental units and more housing choice voucher recipients.

F
IGURE 7-11: LOCATION OF HOUSING CHOICE VOUCHERS, 2010, REDLANDS

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7.3.3.3 Familial Status
In a large majority of the City, less than 20 percent of the adult population lives alone, except in the downtown City center hub as well as the University of Redlands, where students may be living in atypical housing, and where 20–40 percent of adults live alone, as shown in Figure 7-12. Regional trends indicate similar levels of the population living alone across neighboring jurisdictions and the entirety of San Bernardino County.

FIGURE 7-12: PERCENTAGE OF ADULTS LIVING ALONE, 2015-2019 REDLANDS

Source: HCD AFFH Mapping Tool.

The area where a larger percentage of the population lives alone is also, as expected, the area where the lowest percentage of adult residents lives with a spouse, as shown in Figure 7-13.

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FIGURE 7-13: PERCENTAGE OF ADULTS LIVING WITH SPOUSE, 2015-2019, REDLANDS

Source: HCD AFFH Mapping Tool.

The area with the highest percentage of the population living with a spouse corresponds with the wealthiest corner of the City, the southeast corner. There are also more children living with married couples in that southeast portion of the City, as shown in Figure 7-14. This area is farther from downtown, is lower density, and features mostly single-family residential homes.

Compared to the region as a whole, the majority of the City matches trends in surrounding cities where in the majority of the area about 40 –60 percent of adults live with a spouse, with some sparse neighborhoods where under 40 percent live with a spouse. The southeast portion of Redlands stands out in this regard—at over 60 percent of adults living with a spouse, it is comparatively high.

Figure 7-14 displays the percentage of children that are living in married couple households in each census tract. The area with the highest percentage of children in married-couple households correlates with the highest percentage of spouses living in the same household. The areas surrounding the university and downtown have few individuals under 18 years of age, just as they had a low number of spouses living together and a high number of people living alone. The discrepancy in the trends that these data sets

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reveal is that the northwest corner of the City has a low percentage of spouses living together, but a higher percentage of spouses with children that live together, as shown by Figure 7-14. This means that spouses living together in other areas are less likely to have children than those spouse couples in the northwest corner. Although there are few spouses living together in the northwest corner, the few that do are highly likely to be living with children.

Regionally, trends shown in Figure 7-14 continue beyond the bounds of the City, with Loma Linda and Highland having the highest percentage of children in married couple households, matching the adjacent areas of Redlands.

F
IGURE 7-14: PERCENTAGE OF CHILDREN IN MARRIED-COUPLE HOUSEHOLDS, 2015-2019,

REDLANDS

Source: HCD AFFH Mapping Tool.

Throughout the City, there are very few female- headed households with children, as revealed by Figure 7-15. Exceptions include the central portion of the City which sees from 40 percent to 60 percent of children in female-headed households and one tract just below the central tracts (06071008002). There are two census tracts with 20–40 percent of children in female-headed households.

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FIGURE 7-15: PERCENTAGE OF CHILDREN IN FEMALE-HEADED HOUSEHOLDS, 2015-2019,

REDLANDS

Source: HCD AFFH Mapping Tool.

7.3.3.4 Persons with Disabilities
The US Census defines a person with disabilities as someone who reports as having a hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self- care difficulty, or independent living difficulty. Approximately 12 percent of the population in the City of Redlands has a disability, and 48 percent of the disabled population has an ambulatory, or walking, difficulty.

Compared to other characteristics of disabilities, such as a hearing or vision difficulty, a walking difficulty can pose a need for specialized housing, such as a single-story unit or immediate adjacency to transit—a need that may increase with a larger population. Additional adaptations, depending on level of mobility, may include wheelchair access, larger homes for live-in help, or proximity to health facilities.

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TABLE 7-3: DISABILITY CHARACTERISTICS
Characteristic 2010 2019
%
Change
Persons with Disability 7,184 8,235 15%
Percentage of Population with Disability 10.49 11.66

Disability Type by Age Group:

Hearing Difficulty 2,018 2,623 30%
Under 18 Years 113 97 -14%
18 to 64 Years 523 757 45%
65 Years and Older 1,382 1,769 28%
Vision Difficulty 1,453 1,046 -28%
Under 18 Years 164 28 -83%
18 to 64 Years 606 684 13%
65 Years and Older 683 334 -51%
Cognitive Disability 2,579 3,529 37%
Under 18 Years 360 429 19%
18 to 64 Years 1,385 1,994 44%
65 Years and Older 834 1,106 33%
Ambulatory Difficulty 3,684 3,924 7%
Under 18 Years 88 38 -57%
18 to 64 Years 1,570 1,586 1%
65 Years and Older 2,026 2,300 14%
Self-Care Difficulty 1,454 1,736 19%
Under 18 Years 109 152 39%
18 to 64 Years 617 690 12%
65 Years and Older 728 894 23%
Independent Living Difficulty 2,987 3,508 17%
Under 18 Years - - -
18 to 64 Years 1,367 1,815 33%
65 Years and Older 1,620 1,693 5%
Source: American Community Survey 2010 and 2019 5-Year Estimates.

An equitable distribution of health -oriented community facilities and services, including recreation centers, medical facilities, and youth centers, helps ensure the well-being of residents. Figure 7-16 shows the RHNA sites and a relatively equal distribution across the City of individuals with disabilities.

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FIGURE 7-16: RHNA SITE DISTRIBUTION AND POPULATION WITH A DISABILITY (2015-2019) Source: HCD AFFH Mapping Tool.

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Redlands is home to, or adjacent to, numerous care facilities including Redlands Community Hospital, Kaiser Permanente, Beaver Medical Group, and Loma Linda University Behavioral Medical Center, and these health care facilities are well distributed throughout the City . Overall, Redlands is well served by healthcare facilities, and there are no major clusters of the City without access to care.

The accompanying chart in Figure 7-17 displays the breakdown comparison of RHNA units and the City acreage among the percentage of the population with a disability. There is no census tract with greater than 20 percent of the population having a disability. RHNA sites of all income levels are spread throughout the City. Sites are not overly concentrated in areas that have either high or low percentages of the population with a disability.

F
IGURE 7-17: RHNA UNITS BY INCOME AND CITY COMPARISON BY DISABILITY STATUS

Source: HCD AFFH Mapping Tool and City of Redlands.

7.3.3.5 Findings
Overall, there are clear geographic patterns emerging, as evidenced in the university, downtown, and the southeast portions of the City. The university and downtown areas have substantial numbers of unmarried, childless people, living alone with lower incomes which is consistent with the existing land uses of the University of Redlands and older single - and multifamily housing stock in these areas . This central area also has a predominantly Hispanic population. In comparison, the southeast section of the City is a wealthy, mostly White, single-family area, consisting primarily of married couples with children.

Existing land uses in this area consist primarily of post 1950s single -family dwellings on larger lots and in higher elevations (foothills). These trends of wealth, race, and marital status are not unique to the City and persist throughout the San Bernardino County region as discussed in the AI.

Contributing factors to fair housing issues pertaining to segregation patterns include the concentration of minority populations downtown, the concentration of available and appropriate housing for housing 0%
5%
10%
15%
20%
25%
30%
35%
40%
10 - 15% 15 - 20%
0% 0% 0% 51%

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choice vouchers, and the north/south segregation by race and income. These factors will be addressed by the City with actions such as those outlined in Programs 1.5-1, 1.1-3, 1.2-14, 1.5-8, 1.5-10, and 1.3-2:
- Placed Base Improvements
- Transit Villages Specific Plan
- Waive preapplication fee for affordable housing projects - Residential Development in High Opportunity Areas NOFA/Nonprofit Housing Development - Inclusionary Housing Ordinance

7.3.4 Racially & Ethnically Concentrated Areas of Poverty and Racially Concentrated Areas of Affluence
HUD defines a Racially and Ethnically Concentrated Area of Poverty (R/ECAP) as an area where the percentage of the population that is non -White is over 50 percent and the percentage of median household incomes below the poverty line is over 40 percent. R/ECAPs are often the focus of fair housing policy, but Racially Concentrated Areas of Affluence (RCAA) must be considered as well when attempting to eliminate areas of segregation. Overall, in the City of Redlands, the percentage of the population that is White is trending downward while the median household income is trending up. There are no R/ECAPs or RCAAs in Redlands. The sites inventory will not contribute to the creation of a R/ECAP.

Figure 7-18 shows the RHNA sites in the City and R/ECAPs in the vicinity of the City of Redlands. There are 19 R/ECAPS in San Bernardino County, most of which are located in the City of San Bernardino. There are no R/ECAPs in the Ci ty of Redlands. The nearest R/ECAP is northwest of Redlands in the City of San Bernardino, where there are some disparities in access to opportunities. The remaining R/ECAPs are in Barstow, Colton, Grand Terrace, Adelanto, and El Mirage.

Although there are no R/ECAPs, the City of Redlands does have an area of high segregation and poverty per the TCAC opportunity composite scores. The area is in the City’s downtown surrounding the University of Redlands and has a sizeable Hispanic majority. The tract is highly developed but has poor TCAC scores and the highest number of adults living alone with no children. Contributing factors to the areas of high segregation and poverty include the older housing stock and buildings in the tract, limited housing opportunities for higher density and more affordable housing elsewhere in the City, and higher air pollution and diesel particulate pollution due to the proximity of I -10. While the current Downtown Specific Plan permits housing in this area and the City has seen some incremental improvements, this area will benefit from the Transit Villages Specific Plan (TVSP) as it will significantly expand opportunity for transportation, as well as increase housing near existing and future job opportunities. Additionally, the City is expanding its multi-family zoning in areas outside of this tract, providing new opportunities for high quality, affordable housing in new locations in the City.

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FIGURE 7-18: RHNA SITES AND R/ECAPS (2021)

Source: HCD AFFH Mapping Tool.

In addition to R/ECAPs, RCAAs should be examined to ensure fair housing choice. Per HCD’s AFFH Guidance document, a Racially Concentrated Area of Affluence ( RCAA) is an area with a population that is greater than 80 percent White and has a median household income level over $125,000.25 There are no RCAAs in Redlands meeting this definition as the City has no areas where the percentage of the population that is White is over 79 percent. In fact, there are no RCAAs in San Bernardino County meeting this definition.

The area around the Redlands Country Club in the southeast portion of the City is trends the closest to an RCAA, with a median household income level over $125,000 and a White population between 60 percent and 79 percent. Large parts of the southernmost areas of Redlands consist of agriculture zoning. South Redlands does have higher levels of non-Hispanic white population and higher incomes as shown in Figure 7-19.

25 Affirmatively Furthering Fair Housing: Guidance for All Public Entities and for Housing Elements (April 2021 Update).

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There are similar trends of northeast Redlands showing higher income levels and a population that is between 60 and 75% non -White. Census tract 06071007904 which has a portion in northeast Re dlands, has a median income of $145,409; however, this tract has no housing within the City and data for the tract reflects recently constructed subdivisions in the neighboring jurisdiction of Highland. The area of this tract within Redlands is zoned entirely for open space. The areas north of Santa Ana River in the City are all zoned for open space and have no housing within them. The rest of the northeast portion of the City , south of Santa Ana Creek has experienced significant growth in single family development, primarily through Planned Residential Developments . The cost of these newer single family housing units has increased rapidly with the boom in the housing market resulting in a consolidated area of higher housing costs.

While not formally an RCAA, relative to the rest of the City these areas are whiter and more affluent.

Development of affordable units is unlikely in these areas due to single -family homes being the primary residence and HOA restrictions. Encouraging new development allowed by SB 9 and increased ADU construction, as outlined by Program 1.6 -1, can increase affordable rental units in these areas and diversify the region.

FIGURE 7-19: MEDIAN INCOME AND PERCENT NON-WHITE AND RHNA SITES

Source: HCD AFFH Mapping Tool.

7.3.5 Disparities in Access to Opportunity
California Tax Credit Allocation Committee (TCAC) Opportunity Areas One tool used to analyze disparities in access to opportunities is the California Tax Credit Allocation Committee’s (TCAC) Opportunity Area Scores. These were prepared by a task force commissioned by the TCAC and HCD to identify areas statewide whose economic, educational, and environmental characteristics support positive outcomes for low -income families. The tool is update d annually.

Opportunity maps are made for three domains: economic, environmental, and education. Each map uses

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several indicators to determine their individual score. A composite score and resource designation combining the three categorical scores is assigned to each block group.

To determine final resource category, the top 20 percent of overall scores in a county are labeled as highest resource and the next 20 percent of scores are labeled as high resource. Then, any areas that are considered segregated and that have at least 30 percent of the population living below the federal poverty line are labeled as an area of High Segregation and Poverty. Any remaining uncategorized areas in the County are evenly divided between moderate resource and low resource areas.

Education
Education indicators for the TCAC include math proficiency, reading proficiency, high school graduation rates, and student poverty rates. Figure 7-20 displays the TCAC education scores for Redlands. Most of the City has positive educational outcomes. The wealthiest areas of the City of Redlands, consisting of the southern section of the City, has the most positive educational outcomes, while the most highly segregated area have middle to high positive educational outcomes. The area with the least positive educational outcome is of moderate diversity and above moderate income. There does not seem to be a correlation between protected groups and proficient and less proficient schools. After requesting further information on disparities between schools in the area from the Redlands Unified School District, it was emphasized that resources are eq uitably distributed across the district with no disparities that are not actively addressed.

The area with the lowest education score is the northwestern part of the City. It has a high percentage of households with low to moderate income and a high average number of children per household.

Overall, the Redlands Unified School District has an average GreatSchools rating compared to other districts in the state. The ratings are based on academics, equity, and the school environment compared to other public schools in the state. Schools in the northern parts of the City have higher overall scores, while schools around downtown are rated below -average in quality. As public schools receive support from local taxes, these schools may have less resources to provide students with educational support.

Additionally, the downtown area of the City has more children in single parent households than the southern area of Redlands, therefore working parents may not have as much time to provide study support for work outside of the classroom. There are less schools in northwest Redlands, but this area is also majority industrial sites with very few residences.

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FIGURE 7-20: TCAC EDUCATION SCORE, 2021, REDLANDS

Source: HCD AFFH Mapping Tool.

Economic
Economic indicators for TCAC scores include poverty, adult education, job proximity, employment, and median home values. The economic scores for Redlands are shown in Figure 7-21. All of Redlands has a generally positive economic outcome score except for two census tracts in the center of the City. These two tracts have less positive economic outcome scores of 0.22. This is the area of hig h segregation and poverty. The next lowest census tract score in Redlands is 0.68.

The central tracts with scores of 0.22 may have skewed scores due to being occupied by the University of Redlands and therefore having a disproportionately high number of stu dents who are more likely to be unemployed. These tracts also include the Sylvan Mobile Estates, Orange Grove Mobile Estates, and Redlands Ranch mobile home parks as well as two affordable housing developments operated by the San Bernardino County Housing Authority. This area has concentrations of multi- family development and historically lower priced housing opportunities leading to an area with lower incomes. Both census tracts have a high number of lower -income individuals but also a high number of job opportunities at the

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University, Esri campus, the Post Office, the retail and service industry in both downtown Redlands and in the “donut hole”, and Redlands Unified School District. There may still be low economic outcomes in the two identified tracts as many of these jobs require formal background or education.

The San Bernardino County Transportation Authority Regional Assessment of Fair Housing notes that across San Bernardino County, economic opportunity is higher in the East and West Valley and Mountain subregions and lower in the Morongo Basin and Desert Subregions. 26 It lists the Cities of San Bernardino, Rialto and Fontana as those with lower economic opportunity in the region.

FIGURE 7-21: TCAC ECONOMIC SCORE, 2021, REDLANDS

Source: HCD AFFH Mapping Tool.

Employment
The areas with the lowest median household incomes and highest percentage of non -White population have the closest proximity to jobs and employment, as shown by Figure 7-22, while the wealthier, more suburban areas have the lowest proximity in the City. This implies there is not much disparity in access to

26 San Bernardino County Transportation Authority, Regional Assessment of Fair Housing, August 2021 Draft.

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jobs by protected groups. Importantly, the area considered by TCAC to be “High Segregation and Poverty” has some of the best access to jobs of all types, including high -tech, service, agricultural, and retail industries. Central Redlands has excellent access to Esri and the University of Redlands , which are high quality employers. Additionally, these areas have access to major employers immediately outside of the City boundary, such as the Loma Li nda University and Medical Center, and multiple logistics/industrial facilities in the unincorporated donut hole.

The area in the southeast of the City contains hilly terrain and is currently zoned for single -family residential, is almost entirely built -out with single -family neighborhoods, and the lack of commercial, professional, or industrial space can be one reason for the lack of job proximity. The community input received for this cycle indicated that residents felt that limited transit is affecting access to employment and requested that the TVSP area provide sufficient housing to increase the number of residents with excellent access to transit. The compact mixed -use villages centered around the three new Metrolink/Arrow passenger light rail stations of the TVSP will improve access to jobs in this area by increasing density near transit as well as increasing transportation services.

F
IGURE 7-22: JOB PROXIMITY INDEX, 2014-2017 REDLANDS

Source: HCD AFFH Mapping Tool.

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Environmental
The TCAC environmental score is based on CalEnviroScreen 3.0 pollution indicators and values.

Environmental scores are lowest (worst) throughout the middle section of the City and are higher (better) on the north and south ends. The lowest (worst) environmental scores are seen on the border of Loma Linda and San Bernardino.

Overall, Redlands achieves less favorable TCAC scores for environmental conditions than it does for economic and education opportunities. This is largely explained by air quality pollution from I-10, SR 210, large logistic and distribution uses in and around the donut hole and airport. Some of these effects are mitigated by the strong economic and educational resources of Esri and the University of Redlands. These areas also correspond with the areas with lower incomes, higher rates of poverty, racial and ethnic segregation, and single-parent households.

The downtown/central area census tract (06071008002) is in the 91 st percentile for communities in the
State that are disproportionately burdened by multiple sources of pollution. The northwest second census tract (6071007800) is in the 73rd percentile, which is very close to the 75th percentile threshold to require preparation of an Environmental Justice Element.

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FIGURE 7-23: TCAC ENVIRONMENTAL SCORE, 2021, REDLANDS

Source: HCD AFFH Mapping Tool.

CalEnviroScreen
CalEnviroScreen 4.0 is a tool that identifies communities in California that are affected by pollutants and polluting factors such as ozone, particulate matter, drinking water contaminants, pesticide use, lead, toxins, diesel particulates, traffic density, cleanup sites, groundwater threats, hazardous waste, solid waste, and impaired water bodies. A higher score indicates a higher effect of pollutants on the indicated area. RHNA sites and the CalEnviroScreen 4.0 scores for Redlands are shown in Figure 7-24.

A high CalEnviroScreen 4.0 score indicates high pollution. Scores are on a scale of 0 -100. Therefore, an area with a score in a high percentile, such as the areas around the donut hole that have scores between 71 and 80, has high levels of pollution from ozone, diesel matter traffic, or drinking water contamination.

If an area is in the top 25% of CalEnviroScreen scores, the city must include environmental justice goals in its General Plan.

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The lower half of the City, which is predominantly white families, has the lowest scores in the City of Redlands, with a middle range of scores from 21% -60%. The mid -range scores extend through the northeast corner of the City. The area around the “donut hole” in the northwest corner of the City has a higher score of 71% -80% due to high ozone, diesel particulate matter, traffic, and drinking water contaminant scores. These scores can be attributed to the location central to major Highways 10 and 210, as well as the San Bernardino Airport, which lead to ozone and diesel particulate matter contaminated air from vehicle emissions. Additionally, this neighborhood is primarily industrial, with a large number of warehouses and distribution facilities. The location directly east of the airport is in the 91% -100% score range, which may also be explained by the high ozone levels that comes with adjacency to a commercial airport. The City is also a location for four Superfund sites:
 Lockheed Propulsion Co., 1500 Crafton Avenue, northeast portion of the City  Redlands Airport, 1745 Sessums Drive, northeast portion of the City  Redlands Shooting Park, 2125 Orange Street, north-central portion of the City  Redlands Smudge Pot Tanks Site, 100 Feet West of Redlands Boulevard and Texas Street, central portion of the City
Neither information on the type of contaminants nor the status were available. None of these Superfund sites are within residential zoning districts.

In recent years, the City has required air quality and health risk assessments be prepared for residential or educational fac ility projects within 500 feet of major arterials, highways, or interstates. In these scenarios, the City has required high efficiency particulate air filters with a Minimum Efficiency Reporting Value (MERV) of 13 or better, which is the highest end of the MERV range.

The area with the highest score, in the 91%- 100% range, is the area of high segregation and poverty in central Redlands, including downtown and the university areas. Much like the area near the airport, this tract earns its high score from ozone and diesel particulates in the air from industrial uses and traffic on Highway 210 and I -10. This area may have a higher score than the northwest, as poverty is a factor in CalEnviroScreen 4.0, and this area is specifically labeled as high poverty.

Figure 7-24 displays the RHNA sites by income level and CalEnviroScreen 4.0 percentiles scores. The accompanying chart in Figure 7-25 displays the percentage of RHNA units and City acreage that fall into each percentile group of the CalEnviroScreen 4.0 scores. Almost 50% of RHNA units are located in an area that is in the 70
th to 80th percentile of CalEnviroScreen 4.0. However, despite the poor CalEnviroScreen scores, these areas have the best long -term opportunities and access to transit, employment, services, and supporting infrastructure. Transit improvements and investments may lower traffic and pollution scores in the areas. The massive investments in the three new Metrolink stations and the TOD planned as part of the TVSP will ensure that these areas will have among the best quality of life in the area.

Environmental concerns, primarily air quality pollutants from the freeways and San Bernardino Airport can be mitigated with high efficiency HVAC filtration that ensures excellent indoor air quality.

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Comparatively to the region, Redlands has higher CES 4.0 scores than jurisdictions to the west and south, such as the City of San Bernardino, Colton, and parts of Riverside county, which all have high CES 4.0 percentile scores in the 80s and 90s . It scores similarly to jurisdictions to the east, such as Yucaipa and unincorporated areas of San Bernardino County.

FIGURE 7-24: RHNA SITE DISTRIBUTION AND CALENVIROSCREEN 4.0 (2021)

Source: HCD AFFH Mapping Tool.

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FIGURE 7-25: RHNA UNITS BY INCOME AND CITY ACREAGE BY CAL ENVIRO SCREEN 4.0

PERCENTILE

Source: HCD AFFH Mapping Tool and City of Redlands.

Table 7-4 provides additional details on the CES 4.0 scores for each census tract. The census tracts are shown with their population, CES 4.0 percentile score, TCAC opportunity category, and selected categories from the CES score of pollution percentile, poverty percentile, and traffic percentile. These factors are some of those that vary widely across the City and show the differences in environmental hazard exposure between the tracts. As shown in the map above, tracts in the southern and northwestern area have the most positive CES 4.0 scores.

There are three tracts are 6071007200, 6071007604, and 6071008002 that fall above the 90th percentile range. These are low resource and the area of high segregation and poverty. These areas are within the TVSP. These areas are classified as disadvantaged communities and would be the areas subject to an Environmental Justice Element to address the needs of these areas.

TABLE 7-4: CES 4.0 SCORES BY CENSUS TRACT
Census Tract Population
Cal Enviro
Score
Percentile
Pollution
Percentile
Poverty
Percentile
Traffic
Percentile Opportunity Category
6065042412 5129 39.0 31.7 27.0 20.3 Moderate Resource
6065043822 2689 71.6 74.6 44.5 32.3 High Resource
6065043823 7023 44.1 51.0 16.9 50.9 Highest Resource
6071007200 6798 92.3 96.8 85.8 80.1 Low Resource
6071007302 10039 55.4 84.1 23.8 27.0 Moderate Resource
6071007306 5859 32.1 79.7 54.5 35.7 Moderate Resource
6071007604 4306 91.2 93.5 52.4 54.3 Low Resource
0%
10%
20%
30%
40%
50%
60%
30 - 40
40-50
50 - 60
60 - 70
70 - 80
80 - 90
90 - 100
13%

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Census Tract Population
Cal Enviro
Score
Percentile
Pollution
Percentile
Poverty
Percentile
Traffic
Percentile Opportunity Category
6071007800 4912 73.2 95.0 58.4 81.0 Low Resource
6071007904 6697 49.2 48.6 17.9 12.6 Highest Resource
6071008001 6513 69.0 62.7 40.6 71.6 High Resource
6071008002 7256 90.4 88.1 95.6 80.0 High Segregation and Poverty
6071008100 3182 67.5 71.6 75.8 32.1 High Resource
6071008200 5147 29.5 44.9 49.2 6.7 High Resource
6071008301 6340 41.7 45.7 28.3 7.1 High Resource
6071008302 3106 20.6 38.4 13.4 4.5 Highest Resource
6071008401 9953 33.3 37.0 38.0 14.9 High Resource
6071008402 6448 35.0 22.5 38.4 9.2 High Resource
6071008403 5833 24.8 53.4 14.0 69.6 Highest Resource
6071008404 2729 66.8 56.4 92.5 73.8 Moderate Resource
6071008500 8316 42.2 83.3 12.8 69.5 Highest Resource
6071008601 5618 50.7 47.5 45.7 6.6 High Resource
6071008602 3564 46.7 51.5 37.0 6.4 High Resource
6071008706 12298 31.9 60.8 22.1 65.0 High Resource
Source: CalEnviroScreen 4.0
Composite Scores
Figure 7-26 displays the TCAC composite score for Redlands. Composite scores vary throughout the City, with higher resources on the northern and southern portions of the City. There is one tract with high segregation and poverty in the center of the City. Tracts on the west side of the City are identified as low resource areas. Contributing factors to the areas of high segregation and poverty include the older housing stock and buildings in the tract, limited housing opportunities for higher density and more affordable housing except in these areas, and higher air pollution and diesel particulate. The single-family housing stock in this census tract is not dissimilar in age, type, and size as the housing stock in the south- central portion of the City; however, the south -central portion of the City has several locally designated historic districts and individually designated historic structures. The City’s policies on historic preservation and the application of historic district designations to the south portion of the City has resulted in better maintenance and higher desirability. While a historic resources survey of housing stock north of I-10 found that the north-central area was eligible for local historic district designation, this area has no protections

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or guidelines for historic structures. This dichotomy of historic preservation application can be attributed to the north -central portion of the City having greater rehabilitation and maintenance needs, thus contributing reduced desirability.

In the Inland Empire as a whole, just over 9% of the tracts have high segregation and poverty, including the areas surrounding the San Bernardino Airport, adjacent to the City of Redlands.

The four environmental, education, economic, and composite TCAC scores are shown in Table 7-5 for each census tract. The two lowest scoring tracts are in the downtown/central and northwest areas. One tract (06071008002) is identified as high segregation and poverty, the second census tract identified as low resource. It includes the donut hole that is not within City boundaries. Two tracts are moderate resource, one of which is east of the tract that is high segregation and poverty. Additionally, the tract in the southwestern corner of the City is moderate resource ho wever, the majority of this tract lies in the City of Loma Linda. The rest of the tracts in Redlands are high or highest resource.

TABLE 7-5: OPPORTUNITY MAP SCORES AND CATEGORIZATION, 2021 Census Tract
Economic
Domain
Score
Environmental
Domain Score
Education
Domain
Score
Composite
Index Score Final Category
06071007800 0.61 0.01 0.53 0.38 Low Resource
6071007901 0.85 0.74 0.81 0.61 Highest Resource
06071007903 0.81 0.66 0.81 0.55 Highest Resource
06071007904 0.90 0.45 0.81 0.59 Highest Resource
06071008001 0.59 0.37 0.60 0.04 Moderate Resource
06071008002 0.09 0.26 0.53 N/A High Segregation &
Poverty
6071008100 0.66 0.37 0.79 0.30 High Resource
06071008200 0.85 0.62 0.77 0.51 Highest Resource
6071008301 0.84 0.54 0.80 0.52 Highest Resource
06071008302 0.94 0.71 0.77 0.66 Highest Resource
06071008401 0.78 0.62 0.63 0.27 High Resource
6071008402 0.62 0.75 0.74 0.33 High Resource
06071008403 0.90 0.57 0.83 0.65 Highest Resource
06071008404 0.17 0.54 0.72 0.07 Moderate Resource
06071008500 0.98 0.29 0.90 0.85 Highest Resource
Source: California Fair Housing Task Force; TCAC/HCD Opportunity Maps, 2020 Statewide Summary Table, December 2020.

The City has prepared a draft Transit Villages Specific Plan (TVSP) that is currently undergoing environmental review and is anticipated to be heard for adoption in mid-2022. The TVSP would establish a policy environment promoting transit -oriented development (TOD) around three Metrolink / Arrow

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passenger light rail stations that have been recently constructed and are presently undergoing testing for live operation in 2022. These stations are located at the Esri campus, downtown Redlands Santa Fe Depot, and the University of Redlands. The combination of the transit stations, complementary and mixed land uses, and new TVSP and/or development code updates promoting TOD will attract investment, opportunity, and resources to the areas of the City in most need.

The TVSP is a place -based investment in central Redlands. The TVSP will not cause any displacement, as the areas surrounding the specific plan area are largely nonresidential; any residential areas nearby were not included in the plan in order to prevent d isplacement. Redeveloping the area to transit -oriented- development will only benefit the area and increase opportunity, not cause any displacement.

Figure 7-26 displays the RHNA sites by income level and TCAC composite score by census tract . The accompanying chart shown in Figure 7-27 displays the percentage of RHNA units by income and percentage of the City acreage in each TCAC opportunity designation. One census tract falls into the high segregation and poverty category, and slightly less than 20% of units are lo cated in the tract. Just under 50% of units are located in the low resource category. Though much of the City is in the highest resource category, the highest resource areas in the south part of the City are not suitable for moderate - or high- density housing. It includes areas of open space and with topographic challenges to development in the southeast portion of the City. Sites that are located in high resource areas include a mix of anticipated income levels. The highest resource designated areas, the so uth part of the City, do not have access to downtown and employment centers via public transportation.

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FIGURE 7-26: RHNA SITES AND TCAC COMPOSITE SCORE (2021)

Source: HCD AFFH Mapping Tool.

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FIGURE 7-27: RHNA UNITS BY INCOME AND COMPARISON BY TCAC COMPOSITE CATEGORY

Source: HCD AFFH Mapping Tool and City of Redlands.

Though the RHNA sites are concentrated in areas that have lower TCAC designations, they are located in areas suitable for further development in the City. Many RHNA sites are located in the TVSP area, the TVSP is anticipated to attract investment and increase access to resources in the downtown area of the City. RHNA Sites are located in areas with access to public transit and downtown resource and services.

The sites are not expected to have an adverse effect on access to opportunities but rather improve and revitalize access to opportunities in the areas of the City with lower TCAC designations.

7.3.5.1 Opportunity Indicators Regional Comparison
Table 7-6 compares access to opportunities between Redlands and San Bernardino County as a whole.

These indicators are based on HUD’s set of opportunity indices. In many of the indicators, Redlands scores are close to the County as a whole. Redlands has a higher rate of poverty among Native American and Alaska Natives and Native Hawaiian and Other Pacific Islanders. These two groups combined make up less than 2% of the population in Redlands.

Redlands has a lower percentage of Title I Schools in comparison to the County. A Title I school is a school in which children from low -income families make up at least 40% of the enrollment. Title I schools are eligible to use federal grant funds to help meet the educational needs of students.

Compared to the region, downtown Redlands and the TVSP area has excellent access to employment , transportation, and education opportunities. The new li ght rail represents a regional opportunity to increase equity and provide climate-friendly housing growth and development. 0%
10%
20%
30%
40%
50%
60%
High Segregation & Poverty Low Resource Moderate Resource High Resource Highest Resource Lower Moderate Above Moderate City Acreage

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TABLE 7-6: ACCESS TO OPPORTUNITY INDICATORS – CITY AND COUNTY Indicator Redlands San Bernardino County
Poverty Rate
Population Below Federal Poverty Level 11.2% 13.3%
White alone 8.7% 10.3%
Black or African American alone 17.9% 20%
Native American and Alaska Native alone 18.1% 9.5%
Asian alone 8.5% 7.7%
Native Hawaiian and Other Pacific Islander
alone

53.4% 24.9%
Hispanic or Latino 15% 14.3%
School Proficiency
Total Title I Schools 17 472
Total Schools 26 558
% of Schools 65.4% 84.6%
Unemployment Rate
February 2021 4.8% 8.6%
Transit Metrics
All Transit Performance Score 6.0 4.4
Transit Trips Per Week within ½ Mile 1,534 1,098
Jobs Accessible in 30-Min Trip 43,978 44,660
Commuters Who Use Transit 0% 1.6%
Transit Routes within ½ Mile 2 3
Source: 2020 Regional Analysis of Impediments to Fair Housing Choice; California Department of Education Public Schools and Data File February 2020; California Employment and Development Department, Labor Force and Unemployment Rate for Cities and Census Designated Places, February 2021; https://alltransit.cnt.org/metrics/, accessed July 20, 2021; CalEnviroScreen 3.0 Results (June 2018 Update).

Sum does not equal 100 due to rounding.

Transportation
Omnitrans is San Bernardino County’s public transportation system that serves the San Bernardino Valley.

Services include 27 routes including buses, bus rapid transit, and paratransit. Of the three Omnitrans bus routes that operate in the City, only one reaches the area with low educational outcome, and there is little to no transit service available within that northwest wing of the City. This may affect access to education, but the degree of inaccessibility portrayed by Figure 7-20 may be misleading as there are few residences in the primarily industrial area north of the I-10.

Compared to the County as a whole, Redlands scores slightly higher in transportation metrics; however, the region as a whole scores low in transportation metrics. The AllTransit Performance score is measured

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on a scale from zero to ten, with ten being the highest score. Redlands scores a 6.0 on this scale, compared to the whole County, which scores a 4.4. The addition of three new Metrolink & Arrow passenger light rail stations for downtown, the Esri campus, and the University of Redlands will dramatically improve transit service and usage in Redlands and is expected to be a major factor and catalyst in the future growth and economic development of these areas and the entire City of Redlands via the proposed TVSP. The areas around each of the three new Metrolink & Arrow passenger light rail stations will feature and promote compact, urban, walkable mixed -use redevelopment of new housing, services, and employment opportunities that will form an attractive urban core and a full range of new housing op tions for all household types and incomes. The new investment and development will include new amenities, services, and businesses that will serve and improve the quality of life for existing and new neighborhoods, visitors, employees, and residents of Redlands.

San Bernardino County’s public transportation system is Omnitrans, which services the San Bernardino Valley. Services include 27 routes including buses, bus rapid transit, and paratransit. Of the three Omnitrans bus routes that reach the City of Redlands, only one reaches the area with the highest percentage of people in the low to moderate income level and a sizeable Hispanic majority. Generally, transit routes follow east -west corridors along Lugonia Avenue and Citrus Avenue/Brookside Avenue/Barton Road. North-south transit is located along Orange Street/Cajon Street. Both these routes connect to downtown; however, these routes do not reach beyond these corridors to communities and first mile/last mile connectivity remains an ongoing issue. SBCTA recently completed a Station Access Plan to study connectivity in proximity to the train stations, and the City of Redlands recently completed a Sustainable Mobility Plan to study pedestrian and bicycle connectivity throughout the city including to the train and transit stations.

Tracts in the southwest portion of the City have higher percentages of disabled persons and are not served by public transit , except for along the Brookside Avenue/Barton Road corridor. Block groups with the highest percentages of non-White populations and female householders, as well as highest percentages of populations with low to moderate incomes, are located near transit corridors along Orange Street and Lugonia Avenue, yet first mile/last mile connectivity remains an ongoing issue.

The area with the worst job proximity also has the highest median income, so although they will have increased transportation costs in the form of necessary car ownership, this subset of the population will generally not be overly affected by the excess costs. Transit use is, long term, cheaper than automobile use, and walkable areas eliminate transportation costs all together.

The San Bernardino County Transportation Authority (SBCTA) recently completed construction of a new passenger rail line connecting Redlands to the Metrolink system and is establishing a new light rail system called the Arrow light rail, which is the catalyst for the proposed TVSP in Redlands. The project has constructed three new train stations in Redlands in areas of concentrated employment opportunity and activity. The stations are located adjacent to Esri’s headquarters at Redlands Boulevard &New York Street, in the center of downtown at the historic Santa Fe Depot, and adjacent to the University of Redlands campus at University Street & Park Avenue. The new Metrolink/ Arrow light rail stations will create direct and efficient connections to major regional destinations such as the San Bernardino Metrolink station,

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which connects to downtown Los Angeles, Riverside, and Santa Ana. The Metrolink/ Arrow light rail is expected to begin service in 2022.

The public requested to SBCTA transit accessibility and housing near rail stations, extending beyond the university. This desire for increased transit accessibility also made evident a desire for more density. To maximize ridership on the Metrolink/ Arrow light rail service, the City is updating land uses around the planned stations. The implementation of the TVSP around the university, downtown, and Esri campus will significantly increase housing and employment opportunities in these areas. Importantly, the stations and the TVSP will contribute to the revitalization of downtown and increase investment and resources in the tract classified as having patterns of high segregation and poverty. Much of the land around the three station sites is either vacant or underutilized, and primed for transit-oriented infill development.

The goal of the TVSP is to transform vacant and underutilized parcels within one -quarter mile of each station into a lively, transit -oriented neighborhoods. Tree -lined streets and sidewalks provide safe and convenient access to the station, the Esri campus, and downtown. Greens and neighborhood parks create open, accessible, fresh -air spaces for both residents from surrounding multifamily buildings as well as nearby office workers. Buildings accommodate housing for a variety of income levels and family types, including parents with children and seniors. It will enable employees of Esri and other local businesses and institutions to live in Redlands. The downtown station area is intended to be a walkable mixed -use district of pedestrian -scaled blocks, beautiful tree -lined streets with comfortable seating and exterior dining and inviting squares and plazas. Surface parking lots are infilled with urban buildings that frame the sidewalks. The university station area is intended to be the “Town” counterpart to the university’s “gown” with amenities for students, faculty, and staff to live, work, shop, dine, and study.

Anticipation of the TVSP and transit stations has already led to significant investment by downtown property owners with the development of commercial retail/dining and professional office uses in the immediate area around the downtown station. These recent developments were designed with an emphasis on pedestrian amenities, walkability and connectivity, and enhanced landscaping. A four -level parking garage is also currently under construction adjacent to the downtown Metrolink platform to enable a “park once” model for downtown and eliminate the need to drive from destination to destination in the immediate area.

7.3.5.2 Disparities in Access to Opportunity for Persons with Disabilities The City of Redlands permits transitional and supportive housing in all zones that allow residential use, with no restrictions other than those imposed on similar residential uses in the same zone.

7.3.5.3 Findings
Disparities in access to opportunities across Redlands mirrors patterns shown in the integration and segregation analysis. The central areas of the City include tracts that have lower access to opportunity than the rest of the City, with one census tract in the high segregation and poverty area. The downtown area has the highest CalEnviroScreen score. The central areas of the City are likely to see improved access to transit with the construction of three train stops, and significant inve stment and opportunity through the TVSP. In Redlands, higher opportunity areas (as defined by the TCAC) correlate strongly with higher

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income populations. Conversely, areas with lower access to opportunities tend to have lower income and larger minority po pulations. There are no clear patterns showing access issues for populations with disabilities.

Contributing factors to fair housing issues pertaining to access to opportunity include lower environmental quality in census tracts and community opposition to new development. These factors are addressed through Program 1.5 -8 Residential Development in High Opportunity Area , 1.1-2 TVSP , Program 1.5 -4 Expand Fair Housing Outreach in Communities with Disproportionate Needs and ADU Outreach in Program 1.6-1.

7.3.6 Disproportionate Housing Needs
Disproportionate housing needs are analyzed by assessing substandard housing by tenure, race, household size, and elderly households.

7.3.6.1 Substandard Housing
A household is considered to be substandard or have a housing problem if t he home has one or more of the following housing problems:
 Housing unit lacks complete kitchen facilities
 Housing unit lacks complete plumbing facilities
 Household is overcrowded (more than 1 person per room including living and dining rooms but not including the bathroom or kitchen)
 Household is cost burdened (monthly housing costs including utilities exceeds 30% of the monthly household income)
Table 7-7 reveals the trends relating to housing problems and race. Compared to the overall population of the City of Redlands, the percentage of White or Asian households with housing problems is much lower than the percentage of total White or Asian households in the City. In Contrast, the percentage of Black, Native American, and Pacific Islander households with housing problems is approximately double the percentage that would be expected by their proportions of the overall population, meaning that these races are disproportionately experiencing at least one of the four housing problems. The percentage of Hispanics or Latinos with housing problems is comparable to the overall percentage that the Hispanic population makes up of the City’s total population.

The same trends extend to the County level: White and Asian households make up proportionately fewer households with housing problems than their overall population. However, Countywide, this trend als o applies to the Hispanic, Pacific Islander and Native American populations, unlike in the City of Redlands.

The City’s trend of Black households making up proportionately more households with housing problems population than their overall population also extends to the County level.

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TABLE 7-7: ANY HOUSING PROBLEM BY TENURE AND RACE
White Black Asian
Am
Indian
Pac
Islander Other All Hispanic
Redlands
Total with
Housing
Problems
4,650 700 530 55 40 170 8,705 2,860

50.0% 8.0% 6.1% 0.6% 0.5% 2.0% 100.0% 32.9%
Owner-
Occupied
2,080 120 250 15 15 60 3,700 1,160

23.9% 1.4% 2.9% 0.2% 0.2% 0.7% 42. 6% 13.3%
Renter-
Occupied
2,570 580 295 40 25 110 5,320 1,700

29.5% 6.7% 3.4% 0.5% 0.3% 1.3% 61.0% 19.5%
All
Households
with or
without
Housing
Problems
28,392 3,870 5,729 332 147 5,346 71,830 23,261

39.9% 5.4% 8.1% 0.5% 0.2% 7.5% 100.0% 32.7%
San
Bernardino
County Total
with Housing
Problems
86,325 30,710 18,315 1,060 629 6,385 281,885 138,465

30.6% 10.9% 6.5% 0.4% 0.2% 2.3% 100.0% 49.1%
Owner-
Occupied
46,885 8,215 11,325 575 240 2,180 129,495 60,075

16.6% 2.9% 4.0% 0.2% 0.1% 0.8% 45.9% 21.3%
Renter-
Occupied
39,440 22,495 6,990 485 389 4,205 152,390 78,390

14.0% 8.0% 2.5% 0.2% 0.1% 1.5% 54.1% 27.8%
All
Households
with or
without
Housing
Problems
169,364 179,292 154,332 17,782 6,838 368,600 2,149,021 1,145,874

7.9% 8.3% 7.2% 0.8% 0.3% 17.2% 100.0% 53.3%
Source: HUD CHAS 2013-2017.

Note: Data excludes households with two or more races.

An elderly household is a household where either the head of the household is over 62 years of age or there are two people over 62 years of age in the household. In the City of Redlands, elderly households make up 18% of the overall population, but 34% of households with housing problems; Countywide, elderly households make up 12% of the total population, but 28% of the households with housing problems. This disproportionate representation, shown in Table 7-8, may be due to how many elderly households may have acquired their home when employed and now are living on a fixed income (e.g., salary from Social Security), thus creating a cost burden that does not leave enough excess funding to repair housing problems. Additionally, if elderly people acquired their home a long time ago, the older

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building may have more need of repair compared to a home more recently acquired by someone younger with more flexible income. Aging in place assistance may help remedy this imbalance.

Large households are considered households with three or more children, whether there is one present parent or two, but are often also measured as households with over five people, regardless of the number of children. The table below reveals tha t despite large households making up only 7% of the overall population in the City of Redlands, they make up 18% of the households with housing problems.

Countywide, large households make up 10% of the population, but 26% of the households with housing problems. Large households may have increased non-housing costs such as paying for other basic needs like food, day care, insurance, health costs, transportation, and utilities which results in less funding available for housing repairs.

TABLE 7-8: HOUSING PROBLEMS FOR ELDERLY AND LARGE HOUSEHOLDS BY TENURE

Elderly
Renter
s with
Housin
g
Proble
m
Elderly
Owner
s with
Housin
g
Proble
m
All Elderly
Househol
ds with
Housing
Problems
Total
Elderly
Househol
ds
Large
HH
Renter
s with
Housin
g
Proble
m
Large
HH
Owner
s with
Housin
g
Proble
m
All Large
Househol
ds with
Housing
Problems
Total
Large
Househol
ds
City 1,170 1,780 2,950 12,670 985 585 1,570 5,084
Count
y
28,670 50,175 78,845 263,060 40,850 33,005 73855 220,240 Source: HUD CHAS 2013-2017.

7.3.6.2 Cost Burden
Households are considered cost burdened if they spend more than 30% of their income on household costs, including utilities Figure 7-28 displays the percentage of renter households that are experiencing a cost burden by census tract from 2010-2014 and 2015-2019. There is no tract in the City where less than 20% of renters are cost burdened. There is only one tract that is fully in the City where less than 40% of renters are cost burdened. Most tracts have more than 40% of renters experiencing a cost burden. The percentage of renters who are cost burdened increased from 2010-2014 in the southeast and downtown areas of the City. The percentage of cost burdened renter households decreased from 40-60% to 20-40% in three census tracts in the northeast, central and northwestern areas.

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FIGURE 7-28: OVERPAYMENT BY RENTERS, 2010-2014 AND 2015-2019

Source: HCD AFFH Mapping Tool.

Figure 7-29 displays the percentage of homeowners that are experiencing a cost burden by census tract from 2010-2014 and 2015-2019. A significantly smaller number of homeowners experience cost burden compared to renters. There are no tracts in the City where over 60% of homeowners experience a cost burden, and only three tracts in the City fall in the 40%-60% range. A few tracts in the western part of the City saw a decrease in cost-burdened homeowners over time.

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FIGURE 7-29: OVERPAYMENT BY HOMEOWNERS, 2010-2014 AND 2015-2019 Source: HCD AFFH Mapping Tool.

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Table 7-9 reveals the trends relating to cost burden and race. Compared to the overall population of the City of Redlands, the percentage of households with cost burden that are White or Asian is lower than the percentage of total households that are White or Asian in the City. However, the percentage of households with cost burden that are Black, Native American, Hispanic, and Pacific Islander is much larger than the percentage of those ethnicities that comprise the overall population, meaning that these races are disproportionately experiencing cost burden and housing costs requiring too much of their total income.

TABLE 7-9: COST BURDEN BY TENURE AND RACE
White Black Asian
Am
Ind
Pac
Islander Other All Hispanic
Redlands
Total with
Cost Burden
4,390 655 465 55 40 165 8,210 2,440

53.5% 8.0% 5.7% 0.7% 0.5% 2.0% 100.0% 29.7%
Owner-
Occupied
1,945 100 215 15 15 65 3,340 985

23.7% 1.2% 2.6% 0.2% 0.2% 0.8% 40.7% 12.0%
Renter-
Occupied
2,445 555 250 40 25 100 4,870 1,455

29.8% 6.8% 3.1% 0.5% 0.3% 1.2% 59.3% 17.7%
All
Households
28,392 3,870 5,729 332 147 5,346 71,830 23,261

39.9% 5.4% 8.1% 0.5% 0.2% 7.5% 100.0% 32.7%
San
Bernardino
County Total
with Cost
Burden
81,845 29,200 16,335 925 490 1,969 132,214 1,450

61.9% 22.1% 12.4% 0.7% 0.4% 1.5% 100.0% 1.1%
Owner-
Occupied
44,780 7,845 10,375 490 155 1,965 66,195 585

33.9% 5.9% 7.9% 0.4% 11.7% 1.5% 50.1% 0.4%
Renter-
Occupied
37,065 21,355 5,960 435 335 3,915 69,930 865

28.0% 16.2% 4.5% 0.3% 0.3% 3.0% 49.9% 0.7%
All
Households
169,364 179,292 154,332 17,782 6,838 368,600 2,149,021 1,145,874

7.9% 8.3% 7.2% 0.8% 0.3% 17.2% 100.0% 53.3%
Source: HUD CHAS 2013-2017.

Note: Data excludes households with two or more races.

At the County level, the percentage of households with cost burden that are White, Native American, or Pacific Islander is comparable with the percentage of total households that are White or Native American in the County, revealing a higher proportion of White households with cost burden and a lower proportion of Native American or Pacific Islander households with cost burden than in the City of Redlands. Like the City, the County has a much larger percentage of cost-burdened Black households than would be expected by their population. Unlike the City of Redlands, where Asian households make up proportionately less of

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the cost-burdened population than the overall population, at the San Bernardino County level, they make up almost twice the proportion and are overwhelmingly disproportionately cost burdened. Also different from Redlands is the Hispanic population, which makes up a large overall proportion of the population in the County but a very small proportion of cost-burdened households.

An elderly household is a household where either the head of the household is over 62 years of age or there are two people over 62 years of age in the household. In the City of Redlands, elderly households make up 18% of the overall population, but 27% of households with cost burden; Countywide, elderly households make up 12% of the total population, but 41% of the households with cost burden. This disproportionate representation, shown in Table , may be due to how many elderly households may have acquired their home when employed and now are living on a fixed salary (e.g., from Social Security), thus creating a cost burden.

Large households are considered households with three or more children, whether there is one present parent or two, but are often also measured as households with over five people. The table below reveals that despite large households making up only 7% of the overall population in the City of Redlands, they make up 22% of the households with cost burden. County -wide, large households make up 10% of the population, but 33% of the households with cost burden. Large households may need a larger home to accommodate the number of people in the family, and because larger-sized homes may have higher costs (rent/mortgage, utilities, etc.), it may take more of a person’s income to maintain, thus creating a cost burden.

TABLE 7-10: COST BURDEN FOR ELDERLY AND LARGE HOUSEHOLDS BY TENURE With
Housing
Problem Elderly Large HH
All
Renter Elderly Large HH
All
Owners All HH
City 975 629 1,604 1,207 280 1,487 3,091
County 19,895 25,515 45,410 33,745 18,420 52,165 97,575 Source: HUD CHAS 2013-2017.

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7.3.6.3 Overcrowding
A household is considered overcrowded if there is more than one person per room, including dining and living rooms but excluding bathroom and kitchen. Overcrowding is considered one of the four major identified housing problems by HUD.

In the City of Redlands, the area with the most severe overcrowding corresponds with the tract with high segregation and poverty, as shown in Figure 7-30, which follows trends in housing choice voucher usage, less economic opportunity, and a high percentage of the population in low to moderate income levels.

This area is also a predominantly Hispanic community. While it may be assumed that overcrowded households would correlate with families, this area has less children living in married couple households compared to the rest of the City, and a higher quantity of people living alone. It does, however, have a higher number of children in female- or single-parent headed households.

Per the 5
th Cycle Housing Element, there is a history of low-income households being more overcrowded due to scarce housing resources, which is consistent with what is known of the identified area. In the San Bernardino County region as a whole, areas of overcrowding are isolated, but continue in areas with similar characteristics to that in Redlands, such as the areas of older downtown housing in other cities and the industrial area in the City of San Bernardino surrounding the San Bernardino Airport.

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FIGURE 7-30: DISTRIBUTION OF OVERCROWDED HOUSEHOLDS, 2010, REDLANDS

Source: HCD AFFH Mapping Tool.

7.3.6.4 Homelessness
Persons experiencing homelessness and unhoused individuals are groups who experience disproportionate housing needs. The San Bernardino County Homeless Partnership, in collaboration with the San Bernardino County Office of Homeless Services and the Institu te for Urban Initiatives, conducts an annual count of the population experiencing homelessness, known as the Point In Time Count (PITC).

Table displays the PITC for Redlands for the years 2013 and 2020 and the change over time. The 20 20 PITC accounted for 18 6 individuals experiencing homelessness in Redlands. From 2013 to 2020 homelessness tripled in the City, increasing from 62 to 186 individuals. Concentrations of the homeless population are in the downtown area where issues like overcrowding and overpayment are prevalent.

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TABLE 7-11: CHANGE IN POPULATION EXPERIENCING HOMELESSNESS, 2013 - 2020 Characteristic 2013 2020 % Change
Total Homeless 62 186 300%
Sheltered 15 45 300%
Unsheltered 47 141 300%
Transitional Housing 1 - -100%

Male 36 71 81%
Female 9 22 211%
Chronic Homeless 9 59 655%
Families (Including Chronically
Homeless Families)
1 - -
Persons with Mental Health
Problems
13 30 230%
White, non-Hispanic 27 52 192%
Black, non-Hispanic 5 12 240%
American Indian and Alaskan
Native, non-Hispanic
4 2 -50%
Asian, non-Hispanic - 1 -
Native Hawaiian and Other Pacific
Islander, non-Hispanic
- - -
Multiple Races or Other 3 26 867%
Don't Know/Refused - - -
Hispanic/Latino 6 26 433%
Source: San Bernardino County Homeless Partnership 2013 and 2019 Point In Time Counts.

Table 7-12 displays the 2020 PITC for Redlands in comparison with neighboring jurisdictions and the whole of San Bernardino County. The City of San Bernardino has a significantly higher population experiencing homelessness than other cities in the region at 1,056 . Redlands has the second highest count. The 2020 PITC report notes that two-thirds of the population experiencing homelessness were counted in six cities in the County: Fontana, Ontario, Redlands, Rialto, San Bernardino and Victorville.27

27 2019 San Bernardino C ounty Homelessness County and Subpopulation Survey Final Report . https://wp.sbcounty.gov/dbh/sbchp/wp- content/uploads/sites/2/2019/05/2019-homeless-count-and-survey-report.pdf.

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TABLE 7-12: REGIONAL POINT IN TIME COUNT, 2019
Jurisdiction Sheltered Unsheltered Total
Redlands 45 141 186
Highland 0 78 78
Loma Linda 24 27 51
City of San
Bernardino
233 823 1,056
Yucaipa 4 13 17
San Bernardino
County
735 2,390 3,125

Source: San Bernardino Partnership 2019 Homelessness Count and Subpopulation Survey Final Report.

7.3.6.5 Displacement Risk
The Urban Displacement Project at University of California, Berkeley developed a map of communities where residents may be particularly vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost, known as sensitive communities. 28 Sensitive communities are defined based on the following set of criteria:
 The share of very low-income residents is above 20%.

The tract must also meet two of the following criteria:
 The share of renters is above 40%.
 The share of people of color is above 50%.
 The share of very low -income households (50% AMI or below) that are severely rent burdened households is above the county median.
 The areas in close proximity have been experiencing displacement pressures. Displacement pressure is defined as:
o The percentage change in rent above county median for rent increases OR o The difference between tract median rent and median rent for surrounding tracts above median for all tracts in county (rent gap).

Figure 7-31 displays the areas of the City determined to be sensitive to displacement as determined by the Urban Displacement Project. It includes the northwestern and central census tracts. There is very little housing in the western region of the City north of the I-10 freeway and west of Highway 210 and no land there is zoned for residential use.

The citizen anti -growth initiatives in the 1970s, 1980s, and 1990s restricted development and placed a series of regulatory and procedural burdens on multifamily housing. It is unknown the extent to which

28 UCB Sensitive Communities Project.

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this discouraged and deterred development in Redlands. Few new higher- density multifamily developments have been approved in Redlands in the past three decades, with the exception of Luxview Apartments (in 2019) in the southwest region of the city, the Liberty Lane affordable housing project in the central census tract (2018), and Casa Loma Apartments (in 2020) near the university in the eastern region of the city. The large capital investment in the three new Metrolink passenger rail stations and the smart growth compact mixed -use development around each station are expected to provide more multifamily housing and higher-density housing options and transform th e areas over the next 10 to 20 years. There is development interest for increased density near transit stops, as well as for housing to be built in underserved communities so people may continue to live in their community and not have to leave to gain access to affordable housing.

Displacement from Transit-Oriented Development
Fortunately, the largely vacant and underutilized lands around the train stations will permit significant infill and redevelopment with minimal displacement of existing residents. Re development of residential sites (if any) will require advanced notification of tenants, and right of first refusal to occupy replacement of affordable units. Residents with housing choice vouchers will be able to relocate to other units in the area. The planned urban form will increase housing, services, recreation, and employment opportunities in the area. As such, any displacement risk with the development of new housing and with the selection of RHNA sites is anticipated to be minimized . In recent cases where some single-family residences (Ruiz Street) have been replaced with nonresidential development, developers entered negotiations with owner-occupied property owners. These negotiations resulted in market- competitive cash offers that enabled residents to relocate without hardship.

Areas north of I-10 zoned R-1 and within the half-mile of the downtown train station has been excluded from rezoning under the TVSP with the intent of not inducing displacement. Only commercially zoned parcels will undergo z one/development standard updates under the TVSP. Additionally, to take further steps against displacement, the City has included programs addressing displacement such as Program 1.2- 20 Extending Affordability Covenant terms from 55 to 99 years and Program 1.3-9 facilitating the Tenant Protection Act (2019).

Implementation of the TVSP will also address overlapping issues with access to opportunity and disproportionate housing needs in that the TVSP wi ll facilitate the creation of new housing, jobs, resources, and means of transportation within an area of low displacement risk.

Displacement from Environmental Hazards
Much of the TVSP area is within a 100 -year flood zone. The City’s municipal code provides standards for building within the flood plain that includes standards for both new and re-purposed buildings. No special approval or entitlement is needed to construct in the flood zone, only that the building pad be elevated at least 2 feet above the 100 -year flood elevation. Because any new or repurposed building would be constructed above the flood elevation, the risk of displacement by flood is no greater than for dwelling units outside the flood zone.

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FIGURE 7-31: COMMUNITIES SENSITIVE TO DISPLACEMENT, 2017, REDLANDS

Source: HCD AFFH Mapping Tool.

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7.3.6.6 Findings
Trends in disproportionate housing needs show the following:
 Renters experienced greater housing cost burdens than homeowners  Overcrowding above the State average occurs downtown, including the same census tract that is identified as high segregation and poverty
 Large households are the most likely to experience housing problems Contributing factors to fair housing issues pertaining to d isproportionate housing needs include lack of availability of affordable units for low -income households and historic land use and zoning practices.

These will be addressed by the TVSP. Promoting the plan to property owners and affordable and market rate housing developers can help increase housing that will be built near the new transit stops . The City will also fund three beds as stated in Program 1.3-8 Homeless Assistance Program.

7.3.7 Other Contributing Factors
Other contributions that effect the accumulati on of wealth and access to resources include historic disinvestment, lack of infrastructure improvements, ballot growth measures , and presence of older affordable housing units that may be at risk of conversion to market-rate housing.

Environmental Justice
The City has several industrial uses throughout and has identified zoning for these uses. The organization of the zoning pattern generally keeps industrial type uses separated from residential uses. Where industrial and residential are proximate, the City limits industrial activities to “light industrial” uses in order to limit environmental impacts on neighboring zones.

The establishment of I-10 has created a corridor through the middle of the City where neighboring areas are affected by pollution such a s diesel particulate matter. The City implements best practices when reviewing land use developments within 500 feet of I -10 to limit pollution exposure. It does this by conditioning projects to install HVAC systems that have the ability to filter these po llutants. Where possible, noise barriers have been installed along 1 -10 to shield residences from freeway noise. While noise barriers are typically installed and maintained by Calt rans, the City has supported private development projects that seek to beautify and enhance freeway right-of-way such as the Packinghouse District and the Orange Street I-10 eastbound off ramp.

History of Growth Management Land Use Measures
The City’s first growth management initiative was Proposition R , which Redlands voters passed in 1978.

The Growth Management Ordinance is located in Title 19 of the Redlands Municipal Code and was included in direct response to the ballot measures.

Proposition R was amended by Measure N (a zoning ordinance) in 1987; this policy restricts the development of residential dwelling units to 400 units a year within the city, and the extension of utilities

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to 150 units per year outside the existing city limits (within the Sphere of Influence, and therefore in the County of San Bernardino’s jurisdiction). Of the 400 units within the city, 50 are, by resolution, reserved for single-family homes, duplexes, triplexes and four-plexes on existing lots; the remainder are allocated on a point system (adopted as Ordinance No. 2036), which emphasizes design ame nities. However, as noted in the State Law Preemption section below, these provisions have been rendered null and void while SB 330 is in effect. The City Council adopted Resolution 8082 in 2020 suspending enforcement of the annual building permit limit as long as SB330 is in effect.

Measure U, adopted by the voters in 1997, further articulated growth management policies. This General Plan Amendment reinforced and modified certain provisions of Measure N, adopted Principles of Managed Growth, and reduced the development density of San Timoteo and Live Oak canyons by creating a new land use category: Resource Preservation. This particular aspect of Measure U has a negligible effect on the ability of the City to accommodate future residential development because it concerns an area of the city with steep hillsides, natural resources, no sewer service and limited utility infrastructure, and other conditions that would limit the development potential of this part of Redlands, regardless of governmental controls.

In addition, under Measure U, no land designated by the General Plan as Urban Reserve as of June 1, 1987, is to be redesignated for a higher density than the R -E designation as the same existed on June 1, 1987 unless specified findings are made by a four-fifths vote of the City Council.

Measure U limits high -density residential land uses to 27 dwelling units per gross acre (du/ac) of development and requires a City Council supermajority (4/5) to approve any proposed developments in excess of 18 du/ac, or with heights in excess of 2.5 stories or 35 feet. Additionally, Measure U specifies required findings that the developments provide “substantial and overriding economic or social benefits to the City.”
During the eight years of the RHNA projection period (2021 to 2029), 3,516 units would need to be accommodated, or about 440 units per year for Redlands to meet its RHNA. This development rate would not be feasible with the Measure U limit of 400 units per year within city limits (plus unlimited additional SRO and congregate care facilities). However, the City Council adopted Resolution No. 8082 to suspend the Residential Development Allocation program while SB 330 is in effect; therefore, during the time that SB 330 is in effect (through at least 2030), ther e is no 400 -unit limit or competitive evaluation system.

Thus, Resolution No. 8082 eliminates any impact on the City’s ability to meet its RHNA caused by Measure U or the Residential Development Allocation program.

The Redlands City Council took steps to meet the City’s allocation by determining that congregate care and single-room occupancy (SRO) units will not count against Measure U’s limitations as long as group dining facilities and a meal program are provided. City staff has defined SRO units as one-room apartments without kitchen facilities although an SRO ordinance has not been adopted by the City at the time of preparation of this element.

Measure U, although not demonstrated with previous project approvals, could in theory potentially restrict the City’s ability to meet its housing needs obligations, and restricts multi- family housing development through the requirement of a 4/5 vote of the City Council for densities above 18 du/ac or

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housing products greater than two and half stories in height. Additionally, the 75 percent single family to 25 percent multi-family ratio identified in the City’s General Plan via Measure U would, in theory, preclude the City from meeting its RHNA. However , during the time that SB 330 is in effect (likely through 2030), the City cannot enforce the 75/25 ratio target, reducing this constraint on the City’s ability to meet its RHNA.

Measure U provides for an exemption for development “directly related” to the three rail stations being developed and scheduled to open in Redlands in 2022: the New York Street station near the Esri campus which is the City’s largest employer; the downtown station; and the University of Redlands station. If a development project is determined to be exempt from Measure U, then the development is not subject to the aforementioned requirements. This exemption process includes a determination by the City Council that a proposed development is “directly related” to the rail station. In making this determination, the City Council has utilized the following two criteria:
• The project site is located within one-quarter mile of a transit station and a clear pedestrian route is available from the project site to the transit station; and • The project provides residential units at a density of a minimum of 20 units per acre.

The City Council has recently approved exemptions to Measure U for three residential projects i n the downtown that will provide over 950 residential units.

The growth management initiatives may have played a role in the manner and extent of housing development in the City which has generally resulted in a furthering of suburban land use patterns wit h more expensive single-family Planned Residential Development being the primary housing product being developed during the 5
th Cycle. Even so, the City has recently seen renewed interest in higher density housing production and is operating within the limits of these voter approved measures to allow taller and more dense housing in various parts of the City.

Measure U and the City’s growth management voter initiatives are more fully discussed in Section 4.1 – Governmental Constraints.

Spatial Patterns of Segregation There is no indication of historic redlining in Redlands, and none is shown on the AFFH data viewer tool. 29 However, records from the County Recorder of San Bernardino County show the use of racially restrictive c ovenants in the City until the 1940 s in southern Redlands near the Country Club. The use of racially restrictive covenants shaped patterns of segregation and integration across Redlands, limiting some areas to White only residents.

Additionally, physical barriers were inadvertently created between North Redlands (former Lugonia Colony) and South Redlands (former Redlands Colony) by first the Zanja water course, followed by the Santa Fe Railroad, and most dramatically by Interstate 10.30 This division, which initially began between rival colonies attempting incorporation, has played out over the decades with a perceived lack of

29 California HCD AFFH Data Viewer Tool. Redlining Grade Layer. 30 Little Racial Strife Seen, Daily News. August 28, 2017. https://www.dailynews.com/2011/01/16/little-racial-strife-seen/

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infrastructure and investment in North Redlands.31 An inadvertent exacerbation came about in the latter 1950s when the police and fire departments for service purposes divided the city up and simply replaced Lugonia with “Northside”.32 The Report on Redlands Community Vision contains a section on the “north side” in Appendix A which summarizes outreach and engagement feedback. 33 The report documented “community members can make complaints at the commission meetings – sometimes related to north- vs.-south division in the city. Before city developed, there were really two cities. There was a perception that poorer people live on nor th side. The cultural mix on the north side has historically been different, and there are issues dating back to days of segregation. The Human Relations Commission works to educate people on these issues, and build more unity and acceptance . In recent years, the City has tried to have as much public access to planning as possible to help address this rift. ” The report goes on to document comments by residents of the need for improved infrastructure and dedicated resources such as a library and public computer access. The City’s Historic Context Statement offers additional insight to early divisions between then Lugonia and Redlands colonies, quoting a local historian “It seems incredible to us now that there should have been so much jealousy and ill -f eeling between Lugonia and Redlands.

For some time, they felt that they were two separate towns and the section on Orange Street between the zanja and Pearl Avenue was called “the link.” It was all natural enough. Lugonia was well established with many attractiv e features and it was hard to see the trend in population and business moving so definitely away from them. On the other hand, Redlands, with youthful enthusiasm was out to capture the business center, the tourists, and everything else it could. 34 Over the years this sentiment has
dwindled and both portions of the City have become more diverse. Through vision planning and comprehensive planning efforts, the City has made great efforts to direct resources where they are needed.

Portions of this area are inclu ded in the TVSP. The City is working to increase infrastructure investment and redevelopment in this area with the TVSP.

In 2015, the City interviewed business owners at the prominent North Redlands intersection of Orange Street and Colton Avenue (during the I -10 on-ramp/off-ramp beautification project) to ascertain what actions could improve the immediate area. Most respondents indicated the need for police surveillance cameras at the intersection to enhance public safety, and the City successfully coordinated with Caltrans to install additional cameras. There are three primary underpasses that connect North and South Redlands under elevated portions of I -10 (at Sixth St., Orange St., and Eureka St.), and the City has cleaned and revitalized each of them with new lighting, paint, and mural installations to signify the connection and promote the safe passage of pedestrian traffic. In addition, the draft TVSP includes the corridors along Colton Avenue (north and east of I-10) and North Orange Street (from I-10 to Lugonia Avenue) to improve and enhance the connectivity and aesthetic of North Redlands to the downtown area.

31 Report on Redlands Community Vision, 2006. Dyett and B hatia. https://www.cityofredlands.org/sites/main/files/file-attachments/report-on- community-vision_12june2006.pdf?1554324291
32 The City’s Image Comes Hard, Larry Burgess, Ph.D. October 31, 2002. http://www.redlandsfortnightly.org/papers/burgess02.htm. 33 Report on Redlands Community Vision, 2006. Dyett and Bhatia. https://www.cityofredlands.org/sites/main/files/file-attachments/report-on- community-vision_12june2006.pdf?1554324291
34 City of Redlands Citywide Historic Context Statement. Adopted September 19, 2017. https://www .cityofredlands.org/sites/main/files/file- attachments/reso_7782_with_hcs.pdf?1554319748

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In recent years, the City has sought to construct infrastructure improvements incrementally throughout the entire jurisdiction. The City has allocated CDBG funds to repair and pave alleys, repair and rehabilitate public park facilities, and fund service providers who focus their efforts on the northern side of the City.

Many Redlands streets were repaved under the City’s PARIS (Pavement Accelerated Repair Implementation Strategy) program, including North Redlands, over several years as funding became available. The City has installed LED streetlights, established a Community Center, and has bolstered efforts to install new landscape and artwork improvements in some major corridor medians.

7.3.8 Summary and Explanation of Sites Inventory on Fair Housing:

A substantial portion of the sites planned for the lower- and moderate-income RHNA are located within census tracts with identified fair housing issues, leading to a potential concentration of poverty and additional fair housing issues. While the opportunity indicators show that the selected sites have a potential to create over -concentrations of lower -income residents, the inventory was specifically developed to locate high-density residential uses in areas of high opportunity, regardless of the TCAC or CalEnviroScreen score. This is part of a larger smart growth strategy to concentrate future growth around the three new Metrolink and Arrow passenger light rail stations in compact, mixed -use, walkable communities. This makes the most efficient and cost-effective use of existing essential infrastructure. Infill and redevelopment will enhance the public realm and increase amenities, services and employment opportunities that will benefit the immediate and adjacent neighborhoods as well as the entire City. The TVSP will also increase the number and type of housing options for a broad range of housing types, sizes, and incomes, leading to a more diverse, dynamic, and cohesive community. Residents in the future transit villages will have convenient access to many nearby household services and transportation options and will not necessarily be required to own a motor vehicle to access household needs or places of employment. Despite being identified in current maps as areas with lower opportunity, the new Metrolink Stations and TVSP will transform central Redlands into an area of high opportunity, with excellent access to employment, transportation, public amenities, healthcare, and retail destinations.

Most notably, the City identified many sites within immediate proximity to the new Metrolink stations.

These sites are within the TVSP, which will update zoning to allow for high-density residential and mixed uses. Combined, the direct infrastructure investment of the Metrolink stations and more permissive zoning would catalyze redevelopment of underutilized commercial land and improvement in historically low resource areas. Additionally, these areas have pending/ approved market -rate pipeline projects, adding diversity to the housing stock and income levels in central Redlands, as well as helping to stabilize neighborhood rents through additional housing options. Adoption of the TVSP is included in Program 1.1- 3 and Program 1.5-8 serves to provide investment in historically underserved areas within the TVSP.

Properties outside of the TVSP were also selected based on access to employment, grocery stores, parks, and schools. Properties within the East Valley Corridor Specific Plan, which is accommodating a large number of lower and mo derate-income units, have excellent access to employment centers at Esri and the neighboring Loma Linda University.

Additionally, the City is including programs to ensure that the sites inventory affirmatively furthers fair housing and provides increased access to opportunity, investment in historically underserved areas, and

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contributes to increased housing opportunity and a broader equitable quality of life throughout the community. Programs include facilitating the Tenant Protection Act (Program 1.3-9), a continued contract with a fair housing provider and expanded fair housing outreach in communities with disproportionate needs (Program 1.5-2, Program 1.5-4), incentivizing units in areas trending towards RCAAs including southern Redlands through ADUs and SB9 (Program 1.6-1), and removal of a CUP for developments with more than 35 units (Program 1.2-13).

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7.4 IDENTIFICATION AND PRIORITIZATION OF CON TRIBUTING

FACTORS
Table 7-13 displays the contributing factors from the AFFH analysis, their fair housing issues, priority level and meaningful actions included in the Implementation Plan to address them. The City has adopted goals and actions to address the contributing factors identified through the AFFH analysis. Many of the RHNA sites are located in the TVSP area, which includes part of the area of high segregation and poverty. The TVSP is expected in improve resources in this area and provide significant investment into an area with a greater diversity, more environmental risk, and greater poverty. The City is also including outreach programs to address a potential community opposition to housing and improve outreach in communities with disproportionate housing needs. Other programs directed to fair housing include the continuation of the mobile home rent control ordinance, preapplication fee waivers for affordable housing developments and adoption of an inclusionary housing ordinance.

While the City views all contributing factors as an important priority to address, in determining the level on the table higher priority was given to factors that limit fair housing choice and or negatively impact fair housing, per Government Code section 65583(c)(10)(A)(iv).

TABLE 7-13: IDENTIFICATION AND PRIORITIZATION OF CONTRIBUTING FACTORS Fair Housing
Issue Contributing Factor Meaningful Actions Priority
Outreach
Capacity
Lack of monitoring

Lack of awareness of fair
housing services

Lack of a variety of media
inputs

Lack of marketing
community meetings
Continue to contract with a fair housing
service provider to provide fair housing
services to residents of Redlands over the
2021-2029 planning period. As part of its
scope of work, increase outreach and
education including a required fair housing
workshops to be conducted in the
downtown/central part of the City
identified with disproportionate housing
needs and displacement risks. (See
Programs 1.5-2 Coordinate with IFHMB,

1.5-3 Promotion of Fair Housing
Information, and 1.5-4 Expand Fair
Housing Outreach in Communities with
Disproportionate Needs)

Expand outreach and education of the
State’s new Source of Income Protection
(SB 329 and SB 222), (See Program 1.3-6
Outreach and Education.)

Include HCVs as legitimate source of
income for housing. (See Program 1.5-11
.)
Require evidence of effective outreach
from Fair Housing Provider on an annual
Low

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Fair Housing
Issue Contributing Factor Meaningful Actions Priority
basis. City will require attendance reports
to events from fair housing providers.

Based on reports, work with fair housing
provider on plan to increase attendance to
outreach events. (See Programs 1.5-2
Coordinate with IFHMB, 1.5-4 Expand Fair
Housing Outreach in Communities with
Disproportionate Needs, and 1.5-5
- Fair
Housing reporting)
Segregation
Patterns
Concentration of minority
populations in downtown
area of City

Geographic (North/South
and regional) segregation
by race/ethnicity and
income

Concentration of availability
of appropriate housing
types for housing choice
vouchers like affordable
rental units maintained by
private owners

Historic land use and
zoning practices
Annually,- prioritize any disadvantaged or
environmental justice community areas
such as the downtown/central census
tracts, for actions and improvements. (See
Programs 1.5-1 Place-Based
Improvements)

Promote key lower income housing
opportunity sites for affordable housing
development particularly in the TVSP, as a
means to bring new housing opportunities
in high resource areas. (See Program 1.1-3
TVSP)

Provide written letters supporting funding
applications by nonprofit developers for
affordable housing in high resource areas.
(See Programs 1.2-14 Waive
Preapplication Fees for Affordable Housing
Projects, 1.5-8 Residential Development in
High Opportunity Area, and 1.5-10
NOFA/Nonprofit Housing Development)

Study and implement an inclusionary
housing ordinance to encourage low-
income housing development (See
Program 1.3-2).

Removal of CUP requirement for
developments with more than 35 units
(See Program 1.2-13).

Medium

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Fair Housing
Issue Contributing Factor Meaningful Actions Priority
Access to
Opportunity:

Area of High
Segregation and
Poverty
Lower environmental
quality in census tracts

Community opposition to
new development
Adopt and implement the TVSP. Promote
the plan to property owners and affordable
and market rate housing developers. (See
Program 1.5-8 Residential Development in
High Opportunity Area and 1.1-3 TVSP)

Address community opposition through
outreach programs (See Program 1.5-4
Expand Fair Housing Outreach in
Communities with Disproportionate Needs
and ADU Outreach in Program 1.6-1)

High
Disproportionate
housing needs
Lack of availability of
affordable units for low-
income households

Historic land use and
zoning practices
Adopt and implement the TVSP. Promote
the plan to property owners and affordable
and market rate housing developers. Use
the EIR for the TVSP to expedite housing
projects that are consistent with the
specific plan. (See Program 1.5-8
Residential Development in High
Opportunity Area and 1.1-3 TVSP)

The City will fund three beds as stated in
Program 1.3-8
: Homeless Assistance
Program
High
Displacement Increasing rents

Displacement risk due to
economic pressures
As part of the project application review,
require applicant to provide advance
noticing to existing tenants. (See Programs

1.4-1 Preservation of at Risk Housing and

1.4-2 Rehabilitate and Improve Condition
of Existing Affordable Housing Stock)

Focus fair housing outreach and education
on areas with high displacement risk
(downtown/central census tracts identified
as a sensitive community and tracts
identified as disadvantaged communities).
(See Program 1.5-4 Expand Fair Housing
Outreach in Communities with
Disproportionate Needs)

Continue implement the Mobile Home Rent
Control Ordinance (See Program 1.5-9)

Implement a ban on no-fault evictions
(See Program 1.1-1)
Medium

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Appendix A:

Site Inventory Map

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Appendix B:

Site Inventory List

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APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
16712105 1624 Webster St Vacant N/A R-1 OFFICE 0 0.146 0.87 0 1 6 1 Above Moderate 16714105 908 Elise Dr Vacant N/A CP-4
OFFICE
0 4.997 0 0 0

HIGH DENSITY
RESIDENTIAL R-3 30 120 Lower
16714106 1555 Texas St Vacant N/A CP-4
OFFICE
0 6.306 0 0 0

HIGH DENSITY
RESIDENTIAL R-3 30 151 Lower
16715123 1505 Orange St Vacant N/A R-2

MEDIUM DENSITY
RESIDENTIAL 0 0.328 8.85 0 7 27 7 Moderate
16716110 1502 Orange St Vacant 5th R-2

MEDIUM DENSITY
RESIDENTIAL 0 3.958 106.87 0 85 27 85 Lower
16717104 1402 Karon St Vacant N/A EV/SD

MEDIUM DENSITY
RESIDENTIAL 0 9.698 0 0 0

MEDIUM DENSITY
RESIDENTIAL R-2 15 116 Moderate
16718102 1312 Texas St Vacant N/A R-1 COMMERCIAL 0 0.523 3.14 0 3 6 3 Above Moderate 16723105 709 W Lugonia Ave Vacant 5th R-1 COMMERCIAL 0 0.620 3.72 0 3 6 3 Above Moderate 16723226 606 W Western Ave Vacant N/A R-1 COMMERCIAL 0 0.134 0.80 0 1 6 1 Above Moderate 16723312 1244 Columbia St Vacant N/A R-1 COMMERCIAL 0 0.154 0.93 0 1 6 1 Above Moderate 16725313 1257 Herald St Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.132 0.79 0 1 6 1 Above Moderate
16725316 1239 Herald St Vacant N/A R-2

LOW DENSITY
RESIDENTIAL 0 0.152 0.91 0 1 6 1 Above Moderate
16725319 1227 Herald St Vacant N/A R-2

VERY LOW DENSITY
RESIDENTIAL 0 0.152 0.91 0 1 6 1 Above Moderate
16728101 740 W Brockton Ave Vacant N/A R-1

VERY LOW DENSITY
RESIDENTIAL 0 0.431 2.58 0 2 6 2 Above Moderate
16728219 1111 Calhoun St Vacant N/A R-1

LOW DENSITY
RESIDENTIAL 0 0.205 1.23 0 1 6 1 Above Moderate
16728220 1111 Calhoun St Vacant N/A R-1

LOW DENSITY
RESIDENTIAL 0 0.171 1.03 0 1 6 1 Above Moderate
16728221 620 W Brockton Ave Vacant N/A R-1

LOW DENSITY
RESIDENTIAL 0 0.172 1.03 0 1 6 1 Above Moderate
16729110 1143 Ohio St Vacant N/A R-1

LOW DENSITY
RESIDENTIAL 0 0.166 1 0 1 6 1 Above Moderate
16813104 1537 Carmel Ct Vacant N/A R-E

LOW DENSITY
RESIDENTIAL 0 0.692 1.87 0 1 2.7 1 Above Moderate
16829102 1721 E Colton Ave Vacant 5th R-1

LOW DENSITY
RESIDENTIAL 0 9.007 54.04 0 43 6 43 Above Moderate
121226129 1421 Hunter Dr Vacant 5th R-2

LOW DENSITY
RESIDENTIAL 0 4.335 65.02 0 52 15 52 Moderate
16714104 912 Elise Dr Vacant N/A CP-4

LOW DENSITY
RESIDENTIAL 0 14.048 0 0 0

MEDIUM DENSITY
RESIDENTIAL R-2 15 169 Moderate
16903104 1018 Texas St Vacant N/A R-1

VERY LOW DENSITY
RESIDENTIAL 0 0.138 0.83 0 1 6 1 Above Moderate
16903212 929 Lawton St Vacant N/A R-1

VERY LOW DENSITY
RESIDENTIAL 0 0.142 0.85 0 1 6 1 Above Moderate
16903501 910 Lawton St Vacant N/A R-1

VERY LOW DENSITY
RESIDENTIAL 0 0.139 0.84 0 1 6 1 Above Moderate

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APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
16905311 302 W Colton Ave Vacant N/A C-4

VERY LOW DENSITY
RESIDENTIAL 0 0.198 5.94 0 3 TVSP TVSP 30 3 Moderate
16906310 102 W Colton Ave Vacant N/A C-4

LOW DENSITY
RESIDENTIAL 0 0.135 4.04 0 2 TVSP TVSP 30 2 Moderate
16906506 924 Washington St Vacant N/A T

VERY LOW DENSITY
RESIDENTIAL 0 0.137 0.82 0 1 6 1 Above Moderate
16907606 831 N 6th St Vacant N/A R-2

VERY LOW DENSITY
RESIDENTIAL 0 0.141 0.85 0 1 6 1 Above Moderate
16907607 831 N 6th St Vacant N/A R-2

VERY LOW DENSITY
RESIDENTIAL 0 0.149 0.90 0 1 6 1 Above Moderate
16910613 910 Tribune St Vacant N/A R-2

VERY LOW DENSITY
RESIDENTIAL 0 0.124 0.74 0 1 6 1 Above Moderate
16911123 663 New York St Vacant N/A C-M

LOW DENSITY
RESIDENTIAL 0 0.998 0 0 0 TVSP TVSP 30 15 Lower
16911124 1120 W Redlands Blvd Vacant N/A C-M

LOW DENSITY
RESIDENTIAL 0 0.999 0 0 0 TVSP TVSP 30 15 Lower
16915301 604 Ruiz St Vacant N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.168 5.03 0 3 TVSP TVSP 30 3 Lower
16915302 608 Ruiz St Vacant N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.160 4.81 0 2 TVSP TVSP 30 2 Lower
16915303 612 Ruiz St Parking Lot N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.160 4.81 0 2 TVSP TVSP 30 2 Lower
16915314 612 Ruiz St Parking Lot N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.123 3.68 0 2 TVSP TVSP 30 2 Lower
16915611 516 Ruiz St Vacant N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.170 5.10 1 2 TVSP TVSP 30 2 Lower
16915612 512 Ruiz St Vacant N/A SP45/TC OFFICE 0 0.162 4.86 1 1 TVSP TVSP 30 1 Lower 16915613 512 Ruiz St Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.271 8.14 0 4 TVSP TVSP 30 4 Lower
16915614 250 W Stuart St Vacant 4th and 5th SP45/TC

MEDIUM DENSITY
RESIDENTIAL 0 0.351 10.54 0 5 TVSP TVSP 30 5 Lower
16915615 511 Ruiz St Vacant 4th and 5th SP45/TC COMMERCIAL 0 0.272 8.15 0 4 TVSP TVSP 30 4 Lower 16915616 320 Stuart Ave Vacant 4th and 5th SP45/TC COMMERCIAL 0 0.127 3.82 0 2 TVSP TVSP 30 2 Lower 16915617 320 Stuart Ave Vacant 4th and 5th SP45/TC COMMERCIAL 0 0.124 3.73 0 2 TVSP TVSP 30 2 Lower 16915618 320 Stuart Ave Vacant 4th and 5th SP45/TC

MEDIUM DENSITY
RESIDENTIAL 0 0.022 0.66 0 0 TVSP TVSP 30 1 Lower
16915619 508 N Eureka St Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.290 8.70 0 4 TVSP TVSP 30 4 Lower
16915620 516 N Eureka St Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.124 3.71 0 2 TVSP TVSP 30 2 Lower
16915629 523 Ruiz St Vacant N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.156 4.69 0 2 TVSP TVSP 30 2 Lower
16915630 519 Ruiz St Vacant N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.156 4.69 1 1 TVSP TVSP 30 1 Lower
16915631 515 Ruiz St Vacant N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.156 4.69 1 1 TVSP TVSP 30 1 Lower

Redlands Regular Meeting of 02-01-22

361 of 602

APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
16915632 511 Ruiz St Vacant N/A SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.164 4.92 1 1 TVSP TVSP 30 1 Lower
16920203 107 W Colton Ave Vacant N/A C-4

LOW DENSITY
RESIDENTIAL 0 0.148 4.43 0 2 TVSP TVSP 30 2 Moderate
16920205 35 W Colton Ave Vacant N/A C-4

LOW DENSITY
RESIDENTIAL 0 0.123 3.68 0 2 TVSP TVSP 30 2 Moderate
16925101 619 New York St
Single Family
Residential N/A C-M

VERY LOW DENSITY
RESIDENTIAL 0 3.817 0 1 -1 TVSP TVSP 30 56 Lower
16927102 430 Texas St Vacant N/A SP45/SC

LOW DENSITY
RESIDENTIAL 0 0.148 4.44 0 2 TVSP TVSP 30 2 Moderate
16927103 715 W Stuart Ave Vacant N/A SP45/SC

LOW DENSITY
RESIDENTIAL 0 0.152 4.55 0 2 TVSP TVSP 30 2 Moderate
16927107 701 Stuart Ave Vacant N/A SP45/SC

LOW DENSITY
RESIDENTIAL 0 0.160 4.80 0 2 TVSP TVSP 30 2 Lower
16927109 619 Stuart Ave Vacant 4th and 5th SP45/SC

LOW DENSITY
RESIDENTIAL 0 0.176 5.27 0 3 TVSP TVSP 30 3 Lower
16927110 615 Stuart Ave Vacant 4th and 5th SP45/SC

LOW DENSITY
RESIDENTIAL 0 0.176 5.27 0 3 TVSP TVSP 30 3 Lower
16927111 611 W Stuart Vacant 4th and 5th SP45/SC

LOW DENSITY
RESIDENTIAL 0 0.176 5.27 0 3 TVSP TVSP 30 3 Lower
16927112 611 W Stuart Vacant 4th and 5th SP45/SC

LOW DENSITY
RESIDENTIAL 0 0.176 5.27 0 3 TVSP TVSP 30 3 Lower
16927113 607 Stuart Ave Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.165 4.94 0 2 TVSP TVSP 30 2 Lower
16927115 545 Stuart Ave Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.110 3.30 0 2 TVSP TVSP 30 2 Lower
16927116 545 Stuart Ave Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.110 3.30 0 2 TVSP TVSP 30 2 Lower
16927117 545 Stuart Ave Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.183 5.49 0 3 TVSP TVSP 30 3 Lower
16927118 535 W Stuart Ave Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.108 3.25 0 2 TVSP TVSP 30 2 Lower
16927119 535 W Stuart Ave Vacant 4th and 5th SP45/TC

LOW DENSITY
RESIDENTIAL 0 0.090 2.71 0 1 TVSP TVSP 30 1 Lower
16927120 535 W Stuart Ave
Commercial and
Services 4th and 5th SP45/TC

COMMERCIAL/INDUS
TRIAL 0 0.158 4.73 0 2 TVSP TVSP 30 2 Lower
16927153 701 Stuart Ave Vacant 4th and 5th SP45/SC COMMERCIAL 0 0.175 5.26 0 3 TVSP TVSP 30 3 Lower 16927229 420 W Redlands Blvd Parking Lot N/A M-1

COMMERCIAL/INDUS
TRIAL 0 1.569 0 0 0 TVSP TVSP 30 24 Lower
16928130 120 W Redlands Blvd
Commercial and
Services N/A SP45/TCH

COMMERCIAL/INDUS
TRIAL 0 1.479 44.36 0 22 TVSP TVSP 30 22 Lower
16928154 110 W Redlands Blvd
Commercial and
Services N/A SP45/TCH

COMMERCIAL/INDUS
TRIAL 0 0.868 26.03 0 13 TVSP TVSP 30 13 Lower
16928155 4 W Redlands Blvd
Commercial and
Services N/A SP45/TCH

COMMERCIAL/INDUS
TRIAL 0 1.006 30.18 0 15 TVSP TVSP 30 15 Lower
16931317 301 9th St Vacant N/A SP45/SC

COMMERCIAL/INDUS
TRIAL 0 2.157 64.70 0 32

HIGH DENSITY
RESIDENTIAL R-3 30 52 Lower

Redlands Regular Meeting of 02-01-22

362 of 602

APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
16937106 1580 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL/INDUS
TRIAL 0 1.163 0 0 0 TVSP TVSP 30 17 Lower
16937110 1580 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 0.051 0 0 0 TVSP TVSP 30 1 Lower
16937112 1580 Industrial Park Ave Parking Lot N/A EV/CG COMMERCIAL 0 0.149 0 0 0 TVSP TVSP 30 2 Lower 16937117 1580 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 0.057 0 0 0 TVSP TVSP 30 1 Lower
16937118 1520 Industrial Park Ave Parking Lot N/A EV/CG COMMERCIAL 0 0.096 0 0 0 TVSP TVSP 30 1 Lower 16937121 1580 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 0.077 0 0 0 TVSP TVSP 30 1 Lower
16937122 1580 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 0.415 0 0 0 TVSP TVSP 30 6 Lower
16938105 1520 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 6.964 0 0 0 TVSP TVSP 30 104 Lower
16938108 830 Tri City Center Dr
Commercial and
Services N/A EV/CG

COMMERCIAL
0 1.066 0 0 0 TVSP TVSP 30 16 Lower
16938110 800 Tri City Center Dr
Commercial and
Services N/A EV/CG

COMMERCIAL
0 2.350 0 0 0 TVSP TVSP 30 35 Lower
16938111 1460 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 0.908 0 0 0 TVSP TVSP 30 14 Lower
16938113 1515 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 4.572 0 0 0 TVSP TVSP 30 69 Lower
16938114 801 Tri City Center Dr
Commercial and
Services N/A EV/CG

COMMERCIAL
0 1.895 0 0 0 TVSP TVSP 30 28 Lower
16940113 1350 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 0.695 0 0 0 TVSP TVSP 30 10 Lower
17012111 1327 Sylvan Blvd
Single Family
Residential N/A R-2

COMMERCIAL
0 0.996 26.90 1 21 TVSP TVSP 30 14 Lower
17012112 1329 Sylvan Blvd
Single Family
Residential N/A R-2

COMMERCIAL
0 0.900 24.29 1 18 TVSP TVSP 30 12 Lower
17012113 633 N Judson St
Single Family
Residential N/A R-2

COMMERCIAL
0 0.573 15.47 1 11 TVSP TVSP 30 8 Lower
17012114 1331 Sylvan Blvd Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.490 13.24 0 11 TVSP TVSP 30 7 Lower
17012115 1331 Sylvan Blvd
Single Family
Residential N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.249 6.71 1 4 TVSP TVSP 30 3 Lower
17017101 1316 Sylvan Blvd Vacant 5th R-2

HIGH DENSITY
RESIDENTIAL 0 3.127 84.43 0
6 8 TVSP TVSP 30 47 Lower
17020101 1129 Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.287 7.76 0 6 TVSP TVSP 30 4 Lower
17020102 1143 Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.086 2.32 0 2 TVSP TVSP 30 1 Lower
17020107 1123 E Central Ave
Multi-Family
Residential N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.574 15.49 2 10 TVSP TVSP 30 7 Lower
17020108 1119 E Central Ave
Single Family
Residential N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.574 15.49 2 10 TVSP TVSP 30 7 Lower

Redlands Regular Meeting of 02-01-22

363 of 602

APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
17020109 1115 E Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.574 15.49 0 12 TVSP TVSP 30 9 Lower
17020112 1111 Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.574 15.49 0 12 TVSP TVSP 30 9 Lower
17020121 1111 Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.574 15.49 0 12 TVSP TVSP 30 9 Lower
17020124 1111 Central Ave Vacant 5th R-2

HIGH DENSITY
RESIDENTIAL 0 0.574 15.50 0 12 TVSP TVSP 30 9 Lower
17020130 337 N Cook St
Single Family
Residential N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.799 21.58 1 16 TVSP TVSP 30 11 Lower
17020133 1113 E Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.413 11.16 0 9 TVSP TVSP 30 6 Lower
17020134 1143 Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.287 7.75 0 6 TVSP TVSP 30 4 Lower
17020135 1143 Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.137 3.71 0 3 TVSP TVSP 30 2 Lower
17020137 1125 Central Ave Vacant N/A R-2

HIGH DENSITY
RESIDENTIAL 0 0.430 11.62 1 8 TVSP TVSP 30 5 Lower
17020138 1129 Central Ave Vacant 5th R-2

HIGH DENSITY
RESIDENTIAL 0 1.867 50.40 0 40 TVSP TVSP 30 28 Lower
17025105 1110 Central Ave Vacant 5th R-2

HIGH DENSITY
RESIDENTIAL 0 0.641 17.31 0 14 TVSP TVSP 30 10 Lower
17025106 1122 Central Ave Vacant 5th R-2

HIGH DENSITY
RESIDENTIAL 0 0.628 16.95 0 14 TVSP TVSP 30 9 Lower
17025107 1122 Central Ave Vacant 5th R-2

HIGH DENSITY
RESIDENTIAL 0 0.556 15.00 0 12 TVSP TVSP 30 8 Lower
17108501 604 State St Vacant 5th A-P

HIGH DENSITY
RESIDENTIAL 0 0.173 2.60 0 2 TVSP TVSP 30 3 Moderate
17108503 604 Central Ave Vacant N/A A-P

HIGH DENSITY
RESIDENTIAL 0 0.055 0.83 0 1 TVSP TVSP 30 1 Moderate
17108504 604 Central Ave Vacant N/A A-P

HIGH DENSITY
RESIDENTIAL 0 0.082 1.24 0 1 TVSP TVSP 30 1 Moderate
17108913 21 Church St Vacant N/A T

HIGH DENSITY
RESIDENTIAL 0 0.125 1.87 0 1 TVSP TVSP 30 1 Above Moderate 17118137 100 Tennessee St Vacant N/A R-2

COMMERCIAL/INDUS
TRIAL 0 0.663 17.91 0 14 TVSP TVSP 30 10 Lower
17119129 15 Center St Schools 5th R-2

COMMERCIAL/INDUS
TRIAL 0 1.888 50.96 0 41 TVSP TVSP 30 28 Lower
17121109 419 Citrus Ave Vacant N/A C-3

MEDIUM DENSITY
RESIDENTIAL 0 0.035 1.06 0 1 TVSP TVSP 30 1 Above Moderate 17121111 411 Citrus Ave Vacant N/A C-3

MEDIUM DENSITY
RESIDENTIAL 0 0.098 2.94 0 1 TVSP TVSP 30 1 Above Moderate 17121112 407 W Citrus St Vacant N/A C-3

MEDIUM DENSITY
RESIDENTIAL 0 0.104 3.12 0 2 TVSP TVSP 30 2 Above Moderate 17121113 216 Brookside Ave Vacant N/A C-3

MEDIUM DENSITY
RESIDENTIAL 0 0.156 4.69 0 2 TVSP TVSP 30 2 Above Moderate

Redlands Regular Meeting of 02-01-22

364 of 602

APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
17121114 216 Brookside Ave Vacant N/A C-3

MEDIUM DENSITY
RESIDENTIAL 0 0.026 0.77 0 0 TVSP TVSP 30 1 Above Moderate 17121121 216 Brookside Ave Vacant N/A C-3

MEDIUM DENSITY
RESIDENTIAL 0 0.152 4.56 0 2 TVSP TVSP 30 2 Above Moderate 17124124 317 Brookside Ave Vacant 5th A-P

COMMERCIAL/INDUS
TRIAL 0 0.344 10.32 0 5 30 5 Moderate
17135128 311 Normande Ct Vacant N/A R-2

COMMERCIAL/INDUS
TRIAL 0 0.074 1.11 0 1 15 1 Above Moderate
17205201 1617 W Olive Ave Vacant N/A R-S 0 0 0.380 2.28 0 2 6 2 Above Moderate 17208218 1114 W Olive Ave Vacant N/A R-S

MEDIUM DENSITY
RESIDENTIAL 0 0.143 0.86 0 1 6 1 Above Moderate
17208220 1114 W Olive Ave Vacant N/A R-S COMMERCIAL 0 0.157 0.94 0 1 6 1 Above Moderate 17243147 141 Calle Constancia Vacant N/A R-S COMMERCIAL 0 0.903 5.42 0 4 6 4 Above Moderate 17243148 1509 Blossom Ct Vacant 5th R-S COMMERCIAL 0 0.313 1.88 0 2 6 2 Above Moderate 17301139 550 North Pl Vacant 5th R-S COMMERCIAL 0 0.996 5.98 0 5 6 5 Above Moderate 17301140 608 North Pl Vacant 5th R-S COMMERCIAL 0 1.016 6.09 0 5 6 5 Above Moderate 17304315 516 S Cajon St Vacant N/A A-P COMMERCIAL 0 0.215 6.45 0 3 30 3 Moderate 17304316 532 S Cajon St Vacant N/A A-P COMMERCIAL 0 0.275 8.26 0 4 30 4 Moderate 17319116 1233 Morrison Dr Vacant N/A R-S COMMERCIAL 0 0.699 4.20 0 3 6 3 Above Moderate 17402149 1335 Knoll Rd Vacant N/A R-A COMMERCIAL 0 0.704 1.90 0 2 2.7 2 Above Moderate 17402150 1355 Knoll Rd Vacant N/A R-A COMMERCIAL 0 0.740 2.00 0 2 2.7 2 Above Moderate 17402151 1355 Knoll Rd Vacant N/A R-A COMMERCIAL 0 0.846 2.28 0 2 2.7 2 Above Moderate 17402160 1363 Knoll Rd Vacant N/A R-A COMMERCIAL 0 0.734 1.98 0 2 2.7 2 Above Moderate 17404103 322 E Highland Ave Vacant N/A R-S COMMERCIAL 0 0.172 1.03 0 1 6 1 Above Moderate 17408210 340 Summit Ave Vacant N/A R-E COMMERCIAL 0 0.474 1.28 0 1 2.7 1 Above Moderate 17460102 673 Bradbury Dr Vacant N/A R-E COMMERCIAL 0 0.501 1.35 0 1 2.7 1 Above Moderate 17460105 693 Bradbury Dr Vacant N/A R-E COMMERCIAL 0 1.060 2.86 0 2 2.7 2 Above Moderate 17460108 679 Chaucer Ct Vacant N/A R-E COMMERCIAL 0 0.583 1.57 0 1 2.7 1 Above Moderate 17511114 945 W Highland Ave Vacant N/A R-S COMMERCIAL 0 0.454 2.72 0 2 6 2 Above Moderate 29216505 27045 Citrus Ave Agriculture N/A EV/IC

COMMERCIAL
0 5.840 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 139 Lower
29216506 10972 Iowa St
Single Family
Residential N/A EV/IC

COMMERCIAL
0 3.146 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 75 Lower
29216507 11006 Iowa St
Single Family
Residential N/A EV/IC

COMMERCIAL
0 1.075 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 25 Lower
29216508 11018 Iowa St
Single Family
Residential N/A EV/IC

COMMERCIAL
0 1.897 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 45 Lower
29216509 11034 Iowa St
Single Family
Residential N/A EV/IC

COMMERCIAL
0 1.900 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 45 Lower
29216517 10941 Nevada St Agriculture N/A EV/IC

COMMERCIAL
0 4.027 0 0 0

HIGH DENSITY
RESIDENTIAL R-3 30 97 Lower
29216702 11063 Iowa St Vacant N/A EV/IC

COMMERCIAL
0 4.869 0 0 0

MEDIUM DENSITY
RESIDENTIAL R-2 30 58 Moderate
29216707 169 Alabama St
Single Family
Residential N/A EV/IC

COMMERCIAL
0 2.345 0 1 -1

MEDIUM DENSITY
RESIDENTIAL R-2 30 27 Moderate
29216728 10287 Alabama St
Single Family
Residential N/A EV/IC

COMMERCIAL
0 4.725 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 112 Lower

Redlands Regular Meeting of 02-01-22

365 of 602

APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
29216729 169 Alabama St Agriculture N/A EV/IC

COMMERCIAL
0 4.215 0 0 0

HIGH DENSITY
RESIDENTIAL R-3 30 101 Lower
29216730 11006 Iowa St Agriculture N/A EV/IC

COMMERCIAL
0 8.857 0 0 0

HIGH DENSITY
RESIDENTIAL R-3 30 213 Lower
29220120 27395 Citrus Ave Vacant N/A EV/IC

COMMERCIAL
0 10.648 0 0 0

MEDIUM DENSITY
RESIDENTIAL R-2 30 128 Moderate
29821109 1380 Plumwood Vacant N/A R-1 COMMERCIAL 0 4.468 26.81 0 21 6 21 Above Moderate 29821139 2196 Madeira Ave Vacant N/A R-E COMMERCIAL 0 3.787 22.72 0 18 6 18 Above Moderate 16711410 1734 Washington St Vacant N/A R-1 COMMERCIAL 0 0.147 0.88 0 1 6 1 Above Moderate 16712104 1612 Webster St Vacant N/A R-1 COMMERCIAL 0 0.146 0.87 0 1 6 1 Above Moderate 16720133 1455 Clay St Vacant N/A R-1 COMMERCIAL 0 0.156 0.94 0 1 6 1 Above Moderate 16927114 545 Stuart Ave Vacant 4th and 5th SP45/TC COMMERCIAL 0 0.110 3.30 0 2 TVSP TVSP 30 2 Lower 17110101 305 W State St Vacant N/A C-3

PUBLIC/INSTITUTION
AL 0 0.108 3.25 0 2 TVSP TVSP 30 2 Above Moderate
17110102 305 W State St Vacant N/A C-3

PUBLIC/INSTITUTION
AL 0 0.108 3.25 0 2 TVSP TVSP 30 2 Above Moderate
17110103 305 W State St Vacant N/A C-3

PUBLIC/INSTITUTION
AL 0 0.108 3.25 0 2 TVSP TVSP 30 2 Above Moderate
17110104 309 W State St Vacant N/A C-3

PUBLIC/INSTITUTION
AL 0 0.108 3.25 0 2 TVSP TVSP 30 2 Above Moderate
17110105 216 Brookside Ave Vacant N/A C-3

PUBLIC/INSTITUTION
AL 0 0.250 7.49 0 4 TVSP TVSP 30 4 Above Moderate
17121115 216 Brookside Ave Vacant N/A C-3

PUBLIC/INSTITUTION
AL 0 0.116 3.49 0 2 TVSP TVSP 30 2 Above Moderate
17121125 216 Brookside Ave Vacant N/A C-3

PUBLIC/INSTITUTION
AL 0 0.462 13.87 0 7 TVSP TVSP 30 7 Above Moderate
17243146 1520 Blossom Ct Vacant 5th R-S

PUBLIC/INSTITUTION
AL 0 0.364 2.18 0 2 6 2 Above Moderate
17447154 317 Silvertree Ln Vacant 5th R-E

PUBLIC/INSTITUTION
AL 0 0.348 2.09 0 2 6 2 Above Moderate
16902102 831 W Lugonia Ave Vacant 5th A-1

PUBLIC/INSTITUTION
AL 0 4.757 71.36 0 57 15 57 Moderate
16902111 831 W Lugonia Ave Vacant 5th R-1

PUBLIC/INSTITUTION
AL 0 1.641 24.62 0 20 15 20 Moderate
16722110 438 Hidalgo Ave Vacant 5th R-2

PUBLIC/INSTITUTION
AL 0 9.480 142.19 0 114 15 114 Moderate
16722116 1400 Church Pl Vacant 5th R-2

PUBLIC/INSTITUTION
AL 0 2.765 41.47 0 33 15 33 Moderate
16722115 539 Jurupa Ave Vacant 5th R-2

PUBLIC/INSTITUTION
AL 0 3.174 47.62 0 38 15 38 Moderate
16938109 810 Tri-City Center Dr
Commercial and
Services N/A EV/CG

PUBLIC/INSTITUTION
AL 0 3.363 0 0 0 TVSP TVSP 30 50 Lower
16940111 1372 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL/INDUS
TRIAL 0 0.502 0 0 0 TVSP TVSP 30 8 Lower
29216510 11090 Iowa St Vacant 5th EV3000RM

COMMERCIAL/INDUS
TRIAL 0 4.067 61.00 1 48 15 48 Moderate

Redlands Regular Meeting of 02-01-22

366 of 602

APN Site
Address/Intersection Existing Use/Vacancy
Identified in
Last/Last
Two
Planning
Cycle(s)
Zoning
Designation
(Current)
Current General Plan
Minimum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Max Units
Existing
Zoning
Existing
Units
Realistic
Capacity
(Existing
Zoning)
Projected General
Plan
Projected
Zoning
Max
Density
Allowed
(units/acre)
Realistic
Capacity
(rezone)
New Income
Category
29216303 11030 Nevada St
Single Family
Residential N/A EV/IC

COMMERCIAL/INDUS
TRIAL 0 4.261 0 1 -1

MEDIUM DENSITY
RESIDENTIAL R-2 15 50 Moderate
29216302 10940 Nevada St
Multi-Use Residential
Agriculture N/A EV/IC

COMMERCIAL/INDUS
TRIAL 0 8.905 0 2 -2

MEDIUM DENSITY
RESIDENTIAL R-2 15 105 Moderate
29216516 10941 Nevada St
Single Family
Residential N/A EV/IC

HIGH DENSITY
RESIDENTIAL 0 2.497 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 59 Lower
17460107 693 Bradbury Dr Vacant N/A R-E

HIGH DENSITY
RESIDENTIAL 0 0.877 2.37 0 2 2.7 2 Above Moderate
16938112 1402 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 4.682 0 0 0 TVSP TVSP 30 70 Lower
16940110 1380 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 3.182 0 0 0 TVSP TVSP 30 48 Lower
16940112 1362 Industrial Park Ave
Commercial and
Services N/A EV/CG

COMMERCIAL
0 1.252 0 0 0 TVSP TVSP 30 19 Lower
17121120 216 Brookside Ave Vacant N/A C-3 COMMERCIAL 0 0.286 8.57 0 4 TVSP TVSP 30 4 Above Moderate 17121116 216 Brookside Ave Vacant N/A C-3 COMMERCIAL 0 0.218 6.55 0 3 TVSP TVSP 30 3 Above Moderate 17121119 216 Brookside Ave Vacant N/A C-3 COMMERCIAL 0 0.191 5.72 0 3 TVSP TVSP 30 3 Above Moderate 17121118 216 Brookside Ave Vacant N/A C-3 COMMERCIAL 0 0.229 6.86 0 3 TVSP TVSP 30 3 Above Moderate 17121117 216 Brookside Ave Vacant N/A C-3 COMMERCIAL 0 0.312 9.36 0 5 TVSP TVSP 30 5 Above Moderate 16926124 620 New York St
Single Family
Residential N/A C-M

COMMERCIAL
0 5.948 0 1 -1

HIGH DENSITY
RESIDENTIAL R-3 30 142 Lower
17408219 1313 Elm St Vacant N/A R-E COMMERCIAL 0 0.323 0.87 0 1 2.7 1 Above Moderate 17504247 1056 San Jacinto St Vacant N/A R-S

COMMERCIAL/INDUS
TRIAL 0 0.445 2.67 0 2 6 2 Above Moderate
APN

COMMERCIAL
0 0 Projected General
Plan

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Appendix C:

Community
Engagement

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Community Outreach
The California Government Code requires that local governments make diligent efforts to solicit public participation from all economic segments of the community, especially low -income persons, in the development of the Housing Element. During the preparation of this Housing Element update, public input was actively encouraged in a variety of ways. It should be noted that public meeting summaries, including questions and staff responses, have been summarized and edited for clarity. 8 EFFORTS TO ACHIEVE CITIZEN PARTICIPATION
The public participation effort during the drafting of the 6th Cycle Housing Element update included an on-line public outreach survey , stakeholder interviews, and two virtual Community Workshops. Due to the COVID-19 Pandemic, the C ity took a new approach to meetings, which were primarily held on -line over Zoom. The first Community Workshop was held on Monday, April 26 and had 11 attendees from the public. The second was held on Thursday, May 13 and had six attendees from the public. A further 292 people participated in the on-line survey.

8.1 ON-LINE SURVEY RESULTS
Q1. What is your involvement with the City of Redlands?

Q2. What is the zip code of your home/business/agency/school in Redlands?

93%
4% 3% 0%
0%
20%
40%
60%
80%
100%
I am a City resident I represent a housing
agency, social service
agency, a non-profit
organization, a religious
institution, or a government
entity in the City
I own a business or work in
the City
I attend school/college in
the City

54.8%

44.1%

0.4% 0.4% 0.4%
0%
20%
40%
60%
92373 91374 92321 92359 92376

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Q3. How long have you lived, owned a business, worked, or attended school in the City?

Q4. How do you identify?

Q5. Do you have one or more conditions subject to the Americans with Disabilities Act (ADA)?

63%
18% 18%
1% 0%
0%
20%
40%
60%
80%
Over 10 years 1 to 4 years 5 to 10 years Less than one
year
I do not live, own
a business, work,
or attend school
in the City

68.8%

30.9%

0.4%
0%
20%
40%
60%
80%
Female Male Other*
94%
6%
0%
20%
40%
60%
80%
100%
No Yes

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Q6. How old are you?

Q7. How many years of education have you completed?

Q8. What is your race/ethnicity?

2.4%

15.8%

23.7% 23.4%

18.6%

14.4%

0.3% 1.4%
0%
20%
40%
18-24 25-34 35-44 45-54 55-64 65-80 80+ Prefer not
to say
42%
30%
15%
9% 4% 1%
0%
20%
40%
60%
Graduate
degree
4-year college
degree
Some
college/trade
school
Associate
degree
Completed
high school
Less than 12
years

71.5%

16.3% 9.4% 4.5% 1.7% 1.7% 0.4%
0%
20%
40%
60%
80%
White or
Caucasian
Hispanic or
Latino
Prefer not to
say
Asian or
Asian
American
Black or
African
American
American
Indian or
Alaska
Native
Native
Hawaiian or
other Pacific
Islander

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Q9. What is the approximate total annual income for your family, based on the number of people in your household (HH)?

Q10. Are you a homeowner or a renter?

0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
55%
60%
65%
1 person in
HH
2 persons
in HH
3 persons
in HH
4 persons
in HH
5 person in
HH
6 persons
in HH
7 persons
in HH
8 persons
in HH
$9,999 or less
$10,000 to
$14,999
$15,000 to
$24,999
$25,000 to
$34,999
$35,000 to
$49,999
$50,000 to
$64,999
$65,000 to
$74,999
$75,000 to
$99,999
$100,000 or more
73%
23%
4%
0%
10%
20%
30%
40%
50%
60%
70%
80%
Homeowner Renter N/A or prefer not to say

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Q11. What size of housing units are most needed in the City?

Q12. What demographic do you believe need housing the most in the City of Redlands?

30.3%

59.8%

50.2%

11.8%
0%
20%
40%
60%
80%
One-bedroom units 1
bedroom
Two-bedroom units 2
bedroom
Three-or more-
bedroom units 3 or
more bedroom
N/A or prefer not to
say
54% 48%
28%
14% 14%
0%
10%
20%
30%
40%
50%
60%
Low-income
person(s)
Families (3+
persons in
household)
Seniors (65+ or
older)
Students Other (please
specify)

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Q13. What type of housing units are most needed in the City?

Q14. What housing amenities do you think are needed in the City?

42.3% 38.1%

30.2% 28.7% 24.5% 24.2% 21.9%

15.1%
0%
20%
40%
60%
Detached single-family
home
Mixed-use housing
Duplex
Supportive housing
Multi-family/Apartment
homes
Townhome/Condominiums
Senior housing
Buildings dedicated to
providing housing units to
those with mental and
physical disabilities
43%
40% 39%
36%
27%
12%
6%
14%
0%
10%
20%
30%
40%
50%

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Q15. What are the most critical homeless needs i n your community?

Q16. Have you or someone you know ever encountered any of the forms of housing discrimination?

Q18. How well informed would you say you are about housing discrimination?

59%
51%
45%
13% 13%
0%
10%
20%
30%
40%
50%
60%
70%
54%
17%
11% 9% 5% 2% 2%
0%
10%
20%
30%
40%
50%
60%
No I'm not sure I haven't, but
someone I
know has
Yes, I have I think I may
have
N/A or prefer
not to say
Other
(please
specify)
49%
21% 20%
10%
0%
10%
20%
30%
40%
50%
60%
Somewhat informed A little informed Very well informed Not at all informed

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Q19. What would you do if you encountered housing discriminati on?

Q21. Do you believe housing discrimination occurs in the City?

Q22. If you think housing discrimination is occurring, what types of discrimination do you think are most prevalent?

53.5%

29.5% 23.7% 18.3%

4.6% 4.2%
0%
20%
40%
60%
Report it Contact the
person responsible
and tell them that
you believe they
are discriminating
Would not know
what to do
Do nothing and
seek other housing
options
N/A or prefer not
to say
Other (please
specify)
37% 29%
20%
7% 6% 0%
0%
10%
20%
30%
40%
Likely Yes Don't know No Unlikely N/A or prefer
not to say

67.7%

52.1%

39.6%

27.7% 24.9% 24.0% 20.7%

12.9% 9.7% 9.7% 9.7% 9.2% 6.0% 5.5%
0%
20%
40%
60%
80%

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Q23. Were you aware of a tenant's right to request, from a landlord, a physical change to make a home more accessible if necessary due to a disability?

Q24. Have you, or someone you know, ever made a request for a reasonable accommodation?

49% 45%
5%
0%
10%
20%
30%
40%
50%
60%
Yes No Don't know

77.1%

12.5% 9.2%

1.3%
0%
20%
40%
60%
80%
100%
No Yes Don't know N/A or prefer not to
say

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Q25. If yes, what type of accommodation and/or modification did you or the person you know request?

Q27. Which of the following issues, if any, have limited the housing options you were able to consider?

71%
14% 13%
10% 10%
3% 2% 0% 0%
3%
0%
10%
20%
30%
40%
50%
60%
70%
80%
71%
30%
21%
12% 11% 7% 6% 5% 2% 5%
0%
10%
20%
30%
40%
50%
60%
70%
80%

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Q28. Are there any housing programs or services needed that you feel would reduce housing issues described in previous question?

Q29. If you think housing discrimination is occurring, what types of discrimination do you think are most prevalent?

55%
24%
22%
0%
10%
20%
30%
40%
50%
60%
Don't know Yes (please specify) No

51.2%

31.9%

11.7% 9.9% 7.5% 5.6%

0.9% 1.9%
0%
20%
40%
60%
I have not
had this
problem
Not
applicable
My/our
income
level is too
low
The
amount
I/we had
for a down
payment
was too
little
My/our
credit
history of
credit
score(s)
was too
low
The
amount of
savings
I/we had
was too
little
The value
of my
property
was too
low
Other
(please
specify)

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Q30. Do you feel local land use regulations support the development of affordable housing?

8.2 STAKEHOLDER INTERVIEWS
As part of the 6th Cycle Housing Element, the following stakeholder groups were contacted as part of the public outreach process:
 Redlands Unified School District – March 4
 San Bernardino County Homeless Partnership – March 11  Redlands Area Interfaith Council – March 11
 Family Service Association of Redlands – March 12
 Northside Redlands Visioning Committee – March 12
 Inland Valley Association of Realtors – March 12
 Building Industry Association –March 16
 Inland SoCal United Way – March 18
 Inland Temporary Homes – March 18
 University of Redlands – March 25
41% 41%
18%
0%
10%
20%
30%
40%
50%
No opinion No (please specify) Yes

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 Redlands Chamber of Commerce – March 30
In each stakeholder interview, the stakeholders were asked the following questions:
 Please describe your agency or role in the City?
 What would you say are your agency’s top priorities in the next:
1-2 years?
3-5 years?
6 years onward?
 What do you think is the best strategy to build more housing to meet City of Redland s’ RHNA goals?
 What segment of the City’s population do you think is most vulnerable in terms of having affordable housing?
 How do you think the City can assist those/that population segment?  What do you think the greatest challenge may be in terms of housing needs for the City? The responses of each participating organization were as follows:

8.2.1 Redlands Unified School District
The Redlands Unified School District (the District) is an educational partner of the City of Redlands. The District believes the best strategy to meet RHNA goals is to look back on past Measures/Ordinances and review its impact on the local community. For example, Measure U affects the District the most. This measure focuses on growth control, but this is a burden on school district because of a decline in enrollment. It is difficult for the District to maintain budgets while meeting enrollment. The District suggests that City Council focus on the socioeconomic status of population and outdated ordinances. The language written in Measure U (specifically Section 1.a.0.b and 1.a.0.c) hinders the District.

The District notes there is a lack of opportunity for young families to move to Redlands. Housing prices as well as single-family developments are too high for young families. The District states there must be more options for young families, such as 3-bedroom apartments.

The District states that the City can assist vulnerable populations through a good socioeconomic plan, and through rezoning or zoning certain areas as multi- use for young families. At present, development pressure is concentrated on the outskirts of town due to a lack of infill development opportunities. The District states that the Planning Department will have to change some of the current zoning. If there are no land use changes, there will be no opportunities for various options. The District understand that Measure U presents challenges but is prepared to address those challenges with the City.

8.2.2 San Bernardino County Homeless Partnership
The County of San Bernardino (C ounty) Homeless Partnership manages and invests entitlement monies, such as HOME and ESG funds, and allocate them throughout participating jurisdictions. Participating cities may apply for these funds or be assisted through County-funded programs.

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The County states that any City should appropriately zone for multi -family uses Jurisdictions should also be willing to look at non -traditional housing types (smaller units, ADUs, manufactured homes) that may be more cost -effective. For City of Redlands, the County suggests the apply land use while taking into consideration neighborhood characteristics. The City should also be familiar with different partnerships that are available for various funding sources. There are other methods to meet RHNA goals beyond single-family homes with single-family lots (traditional housing).

The County stated that partnerships can assist these populations. There are limited housing resources and partnerships can assist. The County would like jurisdictions lead housing projects (affordable housing or additional housing units), which includes partnering with the developer, partner with the community through the process to add affordable housing stock (community outreach) and provide financial support (alleviate economic burden). The City can apply what they used to do with the Redevelopment Agency.

Instead of treating affordable housing like “any other development project”, they have the ability to guide it through the system.

Finding a balance between new mandates to provide housing and what land is available to absorb these new housing units. This may be met by assisting elected officials and residents explore different types of housing developments that are not considered “traditional”. Through community outreach, similarly to this stakeholder interview, the City can identify areas and places that may be best for new housing units.

ADUs may help meet housing goals and provide alternative living situations for various circumstances.

There should also be a mutual understanding that housing does not pay for services, so the City should be understanding of the economics associated with units, such as fire, police, etc.

8.2.3 Redlands Area Interfaith Council
The Redlands Area Interfaith Council (RAIC) brings groups of people together to interact with one another, acting as an educational group. RAIC also brings in various speakers to these members to inform them what is happening in their community.

RAIC believes the real challenge to building more housing is due to local opposition to low-income housing units. RAIC recognizes that affordable housing plans are needed and has noticed that many lower-income housing units are placed in one area, specifically the West Area, which exacerbates problems there.

RAIC suggests spreading affordable housing units throughout Redlands but is unsure if voters would pass this. RAIC mentions that there are no shelters or active shelters in the City of Redlands. RAIC believes the most vulnerable population are people experiencing homelessness, low -income households, and young families/single-family households. RAIC occasionally works with nonprofits, who are directly engaged with these communities, and knows it is difficult to find affordable housing for these populations. RAIC notes that there is no support system for these individuals and also mentions veterans as a vulnerable population.

RAIC believes apartments are the most affordable way for families to live. However, most of the apartment complexes in Redlands have been controversial. RAIC notes the geographic spread of new apartments, and also states that having walkable neighborhoods would help. RAIC notes that residents of North-west Redlands do not live close to a grocery store, and that transit opportunities would also be beneficial.

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RAIC also believes that the homeless population should be a priority, especially in regard to semi- permanent housing, and states that the greatest challenge will be working with the residents. It has been difficult to bring them on board for housing growth. Redlands residents enjoy the characteristics of a “slow growth” and “small-time feel town”. RAIC suggests focusing on the bigger picture, utilizing more intensive focus groups, increased community outreach, and in-person education. It is also important to remove the image of “outsiders” coming and telling the community what to do—local developers should be involved with development.

8.2.4 Family Service Association of Redlands
Family Service Association of Redlands (Family Service) is a small to midsize nonprofit that provides emergency housing support, emergency food, transportation assistance, daily meals, bus passes, and education assistance. Their emergency rental assistance program helps fight and prevent homelessness by providing emergency financial assistance to families facing eviction or who are behind on rent.

Family Service states that the core problem is affordability of homes. For minimum wage workers, if they experience a financial crisis (sickness, caregiving, funeral, etc.), it will affect their paycheck and send them “down a spiral .” There is a need for more affordable housing stock. Family Service recognizes that affordable housing is costly and not cost-effective, and states it may be helpful to find a developer to create construction for affordable housing.

The most vulnerable populations are households with children under 18 with fixed i ncome at, below, or slightly above poverty line; people experiencing homelessness; and elderly and disabled individuals with fixed incomes. A recent point -in-time count shows a 95% increase in elderly/disabled individuals experiencing homelessness.

Family Service believes that focusing efforts on creating affordable stock by working with HUD or other partnerships can assist these populations. Another way to assist would be providing resources, such as land or financial support. Family Service does not have land, so they work with landlords to get their clients into housing. However, finding housing that aligns with the individual’s budget is difficult due to rising costs of apartments. Thus, families are sharing homes, which leads to overcrowded homes and makes children more vulnerable to sex abuse. Currently, Family Service is in the process of creating the tiny homes and hopes both the City and residents supports this project.

Family Service believes resident perception and resident pus back may be the gre atest challenge.

Currently, the perception amongst residents is that affordable housing will be an eyesore to the community, and that there is a stigma of lower incomes being correlated with “bad people.” Family Service would like to encourage the City to continue to push forward with their efforts for development, especially for vulnerable families. With the COVID-19 pandemic, there is a need for change to develop and have housing stock.

8.2.5 Northside Redlands Visioning Committee
The Northside Redlands Visioning Committee (Committee) is a grassroots organization formed after the termination of the Redevelopment Agencies. The Committee believes that, through policy, it may be possible to develop tax credits for developers. This creates an incentive for developers to build affordable

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units. The Committee also believes easing conditions for approval for housing tracts that are being considered will help build more housing. For example, a percentage of units should be dedicated to affordable units or for various income levels. The Committee urges for new, innovative methods to address housing crisis. For example, creating a First -Time Home Buyer Program will assist in building homes as well as be a starting investment for young families.

The Committee believes the wage earners (blue collar, service industry), unhoused seniors, and people experiencing homelessness are the most vulnerable populations. The Committee feels it should be easier for blue collar workers to live and work in the same city. The Committee would like to see consideration for workforce housing, housing that accommodates regional transportation, and different incentives for First-time Homebuyers.

The Committee feels that the greatest challenge is a lack of access to affordable housing. Another challenge is that developers are not invested in the community. They are tasked to develop and receive fee waivers/incentives. The Committee would like to see investment in the community that is directly applicable to the community rather than for the sake of investment.

8.2.6 East Valley Association of Realtors
The East Valley Association of Realtors (EVAR) is a collective association that is engaged in policy making and advocacy, focusing on State and local policies. EVAR would like to focus density in the downtown core area of Redlands. He recognizes that it is not possible to build affordable housing on Sunset Drive. He would like to look at underutilized areas in the City. For example, the Redlands Mall is not a thriving center and there is not much demand for the retail and commercial space. EVAR would like to push for vertical, residential development in the downtown area. Another strategy is to have more mixed, affordable units within the same neighborhood. For low-income households with subsidized housing, it could include more dense development.

EVAR believes the marginal communities in North Redlands, such as lower-income households and people of color, are the most vulnerable. They already live in overcrowded homes or have not been able to pay rent. EVAR believes that people experiencing homelessness with mental health issues as well as veterans are a vulnerable population in terms of having affordable housing.

For moderate-income households, density growth may assist in affordability and may not cost much t o subsidize the construction of these units. The possibility to achieve these is greater than developing single- family homes. For low-income households, the City can pursue grant funding and bond funding through State or County funds. This can help subsidize development costs for low -income households. They City can also reform permit processing, streamlining process (which induce significant costs of construction).

EVAR suggests that creating flexibility in zoning for underused commercial buildings to be u sed for residential housing can also assist. For example, a big-box retail space could potentially be converted into a mixed-use or fully residential development. These existing spaces already have the services, such as electricity, water, and sewer, needed. EVAR states the greatest challenge is the perception residents of Redlands have regarding affordable housing, or housing developments in general.

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8.2.7 Building Industry Association
The Building Industry Association (BIA) SoCal Chapter is composed of homeow ners, subcontractors, contractors, engineers, trade contractors, plumbers, etc. (people involved in the “home building industry”). Their primarily function is to advocate for housing for all socioeconomic levels. They host an annual housing policy conferen ce to provide legislative updates as well as provide a space for collaboration for resources to Cities that may need assistance in local policy reformation.

BIA would like to see the permanent removal of the ballot imitative that capped development to 300 units per year (SB30 for City of Redlands), and agrees with State legislation that came in to require housing. An array of zoning densities may be another strate gy to meet housing goals. Diversifying housing stock, especially looking to fortify 4,500 square lots, will assist the City. Other desired items include relaxed design requirements because design fees make it more difficult to obtain/construct housing for people of all financial backgrounds.

BIA believes that low- income population is most vulnerable because it is difficult and costly to build affordable housing, and notes it is also challenging to build when a community does not want additional development. BIA suggests that churches can identify surplus church land can provide an opportunity to do infill projects. Any collaboration is necessary to see available land opportunities. BIA refers to different models (City of Riverside, Placentia, Bellflower, etc .) where they leased surplus property from churches , noting that affordable housing for seniors could be built there. BIA also encourages the City to look at prior examples done by different cities.

Finally, BIA noted there is push back to new development. In terms of addressing the community, it is helpful to conduct quarterly focus groups (working groups) for best practices with the City. BIA currently meets with the City of Ontario on a quarterly basis to have a dialogue about fees, delays, etc. so both parties have a mutual understanding of the development process.

8.2.8 Inland SoCal United Way
Inland SoCal United Way (ISUW) comprises three organizations that have merged (United Way of the Inland Valleys, Inland Empire United Way, and Community Connect). ISUW states that educating the public will best assist the City to meet their RHNA goals. NIMBYism is prevalent, and ISUW feels that educating the public will help shift public perception. ISUW states that meeting cost of living wages will greatly assist in housing. They both agree that living wages correlate to housing.

ISUW feels that the most vulnerable populations are those in extreme poverty. ISUW would like to address homelessness by avoiding homelessness in the first place. ISUW would like to see if businesses could be encouraged via credit to hire folks with that living wage. This leads to re-investment into the community and community building. Workers would be able to live and work in the City. ISUW states that there are available funds for rental assistance and should allocate these funds to assist housing issues. Another way to assist these populations is to build affordable housing.

ISUW identified challenges to housing production that included difficulty in construction, whether due to permitting or with construction delays. Another challenge is the counter intuitive policies set in place.

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8.2.9 Inland Temporary Homes
Inland Housing Solutions (IHS) is a nonprofit organization that provides rapid rehousing services, emergency rental assistance, and are se rvice providers for people experiencing homelessness. IHS believes the best strategy is by addressing the need for affordable housing development and to be in agreement with strategies laid out in the County of San Bernardino. IHS states that the City needs to be more strategic in placing affordable housing. They should place these units in areas that are undeveloped.

For example, scattered site housing should be implemented, instead of place all affordable housing units in one area in the City. IHS also would like to advise that additional housing requires additional services, such as police, safety, roads, commercial, etc. so the City should be strategically while taking all these aspects into consideration.

IHS believes that the low-income earners are the most vulnerable population. Specifically, those who are employed in the service, hospitality, and retail sectors of the economy who make minimum wage. It is difficult to maintain cost of living with minimum wage jobs, and Redlands becomes cost prohibitive if the individual is the main provider for the family.

In terms of housing, IHS believes the City should utilize the current housing they have and utilize underdeveloped/undeveloped and that a city cannot build their way out of homelessness. IHS believes that having a study conducted that gathers information regarding homeless individuals, such as where they originated, if they are Redlands locals, and if they attended Redlands High School. This can feed into marketing to change public perception. This can also feed into the targeted populations and how to address their specific needs. IHS suggested that the City could possibly create three models that are pre- approved which relates to faster, more accessible construction of ADUs. The City can also assist in allowing easier permits, fast-track processes, and flexible plan checks to expedite ADU developments. IHS stated the greatest challenge to new housing in the City is the restrictions due to environmental land and the building affordable housing with requisite services.

8.2.10 University of Redlands
The University of Redlands is a private institution for higher education with approximately 5,000 students.

They are located in the TVSP and own approximately 30 acres of undeveloped land. The University of Redlands would like to push a mixed- use village, not so focused on university house, for the transit - oriented station that aligns with the goals of the City of Redlands’ TVSP.

University of Redlands believes the best strategy is through redevelopment or infill development of sites such as the Redlands Mall and University Village Site. Garden style apartments and single -family homes seems to be more accepted by the public. There is also potential in the under-utilized spaces in downtown for the City to meet current housing goals. Three -to-four story buildings were stated as the best fit for character of Redlands.

University of Redlands believes that breaking down the barriers for housing for low-income households are required. There is a need to increase the supply for housing that is attainable to the 50 -80 percent AMI population. Expediting approval processes and improving policies that can specifically target and address these issues can be helpful. For the lower -income population, there are tax credits and bonds that are currently assisting their needs.

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Public perception is a challenge in terms of housing needs. Educating the public and helping them understand that density is not equivalent to high-rises will be greatly helpful in public acceptance. Another challenge is the growth control measures and its corresponding impacts to development. Instead of removing growth control measures, revisions and reformed are required. University of Redlands is also concerned about the flood zone affected development, due to the increased cost of mitigation.

8.2.11 Redlands Chamber of Commerce
The Redlands Chamber of Commerce’s (Chamber) mission is to advocate for local businesses and help create a better business envi ronment. The Chamber states the demographics of the community has shifted. In the Chamber’s experience, many households are not looking to buy a home. With that, the Chamber notes that density can help the City meet their RHNA goals, and that the TVSP be i deal if development is done correctly. The Chamber notes there is not much land left for development under current zoning. Rezoning of commercial sites could hurt the local businesses.

The Chamber notes that North Redlands consists of mostly minorities, while South Redlands is mostly white. The Chamber also notes that most of the service providers and nonprofit organizations are located and serving the Northside. The Chamber broadly states that housing credits to certain population s can assist with those vulnerable populations obtain housing, and that anything would be helpful versus doing nothing.

The Chamber recognizes that one of the greatest challenges is identifying where to build future housing.

Infrastructure poses another challenge. For example, public transportation is available in the City of Redlands, but is not located near the underserved population. It is difficult to reach current, existing bus stops to where they are currently located. The “donut hole” (unincorporated Redlands) has higher density for housing, has existing public transportation, and apartments with amenities. The Chamber would like to see some of those aspects incorporated into Redlands proper, specifically within the TVSP. The Chamber notes the southern portion of the City wo uld be a perfect location for housing because infrastructure (roads, electrical lines, gas lines, etc.) is already available in that area.

Public perception can be a challenge, but the Chamber believes this challenge can be ameliorated. The Chamber notes there was discord between the public and Council with Measure G (redevelopment of the Redlands Mall). The public advertising created only addressed one item, rather than the five items. The Chamber believes Measure T was supported because it was developed through a citizen oversight committee. While a committee can only provide recommendations to the City Council, a committee may help the public lend more trust in future housing and land use related measures.

8.3 COMMUNITY WORKSHOPS
The City of Redlands held two Community Workshops for the Housing Element update. The first one was held on Monday, April 26 and had 11 attendees from the public. The second one was held on Thursday, May 13 and had six attendees from the public. The public asked several questions regarding the Housing Element update at both meetings.

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8.3.1 Survey Questions at Community Workshops
Below are the survey questions provided to the participants at each workshop, followed by questions the participants ask in the Workshops Q and A boxes.

How long have you lived/worked/attended school in the City?

Are you a homeowner, renter, landlord, or other (please select all that apply to you)?

18%
9%
64%
9%
0%
20%
40%
60%
80%
Less than 5 years 5-10 years More than 10 years I do not live/work/attend
school in Redlands
April 26 Community Workshop
73%
9%
0%
27%
0%
20%
40%
60%
80%
Homeowner Renter Landlord Other
April 26 Community Workshop
50%
0%
50%
0%
0%
20%
40%
60%
Less than 5 years 5-10 years More than 10 years I do not live/work/attend
school in Redlands
May 13 Community Workshop
50% 50%
0% 0%
0%
20%
40%
60%
Homeowner Renter Landlord Other
May 13 Community Workshop

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What type of housing do you live in?

Where in Redlands do you live?

82%
0% 0% 0% 0% 0% 0%
18%
0%
20%
40%
60%
80%
100%
Single-famul dwelling
Accessory Dwelling Unit
Duplex, Triplex, Quadplex
Condominium
Apartment Building
Mobile Home
Assisted/Group/Senior
Housing
Other
April 26 Community Workshop
75%
0%
25%
0% 0% 0% 0% 0%
0%
20%
40%
60%
80%
Single-famul dwelling
Accessory Dwelling Unit
Duplex, Triplex, Quadplex
Condominium
Apartment Building
Mobile Home
Assisted/Group/Senior
Housing
Other
May 13 Community Workshop
45%
0%
18%
27%
9%
0%
20%
40%
60%
District 1 District 2 District 3 District 4 District 5
April 26 Community Workshop
50%
0%
50%
25%
0%
0%
20%
40%
60%
District 1 District 2 District 3 District 4 District 5
May 13 Community Workshop

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Please select the top three (3) housing issues facing people in the City of Redlands (multiple choice).

Other: Housing close to local jobs

75% 83%
68%
0% 8% 8% 17%
0%
20%
40%
60%
80%
100%
Homelessness
Cost of housing
(rent/mortgage/down
payment, etc.)
Ability to purchase a home
ADA accessiblity
Substandard housing
quality
Housing segregation and
discrimination
Access to transit/commute
time
April 26 Community Workshop
67% 67%
0%
33%
0% 0%
100%
33%
0%
0%
20%
40%
60%
80%
100%
Difficulty paying rent,
mortgage, down-
payment, etc.

Lack of suitable or
needed housing type
(size, senior, group)
ADA accessibility
Substandard housing
quality
Housing segregation and
discrimination
Access to
transit/commute times
Insufficient housing
supply
Homelessness
Other
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Please provide your top three (3) programs to improve housing access in Redlands (multiple choice).

Other: Updating the City ordinances to be more in-line with what is currently going on. Provide assistance to purchase homes

50%
33% 25%
50% 42% 50%
8%
0%
20%
40%
60%
80%
100%
Inclusionary housing
Minimum densities
Incentives for developers
Reduce excess parking/landscaping
requirements
Permit streamlining
Pre-approvied ADU plans
Other
April 26 Community Workshop
33% 33% 33% 33%
100%
67%
0%
0%
20%
40%
60%
80%
100%
Inclusionary housing
Minimum densities
Incentives for developers
Reduce excess parking/landscaping
requirements
Permit streamlining
Pre-approvied ADU plans
Other
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What are your top three (3) most important criteria for selecting land for housing (multiple choice)?

8.3.2 April 26 Q & A Box
Is there anything that we can do to extend public transportation to the East end of the city / Mentone?
 As noted, transit services currently end at the University of Redlands. However, proximity to employment is very important, as transit follows routes to reach th e most riders. With development surrounding the potential Arrow Rail stations, potential ridership may increase in a 42% 50% 58%
83%
58%
0%
0%
20%
40%
60%
80%
100%
Proximity to transit
Proximity to
commercial/professional services
Proximity to grocery stores
Proximity to community facilities
(parks, schools, civic center, etc.)
Proximity to employment
Other
April 26 Community Workshop
83%
33%
50%
83%
33%
0%
0%
20%
40%
60%
80%
100%
Proximity to transit
Proximity to
commercial/professional services
Proximity to grocery stores
Proximity to community facilities
(parks, schools, civic center, etc.)
Proximity to employment
Other
May 13 Community Workshop

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way that would make transit to Mentone more likely. Omnitrans is in charge of transit within the County of San Bernardino, and participants are suggested to direct questions or suggestions for new services to them. The City will forward this comment to Omnitrans.

How many of the transit stops provide 15 -minute or better service frequencies?  The City does not have that information at present. The majority of stops within the half mile buffer have a 20-minute leeway. A few meet the 15-minute leeway. Commenters are directed to Omnitrans for specific service information.

Although accessibility has not been ranked as a high concern, what is the imp act to having ADA accessibility as a requirement? It seems like building in accessibility is less expensive than retro. It could be a selling point for developers since accessibility allows access to small children, wounded vets, and the elderly.
 Agreed, i ncreased accessibility increases access for seniors and children. Building retrofits are done so with accessibility in mind. It is worth looking at programs to increase accessibility in the Transit Village Specific Plan Area. At present a 3 -story residential building is the tallest type of building that does not require an elevator within Redlands. To encourage further accessibility, there could be a City program to increase elevator access in 3 story buildings that already exist or may potentially exist in the future.

Are there any community centers or senior centers planned for the East end of the city? There is much housing developed there but it appears most services are still concentrated near the commercial sector.
 The City is not aware of new facilities for seniors in the east side of the City. The City can share that comment.

How is the homeless population distributed across cities in Southern California? Does a government agency assign them to cities, or they move to the area they like?
 Homeless populations are not governed by anybody. They self-select where they would like to be, but generally congregate near areas of transit, services, or areas they are familiar with. There are no governmental controls regarding homeless populations.

Will denser dev elopment increase local transit frequency?  Ideally, the two go together. Greater densities allow for greater ridership, which allows for greater transit frequency. The two are complimentary factors, but one does not necessarily cause the other. The City is looking to marry those two as best they can.

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Since business provides more revenue than city expense and residential is opposite, is there planning to balance residential with commercial? This would limit need for transit, too.
 Commercial uses do not nece ssarily increase revenue. Residential uses require more in infrastructure than in terms of revenue, but they should not all be lumped into one category. In some cases, single family residential development has higher maintenance costs due to larger amount of utilities required for each unit. Multifamily development, like commercial, tends to pay for itself.

Has the City looked at what resources Omnitrans would need to increase transit service frequencies and extend service to the eastern end?  It is part of the City’s regular process to route proposed developments to Omnitrans for comment and how the project would/could integrate into the Omnitrans network. There is coordination between agencies.

Are the proposed high density / low -income housing areas close to similar income employment opportunities?
 Any proposed developments that would meet HCD standards for low -income housing are generally located near employment opportunities, as seen on the web -map. Most low -income areas are located in the East Valley Corridor and is well covered by existing services.

Will the Redlands mall get the Measure U exemption? Is MBI helping with that?  The Redlands Mall will be discussed at Tuesday’s Planning Commission meeting, and MBI will not be involved with that project.

Just a comment responding to an earlier question. There is a Library & Senior Center in Mentone (operated by the County) that can serve Redlands residents on the east side of town.
 The Library and Senior Center of Mentone will be added to the web-map.

8.3.3 May 13 Q & A Box
It’s disappointing that there is no average income housing planned for within the transit villages specific plan
 Dan Wery noted that HCD utilizes density as a proxy for income levels. For instance, 30 dwelling units to the acre would be suitable for low-income housing, while 12 units to the acre would be suitable for moderate income housing. Thus, the housing planning within the Transit Villages Specific Plan would be planned for (as the City merely has to plan for, not construct, housing) 30 dwelling units to the acre in order to accommodate housing at all income levels within this part of the City.

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8.3.4 GENERAL THEMES
A few common themes emerged from comments received at both public outreach meetings, including the following:

Affordability is a prio rity. Several participants questioned if more affordable housing will be constructed in the City in the near future, and how these affordable units will be distributed across the City.

To address the issue of affordability, the City will undertake Program 1.1-3 to amend the Zoning Ordinance to require by-right approval of housing development that includes 20 percent of the units as housing affordable to lower -income household on sites previously identified in the past two Housing Element cycles, and Progra m 1.2- 4, a Single Room Occupancy Ordinance to provide additional housing opportunit ies for low - and very low- income households near the planned Metrolink Stations. The City will also undertake several programs to assist with the construction of affordable Accessory Dwelling Unit construction, and will also undertake Program 7.3-2, which calls upon the City to Study and consider the adoption of an inclusionary housing ordinance. Additionally, Program 1.5-9 calls upon the City to continue to implement the Mobile Home Rent Control ordinance to prevent displacement of lower-income and at risk populations.

Homelessness and assistance for those near homelessness is also a concern. There is a need for permanent supportive housing and temporary housing for those suf fering from homelessness and for those with disabilities. Also mentioned was a synergistic need for increased social services in tandem with housing solutions.

To address this issue, this Housing Element contains Program 1 .2-1 to address emergency shelter s, Program 1.2-2 to provide opportunities for Low Barrier Navigation Centers in the City, and Program

1.2-3 to address supportive housing. Program 1 .2-4 will establish a Single Room Occupancy Ordinance to provide additional housing opportunities for low- and very low-income households near the planned Metrolink Stations. Program 1.2-5 has been included to implement mitigating strategies to remove potential constraints on the production of large group homes. Additionally, Program 1.3-7 would administer County funds to service providers including local nonprofits in coordination with City Police Department Homelessness Liaison.

There is community opposition to high density housing in the City. This presents a large constraint, as there are preconceived notio ns regarding affordable housing and those who would occupy affordable units. The general attitude of the community is one of the most frequently mentioned constraints by stakeholders.

Program 1.5-4 has been included in this Housing Element, calling upon the City to Continue to implement the Mobile Home Rent Control ordinance to prevent displacement of lower -income and at-risk populations. The City will implement program 1.6- 1, through which the City will promote incentives and tools available to facilitate ADU construction. Provide easily accessible information on the City's website, at the zoning counter. Coordinate with SBCTA to utilize regional resources and adopt policies, procedures, and standards consistent with neighboring jurisdictions to streamline ADU applications. Additionally, Program 7.5-3 calls upon the City to publicize Fair Housing Information, including information about tenants’ rights, landlord requirements, and recent litigation on the City's

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website, social media platforms, and through physical promotional material (e.g. , flyers, posters) to inform the community about Affirmatively Furthering Fair Housing.

There was repeated concern regarding the siting of new housing units, especially in conjunction with the Transit Villages Specific Plan and existing transit options. At present, most transit services terminate in Redlands given its position in the Inland E mpire. Most stakeholders expressed a desire for new units to be well -connected to existing services and established transportation routes.

Programs 1.1-2 and 1.5-8 has been included in this Housing Element to provide additional capacity for residential development in the City's highest opportunity areas through the Transit Villages Specific Plan (TVSP). Adoption the TVSP by the end of 2022 aims to allow for greater residential development around the three new light rail stations. The City will use the TVSP to facilitate smart- growth planning principles, downtown revitalization, and infill development. Additionally, Programs

1.2-12 and 1.2-13 will amend the zoning ordinance for C-3, C-4, and A-P zones to clarify mixed-use requirements, clarify the requirements and allowances for mixed -use and residential development in these zones, c reate objective standards for mixed -uses, and, as appropriate, change the zoning standards to encourage commercial recycling and residential development in these zones.

Concerns were raised for the ability of young families to afford to live in Redlands, with mentions of the need to build equity in the community, either through tiny homes or accessory dwelling units.

Programs 1.6-1, 1.6-2, 1.6-3, and 1.6-4 have been included in this Housing Element to more easily provide alternative housing typologies such as accessory dwelling units (ADUs) that have the potential for housing families. Program 7.1-1 incorporates the City’s requisite rezoning to accommodate 1,898 very low and low income units, 782 moderate income units, and 1,538 above moderate income units, units that could potentially be utilized as starter homes for young families seeking to build equity.

Additionally, Program 1.2-7 calls upon the City to amend parking requirements, open space standards, and setbacks for multi -family properties to further incentivize and encourage higher density development.

Participants have stated that land use restrictions, including those implemented through Measure U, are a hinderance for further housing developments, especially affordable housing developments. Additional constraints mentioned by the public included permitting difficulties and construction costs.

Programs 1.2-14 and 1.2-15 have been included to reduce permitting requirements for new housing in the City, such as removing the CUP requirement for buildings taller than 35 feet, and waiving pre- application meeting fees and providing technical assistance to projects that propose to provide below market-rate units. Program 1.2 -16 aims to provide information and maps of known environmental constraints at the zoning counter to provide additional clarity and certainty and mitigate non- governmental constraints for project applicants . Additionally, Program 1.6-2 makes a variety of example ADU plan sets available to facilitate reduced applicant cost and expedited review for ADUs.

Ensure example plans provide choices and diversity in size to accommodate a variety of household sizes and types.

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8.3.5 Policies
To address affordability, Program 1.1-2 would allow for by-right approval of projects with 20 percent affordable units on a “reused” Housing Element site. Additionally, Programs 1.6-1, -2, -3 and -4, will allow for the development of ADUs, including affordable ADUs.

To address homelessness, the City is adopting P rograms 1.2-1, -2, -3, -4, and -5. These programs are meant to facilitate the development of emergency shelters, low barrier navigation centers, transitional housing, supportive housing, single-room occupancy units, and group homes in order to provide for a variety of housing typologies to shelter at -risk populations. Programs 1.3 -7 and - 8 are added specifically to administer CDBG funds to service providers including local nonprofits, and to continue assisting in connecting homeless individuals to local service providers, as well as continue funding shelter beds with available grant funding and donations.

To address Measure U and community opposition, Program 1.1 -1 will allow for the necessary rezonings to allow for new housing developments that could be permitted without discretionary action. Program 1.1- 2 will allow for greater residential development around the three new light rail stations, and implement objective design standards with a form -based c ode. Program 1.2- 13 will remove the current CUP requirement for buildings over 35 feet. These programs will provide the necessary land use and zoning framework for the City to develop a variety of housing types at densities that can support moderate and lo wer-income units, which could be permitted on a regular basis without the need for a General Plan Amendment s, CUPs, or other politically sensitive actions.

Additionally, Program 1.1-2 would allow for by-right approval of projects with 20 percent affordable units on a “reused” Housing Element site.

To address the siting of new housing units, Program 1.1 -1 will allow for the necessary rezonings to allow for new housing developments that could be permitted without discretionary action. Program

1.1-2 will allow for greater residential development around the three new light rail stations, and implement objective design standards with a form -based code. These programs will focus future housing development in the City closer to existing transit options, such as bus and rail, as well as exiting job centers, such as downtown Redlands, the University of Redlands, and the Esri campus.

To address the building of equity, Program 1. 3-2 is added to study the viability of an inclusionary housing ordinance. Program 1.4-1 is added to preserve at -risk publicly housing units, while Program

1.5-9 will continue to implement to Mobile Home Rent Control ordinance to prevent displacement of lower-income and at risk populations, continuing to allow these populations to build equity.

To address land use restrictions, such as Measure U , Program 1.1 -1 will allow for the necessary rezonings to allow for new housing developments that could be permitted without discretionary action. Program 1.1- 2 will allow for greater residential development around the three new light rail stations, and impl ement objective design standards with a form -based code. Program 1.1-5 would require minimum densities to ensure residential projects are developed close to their maximum densities.

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Appendix D:

Zoning Code
Abbreviations

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Zoning Code Zoning Designation
A-1 Agricultural
A-1-20 Agricultural
A-2 Estate Agricultural
R-R Rural Residential
R-R-A Rural Residential Animals
R-A Residential Estate
R-A-A Residential Estate Animals
R-E Residential Estate
R-S Suburban Residential
R-1 Single-Family Residential
R-1-D Single-Family Residential
R-2 Multiple-Family Residential
R-2-2000 Multiple-Family Residential
R-3 Multiple-Family Residential
A-P Administrative & Professional Office
A-P-C Administrative & Professional Commercial
M-F Medical Facility
E Educational
C-1 Neighborhood Stores
C-2 Neighborhood Convenience Center
C-3 General Commercial
C-4 Highway Commercial
C-M Commercial Industrial
M-P Planned Industrial
M-1 Light Industrial
I-P Industrial
M-2 General Industrial
P Off Street Parking
O Open Land District
T Transitional District
A-D Airport District
HD Hillside Development
C-D Civic Design District
FP Flood Plain District

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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov

November 15, 2021

Brian Desatnik, Director
Development Services Department
City of Redlands
35 Cajon St.

Redlands, CA 92373

Dear Brian Desatnik:

RE: City of Redlands’ 6
th Cycle (2021-2029) Draft Housing Element

Thank you for submitting the City of Redlands’ (City) draft housing element received for review on September 17, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on November 12, 2021 with you, Catherine Lin (Principal Planner) and your consultants. In addition, HCD considered comments from Dennis Bell and Josh Albrektson pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

The City’s statutory deadline to adopt a housing element was October 15, 2021. For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of this statutory deadline, then any rezoning to accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate.

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Brian Desatnik, Director

Several federal, state, and regional funding programs consider housing element com
pliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For
your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf
and
http://opr.ca.gov/docs/Final_6.26.15.pdf.

HC
D appreciates the hard work and dedication Catherine Lin, Principal Planner, and your consultants provided during the housing element update. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Marisa Prasse, of our staff, at [email protected].

Si
ncerely,
Pau
l McDougall
Encl
osure
Senior Program Manager

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City of Redlands’ 6th Cycle Draft Housing Element Page 3 November 15, 2021

APPENDIX

CITY OF REDLANDS

The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml .

Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the Government Code addressing State Housing Element Law and other resources.

A. Review and Revision

Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)

The review of past programs should report progress in implementation and evaluate effectiveness of programs in achieving goals and objectives. In turn, future programs should be revised as appropriate to better achieve program goals. In many cases, programs were not implemented in the 5
th cycle housing element, and others were done so after the dates stated in the programs. The element should discuss the lack of timely implementation and what will be done differently in the 6th cycle housing element. In other cases, the element does not evaluate the effectiveness of programs and as a result, the element should be revised.

Examples of programs that need additional information and evaluation include, but are not limited to:

• Program 7.2-11 (Assist with Foreclosure Prevention): Describe and evaluate how frequently the City updates the foreclosure prevention resources and how many homeowners were assisted by the program.
• Program 7.4-12 (Threshold and Conditional Use Permit): Describe how the City evaluated the conditional use permit requirement and reached its conclusion that it has not been an impediment to multifamily development.
• Program 7.5-4 (Senior and Handicapped Housing): Describe how many households were assisted under this use of CDBG funds.
• Program 7.5-5 (CDBG Rental Rehabilitation): Describe how many households were assisted under this use of CDBG funds.
• Program 7.6-1 (Buy-Out Assistance): Describe how the City implemented this program, what actions the City took, and how many units were assisted in the 5 th cycle planning
period.
• Program 7.7-1 (Fair Housing Counseling): Describe how many households were assisted by fair housing counselling during the 5th cycle planning period.

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City of Redlands’ 6th Cycle Draft Housing Element Page 4 November 15, 2021

In addition, as part of the review of programs in the past cycle, the element must provide an evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness). For more information, See HCD’s Building Blocks at https://www.hcd.ca.gov/community- development/building-blocks/getting-started/review-revise.shtml.

B. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)

Integration and Segregation: The element includes information on segregation and integration at the local level for race/ethnicity, disability, familial status, and income; however, the regional analyses for race/ethnicity and income need improvement, and some of the conclusions do not reflect the data. The data presented in the Affirmatively Furthering Fair Housing (AFFH) analyses and Housing Needs Assessment (Table 2.1-3 on p. 8) do not support the element’s conclusions that the difference between the City and County’s proportions of non-white Hispanic populations is similar. In addition, the local analysis of segregation by income should be clearer about the north to south patterns and trends. Furthermore, the City is significantly more affluent than the County (Table 2.4-1 p. 16), with 14 percent more of the population in the above-moderate income category compared to the County, yet this is not adequately analyzed or stated. The element should adequately analyze patterns and trends of segregation and integration, include a comparison of the City to the region, and consider other data options such as Census median income by block group. The element’s summary of integration and segregation fair housing issues should be revised to reflect the data and analyses.

Racial/Ethnic Concentrated Areas of Poverty (R/ECAP) and Affluence (RCAA): The element notes there are no R/ECAPs in the City. However, the City does have an area of High Segregation and Poverty according to TCAC/HCD Opportunity maps and should include specific analysis. The analysis should address trends, past and current efforts, including investment and their effectiveness, local data and knowledge, other relevant factors (as noted below), particularly relative to equitable quality of life, resources, and strategies to address any inequities in quality of life. The analysis should also consider any overlapping fair housing issues with other components of the assessment of fair housing (e.g., access to opportunity and disproportionate housing needs, including displacement).

Furthermore, the element should analyze some of the census tracts that have significantly higher rates of white population and income as Racially Concentrated Areas of Affluence (RCAA). Adequate analyses of R/ECAPs and RCAAs will help guide goals and actions to address fair housing issues.

Disparities in Access to Opportunity: The element provides some information on access to opportunity for education, economic, transportation, and environmental, but it generally lacks analysis. The analysis of education opportunity should explain differences in school quality from neighborhood to neighborhood and include comparisons of the City to the

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region for education, economic, transportation, and environmental opportunity. In addition, the analysis of environmental opportunity across neighborhoods should match the CalEnviroScreen data presented, which shows clear disparities between census tracts, and should analyze differences in environmental hazard exposure between census tracts.

Please refer to page 35 of the AFFH guidebook (link: https://www.hcd.ca.gov/community- development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational, employment, environmental, transportation, and any factors that are unique to Redlands.

Disproportionate Housing Needs, Including Displacement: The element does include some information on overcrowded households, substandard housing conditions, homelessness, and cost-burdened households, but it must also analyze spatial trends of substandard housing conditions and homelessness. Furthermore, the displacement analysis should consider (1) any overlapping fair housing issues with other components of the assessment of fair housing (e.g., access to opportunity and disproportionate housing needs, including displacement), (2) displacement risk from environmental hazards such as flood zones, and (3) displacement risk of new transit investments and upzoning to existing low-income census tracts in the absence of substantial affordability and anti-displacement programs.

Local Data and Knowledge and Other Relevant Factors: The element must include local data, knowledge, and other relevant factors to discuss and analyze any unique attributes about the City related to fair housing issues. The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates and service providers. Also, the element must include other relevant factors that contribute to fair housing issues in the jurisdiction. The element should analyze historical land use and investment practices or other information and demographic trends.

While the element includes some information on the history of Redlands (pp. 215-216), it should also describe historic spatial patterns of segregation (ex: spatial patterns of racially restrictive covenants, historic patterns of where residents of different racial/ethnicity backgrounds lived, historic preservation districts, etc.), the environmental justice impacts of the siting of infrastructure and industrial uses, the City’s history of anti-growth land use measures, and the lasting impacts of these actions.

Contributing Factors: The element must list and prioritize contributing factors to fair housing issues. While the element includes a list of 11 contributing factors, these factors should be prioritized based on the outcomes of a complete analysis. In addition, some of these contributing factors seem detached from the Assessment of Fair Housing analyses, while other salient fair housing issues identified in the Assessment of Fair Housing are missing from the list of contributing factors (e.g., North/South segregation by race/ethnicity and income, regional patterns of segregation by race/ethnicity and income, anti-growth and land use constraints). Finally, some contributing factors identified in the element lack adequately responsive programs (these include, but are not limited to displacement and increasing rents, community opposition).

Site Inventory: The element includes maps and graphs of the site inventory that indicate a further entrenchment of existing fair housing issues, and the site inventory is not

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accompanied by adequate programs to ameliorate these impacts. Furthermore, some of the conclusions in the AFFH site inventory analysis do not reflect the data – the transit villages areas are not high opportunity areas according to the TCAC/HCD opportunity maps, but rather shown as areas of high segregation and poverty, low resource, or moderate resource. The analyses, such as Figure 7.3-5 RHNA Units and City Acreage Comparison by Non-White Population, should address RHNA units by income groups (lower, moderate, and above moderate). While the transit village areas will eventually provide better access to transit mobility options and represent an exciting transit-oriented development opportunity, the element should expand the analysis and list of sites to better formulate development opportunities, goals, actions, and metrics that will result in broader equitable quality of life throughout the community. In addition, the analysis of identified sites should address the significant lack of housing opportunities for lower-income households in the southern portion of the city that are proportionally whiter, more affluent, have significantly improved environmental quality of life, better performing schools, and score higher on the access to opportunity maps so to address fair housing issues and avoid an isolation of the RHNA.

Goals, Priorities, Metrics, and Milestones: The element must add or revise programs based on a complete analysis, listing, and prioritization of contributing factors to fair housing issues. Goals and actions must significantly seek to overcome contributing factors to fair housing issues and include metrics and milestones to target meaningful fair housing results. Currently, the element identifies programs to encourage and promote affordable housing; however, most of these programs do not appear to facilitate any meaningful change nor address AFFH requirements. Given that significant portions of the City are considered high-income/opportunity areas, and because Redlands is significantly whiter and wealthier than San Bernardino County, the element could focus on programs that enhance housing mobility and encourage development of more affordable housing choices in an inclusive manner throughout the community. Furthermore, the element must include programs with substantial place-based investments and protection against displacement in areas of high segregation and poverty. For more information, please see HCD’s guidance at
https://www.hcd.ca.gov/community-development/affh/index.shtm.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)

Extremely Low-Income (ELI) Households: While the element identifies the projected number of ELI households, it must still analyze their existing housing needs. This is particularly important given the unique and disproportionate needs of ELI households. For example, the element could analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the magnitude of gaps in housing needs. For additional information, see the Building Blocks at
http://www.hcd.ca.gov/community-development/building-
blocks/housing-needs/extremely-low-income-housing-needs.shtml.

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3. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)

Housing Conditions: The element quantifies the age of the housing stock and includes some information on housing characteristics such as lacking plumbing or kitchen facilities.

However, it must also estimate the number of units in need of rehabilitation and replacement. For example, the analysis could utilize information from the housing element update survey (Appendix C), estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable organizations. This information could be analyzed geographically as part of the assessment of fair housing. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housing-needs/housing- stock-characteristics.shtml.

4. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov.

Code, § 65583, subd. (a)(3).)

Progress in Meeting the RHNA: The RHNA may be reduced by the number of new units built, permitted, approved or pending since July 1, 2021. The element lists (p. 57) 80 units affordable to lower-income households but it should also demonstrate affordability based on actual or anticipated sales price, rents or other mechanism ensuring affordability (e.g., deed-restrictions).

Small Sites: For your information, sites below 0.5 acres are not deemed adequate to meet the lower-income RHNA absent analysis that development below 0.5 acres is appropriate to accommodate the lower-income housing need. Some of these small sites were utilized toward demonstrating adequate sites to accommodate the lower-income RHNA and should not be utilized for the purposes of meeting no net loss law pursuant to Government Code section 65863.

Accessory Dwelling Units (ADU): The element assumes 15 ADUs per year for a potential buildout of 120 units within the planning period. According to HCD records, the City has permitted an average of 10 units per year, less than the 15 units assumed in the element.

The trends noted in the element appear inconsistent with HCD records and, further, are lower than the assumption of 15 ADUs per year. To support assumptions for ADUs in the planning period, the element should either reconsider assumptions, reconcile trends with HCD records or include additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate.

Infrastructure: The element must demonstrate sufficient existing or planned water, sewer, and other dry utilities supply capacity, including the availability and access to distribution facilities to accommodate the City regional housing need for the planning period. (Gov.

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Code, § 65583.2, subd. (b).) Furthermore, the element should address which sites may lack access to infrastructure, as p. 65 of the element states that some sites do not have existing infrastructure service. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/site-inventory- analysis/analysis-of-sites-and-zoning.shtml#environmental.

Environmental Constraints: The element must describe environmental conditions within the city, relate those conditions to identified sites, and describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period. This is particularly significant as it appears that the downtown and surrounding areas where a large share of development is planned, is subject to significant flood risk.

Electronic Sites Inventory Form: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance. Please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Zoning for a Variety of Housing Types:

• Emergency Shelters: The element should clarify if there are any spacing requirements and provide greater detail regarding development standards and whether they pose a constraint to the development of emergency shelters. • Permanent Supportive Housing: Supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with this requirement and include programs as appropriate.
• Employee Housing: Health and Safety Code section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Health and Safety Code section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone. The element must demonstrate zoning in compliance with these requirements or include programs as appropriate.

5. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures… (Gov. Code, § 65583, subd. (a)(5).)

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Measure U: The element explains a few aspects of Measure U such as limits on density, heights, residential unit allocations and traffic levels of service. However, the element should include a complete analysis to better formulate a programmatic response to this severe constraint. For example, the element should discuss potential conflicts with state law, including housing element and state density bonus law. The element should also address the full range of options for exceeding limits in Measure U, timing and cost impacts of a 4/5th vote, including approval findings, any and all other limits on development and how the Measure relates particularly to rezoning sites and accommodating the RHNA.

The analysis should address impact on housing cost, supply, fair housing choice throughout the city, affordability, timing and approval certainty. Based on the outcomes of this analysis, the element must revise programs.

Historic Preservation Measures: The element should provide greater detail and fully analyze the South Redlands Housing Conservation Overlay and the City Design and Preservation element processes mentioned on p. 93 as potential constraints to housing development for all income levels.

Processing and Permit Procedures: The element indicates that multifamily developments of 35 or more dwelling units are subject to a conditional use permit (CUP). The prior housing element had a program to address the CUP and 35-unit threshold as constraints.

Instead, the City merely evaluated the requirement is not a constraint and appears to have eliminated the program. The element (p. 100) also concludes the requirement is not a constraint because multifamily has been approved recently and because the process is no different between rental and ownership development. However, recent multifamily approvals and treating developments the same are not necessarily indicators that these requirements are not constraints. A threshold of 35 units is a constraint and so is the potentially roving approval findings of “…the proposed development is appropriate at the proposed location.” The element should include additional analysis of the threshold and approval findings for impacts on approval certainty, timing and cost and add or modify programs.

Building Codes and Their Enforcement: The element provides an overview of the building code, but it should also identify any local amendments to the building code and analyze impacts on the cost and supply of housing.

Streamlined Ministerial Approval Permit Procedures: The element should describe the City’s SB 35 (Chapter 366, Statutes of 2017) streamlined ministerial approval procedure and application and include programs if appropriate.

Zoning, Development Standards, and Fees: The element must clarify its compliance with new transparency requirements for posting all zoning, development standards, and fees on the City’s website and include programs if appropriate.

Constraints on Housing for Persons with Disabilities:

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• Definition of Family: The element should describe any zoning code definition of a family and analyze as a potential constraint on housing for persons with disabilities. • Group Homes with Six or Fewer Persons: The element describes that group homes for six or fewer persons are permitted in all residential zones. However, these provisions appear to be limited to group homes licensed by the state. Yet, the state does not license all community care facilities or group homes serving six or fewer persons. The element should either clarify that group homes without licenses are also allowed in all residential zones or include a program to address this constraint on housing for persons with disabilities.

• Group Homes for Seven or More Persons: The element subjects group homes for seven or more persons to a CUP and limits them to multifamily and agricultural zones, unlike other similar uses. While the element includes Program 1.2-5 to implement mitigating strategies, the element should specifically analyze these constraints for impacts on housing supply and choices, approval certainty and objectivity for housing for persons with disabilities and modify Program 1.2-5 as appropriate such as committing to allow these uses in all zones that allow residential uses.

6. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).)

Developed Densities and Permit Times: The element must analyze requests to develop housing at densities below those anticipated in the sites inventory and the length of time between receiving approval for a housing development and submittal of an application for building permits. The analysis must address any hinderances on the construction of a locality’s share of the regional housing need.

7. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)

The element includes some general quantification; however, the element should include analysis of households with special housing needs. The analysis should include, but is not limited to, factors such as trends, household income, tenure, housing types, zoning, and available resources. In addition:

• Homelessness: The element includes three different numbers for the 2020

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Point-in-Time Count on pp. 51, 100, and 111. The element should clarify which is the correct, most recent Point-in-Time count and use consistently throughout the element. The element must quantify the total number of persons experiencing homelessness and analyze their special housing needs. • Farmworkers: The element indicates there are farmworkers employed in fulltime farming occupations in Redlands. In addition, farmworkers from the broader area and those employed seasonally may have housing needs, including within the City’s boundaries. The element should acknowledge the housing needs of permanent and seasonal farmworkers at a county-level (e.g., using USDA county-level farmworker data) and include programs as appropriate.

8. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).)

The element states (p. 33) there may be additional projects, funded by the former Redlands Redevelopment Agency, at risk of conversion to market rate uses. If so, the element should identify these projects and include the required analysis. For additional information and sample analysis, see the Building Blocks at
http://www.hcd.ca.gov/community-development/building-
blocks/housing-needs/assisted-housing-developments.shtml and for more information on identifying units at-risk, see the California Housing Partnership Corporation at http://www.chpc.net.

C. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov.

Code, § 65583, subd. (c).)

To have a beneficial impact in the planning period and address the goals of the housing element, programs must be revised with discrete timelines, objectives and specific and clear commitment to outcomes. Programs to be revised with discrete timelines (e.g., annually, Spring 2022) include, but are not limited to, Programs 1.1-7 (Development on Nonvacant Sites), 1.3-4 (Priority Water and Sewer Service), 1.3-6 (Outreach and Education), 1.5-10 (Non-profit Housing Development) and 1.6-1 (ADU Educational Campaign).

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to

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accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)

As noted in Finding B4, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

• Program 1.1-1 (RHNA Rezoning): The Program should commit to a minimum acreage to be rezoned and meet all requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i) such as permitting multifamily uses without discretionary action and residential only and affordability requirements. • Program 1.1-2 (Transit Villages Specific Plan): The Program should commit to allowable densities, acreages, anticipated units and to meet by right requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i) to the extent necessary.
• Program 1.3-1 (Surplus Lands): The Program could consider a schedule of actions including commitment to facilitate development such as zoning, incentives and expediting permit procedures.

3. The housing element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)

The element must include a program(s) to assist in the development of housing affordable to lower-income households, including ELI and special needs households. This is particularly important given that the City only developed 1 very low-income unit during the 5 th cycle planning period. Program actions could include prioritizing some funding for housing developments affordable to ELI households or households with special needs, offering financial incentives or regulatory concessions, expediting or streamlining permit procedures, reducing fees and leasing land.

For additional information, see the Building Blocks at http://www.hcd.ca.gov/community- development/building-blocks/housing-needs/extremely-low-income-housing-needs.shtml.

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.

The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)

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As noted in Findings B5 and B6, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

In addition, the element, including public comments, note several constraints that warrant programs. For example, the element concludes Measure U is a constraint as well as minimum lot sizes (p. 95). The City also received comments to establish quarterly meetings with builders (p. C-17). The element should include programs to address these issues. In addition, while Program 1.2-8 (Socio Economic Cost Benefit Studies) commits to objective standards, it should consider additional measures like removing the requirement or pursue a more comprehensive City initiated study and should include a mid-term evaluation of effectiveness with commitment to alternative actions within a certain time.

2022 Local Voter Initiative: HCD understands the Town Village Specific Plan is subject to a local voter initiative that, if approved, would essentially remove the City’s strategy to accommodate the RHNA, including by income group. As a result, the element must include program actions with timelines related to the initiative including a commitment to immediately remedy any impacts on the City’s adequate sites strategy or HCD may revoke housing element compliance pursuant to Government Code section 65585, subdivision (i).

5. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).)

As noted in Finding B1, the element must include a complete analysis of AFFH. Based on the outcomes of that analysis, the element must add or modify programs to have specific commitment, milestones, and metrics to overcome fair housing issues and to enhance housing mobility strategies, encourage development of new affordable housing in high resource areas, improve place-based strategies, and protect residents from displacement.

6. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).)

The element identifies housing units at-risk of converting to market-rate and includes Program 1.4-1 to monitor the units to ensure tenants receive proper notifications.

However, Program 1.4-1 must also commit to proactively coordinate with qualified entities, assist with funding or support funding applications and educate, support and assist tenants.

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D. Quantified Objectives

Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved... (Gov. Code, § 65583, subd. (b)(1 & 2).)

The element must include quantified objectives estimating the number of housing units by income category that can be constructed, rehabilitated, and conserved in the planning period.

This requirement could be addressed by utilizing a matrix like the one illustrated below:

Income
New
Construction Rehabilitation
Conservation/
Preservation
Extremely Low-
Very Low-
Low-
Moderate-
Above Moderate-
TOTAL

E. Public Participation

Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).)

While Appendix C summarizes many of the public comments and describes how they were considered and incorporated into the element, HCD urges the City to re-evaluate comments related to Measure U and other land use constraints, community opposition to denser housing types, and the appropriateness of some identified sites.

In addition, the element does not clarify whether a full draft element was available to the public before its submittal to HCD. On the call, City staff indicated it may have only been available for one week prior to submittal to HCD. By not providing adequate time for the public to review and comment on a draft of the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element and it reduces HCD’s ability to consider public comments in its review. The availability of the document to the public and opportunity for public comment at least three to four weeks prior to submittal to HCD is essential to the public process and HCD’s review. The City must proactively make future revisions available to the public, including any commenters, prior to submitting any revisions to HCD and diligently consider and address comments, including revising the document where appropriate. HCD’s future review will consider the extent to which the revised element documents how the City solicited, considered, and addressed public comments in the element. The City’s consideration of public comments must not be limited by HCD’s findings in this review letter.

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ENVIRONMENTAL IMPACT REPORT ADDENDUM

2021 - 2029 Housing Element
Update

Lead Agency:

CITY OF REDLANDS

DEVELOPMENT SERVICES DEPARTMENT
35 Cajon Street, Suite 20
Redlands, CA 92373
Contact: Catherine Lin, AICP
909.798.7555 x 2

Prepared by:

MICHAEL BAKER INTERNATIONAL
3536 Concours St #100
Ontario, CA 91764
Contact: Emily Elliott, AICP
909.974.4961

December 2021

JN 179836

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This document is designed for double-sided printing to conserve natural resources.

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2021-2029 HOUSING ELEMENT UPDATE
EIR Addendum

EIR Addendum |December 2021 i Table of Contents

TABLE OF CONTENTS

Contents
TABLE OF CONTENTS .............................................................................................................. I

1.0 INTRODUCTION.............................................................................................................. 2

1.1 PURPOSE OF AN ADDENDUM .................................................................................... 2

1.2 DOCUMENTS INCORPORATED BY REFERENCE ................................................... 3

1.3 PROJECT DESCRIPTION .............................................................................................. 4

1.4 DISCRETIONARY ACTIONS........................................................................................ 6

2.0 ENVIRONMENTAL CHECKLIST ................................................................................ 7

2.1 BACKGROUND .............................................................................................................. 7

3.0 ENVIRONMENTAL ANALYSIS .................................................................................... 9

3.1 AESTHETICS ................................................................................................................ 10

3.2 AGRICULTURE AND FORESTRY RESOURCES ..................................................... 12

3.3 AIR QUALITY .............................................................................................................. 15

3.4 BIOLOGICAL RESOURCES ....................................................................................... 18

3.5 CULTURAL RESOURCES ........................................................................................... 22

3.6 ENERGY ........................................................................................................................ 25

3.7 GEOLOGY AND SOILS ............................................................................................... 26

3.8 GREENHOUSE GAS EMISSIONS .............................................................................. 32

3.9 HAZARDS AND HAZARDOUS MATERIALS .......................................................... 34

3.10 HYDROLOGY AND WATER QUALITY ................................................................ 39

3.11 LAND USE AND PLANNING .................................................................................. 44

3.12 MINERAL RESOURCES .......................................................................................... 45

3.13 NOISE ........................................................................................................................ 46

3.14 POPULATION AND HOUSING ............................................................................... 49

3.15 PUBLIC SERVICES .................................................................................................. 50

3.16 RECREATION ........................................................................................................... 54

3.17 TRANSPORTATION ................................................................................................ 55

3.18 TRIBAL CULTURAL RESOURCES ........................................................................ 58

3.19 UTILITIES AND SERVICE SYSTEMS .................................................................... 59

3.20 WILDFIRE ................................................................................................................. 63

3.21 MANDATORY FINDINGS OF SIGNIFICANCE .................................................... 64

4.0 REFERENCES ................................................................................................................. 66

APPENDICES:

Appendix A 2035 General Plan EIR

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2021-2029 HOUSING ELEMENT UPDATE
EIR Addendum

EIR Addendum | December 2021 2 Introduction

1.0 INTRODUCTION
An addendum to the Environmental Impact Report for the City of Redlands General Plan Update and Climate Action Plan (General Plan EIR) (State Clearinghouse No. 2016081041) has been prepared in conformance with the California Environmental Quality Act (CEQA) (Public Resources Code Section 21000 et seq.), the CEQA Guidelines (Cal. Code Regs., Title 14, Chapter 3, Section 15000 et seq.) and City of Redlands CEQA Guidelines to address minor changes to the City of Redlands General Plan for the City of Redlands 2021-2029 Housing Element Update (Housing Element or “project”). The Housing Element will necessitate future amendments to other elements of the General Plan, in particular, the Land Use Element, and the Safety Element. However, amendments to these elements are not included as part of the scope of this project and future amendments will be reviewed by City Staff to verify consistency with the Housing Element.

State law (California Government Code Sections 65580–65589.8) requires that jurisdictions evaluate their housing elements every eight years. The current statutory update in the Southern California Association of Governments (SCAG) region covers the planning period 2021 through 2029 (6th cycle). The proposed 6th Cycle Housing Element represents a comprehensive update of the adopted 2013- 2021 Housing Element (5th Cycle), in order to comply with State housing law and reflect the current 6th Cycle Regional Housing Needs Assessment (RHNA) Final Allocation Plan.

In general, the 6th Cycle Housing Element identifies and establishes the City’s policies with respect to meeting the housing needs of existing and future residents in Redlands. It establishes housing policies that will guide City decision-making and sets forth an action plan to implement the City’s housing goals over the next eight years. The commitments are in furtherance of the statewide housing goal of “early attainment of decent housing and a suitable living environment for every California family,” as well as a reflection of the concerns unique to the City of Redlands.

1.1 PURPOSE OF AN ADDENDUM
CEQA, a Statewide environmental law contained in Public Resource Code (PRC) Sections 21000–21177, applies to most public agency decisions which carry out, authorize, or approve actions that have the potential to adversely affect the environment. The CEQA Guidelines allow for updating and using a previously certified EIR for projects that have changed or are different from the prev ious project or conditions analyzed in the certified EIR. In cases where changes or additions occur with no new significant environmental impacts, an addendum to a previously certified EIR may be prepared, consistent with CEQA Guidelines Section 15164. This Addendum has been prepared in accordance with Section 21166 of CEQA and Sections 15162 and 15164 of the CEQA Guidelines.

Section 15164(a) of the CEQA Guidelines states that “the lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” Pursuant to Section 15162(a) of the CEQA Guidelines, a Subsequent EIR or Negativ e Declaration is only required when:

1. Substantial changes are proposed in the project which will require major revision of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revision of the previous EIR due to the involvement of new significant environmental increase in the severity of previously identified significant effects; or

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3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:

(a) The project will have one or more significant effects not discussed in the previous EIR;

(b) Significant effects previously examined will be substantially more severe than shown in the previous EIR;

(c) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or

(d) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. (CEQA Guidelines Section 15162[a])
The following describes the requirements of an Addendum, as defined by CEQA Guidelines Section 15164:

1. The lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.

2. An addendum to an adopted negative declaration may be prepared if only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred.

3. An addendum need not be circulated for public review but can be included in or attached to the final EIR or adopted negative declaration.

4. The decision-making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project.

5. A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section 15162 should be included in an addendum to an EIR, the lead agency’s findings on the project, or elsewhere in the record. The explanation must be supported by substantial evidence.

If none of these circumstances are present, and only minor technical changes or additions are necessary to update the previously certified EIR, an Addendum may be prepared, consistent with CEQA Guidelines Section 15164. The City of Redlands certified its 2035 General Plan EIR in December 2017, approximately three years after the City adopted the 5th Cycle Housing Element and certified its corresponding Initial Study/Negative Declaration (IS/ND). Thus, although the 5th Cycle Housing Element was not expressly included within the scope of the 2035 General Plan and its corresponding EIR, the land use assumptions and policies of the 5th Cycle Housing Element were considered as an existing condition at the time of its preparation. For this reason, this Addendum relies on the 2035 General Plan EIR and the related administrative record and is intended to be included or attached to the 2035 General Plan EIR. It is not to be considered an independent or separate document from the 2035 General Plan EIR.

1.2 DOCUMENTS INCORPORATED BY REFERENCE

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The following documents were utilized during preparation of this Addendum and are incorporated into this document by reference. The documents are available for review at the City of Redlands Development Services Department, 35 Cajon Street, Suite 20, Redlands, CA 92373.

• City of Redlands 2035 General Plan. The City of Redlands 2035 General Plan (2035 General Plan) was adopted in December 2017. The 2035 General Plan is organized around seven Themes (or chapters), which include policies and actions to guide future development. The seven Themes in the 2035 General Plan are: 1. Distinctive City, 2. Prosperous Economy, 3. Livable Community, 4.

Connected City, 5. Vital Environment , 6. Healthy Community , 7. Sustainable Community . The State-mandated elements of Land Use, Circulation, Open Space, Conservation, Health & Safety, Noise, and Housing are all integrated within the Themes noted above. • City of Redlands 2035 General Plan Environmental Impact Report . Pursuant to CEQA and the CEQA Guidelines, the City of Redlands pre pared an EIR to analyze the impacts of 2035 General Plan buildout. According to the 2035 General Plan EIR, significant and unavoidable impacts were identified for agricultural resources, air quality, and transportation. The 2035 General Plan EIR was certified in December 2017.

• City of Redlands General Plan Housing Element Update (General Plan Amendment No. 130) Initial Study & Negative Declaration . Pursuant to CEQA and the CEQA Guidelines, the City of Redlands prepared an Initial Study/Negative Declarati on (IS/ND) to analyze the impacts of implementing the 5th Cycle Housing Element for the 2013-2021 planning period.

• City Code of the City of Redlands . The City’s Land Use Zoning Ordinance is found in the City Code of the City of Redlands (City Code) Title 18, Zoning Regulations, which carries out the City’s General Plan policies by regulating development and land uses within Redlands. City Code Chapter

18.16, Districts and Zoning Map, describes and provides development standards for the City’s 32 land use districts and three (3) overlay districts.

1.3 PROJECT DESCRIPTION

The 6th Cycle Housing Element (referred to as the “project”) retains many of the goals, policies, and relevant implementation programs previously included as part of the 5th Cycle Housing Element. The project consists of updates to the Housing Element, particularly limited to the Housing Needs Assessment, which contains updated statistics and analyses based on data from the 2010 US Census and the 2019 American Community Survey and a revised sites inventory to meet the City’s RHNA. All other updates are limited to background information updates and policy updates in accordance with State law and internal consistency. A summary of the revisions proposed by the project is included below.

HOUSING ELEMENT UPDATE OVERVIEW
The proposed 6th Cycle Housing Element Update represents a comprehensive update to the adopted 5th Cycle Housing Element. The update is proposed to comply with State housing law and reflect the current 6th Cycle RHNA Final A llocation Plan. The Housing Element, which is one of the City’s General Plan Elements, consists of seven key chapters:

o Chapter 1, Introduction, provides information on the purpose and scope of the Housing Element, the State of California’s requirements, the Housing Element’s relationship to other General Plan elements, a discussion on public outreach, and organization of the document.

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o Chapter 2, Housing Needs Assessment, Regional Housing Needs Assessment and Special Needs, describes Redlands’ demographic and employment trends, characteristics of the City’s current housing stock, housing affordability, and energy conservation opportunities.

The Regional Housing Needs Assessment and Special Needs section explains Redlands’ allocation of the regional housing need, projects housing needs, and describes the characteristics and needs of various special populations, including the elderly, people with disabilities, homeless, and single parents
o Chapter 3, Housing Resources and Sites Inventory, identifies specific si tes suitable for residential development to allow for a comparison of the RHNA with realistic development capacity. Environmental and infrastructure constraints on potential housing sites are also described.
o Chapter 4, Constraints, identifies and analyzes potential and actual constraints to housing development in Redlands, both related to governmental actions (e.g., regulatory standards) and non-governmental conditions (e.g., the housing market or construction costs). o Chapter 5, Quantified Objectives, Housing Goals, Policies, and Programs , includes the goals, objectives, policies, and programs for this Housing Element planning period. o Chapter 6, Review of Past Accomplishments, describes the City’s accomplishments and provides an assessment of the effectiveness of the programs in the prior 5th Cycle Housing Element.
o Chapter 7, Affirmatively Furthering Fair Housing, includes an analysis of Fair Housing, contributing factors to housing problems, and action items to address them.

Appendices cover the topics of community engagement, sites inventory map, and sites inventory data.

CITY OF REDLANDS HOUSING NEEDS
The City’s RHNA for the 2021-2029 planning period r eflects the California Department of Housing and Community Development’s (HCD) determination of the housing needs in a region, broken down by income level. Redlands’ RHNA is 3,516 housing units. As part of the 2021-2029 Housing Element update, the City has identified land available for residential development under existing and future zoning to fulfill its RHNA. The City will rezone land to provide for up to 4,219 units (RHNA + 20% buffer) within three years from the date of adoption. The proposed inventory draft, included as Appendix A and Appendix B of the Housing Element, includes additional capacity beyond what is necessary to meet the RHNA + 20% buffer.

Some of the rezone candidate sites identified in the RHNA may not be rezoned, or will be zoned differently than illustrated in the sites inventory based on the results of additional public engagement and environmental review. Regardless of any final decisions on the specific sites to rezone, Redlands will have adequate capacity to meet the RHNA for all income levels after rezoning within three years of Housing Element adoption.

Although the proposed housing inventory sites are described and incorporated in the 2035 General Plan, approximately 119 acres of the project’s housing inventory sites are not presently designated for housing and would require a future amendment to the 2035 General Plan Land Use Map. In addition, the 6th Cycle Housing Element will necessitate future amendments to the General Plan Land Use Element and Safety Element. As discussed, amendments to these elements are not included as part of the scope of this project and future amendments will be reviewed by City Staff to verify consistency with the Housing Element and determine further environmental review requirements.

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1.4 DISCRETIONARY ACTIONS

The City of Redlands is the Lead Agency under CEQA and has discretionary authority over the project.

The project would be subject to various City permits and approvals, including, but not limited to:

o California Environmental Quality Act review;
o Adoption of the 2021-2029 Housing Element;

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2.0 ENVIRONMENTAL CHECKLIST

2.1 BACKGROUND

1. Project Title: 2021-2029 Housing Element Update

2. Lead Agency Name and Address:

City of Redlands
Development Services Department
35 Cajon Street, Suite 20
Redlands, CA 92373

3. Contact Person and Phone Number:

Catherine Lin, AICP, Principal Planner
909.798.7555 x 2

4. Project Location: Redlands is located at the base of the San Bernardino Mountains in San Bernardino County, 60 miles northeast of Los Angeles and 45 miles west of Palm Springs.

5. Project Sponsor’s Name and Address:

City of Redlands
Development Services Department
35 Cajon Street, Suite 20
Redlands, CA 92373

6. General Plan Designation: Various

7. Zoning: Various

8. Description of the Project: Refer to Section 1.3, Project Description.

9. Surrounding Land Uses and Setting: Various

10. Other public agencies whose approval is required (e.g., permits, financing approval or participation agreement).

None applicable.

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3.0 ENVIRONMENTAL ANALYSIS

This section describes the environmental impacts of the project as compared to those identified in the 2035 General Plan EIR and discusses any substantial changes to existing conditions or regulatory setting since the 2035 General Plan EIR was certified. The issue areas evaluated in this document include the following, pursuant to Appendix G of the CEQA Guidelines, and have been modified to evaluate the project changes for which an EIR has been previously certified to assist in the determination of the need for a supplemental EIR or an Addendum.

In December 2018, the Natural Resources Agency amended the CEQA Guidelines, which included modifications to Appendix G, Environmental Checklist For m. As such, the following analysis identifies where modifications to the Appendix G topical areas and thresholds have been added and/or updated since the 2035 General Plan EIR was prepared.

• Aesthetics
• Agriculture and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Energy
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
• Wildfire
• Mandatory Findings of Significance

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A summary of impacts of the adopted Specific Plan and the mitigation measures imposed is provided along with an analysis of the potential impacts resulting from the project and whether those impacts substantially exceed those discussed in the certified 2035 General Plan EIR.

3.1 AESTHETICS

This section corresponds with 2035 General Plan EIR Section 3.1, Aesthetics.

Except as provided in Public Resources Code Section 21099, would the project:

a) Have a substantial adverse effect on a scenic vista?

As detailed in the 2035 General Plan EIR, scenic vistas in the City of the scenic corridors and views to and from the open spaces, canyonlands, hillsides, groves, and the San Bernardino Mountains. Scenic views are also found in the urbanized part of the city, including along scenic and historic drives. The General Plan would continue to regulate development in these areas and contains policies to ensure that opportunities to enjoy scenic views are either preserved or enhanced. Thus, substantial adverse effects are not expected to occur.

The proje ct proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would b e rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. These projects would be regulated by existing General Plan policies to ensure that opportunities to enjoy scenic views are preserved or enhanced. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning scenic vistas as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mi tigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway?

As detailed in 203 5 General Plan EIR, p olicies under the existing General Plan ensure that Redlands maintains special design standards for designated scenic drives that are sensitive to the streets’ scenic qualities. These policies designate additional scenic streets with special design standards and encourage streetscape design that is cognizant of viewpoints and vistas. Specific developments would be required to follow these design standards. Individual development projects will still be subject to development and planning review and must therefore conform to zoning and other ordinances regarding aesthetic qualities such as lighting, signage, landscaping, and building setbacks.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose

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rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning State Scenic Highways as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

c) Substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?

As detailed in the 2035 General Plan EIR, the General Plan does not call for any substantial changes to land use or building design for most neighborhoods within the planning area and includes provisions to preserve or improve the existing visual character of the city. Proposed rezoning’s and policies would direct new development into underutilized or previously developed areas, where any proposed changes in land use and physical design are intended to increase visual quality.

In addition, proposed policies seek to ensure that any development or redevelopment is visibly compatible with the surrounding environment. Policies regarding visual compatibility in the General Plan pertain to scale, historic preservation, landscaping, and preservation of scenic views and vistas. Policies pertaining to areas of new development promote visually appealing streetscapes and public art to improve the visual character of the Planning Area. The General Plan has policies intended to preserve the existing historic character of Redlands. These policies aim to aid property owners to preserve historic structures, strengthen the influence of the Historic and Scenic Preservation Commission, and encourage streetscape and building design that compliments the historic character of the community. The open space and canyon components of the Planning Area’s visual character would not be significantly altered by the Project. The General Plan contains policies to preserve hillsides and ridges, open space, and natural scenery.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning the visual character or qu ality of public views as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

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Level of Significance: Less Than Significant Impact.

d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area?

As detailed in the 2035 General Plan EIR, new development resulting from implementation of the General Plan would necessitate the use of additional light fixtures and would contribute to existing conditions of light and glare. New light sources may include residential and non-residential interior and exterior lighting, parking lot lighting, commercial signage lighting, and lamps for streetscape and public recreational areas.

Most new development resulting from the General Plan would take place in or near developed and urbanized areas, where moderate light and glare already exist, and would not be out of character with the urban environment.

The General Plan includes policies related to buffering between development and sensitive habitats, and between commercial, residential, and industrial uses. The General Plan also includes a policy to preserve the visual character of the canyon areas and the agricultural area of Crafton by exploring the adoption of a dark sky ordinance. With these measures in place, this impact was determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning day or nighttime views as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.2 AGRICULTURE AND FORESTRY RESOURCES

This section corresponds with 2035 General Plan EIR Section 3.2, Agricultural Resources.

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model t o use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment Project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.

Would the project:

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a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?

According to the 2035 General Plan EIR, proposed land use changes could impact areas designated Prime Farmland, Farmland of Statewide Importance, or Unique Farmland (important farmland) designated by the currently under cultivation throughout the City. This includes the East Valley Corridor, whe re some farmland has been converted to commercial and industrial land uses since the adoption of the 1995 General Plan and is proposed to be rezoned pursuant to the project. While existing General Plan policies provide a framework to permit existing agricu ltural uses and ensure that important farmland remains as farming or other related agricultural support uses, the conversion of this farmland was determined to be a significant and unavoidable impact.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning farmland as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: The 2035 General Plan EIR determined that no mitigation is available that would reduce impacts to a level that is less than significant.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Significant and Unavoidable.

b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?

According to the 2035 General Plan EIR, Williamson Act contracts are spread throughout the periphery of the City. Most contracted land is located in Crafton, but there are also contracted lands in the San Timoteo Canyon and in the north of the city near the Santa Ana River Wash. Most of the land contracted under the Williamson Act would not be susceptible to buildout pressure due to their categorization as low -density Rural Living and Agriculture land uses under the General Plan. Some contracted land is located on sites designated as Very Low Density Residential, which allows for the continuation of agricultural uses. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning existing zoning for agricultural use as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

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Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less than Significant Impact

c) Conflict with existing zoning for, or cause rezoning, of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

The City does not contain any forest land. Furthermore, no portion of the City zoned for forestland.

Therefore, the project would not result in the loss of forestland or the conversion of forestland to non-forest use. Therefore, development of the project would not result in greater impacts than previously analyzed in the 2035 General Plan EIR. No impact would occur.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

d) Result in the loss of forest land or conversion of forest land to non- forest use?

Refer to Response 3.2(c).

Certified General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?

As discussed in response 3.2(a), implementation of the Housing Element would not result in greater impacts than previously analyzed in the 2035 General Plan EIR. The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning the farmland and forestland as compared to the 2035 General Plan EIR.

Certified General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

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Level of Significance: Less than Significant Impact.

3.3 AIR QUALITY

This section corresponds with 2035 General Plan EIR Section 3.3, Air Quality.

Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations . Would the project:

a) Conflict with or obstruct implementation of the applicable air quality plan?

Based on the 2035 General Plan EIR, the buildout of the General Plan would not result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delay timely attainment to the ambient air quality standards or emission reductions in the Air Quality Management Plan.

In addition, the General Plan EIR determined that the buildout of the General Plan would not exceed the assumptions of the Air Quality Management Plan. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning conflicting with an applicable air quality plan.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less than Significant Impact

b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard?

Based on the 2035 General Plan EIR, the cumulative impacts that were analyzed from the General Plan must evaluate the project’s contribution to the cumulative increase in pollutants for which the SCAB is designated as nonattainment for the California Ambient Air Quality Standards ( CAAQS) and National Ambient Air Quality Standards (NAAQS). If the General Plan does not exceed thresholds and is determined to have less-than-significant impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the General Plan , in combination with the emissions from other proposed or reasonably foreseeable future projects, are in excess of established thresholds. However, the General Plan would only be considered to have a significant cumulative impact if its contribution accounts for a

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significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).

The South Coast Air Basin (SCAB) has been designated as a Federal nonattainment area for O3 and PM2.5, and a State nonattainment area for O 3, PM10, PM2.5, and NO2. PM10 and PM2.5 emissions associated with construction generally result in localized impacts. Future development projects allowed under the 2035 General Plan and associated land uses would generate vehicle trips and vehicle miles travelled (VMT) that would result in ozone precursor emissions and particulate matter. However, individual projects proposed under the General Plan would be required to undergo subsequent environmental review pursuant to CEQA, and as part of this review effort, projects requiring discretionary approval would be required to assess whether the project complies with the applicable air quality plan. Additionally, SCAQMD would require that individual projects demonstrate compliance with SCAQMD rules and regulations governing air quality, specifically particulate matter. The City of Redlands would continue to coordinate with SCAQMD to ensure citywide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. Therefore, the General Plan would result in a cumulatively considerable impact.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning net increase of pollutants as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No mitigation is available beyond measures identified in the AQMP, SIP, CARB motor vehicle standards, SCAQMD regulations for stationary sources and architectural coatings, Title 24 energy efficiency standards, and principles and actions in the proposed General Plan that would partially reduce impacts. Therefore, impacts would remain significant and unavoidable.

Level of Significance: Significant and Unavoidable.

c) Expose sensitive receptors to substantial pollutant concentrations?

According to the 2035 General Plan, buildout of the General Plan could allow residential and other sensitive land uses to locate in the vicinity of air pollutant sources such as stationary sources and the freeways.

Policies in the General Plan would serve to protect new sensitive receptors from exposure to substantial pollutant concentrations. Proposed policies would require applicants for sensitive land uses to minimize the potential for air pollution exposure through siting and design. Proposed policies also would require the development of requirements for retrofitti ng existing residential buildings within a 500-foot buffer along the freeway to abate air pollution, and limit new residential developments within the buffer. The SCAQMD permitting process for new emissions sources and existing sources in the vicinity of n ew sensitive developments would further help to ensure that substantial exposure to air pollutants would be avoided.

Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose

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rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning sensitive receptors in relation to substantial pollutant concentrations as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No required.

Level of Significance: Less Than Significant Impact.

d) Result in other emissions (such as those leading to odors adversely affecting a substantial number of people)?

Based on the 2035 General Plan EIR, odors would be generated from vehicles and/or equipment exhaust emissions during construction of future projects under the General Plan . Odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and architectural coatings. Such odors are temporary and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be considered less than significant.

Land uses and industrial operations that are associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding. Development under the General Plan is required to meet all local, State, and Federal regulations related to odor control, incl uding permit requirements. However, new sensitive receptors would be potentially located near odor -generating land uses. Future project -level analysis will demonstrate consistency with the General Plan , principles and actions would ensure that odor impacts would be reduced to a level that is less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the
project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning emissions compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: None required.

Level of Significance: Less Than Significant Impact.

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3.4 BIOLOGICAL RESOURCES

This section corresponds with 2035 General Plan EIR Section 3.4, Biological Resources.

Would the project:

a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

As stated in 2035 General Plan EIR, there are 19 species that are State or federally listed as rare, threatened, or endangered species that have been or were identified as potentially present within the Planning Area.

The following eight species are known to either be present or have a moderate to high probability of occurring due to the presence of suitable habitat, mainly along the Santa Ana River, Mill Creek, and San Timoteo Creek:

• Nevin’s barberry;
• Slender-horned spineflower;
• Santa Ana River woolly star;
• Southwestern willow flycatcher;
• California gnatcatcher;
• Least Bell's vireo;
• San Bernardino kangaroo rat; and
• Stephens’ kangaroo rat.

According to the 2035 General Plan EIR, direct impacts on special- status species could result from the conversion of habitat either temporarily, as a result of grading, excavat ion, and construction activities, or permanently from the ongoing operation and/or maintenance of a project or plan. Indirect impacts could result from elevated dust or noise levels or increased sediment loads in runoff from construction activities.

Indirect impacts could also result from permanent alterations to hydrology upstream of habitats supporting sensitive species, including increased runoff, sedimentation, or pollutant loads, and increased human activity. Most new development expected to occur with in the timeframe of the General Plan would be within existing developed areas, rather than along the Santa Ana River, Mill Creek, and San Timoteo Creek where critical habitat has been identified. In addition to these critical habitat areas, vacant and underutilized parcels in the Planning Area may be providing habitat for a variety of species. Infill development and redevelopment under the General Plan could affect habitat and species on these parcels.

The 2035 General Plan EIR concluded that p rinciples and actions in the General Plan, the City’s development review process, and regulatory permitting required by existing Federal and State laws relative to listed species would reduce potential impacts on federally or State- listed species and speci al status species to less than significant levels. For instance, Action 6- A.11 would require a biological survey for individual projects that would identify specific impacts to critical habitat and restrict development accordingly, and Action 6-A.12 would require the same for projects adjacent to wetlands, riparian corridors, or wildlife corridors. Other proposed policies would require the City to protect wildlife habitat and wildlife corridors, limit grading and ground-disturbing activities, and support conservation and restoration of natural habitats. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose

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rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning habitat modifications as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: None required.

Level of Significance: Less Than Significant Impact.

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

As stated in the 2035 General Plan EIR, future development or public works activities in the city may result in significant impacts on riparian vegetation or other sensitive natural communities, especially on land with native vegetation adjacent to or immediately upstream of the Santa Ana River, Mill Creek, and San Timoteo Creek. However, most riparian areas are designated Open Space under the General Plan and would thus be protected from direct impacts from development. Furthermore, principles and actions in the General Plan would serve to reduce any potential impacts. General Plan Principle 6-P.7 would require the City to protect environmentally sensitive lands, and Principle 6- P.9 would require the City to protect wildlife corridors, including natural watercourses. Action 6- A.12 would require the City to review all future private development and public works activities on sites that contain or are adjacent to riparian resources to determine an appropriate buffer between developed uses and drainages, and Action 6- A.15 would require the City to enhance riparian corridors. Action 6- A.35 would promote the protection and restoration of waterways and riparian areas. In addition, projects that involve removal of riparian vegetation would have to comply with established regulatory permitting through the appropriate federal and/or State agency, consistent with current F ederal and State laws. The General Plan principles and actions discussed above, the City’s development review process, and regulatory permitting required by existing Federal and State laws relative to riparian habitat or other sensitive natural communities would reduce potential impacts of the project to less than significant levels.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a u se that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning any riparian habitat or other sensitive natural community as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required for the 2035 General Plan EIR.

Mitigation Measures: None required.

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Level of Significance: Less Than Significant Impact.

c) Have a substantial adverse effect on State or Federal ly protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

As stated in 2035 General Plan EIR, several of the natural watercourses would likely be considered under the Federal jurisdiction of the USACE as waters of the U.S. and thus subject to the F ederal Clean Water Act. Smaller drainages, particularly in the hilly areas in the southern and eastern portions of the Planning Area, may be considered jurisdictional by the USACE. The Zanja and Morey Arroyo are artificial ditches but may also be subject to regulation by the USACE. It is possible that one or more of these drainages may contain wetland features, either now or in the future, depending on annual rainfall, but there is little or no potential for marshes, vernal pools, or other specific types of wetlands to occur within the city.

The 2035 General Plan EIR determined that General Plan Action 6-A.12 would reduce potential impacts by requiring the City to review all future private development and public works activities on sites that contain or adjacent to wetlands to determine an appropriate buffer from developed uses. Projects that involve impacts on drainages with wetland features would have to comply with established regulatory permitting through the appropriate F ederal and/or State agency, consistent with current F ederal and State laws. Implementation of the indicated General Plan policies, and the City’s development review process, and regulatory permitting required by existing F ederal and State laws relative to jurisdictional features, were determined to reduce potential impacts of the General Plan on federally protected wetlands to less than significant levels.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies futu re candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning State or Federally protected wetlands as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: None required.

Level of Significance: Less Than Significant Impact.

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

As stated in the 2035 General Plan EIR, the many drainages, canyons, and extensive hillsides with native vegetation can provide corridors or areas for travel for local wildlife, especially where such drainages or areas connect to larger areas of undisturbed native vegetation, all of which can provide a variety of resources and protection for native wildlife. Future development within the Planning Area could sever or restrict connectivity or the usefulness of such wildlife corridors if human activities or improvements can encroach into such corridor areas; however, principles and actions in the General Plan would reduce the potential impact on wildlife corridors. Principle 4-A.67 would require the City to create wildlife corridors extending

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throughout the Live Oak Canyon and San Timoteo Canyon areas. Principles 6-P.7, 6-P.8, and 6-P.9 would require the City to protect wildlife habitat, including wildlife corridors connecting the San Bernardino National Forest, Santa Ana River Wash, Crafton Hills, San Timoteo and Live Oak Canyons, the Badlands, and other open space areas. Action 6 -A.14 would reduce impacts from transportation projects on wildlife corridors; Action 6-A.12 would require projects adjacent to wildlife corridors to be specifically analyzed; and Action 6-A.15 would require the City to enhance riparian corridors.

According to the 2035 General Plan EIR, s pecific developments that involve impacts on drainages or corridors of native vegetation would have to comply with established regulatory permitting through the appropriate Federal and/or State agency, consistent with current Federal and State laws. Implementation of the indicated General Plan policies and the City’s development review process, and possible regulatory permitting required by existing federal and State laws relative to listed species that utilize wildlife corridors, would reduce potential impacts of the project to less than significant levels. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that wo uld be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning wildlife movement as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: None required.

Level of Significance: Less Than Significant Impact.

e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

As stated in 2035 General Plan EIR, the General Plan establishes the over-arching policies and direction for the City relative to development review and protection of biological resources, so the General Plan would not conflict with local ordinances or policies which are intended to implement and be consistent with the goals of the General Plan. The General Plan’s policies to promote the health and maintenance of street trees is consistent with Municipal Code Chapter 12.52. Proposed policies are also consistent with the Street Tree Policy and Protection Guidelines Manual adopted in accordance with the Municipal Code, though these guidelines may be updated to better implement General Plan policies to care for street trees and trees in public places. The principles and actions of the General Plan would help to lay the groundwork for any future ordinances or programs to protect trees and other biological resources.

The 2035 General Plan EIR also concluded that implementation of the General Plan would also be consistent with the Upper Santa Ana Wash Land Management and Habitat Conservation Plan (Wash Plan) and the San Bernardino County General Plan. Policies in the General Plan maintain consistency with the Wash Plan by deferring to the Wash Plan’s resource management standards. Similarly, the General Plan seeks to maintain consistency with the policies of the San Bernardino County G eneral Plan, particularly regarding the protection of open space and natural resources including critical habitat and habitat for sensitive plant or animal species. Any future specific ordinances or programs to protect biological resources

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would have to be consistent with the goals of the General Plan. Therefore, there would be no inconsistencies and no impacts in this regard, and no need for mitigation.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be r ezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning local polices or ordinances protecting biological resources as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: None required.

Level of Significance: Less than Significant Impact.

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?

As stated in the 2035 General Plan EIR, at present, there are no adopted regional habitat conservation plans or natural community conservation plans. However, the City is participating in the proposed Wash Plan, which has a habitat conservation plan component. Policies in the General Plan emphasize consistency with the Wash Plan’s habitat conservation policies. Therefore, implementation of the General Plan would have a less than significant impact.

The project proposes updates to the City’s Housing Element that are primarily limited to ba ckground information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered und er the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning an adopted Habitat Conservation Plan or Natural Community Conservation Plan as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.5 CULTURAL RESOURCES

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This section corresponds with 2035 General Plan EIR Section 3.8, Historical, Archaeological, and Paleontological Resources.

Would the project:

a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section15064.5?

Based on the 2035 General Plan EIR, implementation of the General Plan would not directly result in the destruction of, or damage to, historical resources. H owever, future development and redevelopment permitted under the General Plan could result in changes that affect historic resources. Changes could include demolition, seismic retrofitting, and accidents caused by nearby construction. The impac t of such activities would be considered significant if they were to cause a substantial adverse change to the historical resources as defined by CEQA Guidelines Section 15064.5.

The 2035 General Plan EIR determined that impacts to historic resources woul d be reduced through implementation of the CEQA Guidelines. The CEQA Guidelines require a project that will have potentially adverse impacts on historical resources to conform to the Secretary of the Interior’s Standards for the Treatment of Historic Properties. In addition, the Redlands Historic and Scenic Preservation Ordinance offers additional protections to historic resources by giving the City the authority to make recommendations, decisions, and determinations regarding the designation, preservation, protection, and enhancement of historic resources, including the authority to deny demolition, except in cases of proven hardship. Finally, the General Plan includes goals and policies that would minimize or avoid impacts on historical resources by requiring the protection and preservation of such resources. Proposed policies seek to recognize historic resources within the Planning Area in a manner that fosters the preservation of historic character in the area’s structures and neighborhoods. Propose d policies also establish development procedures and incentives that promote historic preservation. Impacts to historic resources were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning historical resources as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?

Based on the 2035 General Plan EIR, the records search conducted for the General Plan update indicated the presence of 11 prehistoric resourc es within one mile of the Planning Area. The prehistoric resources

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include habitation areas, artifact scatters, bedrock milling sites, and isolated artifacts. As the records search area has not been 100 percent studied and there are areas within the Planni ng Area that have never been examined or researched, there is potential for new archaeological resources to be discovered in the future.

Future development projects or public works activities allowed under the General Plan may involve grading, excavation, overland vehicle travel, or other ground-disturbing activities, or could facilitate public access to archaeological sites, which could disturb or damage unknown archaeological resources. The impact of such activities would be considered significant if they were to cause a substantial adverse change to the archaeological resources as defined by CEQA Guidelines Section 15064.5.

According to the 2035 General Plan EIR, although General Plan buildout may result in actions that could adversely affect archaeological resources, policies in the General Plan would minimize or avoid impacts by requiring the protection and preservation of such resources. In accordance with Public Resources Code Section 21083.2 and CEQA Guidelines Section 15064.5(f), which recognize that historical or unique archaeological resources may be accidentally discovered during project construction, General Plan Action 2-A.74 would require that areas identified to contain historical or unique archaeological resources be evaluated of by a qualifi ed archaeologist for implementation of avoidance or appropriate mitigation measures, pursuant to CEQA Guidelines Section 15064.5(f). Additional proposed policies would serve to ensure the availability of information regarding archaeological resources in th e Planning Area in order to allow the avoidance of negative impacts on known resources, as well to ensure the development of appropriate mitigation and monitoring procedures for projects on sensitive sites. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning an archaeological resource pursuant to Section 15064.5 as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

c) Disturb any human remains, including those interred outside of formal cemeteries?

Based on the 2035 General Plan EIR, Human remains, particularly those interred outside formal cemeteries, could be disturbed during grading, excavation, or other ground-disturbing activities associated with future development or redevelopment projects allowed under the General Plan. The treatment of Native American human remains is regulated by Public Resources Code Section 5097.98, as amended by Assembly Bill 2641, which addresses the disposition of Native American burials, protects remains, and appoints the NAHC to resolve disputes. Future private development and public works activities are required to comply with existing State law.

Although the General Plan does not include any goals or policies that directly address the disturbance of human remains, future development and redevelopment projects allowed under the General Plan would be

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required to adhere to the laws and regulations discussed above. Therefore, impacts associated with the disturbance of human remains would be less than significant because existing laws and regulations would reduce the potential for encountering human remains and ensure the appropriate disposition of any human remains that are encountered.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with S tate law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning human remains, including those interred outside of formal cemeteries as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.6 ENERGY

This section corresponds with 2035 General Plan EIR Section 3.5, Energy, Greenhouse Gases, and Climate Change.

Would the project:

a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?

Based on the 2035 General Plan EIR, development under the General Plan would increase future energy consumption within the plan area, resulting in additional demand for electricity and natural gas supply and services. Future development projects and land uses proposed under the General Plan would increase the population and employment in the city, and associated energy demand above existing conditions. However, despite the overall increase in future energy use, the state’s current and future energy code and the General Plan policies would ensure energy efficient designs in new development and encourage energy efficiency upgrades in existing development, both of which would minimize wasteful, inefficient energy consumption.

The General Plan policies also require energy conservation. Future development would be required to comply with Title 24 energy performance standards and the General Plan energy conservation policies and actions. With implemen tation of the General Plan and the proposed CAP, impacts would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City

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review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning a significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?

Based on the 2035 General Plan EIR, all future development under the General Plan would be required to comply with the latest California Building Standards Code requirements, including Energy Efficiency Standards, as well as all Federal, State, and local rules and regulations pertaining to energy consumption and conservation. The General Plan includes policies that emphasize energy reduction strategies. The proposed Climate Action Plan (CAP) includes an inventory of citywide GHG emissions, forecasts of future citywide GHG emissions , monitoring and reporting processes to ensure State GHG targets are met , and options for reducing GHG emissions beyond State requirements. The proposed CAP is written for intended implementation through the year 2035. Through implementation of City policies as delineated in the General Plan, the General Plan would support the CARB passenger vehicle GHG emissions reduction targets through measures that would reduce VMT throughout the city. Additionally, CARB’s LCFS, which aims to reduce the carbon intensity of the life cycle of gasoline and diesel fuels by 10 percent by 2020, would further assist in meeting energy reduction goals and GHG emission reduction targets. Therefore, impacts were determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning conflicting with a State or local plan for renewable energy or energy efficiency as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.7 GEOLOGY AND SOILS

This section corresponds with 2035 General Plan EIR Section 3.6, Geology, Soils, and Seismicity.

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Would the project:

a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss injury, or death involving:

i) Rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

According to the 2035 General Plan EIR, the majority of the Alquist -Priolo designated zones and other fault lines are outside of the Planning Area, some of these faults extend into the south and northeast portions of the Planning Area. A San Bernardino County Designated Fault Zone is in the Crafton Hills portion of the Planning Area. Within these areas, the General Plan allows for some residential land uses that are very low density. However, potential adverse effects on people or structures from the rupture of a known earthquake fault would be minimized to the greatest extent feasible by CBC requirements that protect buildings from fault rupture and the policies proposed in the General Plan Update listed below that require geotechnical reports and continued restrictions near active/potentially active faulting. Thus, impacts related to fault rupture were determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a resu lt, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning earthquake fault rupture as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

ii) Strong seismic ground shaking?

According to the 2035 General Plan EIR, earthquakes in and near the Planning Area have the potential to cause ground shaking of significant magnitude. The General Plan would allow for additional development within the city, which could expose people and property to strong seismic ground shaking. However, new buildings would be constructed in compliance with the CBC. Section 1613 of the CBC requires all structures be designed and constructed to resist the effects of earthquake motions in accordance with the Minimum Design Loads for Buildings and Other Structures established by the American Society of Civil Engineers. Additionally, the General Plan policies would further r educe any potential impacts associated with strong seismic ground shaking. Therefore, impacts to people and structures from strong seismic ground shaking would be less than significant.

The project proposes updates to the City’s Housing Element that are p rimarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies

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future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning se ismic ground shaking compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

iii) Seismic-related ground failure, including liquefaction?

According to the 2035 General Plan EIR, several locations within the Planning Area are considered prone to liquefaction hazards. The areas in the northern part of the Planning Area, around the Santa Ana River, Mentone Boulevard, and Mill Creek Road are susceptible to liquefaction. Damage from earthquake-induced ground failure associated with liquefaction could be high in buildings constructed on improperly engineered fills or saturated alluvial sediments that have not received adequate compaction or treatment in accordance with current building code requirements. Ground failure, including liquefaction, as a result of an earthquake could occur in the Planning Area depending on the underlying conditions including moisture content, relative size of soil particles, and density of subsurface materials within 50 feet of ground surface.

The General Plan designates most of the areas susceptible to liquefaction as Open Space, but it allows for some additional industrial, commercial, and low-density residential development in the Planning Area. The 2035 General Plan EIR determined that impacts from ground failure, including liquefaction, from development of land uses associated with the project would be addressed through site-specific geotechnical studies prepared in accordance with CBC requirements and standard industry practices. Subsequent development would be required to conform to the current seismic design provisions of the CBC to minimize losses from ground failure as a result of an earthquake. These future projects would also be required to adhere to Project policies that contain seismic safety requirements and help strengthen existing code requirements such as limiting the disturbance of natural terrain and vegetation to the minimum necessary to accommodate reasonable use of property. Therefore, the potential impact related to seismically related ground failure including liquefaction is less than significant. Furthermore, the General Plan does not designate any new residential or commercial land uses in high liquefaction susceptibility areas beyond those designated in the current General Plan.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning
seismic-related ground failure as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

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Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

iv) Landslides?

According to the 2035 General Plan EIR, landslide-susceptible areas are primarily located in various parts of southern Redlands and some smaller parts in the eastern side of the Planning Area. Landslides may occur on slopes of 15 percent or less . H owever, the probability is greater on steeper sl opes that exhibit old landslide features such as scarps, slanted vegetation, and transverse ridges. Landslide susceptible areas are characterized by steep slopes and downslope creep of surface materials.

The 2035 General Plan EIR determined impacts from landslides on development of future land uses associated with buildout of the General Plan would be addressed through site-specific geotechnical studies prepared in accordance with CBC requirements and standard industry practices, which would specifically address landslide hazards located in landslide hazard areas. Development would conform to the current design provisions of the CBC to mitigate losses from landslides. Proposed developments would also adhere to the development requirements contained in the proposed policies below as well as the existing regulations to resist landslides through modern construction design, slope stabilization techniques, and density limits.

Therefore, the potential for adverse landslide impacts related to proposed changes from buildout of the General Plan was considered less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning landslides as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Result in substantial soil erosion or the loss of topsoil?

According to 2035 General Plan EIR, development associated with the General Plan would likely include earthwork activities that could expose soils to the effects of erosion or loss of topsoil. Once disturbed, either through removal of vegetation, asphalt, or an entire structure, stockpiled soils can be exposed to the effects of wind and water if not managed properly. Generally, earthwork and ground- disturbing activities, unless below minimum requirements, require a grading permit, compliance with which minimizes erosion, and the City’s grading permit requirements ensure that construct ion practices include measures to protect exposed soils such as limiting work to dry seasons, covering stockpiled soils and use of straw bales and silt fences to minimize offsite sedimentation.

In addition, development that disturbs more than one acre would be subject to compliance with a National Pollutant Discharge Elimination System (NPDES) permit, including the implementation of best

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management practices (BMPs), some of which are specifically implemented to reduce soil erosion or loss of topsoil, and the implementation of a storm water pollution prevention plan (SWPPP) through the local jurisdiction. BMPs that are required under a SWPPP include erosion prevention measures that have proven effective in limiting soil erosion and loss of topsoil. Generally, once construction is complete and exposed areas are revegetated or covered by buildings, asphalt, or concrete, the erosion hazard is substantially eliminated or reduced. Therefore, the potential for adverse soil erosion and topsoil loss impacts related t o land use changes from implementation of the General Plan was determined to be less than significant with implementation of General Plan polices.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning substantial soil erosion as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?

According to the 2035 General Plan EIR, some improvements associated with buildout of the General Plan could be located on geologic units or soils that are unstable, or that could become unstable and result in geologic hazards if not addressed appropriately. However, the potential hazards of unstable soil or geologic units would be addressed largely through the integration of geotechnical information in the planning and design process for projects to determine the local soil suitability for specific projects in accordance with standard industry practices and state-provided requirements, such as CBC requirements which are used to minimize the risk associated with these hazards. Geotechnical investigations would be required to thoroughly evaluate site-specific geotechnical characteristics of subsurface soils and bedrock to assess potential hazards and recommend site preparation and design measures to address any hazards which may be present. These measures are enforced through compliance with the CBC to avoid or reduce hazards relating to unstable soils and slope failure. In addition, General Plan policies would help ensure that potential impacts related to unstable units are minimized and would reduce the potential impact to less than significant. The potential for landslide, lateral spreading, subsidence, liquefaction, or collapse impacts related to changes from implementation of the General Plan were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035

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General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning unstable geologic units or soils that have the potential to result in landslides, lateral spreading, subsidence, and liquefication or collapse as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

d) Be located on expansive soil, as defined in Table 18-1- B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?

Refer to Response 3.7(c). The project would not result in new or substantially more severe environmental impacts concerning expansive soil as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

e) Have soils inca pable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?

According to the 2035 General Plan EIR, future development that may result from buildout of the General Plan in areas where sewers are not available could include septic systems or other alternative wastewater disposal systems. The City of Redlands Municipal Code prevents well drilling near septic tanks.

Furthermore, General Plan policies would make sure that future development in areas where sewer systems are not available would not impair the surrounding soil’s ability to support the use of alternative wastewater disposal systems. Impacts related to soils capability to support wastewater disposal were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning septic tanks and wastewater as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

According to the 2035 General Plan EIR, some portions of the City, especially in San Timoteo Canyon, are underlain by geologic formations that have yielded fossiliferous materials. It is possible that future development or public works activities within the city could cause significant impacts on these resources if they are disturbed during grading or excavation activities. Implementation of the General Plan would not directly result in physical construction that could impact paleontological resources. However, future development and redevelopment allowed under the General Plan could result in direct or indirect impacts on paleontological resources. Construction activities such as grading, excavation, and ground disturbing activities may result in the accidental destruction or disturbance of paleontological sites.

However, the 2035 General Plan EIR disclosed that the majority of development anticipated under the General Plan would involve redevelopment of or new development within existing developed areas.

Substantial excavation activities for installation of new infrastructure would be limited to new development in undeveloped areas; potential for this type of development does exist but is limited by the General Plan .

For example, in the General Plan, undeveloped areas in San Timoteo Canyon are designated for land uses with extremely low development potential, including Resource Preservation, Open Space, and Parks/Golf Courses. Other undeveloped areas in the Planning Area’s periphery, including the Santa Ana River Wash, Mentone, and Crafton, would be designated with low-density or open space uses as well. Thus, the likelihood of finding new or undiscovered paleontological resources would be limited. In addition, the General Plan includes the policies that would minimize or avoid impacts on paleontological resources, in addition to subsequent measures to be implemented as applicable. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning paleontological resources as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.8 GREENHOUSE GAS EMISSIONS

This section corresponds with 2035 General Plan EIR Section 3.5, Energy, Greenhouse Gases, and Climate Change.

Would the project:

a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

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Based on the 2035 General Plan EIR, Planning Area GHG emissions from the 2015 inventory were 472,651 MTCO2e per year, or 6.1 MTCO 2e per capita per year. Through General Plan policies and other city programs, such as the Redlands Bicycle Master Plan , the T ransit Villages Specific Plan, and the City’s CAP, GHG emissions are expected to be reduced on a per capita basis. In total, the City’s previously - identified strategies would reduce GHG emissions to 363,092 MTCO2e in 2020 and 359,358 MTCO2e by 2035, or 4.8 and 4.5 MTCO 2e per capita, respectively. These plans and programs that reduce GHG emissions would continue with implementation of the project. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of H ousing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning greenhouse gas emissions as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?

Based on the 2035 General Plan EIR, the implementation of the General Plan policies aimed at reducing GHG emissions, and the CAP that would serve as the implementation tool for GHG monitoring and reporting, number of strategies and measures aimed at reducing greenhouse gas emissions would be implemented. Additionally, the SCAG R TP/SCS includes a set of policy objectives related to mobility, reliability, system preservation and safety, social equity, healthy environment, and economic growth. The RTP will assist in SCAG’s implementation of SB 375, the California Global Warming Solutions Act of 2006, and regional GHG targets. With implementation of the General Plan’s goals and policies related to sustainability and multi-modal transportation objectives, the General Plan would complement the goals and policies of the RTP/SCS and would continue to carry out the goals of AB 32 and SB 375. Therefore, future development projects and land uses proposed under the General Plan and the City’s CAP would, by nature, result in reduced transportation GHG emissions. This achieves the overarching goals of local, regional, and State plans to reduce GHG emissions. Impacts would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning applicable plans, policies, and regulations adopted for the purpose of reducing GHG emissions as compared to the 2035 General Plan EIR.

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Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.9 HAZARDS AND HAZARDOUS MATERIALS

This section corresponds with 2035 General Plan EIR Section 3.7, Hazards and Hazardous Materials.

a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?

As stated in the 2035 General Plan EIR , implementation of the General Plan would allow for the development of land uses, including residential, mixed-use, recreational, industrial, commercial, and office uses, that may require the routine use, transport, and disposal of ha zardous material and waste within the Planning Area. Additionally, future construction activities associated with buildout of the General Plan may generate hazardous materials and waste, such as fuels and oils from construction equipment and vehicles.

Federal and State regulations require adherence to specific guidelines regarding the use, transportation, disposal, and accidental release of hazardous materials. There are currently no permitted hazardous waste facilities in the Planning Area. Any future disposal of hazardous waste by a hazardous waste generator, transporter, or treatment storage and disposal facility would require compliance with relevant federal and State law, including permitting through the DTSC and compliance with the SBFD’s CUPA requirements for hazardous waste generation and onsite treatment.

Policies in the General Plan seek to ensure that more intense land uses that may be more likely to utilize hazardous materials are sufficiently buffered from lower intensity uses such as residential. Proposed policies also seek to ensure that all projects, including those using hazardous materials, meet development standards to ensure public safety, and that emergency responders have the appropriate facilities and agreements in place to act quickly in case of an upset.

Implementation of applicable federal, State, and local regulations and policies would serve to lessen the risk of death, injury, and/or property loss associated with the transport, use, or disposal of hazardous materials by promoting safe handling and storage, documentation and information sharing, and appropriate emergency planning and response. In addition, compliance with General Plan policies would further ensure safe practices regarding hazardous materials. Therefore, the 2035 General Plan EIR determined that compliance with the General Plan policies and federal and State regulations will ensure the impact of routine use, transport, and dispos al of hazardous materials associated with implementation of the General Plan would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental

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impacts concerning the transportation, use, or disposal of hazardous materials as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

As stated in 2035 General Plan EIR, implementation of the General Plan would result in future development of land uses that would involve the use, transportation, disposal, and storage of hazardous materials in the Planning Area. Thus, personal injury, property damage, environmental degradation, or death could result from the release of hazardous materials caused by upset or accident conditions. Although the risk of upset and accident conditions involving the release of hazardous materials into the environment cannot be eliminated, it can be reduced to a manageable level. Exi sting regulations at the F ederal, State, and local levels serve to minimize the potential for upset during routine transportation, use, and disposal.

Additionally, regulations are in place to minimize the risk of upset or accident involving sites that have previously been contaminated by hazardous substances. Proper implementation of the SBFD’s CUPA programs would help to ensure documentation of releases and threatened releases as well as the development of risk management and hazardous materials release response plans. Given existing regulations and programs and General Plan policies that reduce the potential for hazardous materials upsets and promote the ability of emergency services to respond to incidents, impacts associated with the release of hazardous materials into the environment were determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning the accidental release of hazardous materials into the environment as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?

As stated in the 2035 General Plan EIR, the General Plan would allow land uses that would be reasonably expected to handle hazardous materials or generate hazardous emissions. Under the land use designations

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of the General Plan, there would be a range of land uses potentially allowed within a quarter-mile of existing schools (there are no proposed schools). The most intense uses allowed under the General Plan, under the Light Industrial or Commerc ial/Industrial designations, include manufacturing, distribution, research and development, and ancillary commercial uses for the former; and auto services, commercial retail and services, manufacturing for the latter. Heavy industries would only be permitted in areas designated by the proposed Santa Ana River Wash Plan, located away from any schools. The proposed CAP does not propose any land use changes and would not directly affect the siting of future development.

According to the 2035 General Plan EIR, future projects associated with buildout of the General Plan would be subject to regulations regarding the siting of uses handling hazardous materials. Furthermore, individual users of hazardous materials would continue to be regulated by local disclosure, permitting, and notification requirements of the “Disclosure of Hazardous Materials” program consistent with all F ederal, State, and local laws. Public schools are also required to evaluate and potentially amend their school safety plan on an annual basis. In the case that new schools or alterations to existing schools would be required in the future, the siting of schools, including existing facilities and upgrading construction projects, would be regulated by the California Department of Education; and new facilities would not be constructed within a quarter mile of facilities emitting or handling materials consistent with California Department of Education requirements. In addition, General Plan policies encourage compatibility of adjacent land uses, require buffering between high- and low-intensity land uses, prohibit the creation of harmful emissions, allow for the availability of information regarding hazardous materials for school planning, and provide for emergency planning to address potential upsets. Therefore, impacts were determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning hazardous materials in relation to schools as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

As stated in 2035 General Plan EIR , there are numerous sites in the Planning Area that are included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5. Several of the sites have reported releases to the ground resulting in soil and groundwater contamination and which are subject to various State and Federal laws and regulators, including CERCLA, EPA, DTSC, and the RWQCB, and a re in various stages of the cleanup process as stipulated by the relevant agencies.

Redevelopment of sites with existing soil or groundwater contamination in accordance with the Project could potentially pose a significant hazard to the public or the environment through releases of hazardous

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materials into the environment. H owever, these sites are regulated by existing F ederal and State policies and have been or are being investigated and remediated.

The 2035 General Plan EIR determined that General Plan policies would limit any impacts on new development from listed hazardous materials sites . Existing regulations and CUPA programs would also help by ensuring the reporting and documentation of any hazardous materials incidents in the Planning Area such that property owners could be aware of potential hazards. For future projects, CEQA requires developers to reference the Cortese List and state if the project or any alternatives would be located on a listed site. Based on these policies, regulations, and programs, impacts were determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning sites containing hazardous materials as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

As stated in 2035 General Plan EIR, the Planning Area includes portions that are within the airport land use plan area of the Redlands Municipal Airport or within two miles of the San Bernardino International Airport (SBIA). General Plan policies ensure that future development would be compatible with the policies and standards of the ALUCP. Such policies would ensure that future residential development occurs within the range allowed by the ALUCP. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning airport safety and noise as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

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Level of Significance: Less Than Significant Impact.

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

As stated in the 2035 General Plan EIR, physical development within the Planning Area, including new roadways, land uses, and increased densities, could create obstacles to the implementation of emergency response or evacuation plans adopted for the Planning Area. However, policies in the General Plan would eliminate or reduce these impacts by seeking to utilize the Redlands HMP, which is consistent with the MJHMP, as a guide for emergency planning, thus considering the area’s hazards and promoting means to reduce local risks, as well as to improve emergency access, ingress, and egress, emergency preparedness, and inter-jurisdictional cooperation throughout the Planning Area. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning emergency response or evacuation plans as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?

As stated in the 2035 General Plan EIR, a majority of Redlands is characterized by Cal Fire as having a Moderate fire threat level, with areas of High, Very High, and Extreme threat found on the periphery of the city and in the SOI outside of city limits: in the canyonlands, Crafton, Mentone, and in the Santa Ana River Wash. Some areas of Little or No Threat can be found along San Timoteo Creek and the Santa Ana River.

Areas of High to Extreme fire threat are characterized by natural vegetation that can serve as fuel for wildland fires, and steeper topographies that can impede emergency access and facilitate the rapid spread of potential fire.

Areas identified as High to Extreme fire threat correspond to General Plan land use designations associated with open space, agriculture, and very low residential densities, which would minimize the exposure of people and structures to fire hazards. In Crafton, where some residential development could be allowed under the Rural Living, Very Low Density Residential, Low Density Residential, and Hillside Conservation land uses, projects would be constrained by terrain and General Plan policies that limit development based on slope and emergency access in order to reduce the safety risks associated with these factors. The Hillside Conservation designation would only allow development if it would not negatively impact public safety or welfare. Proposed policies for the canyonlands would require fir e safety measures including access roads to be in place before any development could be allowed, though most land in the canyons would be designated as Resource Preservation and thus developed at a low-density rate. New development that occurs

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pursuant to the Project would generally take place within areas shown with Moderate fire threat, which covers most of the already urbanized portions of the Planning Area accessible to emergency services and managed vegetation. In general, proposed policies would require all development to adhere to safety standards provided in the CBC and California Fire Code, and would promote close coordination with the Redlands Fire Department and the fire services of neighboring jurisdictions to ensure the safety of new development. Land use patterns that limit new development in areas of High to Extreme fire threat; proposed policies that promote fire safety through agency cooperation and management of risk factors associated with fire threat; adherence to applicable building and fire codes; and existing programs such as weed abatement and education under the Redlands Fire Department and fire services in neighboring jurisdictions would serve to reduce any impacts related to the exposure of people or structures to wildland fire to less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning wildland fires as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.10 HYDROLOGY AND WATER QUALITY

This section corresponds with 2035 General Plan EIR Section 3.9, Hydrology and Water Quality.

Would the project:

a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?

According to the 2035 General Plan EIR , buildout of the General Plan would have a significant environmental impact if it would violate water quality standards and waste discharge requirements set out in Municipal Permit Order No. R8 -2010-0036, NPDES Permit No. CAS618036, issued by the Santa Ana RWQCB. Violation of these permits could occur if the Project would substantially increase pollutant loading levels in the sanitary sewer system or in groundwater underlying the city, either directly through the introduction of pollutants generated by industrial land uses, or indirectly through stormwater pollution.

As National Pollutant Discharge Elimination System (NPDES) Permit CAS618036 is based on the federal Clean Water Act, compliance with the Porter–Cologne Water Quality Control Act (Division 7 of the Water Code, commencing with Section 13000), applicable state and federal regulations, all applicable provisions of statewide water quality control plans and policies adopted by the SWRCB, the Basin Plan adopted by the RWQCB, the California Toxics Rule, the California Toxics Rule Implementation Plan, and NPDES would ensure compliance with other applicable plans and regulations pertaining to water quality.

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In addition, every construction activity within the Planning Area that has the potential to negatively affect water quality is required to comply with the NPDES St ormwater Discharge Permit. Implementation of practices required by the NPDES Permit would reduce the volume of runoff from impervious surfaces and increase the amount of natural filtration of pollutants from stormwater occurring on site, generally improving the quality of stormwater before it enters the city’s stormwater system.

Furthermore, the General Plan contains goals and poli cies pertaining to water quality that will promote protection to city’s natural water bodies, prevent water pollution, ensure preparation and implementation of applicable water quality
Plans, require incorporation of BMPs, and ensure compliance with the city’s NPDES Permit and other related regulations. Overall, the General Plan ’s policies would promote improved water quality in the Planning Area and continued compliance with Federal, State, and local water quality regulations, and would ensure that water quality is protected to the maximum extent practicable. Therefore, the 2035 General Plan EIR determined that impacts would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning surface or groundwater quality as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may imped e sustainable groundwater management of the basin?

According to the 2035 General Plan EIR , the Planning Area is located in the Upper Santa Ana Valley Groundwater Basin. The City's domestic water wells constitute about 50 percent of the water supply, and the General Plan would allow for additional development within the Planning Area that could increase demands for water. However, the General Plan policies, along with water conservation policies would help to conserve groundwater in the Planning Area. Furthermore, the Cit y’s Well Drilling Ordinance protects groundwater from potential sources of contamination resulting from well drilling. The proposed CAP does not include any land use changes or other measures that would impact groundwater supplies. Overall, the 2035 General Plan EIR determined that impacts on groundwater would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental

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impacts concerning groundwater supplies or groundwater recharge as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or rive or through the addition of impervious surfaces, in a manner that would:

i) Result in substantial erosion or siltation on- or off-site?

According to the 2035 General Plan EIR, the i mplementation of the General Plan would not involve the direct alteration of existing streams, rivers, or other drainage patterns. However, future development/redevelopment allowed under the General Plan could impact the existing drainage system.

Increases to impervious surfaces, such as roofs, patios, driveways, and parking areas would lead to increased stormwater flow. The General Plan would allow for additional development that could increase the number of impervious surfaces within the city and could increase runoff from these sites into the local storm drains in the Planning Area. An increase in runoff volumes could result in hydromodification effects, such as erosion, siltation, and flooding on the hydrological systems within the Planning Area, which occur when rainfall runoff is increased from impervious areas above the natural rainfall rate that would otherwise occur. However, most of the development that may occur in the Planning Area is redevelopment of areas with already impervious surfaces.

Furthermore, the City recognizes the importance of water quality and preventing hydromodification. Any development that would occur under the General Plan would be subject to City’s Flood Damage Prevention ordinance that helps prevent flood damage resulting from hydromodification. Adherence to the City’s Storm Drains Ordinance would limit surface runoff from development under the General Plan , reducing siltation and erosion. In addition, the General Plan ’s goals and policies are intended to preserve natural watercourses or naturalized drainage channels, and to ensure future development incorporates BMPs to reduce runoff from a site. For these reasons, the 2035 General Plan EIR determined that impacts associated with the General Plan would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned wi thin three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning erosion as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

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Level of Significance: Less Than Significant Impact.

ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?

Refer to Response 10(c)(i) above.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?

According to the 2035 General Plan EIR, implementation of the General Plan would not involve the direct alteration of existing streams, rivers, or other drainage patterns. However, future development/redevelopment allowed under the General Plan could impact the existing drainage system.

Increases to impervious surfaces, such as roofs, patios, driveways, and parking areas would lead to increased stormwater flow. Additionally, every construction activity within the Planning Area that has the potential to negatively affect water quality must prepare a construction Stormwater Pollution Prevention Plan (SWPPP). Projects that would result in the disturbance of one acre or more of pervious surface or would create more than 10,000 square feet of impervious surfaces are subject to the NPDES Stormwater Discharge Permit and stormwater pollution prevention requirements.

Furthermore, the proposed goals and policies promote the protection of the city’s natural water bodies, prevent water pollution, ensure preparation and implementation of applicable water quality plans, require incorporation of BMPs, and otherwise ensure compliance with the City’s NPDES Permit and other related regulations. Overall, the proposed General Plan’s goals and policies would promote improved water quality in the city and continued compliance with Federal, S tate, and local water quality regulations, and would ensure that water quality is protected to the maximum extent practicable. T he 2035 General Plan EIR determined that impacts would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts stormwater drainage or runoff as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?

According to the 2035 General Plan EIR, the Planning Area is located sufficiently inland to be out of what would be considered a potential hazard area for seiches, tsunamis, and sea level rise. Mudflow, also known as a landslide or mudslide, is a flow of dirt and debris that occurs after intense rainfall or earthquakes. The speed of the mudflow is dependent on the amount of precipitation, steepness of slope, and vibration of the ground. Potential impacts of the proposed General Plan related to mudflow are reduced by CBC design provisions, geotechnical investigation requirements, modern construction design, slope stabilization techniques, and density limits. The 2035 General Plan EIR determined that c ompliance with the City’s existing regulations pertaining to flooding and landslide hazards, along with the propose d General Plan policies would ensure the impacts associated with mudflow would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning floods, tsunamis, or seiches as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

According to the 2035 General Plan EIR, t he General Plan would allow for new development that could potentially degrade water quality. However, development would be subject to the RWQCB requirements and City of Redlands Municipal Code. Furthermore, the General Plan contains goals and policies pertaining to water quality, as described previously. Overall, the General Plan ’s goals and policies would promote improved water quality in the Planning Area and continued compliance with Federal, State, and local water quality regulations, and would ensure that water quality is protected to the maximum extent practicable.

Therefore, the General Plan would not substantially degrade water quality and the 2035 General Plan EIR determined impacts would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning a water quality control plan as compared to the 2035 General Plan EIR.

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Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.11 LAND USE AND PLANNING

This section corresponds with 2035 General Plan EIR Section 3.10, Land Use and Housing.

Would the project:

a) Physically divide an established community?

As stated in the 2035 General Plan EIR , the General Plan would not result in uses or development that would physically divide any established community. Additionally, the General Plan does not propose new highways or infrastructure facilities that would physically divide the community. Rather, by improving connectivity and land use consistency within and between existing neighborhoods, the General Plan provides more linkages within the city and the region. Policies are proposed that seek to minimize the impact of the interstate highway as a physical barrier and unite the northern and southern parts of the city through land uses, infrastructure, and design. Therefore, implementation of the General Plan would not cause an adverse impact in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning the physical division of established communities as compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?

The 2035 General Plan EIR concluded that, s ince the General Plan would update policies and land use designations for future development, it may naturally be inconsistent with existing planning regulations, such as density/intensity standards and allowed uses, that were designed to implement the current General Plan. These ex isting regulations must be updated to be consistent with and/or effectively implement the proposed project if it were adopted. Amendments to the General Plan may also be needed from time to time to conform to State or federal laws passed since adoption of the General Plan, and to eliminate or modify

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policies that may become obsolete or unrealistic due to changed conditions. Additionally, the City’s Zoning Ordinance would be revised to implement the proposed project, and it will translate the proposed Genera l Plan policies into specific use regulations, development standards and performance criteria that will govern development on individual properties. The Zoning Ordinance prescribe s standards, rules, and procedures for development under the project. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning existing land use plans compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

3.12 MINERAL RESOURCES

This section corresponds with 2035 General Plan EIR Section 3.11, Mineral Resources.

Would the project:

a) Result in the loss of availability of a known mineral resource of value to the region and the residents of the State?

According to 2035 General Plan EIR, the General Plan includes changes to land use designations in areas designated by The State Mining and Geology Board (SMGB) as containing regionally significant aggregate resources classified as the Mineral Resource Zone-2 (MRZ-2). Given that the General Plan would continue to apply a land use designation appropriate for mining to nearly all SMGB-designated land in the Planning Area; would not create land use conflicts with any existing mining operation; and is compatible with the Wash Plan, which would not significantly impact mineral resource availability within its planning area; the 2035 General Plan EIR determined that the General Plan would have a less than significant impact on the availability of a known mineral resource that would be of value to the region and the residents of the state.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning mineral resources compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

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Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Result in the loss of availability of a locally -important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?

According to 2035 General Plan EIR, the General Plan does not contain land use changes or policies that would affect existing mining operations within or adjacent to the Planning Area. The General Plan does not designate any locally important mineral resource recovery sites in the Planning Area, though it does include the Flood Control/Construction Aggregates Conservation/Habitat Preservation land use designation which applies to land that would potentially be used for aggregate mining activities. All areas containing existing mining uses in areas that are currently designated as Flood Control/Construction Aggregates Conservation/Habitat Preservation would be redesignated as Open Space, which would include construction aggregate mining as a conditionally permitted land use in the same fashion as the existing Flood Control/Construction Aggregates Conservation/Habitat Preservation designation. Similarly, no proposed land use changes would conflict with the Wash Plan, which applies an Aggregate Mining designation to portions of the Santa Ana River Wash with existing mining activity or that are suitable for future potential mining activity. Policies in the General Plan would support the implementation of the Wash Plan and its designations. No impact was identified in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to backg round information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts concerning the availability of locally-important mineral resources compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

3.13 NOISE

This section corresponds with 2035 General Plan EIR Section 3.12, Noise.

Would the project result in?

a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

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According to the 2035 General Plan EIR, implementation of the General Plan may result in both temporary and permanent increases in ambient noise levels. Specific developments under the proposed project could expose existing and/or new sensitive uses to stationary noise sources, such as industrial and/or commercial uses. The development of new commercial and industrial uses pursuant to the General Plan may increase noise levels in their vicinity due to the establishment of new stationary noise sources. Although vehicular noise is exempt from local regulation when operating on public streets, cities and counties can regulate vehicular noise while operating on private property. The use of heavy trucks on private properties (e.g., making deliveries to commercial and industrial uses) would result in noise levels of 73 dBA at 50 feet from the source of the noise (e.g., truck’s engine, idling trucks). The use of multiple trucks on a site, such as might occur at a warehouse, would generate noise levels of about 80 dBA Leq as measured at 50 feet.

Industrial processing equipment and conducting outdoor industrial activities could also generate increased noise levels. New projects developed under the General Plan would be subject to the City’s noise ordinance.

Compliance the City’s noise ordinance in the Municipal Code in Sections 8.06.070 and 8.06.080, would result in less than significant noise impact. Implementation of the General Plan principals and actions would further reduce the impacts from stationary noise sources on sensitive land uses and include mechanisms to ensure appropriate review and placement of noise reduction requirements on new development.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to ambient noise levels compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Generation of excessive groundborne vibration or groundborne noise levels?

As stated in 2035 General Plan EIR, implementation of the General Plan may result in groundborne vibration, but the increases associated with various sources would be less than significant, as discussed below.

Construction Vibration

Future development under the General Plan would generate excessive groundborne noise and vibration near construction sites, and if sensitive receptors or land uses are adjacent to these sites, there could be significant impacts from groundborne noise or vibration. Construction activities can produce vibration that may be felt by adjacent land uses. If construction of a particular development did not require the use of equipment, such as pile drivers, known to generate substantial construction vibration levels, the primary source of vibration during construction would likely be from bulldozer and truck operation.

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Vibration generated by construction equipment can result in varying degrees of ground vibration, depending on the equipment. The operation of construction equipment causes ground vibrations that spread through the ground and diminish in strength with distance. Buildings situated on soil near the active construction area respond to these vibrations, which range from imperceptible to low rumbling sounds, with perceptible vibrations and slight damage at the highest vibration levels. Typically, construction-related vibrations do not reach vibration levels that would result in damage to nearby structures.

Traffic Vibration

The General Plan update would allow for future land development, which would not in and of itself generate any traffic vibration levels. Vehicular traffic would generate groundborne vibration and are typically caused by poor road conditions, such as potholes, bumps, expansion joints, or other discontinuities in the road surface. Passenger vehicles and trucks would cause effects such as rattling of windows, and the source would almost always be airborne noise. For areas within the Planning Area where the General Plan update would not improve roadways, vibration levels generated from vehicular traffic would not change. For areas within the Planning Area where the General Plan would improve roadways, vibration levels generated from vehicular traffic would be reduced because potholes, bumps, or other discontinuities in the road surface would be addressed. Therefore, groundborne vibration impacts generated by vehicles traveling within the Planning Area would be considered less than significant.

Rail Vibration

The operations of the Union Pacific Railroad (UPRR) currently generate vibration levels. Although existing train operations generate vibration levels, the General Plan would not change vibration levels generated from trains.

In addition, all future developments within the City that fall within the required noise screening distances as specified in the FTA Noise and Vibration Manual, a detailed noise analysis would be required. The screening distance for commuter rail is 750 feet with no obstruction between the rail line and receptor and 375 feet with intervening buildings. Therefore, vibration levels generated from trains would be considered less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to groundborne vibration or noise levels compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

c) For a project located within the vicinity of a private airstrip an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use

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airport, would the project expose people residing or working in the project area to excessive noise levels?

As detailed in 2035 General Plan EIR, The Redlands Municipal Airport is in the northeast part of the city.

Residential uses and a school located south of the Redlands Municipal Airport would have the potential to be exposed to aircraft noise levels exceeding 60 dBA CNEL. However, the General Plan would not change the land use of the existing residences and one school located within the 60 dBA CNEL contours for the Redlands Municipal Airport. Future residences would include noise attenuation consistent with the Noise Element of the General Plan and the ALUCP for the Redlands Municipal Airport. Impacts due to aircraft noise were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to airport noise compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No new additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.14 POPULATION AND HOUSING

This section corresponds with 2035 General Plan EIR Section 3.10, Land Use and Housing.

Would the project:

a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?

Based on the 2035 General Plan EIR, about 6,400 housing units are projected to be built in the Planning Area by 2035, approximately 2,900 more units than the project is proposed to zone for. The project continues to focus infill residential development opportunities in vacant areas in Redlands, while existing General Plan policies seek to preserve existing neighborhoods. However, the General Plan would increase the overall number of dwelling units and provide housing to serve the diverse needs of the community, meaning potentially displaced people would be able to find housing elsewhere in the community. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of

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the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to unplanned population growth compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were requ ired in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

According to the 2035 General Plan EIR, buildout of the General Plan would not directly displace any housing units, businesses, or people. Redevelopment of existing uses will likely occur; however, such development will take place over time as the market allows and will result in a net increase in residential units. Though it is impossible to guarantee residents will not be displaced as a result of implementation of the project, General Plan policies seek to preserve existing neighborhoods. The project would accommodate an increase in housing opportunities in the City and would not displace substantial numbers of existing housing or people, necessitating the construction of replacement housing elsewhere. Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to displacement compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.15 PUBLIC SERVICES

This section corresponds with 2035 General Plan EIR Section 3.13, Public Facilities and Services.

a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable serve ratios, response times or other performance objectives for any of the public services:

i) Fire Protection?

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With a projected increase in population of about 16,400 additional residents in the Planning Area at General Plan buildout, the 2035 General Plan EIR concluded that demand for fire protection services will increase.

Population increases may result in increased alarms and call volumes that may negatively impact Fire Department response times unless adequate staffing and facilities are maintained. The majority of new development under the project will be located in infill sites in urbanized areas of the city, most of which are in areas of low fire hazard severity. Due to the minimal effects that the development of new facilities would have on the environment, the concentration of most new development in areas already well -served by fire protection services, and the addition of policies to reduce fire hazards in the city, this impact was determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the proje ct present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to fire protection compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Police Protection?

According to the 2035 General Plan EIR, the General Plan policies aim to mitigate increases in demand for police services. Policies include those that encourage physical planning and community design practices that promote safety, as well as policies that include residents in community safety efforts. Because meeting facilities needs for an expanded Police Department would not pose detrimental environmental impacts, and because policies and Mitigation Measure 4.9-a promote improved public safety, this impact was determined to be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to police protection compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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c) Schools?

The 2035 General Plan EIR determined the school-aged population is expected to increase. This increase will impact enrollment totals in Redlands Unified School. District (RUSD) facilities in the Planning Area.

Although ongoing demographic trends are causing reductions in the percentage of school -aged children compared to the total population, the projected population increase would result in the number of elementary school students exceeding school capacity. According to the California Department of Finance projections, San Bernardino County’s school -aged population as a percentage of the total population is likely to decline slightly over the planning horizon: the percentage of the population aged 5 to 17 is projected to decline by about 2 percent, from 19.79 percent of the population to 17.22 percent.

As discussed in the 2035 General Plan EIR , RUSD can utilize trailers and temporary classrooms to accommodate students in the interim, but a new school may be required for the long run. The school district owns land north of Mission Road just outside the Planning Area in Loma Linda, which could be utilized to the construction of a new facility, if necessary. The policies included in the General Plan would ensure that school facilities are expanded to meet demand as development occurs. Development of schools would require project-level environmental review and site- specific mitigation measures as appropriate, ensuring that adverse environmental effects are avoided or mitigated. This impact was considered less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to schools compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No new additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

d) Parks?

According to the 2035 G eneral Plan EIR, a t buildout, the General Plan may generate an increase in population of up to 10,964 residents in the City of Redlands. Without the development of new parks, this increase would place additional physical demands on existing parks and facilities. An increase in the number of park users would cause parks to be in active use for longer periods of time and/or used more intensively over the course of a typical day. As a result, vital park elements such as vegetation, water resources, built structures, walking/biking paths, sport facilities, and others would face increased wear-and- tear over the course of the planning period and, without proper maintenance, their useful life could be shortened.

The General Plan calls for the addition of several parks in the Sphere of Influence (SOI) outside of city limits an area that is underserved by parkland. This increase would improve the ratio of park acres per 1,000 residents in the SOI outside of city limits and the Planning A rea as a whole. With about 16,355 new

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residents expected in the Planning Area in 2035, the 140.9 acres of proposed parkland in Redlands in addition to 55 acres of proposed parkland in the SOI outside of city limits would result in a ratio of 6.4 acres per 1,000 residents in the Planning Area as a whole, which would also exceed the City’s park standard of 5 acres per 1,000 people.

The General Plan provides for new parkland to serve the city’s population as it expands. With the City’s development impact fees, this would ensure that new parkland is distributed evenly throughout the Planning Area, thus preventing any existing neighborhood, community, or regional parks, or other recreational facilities from overuse that could result in the physical deterioration of those facilities. Additional policies requiring proper maintenance of existing and future recreational facilities also serve to ensure that the Planning Area’s parks remain in good physical condition. The development of new recreational facilities would be subject to existing building and construction regulations that would ensure that construction activities have a minimal effect on the surrounding environment. These, along with General Plan policies established to protect biological resources and air and water quality, ensure that the General Plan would have a less than significant impact on the physical and environmental quality of Redlands’ parks.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to parks compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures wer e required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

e) Other public facilities?

The 2035 General Plan EIR determined that the projected increase of about 16,400 residents in the Planning Area by 2035 will likely increase demand for library and other community services. A portion of this increase in demand can be accommodated by extending the hours of operation of the Smiley Library. Owing to the gradual nature of this facilities need, the General Plan policies for new development, and the continued assessment of existing library facilities and services would ensure that significant environmental impacts from the provision of additional library space would not occur. In addition, development impact fees from new development would serve to ensure that improvements are made in a timely manner so as to avoid the deterioration of existing library facilities. The development of new library facilities would be subject to existing building and construction regulations that would ensure that construction activities have a minimal effect on the surrounding environment, while project -level environmental review and site- specific mitigation measures would help ensure that adverse environmental effects are avoided or mitigated.

This impact was concluded to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to backgro und information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City

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review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to other public facilities compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: N o mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.16 RECREATION

This section corresponds with 2035 General Plan EIR Section 3.13, Public Facilities and Services.

a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?

Based on the 2035 General Plan EIR , the General Plan provides for new parkland to serve the city’s population as it expands. With the City’s development impact fees, this would ensure that new parkland is distributed evenly throughout the Planning Area, thus preventing any existing neighborhood, community, or regional parks, or other recreational facilities from overuse that could result in the physical deterioration of those facilities. Additional policies requiring proper maintenance of existing a nd future recreational facilities also serve to ensure that the Planning Area’s parks remain in good physical condition. The development of new recreational facilities would be subject to existing building and construction regulations that would ensure tha t construction activities have a minimal effect on the surrounding environment. These, along with General Plan policies established to protect biological resources and air and water quality would ensure that the General Plan would have a less than significant impact on the physical and environmental quality of Redlands’ parks.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to parks or recreational facilities compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?

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Refer to Response 3.6(a).

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact with Mitigation.

3.17 TRANSPORTATION

This section corresponds with 2035 General Plan EIR Section 3.15, Transportation.

Would the project:

a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?

As detailed in the 2035 General Plan EIR, impacts from the General Plan on the vehicular network were forecasted for intersection, roadway, and freeway analysis. Projected LOS were compared to the performance criteria for the applicable jurisdictions to determine whether a significant impact would occur.

For intersections and roadway segments, if all roadway improvements in the General Plan were implemented, impacts would be less than significant. However, because eight of the proposed improvements would be located on facilities partially or fully controlled by other jurisdictions, the City of Redlands could not guarantee implementation. Therefore, some impacts could occur that would be significant and unavoidable. In addition, four freeway segments were determined to experience significant and unavoidable impacts. The impacts on the freeway system are not in the City’s control as these would occur due to regional growth and would occur with or without the implementation of the General Plan, creating a significant and unavoidable impact. These impacts are discussed in more detail below.

The General Plan includes a series of policies to address changes in vehicle LOS resulting from buildout.

Proposed policies include roadway and intersection improvements as well as strategies to reduce congestion, particularly on local roads, through the layered network, transportation demand management, and promoting the use of alternative transportation modes. The General Plan’s land use strategy serves to minimize vehicular traffic by promoting walking, bicycling, and transit use. The General Plan also establishes policies that strengthen and expand the non-motorized transportation system and would not conflict with any established plans, ordinances, or policies establishing measures of effectiveness for these forms of circulation. No mitigation is available beyond the implementation of General Plan Action 5-A.38.

Although these policies require the City to coordinate with adjacent jurisdictions to implement the improvements, the ultimate decision to implement the improvements resides with another jurisdiction.

Since the City cannot guarantee that the needed improvements will be implemented, the 2035 General Plan EIR determined that impacts would be significant and unavoidable.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035

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General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to a program, plan, ordinance, or policy addressing the circulation system compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Significant and Unavoidable.

b) Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? 1 As stated in 2035 General Plan EIR, the six CMP intersections and 14 CMP roadway segments within the Planning Area, implementation of the Project would not degrade existing levels of service below acceptable levels or further degrade existing unacceptable level of service, if all General Plan improvements would be implemented. However, as with the intersection and roadway segment analysis, some improvements that are part of the General Plan, and which are assumed in the roadway analysis, are partially or fully within the control of other jurisdictions and thus cannot be guaranteed by the City of Redlands. Without the proposed improvements, the LOS would worsen at a roadway segment already operating at LOS F, resulting in a potentially significant and unavoidable impact.

Although this policy requires the City of Redlands to coordinate with San Bernardino County to implement the improvement, the ultimate decision to implement the improvements resides with another jurisdiction.

Since the City cannot guarantee that the needed improvements will be implemented, the 2035 General Plan EIR determined that this impact would be significant and unavoidable.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to service standards and t ravel demand measures compared to the 2035 General Plan EIR.

1 The revised project is not required to analyze vehicle miles traveled (VMT) since it was circulated for public review prior to adoption of VMT as the means for analyzing transportation impacts. “If an environmental document has not yet been sent out for public review before July 1, 2020, the agency’s environmental document must use VMT for analyzing transportation impacts using VMT as of July 1. (See CEQA Guidelines, § 15007(c) [“If a document meets the content requirements in effect when the document is sent out for public review, the document shall not need to be revised to conform to any new content requirements in Guideline amendments taking effect before the document is finally approved.”].)

Since circulation of an addendum is not required in accordance with CEQA Guidelines Section 15164, and LOS was the primary method for analyzing transportation impacts when the previously certified EIR was circulated for public review, an analysis of VMT for the revised project is not required under CEQA.

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Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Significant and Unavoidable.

c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

The 2035 General Plan EIR states that the General Plan provides for safety and compatibility in the transportation network. Proposed policies ensure that the design of roadway facilities considers the needs of users of all modes to promote safe street designs that are appropriate for adjacent land uses. The layered network approach in the General Plan is intended to reduce conflicts from incompatible modes while incorporating facilities that can safely accommodate a range of users. For example, the General Plan seeks to use the layered network to identify routes that are more appropriate for goods movement, which would allow truck traffic to avoid local roads and residential neighborhoods. The roadway classification system in the General Plan supports this by requiring up- to-date design standards tailored for the users and conditions likely for each classification. Thus, transportation policies in the General Plan would reduce design hazards and conflicts between incompatible land uses and between all transportation network users.

Impacts were determined to be less than significant in this regard.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law . The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to geometric design features and incompatible uses within the transportation system compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

d) Result in inadequate emergency access?

According to the 2035 General Plan EIR, emergency vehicles take the fastest and most expedient routes to access an emergency. In the event of an evacuation, the primary routes include, if available: Redlands Boulevard, Fern Avenue, Terracina Boulevard, and Barton Road. The General Plan includes policies and actions aimed at ensuring that adequate emergency access is provided for existing and future development.

The 2035 General Plan EIR determined that implementation of current State and federal regulations, combined with General Plan policies and actions, would reduce the potential impacts on study intersection and roadway segments along emergency access routes in the Planning Area to a less than significant level.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose

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rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to emergency access compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.18 TRIBAL CULTURAL RESOURCES
This section corresponds with 2035 General Plan EIR Section 3.8, Historical, Archaeological, and Paleontological Resources.

a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resou rces Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or

Based on the 2035 General Plan EIR , there are no known tribal cultural resources in the Planning Area.

However, the Planning Area has the potential to contain tribal cultural resources from past Native American activities. Sensitive areas include lands along water sources though there is potential that resources near waterways have been disturbed over time by alluvial processes and flooding and the many rock outcroppings and boulders in upland portions of the Planning Area. Thus, it is possible that future development in the Planning Area could encounter tribal cultur al resources. Future development allowed under the General Plan could result in direct or indirect impacts through grading, overland vehicle travel, or other ground-disturbing activities, or through facilitation of access to archaeological sites by the public.

The impact of such activities would be considered significant if they were to cause a substantial adverse change to the resources as defined by CEQA Guidelines Section 15064.5. Policies in the General Plan would minimize or avoid potential impacts to any resources not known at this time that may be encountered in future and would promote consultation with local Native American tribal groups during future projects to ensure the protection of tribal cultural resources. Future development projects would a lso be subject to State and federal law regarding the protection of tribal cultural resources. Thus, impacts concerning tribal cultural resources were considered less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035

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General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to tribal cultural resources compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Refer to Response 3.18(a)(i) above.

Certified 2035 General Plan EIR Mitigation Measures: Refer to Mitigation Measures 4.11-a.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

3.19 UTILITIES AND SERVICE SYSTEMS

This section corresponds with 2035 General Plan EIR Section 3.14, Public Utilities.

Would the project:

a) Require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?

As detailed in the 2035 General Plan EIR, the development of future residential, commercial, and industrial land uses in the planning area would be allowed. Additional population and businesses would generate additional demand for water and wastewater services, and therefore, a potential increased demand for water provision and wastewater collection, conveyance, and treatment services over currently established levels. General Plan buildout would allow for the future development of residential uses in Redlands. Additional population and businesses would generate additional demand for water and wastewater services, and therefore, a potential increased demand for water provision and wastewater collection, conveyance, and treatment services over currently established levels. The 2035 EIR determined that at buildout of the General Plan these facilities and services would be adequate to serve the projected buildout, and impacts would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035

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General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to regulations pertaining to utilities compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?

As detailed in the 2035 General Plan EIR, the City of Redlands projected water supplies for 2035 of 64,098 af from existing sources and entitlements. The City of Redlands has identified adequate supply from existing water sources and entitlements to meet demand through 2035. The 2015 RUWMP shows that in a normal year, demand for potable and raw water could be met through surface water diversions and groundwater extraction alone. Imported water, which is subject to availability from the SWP, would only account for about 5 percent of the total potential supply. Potable and raw water diversions as projected in the 2015 RUWMP would be in line with projections made for the 2015 IRWMP, which considered each service provider’s demands in terms of a regional water budget. The 2015 IWRMP projected that surface water diversions and groundwater extractions from the San Bernardino Basin Area (Bunker Hill Subbasin) by the City of Redlands in 2035 would be 34,549 af for a population of 101,644 people.

The 2015 RUWMP also includes projections showing adequate supply for multiple dry years. In the event of a water shortage, the City of Redlands would rely on its Water Conservation Plan. While a series of dry years would reduce supply, the City has the potential to utilize multiple sources and offset normal supplies with additional groundwater
and conservation efforts without seeking additional entitlements or water sources. Implementation of policies in the General Plan would reduce the overall water usage in the Planning Area by curbing demand for domestic and commercial purposes and promoting water conservation strategies. Proposed policies also seek to ensure the long -term quality and maintenance of surface waters and groundwater supplies, while exploring new options for the capture and utilization of sto rmwater. As future development under the General Plan has been projected to be accommodated by existing water sources and entitlements, compliance with local and regional water management plans, as well as further compliance with SBx7-7 and implementation of General Plan policies, would reduce the impact to less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to regulations pertaining to water supplies compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

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Level of Significance: Less Than Significant Impact.

c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

As detailed in the 2035 General Plan EIR , implementation of the General Plan would result in future residential and commercial uses in Redlands that could generate additional wastewater. Therefore, wastewater collection, conveyance, and treatment needs would increase over current levels. Additionally, goals and policies in the General Plan aim to conserve water by curbing demand for domestic and commercial purposes, ensure coordinated planning for the provision of public facilities including water infrastructure, and ensure that utilities be designed and constructed to preserve the natural character of an area. Such policies would help to reduce the demand on existing treatment infrastructure and allow for meaningful consideration of potential impacts of any future decisions regarding the provision of new infrastructure.

In addition, current regulations require compliance with water quality standards and wou ld not allow development without adequate utility capacity, including wastewater treatment capacity. Future development projects allowed under the General Plan would be reviewed by the City and the applicable wastewater providers to determine that sufficie nt capacity exists to serve the development. Therefore, through compliance with State and local regulations, and implementation of the General Plan policies, the 2035 General Plan EIR concluded that impacts would be less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezon ed within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to wastewater compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

As stated in the 2035 General Plan EIR , waste collection services are provided by the City of Redlands .

Solid waste is primarily disposed of at the California Street Landfill and the San Timoteo Sanitary Landfill.

The California Street Landfill has a maximum permitted throughput of 829 tons per day. Its maximum permitted capacity is 10 million cubic yards, of which 4,800,000 cubic yards remain. The San Timoteo Sanitary Landfill has a permitted capacity of 20,400,000 cubic yards and a maximum daily throughput of 2,000 tons. Its remaining capacity is 13,605,388 cubic yards.

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Given the City’s ability to meet its disposal targets, as well as the remaining capacity in area landfills, meeting the collection, transfer, recycling, and disposal needs of the projected population of the Redlands General Plan would not result in adverse impacts on landfill facilities. It is also likely that changes in regulations will occur that will decrease the need for landfill capacity through new recycling measures. The 2035 General Plan EIR determined that c ompliance with solid waste regulations and implementation of General Plan policies would reduce impacts to less than significant levels.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to the generation of solid waste compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation me asures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

e) Comply with Federal, State, and local management and reduction statutes and regulations related to solid waste?

As detailed in the 2035 General Plan EIR , City of Redlands Municipal Code establishes requirements for recycling to facilitate compliance with State recycling mandates. It establishes mandates related to solid waste, including access points for solid waste and recycling collection vehicles, as wel l as capacity requirements for waste generation of buildings. Development of future land uses, as designated in the General Plan, would be required to comply with federal, State, and local statutes and regulations related to solid waste.

As described above, waste collection services are provided by the City of Redlands for areas within city limits. The Redlands Quality of Life Department provides residential waste collection, green waste collection for yard waste, and curbside recycling. Hazardous and electronic waste is managed by the Redlands Fire Department, which operates a household hazardous and electronic waste disposal site on a weekly basis. Waste collection for the Mentone and Crafton areas is carried out by private haulers contracted with San Bernardino County. Furthermore, policies provided in the General Plan regarding solid waste disposal, recycling, etc., would further ensure compliance with applicable regulations. Therefore, there would be no impact.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three year s of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to regulations pertaining to solid waste compared to the 2035 General Plan EIR.

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Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

3.20 WILDFIRE

The previously certified 2035 General Plan EIR did not specifically evaluate wildfire as it was not required in the CEQA Guidelines at the time the 2035 General Plan EIR was prepared. Nonetheless, this section corresponds with 2035 General Plan EIR Section 3.7, Hazard and Hazardous Material s. The project’s impacts, as currently proposed, are discussed below.

If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project:

a) Substantially impair an adopted emergency response plan or emergency evacuation plan?

Based on the 2035 General Plan EIR, the City’s relevant emergency response or emergency evacuation plans include the San Bernardino County Emergency Operations Plan and, to the extent that they mitigate potential disasters in the Planning Area, the Redlands HMP and the San Bernardino County MJHMP.

Physical development under the project, including new roadways, land uses, and increased densities, could create obstacles to the implementation of emergency response or evacuation plans adopted for the Planning Area. However, policies in the General Plan would eliminate or reduce these impacts by seeking to utilize the Redlands HMP, which is consistent with the MJHMP, as a guide for emergency planning, thus considering the area’s hazards and promoting means to reduce local risks, as well as to improve emergency access, ingress, and egress, emergency preparedness, and inter -jurisdictional cooperation throughout the Planning Area. Thus, the impact is less than significant.

The project proposes updates to the City’s Housing Element that are primarily limited to background information updates and policy updates in accordance with State law. The project does not propose rezoning; rather, it identifies future candidate sites that would be rezoned within three years of Housing Element adoption. Future rezoning activities necessary to fulfill the City’s RHNA would be subject to City review and approval and would be analyzed in accordance with CEQA requirements. As a result, none of the components of the project present a new use or intensify a use that was considered under the 2035 General Plan EIR. Therefore, the project would not result in new or substantially more severe environmental impacts pertaining to an adopted emergency response plan or emergency evacuation plan compared to the 2035 General Plan EIR.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

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Refer to Response 3.20(a).

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

Refer to Response 3.20(a).

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?

Refer to Response 3.20(a).

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: No Impact.

3.21 MANDATORY FINDINGS OF SIGNIFICANCE

Based on this Addendum, the project has not substantially changed in regard to the setting, design, impacts, and mitigation measures as described in the 2035 General Plan EIR . New circumstances or new information, including any new or revised environmental laws, regulations, or policies have not modified the impacts of the project.

a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

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The project would not result in impacts beyond those identified in the 2035 General Plan EIR in this regard and does not have the potential to degrade the environment, reduce the habitat of a fish or wildlife species, threaten plant or animal communities, reduce or restrict endangered plant or animal species or eliminate important examples of maj or periods of California history or prehistory with compliance with the 2035 General Plan EIR mitigation measures.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

b) Does the project have impacts that are individually limited, but cumulatively considerable ? (“Cumulatively considerable” means that the inc remental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

Given the nature and scope of the project, and in consideration of mitigation measures that are included in the 2035 General Plan EIR, the project would not involve impacts that are cumulatively considerable.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?

Construction-related activities are anticipated to have some relatively minor, temporary impacts which can be mitigated with implementation of measures included in the 2035 General Plan EIR. Furthermore, potential long -term (operational) impacts would be reduced to less than significant levels through implementation of required 2035 General Plan EIR mitigation measures. Thus, the project would not involve environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly.

Certified 2035 General Plan EIR Mitigation Measures: No mitigation measures were required in the 2035 General Plan EIR.

Mitigation Measures: No additional mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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4.0 REFERENCES

The following references were utilized for the preparation of this Addendum:

City of Redlands. 2017. City of Redlands General Plan 2035.

City of Redlands. 2017. City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report.

City of Redlands. Redlands Municipal Code. Continuously updated.

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RESOLUTION NO. 8292

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS APPROVING GENERAL PLAN AMENDMENT NO. 0144 FOR THE ADOPTION OF THE 6 TH CYCLE 2021-2029 HOUSING ELEMENT UPDATE AND

APPROVING THE ADDENDUM TO THE CERTIFIED ENVIRONMENTAL
IMPACT REPORT FOR THE 2035 GENERAL PLAN AND CLIMATE ACTION PLAN.

WHEREAS, Government Code section 65580et seq. requires cities to prepare a Housing Element as a component of each city’s General Plan and to revise it regularly on a schedule set forth by law; and

WHEREAS, the City of Redlands initiated an update to the Housing Element of the General Plan and prepared proposed revisions to the Housing Element for the 2021-2029 planning period (“6th Cycle 2021-2029 Housing Element”), which replaces the Housing Element that covered the period 2013
to 2021; and

WHEREAS, the 6th Cycle 2021-2029 Housing Element sets forth the housing policies for the City, will facilitate the preservation and development of housing, and will establish programs to accommodate the City’s share of the regional housing need in Southern California; and

WHEREAS, the 6th
Cycle 2021-2029 Housing Element complies with the requirements of State law; and

WHEREAS, in accordance with Government Code section 65583, the City finds that the proposed 6th Cycle 2021-2029 Housing Element complies with the duty to Affirmatively Further Fair Housing; and

WHEREAS, the City has been allocated 3,516 new housing units as its share of the Regional Housing Needs Assessment (“RHNA”) in Southern California; and

WHEREAS,
an extensive public outreach effort was conducted to obtain resident and citizen input into the Draft 6 th Cycle 2021-2029 Housing Element, including a citywide housing needs survey, individual stakeholder interviews, community meetings held on April 26 and May 13, 2021, Planning Commission study sessions held on April 13 and May 25, 2021, as well as a City Council study session held on June 29, 2021; and

WHEREAS,
the Draft 6 th Cycle 2021-2029 Housing Element was reviewed by the State Department of Housing and Community Development ( “HCD”) per Government Code section 65585(b), and has been revised to address comments from HCD; and

WHEREAS, on December 30, 2021, the Planning Division caused a public notice display advertisement concerning the Planning Commission public hearing to be published in a newspaper of

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general circulation in the City, in accordance with Redlands Municipal Code and applicable Government Code provisions; and

WHEREAS,
on January 11, 2022, the Planning Commission held a duly noticed public hearing on the Draft 6th Cycle 2021-2029 Housing Element and the addendum to the 2035 General Plan and Climate Action Plan EIR, and considered the staff ’s verbal and written reports, and the testimony and any written evidence submitted by the general public; and

WHEREAS, on January 11, 2022, the Planning Commission recommended to the City Council the adoption of the 6th Cycle 2021-2029 Housing Element Update and the related addendum to the 2035 General Plan and Climate Action Plan EIR; and

WHEREAS,
on January 20, 2021, the City Clerk caused a public notice display advertisement concerning the City Council public hearing for the 6 th Cycle 2021-2029 Housing Element Update to be published in a newspaper of general circulation in the City, in accordance within the
Redlands Municipal Code and applicable Government Code provisions; and

WHEREAS,
on February 1, 2022, the City Council held a duly noticed public hearing on the 6th Cycle 2021-2029 Housing Element Update and the related addendum to the 2035 General Plan and Climate Action Plan EIR, and considered the verbal and written staff reports, and the testimony and any written evidence submitted by the general public;

NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS AS FOLLOWS:

1. California Environmental Quality Act. An addendum to the City of Redlands 2035 General Plan and Climate Action Plan EIR is the appropriate environmental document for the 6th Cycle 2021- 2029 Housing Element Update. The 6th Cycle 2021-2029 Housing Element Update will necessitate future amendments to the General Plan Land Use Map as well as the Safety Element. However, the amendments will occur in the future and are not included as part of the scope of this project.

Therefore, in accordance with section 15164(a) of the State Guidelines implementing CEQA, none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred, and an addendum to the 2035 General Plan and Climate Action Plan EIR has been prepared
for the 6th Cycle 2021-2029 Housing Element Update.

2. Adoption of the 6th Cycle 2021-2029 Housing Element. The City Council herby adopts the 6th Cycle 2021-2029 Housing Element Update and the related addendum to the City of Redlands 2035 General Plan and Climate Action Plan EIR.

3 . Effective Date. This Resolution shall become effective upon adoption.

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ADOPTED, SIGNED AND APPROVED this 1st day of February, 2022.

Paul T. Barich, Mayor

ATTEST:

______________________________
Jeanne Donaldson,
City Clerk

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I, Jeanne Donaldson, City Clerk of the City of Redlands, do hereby certify that the foregoing Resolution was duly adopted by the City Council at a regular meeting thereof held on the 1st day of February, 2022, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

________________________
Jeanne Donaldson, City Clerk

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City Council/Successor Agency Meeting L. 1.

DATE: 02/01/2022
TO: Honorable Mayor and City Council Members
SUBJECT: Consideration of a letter of support for the University of Redlands' State budget request for University Village - A Model
Transit-Integrated Neighborhood in Redlands, CA (City Manager Duggan)
MOTION:

If the City Council concurs with staff's recommendation, the following motion is provided.

I move to authorize the issuance of a letter in support of the University of Redlands' State budget request for University Village - A Model Transit-Integrated Neighborhood in Redlands, CA.

RECOMMENDATION:

It is recommended that the City Council authorize the issuance of a letter in support of the University of Redlands' State budget request for University Village - A Model Transit-Integrated Neighborhood in Redlands, CA.

DISCUSSION:

The University of Redlands is currently seeking an $18 million state budget allocation for University Village -- a 30-acre transit-oriented, multi-use, mixed-income, sustainable community adjacent to the terminus station of the MetroLink commuter train system. The City recognizes that University Village will be an important economic driver for the City of Redlands while creating a model neighborhood of the future that is self-contained and socio-economically diverse. In consideration of this, staff is seeking City Council authority to issue a letter in support of the University of Redlands' State budget request for its University Village project.

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SUBMITTED BY:

Charles M. Duggan, Jr., City Manager

Attachments
Letter of Support-University of Redlands

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City of

REDLANDS
Incorporated 1888
35 Cajon Street, Redlands, CA 92373
909-798-7533
[email protected]
February 1, 2022
The Honorable James Ramos
California State Capitol
P.O. Box 942849
Sacramento, CA 94249-0040
Re: University of Redlands State Budget Request for University Village – a Model Transit- Integrated Neighborhood in Redlands, CA
Dear Assemblymember Ramos:

The City of Redlands wholeheartedly supports the University of Redlands’ request for an $18 million state budget allocation for University Village – a 30-acre transit-oriented, multi-use, mixed-income, sustainable community adjacent to the terminus station of the MetroLink commuter train system.

University Village will be an important economic driver for the City of Redlands. It will uplift our underserved population through an at-risk youth employment program, a commitment to local hiring goals, and construction contracts to be awarded to priority businesses including MBE and WBE.

While creating a model neighborhood of the future that is self-contained and socio- economically-diverse, University Village will also contribute new affordable housing that is greatly needed in our city.

We urge you to support this funding request for Fiscal Year 2022 that will benefit the entire City of Redlands.

Sincerely,
Paul T. Barich
Mayor
City of Redlands
Cc: City Council
Charles M. Duggan, Jr., City Manager

EDDIE TEJEDA
Mayor Pro Tem

DENISE DAVIS
Council Member

JENNA GUZMAN-LOWERY
Council Member

MICK GALLAGHER
Council Member
PAUL T. BARICH
Mayor

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City Council/Successor Agency Meeting L. 2.

DATE: 02/01/2022
TO: Honorable Mayor and City Council Members
SUBJECT: Consideration of a five-year lease agreement with Lenslock Inc. for body worn cameras in the amount of $478,065 (Police Chief Catren) MOTION(S):

If the City Council determines that staff’s recommendation is appropriate, the following motion is provided:

I move to approve the five-year lease agreement with LensLock Inc. for body worn cameras in the amount of $478,065.

RECOMMENDATION:

Staff recommends that Council approve the acceptance of the five-year lease agreement with Lenslock Inc. for body worn cameras in the amount of $478,065.00.

DISCUSSION:

Body-worn cameras (BWC) provide officers with a reliable and compact tool to systematically and automatically record their field observations and encounters.

They can be used to document interactions with victims, witnesses, and others during police-public encounters; arrests; and critical incidents. The Redlands City Council approved funding for body worn cameras for police department personnel in the FY 21/22 budget. Since then, the department has met with industry leaders and obtained three competitive quotes to implement a body worn camera program.

After examining the products and services of multiple BWC providers, staff identified LensLock of Poway, California as the best suited to its needs.

LensLock provides BWC services to law enforcement agencies in California, Nevada, Colorado, Utah, and Georgia. Founded in 2016 and led by technology innovators, LensLock has demonstrated that their products meet the goals and

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objectives that the Redlands Police Department has identified for its BWC system. Specifically, LensLock is the only company that provides a free, unlimited redaction service and integration with the department’s existing CAD/RMS. This service is the reason we seek procurement by sole source purchase pursuant to RMC 2.16.010. The proposal is to acquire 102 BWC units for our field personnel. The acquisition includes the supporting hardware, software, implementation, training, unlimited data plan, and software and database maintenance during the five-year service plan.

ALTERNATIVES:

Do not accept the five-year lease agreement with LensLock Inc. for body worn cameras in the amount of $478,065.

STRATEGIC PLAN:

Not applicable
SUBMITTED BY:

Christopher R. Catren, Chief of Police
RECOMMENDED BY:

Charles M. Duggan Jr., City Manager
REVIEWED BY:

Daniel J. McHugh, City Attorney
Janice McConnell, Assistant City Manager
Danielle Garcia, Management Services/Finance Director
Dana Abramovitz-Daniel, Procurement Manager
PREPARED BY:

Sean Flynn, Sergeant
Fiscal Impact
Fiscal Year: 2021-22
Revenue Generating: N
Appropriation Required Y/N: N
Amount: $95,613.00
Budgeted Y/N: Y
Account No.: 1012028706
Discussion:

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The first year cost of the BWC system under the five year lease program is $95,613 which is within the established budget for FY 2021/22. Subsequent years will be requested during the budgeting process.

Attachments
LensLock Business Proposal
Sole Source Form
LensLock Lease Agreement

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LensLock Regional Sales Manager

Sean O’Grady
949-690-6552
[email protected]

13125 Danielson St. Suite 112
Poway, CA 92064
U.S.A.

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ATTENTION : SHIP TO:

Chief Chris Catren
Redlands Police Department
1270 W Park Ave.,
Redlands, CA 92373
Customer ID #21 -555

Annual Total

QTY DESCRIPTION UNIT PRICE ANNUAL COST
80 Gen 12 Body Worn Camera Service – UNLIMITED Data Plan $1,099.00 $87,920.00 22 Gen 12 Body Worn Camera Service – UNLIMITED Data Plan $1,099.00 included

85 Holster Bluetooth Integration Devices $199.00 included 60 Bluetooth Integration Technology System $299.00 included 1 CAD Integration with Spillman $28,985.00 included
1 Unlimited Outsourced LensLock Redaction included

1 On-Site Implementation & Training Fee – One-Time Fee $1,895.00 included 1 Shipping & Handling Fees – One-Time Fee $1,295.00 included 1 Software & Database Maintenance Fee – Annual Fee $495.00 included

SUBTOTAL $87,920.00
SALES TAX ( 8.75%) $7,693.00
ANNUAL TOTAL $95,613.00

Thank you SINCERELY for your business!
Important Note : Please be informed that pricing integrity is very important to our entire company including our Board of Directors, employees, and especially our valued customer base. As such, it is our corpor ate goal to charge all customers the exact same price of $ 1,099/BWC/Year through March 31st, 2022.

Proposal Number: #21-555
Proposal Valid for 30 days
Services: Body Worn Camera Svc
Payment Terms: KS State Bank
Length of Service: 60 Months
Start Date: December 28, 2021

SALES REPRESENTATIVE
Sean O’Grady
Regional Manager
Phone: 949 -690-6552
Email: [email protected]

Sgt. Sean Flynn
Issued: December 7th , 2021

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ATTENTION : SHIP TO :

Chief Chris Catren
Redlands Police Department
1270 W Park Ave.,
Redlands, CA 92373
Customer ID #21 -555

5 Year Total
QTY DESCRIPTION UNIT PRICE 5 YEAR COST
80 Gen 12 Body Worn Camera Service – UNLIMITED Data Plan $1,099.00 $439,600.00 22 Gen 12 Body Worn Camera Service – UNLIMITED Data Plan $1,099.00 included

85 Holster Bluetooth Integration Devices $199.00 included 60 Bluetooth Integration Technology System $299.00 included 1 CAD Integration with Spillman $28,985.00 included
1 Unlimited Outsourced LensLock Redaction included

1 On-Site Implementation & Training Fee – One-Time Fee $1,895.00 included 1 Shipping & Handling Fees – One-Time Fee $1,295.00 included 5 Software & Database Maintenance Fee – Annual Fee $495.00 included

SUBTOTAL $439,600.00
SALES TAX (8.75%) $38,465.00
5Y TOTAL $478,065.00

https://www.lenslock.com/terms -of-use

PAYMENT OPTIONS
Monthly Payment : *$7,967.75
Quarterly Payment: *$23,903.25
Annual Payment: *$95,613.00
Thank you SINCERELY for your business!
Important Note : Please be informed that pricing integrity is very important to our entire company including our Board of Directors, employees, and especially our valued customer base. As such, it is our corporate goal to charge all customers the exact same price of $ 1,099/BWC/Year March 31 st, 2022.

Proposal Number: #21 -555
Proposal Valid for 30 days
Services: Body Worn Camera Svc
Payment Terms: KS State Bank
Length of Service: 60 Months
Start Date: December 28, 2021

SALES REPRESENTATIVE
Sean O’Grady
Regional Manager
Phone: 949 -690-6552
Email: [email protected]
Sgt. Sean Flynn
Issued: December 7th , 2021

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CLIENT: Redland Police Department, CA

Chris Catren - Chief
_____________________________________________
(Name - Title)

_____________________________________________
(Signature)

_____________________________________________
(Date)

VENDOR: LensLock, In c.

Andrew Lynch – Vice President of Sales
_____________________________________________
(Name - Title)

_____________________________________________
(Signature)

____________________________________________
(Date)

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Sole Source/ Single Source/ Standardization Form
For procurement of supplies, equipment and services valued at $5,000 and over NOTE: Every question must be answered with appropriate documentation attached; incomplete forms will be immediately rejected by Purchasing.

Date:_______________________
TO: Purchasing Division
FROM: ________________________________
Purchase Requisition #
___________________
Estimated Total Cost: $_________________
Proposed Vendor: ______________________
Request Term: _________________
This form must accompany the purchase document whenever an exception to the competitive process is requested. Requests for goods and/or services from a specific vendor or limited to a s
pecific brand, where substitutes to the recommended vendor or brand are unacceptable, must be
accompanied by a written justification explaining the circumstances that make alternatives un
acceptable.

The City M anager w ill de termine whether t he justification is appropriate. R equ ests for exception must be supported by factual statements tha t will pass an audit.

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EXCEPTION TO BIDDING AND DISCLOSURE STATEMENT Page
Rev 1.31.19
2 INSTRUCTIONS

1. P
lease check all applicable categories (a. through i.) below and provide additional information where indicated.
a. The requested product is an integral repair part or accessory c ompatible with existing equipment.

Existing Equipment:

Manufacturer/Model Number:

Age:

Current Estimated Value:
b. The requested product has unique design/performance specifications or quality r
equirements that are not available in comparable products. c. I have standardized the requested product and the use of another brand/model would require considerable time and funding to evaluate.
d. T he requested product is one in which I (and/or my staff) have specialized training and/or extensive expertise. Retraining would incur substantial cost in time and/or funding.
e. The requested product is used or demonstration equipment available at a lower-than- new cost.
f. Repair/Maintenance service is available only from manufacturer or designated service representative.
g. Upgrade to or enhancement of existing software is available only from manufacturer. h. Service proposed by vendor is unique; therefore, competitive bids are not available or applicable.
i. Other factors (provide detailed explanation in #2 below).

2. Provide a detailed explanation and pertinent documentation for each category checked in item 1 above. Attach additional sheets if necessary:

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EXCEPTION TO BIDDING AND DISCLOSURE STATEMENT Page
Rev 1.31.19
3 3. Was an evaluation of other equipment, products, or services performed? Yes No
If yes, please explain the type of evaluation performed and provide all supporting documentation:

4. List
below the name of each individual who was involved in the evaluation, if conducted, and in making the recommendation to procure this product or service. Attach additional information, if necessary.

5. Explain what action(s) the department would take if the sole/single source services were no longer available

6. I certify that the above information is accurate to the best of my knowledge, and a signed copy of this document will be kept on file and available for audit in my department _________________________________________________________ Pr
epared by Date _________________________________________________________ Dep
artment Director Date Purch
asing Approvals
______________________________________________________
P
urchasing Agent Approval Date
_______________________________________________________

City Manager Approval Date

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CITY O

F REDLANDS, CALIFORNIA
DOCUM

ENTATION INSTRUCTIONS
The
instructions listed below should be followed when completing the enclosed documentation. Please sign in blue ink and print on single sided pa
per only. Documentation completed improperly will delay funding. If you have any questions regarding the Conditions to Funding, instructions or th
e documentation, please call us at (877) 587-4054.

I. Attached
Documentation

1. Government Ob
ligation Contract
 An authorized individual that is with the Obligor should sign on the first space provided. All original signatures are required for fu
nding.

2. Exh
ibit A – Description of Equipment
 Review equipment description. Complete serial number/VIN if applicable.  List the location where the equipment will be located after delivery/installation.

3. Exhibit B – Payment Schedule
 Sign and print name and title

4. Exhibit C - Certificate of Acceptance
 Sign and print name and title

5. Exhibit D - Obligor Resolution
 Type in the date of the meeting in which the purchase was approved.  Print or type the name and title of the individual(s) who is authorized to execute the Contract.  The secretary, chairman or other authorized board member of the Obligor must sign the Resolution where indicated.  A second authorized individual that is with the Obligor should attest the Resolution where indicated.

6. Exhibit E - Bank Qualified Certificate
 Sign and print name and title

7. Insurance Requirements
 Complete insurance company contact information where indicated.

8. Debit Authorization – (Preferred)
 Complete form and attach a voided check

9. 8038G IRS Form
 Please read 8038 Review Form
 In Box 2, type Employer Identification Number
 Sign and print name and title

II. Additional D
ocumentation Required

1. F
irst payment check as stated on attached invoice

2. Insurance certificate as stated on the Insurance Requirements Form

3. Vendor Invoice for the amount to finance listing applicable SN/VIN, down payment, trade, etc.

4. Signed and completed Credit Application

III
. Condition to Funding
If, fo
r any reason: (i) the required documentation is not returned by April 7, 2022, is incomplete, or has unresolved issues relating thereto, or (ii) on, or prior to the return of the documentation, there is a change of circumstance, including but not limited to changes in the federal corporate income tax rate or reducing/capping the tax-exempt interest benefit, which adversely affects the expectations, rights or security of the Obligee or its assignees; then Obligee or its assignees reserve the right to withdraw/void its offer to fund this transaction in its entirety. Neither KS StateBank nor Baystone Government Finance is acting as an advisor to the municipal entity/obligated person and neither owes a fiduciary duty pursuant to Section 15B of the Exchange Act of 1934.

All documentation should be returned to:

KS State
Bank
2627 KFB Plaza, Suite 202E
Manhattan, Kansas 66503

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CA SF
P Abatement Firm Term BQ

GOVERNM

ENT OBLIGATION CONTRACT
O
bligor Obligee
City of Redlands, California KS StateBank
35 Cajon Street 1010 Westloop, P.O. Box 69
Redlands, California 92373 Manhattan, KS 66505-0069
Da
ted as of December 31, 2021
Th
is Government Obligation Contract dated as of the date listed above is between Obligee and Obligor listed directly above. Obligee desires to finance the purchase of the Equipment described in Exhibit A to Obligor and Obligor desires to have Obligee finance the purchase of the Equipment subject to the terms and conditions of this Contract which are set forth below.

I. Definitions
Section 1.01 Definitions. The following terms will have the meanings indicated below unless the context clearly requires otherwise:
“Ad
ditional Schedule” refers to the proper execution of additional schedules to Exhibit A and Exhibit B, as well as other exhibits or documents that may be required by the Obligee all of which relate to the financing of additional Equipment.
“Budget Year” means the Obligor's fiscal year.
“Commencement Date” is the date when Obligor's obligation to pay Contract Payments begins. “Contract” means this Government Obligation Contract and all Exhibits attached hereto, all addenda, modifications, schedules, refinancings, guarantees and all documents relied upon by Obligee prior to execution of this Contract.
“Contract Payments” means the payments Obligor is required to make under this Contract as set forth on Exhibit B. “Contract Term” means the Original Term and all Renewal Terms. “Exhibit” includes the Exhibits attached hereto, and any “Additional Schedule”, whether now existing or subsequently created. “Equipment” means all of the items of Equipment listed on Exhibit A and any Additional Schedule, whether now existing or subsequently created, and all replacements, restorations, modifications and improvements.
“Government” as used in the title hereof means a State or a political subdivision of the State within the meaning of Section 103(a) of the Internal Revenue Code of 1986, as amended (“Code”), or a constituted authority or district authorized to issue obligations on behalf of the State or political subdivision of the State within the meaning of Treasury Regulation 1.103-1(b), or a qualified volunteer fire company within the meaning of section 150(e)(1) of the Code. “Obligee” means the entity originally listed above as Obligee or any of its assignees. “Obligor” means the entity listed above as Obligor and which is financing the Equipment through Obligee under the provisions of this Contract. “Original Term” means the period from the Commencement Date until the end of the Budget Year of Obligor. “Renewal Term” means the annual term which begins at the end of the Original Term and which is simultaneous with Obligor's Budget Year and each succeeding Budget Year for the number of Budget Years necessary to comprise the Contract Term. “State” means the state which Obligor is located.

II. Obligor Warranties
Section 2.01 Obligor represents, warrants and covenants as follows for the benefit of Obligee or its assignees:
(a
) Obligor is an “issuer of tax exempt obligations” because Obligor is the State or a political subdivision of the State within the meaning of Section 103(a) of the Internal Revenue Code of 1986, as amended, (the “Code”) or because Obligor is a constituted authority or district authorized to issue obligations on behalf of the State or political subdivision of the State within the meaning of Treasury Regulation 1.103-1(b), or a qualified volunteer fire company within the meaning of section 150(e)(1) of the Code. (b) Obligor has complied with any requirement for a referendum and/or competitive bidding. (c) Obligor has complied with all statutory laws and regulations that may be applicable to the execution of this Contract; Obligor, and its officer executing this Contract, are authorized under the Constitution and laws of the State to enter into this Contract and have used and followed all proper procedures of its governing body in executing and delivering this Contract. The officer of Obligor executing this Contract has the authority to execute and deliver this Contract. This Contract constitutes a legal, valid, binding and enforceable obligation of the Obligor in accordance with its terms.
(d) Obligor shall use the Equipment only for essential, traditional government purposes. (e) Should the IRS disallow the tax-exempt status of the interest portion of the Contract Payments as a result of the failure of the Obligor to use the Equipment for governmental purposes, or should the Obligor cease to be an issuer of tax exempt obligations, or should the obligation of Obligor created under this Contract cease to be a tax exempt obligation for any reason, then Obligor shall be required to pay additional sums to the Obligee or its assignees so as to bring the after tax yield on this Contract to the same level as the Obligee or its assignees would attain if the transaction continued to be tax-exempt. (f) Obligor will submit to the Secretary of the Treasury an information reporting statement as required by the Code. (g) Upon request by Obligee, Obligor will provide Obligee with current financial statements, reports, budgets or other relevant fiscal information. (h) Obligor shall retain the Equipment free of any hazardous substances as defined in the Comprehensive Environmental Response, Compensation and Liability Act, 42 U.S.C. 9601 et. seq. as amended and supplemented.
(i) Obligor hereby warrants the General Fund of the Obligor is the primary source of funds or a backup source of funds from which the Contract Payments will be made. (j) Obligor presently intends to continue this Contract for the Original Term and all Renewal Terms as set forth on Exhibit B hereto. The official of Obligor responsible for budget preparation will include in the budget request for each Budget Year the Contract Payments to become due in such Budget Year, and will use all reasonable and lawful means available to secure the appropriation of money for such Budget Year sufficient to pay the Contract Payments coming due therein. Obligor reasonably believes that moneys can and will lawfully be appropriated and made available for this purpose.
(k) Obligor has selected both the Equipment and the vendor(s) from whom the Equipment is to be purchased upon its own judgment and without reliance on any manufacturer, merchant, vendor or distributor, or agent thereof, of such equipment to the public. (l) Obligor owns the Equipment and any additional collateral free and clear of any liens, and Obligor has not and will not, during the Contract Term, create, permit, incur or assume any levies, liens or encumbrances of any kind with respect to the Equipment or any additional collateral except those created by this Contract. (m) Obligor warrants, as applicable, the purchase of any telecommunications and video surveillance services or equipment financed hereunder complies with 2 CFR § 200.216 and 2 CFR § 200.471.
(n) Obligor finds and determines that the amount of the Contract Payments set forth in Exhibit B are equal to the fair rental value of the related Equipment during the respective Budget Year of Obligor in which such Contract Payments are made. (o) The Equipment will have a useful life that is substantially in excess of the Contract Term.

Section 2.02 Escrow Agreement. In the event both Obligee and Obligor mutually agree to utilize an Escrow Account, then immediately following the execution and delivery of this Contract, O
bligee and Obligor agree to execute and deliver and to cause Escrow Agent to execute and deliver the Escrow Agreement. This Contract shall take effect only upon execution and delivery of the Escrow Agreement by the parties thereto. Obligee shall deposit or cause to be deposited with the Escrow Agent for credit to the Equipment Acquisition Fund the sum of N/A, which shall be held, invested and disbursed in accordance with the Escrow Agreement.

III. Acquisition of Equipment, Contract Payments and the Purchase Option Price Section 3.01 Acquisition and Acceptance. Obligor shall be solely responsible for the ordering of the Equipment and for the delivery and installation of the Equipment. Execution of the Certificate of
Acceptance or, alternatively, Payment Request and Equipment Acceptance Form, by a duly authorized representative of Obligor, shall constitute acceptance of the Equipment on behalf of the Obligor.

Section 3.02 Contract Payments. Obligor shall pay Contract Payments exclusively to Obligee or its assignees in lawful, legally available money of the United States of America. The Contract Paym
ents shall be sent to the location specified by the Obligee or its assignees. The Contract Payments, payable without notice or demand, are due as set forth on Exhibit B. Obligee shall have the option to charge interest at the highest lawful rate on any Contract Payment received later than the due date for the number of days that the Contract Payment(s) were late, plus any additional accrual on the outstanding balance for the number of days that the Contract Payment(s) were late. Obligee shall also have the option, on monthly payments only, to charge a late

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fee o
f up to 10% of the monthly Contract Payment that is past due. Furthermore, Obligor agrees to pay any fees associated with the use of a payment system other than check, wire transfer, or ACH. Once all amounts due Obligee hereunder have been received, Obligee will release any and all of its rights, title and interest in the Equipment.

Section 3.03 Abatement. During any period in which, by reason of material damage or destruction or taking under the power of eminent domain (or sale to any entity threatening the use of such
power) or material title defect with respect to the Equipment, there is substantial interference with the use and possession by Obligor of the Equipment, the Contract Payments due under the Contract with respect to the Equipment shall be abated proportionately in whole or in part. Obligor shall immediately notify Obligee upon the occurrence of any event causing substantial interference with Obligor's use and possession of the Equipment and such notice shall be provided prior to the abatement of any Contract Payments. The amount of abatement shall be such that the remaining rental obligation represents fair consideration for Obligor’s use and possession of the Equipment, or portions thereof, not substantially interfered with, and end on the earlier of the date on which the use and possession of the Equipment is restored to Obligor or the date on which Obligor uses the Net Proceeds of insurance or a condemnation awards to pay the Contract Payments or the applicable Purchase Option Price. In the event of any such interference, this Contract and the related abatement agreement shall continue in full force and effect. To the extent allowed by law, Obligor waives the benefits of Civil Code Section 1932 and any and all other rights to terminate this Contract and the related Abatement agreement by virtue of any interference with the use and possession of any Equipment, although such waiver shall not constitute a waiver of abatement of Contract Payments, as set forth in this section.

Section 3.04 Contract Payments Unconditional. Except as provided in Section 3.03, the obligation of Obligor to make Contract Payments or any other payments required hereunder shall be absolute
and unconditional in all events. NOTWITHSTANDING ANY DISPUTE BETWEEN OBLIGOR AND OBLIGEE OR BETWEEN OBLIGOR AND VENDOR OR ANY OTHER PERSON, OBLIGOR SHALL

MAKE ALL CONTRACT PAYMENTS AND OTHER PAYMENTS REQUIRED HEREUNDER WHEN DUE AND SHALL NOT WITHHOLD ANY CONTRACT PAYMENT OR OTHER PAYMENT PENDING FINAL

RESOLUTION OF SUCH DISPUTE NOR SHALL OBLIGOR ASSERT ANY RIGHT OF SET-OFF OR COUNTERCLAIM AGAINST ITS OBLIGATION TO MAKE CONTRACT PAYMENTS OR OTHER PAYMENTS REQUIRED HEREUNDER. Obligor's obligation to make Contract Payments or other payments shall not be abated on account of failure of the Equipment to perform as desired or obsolescence of the Equipment and shall not be abated through accident or unforeseen circumstances except as provided in Section 3.03.

Section 3.05 Purchase Option Price. Upon thirty (30) days written notice, Obligor shall have the option to pay, in addition to the Contract Payment, the corresponding Purchase Option Price w
hich is listed on the same line on Exhibit B. This option is only available to the Obligor on the Contract Payment date and no partial prepayments are allowed. If Obligor chooses this option and pays the Purchase Option Price to Obligee then Obligee will transfer any and all of its rights, title and interest in the Equipment to Obligor.

Section 3.06 Contract Term. The Contract Term shall be the Original Term and all Renewal Terms until all the Contract Payments are paid as set forth on Exhibit B except as provided under Sec
tion 9.01 below.

Section 3.07 Disclaimer of Warranties. OBLIGEE MAKES NO WARRANTY OR REPRESENTATION, EITHER EXPRESS OR IMPLIED, AS TO THE VALUE, DESIGN, CONDITION, MERCHANTABILITY, FI
TNESS FOR PARTICULAR PURPOSE OR ANY OTHER WARRANTY WITH RESPECT TO THE EQUIPMENT. OBLIGEE IS NOT A MANUFACTURER, SELLER, VENDOR OR DISTRIBUTOR, OR AGENT THEREOF, OF SUCH EQUIPMENT; NOR IS OBLIGEE A MERCHANT OR IN THE BUSINESS OF DISTRIBUTING SUCH EQUIPMENT TO THE PUBLIC. OBLIGEE SHALL NOT BE LIABLE FOR ANY INCIDENTAL, INDIRECT, SPECIAL OR CONSEQUENTIAL DAMAGE ARISING OUT OF THE INSTALLATION, OPERATION, POSSESSION, STORAGE OR USE OF THE EQUIPMENT BY OBLIGOR.

IV. Appropriation of Money
Section 4.01 Appropriation. The person or entity in charge of preparing Obligor's budget will include in the budget request for each Budget Year the Contract Payments to become due in such Bud
get Year with respect to the Contract, and will use all reasonable and lawful means available to secure the appropriation of money for such Budget Year sufficient to pay all such Contract Payments coming due therein. The covenants on the part of Obligor contained in this Contract, including the covenant to budget and appropriate amounts necessary to make Contract Payments, shall be deemed to be duties imposed by law, and it shall be the duty of each and every public official of Obligor to take such action and do such things as required by law in the performance of the official duty of such officials to enable Obligor to carry out and perform the covenants and contracts in this Contract. This Contract and each abatement agreement represent a firm contract and not a non-appropriation contract.

V. Insurance, Damage, Insufficiency of Proceeds
Section 5.01 Insurance. Obligor shall maintain both casualty insurance, liability insurance and rental interruption and loss of use and occupancy insurance at its own expense with respect to th
e Equipment. Obligor shall be solely responsible for selecting the insurer(s) and for making all premium payments and ensuring that all policies are continuously kept in effect during the period when Obligor is required to make Contract Payments. Obligor shall provide Obligee with a Certificate of Insurance which lists the Obligee and/or assigns as a loss payee and an additional insured on the policies with respect to the Equipment.
(a) Obligor shall insure the Equipment against any loss or damage by fire and all other risks covered by the standard extended coverage endorsement then in use in the State and any other risks reasonably required by Obligee in an amount at least equal to the then applicable Purchase Option Price of the Equipment. Alternatively, Obligor may insure the Equipment under a blanket insurance policy or policies.
(b) The liability insurance shall insure Obligee from liability and property damage in any form and amount satisfactory to Obligee. (c) Obligor shall maintain or cause to be maintained at its expense throughout the Contract, rental interruption insurance against loss of use of the Equipment or portions thereof with coverage equal to the maximum total Contract Payments payable under the Contract by Obligor for any consecutive 24-month period. The policy shall insure against abatement of Contract Payments payable by Obligor resulting from Obligor's loss of use of the Equipment or any substantial portion thereof and caused by any and all perils, either insured or uninsured, including acts of God. The Net Proceeds of such insurance shall be payable to Obligee in amounts proportionate to Obligor's loss of use of the Equipment and the corresponding rental abatement, if any, and shall supplement Contract Payments made by Obligor, if any, during the period in which Obligor's use and occupancy of the Equipment is being restored in sufficient amounts to make Obligee whole.
(d) Obligor may self-insure against the casualty risks and liability risks described above. If Obligor chooses this option, Obligor must furnish Obligee with a certificate and/or other documents which evidences such coverage.
(e) All insurance policies issued or affected by this Section shall be so written or endorsed such that the Obligee and its assignees are named additional insureds and loss payees and that all losses are payable to Obligor and Obligee or its assignees as their interests may appear. Each policy issued or affected by this Section shall contain a provision that the insurance company shall not cancel or materially modify the policy without first giving thirty (30) days advance notice to Obligee or its assignees. Obligor shall furnish to Obligee certificates evidencing such coverage throughout the Contract Term.

Section 5.02 Damage to or Destruction of Equipment. Obligor assumes the risk of loss or damage to the Equipment. If the Equipment or any portion thereof is lost, stolen, damaged, or d
estroyed by fire or other casualty, Obligor will immediately report all such losses to all possible insurers and take the proper procedures to obtain all insurance proceeds. At the option of Obligee, Obligor shall either (1) apply the Net Proceeds to replace, repair or restore the Equipment or (2) apply the Net Proceeds to the applicable Purchase Option Price. For purposes of this Section and Section 5.03, the term Net Proceeds shall mean the amount of insurance proceeds collected from all applicable insurance policies after deducting all expenses incurred in the collection thereof.

Section 5.03 Insufficiency of Net Proceeds. If there are no Net Proceeds for whatever reason or if the Net Proceeds are insufficient to pay in full the cost of any replacement, repair, restoration, mod
ification or improvement of the Equipment, then Obligor shall, at the option of Obligee, either (1) complete such replacement, repair, restoration, modification or improvement and pay any costs thereof in excess of the amount of the Net Proceeds or (2) apply the Net Proceeds to the Purchase Option Price and pay the deficiency, if any, to the Obligee.

Section 5.04 Obligor Negligence. Obligor assumes all risks and liabilities, whether or not covered by insurance, for loss or damage to the Equipment and for injury to or death of any person or d
amage to any property whether such injury or death be with respect to agents or employees of Obligor or of third parties, and whether such property damage be to Obligor’s property or the property of others (including, without limitation, liabilities for loss or damage related to the release or threatened release of hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act, the Resource Conservation and Recovery Act or similar or successor law or any State or local equivalent now existing or hereinafter enacted which in any manner arise out of or are incident to any possession, use, operation, condition or storage of any Equipment by Obligor), which is proximately caused by the negligent conduct of Obligor, its officers, employees and agents.

Section 5.05 Reimbursement. Obligor hereby assumes responsibility for and agrees to reimburse Obligee for all liabilities, obligations, losses, damages, penalties, claims, actions, costs and exp
enses (including reasonable attorneys’ fees) of whatsoever kind and nature, imposed on, incurred by or asserted against Obligee that in any way relate to or arise out of a claim, suit or proceeding, based in whole or in part upon the negligent conduct of Obligor, its officers, employees and agents, or arose out of installation, operation, possession, storage or use of any item of the Equipment, to the maximum extent permitted by law.

VI. Title and Security Interest
Section 6.01 Title. Title to the Equipment shall vest in Obligor when Obligor acquires and accepts the Equipment. Title to the Equipment will automatically transfer to the Obligee in the event O
bligor defaults under Section 9.01. In such event, Obligor shall execute and deliver to Obligee such documents as Obligee may request to evidence the passage of legal title to the Equipment to Obligee.

Section 6.02 Security Interest. To secure the payment of all Obligor’s obligations under this Contract, as well as all other obligations, debts and liabilities, plus interest thereon, whether now exist
ing or subsequently created, Obligor hereby grants to Obligee a security interest under the Uniform Commercial Code constituting a first lien on the Equipment described more fully on Exhibit A. Furthermore, Obligor agrees that any other collateral securing any other obligation(s) to Obligee, whether offered prior to or subsequent hereto, also secures this obligation. The security interest established by this section includes not only all additions, attachments, repairs and replacements to the Equipment but also all proceeds therefrom. Obligor authorizes Obligee to prepare and record any Financing Statement required under the Uniform Commercial Code to perfect the security interest created hereunder. Obligor agrees that any Equipment listed on Exhibit A is and will remain personal property and will not be considered a fixture even if attached to real property.

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VII. Ass
ignment
Section 7.01 Assignment by Obligee. All of Obligee's rights, title and/or interest in and to this Contract may be assigned and reassigned in whole or in part to one or more assignees or sub- ass
ignees by Obligee at any time without the consent of Obligor. No such assignment shall be effective as against Obligor until the assignor shall have filed with Obligor written notice of assignment identifying the assignee. Obligor shall pay all Contract Payments due hereunder relating to such Equipment to or at the direction of Obligee or the assignee named in the notice of assignment. Obligor shall keep a complete and accurate record of all such assignments.

Section 7.02 Assignment by Obligor. None of Obligor's right, title and interest under this Contract and in the Equipment may be assigned by Obligor unless Obligee approves of such assignment in
writing before such assignment occurs and only after Obligor first obtains an opinion from nationally recognized counsel stating that such assignment will not jeopardize the tax-exempt status of the obligation.

VIII. Maintenance of Equipment
Section 8.01 Equipment. Obligor shall keep the Equipment in good repair and working order, and as required by manufacturer’s and warranty specifications. If Equipment consists of copiers, O
bligor is required to enter into a copier maintenance/service agreement. Obligee shall have no obligation to inspect, test, service, maintain, repair or make improvements or additions to the Equipment under any circumstances. Obligor will be liable for all damage to the Equipment, other than normal wear and tear, caused by Obligor, its employees or its agents. Obligor shall pay for and obtain all permits, licenses and taxes related to the ownership, installation, operation, possession, storage or use of the Equipment. If any fees are required to be paid by the California Debt & Investment Advisory Commission then such fees shall be paid directly from the Obligor to the California Debt & Investment Advisory Commission. If the Equipment includes any titled vehicle(s), then Obligor is responsible for obtaining such title(s) from the State and also for ensuring that Obligee is listed as First Lienholder on all of the title(s). Obligor shall not use the Equipment to haul, convey or transport hazardous waste as defined in the Resource Conservation and Recovery Act, 42 U.S.C. 6901 et. seq. Obligor agrees that Obligee or its Assignee may execute any additional documents including financing statements, affidavits, notices, and similar instruments, for and on behalf of Obligor which Obligee deems necessary or appropriate to protect Obligee’s interest in the Equipment and in this Contract. Obligor shall allow Obligee to examine and inspect the Equipment at all reasonable times.

IX. Default
Section 9.01 Events of Default defined. The following events shall constitute an “Event of Default” under this Contract:
(a
) Failure by Obligor to pay any Contract Payment listed on Exhibit B for fifteen (15) days after such payment is due according to the Payment Date listed on Exhibit B, other than by reason of abatement as provided under Section 3.03.
(b) Failure by Obligor to maintain any of the insurances as required under section 5.01. (c) Failure to pay any other payment required to be paid under this Contract at the time specified herein and a continuation of said failure for a period of fifteen (15) days after written notice by Obligee that such payment must be made. If Obligor continues to fail to pay any payment after such period, then Obligee may, but will not be obligated to, make such payments and charge Obligor for all costs incurred plus interest at the highest lawful rate. (d) Failure by Obligor to observe and perform any warranty, covenant, condition, promise or duty under this Contract for a period of thirty (30) days after written notice specifying such failure is given to Obligor by Obligee, unless Obligee agrees in writing to an extension of time. Obligee will not unreasonably withhold its consent to an extension of time if corrective action is instituted by Obligor. Subsection (c) does not apply to Contract Payments and other payments discussed above. (e) Any statement, material omission, representation or warranty made by Obligor in or pursuant to this Contract which proves to be false, incorrect or misleading on the date when made regardless of Obligor's intent and which materially adversely affects the rights or security of Obligee under this Contract. (f) Any provision of this Contract which ceases to be valid for whatever reason and the loss of such provision would materially adversely affect the rights or security of Obligee. (g) Obligor admits in writing its inability to pay its obligations. (h) Obligor defaults on one or more of its other obligations. (i) Obligor becomes insolvent, is unable to pay its debts as they become due, makes an assignment for the benefit of creditors, applies for or consents to the appointment of a receiver, trustee, conservator, custodian, or liquidator of Obligor, or all or substantially all of its assets, or a petition for relief is filed by Obligor under federal bankruptcy, insolvency or similar laws, or is filed against Obligor and is not dismissed within thirty (30) days thereafter.

Section 9.02 Remedies on Default. Whenever any Event of Default exists, Obligee shall have the right to take one or any combination of the following remedial steps:
(a
) Obligee, with or without terminating this Contract, may collect each installment of Contract Payments as it becomes due and payable with respect to the Equipment in accordance with Exhibit B to the end of the Contract Term.
(b) Obligee, with or without terminating this Contract, may repossess any or all of the Equipment by giving Obligor written notice to deliver the Equipment to the location designated by Obligee. In the event Obligor fails to do so within ten (10) days after receipt of such notice, Obligee may enter upon Obligor's premises where the Equipment is kept and take possession of the Equipment and charge Obligor for costs incurred in repossessing the Equipment, including reasonable attorneys' fees. Obligor hereby expressly waives any damages occasioned by such repossession. If the Equipment or any portion of it has been destroyed or damaged beyond repair, Obligor shall pay the applicable Purchase Option Price of the damaged or destroyed Equipment as set forth in the Contract Payment Schedule. Notwithstanding the fact that Obligee has taken possession of the Equipment, Obligor shall continue to be responsible for the Contract Payments with respect thereto as and when such Contract Payments become or would have become due and payable. (c) If Obligee, in its discretion, takes possession and disposes of the Equipment or any portion thereof, Obligee shall apply the proceeds of any such disposition to pay the following items in the following order: (i) all costs (including, but not limited to, attorneys' fees) incurred in securing possession of the Equipment; (ii) all expenses incurred in completing the disposition; (iii) any sales or transfer taxes; and (iv) the balance of any Contract Payments with respect thereto as and when such Contract Payment would become due and payable. Any disposition proceeds remaining after the requirements of clauses (i), (ii), (iii), (iv) have been met shall be paid to Obligor. (d) By action pursuant to the California Code of Civil Procedure, or as otherwise provided by law, obtain the issuance of a writ of mandamus enforcing, for the entire balance due, or as it becomes due, under Exhibit B of the Contract, the duty of Obligor to appropriate and take all other administrative steps necessary for the making of all Contract Payments. (e) Obligee may take any other remedy available at law or in equity with respect to an Event of Default, including (without limitation) those requiring Obligor to perform any of its obligations under this Contract or to pay any moneys due and payable to Obligee, provided Obligee shall have no right to accelerate Contract Payments or otherwise declare any Contract Payments not then in default to be immediately due and payable.

Section 9.03 No Remedy Exclusive. No remedy herein conferred upon or reserved to Obligee is intended to be exclusive and every such remedy shall be cumulative and shall be in addition to ever
y other remedy given under this Contract now or hereafter existing at law or in equity. No delay or omission to exercise any right or power accruing upon any default shall impair any such right or shall be construed to be a waiver thereof.

Section 9.04 Return of Equipment and Storage.
(a
) Surrender: The Obligor shall, at its own expense, surrender the Equipment, any additional collateral and all required documentation to evidence transfer of title from Obligor to the Obligee in the event of a default by delivering the Equipment and any additional collateral to the Obligee to a location accessible by common carrier and designated by Obligee. In the case that any of the Equipment and any additional collateral consists of software, Obligor shall destroy all intangible items constituting such software and shall deliver to Obligee all tangible items constituting such software. At Obligee’s request, Obligor shall also certify in a form acceptable to Obligee that Obligor has complied with the above software return provisions and that they will immediately cease using the software and that they shall permit Obligee and/or the vendor of the software to inspect Obligor’s locations to verify compliance with the terms hereto.
(b) Delivery: The Equipment and any additional collateral shall be delivered to the location designated by the Obligee by a common carrier unless the Obligee agrees in writing that a common carrier is not needed. When the Equipment and any additional collateral is delivered into the custody of a common carrier, the Obligor shall arrange for the shipping of the item and its insurance in transit in accordance with the Obligee’s instructions and at the Obligor’s sole expense. Obligor at its expense shall completely sever and disconnect the Equipment and any additional collateral or its component parts from the Obligor’s property all without liability to the Obligee. Obligor shall pack or crate the Equipment and any additional collateral and all of the component parts of the Equipment and any additional collateral carefully and in accordance with any recommendations of the manufacturer. The Obligor shall deliver to the Obligee the plans, specifications, operation manuals or other warranties and documents furnished by the manufacturer or vendor on the Equipment and any additional collateral and such other documents in the Obligor’s possession relating to the maintenance and methods of operation of such Equipment and any additional collateral. (c) Condition: When the Equipment is surrendered to the Obligee it shall be in the condition and repair required to be maintained under this Contract. It will also meet all legal regulatory conditions necessary for the Obligee to sell or lease it to a third party and be free of all liens. If Obligee reasonably determines that the Equipment or an item of the Equipment, once it is returned, is not in the condition required hereby, Obligee may cause the repair, service, upgrade, modification or overhaul of the Equipment or an item of the Equipment to achieve such condition and upon demand, Obligor shall promptly reimburse Obligee for all amounts reasonably expended in connection with the foregoing. (d) Storage: Upon written request by the Obligee, the Obligor shall provide free storage for the Equipment and any additional collateral for a period not to exceed 60 days after the expiration of the Contract Term before returning it to the Obligee. The Obligor shall arrange for the insurance described to continue in full force and effect with respect to such item during its storage period and the Obligee shall reimburse the Obligor on demand for the incremental premium cost of providing such insurance.

X. Miscellaneous
Section 10.01 Notices. All notices shall be sufficiently given and shall be deemed given when delivered or mailed by registered mail, postage prepaid, to the parties at their respective places of
business as first set forth herein or as the parties shall designate hereafter in writing.

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Sec
tion 10.02 Binding Effect. Obligor acknowledges this Contract is not binding upon the Obligee or its assignees unless the Conditions to Funding listed on the Documentation Instructions h
ave been met to Obligee's satisfaction, and Obligee has executed the Contract. Thereafter, this Contract shall inure to the benefit of and shall be binding upon Obligee and Obligor and their respective successors and assigns.

Section 10.03 Severability. In the event any provision of this Contract shall be held invalid or unenforceable by any court of competent jurisdiction, such holding shall not invalidate or render u
nenforceable any other provision hereof.

Section 10.04 Amendments, Addenda, Changes or Modifications. This Contract may be amended, added to, changed or modified by written agreement duly executed by Obligee and Obligor.

Fur
thermore, Obligee reserves the right to directly charge or amortize into the remaining balance due from Obligor, a reasonable fee, to be determined at that time, as compensation to Obligee for the additional administrative expense resulting from such amendment, addenda, change or modification requested by Obligor.

Section 10.05 Execution in Counterparts. This Contract may be simultaneously executed in several counterparts, each of which shall be an original and all of which shall constitute but one and th
e same instrument.

Section 10.06 Captions. The captions or headings in this Contract do not define, limit or describe the scope or intent of any provisions or sections of this Contract.

Sec
tion 10.07 Master Contract. This Contract can be utilized as a Master Contract. This means that the Obligee and the Obligor may agree to the financing of additional Equipment under this Cont
ract at some point in the future by executing one or more Additional Schedules to Exhibit A and Exhibit B, as well as other exhibits or documents that may be required by Obligee. Additional Schedules will be consecutively numbered on each of the exhibits which make up the Additional Schedule and all the terms and conditions of the Contract shall govern each Additional Schedule.

Section 10.08 Entire Writing. This Contract constitutes the entire writing between Obligee and Obligor. No waiver, consent, modification or change of terms of this Contract shall bind either p
arty unless in writing and signed by both parties, and then such waiver, consent, modification or change shall be effective only in the specific instance and for the specific purpose given. There are no understandings, agreements, representations, conditions, or warranties, express or implied, which are not specified herein regarding this Contract, the Equipment or any additional collateral, financed hereunder. Any terms and conditions of any purchase order or other documents submitted by Obligor in connection with this Contract which are in addition to or inconsistent with the terms and conditions of this Contract will not be binding on Obligee and will not apply to this Contract.