Agenda packet — Redlands City Council, May 10, 2022 (part 2 of 3)

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Wastewater
Impact USWW-1: Require or result
in the relocation or construction of
new or expanded wastewater
treatment or storm drainage
facilities, the construction or
relocation of which could cause
significant environmental effects.

See PMM HYD-1.

PMM USWW-1: In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to reduce substantial adverse effects on utilities and service systems, particularly for construction of wastewater facilities, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
• During the design and CEQA review of individual future projects, implementing agencies and projects sponsors shall determine whether sufficient wastewater capacity exists for the proposed projects. There CEQA determinations must ensure that the proposed development can be served by its existing or planned treatment capacity. If adequate capacity does not exist, project sponsors shall coordinate with the relevant service provider to ensure that adequate public services and utilities could accommodate the increased demand, and if not, infrastructure improvements for the appropriate public service or utility shall be identified in each project’s CEQA documentation. The relevant public service provider or utility shall be responsible for undertaking project-level review as necessary to provide CEQA clearance for new facilities.

The Project’s impacts would be less than significant as a result of implementation of regulatory requirements. Nevertheless, the Project substantially conforms to this mitigation measure because most wastewater generated by sewered
development within the Planning Area is treated at the
Redlands Wastewater Treatment Facility. The Redlands
Wastewater Treatment Facility treats approximately 6 million gallons per day (mgd) with a capacity of 9.5 mgd. As
discussed in Section 6.3.19, Utilities and Service Systems, the Project would connect to existing water, wastewater, and storm drainage facilities, and would not require new or expanded wastewater treatment or storm drainage facilities.

Furthermore, the Applicant would be required to pay
Developer Impact Fees to offset any impacts to existing wastewater facilities.

Impact USWW-2: 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.

See PMM UWW-1. The Project’s impacts would be less than significant as a result of implementation of regulatory requirements. Nevertheless, the Project substantially conforms to this mitigation measure because most wastewater generated by sewered
development within the Planning Area is treated at the
Redlands Wastewater Treatment Facility. The Redlands
Wastewater Treatment Facility treats approximately 6 million gallons per day (mgd) with a capacity of 9.5 mgd. As
discussed in Section 6.3.19, Utilities and Service Systems, the Project would generate approximately 111,370 gpd of
wastewater per day. All new residential development that connects to the system is required to pay its applicable fairshare Development Impact Fee(s). As such, the Redlands Wastewater Treatment Facility would have adequate
capacity to serve the Project.

Water Supply
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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Impact USWS-1: Require or result
in the relocation or construction of
new or expanded water facilities,
the construction or relocation of
which could cause significant
environmental effects.

PMM USSW-1: In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to ensure sufficient water supplies, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Reduce exterior consumptive uses of water in public areas, and should promote reductions in private homes and businesses, by shifting to drought-tolerant native landscape plantings, using weather-based irrigation systems, educating other public agencies about water use, and installing related water pricing incentives. b) Promote the availability of drought-resistant landscaping options and provide information on where these can be purchased. Use of reclaimed water especially in median landscaping and hillside landscaping can and should be implemented where feasible.
c) Implement water conservation best practices such as low-flow toilets, waterefficient clothes washers, water system audits, and leak detection and repair. d) For projects located in an area with existing reclaimed water conveyance infrastructure and excess reclaimed water capacity, use reclaimed water for nonpotable uses, especially landscape irrigation. For projects in a location planned for future reclaimed water service, projects should install dual plumbing systems in anticipation of future use. Large developments could treat wastewater onsite to tertiary standards and use it for non-potable uses onsite The Project’s impacts would be less than significant as a result of implementation of regulatory requirements. Nevertheless, the Project substantially conforms to this mitigation measure because the Project would connect to the existing water lines in the surrounding streets. The construction activities related to the onsite water infrastructure that would be needed to serve the proposed Project is included as part of the Project and would not result in any physical environmental effects beyond those identified throughout this SCEA. Additionally, the new onsite water system would convey water supplies to the
proposed residences and landscaping through
plumbing/landscaping fixtures that are compliant with the CalGreen Plumbing Code for efficient use of water.

Furthermore, the Applicant would be required to pay
Developer Impact Fees to offset any impacts to existing water facilities.

Impact USWS-2: Have sufficient
water supplies available to serve
the project and reasonably
foreseeable future development
during normal, dry and multiple
dry years.

See PMM USWS-1. The Project’s impacts would be less than significant.

Nevertheless, the Project substantially conforms to this mitigation measure because the City has determined that the projected water supply available during normal, single-dry water years as included in the 25-year projection contained in its adopted 2015 Urban Water Management Plan can
accommodate the projected water demand associated with
the Project, in addition to the existing and planned future development. Additionally, the Water Supply Assessment
prepared for the proposed Project concluded that the Project would have a demand of 189 acre-feet per year, which is within the projected water demands and supplies as analyzed in the UWMP. In addition, all new residential development that connects to the system is required to pay its applicable fair-share Development Impact Fee(s).

Wildfire
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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Impact WF-2: 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.

Impact HAZ-7: Expose people or
structures, either directly or
indirectly, to a significant risk of
loss, injury or death involving
wildland fires.

PMM WF-1: In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to wildfire risk, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Launch fire prevention education for local cities and counties such that local fire agencies, homeowners, as well as commercial and industrial businesses are aware of potential sources of fire ignition and the related procedures to curb or lessen any activities that might initiate fire ignition.
b) Ensure structures in high fire risk areas are built to current state and federal standards which serve to greatly increase the chances the structure will survive a wildfire and also allow for people to shelter-in-place. c) Improve road access for emergency response and evacuation so people can evacuate safely and timely when necessary.
d) Improve, and educate regarding, local emergency communications and notifications with residents and businesses.
e) Enforce defensible space regulations to keep overgrown and unmanaged vegetation, accumulations of trash and other flammable material away from structures.
f) Provide public education about wildfire risk and fire prevention measures, and safety procedures and practices to allow for safe evacuation and/or options to shelter-in-place
g. Include external sprinklers with an independent water source to reduce flammability of structures.
h. Include local solar power paired with batteries to reduce power flow in electricity lines.
i. For developments in high fire-prone areas, have a fire protection plan for residents and businesses.
j. Provide fire hazard and fire safety education for homeowners in or near fire hazard areas.
k. Developments in fire-prone areas should have fire-resistant feature, such as: − Ember-resistant vents
− Fire-resistant roofs
The Project’s impacts would be less than significant.

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project − Surrounding defensible space
− Proper maintenance and upkeep of structures and surrounding area Impact WF-3: 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
risks or that may result in
temporary or ongoing impacts to
the environment.

See PMM HAZ-4.

PMM WF-2: In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to wildfire risk, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) New development or infrastructure activity within very high hazard severity zones or SRAs shall be required to:
1) Submit a fire protection plan including the designation of fire watch staff;
2) Maintain water and other fire suppression equipment designated solely for firefighting on site for any construction and maintenance activities;
3) Locate construction and maintenance equipment in designated “safe areas” such that they do not discharge combustible materials; and 4) Designate trained fire watch staff during project construction to reduce risk of fire hazards.

The Project’s impacts would be less than significant.

Impact WF-4: Expose people or
structures to significant risks,
including downslope or
downstream flooding or landslides,
as a result of runoff, post-fire slope
stability, or drainage changes.

See PMM WF-1, PMM WF-2, PMM HYD-1, and PMM HAZ-4. The Project’s impacts would be less than significant.

Nevertheless, the Project substantially conforms to this mitigation measure because the Project is not located in a Fire Hazard Area that may contain substantial fire risk or a Very High Fire Hazard Severity Zone. The City’s General Plan Safety Element (Section 7.4) discusses Emergency
Management, which outlines goals and policies aimed at
emergency preparedness to protect the health, safety and welfare of the general public during and after natural, manmade (technological), or attack-related emergencies.

Additionally, the proposed Project does not include any characteristics (e.g., permanent road closures or long-term blocking of road access) that would substantially impair or otherwise conflict with an emergency response plan or
emergency evacuation plan.

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6 SUSTAINABLE COMMUNITIES ENVIRONMENTAL ANALYSIS/ INITIAL

STUDY CHECKLIST
This section includes the completed environmental checklist form. The checklist form is used to assist in evaluating the potential environmental impacts of the proposed Project. The checklist form identifies potential Project effects as follows: 1) Potentially Significant Impact; 2) Less Than Significant with Mitigation Incorporated; 3) Less Than Significant Impact; and, 4) No Impact. Substantiation and clarification for each checklist response is provided in Section 5 (Environmental Evaluation). Included in the discussion for each topic are standard condition/regulations and mitigation measures, if necessary, that are recommended for implementation as part of the proposed Project.

6.1 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below ( ) would be potentially affected by this Project, involving at least one impact that is a “Potentially Significant Impact” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.

Environmental Factors Potentially Affected
Aesthetics Agriculture and Forest Resources Air Quality Biological Resources Cultural Resources Energy
Geology/Soils Greenhouse Gas Emissions Hazards and Hazardous Materials
Hydrology/Water Quality Land Use/Planning Mineral Resources Noise Population/Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities/Service Systems Wildfire Mandatory Findings of Significance
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6.2 DETERMINATION
(To be completed by the Lead Agency) on the basis of this initial evaluation I find that the proposed Project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed Project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed Project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed Project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed Project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

I find that the proposed Project is a qualified “transit priority project” that satisfies the requirements of Sections 21155 and 21155.2 of the Public Resources Code (PRC), and/or qualified “residential or mixed use residential project” that satisfies section 21159.28(d) of the PRC, and although the Project could have a potentially significant effect on the environment, there will not be a significant effect in this case, because the SUSTAINABLE COMMUNITIES ENVIRONMENTAL ASSESSMENT (SCEA) identifies measures that either avoid or mitigate to a level of insignificance all potentially significant or significant effects of the Project. ___________________________________________________________________________________ Signature Date
___________________________________________________________________________________ Printed Name For

EVALUATION OF ENVIRONMENTAL IMPACTS
1) A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question.

A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

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2) All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.
3) Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required. 4) “Negative Declaration: Potentially Significant Unless Mitigation Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from “Earlier Analysis,” as described in (5) below, may be cross-referenced). 5) Earlier analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063 (c)(3)(d). In this case, a brief discussion should identify the following:
(a) Earlier Analysis Used. Identify and state where they are available for review. (b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis.
(c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.
6) Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.
7) Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion. 8) This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.
9) The analysis of each issue should identify: (a) the significance criteria or threshold used to evaluate each question; and (b) the mitigation measure identified, if any, to reduce the impact to less than significance.

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6.3 ENVIRONMENTAL CHECKLIST QUESTIONS
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

1. AESTHETICS. Except as provided in Public
Resources Code Section 21099 would the Project:
a) Have a substantial adverse effect on a scenic
vista?
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a state
scenic highway
c) In non-urbanized areas, 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?
d) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
Except as provided in Public Resources Code Section 21099 would the Project:
a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
c) In non-urbanized areas, 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? d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
a-d) Less than Significant Impact. In 2013, the State of California enacted Senate Bill 743 (SB 743), which made several changes to the California Environmental Quality Action (CEQA) for projects located in areas served by transit. Specifically, Public Resources Code Section 21099 provides that “aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area shall not be considered significant impacts on the environment.” Public Resources Code Section 21099 defines a “transit priority area” as an area within one-half mile of a major transit stop that is “existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations.” Public Resources Code Section 21064.3 defines “major transit stop” as “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.” Public Resources Code Section 21099 defines an Redlands Joint Special Meeting of the
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infill site as a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses. This state law supersedes the aesthetic impact thresholds set forth in CEQA Guidelines Appendix G.

The Project would be a mixed-use, infill project located in a TPA. The Project includes development of an urban and developed site in Downtown Redlands. Public bus and rail transit is provided within the area of the Project site and the site is designated as a transit priority area and high quality transit area by the 2020-2045 RTP/SCS. The nearest rail station is the Arrow Line Downtown Redlands Station that is located approximately 0.16 mile north of the Project site. Furthermore, the Project would be subject to City of Redlands General Plan Action 2-A.35 that requires shielding of light to minimize lighting of adjacent off-site areas and generation of glare.

Thus, the Project’s aesthetic (and parking) impacts are not considered significant on the environment pursuant to Public Resources Code Section 21099. Therefore, an assessment of the Project’s potential aesthetic impacts is not required.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measure
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

2. AGRICULTURE AND FORESTRY
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 to 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:
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?
b) Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
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))?
d) Result in the loss of forest land or conversion
of forest land to non-forest use?
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?
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a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
No Impact. The Project site is currently developed and located in an urbanized area that is not used for agriculture. In addition, the Project site is designated as “Urban and Built-Up Land” on maps prepared pursuant to the California Department of Conservation Important Farmland Finder (CDC 2021). The Project site and adjacent areas are not designated as Prime, Unique, or Farmland of Statewide Importance. No areas of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance would be affected by the Project or converted to a non-agricultural use. Thus, no impact would occur. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The Williamson Act (California Land Conservation Act of 1965) restricts the use of agricultural and open space lands to farming and ranching by enabling local governments to contract with private landowners for indefinite terms in exchange for reduced property tax assessments. The Project site is zoned C-3. Therefore, rezoning and development of the site would not result in the loss of agricultural land or affect any Williamson Act contracts. In addition, no parcels in the Project vicinity have Williamson Act contracts. Therefore, implementation of the Project would not conflict with existing zoning for agricultural use or a Williamson Act contract, and no impact would occur. 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))? No Impact. As discussed previously, the Project site within an urbanized area and is developed with commercial structures and associated parking lots The Project site and vicinity is void of forest land or timberland. As described previously, the Project site is currently zoned for C-3 (General Commercial) District and is surrounded by areas zoned for commercial, residential, or public institution uses. No areas designated or zoned as forest land or timberland, or for timberland production, exist on or near the project site. Thus, no impact would occur from implementation of the proposed Project. d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. The project site contains a limited number of trees and does not include forestland or timberland.

Additionally, the project site is not zoned as forestland, and is surrounded by urban development on all sides. The project would not conflict with existing zoning for, or cause rezoning of, forestland, timberland, or timberland zoned Timberland Production. No impact would occur. 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? No Impact. As discussed previously, the Project site is in an urbanized residential area of the City of Redlands and is developed with commercial buildings and associated parking lots. It is currently not used for agricultural purposes and is not designed or zoned for forest land. The proposed Project would not convert farmland to a nonagricultural use or convert forest land to a non-forest use. Likewise, the proposed Project would not contribute to environmental changes that could result in conversion of farmland to a nonagricultural use or conversion of forest land to a non-forest use. Thus, no impact would occur.

Project Design Features
None.

Existing Plans, Programs, or Policies
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None.

Mitigation Measure
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

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?
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?
c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those
leading to odors) affecting a substantial
number of people?
The discussion below is based on the State Street Village Air Quality Impact Analysis prepared by Urban Crossroads, included as Appendix A.
a) Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. The Project site is located in the South Coast Air Basin and is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The SCAQMD and the Southern California Association of Governments (SCAG) are responsible for preparing the Air Quality Management Plan (AQMP), which addresses federal and state Clean Air Act (CAA) requirements. The AQMP details goals, policies, and programs for improving air quality in the Basin. In preparation of the AQMP, SCAQMD and SCAG uses regional growth projections to forecast, inventory, and allocate regional emissions from land use and development-related sources. For purposes of analyzing consistency with the AQMP, if a proposed Project would result in growth that is substantially greater than what was anticipated, then the proposed Project would conflict with the AQMP. On the other hand, if a Project’s density is within the anticipated growth of a jurisdiction, its emissions would be consistent with the assumptions in the AQMP, and the Project would not conflict with SCAQMD’s attainment plans. In addition, the SCAQMD considers a Project consistent with the AQMP if the Project would not result in an increase in the frequency or severity of existing air quality violations or cause a new violation.

Furthermore, The South Coast Air Basin (SCAB) is in a non-attainment status for federal and state ozone standards and state and federal particulate matter standards. Any development in the SCAB, including the proposed Project, could cumulatively contribute to these pollutant violations. Should construction or operation of the proposed Project exceed these thresholds a significant impact could occur; however, if estimated emissions are less than the thresholds, impacts would be considered less than significant.

The proposed Project is a redevelopment Project on a site that has been previously used for commercial uses and is located within a commercial neighborhood. The proposed Project would remove the existing Redlands Joint Special Meeting of the
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commercial buildings making up the Redlands Mall and develop 700 multi-family dwelling units, 71,778 square feet (SF) of ground-floor retail, approximately 12,328 SF of office space, amenity areas, community building, and a 1,721 SF rooftop restaurant space with a rooftop deck on the northern site. The proposed Project would remove the existing paving and develop a 14,500 SF drugstore with associated parking on the southern site. As further described in Section 14, Population and Housing, the 700 new residences would result in an 0.9 increase of residential units within the city. Furthermore, the development of the 87,999 SF of commercial retail and restaurant uses would result in the need for approximately 710 employees. The development of 12,328 SF of office space would result in the need for approximately 18 new employees.

This limited level of growth on within a developed area would not exceed growth projections and would be consistent with the assumptions in the AQMP. Additionally, as previously discussed within Section 4.2.1 of this SCEA, the proposed Project would be consistent with 2020-2045 RTP/SCS In addition, as detailed below, the emissions generated by construction and operation of the proposed Project would not exceed thresholds, and the Project would not result in an increase in the frequency or severity of existing air quality violations or cause a new violation. Therefore, impacts related to conflict with the AQMP from the proposed Project would be less than significant. 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? Less Than Significant Impact. The South Coast Air Basin (SCAB) is in a non-attainment status for federal and state ozone standards and state and federal particulate matter standards. Any development in the SCAB, including the proposed Project, could cumulatively contribute to these pollutant violations. Evaluation of cumulative air quality impacts of the proposed Project has been completed pursuant to SCAQMD’s cumulative air quality impact methodology, SCAQMD states that if an individual project results in air emissions of criteria pollutants (ROG, CO, NOx, SOx, PM10, and PM2.5) that exceed the SCAQMD’s recommended daily thresholds for project-specific impacts, then it would also result in a cumulatively considerable net increase of the criteria pollutant(s) for which the project region is in non-attainment under an applicable federal or state ambient air quality standard.

SCAQMD published its Final Localized Significance Threshold Methodology in July 2008, recommending that all air quality analyses include an assessment of both construction and operational impacts on the air quality of nearby sensitive receptors from emissions of CO, NOX, PM10, and PM2.5. The methodologies from the SCAQMD CEQA Air Quality Handbook are used in evaluating Project impacts. SCAQMD has established daily mass thresholds for regional pollutant emissions, which are shown in Table AQ-1.

Table AQ-1: SCAQMD Regional Daily Emissions Thresholds
Pollutant Construction
(lbs/day)
Operations
(lbs/day)
NOx 100 55
VOC 75 55
PM10 150 150
PM2.5 55 55
SOx 150 150
CO 550 550
Lead 3 3 Source: Urban Crossroads 2021 (Appendix A)
Construction
Construction activities associated with the proposed Project would generate pollutant emissions from the following: (1) demolition of the existing structures and removal of the existing infrastructure and pavement, (2) site preparation, (3) grading, (4) building construction, (5) paving, and (6) architectural coating. The amount of emissions generated on a daily basis would vary, depending on the intensity and types of construction activities occurring.

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It is mandatory for all construction projects to comply with several SCAQMD Rules, including Rule 403 for controlling fugitive dust, PM10, and PM2.5 emissions from construction activities. Rule 403 requirements include, but are not limited to, applying water in sufficient quantities to prevent the generation of visible dust plumes, applying soil binders to uncovered areas, reestablishing ground cover as quickly as possible, utilizing a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the proposed Project site, covering all trucks hauling soil with a fabric cover and maintaining a freeboard height of 12-inches, and maintaining effective cover over exposed areas. Compliance with Rule 403 was accounted for in the construction emissions modeling and is included as PPP AQ-1. In addition, implementation of SCAQMD Rule 1113, which governs the VOC content in architectural coating, paint, thinners, and solvents was accounted for in construction emissions modeling, and is included as PPP AQ-2. Additionally, Project construction would utilize equipment during demolition, grading, and site preparation phases that equal or exceed Environmental Protection Agency (EPA) and California Air Resource Board (CARB) Tier III engine emissions standards, included as PDF AQ-1. As shown in Table AQ-2, CalEEMod results indicate that construction emissions generated by the proposed Project would not exceed SCAQMD regional thresholds with implementation of PPP AQ-1, PPP AQ-2, and PDF AQ-1. Therefore, construction activities would result in a less than significant impact.

Table AQ-2: Project Construction Emissions and Regional Thresholds Year
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
2022 4.30 59.02 63.40 0.12 14.07 7.15
2023 7.91 93.81 109.30 0.27 22.61 10.69
2024 4.04 22.31 44.87 0.13 6.64 2.36
2025 3.79 21.08 43.07 0.13 6.55 2.27
2026 49.96 31.28 63.47 0.17 8.17 3.05
Maximum Daily Summer Emissions 49.96 93.81 109.30 0.27 22.61 10.69 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Winter
2022 4.31 59.21 63.24 0.12 14.07 7.15
2023 8.04 94.25 106.71 0.27 22.61 10.69
2024 4.17 22.77 42.57 0.13 6.64 2.36
2025 3.91 21.52 40.94 0.13 6.55 2.27
2026 50.11 31.73 61.03 0.16 8.17 3.05
Maximum Daily Winter Emissions 50.11 94.25 106.71 0.27 22.61 10.69 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Source: Urban Crossroads 2021 (Appendix A)
Operation
Implementation of the proposed Project would result in long-term regional emissions of criteria air pollutants and ozone precursors associated with area sources, such as natural gas consumption, landscaping, applications of architectural coatings, and consumer products. Operational vehicular emissions would generate a majority of the emissions from implementation of the Project. In addition, compliance with Redlands Joint Special Meeting of the
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SCAQMD Rule 445 that prohibits the use of wood burning stoves and fireplaces in new developments will also be included as PPP AQ-3 to ensure compliance.

Operational emissions associated with the proposed Project were modeled using CalEEMod and are presented in Table AQ-3. As shown, the proposed Project would result in long-term regional emissions of the criteria pollutants, however, these emissions would be below the SCAQMD’s applicable thresholds. Therefore, the Project’s operational emissions would not exceed the NAAQS and CAAQS, would not result in a cumulatively considerable net increase of any criteria pollutant, and impacts would be less than significant.

Table AQ-3: Project Operational Emissions and Regional Thresholds Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Area Source 19.81 0.69 59.73 0.00 - 0.33
Energy Source 0.52 4.56 2.84 0.03 - 0.36
Mobile Source Passenger Cars 5.74 5.11 48.28 0.10 11.36 0.07 Maximum Daily Summer Emissions 26.07 10.35 110.85 0.13 11.36 0.76 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Winter
Area Source 19.81 0.69 59.73 0.00 - 0.33
Energy Source 0.52 4.56 2.84 0.03 - 0.36
Mobile Source Passenger Cars 5.47 5.49 47.63 0.10 11.36 0.07 Maximum Daily Winter Emissions 25.79 10.73 110.20 0.13 11.36 0.76 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Source: Urban Crossroads 2021 (Appendix A)

c) Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact. The SCAQMD’s Final Localized Significance Threshold Methodology (SCAQMD 2008) recommends the evaluation of localized NO2, CO, PM10, and PM2.5 construction-related impacts to sensitive receptors in the immediate vicinity of the Project site. Such an evaluation is referred to as a localized significance threshold (LST) analysis. According to the SCAQMD’s Final Localized Significance Threshold Methodology, “off-site mobile emissions from the Project should not be included in the emissions compared to the LSTs” (SCAQMD 2008). SCAQMD has developed LSTs that represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards, and thus would not cause or contribute to localized air quality impacts. LSTs are developed based on the ambient concentrations of NOx, CO, PM10, and PM2.5 pollutants for each of the 38 source receptor areas (SRAs) in the SCAB. The City of Redlands is located within SCAQMD SRA 35.

Sensitive receptors can include residences, schools, playgrounds, childcare centers, athletic facilities. The nearest sensitive receptors are existing residences are located adjacent to the project site. The distance between the Project site boundary and the closest existing residential structure is approximately 46-feet south of the Project. The LST Methodology explicitly states that “It is possible that a project may have receptors closer than 25 meters. Projects with boundaries located closer than 25 meters (82 feet) to the nearest receptor should use the LSTs for receptors located at 25 meters.” As the existing residence is located Redlands Joint Special Meeting of the
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less than 25-meters from the Project site, the 25-meter receptor distance is used for evaluation of localized impacts.

Construction
Construction of the proposed Project may expose nearby residential sensitive receptors to airborne particulates as well as a small quantity of construction equipment pollutants (i.e., usually diesel-fueled vehicles and equipment). However, construction contractors would be required to implement measures to reduce or eliminate emissions by following SCAQMD’s standard construction practices (Rules 402 and 403, as included as PPP AQ-1 and PPP AQ-2). Rule 402 requires implementation of dust suppression techniques to prevent fugitive dust from creating a nuisance off site. Rule 403 requires that fugitive dust be controlled with best available control measures so that the presence of such dust does not remain visible in the atmosphere beyond the property line of the emission source. Additionally, the Project would implement PDF AQ-1 and utilize Tier III equipment during demolition, site preparation, and grading. As shown in Table AQ-4, Project construction-source emissions would not exceed the applicable SCAQMD LSTs.

Table AQ-4: Localized Significance Summary of Construction On-Site Site Emissions Emissions (lbs/day)
NOX CO PM10 PM2.5
Maximum Daily Emissions 63.4 72.1 9.6 5.1
SCAQMD Localized Threshold 224 2,174 14 9
Threshold Exceeded? No No No No
Source: Urban Crossroads 2021 (Appendix A)
Operations
Operation of the proposed Project would include emissions from vehicles traveling to the Project site and from vehicles in the parking lots and loading areas. As demonstrated in Table AQ-5, emissions would not exceed SCAQMD LSTs for operations, and impacts would be less than significant.

Table AQ-5: Localized Significance Summary of Operations Operational Activity Emissions (lbs/day)
NOX CO PM10 PM2.5
Maximum Daily Emissions 5.25 62.57 0.69 0.69
SCAQMD Localized Threshold 224 2,174 4 3
Threshold Exceeded? No No No No
Source: Urban Crossroads 2021 (Appendix A)
CO Hot Spot Analysis
Less than Significant Impact. An adverse CO concentration, known as a “hot spot”, would occur if an exceedance of the state one-hour standard of 20 ppm or the eight-hour standard of 9 ppm were to occur.

In 2003, the SCAQMD estimated that a project would have to increase traffic volumes at a single intersection by more than 44,000 vehicles per hour—or 24,000 vehicles per hour where vertical and/or horizontal air does not mix—in order to generate a CO hot spot.

As detailed in Section 6.3.13, Transportation, in Table T-1, the proposed Project would generate 682 new vehicle trips (339 inbound trips and 343 outbound trips) during the weekday AM peak hour. During the weekday PM peak hour, the Project is expected to generate 217 new vehicle trips (156 inbound trips and 62 outbound trips). Over a 24-hour period, the Project is forecast to generate approximately 1,866 new daily trip ends during a typical weekday. Thus, buildout of the proposed Project would not result in an increase in traffic volumes at a single intersection by more than 44,000 vehicles per hour—or 24,000 vehicles per hour where vertical and/or horizontal air does not mix and would not generate a CO hot spot. Therefore, impacts related to CO “hot spots” from operation of the proposed Project would be less than significant.

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d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less Than Significant Impact. According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor issues include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting activities, refineries, landfills, dairies, and fiberglass molding operations. The proposed project would implement residential development within the project area. Residential uses do not involve the types of activities that would emit objectionable odors affecting a substantial number of people. In addition, odors generated by new and existing non-residential land uses are required to be in compliance with SCAQMD Rule 402 to prevent odor nuisances on sensitive land uses. SCAQMD Rule 402, Nuisance, states:

A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.

During construction, emissions from diesel equipment, use of volatile organic compounds from architectural coatings, and paving activities may generate some nuisance odors. However, these odors would be temporary and are not expected to affect a substantial number of people. Therefore, emission impacts relating to both operational and construction activity odors would be less than significant.

Project Design Features
PDF AQ-1: Tier III Equipment. Project construction will utilize equipment during demolition, grading, and site preparation phases that equal or exceed Environmental Protection Agency (EPA) and California Air Resource Board (CARB) Tier III engine emissions standards
Existing Plans, Programs, or Policies
PPP AQ-1: Rule 403. All applicable measures included in Rule 403, shall be incorporated into Project plans and specifications as implementation of Rule 403, which include but are not limited to (1):
• All clearing, grading, earth-moving, or excavation activities shall cease when winds exceed 25 mph per SCAQMD guidelines in order to limit fugitive dust emissions. • The contractor shall ensure that traffic speeds on unpaved roads and Project site areas are limited to 15 miles per hour or less.
• The contractor shall ensure that all disturbed unpaved roads and disturbed areas within the Project are watered at least three (3) times daily during dry weather. Watering, with complete coverage of disturbed areas, shall occur at least three times a day, preferably in the mid-morning, afternoon, and after work is done for the day.

PPP AQ-2: Rule 1113. The following measures shall be incorporated into Project plans and specifications as implementation of SCAQMD Rule 1113 (2):
• Only “Low-Volatile Organic Compounds (VOC)” paints (no more than 50 gram/liter of VOC) consistent with SCAQMD Rule 1113 shall be used.

PPP AQ-3: Rule 445. The following measures shall be incorporated into Project plans and specifications as implementation of SCAQMD Rule 445 (3):
• Rule 445 prohibits the use of wood burning stoves and fireplaces in new developments.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

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?
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 US Fish and
Wildlife Service?
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interruption, or other means?
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?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
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?
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? Less than Significant Impact with Mitigation Incorporated. The Project site is located in an urbanized and developed area of the city. The Project site is heavily disturbed, graded, and consists of mostly developed land with commercial buildings and surface parking lots. In its existing condition, the Project site contains a variety of ornamental trees and other landscaping surrounding the commercial buildings and within the surface lots. The existing trees on the site have the potential to provide habitat for nesting migratory birds.

Many of these trees would be removed during construction. Therefore, the proposed Project has the potential to impact active bird nests if vegetation and trees are removed during the nesting season. Nesting birds are Redlands Joint Special Meeting of the
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protected under the federal Migratory Bird Treaty Act (MBTA) (United States Code Title 33, Section 703 et seq.; see also Code of Federal Regulations Title 50, Part 10) and Section 3503 of the California Fish and Game Code. Any activities that occur during the nesting/breeding season of birds protected by the federal Migratory Bird Treaty Act (MBTA), could result in a potentially significant impact if requirements of the MBTA are not followed. Therefore, implementation of MM BIO-1 would ensure MTBA compliance and would require a nesting bird survey to be conducted prior to the commencement of construction during nesting season, which would reduce potential impacts related to nesting avian species and native wildlife nursery sites to a less than significant level.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or US Fish and Wildlife Service?
No Impact. Riparian habitats are those occurring along the banks of rivers and streams. Sensitive natural communities are natural communities that are considered rare in the region by regulatory agencies, known to provide habitat for sensitive animal or plant species, or known to be important wildlife corridors. As described above, the Project site is heavily disturbed, graded, and consists of mostly vacant land other than a small cluster of single-family residences and associated structures on the eastern portion of the Project site.

According to the National Wetlands Inventory managed by the USFWS, the Project site does not contain riparian habitat (USFWS 2021). There are no riparian habitat or other sensitive natural communities as identified in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Therefore, no impact would occur.
c) Have a substantial adverse effect on state or federally protected wetlands (including but not limited to, marsh, vernal, pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
No Impact. Wetlands are defined under the federal Clean Water Act as land that is flooded or saturated by surface water or groundwater at a frequency and duration sufficient to support, and that normally does support, a prevalence of vegetation adapted to life in saturated soils. Wetlands include areas such as swamps, marshes, and bogs. As previously discussed, according to the National Wetlands Inventory managed by the USFWS, the Project site does not contain federally protected wetlands (USFWS 2021). In addition, the Project site does not contain any jurisdictional areas that would be subject to Section 404 of the Clean Water Act, and the proposed Project does not involve any hydrological interruption on any existing water resources. Therefore, the redevelopment of the Project site would not result in impacts to wetlands. 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?
Less than Significant Impact with Mitigation Incorporated. Wildlife corridors are linear features that connect areas of open space and provide avenues for the migration of animals and access to additional areas of foraging. The Project site does not contain, or is not adjacent to, any wildlife corridors. The Project site is surrounded by roadways and developed areas. Areas of commercial, residential, public institutional, and additional roadways are located beyond the roadways adjacent to the site. Development of the site would not result in impacts related to established native resident or migratory wildlife corridor.

As described previously, the Project site contains ornamental vegetation that provides potentially suitable habitat for nesting birds. Therefore, if vegetation is required to be removed during nesting bird season, Mitigation Measure BIO-1 has been included to require a nesting bird survey to be conducted prior to vegetation removal. With the implementation of Mitigation Measure BIO-1, impacts related to native wildlife nursery sites would be reduced to a less than significant level.

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e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No Impact. Chapter 12.52 of the City of Redlands’s Municipal Code regulates trees and tree protection along streets and in public places. As part of the Project, existing trees around the perimeter of the Project site and throughout the existing parking lot areas of the Project site would be removed and replaced with a variety of trees and ornamental landscaping. However, none of the trees that would be removed are located within the city or any other public space. Therefore, the project would not conflict with the City’s tree preservation policy.

In addition, the City General Plan outlines policies that protect biological resources; however, these policies pertain to ecological areas such as San Timoteo Canyon, Live Oak Canyon, the Crafton Hills, and the Santa Ana River, Mill Creek, and other riparian areas within the city. The Project site is in an urbanized area of the city and is not located in an area identified by the city as having ecological value. Therefore, implementation of the proposed Project would not conflict with any local policies or ordinances protecting biological resources, and no impact would occur.
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? No Impact. The project site is developed and within an urbanized area. The project site is not located within the boundaries of any adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Therefore, implementation of the proposed project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. No impact would occur.

Project Design Feature
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
MM BIO-1: Pre‐construction Nesting Bird Survey. Construction plans and Project specifications shall state that if construction or other Project activities are scheduled to occur during the bird breeding season (February through August for raptors and March through August for most migratory bird species), a pre‐construction nesting bird survey shall be conducted by a qualified biologist to ensure that active bird nests, will not be disturbed or destroyed. The survey shall be completed no more than three days prior to initial ground disturbance. The nesting bird survey shall include the Project area and adjacent areas where proposed Project activities have the potential to affect active nests, either directly or indirectly due to construction activity or noise.

If an active nest is identified, a qualified biologist shall establish an appropriate disturbance limit buffer around the nest using flagging or staking. Construction activities shall not occur within any disturbance limit buffer zones until the nest is deemed inactive by the qualified biologist.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

5. CULTURAL RESOURCES. Would the
Project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
in § 15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?
c) Disturb any human remains, including those
interred outside of formal cemeteries?
The discussion below is based on the Cultural and Paleontological Resources Assessment for the Redlands Mall Redevelopment Project, prepared by Material Culture Consulting (MCC 2021), Appendix B. a) Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5?
Less than Significant Impact. According to the State CEQA Guidelines, a historical resource is defined as something that meets one or more of the following criteria: (1) listed in, or determined eligible for listing in, the California Register of Historical Resources; (2) listed in a local register of historical resources as defined in Public Resources Code (PRC) Section 5020.1(k); (3) identified as significant in a historical resources survey meeting the requirements of PRC Section 5024.1(g); or (4) determined to be a historical resource by the Project’s Lead Agency. Implementation of the proposed Project would not cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5 of the State CEQA Guidelines, as there are no eligible historical resources on the Project site.

The California Register of Historical Resources defines a “historical resource” as a resource that meets one or more of the following criteria: (1) associated with events that have made a significant contribution to the broad patterns or local or regional history of the cultural heritage of California or the United States; (2) associated with the lives of persons important to local, California, or national history; (3) embodies the distinctive characteristics of a type, period, region, or method of construction or represents the work of a master or possesses high artistic values; or (4) has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation.

In addition, Section 2.62 of the Redlands Municipal Code states that a structure with aesthetics, architectural, historical value which is 50 years old or older may be designated as a Historic Resource. A structure with exceptional esthetics, architectural, or historical value may be designated as a Landmark Resource. The criteria, any one of which may be used to determine such designation, are as follows:

A. It [a nominated resource] has significant character, interest, or value as part of the development, heritage or cultural characteristics of the city of Redlands, state of California, or the United States; B. It is the site of a significant historic event;
C. It is strongly identified with a person or persons who significantly contributed to the culture, history or development of the city;
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D. It is one of the few remaining examples in the city possessing distinguishing characteristics of an architectural type or specimen;
E. It is a notable work of an architect or master builder whose individual work has significantly influenced the development of the city;
F. It embodies elements of architectural design, detail, materials, or craftsmanship that represents a significant architectural innovation;
G. It has a unique location or singular physical characteristics representing an established and familiar visual feature of a neighborhood, community, or the city; H. It has unique design or detailing;
I. It is a particularly good example of a period or style; J. It contributes to the historical or scenic heritage or historical or scenic properties of the city (to include, but not be limited to, landscaping, light standards, trees, curbings, and signs); K. It is located within a historic and scenic or urban conservation district, being a geographically definable area possessing a concentration of historic or scenic properties which contribute to each other and are unified aesthetically by plan or physical development.

The Project site includes the main Redlands Mall commercial building, which was built in 1977, and a stand-alone retail store that was built in 1977. Therefore, all buildings onsite are under 45 years old and are not eligible for listing as a historic resource.

The Project site contains a portion of the Mill Creek Zanja on the northwest corner, located within an existing stormwater easement. The onsite portion of the Mill Creek Zanja is currently paved over with a parking lot.

Other portions of the Mill Creek Zanja are listed in the California Register of Historical Resources and National Register of Historic Places. Additionally, a segment of the Mill Creek Zanja was discovered directly east of the Project site at the southeastern intersection of Orange Street and Redlands Boulevard. The segment was observed subsurface, below the ground floor of the building at 120 Orange Street. During the intensive pedestrian survey conducted on May 12, 2021, the Mill Creek Zanja was not located, and no other cultural or historical resources were identified. As shown on Figure 3-1, Conceptual Site Plan, the Project would leave the existing Mill Creek Zanja stormwater easement in place and would not result in any excavation within the easement. As such, the Project would not cause a substantial adverse change to the Mill Creek Zanja, and impacts would be less than significant. b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Less than Significant with Mitigation Incorporated. In its existing setting, the Project site is heavily disturbed, graded, and consists of vacant land, paved areas, and three single-family residences. A records search for the Project site was conducted at the South Central Coastal Information Center (SCCIC) of the California Historical Resources Information System (CHRIS) that included California Points of Historical Interest (PHI), California Historical Landmarks (CHL), the California Register of Historic Resources, the National Register of Historic Places, the California State Historic Resources Inventory (HRI), and historic topographic maps. The records search revealed that 408 cultural resources have been recorded within one-half mile of the Project site. One cultural resource, the Mill Creek Zanja, is located under the northwest portion of the Project site.

As described previously, the Project site has been previously disturbed from various past uses that involve grading, installation of utility infrastructure, and building construction. However, due to the presence of the Mill Creek Zanja in the northwest portion of the Project site, the potential for archaeological resources onsite is considered low to moderate. However, Mitigation Measure CUL-1 has been included to require archaeological monitoring of ground disturbing activities to ensure that inadvertent discovery of resources during ground-disturbing activities are less than significant.

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Mitigation Measure CUL-1 requires retention of an archaeologist that would observe ground disturbing activities and recover archaeological resources as necessary. In addition, the archaeologist would be present at the pre-grading conference to establish procedures for archeological resource surveillance. Mitigation CUL-1would also halt work within 50 feet of a find until it can be evaluated by the qualified on-call archaeologist. Construction activities could continue in other areas. If the discovery proves to be significant, additional work, such as data recovery excavation, may be warranted and shall be discussed in consultation with the appropriate regulatory agency(ies). With implementation of Mitigation Measure CUL-1, impacts related to archaeological resources would be less than significant. c) Disturb any human remains, including those interred outside of formal cemeteries? Less than Significant with Mitigation Incorporated. The Project site has been previously disturbed, as described above, and has not been previously used as a cemetery. It is not anticipated that implementation of the proposed Project would result in the disturbance of human remains. In addition, compliance with California Health and Safety Code Section 7050.5, CEQA Section 15064.5, and Public Resources Code Section 5097.98, included as MM TCR-5, mandate the process to be followed in the event of an accidental discovery of any human remains. Specifically, California Health and Safety Code Section 7050.5 requires that if human remains are discovered, disturbance of the site shall remain halted until the coroner has conducted an investigation into the circumstances, manner, and cause of death, and made recommendations concerning the treatment and disposition of the human remains to the person responsible for the excavation, or to his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. If the coroner determines that the remains are not subject to his or her authority and if the coroner has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Compliance with existing law, included as MM TCR-5, would ensure that impacts to human remains would be less than significant.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
MM CUL-1: Archaeological Monitoring. The Applicant shall retain a qualified archaeologist to perform archaeological monitoring and the archaeologist shall be present during initial grounddisturbing activities (e.g., site preparation, demolition of historic structures, and grading up to ten feet below surface) to identify and assess any known or suspected archaeological and/or cultural resource. The qualified archaeologist shall develop a Cultural Resources Management Plan to address the details, timing, and responsibility of all archaeological and cultural resource activities that occur on the Project site. The plan shall include a scope of work, project grading and development scheduling, pre-construction meeting (with consultants, contractors, and monitors), a monitoring schedule during all initial grounddisturbance related activities, safety requirements, and protocols to follow in the event of previously unknown cultural resources discoveries that could be subject to a cultural resources evaluation. The plan shall be submitted to the City and the Consulting Tribe(s) for review and comment, prior to final approval by the City. The Monitoring and Treatment Plan shall incorporate the components described in Mitigation Measure TCR-1.

MM TCR-5, as included below.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

6. ENERGY. 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?
b) Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency?
The discussion below is based on the State Street Village Energy Analysis, prepared by Urban Crossroads, included as Appendix C.
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Less than Significant Impact.

Construction
During construction of the proposed Project would consume energy in three general forms:

1. Petroleum-based fuels used to power off-road construction vehicles and equipment on the Project sites, construction worker travel to and from the project site, as well as delivery truck trips;

2. Electricity associated with providing temporary power for lighting and electric equipment; and

3. Energy used in the production of construction materials, such as asphalt, steel, concrete, pipes, and manufactured or processed materials such as lumber and glass.

Construction activities related to the proposed mixed-use development and the associated infrastructure is not expected to result in demand for fuel greater on a per-unit-of-development basis than other development projects in Southern California. Table E-1 details the construction fuel usage over the Project’s 4-year construction period. As shown in Table E-1, Project construction would require the consumption of 329,564 gallons of diesel fuel.

Table E-1: Construction Equipment Fuel Consumption Estimates Activity/
Duration
Duration
(Days) Equipment HP Rating Quantity Usage Hours
Load
Factor
HPhrs/day
Total Fuel
Consumption
(gal. diesel
fuel)
Demolition 84
Concrete/Industrial
Saws 81 2 8 0.73 946 4,296
Excavators 158 5 8 0.38 2,402 10,905
Rubber Tired Dozers 247 3 8 0.40 2,371 10,767
Site
Preparation 125
Crawler Tractors 97 4 8 0.37 1,148 7,760
Rubber Tired Dozers 247 3 8 0.40 2,371 16,022
Grading 130 Crawler Tractors 97 2 8 0.37 574 4,035
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Excavators 158 3 8 0.38 1,441 10,126
Graders 187 1 8 0.41 613 4,310
Rubber Tired Dozers 247 1 8 0.40 790 5,554
Building
Construction 865
Scrapers 367 2 8 0.48 2,819 131,787
Cranes 231 1 8 0.29 536 25,058
Forklifts 89 3 8 0.20 427 19,974
Generator Sets 84 1 8 0.74 497 23,251
Tractors/Loaders/Back
hoes 97 3 8 0.37 861 40,274
Paving 125
Welders 46 1 8 0.45 166 1,119
Pavers 130 2 8 0.42 874 5,903
Paving Equipment 132 2 8 0.36 760 5,137
Architectural
Coating 125 Rollers 80 2 8 0.38 486 3,286
CONSTRUCTION FUEL DEMAND (GALLONS DIESEL FUEL) 329,564
Source: Urban Crossroads, 2021 (Appendix C)
Table E-2 shows the energy consumption for construction worker light-duty auto (LDA) vehicles. As shown, construction worker LDAs would consume 225,122 gallons of gasoline.

Table E-2: Construction Worker Fuel Consumption Estimates (LDA) Construction
Activity
Duration
(Days)
Worker
Trips/ Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Demolition 84 21 14.7 26,169 31.93 820
Site Preparation 125 13 14.7 23,365 31.93 732
Grading 130 16 14.7 31,049 31.93 972
Building Construction 865 542 14.7 6,889,534 31.93 215,769 Paving 125 11 14.7 19,471 31.93 610
Architectural Coating 125 108 14.7 198,600 31.93 6,220
TOTAL CONSTRUCTION WORKER (LDA) FUEL CONSUMPTION 225,122 Source: Urban Crossroads, 2021 (Appendix C)
Table E-3 and E-4 show the energy consumption for construction worker light-duty-trucks (LDT). As shown, construction worker LDT-1s would require 27,249 gallons of fuel and LDT-2s would require 89,774 gallons of fuel.

Table E-3: Construction Worker Fuel Consumption Estimates (LDT1) Construction
Activity
Duration
(Days)
Worker
Trips / Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Demolition 84 2 14.7 2,658 26.79 99
Site Preparation 125 1 14.7 2,373 26.79 89
Grading 130 2 14.7 3,153 26.79 118
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Building Construction 865 55 14.7 699,664 26.79 26,117
Paving 125 1 14.7 1,977 26.79 74
Architectural Coating 125 11 14.7 20,169 26.79 753
TOTAL CONSTRUCTION WORKER (LDT2) FUEL CONSUMPTION 27,249 Source: Urban Crossroads, 2021 (Appendix C)
Table E-4: Construction Worker Fuel Consumption Estimates (LDT2) Construction
Activity
Duration
(Days)
Worker
Trips / Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Demolition 84 7 14.7 8,218 25.15 327
Site Preparation 125 4 14.7 7,337 25.15 292
Grading 130 5 14.7 9,751 25.15 388
Building Construction 865 170 14.7 2,163,590 25.15 86,044 Paving 125 3 14.7 6,115 25.15 243
Architectural Coating 125 34 14.7 62,368 25.15 2,480
TOTAL CONSTRUCTION WORKER (LDT1) FUEL CONSUMPTION 89,774 Source: Urban Crossroads, 2021 (Appendix C)
Tables E-5 through E-7 show the fuel consumption by medium-heavy duty (MHDT) and heavy-heavy duty (HHDT) vendor and hauling vehicle trips during various construction phases of the Project.

Table E-5: Construction Vendor Fuel Consumption Estimates (MHDT) Construction Activity Duration
(Days)
Vendor
Trips /
Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
2020
Grading 130 88 6.9 78,936 10.08 7,832
TOTAL CONSTRUCTION VENDOR (MHDT) FUEL CONSUMPTION 7,832 Source: Urban Crossroads, 2021 (Appendix C)
Table E-6: Construction Vendor Fuel Consumption Estimates (HHDT) Construction Activity Duration
(Days)
Vendor
Trips /
Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
2020
Grading 130 89 6.9 79,833 6.33 12,613
TOTAL CONSTRUCTION VENDOR (HHDT) FUEL CONSUMPTION 12,613 Source: Urban Crossroads, 2021 (Appendix C)
Table E-7: Construction Hauling Fuel Consumption Estimates (HHDT) Construction Activity Duration
(Days)
Hauling
Trips /
Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
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2020
Demolition 84 27 20 45,480 6.33 7,185
Grading 130 47 20 122,500 6.33 19,354
TOTAL CONSTRUCTION HAULING (HHDT) FUEL CONSUMPTION 26,539 Source: Urban Crossroads, 2021 (Appendix C)
Construction of the Project would result in fuel consumption from the use of construction tools and equipment, vendor and haul truck trips, and vehicle trips generated from construction workers traveling to and from the site. There are no unusual Project characteristics that would cause the use of construction equipment that would be less energy efficient compared with other similar construction sites in other parts of the State.

Therefore, construction-related fuel consumption by the Project would not result in inefficient, wasteful, or unnecessary energy use compared with other construction sites in the region, and impacts would be less than significant.

Operation
Once operational, the Project would generate demand for electricity, natural gas, as well as gasoline for fuel tanks. Operational use of energy includes the heating, cooling, and lighting of the building, water heating, operation of electrical systems and plug-in appliances, parking lot and outdoor lighting, and the transport of electricity, natural gas, and water to the areas where they would be consumed. This use of energy is typical for urban development, and no operational activities or land uses would occur that would result in extraordinary energy consumption.

The State of California provides a minimum standard for building design and construction standards through Title 24 of the California Code of Regulations (CCR). Compliance with Title 24 is mandatory at the time new building permits are issued by local governments. The City’s administration of the Title 24 requirements includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. Typical Title 24 measures include insulation; use of energy-efficient heating, ventilation and air conditioning equipment (HVAC); solar panels on each residential building; energy-efficient indoor and outdoor lighting systems; reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of skylights, etc. In complying with the Title 24 standards, impacts to peak energy usage periods would be minimized, and impacts on statewide and regional energy needs would be reduced. Thus, operation of the Project would not use large amounts of energy or fuel in a wasteful manner, and no operational energy impacts would occur. As detailed in Table E-8, vehicles and trucks traveling to and from the operational Project site would consume 146,977 gallons of fuel.

Table E-8: Total Project-generated Traffic Annual Fuel Consumption Vehicle Type Annual Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated Annual
Fuel Consumption
(gallons)
Light-Duty Auto 2,267,156 36.03 62,932
Light-Duty Truck 1 263,009 30.05 8,753
Light-Duty Truck 2 780,215 28.99 26,909
Medium-Duty Vehicle 535,612 23.38 22,914
Heavy Light-Duty Truck 1 99,624 14.58 6,834
Heavy Light-Duty Truck 2 27,706 14.79 1,873
Medium Heavy-Duty Truck 51,694 10.89 4,746
Heavy Heavy-Duty Truck 38,583 7.03 5,489
Other Bus 3,424 6.89 497
Urban Bus 2,058 4.73 435
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Motorcycle 104,201 36.90 2,824
School Bus 3,160 8.48 373
Motor Home 15,064 6.28 2,398
Total (All Vehicles) 4,191,506 NA 146,977
Source: Urban Crossroads, 2021 (Appendix C)
As shown in Table E-9, the Project would result in an annual natural gas demand of 10,041,071 thousand British thermal units (kBTU) of natural gas, and approximately 3,577,519 kilowatt-hour (kWh) of electricity.

Table E-9: Project Annual Operational Energy Demand Summary Natural Gas Demand kBTU/year
Apartments 9,447,140
Retail 63,570
Pharmacy 23,635
Quality Restaurant 506,726
Sit-Down Restaurant 3,685,280
Fast-Food Restaurant 3,685,280
Office 126,009
Enclosed Parking with Elevator 0
TOTAL PROJECT NATURAL GAS DEMAND 10,041,071
Electricity Demand kWh/year
Apartments 2,783,080
Retail 509,730
Pharmacy 189,515
Quality Restaurant 95,194
Sit-Down Restaurant 692,320
Fast-Food Restaurant 692,320
Office 152,775
Enclosed Parking with Elevator 2,733,054
TOTAL PROJECT ELECTRICITY DEMAND 3,577,519
kBTU – kilo-British Thermal Units
kWh – Kilo Watt Hours
Source: Urban Crossroads, 2021 (Appendix C)
As such, Project construction and operations would not result in the inefficient, wasteful, or unnecessary consumption of energy. The Project would therefore not cause or result in the need for additional energy producing or transmission facilities. The Project would not engage in wasteful or inefficient uses of energy and aims to achieve energy conservations goals within the State of California. Therefore, impacts would be less than significant.
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Less than Significant Impact. As previously discussed, the City of the Redlands Municipal Code Chapter

15.18 requires that all new residential development comply with the California Green Building Standards, Title 24, Part 11 (CalGreen). CALGreen Code includes provisions related to insulation and design aimed at minimizing energy consumption. In addition, the proposed Project would be consistent with applicable plans related to renewable energy and energy efficiency, including the implementation of solar energy.

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Implementation of the requirements are ensured through the City’s development permitting process. As such, the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would not occur.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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The discussion below is based on the Geotechnical Engineering Report, prepared by Terracon, September 30, 2021 (Terracon 2021) included as Appendix D and the Cultural and Paleontological Resources Assessment for the Redlands Mall Redevelopment Project, prepared by Material Culture Consulting (MCC 2021) and included as Appendix B.

Potentially
Significant Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

7. GEOLOGY AND SOILS. 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?
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss of
topsoil?
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 onor off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
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?
e) Have soils incapable of adequately supporting
the use of septic tanks or alternative waste water
disposal systems where sewers are not available
for the disposal of waste water?
f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
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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?
No Impact. In 1972, the Alquist-Priolo Special Studies Zones Act was signed into law and renamed the Alquist-Priolo Earthquake Fault Zoning Act (A-P Act) in 1994. The primary purpose of the Act is to mitigate the hazard of fault rupture by prohibiting the location of structures for human occupancy access the trace of an active fault. The A-P Act requires the State Geologist (Chief of the California Geology Survey) to delineate “Earthquake Fault Zones” along with faults that are “sufficiently active” and “well-defined.” The boundary of an “Earthquake Fault Zone” is generally about 500 feet from major active faults and 200 to 300 feet from well-defined minor faults. The A-P Act dictates that cities and counties withhold development permits for sites within an Alquist-Priolo Earthquake Zone until geologic investigations demonstrate that the site zones are not threatened by surface displacements from future faulting.

The Project site does not contain and is not in the vicinity of an earthquake fault, is not affected by a statedesignated AP Earthquake Fault Zone. The closest active faults are the San Andreas Fault, which is located approximately 5.2 miles northeast of the site, and the San Jacinto Fault, which is located approximately 4.5 miles southwest of the site. Accordingly, the potential for ground rupture at the site is considered low. Thus, the proposed Project would not expose people or structures to potential substantial adverse effects from rupture of a known earthquake fault that is delineated on an Alquist-Priolo Earthquake Fault Zoning Map, and impacts would not occur.
ii. Strong seismic ground shaking?
Less Than Significant Impact. The Project site is located within a seismically active region of Southern California. As mentioned previously, the San Andreas Fault is located approximately 5.2 northeast of the Project site and the San Jacinto Fault is located approximately 4.5 miles southwest of the Project site. Thus, moderate to strong ground shaking can be expected at the site. The amount of motion can vary depending upon the distance to the fault, the magnitude of the earthquake, and the local geology. Greater movement can be expected at sites located closer to an earthquake epicenter, that consists of poorly consolidated material such as alluvium, and in response to an earthquake of great magnitude.

Structures built in the City are required to be built in compliance with the California Building Code (CBC [California Code of Regulations, Title 24, Part 2]), included in the Municipal Code as Chapter 15.04. In addition, PPP GEO-1 has been included to provide provisions for earthquake safety based on factors including occupancy type, the types of soils onsite, and the probable strength of the ground motion.

Compliance with the CBC would include the incorporation of: 1) seismic safety features to minimize the potential for significant effects as a result of earthquakes; 2) proper building footings and foundations; and 3) construction of the building structures so that it would withstand the effects of strong ground shaking.

Because the proposed Project would be constructed in compliance with the CBC, the proposed Project would result in a less than significant impact related to strong seismic ground shaking. iii. Seismic-related ground failure, including liquefaction? Less Than Significant Impact. Soil liquefaction is a phenomenon in which saturated, cohesionless soils layers, located within approximately 50 feet of the ground surface, lose strength due to cyclic pore water pressure generation from seismic shaking or other large cyclic loading. During the loss of stress, the soil acquires “mobility” sufficient to permit both horizontal and vertical movements. Soil properties and soil conditions such as type, age, texture, color, and consistency, along with historical depths to ground water are used to Redlands Joint Special Meeting of the
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identify, characterize, and correlate liquefaction susceptible soils.

Soils that are most susceptible to liquefaction are clean, loose, saturated, and uniformly graded fine-grained sands that lie below the groundwater table within approximately 50 feet below ground surface. Lateral spreading is a form of seismic ground failure due to liquefaction in a subsurface layer.

According to Redlands General Plan Figure 7-6, the Project site is not located in an area mapped for liquefaction susceptibility; therefore, the potential for liquefaction to occur is low. Additionally, as discussed in the Geotechnical Engineering Investigation, historic groundwater levels are approximately 100 feet below ground surface. Compliance with the CBC, as included as PPP GEO-1, would require specific engineering design recommendations be incorporated into grading plans and building specifications as a condition of construction permit approval to ensure that project structures would withstand the effects of seismic ground movement, including liquefaction and settlement. Compliance with the requirements of the CBC and City’s Municipal Code for structural safety (included as PPP GEO-1) would reduce hazards from seismic-related ground failure, including liquefaction and settlement to a less than significant level. iv. Landslides?
No Impact. Landslides and other slope failures are secondary seismic effects that are common during or soon after earthquakes. Areas that are most susceptible to earthquakes induced landslides are steep slopes underlain by loose, weak soils, and areas on or adjacent to existing landslide deposits.

As described above, the Project site is located in a seismically active region subject to strong ground shaking.

However, the site is located in a relatively flat and developed area. According to the San Bernardino Countywide Plan Policy Map HZ-2, the Project site is not located in an area mapped for landslide risk.

Therefore, the Project would not cause potential substantial adverse effects related to slope instability or seismically induced landslides.
b) Result in soil erosion or the loss of topsoil?
Less Than Significant Impact. In its existing condition, the Project site is developed with a shopping mall, stand-alone commercial building, parking lots, and ornamental vegetation. The Project would involve the demolition of the existing commercial uses and construction of a mixed-use development on the Project site.

During construction activities, soil would be exposed and there would be an increased potential for soil erosion compared to existing conditions. Additionally, during a storm event, soil erosion could occur at an accelerated rate. The increased erosion potential could result in short-term water quality impacts.

As discussed in further detail in Section 10, Hydrology and Water Quality, the proposed Project would increase the impervious surface area on the Project site compared to existing conditions. This would change the volume of stormwater runoff generated from the Project site. However, since the Project site is relatively flat, soil erosion would be controlled via implementation of standard erosion control practices required by a Stormwater Pollution Prevention Plan (SWPPP) during construction (included as PPP WQ-1). Furthermore, the Project would implement SCAQMD Rule 403 (included as PPP AQ-1), which would limit wind erosion during Project construction.

Once developed, the Project’s implementation would not increase the volume of runoff from the Project site because the proposed Project would include landscaped pervious surfaces intended to capture stormwater runoff, as well as new drainage infrastructure designed to accommodate the increase in stormwater runoff, which is further described in Section 10, Hydrology and Water Quality. In addition, implementation of the project requires City approval of a site-specific Water Quality Management Plan (WQMP), which would ensure that the City’s Municipal Code, RWQCB requirements, and appropriate operational BMPs would be implemented to minimize or eliminate the potential for soil erosion or loss of topsoil to occur. As a result, potential impacts related to substantial soil erosion or loss of topsoil would be less than significant.

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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 offsite landslide, lateral spreading, subsidence, liquefaction or collapse?
Less Than Significant Impact. As described above, the Project site is relatively level, and does not contain nor is adjacent to any significant slope or hillside area. The Project would not create slopes. Thus, on or offsite landslides would not occur from implementation of the Project.

Lateral spreading, a phenomenon associated with seismically induced soil liquefaction, is a display of lateral displacement of soils due to inertial motion and lack of lateral support during or post liquefaction. It is typically exemplified by the formation of vertical cracks on the surface of liquefied soils, and usually takes place on gently sloping ground or level ground with nearby free surface such as drainage or stream channel.

According to the Geotechnical Engineering Investigation for the proposed Project, the depth of groundwater is anticipated to be at a depth of 100 feet or greater, therefore, the potential for liquefaction to occur is low to non-existent (Terracon, 2021). Thus, the soils are not susceptible to lateral spreading and impacts related to liquefaction and lateral spreading would be less than significant.

Differential settlement or subsidence could occur if buildings or other improvements are built on low-strength foundation materials (including imported fill) or if improvements straddle the boundary between different types of subsurface materials (e.g., a boundary between native material and fill). Although differential settlement generally occurs slowly enough that its effects are not dangerous to inhabitants, it can cause building damage over time. Soils susceptible to seismically induced settlement typically include loose, granular materials (Terracon, 2021).

With implementation of the requirements of the CBC, as included as PPP GEO-1, the potential for settlement or collapse of soils is considered low (Terracon, 2021). Therefore, compliance with the requirements of the CBC as identified in the site geotechnical design recommendations that would be reviewed by the City for appropriate inclusion, as part of the building plan check and development review process, would reduce potential impacts related to ground collapse to a less than significant level. 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? Less Than Significant Impact. Expansive soils contain certain types of clay minerals that shrink or well as the moisture content changes; the shrinking or swelling can shift, crack, or break structures built on such soils.

Arid or semiarid areas with seasonal changes of soil moisture experiences, such as southern California, have a higher potential of expansive soils than areas with higher rainfall and more constant soil moisture.

The Geotechnical Engineering Investigation performed an evaluation of the potential for expansive soils at the site and expansion index testing was performed on representative samples of the near surface soils which are anticipated to be within the zone of influence of the planned improvements. The Investigation found that the site has approximately 3 to 9.5 feet of fill material across the majority of the site. As discussed in the Geotechnical Engineering Investigation, all onsite soils and engineered fill soils would be required to meet CBC expansion index requirements, included as PPP GEO-1. As required by PPP GEO-1, specific engineering design recommendations would be incorporated into grading plans and building specifications as a condition of construction permit approval to ensure that Project structures would withstand the effects of related to ground movement, including expansive soils. Thus, impacts related to expansive soils would be less than significant.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? No Impact. The Project would not use septic tanks or alternative methods for disposal of wastewater into subsurface soils. Furthermore, the proposed Project would connect to existing public wastewater Redlands Joint Special Meeting of the
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infrastructure. Therefore, the Project would not result in any impacts related to septic tanks or alternative wastewater disposal methods.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Less than Significant with Mitigation Incorporated. As mentioned previously, the proposed Project is located on a previously disturbed site within an urbanized area of the City of Redlands. As discussed within the Cultural and Paleontological Resources Assessment prepared for the Project site, the site soils consist of younger and older surficial deposits, more specifically very young wash deposits, active (Qvyw), old alluvialfan deposits, Unit 3 (Qof3), and very old axial-valley deposits, Unit 3 (Qvoa3).

Very young surficial deposits are the result of recently transported and deposited sediment into channels and washes on surfaces of alluvial fans, alluvial plains, and on hill slopes. Older surficial deposits contain sedimentary units that are moderately consolidated and slightly to moderately dissected. Alluvial-fan deposits (Qof series) are gravelly sand and silt sediments. Very old surficial deposits are sedimentary units that are moderately to well consolidated to lithified, and moderately to well dissected. Valley-filling deposits (Qvoa series) are dominated by sand with minor gravel alluvial deposits and includes residuum or pedogenic-soil profile developed on the San Timoteo Formation beds. The San Timoteo Badlands area and the western portion of the City of Redlands have a high potential to produce significant paleontological resources.

A records search at the Natural History Museum of Los Angeles County did not identify any previous finds of vertebrate fossil localities within the Project site. However, records of vertebrate fossil localities have been found in other local sedimentary deposits similar to those that occur on the Project site. Previous finds include a vertebrate fossil locality from somewhat similar deposits is located approximately 8 to 10 miles south of the Project site. The locality came from the San Timoteo Formation and consisted of vertebrates belonging to the horse and camel family at an unknown depth. Additional literature was consulted, including The University of California Museum of Paleontology (UCMP)’s Miocene Mammal Mapping Project (MioMap), resulting in eight fossil localities from the San Timoteo Formation located approximately five miles southsoutheast of the Project site.

Therefore, Project related excavations that extend down into older Quaternary deposits may encounter fossil vertebrates. As a result, Mitigation Measure PAL-1 is included to require that any substantial excavations below three feet be monitored to identify and recover any significant fossil remains. With implementation of Mitigation Measure PAL-1, impacts to paleontological resources would be less than significant.

Project Design Features
None.

Existing Plans, Programs, or Policies
PPP GEO-1: California Building Code. The Project is required to comply with the California Building Code as included in the City’s Municipal Code Chapter 15.04 to preclude significant adverse effects associated with seismic hazards. California Building Code related and geologist and/or civil engineer specifications for the Project are required to be incorporated into grading plans and specifications as a condition of Project approval.

PPP WQ-1: SWPPP. As listed below in Section 10, Hydrology and Water Quality.

Mitigation Measures
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MM PAL-1: Paleontological Resources. Prior to the issuance of the first grading permit, the applicant shall provide a letter to the City of Redlands Planning Department, or designee, from a paleontologist selected from the roll of qualified paleontologists maintained by the County, stating that the paleontologist has been retained to provide services for the project. The paleontologist shall develop a Paleontological Resources Impact Mitigation Plan (PRIMP) to mitigate the potential impacts to unknown buried paleontological resources that may exist onsite for the review and approval by the City. The PRIMP shall require that the paleontologist be present at the pre-grading conference to establish procedures for paleontological resource surveillance. The PRIMP shall also require paleontological monitoring for ground disturbing activities greater than five feet in depth within native soil, as determined by the Project paleontologist.

In the event paleontological resources are encountered, ground-disturbing activity within 50 feet of the area of the discovery shall cease. The paleontologist shall examine the materials encountered, assess the nature and extent of the find, and recommend a course of action to further investigate and protect or recover and salvage those resources that have been encountered.

Criteria for discard of specific fossil specimens will be made explicit. If a qualified paleontologist determines that impacts to a sample containing significant paleontological resources cannot be avoided by project planning, then recovery may be applied. Actions may include recovering a sample of the fossiliferous material prior to construction, monitoring work and halting construction if an important fossil needs to be recovered, and/or cleaning, identifying, and cataloging specimens for curation and research purposes.

Recovery, salvage and treatment shall be done at the Applicant’s expense. All recovered and salvaged resources shall be prepared to the point of identification and permanent preservation by the paleontologist. Resources shall be identified and curated into an established accredited professional repository. The paleontologist shall have a repository agreement in hand prior to initiating recovery of the resource.

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The discussion below is based on the State Street Village Greenhouse Gas Analysis, prepared by Urban Crossroads, included as Appendix E.

Technical Background
Constituent gases of the Earth’s atmosphere, called atmospheric greenhouse gases (GHGs), play a critical role in the Earth’s radiation amount by trapping infrared radiation from the Earth’s surface, which otherwise would have escaped to space. Prominent greenhouse gases contributing to this process include carbon dioxide (CO2), methane (CH4), ozone (O3), water vapor, nitrous oxide (N2O), and chlorofluorocarbons (CFCs).

This phenomenon, known as the Greenhouse Effect, is responsible for maintaining a habitable climate.

Anthropogenic (caused or produced by humans) emissions of these greenhouse gases in excess of natural ambient concentrations are responsible for the enhancement of the Greenhouse Effect and have led to a trend of unnatural warming of the Earth’s natural climate, known as global warming or climate change.

Emissions of gases that induce global warming are attributable to human activities associated with industrial/manufacturing, agriculture, utilities, transportation, and residential land uses.

Section 15364.5 of the California Code of Regulations defines GHGs to include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride 1. Emissions of CO2 and N2O are byproducts of fossil fuel combustion. Methane, a potent greenhouse gas, results from off-gassing associated with agricultural practices and landfills. Sinks of CO2, where CO2 is stored outside of the atmosphere, include uptake by vegetation and dissolution into the ocean.

California has passed several bills and the Governor has signed at least three executive orders regarding greenhouse gases. These regulations require the use of alternative energy, such as solar power. The California Energy Commission passed a measure as an update to the state’s 2019 Title 24, Part 6, Building Energy Efficiency Standards, which requires that all new homes under three stories high install solar panels starting January 1, 2020, and that solar systems must be sized to net out the annual kilowatt-hour energy usage of the dwelling 2. All new residential projects under three stories, including the proposed project, are required to comply with these new standards.

GHG Thresholds
The City of Redlands has an adopted Climate Action Plan (CAP)3, which was adopted December 5, 2017.

The 2017 Scoping Plan was prepared to meet the most current GHG emissions reduction targets set in Executive Order S‐3‐15 and SB 32 that recommends local governments to develop plans to reduce GHG 1 Section 38505(g), Health and Safety Code; and Section 21083.05, Public Resources Code 2 2019 California Energy Code, Title 24, Part 6, Section 110.10(b), https://codes.iccsafe.org/content/CAEC2019/subchapter-2-all-occupanciesmandatory-requirements-for-the-manufacture-construction-and-installation-of-systems-equipment-and-building-components 3 City of Redlands, 2017. Climate Action Plan.

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact

8. GREENHOUSE GAS EMISSIONS. Would
the Project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
emissions of greenhouse gases?
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emissions to 6 MTCO2e per capita per year by the year 2030 and 2 MTCO2e per capita per year by the year 2050. Since the CAP was prepared in coordination with the General Plan that has a horizon year of 2035, the Redlands CAP also provided a year 2035 target of 5 MTCO2e per capita per year, which was determined through interpolation of the 2030 and 2050 GHG emissions targets from the 2017 Scoping Plan.

Since the Project is anticipated to be fully operational by 2026, the proposed Project would be considered to create a significant cumulative GHG impact if implementation of the Project would exceed 6 MTCO2e per year per service population.

In addition, SCAQMD methodology for Project’s construction are to average them over 30-years and then add them to the Project’s operational emissions to determine if the Project would exceed the screening values listed above.
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant Impact. GHG emissions associated with Project construction would occur over the short term and would consist primarily of emissions from equipment exhaust. Long-term regional emissions would also be associated with new vehicular trips and stationery-source emissions (i.e., natural gas used for heating and electricity usage for lighting). The calculations presented below include construction emissions in terms of annual CO2e GHG emissions from increased energy consumption, water usage, and solid waste disposal, as well as estimated GHG emissions from vehicular traffic that would result from implementation of the proposed Project.

As discussed previously, during construction of the proposed Project, GHGs would be emitted through the operation of construction equipment, as well as emissions from worker and vendor vehicles, each of which typically uses fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

During operations, the Project would generate long-term GHG emissions from vehicular trips; water, natural gas, and electricity consumption; and solid waste generation. Mobile-source emissions of GHGs would include project generated vehicle trips associated with resident trips to and from the project site. Area-source emissions would be associated with activities such as landscaping and maintenance of proposed land uses, natural gas for cooking and heating, and other sources. Increases in stationary-source emissions would also occur at off-site utility providers as a result of demand for electricity, natural gas, and water by the proposed use.

The annual GHG emissions associated with the operation of the proposed Project are estimated to be approximately 4,606.4 MT CO2e/yr as summarized in Table GHG-1. The Project is estimated to have a service population of 1,388. This would result in an efficiency of 3.33 MT CO2e/SP. This would be below the 6.0 MT CO2e/service population threshold used by the City of Redlands. As such, a less than significant impact related to greenhouse gas emissions would result from the Project.

Table GHG-1: Total Project GHG Emissions
Emission Source Emissions (MT/yr)
CO2 CH4 N2O Total CO2e
Annual construction-related emissions amortized over 30 years 217.74 0.02 0.01 221.30 Area 12.21 0.01 0.00 12.51
Energy 2,327.68 0.14 0.03 2,340.42
Mobile 1,341.72 0.09 0.06 1,362.84
Waste 167.26 9.88 0.00 414.37
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Water Use 200.91 1.67 0.04 254.99
Total CO2e (All Sources) 4,606.43
Service Population 1,388.08
Project Efficiency 3.32
Efficiency Threshold 6.00
Exceed Efficiency Threshold? No
Source: Urban Crossroads, 2021 (Appendix E)
-- = Emission factor only provided in MT CO2e
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
No Impact. The Project would involve the demolition of the existing commercial buildings and construction of a mixed-use development on the Project site. In 2006, the California State Legislature adopted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires CARB to adopt rules and regulations that would achieve GHG emissions equivalent to statewide levels in 1990 by 2020 through an enforceable statewide emission cap, which was phased in starting in 2012. Therefore, as the proposed Project meets the current City thresholds for GHG emissions per service population, it would also be on track to meet the reduction target of 40 percent below 1990 levels by 2030, as mandated by the State. Furthermore, all of the post-2020 reductions in GHG emissions are addressed via regulatory requirements at the State level, and the proposed Project would be required to comply with these regulations as they come into effect.

As discussed previously, the City of Redlands has an adopted Climate Action Plan (CAP) 4, which was adopted December 5, 2017. Executive Order S‐3‐15 and SB 32 that recommends local governments to develop plans to reduce GHG emissions to 6 MTCO2e per capita per year by the year 2030 and 2 MTCO2e per capita per year by the year 2050. Since the CAP was prepared in coordination with the General Plan that has a horizon year of 2035, the Redlands CAP also provided a year 2035 target of 5 MTCO2e per capita per year, which was determined through interpolation of the 2030 and 2050 GHG emissions targets from the 2017 Scoping Plan. Emissions from vehicles, which are the main source of operational GHG emissions associated with the Project (as shown in Table GHG-1), would be reduced through implementation of the state and federal fuel and vehicle emission standards. In addition, the Project would not exceed 6 MTCO2e per capita, as shown in Table GHG-1. Therefore, implementation of the proposed Project would not conflict with existing plans, policies, and regulations adopted for the purpose of reducing the emissions of greenhouse gas.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.
4 City of Redlands, 2017. Climate Action Plan.

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The discussion below is based on the Phase I Environmental Site Assessment, prepared by Partner Engineering and Science, Inc., included as Appendix F.
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less Than Significant Impact. A hazardous material is defined as any material that, due to its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous wastes, and any material that regulatory agencies have Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

9. HAZARDS AND HAZARDOUS
MATERIALS. Would the Project:
a) Create a significant hazard to the public or
the environment through the routine transport,
use, or disposal of hazardous materials?
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?
c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of
an existing or proposed school?
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?
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?
f) Impair implementation of or physically
interfere with an adopted emergency response
plan or emergency evacuation plan?
g) Expose people or structures, either directly
or indirectly, to a significant risk of loss, injury
or death involving wildland fires?
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a reasonable basis for believing would be injurious to the health and safety of persons or harmful to the environment if released into the home, workplace, or environment. Hazardous wastes require special handling and disposal because of their potential to damage public health and the environment.

Construction
The proposed construction activities would involve the transport, use, and disposal of hazardous materials such as paints, solvents, oils, grease, and caulking. In addition, hazardous materials would be needed for fueling and servicing construction equipment on the site. These types of materials are not acutely hazardous, and all storage, handling, use, and disposal of these materials are regulated by federal and state requirements, which the project construction activities are required to strictly adhere to. These regulations include: the federal Occupational Safety and Health Act and Hazardous Materials Transportation Act; Title 8 of the California Code of Regulations (CalOSHA), and the state Unified Hazardous Waste and Hazardous Materials Management Regulatory Program. As a result, the routine transport, use or disposal of hazardous materials during construction activities of the project would be less than significant.

Operation
The Project involves construction of 700 residential units; 71,778 SF of ground floor commercial retail; 12, 328 SF of upper floor commercial and office space; and a 14,500 SF outparcel drug store. Residential and commercial uses typically do not present a hazard associated with the accidental release of hazardous substances into the environment because residents and retail/office employees are not anticipated to use, store, dispose, or transport large volumes of hazardous materials. Typically used hazardous materials include solvents, cleaning agents, paints, pesticides, batteries, fertilizers, and aerosol cans. These types of materials are not acutely hazardous and would only be used and stored in limited quantities within the residential and commercial buildings. The normal routine use of these hazardous materials products pursuant to existing regulations would not result in a significant hazard to people or the environment in the vicinity of the Project.

Therefore, the Project would not result in a significant hazard to the public or to the environment through the routine transport, use, or disposal of hazardous waste, and impacts would be less than significant. 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? Less Than Significant Impact.

Construction
Accidental Releases. While the routine use, storage, transport, and disposal of hazardous materials in accordance with applicable regulations during construction activities would not pose health risks or result in significant impacts; improper use, storage, transportation and disposal of hazardous materials and wastes could result in accidental spills or releases, posing health risks to workers, the public, and the environment.

To avoid an impact related to an accidental release, the use of best management practices (BMPs) during construction are implemented as part of a Stormwater Pollution Prevention Plan (SWPPP) as required by the National Pollution Discharge Elimination System General Construction Permit (and included as PPP WQ-1).

Implementation of an SWPPP would minimize potential adverse effects to workers, the public, and the environment. Construction contract specifications would include strict on-site handling rules and BMPs that include, but are not limited to:
• Establishing a dedicated area for fuel storage and refueling and construction dewatering activities that includes secondary containment protection measures and spill control supplies; • Following manufacturers’ recommendations on the use, storage, and disposal of chemical products used in construction;
• Avoiding overtopping construction equipment fuel tanks; • Properly containing and removing grease and oils during routine maintenance of equipment; and • Properly disposing of discarded containers of fuels and other chemicals.

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Underground Storage Tanks. As discussed in the Phase I Environmental Site Assessment, there is potential for multiple underground storage tanks (UST) to exist onsite due to the past operation of the site as a gas station. Based on a review of historic Sanborn maps, several gas stations existed onsite from approximately 1949 until 1955. No information pertaining to these facilities including the exact location of USTs, installation or removal dates, tank capacity or construction was found during preparation of the Phase I Environmental Site Assessment. Based on the length of time that the subject property had been utilized as a gasoline service station, and absent the data confirming whether a release had occurred following the removal of any USTs, it is possible that petroleum hydrocarbons may have impacted the subsurface soils of the subject property.

However, with adherence to California UST Regulations (Title 23, Chapter 16 of the California Code of Regulation), included as PPP HAZ-1, impacts related to USTs would be less than significant.

Asbestos-Containing Materials. The use of asbestos-containing materials (a known carcinogen) and lead paint (a known toxin) was common in building construction prior to 1978 (the use of asbestos-containing materials in concrete products was common through the 1950s). Asbestos is a carcinogen and is categorized as a hazardous air pollutant by the federal Environmental Protection Agency (EPA). Federal asbestos requirements are found in the Code of Federal Regulations (CFR) Title 40, Part 61, Subpart M, and are enforced in the project area by the SCAQMD. SCAQMD Rule 1403 establishes survey requirements, notification, and work practice requirements to prevent asbestos emissions from emanating during building renovation and demolition activities.

Based on the age of the onsite buildings, it is possible that asbestos-containing building materials are present in the existing structures on the Project site. As a result, asbestos surveys and abatement would be required prior to demolition of the existing building pursuant to the existing SCAQMD, Cal/OSHA, and Section 19827.5 of the California Health and Safety Code requirements.

SCAQMD Rule 1403 requires notification of the SCAQMD prior to commencing any demolition or renovation activities that involve asbestos containing materials. Rule 1403 also sets forth specific procedures for the removal of asbestos and requires that an onsite representative trained in the requirements of Rule 1403 be present during the stripping, removing, handling, or disturbing of asbestos-containing materials. Mandatory compliance with the provisions of Rule 1403 would ensure that construction-related grading, clearing and demolition activities do not expose construction workers or nearby sensitive receptors to significant health risks associated with asbestos-containing materials. With compliance with AQMD Rule 1403, potential impacts related to asbestos being released into the environment would be less than significant.

Lead Based Paint. Based on the age of the existing commercial buildings, it is also possible that lead-based paint may be present. Pursuant to existing regulations, a lead-based paint survey shall be completed prior to any activities with the potential to disturb suspected lead based painted surfaces. The regulations specify actions to manage and control exposure to lead-based paint (per the Code of Federal Regulations Title 29, Section 1926.62 and California Code of Regulations Title 8 Section 1532.1) that cover the demolition, removal, cleanup, transportation, and disposal of lead-containing material. The regulations outline the permissible exposure limit, protective measures, monitoring and compliance to ensure the safety of construction workers exposed to lead-based materials. In addition, Cal/OSHA’s Lead in Construction Standard requires the project to develop and implement a lead compliance plan when lead-based paint would be disturbed during construction. The plan must describe activities that could emit lead, methods for complying with the standard, safe work practices, and a plan to protect workers from exposure to lead during construction activities. Cal/OSHA requires 24-hour notification if more than 100 square feet of leadbased paint would be disturbed. With compliance to the Cal/OSHA requirements, potential impacts related to lead-based paint being released into the environment would be less than significant.

Operation
Operation of the proposed multi-family residences, commercial and office uses, and associated areas involve use and storage of common hazardous materials such as paints, solvents, cleaning products, fuels, lubricants, adhesives, sealers, and pesticides/herbicides. Normal routine use of these typical commercially used products pursuant to existing regulations would not result in a significant hazard to the environment, residents, or workers in the vicinity of the Project.

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c) Emit hazardous emissions or handle hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
Less Than Significant Impact. As described previously, the proposed mixed-use Project would not produce hazardous emissions or handle acutely hazardous materials, substances, or wastes. The nearest schools to the Project site are McKinley Elementary School located at 645 W. Olive Avenue, which is 0.39-mile from the Project site, and Redlands High School located at 840 E. Citrus Avenue, which is 0.52-mile from the Project site. As such, the Project site is not located within one-quarter mile of any existing or proposed schools.

Therefore, the Project would not emit hazardous emissions or handle hazardous materials, substances, or waste within one-quarter mile of a school and impacts would be less than significant. 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?
Less Than Significant Impact. According to the California Department of Toxic Substances Control (DTSC) EnviroStor database, the Project site is not located on a federal Superfund site, State response site, voluntary cleanup site, school cleanup site, corrective action site, or tiered permit site (DTSC 2021). However, the Project site is identified by the State Water Resources Control Board GeoTracker as having a former leaking underground storage tank. In 1987 a leak of diesel fuel associated with an underground storage tank was reported, cleaned up, and reported as closed (SWRCB 2021). As such, the leaking underground storage tank no longer poses a hazard to the public or the environment. However, according to the Phase I ESA, absent the data confirming whether a release had occurred following the removal of any USTs, it is possible that petroleum hydrocarbons may have impacted the subsurface soils of the subject property. As such, Project-specific MM HAZ-1 is included to require the applicant to pay for the removal of any UST that is encountered during construction activities and requires further soil sampling and remediation if potentially impacted soils are encountered. With implementation of MM HAZ-1, impacts related to existing USTs would be less than significant.

Therefore, the proposed Project would result in less than significant impacts related to a known hazardous materials site pursuant to Government Code Section 65965.5 and would not create a significant hazard to the public or the environment.
e) For a project 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? No Impact. The proposed Project is not within an airport land use plan; however, the proposed Project is located approximately 2.45 miles southwest from the Redlands Municipal Airport. According to the Figure 7-7: Airport Hazards, within the City’s General Plan, the Project site is not within a A: Runway Protection Zone, B1: Approach/Departure Zone, B2: Extended Approach/Departure Zone, C: Common Traffic Pattern, D: Other Airport Environ, or within an Area of Special Compatibility Concern. Additionally, the proposed mixed-use development would be a maximum of five stories and approximately 59 ft in height at the parapet. Thus, the residential development would not be of a sufficient height to require modifications to the existing air traffic patterns at the airport and would not affect aviation traffic levels or otherwise result in substantial aviation-related safety risks. Therefore, the proposed Project would not result in an impact to an airport land use plan and would not result in a safety hazard or excessive noise for people residing or working in the Project area.
f) Impair implementation of an adopted emergency response plan or emergency evacuation plan? Less Than Significant Impact. The proposed Project would not physically interfere with an adopted emergency response plan or emergency evacuation plan.

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Construction
The proposed construction activities, including equipment and supply staging and storage, would occur within the Project site, and would not restrict access of emergency vehicles to the Project site or adjacent areas. The installation of new driveways and connections to existing infrastructure systems that would be implemented during construction of the proposed Project would not require closure of Redlands Boulevard, Eureka Street, W Citrus Avenue, or Orange Street. Any temporary lane closures needed for utility connections or driveway construction would be required to implement appropriate measures to facilitate vehicle circulation, as included within construction permits. Thus, implementation of the project through the City’s permitting process would ensure existing regulations are adhered to and would reduce potential construction related emergency access or evacuation impacts to a less than significant level.

Operation
Direct access to the Project site would be provided from driveways along Redlands Boulevard, Eureka Street, Third Street, and the public alley. The project driveways and internal access would be required through the City’s permitting procedures to meet the City’s design standards to ensure adequate emergency access and evacuation. The Project is also required to provide fire suppression facilities (e.g., hydrants and sprinklers).

The Fire Department and/or Public Works Department would review the development plans as part of the permitting procedures to ensure adequate emergency access pursuant to the requirements in Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9), included as Municipal Code Chapter 15.20. As such, the Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan, and impacts would be less than significant.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
No Impact. The Project site is within an urbanized area of the City of Redlands. The Project site is bounded by W Redlands Boulevard to the north, Orange Street and Fourth Street to the east, Eureka Street to the west, and Citrus Avenue and a public alleyway to the south. The Project site is not adjacent to any wildland areas. According to the CAL FIRE Fire Hazard Severity Zone map, the Project site is not within an area identified as a Fire Hazard Area that may contain substantial fire risk or a Very High Fire Hazard Severity Zone (VHFHSZ) (CAL FIRE 2021). As a result, the proposed Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

Project Design Features
None.

Existing Plans, Programs, or Policies
PPP HAZ-1: California UST Regulations. Underground storage tank (UST) repairs and/or removals will be conducted in accordance with the California UST Regulations (Title 23, Chapter 16 of the California Code of Regulations). Any unauthorized release of hazardous materials will require release reporting, initial abatement, and corrective actions that will be completed with oversight from the Regional Water Quality Control Board, Department of Toxic Substances Control, Riverside County Environmental Health Division, South Coast Air Quality Management District, and/or other regulatory agencies, as necessary. Use of existing USTs will also have to be conducted (i.e., used, maintained and monitored) in accordance with the California UST Regulations (Title 23, Chapter 16 of the California Code of Regulations).

PPP WQ-1: SWPPP. As listed below in Section 10, Hydrology and Water Quality.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

10. HYDROLOGY AND WATER QUALITY.

Would the Project:
a) Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface or ground water
quality?
b) Substantially decrease groundwater supplies
or interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the
basin?
c) Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or river
or through the addition of impervious surfaces,
in a manner which would:
i) result in substantial erosion or siltation on- or
off-site;
ii) substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or offsite;
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; or
iv) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
The discussion below is based on the Preliminary Water Quality Management Plan, prepared by Proactive Engineering Consultants, Inc., October 6, 2021, included as Appendix G. a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Less Than Significant Impact. The proposed Project involves demolition of three existing commercial buildings, pavement, infrastructure, and construction of a mixed-use development on the Project site.

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Construction
Construction of the Project would require grading and excavation of soils, which would loosen sediment, and then have the potential to mix with surface water runoff and degrade water quality. Pollutants of concern during Project construction include sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and transport of sediment downstream compared to existing conditions. During a storm event, soil erosion could occur at an accelerated rate. In addition, constructionrelated pollutants, such as chemicals, liquid and petroleum products (e.g., paints, solvents, and fuels), and concrete-related waste, could be spilled, leaked, or transported via stormwater runoff into adjacent drainages and into downstream receiving waters.

Construction of the Project would disturb more than one acre of soil; therefore, the proposed Project would be required to obtain coverage under the NPDES General Permit for Discharges of Storm Water Associated with Construction Activity. Construction of the Project would disturb more than one acre of soil; therefore, the proposed Project would be required to obtain coverage under the NPDES General Permit for Discharges of Storm Water Associated with Construction Activity. Construction activity subject to this permit includes clearing, grading, and ground disturbances such as trenching, stockpiling, or excavation. The Construction General Permit requires implementation of a stormwater pollution prevention plan (SWPPP) that is required to identify all potential sources of pollution that are reasonably expected to affect the quality of storm water discharges from the construction site. The SWPPP would generally contain a site map showing the construction perimeter, proposed buildings, stormwater collection and discharge points, general pre- and post-construction topography, drainage patterns across the site, and adjacent roadways. The SWPPP would also include construction Best Management Practices (BMPs) such as:
• Maximize the permeable area,
• Incorporate landscaped buffer areas,
• Maximize canopy interception with drought tolerant landscaping • Low flow infiltration within sand filter zones
• Site design with minimum design standards
• Landscape design with minimum to no impervious surfaces • Isolated roof run-off into proposed Treatment Control Facility Adherence to the Construction General Permit requirements and implementation of the appropriate BMPs as ensured through the City’s construction permitting process are included as PPP WQ-1, which would ensure that the Project would not violate any water quality standards or waste discharge requirements. Potential water quality degradation associated with construction activities would be minimized, and impacts would be less than significant.

Operation
The proposed Project would include operation of multi-family residences and commercial retail uses, which would introduce the potential for pollutants such as, chemicals from cleaners, pesticides and sediment from landscaping, trash and debris, and oil and grease from vehicles. These pollutants could potentially discharge into surface waters and result in degradation of water quality. However, in accordance with the County of San Bernardino and the NPDES Areawide Stormwater Program, the proposed Project would be required to incorporate a WQMP with post-construction (or permanent) Low Impact Development (LID) site design, source control, and treatment control BMPs. The LID site design would minimize impervious surfaces and provide infiltration of runoff into landscaped areas.

The source control BMPs would minimize the introduction of pollutants that may result in water quality impacts; and treatment control BMPs that would treat stormwater runoff. The proposed Project would install an onsite storm drain system that would convey runoff to a pre-treatment unit then to an underground infiltration/detention system. This system would remove coarse sediment, trash, and pollutants (i.e., sediments, nutrients, heavy metals, oxygen demanding substances, oil and grease, bacteria, and pesticides). The Redlands Joint Special Meeting of the
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additional types of BMPs that would be implemented as part of the proposed project are listed in Table HYD-1.

Table HYD-1: Types of BMPs Incorporated into the Project Design Type of BMP Description of BMPs
LID Site
Design
Optimize the site layout: The site has been designed so that runoff from impervious surfaces would flow to landscaping areas or to the pre-treatment unit then to the underground infiltration/detention systems.

Use pervious surfaces: 74,835 SF of landscaping is incorporated into the Project design to increase the amount of pervious area and onsite retention of stormflows. Additionally, the Project would include planter boxes throughout the site.

Source
Control
Storm Drain Stenciling: All inlets/catch basins would be stenciled with the words “Only Rain Down the Storm Drain,” or equivalent message.

Need for future indoor & structural pest control: The buildings would be designed to avoid openings that would encourage entry of pests to minimize the use of pesticides.

Landscape/outdoor pesticide use: Final landscape plans would accomplish all of the following:
• Design landscaping to minimize irrigation and runoff, to promote surface infiltration where appropriate, and to minimize the use of fertilizers and pesticides that can contribute to storm water pollution. • Consider using pest-resistant plants, especially adjacent to hardscape. • To ensure successful establishment, select plants appropriate to site soils, slopes, climate, sun, wind, rain, land use, air movement, ecological consistency, and plant interactions
Roofing, gutters and trim: The architectural design would avoid roofing, gutters, and trim made of copper or other unprotected metals that may leach into runoff.

Sidewalks and parking lots: Sidewalks and parking lots shall be swept regularly to prevent the accumulation of litter and debris. Debris from pressure washing would be collected to prevent entry into the storm drain system. Wash water containing any cleaning agent or degreaser would be collected and discharged to the sanitary sewer and not discharged to a storm drain.

Treatment
Control
The pre-treatment unit and infiltration/detention systems proposed for the Project would detain runoff, filter it prior to discharge.

With implementation of the operational source and treatment control BMPs that are outlined in the preliminary WQMP (Appendix G) that would be reviewed and approved by the City during the project permitting and approval process, potential pollutants would be reduced to the maximum extent feasible, and implementation of the proposed project would not substantially degrade water quality. Therefore, impacts would be less than significant.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? Less Than Significant Impact. The proposed Project would not deplete groundwater supplies. The Project site is underlain by the Bunker Hill Subbasin and Yucaipa Subbasin. The City extracts water from the Bunker Redlands Joint Special Meeting of the
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Hill Subbasin and Yucaipa Subbasin (UWMP 2015). The groundwater from Bunker Hill totals 51.1% of the City’s annual water production. Water pumping from the Bunker Hill Subbasin is adjudicated, which limits the allowable groundwater extraction to ensure a safe yield. Because the groundwater basin is managed through this plan, which limits the allowable withdrawal of water from the basin by water purveyors, and the Project would not pump water from the Project area (as water supplies would be provided by the City), the proposed Project would not result in a substantial depletion of groundwater supplies.

In addition, development of the proposed Project would result in large areas of impervious surfaces on the Project site. However, the Project would install an onsite storm drain system that would convey runoff to infiltration basins within the parking structures or modular wetland systems. In addition, the Project includes 74,835 SF of landscaping that would infiltrate stormwater onsite. Stormwater capture would be compliant with the Design Capture Volume (DCV) requirements of the the San Bernardino County Stormwater Program through the implementation of infiltration, biotreatment, and Water Quality Credits. As a result, the proposed Project would not decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. The proposed Project would have a 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 river or through the addition of impervious surfaces, in a manner which would:
i. result in substantial erosion or siltation on- or off-site; Less Than Significant Impact. As described previously, existing regulations require the project to implement a project specific SWPPP during construction activities, that would implement erosion control BMPs, such as silt fencing, fiber rolls, or gravel bags, stabilized construction entrance/exit, hydroseeding, etc. to reduce the potential for siltation or erosion during Project construction. In addition, the Project is required to implement a WQMP, included as PPP WQ-2, that would provide operational BMPs to ensure that operation of the multi-family residences would not result in erosion or siltation. With implementation of these regulations, impacts related to erosion or siltation onsite or off-site would be less than significant. ii. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
Less Than Significant Impact. As discussed previously, the Project would install an onsite storm drain system that would convey runoff to modular wetland systems or to an underground infiltration/detention system that would capture and filter runoff. In addition, the project includes 74,835 SF of landscaping that would capture stormwater onsite. These drainage facilities have been designed to accommodate the Project. The drainage facilities in drainage management area (DMA) 1 of the site have been designed to accommodate 8,670 cubic feet of stormwater, DMA 2 has been designed to accommodate 12,660 cubic feet of stormwater, and DMA 3 has been designed to accommodate 4,320 cubic feet of stormwater. Additional stormwater capture and treatment methods such as biotreatment and Water Quality Credits would be applied to comply with San Bernardino County Stormwater Program requirements. As such, impacts related to flooding resulting from alteration of drainage patterns would be less than significant. 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; or
Less Than Significant Impact. As discussed previously in Response 6.3.10(a), construction of the proposed Project has the potential to introduce pollutants to the storm drainage system from erosion, siltation, and accidental spills. However, as required by PPP WQ-1, a SWPPP would be implemented to reduce potential impacts to water quality, including those impacts associated with soil erosion, siltation, and spills, so as not to provide additional sources of polluted runoff to the storm drain system. Therefore, construction impacts Redlands Joint Special Meeting of the
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related to the provision of substantial additional sources of polluted runoff would be less than significant, and no mitigation is required.

The Project would remove the existing storm drain in Lot 2 and install new storm drain lines throughout the site and within the 3rd Street and State Street extensions. Additionally, the Project would install multiple planter boxes for stormwater infiltration (74,835 SF of landscaping) and an infiltration chamber under the proposed public plaza at the terminus of State Street. Courtyards above proposed parking garages would drain to chambers in the garages where stormwater would then be pumped to the infiltration chamber. The existing Mill Creek Zanja Channel Easement would be protected in place. These drainage facilities have been designed to accommodate the Project and would reduce potential additional sources of polluted runoff to a less than significant level.
iv. impede or redirect flood flows?
Less Than Significant Impact. According to FEMA’s FIRM Flood Map, the majority of the Project site is located in Flood Zone AO, which means the Project site has the potential for shallow flooding during 100- year storm events. Since the proposed Project is partially within Zone AO, it must comply with City of Redlands Municipal Code Chapter 15.32, Flood Damage Prevention. Compliance measures include constructing occupiable building floors at least 2 feet above the estimated 100-year flood level to limit impacts from flooding. With compliance with Municipal Code Chapter 15.32, the proposed Project would not impede or redirect flood flows and impacts would be less than significant. d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? Less Than Significant Impact. According to FEMA’s FIRM Flood Map, the majority of the Project site is located in Flood Zone AO, which means the Project site has the potential for shallow flooding during 100- year storm events. Since the proposed Project is partially within Zone AO, it must comply with City of Redlands Municipal Code Chapter 15.32, Flood Damage Prevention. With compliance with Municipal Code Chapter 15.32, the proposed Project would not risk release of pollutants due to Project inundation and impacts would be less than significant.

Tsunamis are generated ocean wave trains generally caused by tectonic displacement of the sea floor associated with shallow earthquakes, sea floor landslides, rock falls, and exploding volcanic islands. The proposed Project is approximately 50 miles from the ocean shoreline. Based on the inland location of the Project site, the Project site is not at risk of inundation from tsunami. Therefore, the proposed Project would not risk release of pollutants from inundation from a tsunami and no impacts would occur.

A seiche is a phenomenon that occurs when seismic ground shaking induces standing waves inside water retention facilities (e.g., reservoirs and lakes). Such waves can cause retention structures to fail and flood downstream properties. The Project site is not located adjacent to any water retention facilities. For this reason, the Project site is not at risk of inundation from seiche waves. Therefore, the proposed Project would not risk release of pollutants from inundation from seiche and no impacts would occur. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less Than Significant Impact. The Project site is partially developed, and the proposed Project would result in a substantial increase of imperviousness. As described above, the proposed storm drain system is sized to adequately accommodate increased stormwater flows from the Project area and would maintain the existing drainage pattern of the site. Runoff would discharge into one of onsite infiltration basins or planter boxes, which would retain, slow, and/or filter the runoff before its discharge through new storm drain connections to the existing storm drain infrastructure.

As described previously, the Project would be required to have an approved SWPPP, which would include construction BMPs to minimize the potential for construction related sources of pollution. For operations, the proposed Project would be required to implement source control BMPs to minimize the introduction of pollutants; and treatment control BMPs to treat runoff. With implementation of the operational source and Redlands Joint Special Meeting of the
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treatment control BMPs that would be required by the City during the project permitting and approval process, potential pollutants would be reduced to the maximum extent feasible, and implementation of the proposed project would not obstruct implementation of a water quality control plan.

Also as described previously, groundwater is adjudicated, which limits the allowable groundwater extraction to ensure a safe yield. Because the groundwater basin is managed through this plan, which limits the allowable withdrawal of water from the basin by water purveyors, and the Project would not pump water from the project area (as water supplies would be provided by the City), the proposed Project would not conflict with or obstruct a groundwater management plan, and no impacts would occur.

Project Design Features
None.

Existing Plans, Programs, or Policies
PPP WQ-1: Prior to grading permit issuance, the project developer shall have a Stormwater Pollution Prevention Plan (SWPPP) prepared by a QSD (Qualified SWPPP Developer) pursuant to the Municipal Code Chapter 13.54. The SWPPP shall incorporate all necessary Best Management Practices (BMPs) and other City requirements to comply with the National Pollutant Discharge Elimination System (NPDES) requirements to limit the potential of polluted runoff during construction activities. Project contractors shall be required to ensure compliance with the SWPPP and permit periodic inspection of the construction site by City of Redlands staff or its designee to confirm compliance.

PPP WQ-2: Prior to grading permit issuance, the project developer shall have a Water Quality Management Plan (WQMP) approved by the City for implementation. The project shall comply with the City’s Municipal Code Section 13.54 and the Municipal Separate Storm Sewer System (MS4) permit requirements in effect for the Regional Water Quality Control Board (RWQCB) at the time of grading permit to control discharges of sediments and other pollutants during operations of the Project.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

11. LAND USE AND PLANNING. Would the
Project:
a) Physically divide an established community?
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?
a) Physically divide an established community?
No Impact. The Project site is currently developed with commercial buildings and parking lots within an urbanized portion of the city surrounded by commercial, public institution, and residential uses. The proposed Project would develop the site to provide a mixed-use development with 700 multi-family dwelling units, 71,778 square feet (SF) of ground-floor retail, 12,328 SF of office space, amenity areas, community building, a 1,721 SF rooftop restaurant space with a rooftop deck, a 14,500 SF drugstore, a recreational building, recreational areas, and associated parking. The Project would not physically divide an established community and will be consistent with the mixed-use character of the surrounding Downtown Redlands area.

In addition, the Project would not change roadways, pedestrian bridges, or install any infrastructure that would result in a physical division. Thus, the proposed Project would not result in impacts related to physical division of an established community.
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? Less Than Significant Impact with Mitigation Incorporated. The documents regulating land use for the Project site and immediate vicinity are the City’s General Plan and the City’s Municipal Code. The proposed Project’s relationship to these planning documents is described below.

General Plan. The 11.08-acre northern portion of the Project site has a General Plan designation on Commercial and the 1.17-acre southern portion of the Project site has a General Plan Designation of Public/Institutional. Additionally, the entire Project site is within the Transit Villages overlay. These General Plan designations do not have the purpose of avoiding or mitigating an environmental effect.

The proposed Project is a mixed-use development with a residential density of approximately 57.1 du/ac.

The Commercial designation allows for residential and mixed-use development, which the Project would be consistent with. Additionally, the Project includes General Plan Amendment to redesignate the parcels south of Citrus Avenue from Public/Institutional to Commercial.

Table LU-1: General Plan Consistency
General Plan Policies Project Consistency
Distinctive City
2-A.1 Provide for the equitable distribution of
public facilities and amenities, such as parks and
public facilities, throughout Redlands.

Consistent. The Project would provide paseos and a
public green space fronting 3rd Street, providing
needed public park space in Downtown Redlands.
2-A.4 Maintain continuity in streetscape design
along major streets and avenues that traverse north
Consistent. The Project does not propose any changes
to the streetscapes along Orange, Redlands, and
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and south – California, Nevada, Alabama,
Tennessee, Orange, Church, University, Judson, and
Wabash; and those that traverse east and west –
Pioneer, San Bernardino, Lugonia, Redlands
Boulevard, and Citrus.

Citrus. The Project would provide ground floor retail,
which is consistent with surrounding commercial uses
along these streets.
2-A.8 Insist on high-quality development and
revitalization in older neighborhoods, such as the
Orange Street and Colton Avenue commercial
corridors, that is sensitive to historic architecture,
and provides a broad range of retail, restaurants,
professional services, and offices that meet the
community’s needs. Build a sense of community in
these commercial areas.

Consistent. The Project replace the vacant Redlands
Mall with a mixed-use development with ground floor
retail, office space, a restaurant, and residential units along Orange Street. Project development includes
design features and mitigation measures to ensure
sensitivity to surrounding historical architecture.
2-A.10 Permit densities, design, and uses that will
help preserve the character and amenities of
existing neighborhoods.

Consistent. The Project would replace the vacant
Redlands Mall and would develop 700 multi-family
dwelling units, 71,778 SF of ground-floor retail,
12,328 SF of office space, amenity areas, community
building, a 1,721 SF rooftop restaurant space with a
rooftop deck, and 14,500 SF drugstore. The Project
would result in a residential density of 57.1 dwelling
units per acre. The proposed density would be
consistent with the Redlands General Plan Transit
Villages Overlay as it would promote higher density
uses in areas with access to the Arrow Line.

Additionally, the Project would be consistent with the
mixed-use nature of the Downtown Redlands area and
would provide additional public amenities downtown.
2-A.16 Use transit stations as focal points for
interconnectivity; plan to equally serve travelers
from north and south. Plan for each village around
the transit stations to have a unique character that
complements the adjacent neighborhoods.

Consistent. The proposed Project would be within the
Transit Villages Overlay. The Project would
complement surrounding commercial uses by providing
a mixed-use development with ground floor retail,
office space, a restaurant, residential units, and
public/private open space in the Downtown Redlands
area.
2-A.18 Promote a safe and secure environment
near transit stations through design, adjacent land
use considerations, public space programming, and
coordination with public safety providers.

Consistent. The Project would provide needed public
space in the Downtown area and would remove the
blighted Redlands Mall. The Project would be
reviewed by the City of Redlands Police Department
and City of Redlands Fire Department to ensure that
accurate safety measures are provided, including
security lighting and parking lot lighting.
2-A.25 Require any application that would alter or
demolish an undesignated and unsurveyed resource
over 50-years-old to be assessed on the merits of
the structure, and to be approved by the Historic
and Scenic Preservation Commission.

Consistent. The proposed Project would demolish the
mostly vacant Redlands Mall building and commercial
building on the southwest corner of Redlands
Boulevard and Orange Street. All of the buildings
were built in 1977. Therefore, the buildings are less
than 50 years old and are not of historic age.
2-A.34 Uphold the designation of the following
streets within the city as scenic highways, drives,
and historic streets. Special development
standards have been adopted by Resolution for
these streets. The streets are:
• Brookside Avenue, from Lakeside Avenue
to Eureka Street;
Consistent. The Project is bounded by Redlands
Boulevard, Orange Street, Citrus Avenue, and Eureka
Street. None of these streets are designated as scenic
highways, drives, or historic streets. As such, the Project would not result in aesthetic impacts to designated
scenic streets in Redlands.

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• Olive Avenue, from Lakeside Avenue to
Cajon Street;
• Center Street, from Brookside Avenue to
Crescent Avenue;
• Highland Avenue, from Serpentine Drive to
Cajon Street;
• Sunset Drive, from Serpentine Drive to
Edgemont Drive;
• Cajon Street;
• Mariposa Drive, between Halsey and
Sunset Drive; and
• Dwight Street, between Pepper Street and
Mariposa Drive.

In addition, consider designating the following
roads as scenic drives within the community as
neighborhood connectors and recreational routes
for drivers and bike riders.
• Riverview Drive along the Santa Ana River
Wash;
• Live Oak Canyon Road;
• San Timoteo Canyon Road;
• Sylvan Boulevard;
• Nevada Street, from the Orange Blossom
Trail to Barton Road;
• Pioneer Avenue, from River Bend Drive to
Judson Street; and
• Rural roads in Crafton.
2-A.35 Establish standards for the evaluation of
exterior lighting for new development and
redevelopment to ensure that exterior lighting
(except traffic lights, navigational lights, and other
similar safety lighting) is minimized, restricted to
low-intensity fixtures, shielded, and concealed to
the maximum feasible extent, and that highintensity perimeter lighting and lighting for sports and other private recreational facilities is limited to reduce light pollution visible from public viewing
areas.

Consistent. The proposed Project would include
exterior lighting in the public open space and
surrounding project buildings. All exterior lighting will be property shielded and concealed to reduce light
pollution.
2-A.71 Using an annually updated Archaeological
Resource Sensitivity Map, review proposed
development projects to determine whether a site
contains known prehistoric or historic cultural
resources and/or to determine the potential for
discovery of additional cultural resources.

Consistent. As discussed in Section 6.5, Cultural
Resources, a review of the SCCIC was conducted. The
Project site contains an underground portion of the Mill Creek Zanja. Portions of the Mill Creek Zanja are
listed in the California Register of Historic Resources and the National Register of Historic Places. The
Project would leave the existing Zanja stormwater
easement in place. However, there is a potential that
during ground disturbing activities, archaeological
resources are uncovered. As such, the Project would
incorporate MM CUL-1 requiring archaeological
monitoring. With implementation of MM CUL-1,
impacts would be less than significant.
2-A.72 Require that applicants for projects
identified by the South Coastal Information Center
as potentially affecting sensitive resource sites hire
a consulting archaeologist to develop an
archaeological resource mitigation plan and to
monitor the project to ensure that mitigation
measures are implemented.

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2-A.73 Require that areas found during construction
to contain significant historic or prehistoric
archaeological artifacts be examined by a
qualified consulting archaeologist (RPA certified) or
historian for appropriate protection and
preservation.
2-A.74 Proactively coordinate with the area’s
native tribes in the review and protection of any
tribal cultural resources discovered at development
sites.

Consistent. As discussed in Section 6.18, Tribal
Cultural Resources, in compliance with AB 52 and SB
18 requirements, on March 30 and April 8, 2021, the
City sent letters to the following Native American
tribes that may have knowledge regarding tribal
cultural resources in the Project vicinity. Additionally, on September 11, 2020, Material Culture Consulting
requested a Sacred Lands File (SLF) search from the
Native American Heritage Commission. On September
14, 2020, the NAHC responded that the SLF search
yielded positive results for known tribal cultural
resources or sacred lands within a 1-mile radius of the Project site. The Soboba Band of Luiseño Indians and
San Manuel Band of Mission Indians requested
consultation regarding the proposed Project. The
Soboba Band of Luiseño Indians considers the area
sensitive for cultural resources as several sites are
located nearby. Although no information for site
specific tribal cultural resources was provided (and
there are no known tribal cultural resources on or
adjacent to the Project site), the consulting tribes
requested inclusion of mitigation due to the potential
of the Project to unearth previously undocumented
tribal cultural resources during construction.

Therefore, the tribes request that in addition to MM
CUL-1: Inadvertent Discoveries, a tribal monitor be
retained to monitor any ground disturbing activities for the Project. Mitigation Measures TCR-1 through TCR-5
have been included to require a Monitoring and
Treatment Plan and Native American monitoring of
excavation and grading activities to avoid potential
impacts to tribal cultural resources that may be
unearthed by Project construction activities.
2-A.75 Require, as a standard condition of
approval, that project applicants provide an
assessment as to whether grading for the proposed
project would impact underlying soil units or
geologic formations that have a moderate to high
potential to yield fossiliferous materials, prior to
issuance of a grading permit. If the potential for
fossil discovery is moderate to high, require
applicants to provide a paleontological monitor
during rough grading of the project.

Consistent. As discussed in Section 6.3.7, Geology and
Soils, soils underlying the Project site are mapped as
younger and older surficial deposits, more specifically very young wash deposits, active (Qvyw), old alluvialfan deposits, Unit 3 (Qof3), and very old axial-valley deposits, Unit 3 (Qvoa3). While the younger deposits
typically do not contain significant vertebrate fossils within the uppermost layers, it is likely there are
underlaying sediments of older Quaternary deposits.

As such, MM PAL-1 is included to require
paleontological monitoring and preparation of a
PRMP. With implementation of MM PAL-1, impacts
would be less than significant.
2-A.76 Establish a procedure for the management
of paleontological materials found on-site during a
development, including the following provisions:

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• If materials are found on-site during
grading, require that work be halted until
a qualified professional evaluates the find
to determine if it represents a significant
paleontological resource.
• If the resource is determined to be
significant, the paleontologist shall
supervise removal of the material and
determine the most appropriate archival
storage of the material.
• Appropriate materials shall be prepared,
catalogued, and archived at the
applicant’s expense and shall be retained
within San Bernardino County if feasible.
2-A.94 Encourage mixed-use projects Downtown
that integrate retail, restaurant, office, and
residential uses. Permit urban housing at a density
up to the High-Density Residential standard.

Consistent. The proposed Project would include the
development of a mixed-use development within the
Downtown Redlands area. The proposed buildings
would include 700 multi-family dwelling units, 71,778
SF of ground-floor retail, 12,328 SF of office space,
amenity areas, community building, a 1,721 SF
rooftop restaurant space with a rooftop deck, and a
14,500 SF drugstore. The Project would result in a
residential density of 57.1 dwelling units per acre,
which would be above High-Density Residential
standard, but within the allowed density set forth by
the proposed Transit Villages Specific Plan.
2-A.96 Promote redevelopment of the Redlands
Mall with a vibrant mix of uses. Explore feasibility
of re-extending the traditional street grid through
the new development.

Consistent. The proposed Project would redevelop
the Redlands Mall with 700 multi-family dwelling units, 71,778 SF of ground-floor retail, 12,328 SF of office
space, amenity areas, community building, a 1,721 SF
rooftop restaurant space with a rooftop deck, and
14,500 SF drugstore. Additionally, the Project would
help reestablish the traditional street grid by
extending State Street east to 3rd Street and 3rd Street south to Citrus Avenue.
2-A.97 Seek an increased presence of both
residents and activity in Downtown with new
development—particularly residential as part of
mixed-use development—as well as commercial,
entertainment, and cultural uses that serve both
residents and visitors.

Consistent. The proposed Project would redevelop
the Redlands Mall with 700 multi-family dwelling units
including live/work units, 0-bedroom units, studios, 1- bedroom units, 2-bedroom units, and 3-bedroom units
in provide a variety of housing within the Downtown
Redlands area.
2-A.99 Ensure that new development along
Redlands Boulevard is pedestrian-oriented.

Consistent. The proposed Project would redevelop
the Redlands Mall with 700 multi-family dwelling units, 71,778 SF of ground-floor retail, 12,328 SF of office
space, amenity areas, community building, a 1,721 SF
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rooftop restaurant space with a rooftop deck, and a
14,500 SF drugstore. Additionally, the Project would
provide multiple pedestrian paseos to promote
pedestrian accessibility and encourage alternative
transportation.

Prosperous Economy
3-A.5 Promote revitalization and rehabilitation of
older commercial and industrial areas to make them
more competitive, accessible, aesthetically
appealing, and economically viable.

Additionally, the Project would draw on the aesthetics
of the Downtown Redlands historic buildings and
provide increased economic activity in the area.
3-A.10 Encourage mixed-use projects within the
Transit Villages that will attract a wide array of
uses including retail, restaurant, entertainment,
office, residential, and cultural offerings
Consistent. As discussed above, the proposed Project
would redevelop the site with a mixed-use project
consisting of 700 multi-family dwelling units, 71,778
SF of ground-floor retail, 12,328 SF of office space,
amenity areas, community building, a 1,721 SF
rooftop restaurant space with a rooftop deck, and a
14,500 SF drugstore.
3-A.12 Encourage the location of commercial
centers according to function and scale – regional,
general, and neighborhood –so that centers of
different scales complement one another and each
is accessible to the primary market it is designed to
serve.

Consistent. The proposed Project would be scaled,
buffered, and designed to be compatible with the
surrounding commercial uses and historic architecture
throughout Redlands.
3-A.14 Encourage commercial development,
neighborhood retail, and professional offices and
services of the appropriate scale and business
types along neighborhood commercial corridors,
such as Orange Street and Colton Avenue.

Consistent. The eastern boundary of the proposed
Project would border Orange Street. The proposed
Project would include appropriately scaled retail,
office space, a garage entry, and multi-family
residences along Orange Street.
3-A.19 Support opportunities to enhance innovation
through business incubators, expanded broadband
and digital infrastructure, live-work spaces, mixeduse development, and policies that accommodate other industry innovations at the Redlands Municipal
Airport, along Colton Avenue and Orange Street,
Downtown, and in the Transit Villages.

Consistent. The proposed Project would provide a
mixed-use development including 700 multi-family
dwelling units, 71,778 SF of ground-floor retail,
12,328 SF of office space, amenity areas, community
building, a 1,721 SF rooftop restaurant space with a
rooftop deck located downtown, and a 14,500 SF
drugstore.
3-A.34 Encourage and support unique specialty
retail and restaurant uses in the Downtown core.

Consistent. As discussed previously, the Project would
include 71,778 SF of ground-floor retail, which could
include restaurant space depending on market needs,
and a 1,721SF rooftop restaurant with a rooftop
deck. The rooftop restaurant would provide a unique
restaurant use in the Downtown core. The Project would
also construct a 14,500 SF drugstore south of Citrus
Avenue.
3-A.36 Support revitalization of underutilized
commercial space throughout Downtown, including
the Redlands Mall, which could create new
opportunities for businesses and residents, and
provide a critical link to rail.

Consistent. The proposed Project would redevelop the
mostly vacant Redlands Mall and provide retail, office
space, residential units, and a community building
which would provide opportunities for businesses and
residents and provide a critical link to rail.

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3-A.37 Ensure adequate parking Downtown and
efficiency in traffic flow to enable the continued
revitalization of the commercial core
Consistent. Street parking would be provided
throughout the Project site and along the boundaries
of the Project. In addition, a parking garage would be
provided with two entrances along Redlands
Boulevard to serve the proposed Project.
3-A.39 Encourage and support the development of
additional housing Downtown to increase the vitality
and diversity of Downtown retail and services.

Consistent. The proposed Project would include 700
multi-family dwelling units which would provide
additional housing Downtown. As the Project proposes
a mixed-use development, it would provide diverse
uses to the Downtown area.
3-A.40 Enhance and expand the public spaces
Downtown (streetscapes, plazas, parks) to improve
the pedestrian experience.

Consistent. The proposed Project would include a
village plaza along State Street that would enhance
walkability throughout the Project site. In addition,
sidewalks would be provided throughout the Project to
improve the pedestrian experience
Livable Community
4-A.1 Promote the orderly development and
growth of urban areas in infill areas and the city
center while encouraging the ongoing cultivation of
agricultural land and the preservation of rural living
areas in the canyons, Crafton, and Mentone.

Consistent. The proposed Project would redevelop the
Redlands Mall which would develop an underutilized
site within Downtown and would not affect any
agricultural land within the City as the existing Project site is fully developed.
4-A.3 Ensure that infill development complements
existing development in use, design, and scale, and
that it supports the cohesion and integration of the
city’s development pattern.

Consistent. The proposed Project would be scaled
and designed to be compatible with the Downtown
architectural styles within the City including Spanish
Mission and 19th Century, and Mediterranean Style
Contemporary.
4-A.7 Promote a range of residential densities to
encourage a mix of housing types in varying price
ranges and rental rates.

Consistent. The proposed Project would include 700
multi-family dwelling units which would include livework units, studios, one-bedroom, two-bedroom, and three-bedroom units. The proposed dwelling units
would vary in price range and provide a mix of
housing types.
4-A.8 Promote the development of a greater
variety of housing types, including single-family
homes on small lots, accessory dwelling units,
townhomes, lofts, live-work spaces, and senior and
student housing to meet the needs of future
demographics and changing family sizes.

Consistent. As mentioned above, the proposed Project
would include 700 multi-family dwelling units which
would include live-work units, studios, one-bedroom,
two-bedroom, and three-bedroom units. The proposed
dwelling units would vary in price range and provide
a mix of housing types.
4-A.9 Encourage the incorporation of residential
units in Downtown mixed-use projects consistent with
the Redlands Downtown Specific Plan.

Consistent. As mentioned above, the proposed Project
would include 700 multi-family dwelling units which
would be consistent with the Redlands Downtown
Specific Plan.
4-A.11 Ensure that opportunities exist for the
development of housing types that are affordable
to all segments of the Redlands community and are
distributed equitably throughout the community.

Consistent. As mentioned above, the proposed Project
would include 700 multi-family dwelling units which
would include live-work, studios, one-bedroom, twobedroom, and three-bedroom units. The units would vary in price based on size and location.
4-A.12 Support new residential development in
Downtown, the Transit Villages, and other focused
infill sites accessible to transit and in central parts of the community.

Consistent. The proposed Project would include 700
multi-family dwelling units located Downtown which
would be accessible to transit.

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4-A.13 Permit densities, design, and uses that will
help preserve the character and amenities of
existing older neighborhoods.

Consistent. As mentioned previously, the proposed
Project would be scaled and designed to be
compatible with the Downtown historic architectural
styles within the City including Spanish Mission and 19th Century, and Mediterranean Style Contemporary.
4-A.15 Promote the preservation, maintenance,
and improvement of property through code
enforcement to mitigate or eliminate deterioration
and blight conditions, and to help encourage new
development and reinvestment.

Consistent. The proposed Project would redevelop
the mostly vacant Redlands Mall with a mixed-use
development that would reduce the current blight
conditions of the Redlands Mall.
4-A.18 Focus the development of office space in
transit-accessible locations.

Consistent. The proposed office space would be
located along Orange Street. The nearest Omnitrans
bus stop is located at Redlands Boulevard which is
approximately 0.1 mile from the proposed office
space. Additionally, the Project would be
approximately 0.16-mile from the downtown Arrow
Line station.
4-A.20 Establish new neighborhood commercial
centers to serve the needs of community members in
areas planned to accommodate new growth, such
as Downtown and the Transit Village areas.

Consistent. The proposed Project would redevelop
the site with a mixed-use development including 700
multi-family dwelling units, 71,778 SF of ground-floor
retail, 12,328 SF of office space, amenity areas,
community building, a 1,721 SF rooftop restaurant
space with a rooftop deck located downtown, and a
14,500 SF drugstore.
4-A.21 Revitalize neighborhood shopping centers in
neighborhoods where existing centers have
reached the end of their economic life.

Consistent. The proposed Project would redevelop
the mostly vacant Redlands Mall with a mixed-use
Project including 71,778 SF of ground-floor retail and
a 14,500 SF drugstore.
4-A.87 Promote clusters of mixed-use development
along Redlands Boulevard near the Mixed-Use
Cores of the proposed Transit Villages, providing
opportunities for commercial, office, and residential
development consistent with the needs and
characteristics specific to each Transit Village.

Consistent. As mentioned previously, the proposed
Project would consist of a mixed-use development
including 700 multi-family dwelling units, 71,778 SF of ground-floor retail, 12,328 SF of office space,
amenity areas, community building, a 1,721 SF
rooftop restaurant space with a rooftop deck, and a
14,500 SF drugstore located downtown.
4-A.88 Promote infill development along Redlands
Boulevard where it is classified as a Boulevard to
create a continuous corridor of mixed-use and
commercial activity.

Consistent. The proposed Project would include
residential units, amenities, a pool deck and recreation area, and a community building along Redlands
Boulevard. Furthermore, the Project would include
ground-floor retail along Redlands Boulevard.
4-A.93 Seek to improve the mix of office,
professional, and service-related businesses along
Colton Avenue and Orange Street that will serve
the neighborhood.

Consistent. As discussed above, the proposed Project
would develop office space, retail space, and
residential units along Orange Street.
4-A.95 Promote infill development to create a
continuous corridor of mixed-use and commercial
activity.

Consistent. The proposed Project would be an infill
development that would redevelop the mostly vacant
Redlands Mall with multi-family dwelling units, retail, office space, amenity areas, a community building,
and rooftop restaurant space.
4-A.96 Encourage site designs that create an active
street frontage and screen parking from the Colton
Avenue and Orange Street frontages.

Consistent. The proposed Project would include
landscaping along the Orange Street frontage
including street trees and grasses. A parking entry
would be provided to screen parking from the Orange
Street frontage.

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4-A.97 Encourage the development of bicycle,
pedestrian, and transit access that reduces the need
for on-site parking. Improve the pedestrian
experience within these corridors through street
trees and landscaping.

Consistent. The proposed Project would include
sidewalks, plazas, and transit access that would
increase walkability and improve the pedestrian
experience.
4-A.98 Create greater opportunity to intensify and
consolidate land uses on adjacent parcels and
connect existing assets through infill development.

Consistent. The proposed Project would consist of an
infill development that would redevelop the Redlands
Mall with a mixed-use development that would be
similar to the surrounding uses.
4-A.121 Encourage a centrally-located mix of uses
to promote activity and economic vitality.

Consistent. The proposed Project would redevelop
the mostly vacant Redlands Mall with a mixed-use
project including 700 multi-family dwelling units,
71,778 SF of ground-floor retail, 12,328 SF of office
space, amenity areas, community building, a 1,721 SF
rooftop restaurant space with a rooftop deck, and a
14,500 SF drugstore located downtown.
4-A.126 Establish boulevards along Orange Street,
Colton Avenue, and Redlands Boulevard with
pedestrian-oriented streetscape improvements and
groundfloor active uses.

Consistent. The proposed Project would include
frontage improvements along Orange Street and
Redlands Boulevard including sidewalks and
landscaping.
4-A.150 Encourage the undergrounding of utilities
for all new development.

Consistent. The proposed Project would install new
onsite utilities that would be underground and connect
to existing lines.
4-A.157 Include the Police and Fire departments in
the review of new developments to provide
feedback on building and site design safety.

Consistent. The proposed Project would undergo plan
checks that would allow for Police and Fire review to
ensure building and site design safety requirements
are met.

Connected City
5-A.3 Ensure new street design and potential
retrofit opportunities for existing streets minimize
traffic volumes and/or speed as appropriate within
residential neighborhoods without compromising
connectivity for emergency vehicles, bicycles,
pedestrians, and users of mobility devices. This
could be accomplished through:
• Management and implementation of
complete street strategies, including
retrofitting existing streets to foster biking
and walking as appropriate;
• Short block lengths, reduced street widths,
and/or traffic calming measures; and
• Providing pedestrians and bicyclists with
options where motorized transportation is
prohibited.

Consistent. The proposed Project would be designed
to include sidewalks and plazas to facilitate
pedestrian and bicyclists with accessibility to and from the Project site. Street improvements would include
sidewalks and bike lanes along all streets throughout
and surrounding the Project. The Project would
undergo City review which would ensure appropriate
emergency vehicle access and circulation is provided.
5-A.7 Add new streets to create a finer grained,
pedestrian-scaled road network where the
roadway network is characterized by particularly
long blocks, connecting residential areas to parks
and Transit Village cores. Ensure the street systems
in Transit Villages support development of
connected and accessible communities.

Consistent. The proposed Project would add new
internal streets connecting State Street from the east
and west by a new public plaza and 3rd Street from
the north and south which would support development
of connected and accessible communities.

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5-A.15 Maintain access for emergency vehicles and
services by providing two means of ingress/egress
into new communities, limitations on the length of culde-sacs, proper roadway widths and road grades, adequate turning radius, and other requirements
per the California Fire Code.

Consistent. The proposed Project would undergo City
review to ensure adequate emergency access is
provided throughout the Project site.
5-A.68 Provide for direct pedestrian paths and
access from new developments to the nearest public
transportation stop.

Consistent. The nearest Omnitrans bus stop is
approximately 0.1 mile from the proposed Project
located at Redlands Boulevard. Sidewalks would be
provided throughout the site and along Redlands
Boulevard and Orange Street which would provide
access to the bus stop and connect to existing
sidewalks.
5-A.73 Provide adequate parking availability
Downtown for residents, commuters, visitors, and
shoppers throughout the day.

Consistent. As mentioned previously, street parking
would be provided throughout the Project site with an
additional parking garage along Redlands Boulevard
which would serve the Project and would be adequate
for residents, commuters, visitors, and shoppers.
5-A.75 Consider techniques to reduce the amount
of area in the Transit Villages occupied by parking,
especially for developments located within easy
walking distance of the Passenger Rail stations.

Consistent. As mentioned previously, the proposed
Project would include a parking garage along
Redlands Boulevard and street parking throughout the
site.
5-A.77 Encourage developers to meet their
minimum parking requirements via shared parking
between uses, payment of in-lieu fees, joint parking
districts, or off-site parking within a reasonable
walking time of 10 minutes or less.

Consistent. The proposed Project would undergo City
review to ensure that the Project meets the minimum
parking requirements. Parking would be included
onsite which would not result in off-site parking.

Vital Environment
6-A.35 Promote the use of Low Impact
Development strategies, BMPs, pervious paving
materials, and on-site infiltration for treating and
reducing stormwater runoff before it reaches the
municipal stormwater system.

Consistent. The proposed Project would include low
impact development strategies, BMPs, pervious paving
materials, and on-site infiltration for treating and
reducing stormwater runoff as discussed in the WQMP
included as Appendix G.
6-A.43 Ensure that post-development peak
stormwater runoff discharge rates do not exceed
the estimated pre-development rate. Dry weather
runoff from new development must not exceed the
pre-development baseline flow rate to receiving
waterbodies.

Consistent. A preliminary WQMP was prepared for
the Project and is included as Appendix G. The
hydrology report ensures that post-development peak
stormwater runoff discharge rates would not exceed
the estimated pre-development rates.

Healthy Community
7-A.35 Implement street design features that
facilitate walking and biking in both new and
established areas. Require a minimum standard of
these features for all new developments.

Consistent. The proposed Project would include bike
paths and sidewalks throughout the site.
7-A.36 Discourage street closures; encourage
creating new connections.

Consistent. The proposed Project would create new
street connections including State Street extending
from Orange Street to 3rd Street and 3rd Street would
extend from the north to the south of the Project site. 7-A.46 Encourage the provision of bike lockers,
bike-sharing, and other methods of supporting
active transportation that can contribute to healthy
lifestyles.

Consistent. The proposed Project would include bike
racks and bike locker rooms throughout the Project site to support active transportation in the City.

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7-A.73 Improve the sense of safety within
Downtown, including the Redlands Mall area.

Consistent. The proposed Project would redevelop
the mostly vacant Redlands Mall with a mixed-use
project including 700 multi-family dwelling units,
71,778 SF of ground-floor retail, 12,328 SF of office
space, amenity areas, community building, a 1,721 SF
rooftop restaurant space with a rooftop deck, and
14,500 SF drugstore located downtown. Lighting
would be provided to enhance safety within the
Project site.
7-A.75 Consider the impacts to health and safety
from potential flooding on future development in
flood-prone areas, including Downtown Redlands.

Ensure that new development follows appropriate
design standards.

Consistent. The Project has been designed to reduce
flooding impacts by including landscaping throughout
the site. Additionally, buildings would be designed to
be above the flood line in order to minimize impacts
related to flooding.
7-A.95 Coordinate with the Redlands Fire
Department and other fire prevention agencies to
review all applications for new development. The
Fire Department’s review should ensure compliance
with fire safety regulations and assess potential
impacts to existing fire protection services and the
need for additional and expanded services
Consistent. The proposed Project would undergo City
review which includes Redlands Fire Department
review. The Fire Department would ensure the Project
complies with all fire safety regulations.
7-A.107 Continue to restrict development within
Alquist-Priolo Earthquake Fault Zones and along
other active and potentially active faults that have
not yet received Alquist-Priolo classification
Consistent. The proposed Project is not within an
Alquist-Priolo Earthquake Fault Zone. The nearest
Alquist-Priolo Earthquake Fault Zone is approximately

2.7 miles to the northeast. In addition, the Project
would comply with Title 24 of the California Building
Code as included in Chapter 15.04 of the City’s
Municipal Code.
7-A.109 Require areas identified as having
significant liquefaction potential (including
secondary seismic hazards such as differential
compaction, lateral spreading, settlement, rock fall,
and landslide) to undergo geotechnical study prior
to development and to mitigate the potential
hazard to a level of insignificance or, if mitigation
is not possible, to preserve these areas as open
space or agriculture.

Consistent. A geotechnical report was prepared for
the proposed Project included as Appendix D. Based
on the geotechnical report, the proposed Project site
is not located within an area identified as having
liquefaction potential.
7-A.114 For new construction and exterior building
expansions including multistory additions or lateral
expansions as deemed appropriate by the City
Building Department, require the preparation of a
geotechnical/soils/geologic report by a registered
civil geotechnical/soils engineer and a certified
engineering geologist. This report shall address
erodible or expansive and collapsible soils, existing
or potential landslides, areas with unsuitable
percolation characteristics, large-scale subsidence,
non-rippable bedrock areas, ground motion
parameters, active/potentially active faulting,
liquefaction, and any other geotechnical concepts
as appropriate, and make recommendations for
mitigating any potential adverse impacts.

Consistent. As mentioned above, a geotechnical
report was prepared for the proposed Project
included as Appendix D. The geotechnical report
addresses geologic concerns on the site and provides
recommendations for Project grading and construction.

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7-A.115 Require soil erosion mitigation during
construction.

Consistent. The proposed Project would include
preparation of a SWPPP to mitigate any potential soil
erosion during construction.
7-A.123 Regulate development on sites with known
contamination of soil and groundwater to ensure
that construction workers, future occupants, the
public, and the environment are adequately
protected from hazards associated with
contamination. Work with State and local agencies
to encourage cleanup of such sites.

Consistent. The proposed Project would redevelop the
mostly vacant Redlands Mall with a multi-use
development. As discussed in Section 6.3.9, Hazards,
there is potential for multiple underground storage
tanks (UST) to exist onsite due to the past operation of the site as a gas station. Based on a review of historic Sanborn maps, several gas stations existed onsite from
approximately 1949 until 1955. No information
pertaining to these facilities including the exact
location of USTs, installation or removal dates, tank
capacity or construction was found during preparation
of the Phase I Environmental Site Assessment. Based on
the length of time that the subject property had been
utilized as a gasoline service station, and absent the
data confirming whether a release had occurred
following the removal of any USTs, it is possible that
petroleum hydrocarbons may have impacted the
subsurface soils of the subject property. As such,
Project-specific MM HAZ-1 is included to require the
applicant to pay for the removal of any UST that is
encountered during construction activities and requires further soil sampling and remediation if potentially
impacted soils are encountered. With implementation
of MM HAZ-1, impacts related to existing USTs would
be less than significant.
7-A.124 Prohibit the development of projects that
would reasonably be anticipated to emit hazardous
air emissions or handle extremely hazardous
substances within a quarter mile of a school.

Consistent. The proposed Project would redevelop
the mostly vacant Redlands Mall with a mixed-use
project including 700 multi-family dwelling units,
71,778 SF of ground-floor retail, 12,328 SF of office
space, amenity areas, community building, a 1,721 SF
rooftop restaurant space with a rooftop deck, and a
14,500 SF drugstore located downtown. The
proposed Project would not emit hazardous air
emissions or handle extremely hazardous substances.

In addition, the closest elementary school is
approximately 2.8 miles to the east of the Project site. 7-A.135 Use the noise and land use compatibility
matrix (Table 7-10) and Future Noise Contours map
(Figure 7-9) as criteria to determine the
acceptability of a given land use, including the
improvement/construction of streets, railroads,
freeways, and highways. Do not permit new noisesensitive uses—including schools, hospitals, places of worship, and homes—where noise levels are
“normally unacceptable” or higher, if alternative
locations are available for the uses in the city.

Consistent. A noise study was prepared for the
proposed Project included as Appendix H. As
demonstrated by the Noise Impact Analysis, the
Project would satisfy the City of Redlands 45 dBA
CNEL residential interior noise level standards, which
would be verified as a part of the permit issuance and
building plan check process.
7-A.136 Require a noise analysis be conducted for
all development proposals located where projected
noise exposure would be other than “clearly” or
“normally compatible” as specified in Table 7-10
Consistent. As mentioned above, a noise study was
prepared for the proposed Project included as
Appendix H. As demonstrated by the Noise Impact
Analysis, the Project would satisfy the City of Redlands Redlands Joint Special Meeting of the
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45 dBA CNEL residential interior noise level standards, which would be verified as a part of the permit
issuance and building plan check process.
7-A.137 For all projects that have noise exposure
levels that exceed the standards in Table 7-10,
require site planning and architecture to
incorporate noise-attenuating features. With
mitigation, development should meet the allowable
outdoor and indoor noise exposure standards in
Table 7-11. When a building’s openings to the
exterior are required to be closed to meet the
interior noise standard, mechanical ventilation shall
be provided.

Consistent. The proposed Project would not exceed
noise levels that exceed the standards set forth in
Table 7-10. As demonstrated by the Noise Impact
Analysis, the Project would satisfy the City of Redlands 45 dBA CNEL residential interior noise level standards, which would be verified as a part of the permit
issuance and building plan check process.
7-A.138 Continue to maintain performance
standards in the Municipal code to ensure that noise
generated by proposed projects is compatible with
surrounding land uses.

Consistent. The proposed Project would be consistent
with the noise standards set by the City’s Municipal
code. As discussed in Section 6.3.13, Noise, projected
construction and operational noise levels at
surrounding sensitive receptors, including nearby
residences, would be within allowable limits.
7-A.149 Ensure that construction and grading
projects minimize short-term impacts to air quality.
a. Require grading projects to provide a
stormwater pollution prevention plan
(SWPPP) in compliance with City
requirements, which include standards for
best management practices (BMPs) that
control pollutants from dust generated by
construction activities and those related to
vehicle and equipment cleaning, fueling,
and maintenance;
b. Require grading projects to undertake
measures to minimize mono-nitrogen oxides
(NOx) emissions from vehicle and
equipment operations; and
c. Monitor all construction to ensure that
proper steps are implemented.

Consistent. As discussed in Section 6.3.3, Air Quality, the proposed Project would minimize short-term
impacts to air quality and impacts related to air
quality during construction would be less than
significant. In addition, a SWPPP would be prepared
for the proposed Project in compliance with City
requirements.
7-A.153 Require applicants for sensitive land uses
(e.g. residences, schools, daycare centers,
playgrounds, and medical facilities) to site
development and/or incorporate design features
(e.g. pollution prevention, pollution reduction,
barriers, landscaping, ventilation systems, or other
measures) to minimize the potential impacts of air
pollution on sensitive receptors.

Consistent. The proposed Project would include
landscaping along the boundaries of the site and
throughout the Project. In addition, the proposed
mixed-use development would not exceed
operational Air Quality or GHG thresholds which
would not significantly impact air pollution on sensitive receptors.

Sustainable Community
8-A.8 Implement and enforce California Code of
Regulations Title 24 building standards (parts 6 and
11) to improve energy efficiency in new or
substantially remodeled construction. Consider
implementing incentives for builders that exceed the
standards included in Title 24 and recognize their
achievements over the minimum standards
Consistent. The proposed Project would implement
Title 24 building standards and California Green
Building Standards as included in Chapter 15.16 of
the City’s Municipal Code.
8-A.9 Encourage the use of construction, roofing
materials, and paving surfaces with solar
Consistent. As discussed above, the Project would
comply with the California Green Building Standards
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reflectance and thermal emittance values per the
California Green Building Code (Title 24, Part 11
of the California Code of Regulations) to minimize
heat island effects.
as included in Chapter 15.16 of the City’s Municipal
Code.
8-A.10 Integrate trees and shade into the built
environment to mitigate issues such as stormwater
runoff and the urban heat island effect.

Consistent. The proposed Project would include street
trees along the Project boundaries and throughout the
site.
8-A.25 Encourage water conservation through the
following strategies:
• Establish water and wastewater rates that
encourage conservation and provide for
system maintenance.
• Update the landscape irrigation ordinance
to continue reducing the use of potable
water for landscape irrigation to
CALGreen requirements. All aspects of
landscaping from the selection of plants to
soil preparation and the installation of
irrigation systems should be designed to
reduce water demand, retain runoff,
decrease flooding, and recharge
groundwater.
• Establish incentives for use of water
efficient fixtures and fittings.
• Expand the current landscaping ordinance
for parking lots (Section 18.168.210 of the
Municipal Code) to encourage the use of
drought tolerant species.
• Promote the use of permeable surfaces for
hardscape. Impervious surfaces such as
driveways, streets, and parking lots should
be minimized so that land is available to
absorb stormwater, reduce polluted urban
runoff, recharge groundwater, and reduce
flooding.
• Incorporate water holding areas such as
creek beds, recessed athletic fields, ponds,
cisterns, and other features that serve to
recharge groundwater, reduce runoff,
improve water quality, and decrease
flooding into the urban landscape.

Consistent. The proposed Project would include
landscaping and irrigation consistent with CalGreen
requirements which would be designed to reduce
water demand, retain runoff, decrease flooding, and
recharge groundwater.
8-A.37 Promote design in new development that
incorporates space for recycling containers and
other waste diversion facilities.

Consistent. The proposed Project would include
recycling containers for onsite waste. Additionally, the Project would comply with AB 341 that requires
diversion of a minimum of 75 percent of operational
solid waste
8-A.39 Continue implementation and enforcement
of the California Building and Energy codes to
promote energy efficient building design and
construction.

Consistent. As mentioned previously, the proposed
Project would comply with the CBC and California
Green Building Standards Code as included in
Chapter 15.16 and 15.04.

Project Design Features
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None.

Existing Plans, Programs, and Policies
None.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

12. MINERAL RESOURCES. Would the Project:
a) Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the state?
b) Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan
or other land use plan?
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
No Impact. In 1975, the California Legislature enacted the Surface Mining and Reclamation Act (SMARA), which, among other things, provided guidelines for the classification and designation of mineral lands. Areas are classified on the basis of geologic factors without regard to existing land use and land ownership. The areas are categorized into four Mineral Resource Zones (MRZs): MRZ-1: An area where adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence; MRZ-2: An area where adequate information indicates that significant mineral deposits are present, or where it is judged that a high likelihood exists for their presence; MRZ-3:

An area containing mineral deposits, the significance of which cannot be evaluated; and MRZ-4: An area where available information is inadequate for assignment to any other MRZ zone.

As shown in Figure 6-4 of the City’s General Plan, the Project site is located within MRZ-3. Additionally, the site has not been historically used for the extraction of mineral resources. Therefore, development of the site would not result in the loss of availability of a known mineral resource and no impacts would occur. b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on the general plan, specific plan or other land use plan? No Impact. As discussed in Response 6.3.12(a), no known valuable mineral resources exist on or near the Project site, and no mineral resource extraction activities occur on the site. In addition, the Project site is currently developed with commercial buildings and paved parking lots. Therefore, no impacts related to the loss of availability of a locally important mineral resource recovery site, as delineated on a local general plan, specific plan, or other land use plan, would occur as a result of Project implementation.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

13. 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?
b) Generation of excessive groundborne
vibration or groundborne noise levels?
c) For a project located within the vicinity of a
private airstrip or 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 expose people
residing or working in the project area to
excessive noise levels?
The discussion below is based on the Noise Impact Analysis prepared by Urban Crossroads, included as Appendix H.

Noise Element of the General Plan
The City’s General Plan Noise Element (Section 7.5) establishes limitations on sound levels to be received by various land uses. New development may cause existing noise‐sensitive land uses to be affected by noise generated from new developments, or it may locate a sensitive use in such a place that it is adversely affected by noise. Of particular attention to the City of Redlands are noise levels near loud transportation corridors, including roadways, the airport, railways. The Noise Element also states that typical noise standards for sensitive land uses include 60 dBA CNEL for exterior areas and 45 dBA CNEL for interior areas for single family, duplex, and multiple family land uses.

Municipal Code
Section 8.06.070 and Section 8.06.080 of the City’s Municipal Code outline the exterior and interior noise standards for stationary noise sources, as shown in Table N-1 below.

Table N-1: Significance Thresholds
Receiving Land Use Category Exterior
Time
Period
Exterior
Noise Level
- dBA
Interior
Time
Period
Interior
Noise Level
- dBA
Residential districts; public space; institutional
10:00 P.M.
- 7:00 A.M.
50 dBA Leq Anytime 45 dBA Leq
7:00 A.M. -
10:00 P.M.
60 dBA Leq
Commercial 10:00 P.M.
- 7:00 A.M.
60 dBA Leq Anytime 50 dBA
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7:00 A.M. -
10:00 P.M.
65 dBA Leq
Source: City of Redlands’s Municipal Code Sections 8.06.070 and 8.06.080 In addition, it is unlawful to cause the noise level on any residential property to exceed these interior noise standards:

1. For a cumulative period of more than 5 minutes in any hour;

2. Plus 5 dB(A) for a cumulative period of more than 1 minute in any hour; or

3. Plus 10 dB(A) for any period of time.

Section 8.06.120 of the City’s Municipal Code states that the noise standards shall not apply to noise sources associated with new construction, remodeling, rehabilitation, or grading of any private property, provided such activities take place between the hours of 7:00 am and 8:00 pm on weekdays, including Saturdays, with no activity taking place at any time on Sundays or federal holidays. In addition, all motorized equipment used in such activities are required to be equipped with functioning mufflers.

Existing Noise Levels
As detailed in the Noise Impact Analysis (Appendix H), to identify the existing ambient noise level environment, 24-hour noise level measurements were taken at six locations in the Project study area. The long-term noise level measurements were positioned as close to the nearest sensitive receiver locations, as possible to assess the existing ambient hourly noise levels surrounding the Project site. See Figure N-1, Noise Measurement Locations.

A description of the locations and the existing noise levels are provided in Table N-2.

Table N-2: 24-Hour Ambient Noise Level Measurements
Location1 Description
Energy Average
Noise Level
(dBA Leq)2 CNEL
Daytime Nighttime
L1 Northwest corner of the Third and Third Street
and Stuart Avenue 63.9 56.4 62.3
L2 Northeast Corner of Fifth Street and State Street 65.0 65.0 65.0 L3 120 Vine Street 55.4 53.8 54.9
L4 24 Kendall Street 65.0 61.4 68.8
L5 Southwest corner of the Eureka Street and
Redlands Boulevard 71.6 62.2 69.9
1 See Figure N-1 for the noise level measurement locations. 2 Energy (logarithmic) average levels. The long-term 24-hour measurement worksheets are included in Appendix H. "Daytime" = 7:00 a.m. to 10:00 p.m.; "Nighttime" = 10:00 p.m. to 7:00 a.m.

Source: Urban Crossroads, 2021 (Appendix H)
Sensitive receptors adjacent to the Project site are shown in Figure N-2, Receiver Locations.

R1: Location R1 represents the existing residence at 511 North Third Street, approximately 987 feet north of the Project site. Receiver R1 is placed at the private outdoor living area Redlands Joint Special Meeting of the
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(backyard). A 24-hour noise measurement near this location, L1, is used to describe the existing ambient noise environment.

R2: Location R2 represents the existing park at 151 North Fifth Street, approximately 405 feet east of the Project site. Receiver R2 is placed at the private outdoor use area. A 24-hour noise measurement was taken near this location, L2, to describe the existing ambient noise environment.

R3: Location R3 represents the existing residence at 120 Vine Street, approximately 46 feet south of the Project site. Receiver R3 is placed at the private outdoor living area (backyard).

A 24-hour noise measurement near this location, L3, is used to describe the existing ambient noise environment.

R4: Location R4 represents the existing residence at 24 Kendal Street, approximately 507 feet west of the Project site. Receiver R4 is placed at the private outdoor living area (backyard).

A 24-hour noise measurement near this location, L3, is used to describe the existing ambient noise environment.

R5: Location R5 represents an existing business at 308 State Street, approximately 92 feet west of the Project site. Receiver R5 is placed at the nearest location someone may stand for up to one hour and is representative of businesses surrounding the project site on all sides. A 24-hour noise measurement near this location, L4, is used to describe the existing ambient noise environment.

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Figure N-1 Noise Measurement Locations
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Figure N-2: Receiver Locations
Receiver Locations
Distance from receiver locations to the Project boundary (in feet) Redlands Joint Special Meeting of the
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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?
Less Than Significant Impact.

Construction
As described above, General Plan and Municipal Codes do not identify specific construction noise level limits and Section 8.06.120 of the City’s Municipal Code exempts construction noise between the hours of 7:00 am and 8:00 pm on weekdays, including Saturdays, with no activity taking place at any time on Sundays or federal holidays. The Project would comply with the City’s construction hours regulations, as verified by standard City Conditions of Approval. Neither the City’s General Plan nor Municipal Code establish numeric maximum acceptable construction source noise levels at potentially affected receivers, which would allow for a quantified determination of what CEQA constitutes a substantial temporary or periodic noise increase.

Thus, a construction-related noise level threshold is applied from the Criteria for Recommended Standard:

Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH). A division of the U.S. Department of Health and Human Services, NIOSH identifies a noise level threshold based on the duration of exposure to the source. To evaluate whether the Project would generate potentially significant short-term noise levels at off-site sensitive receiver locations a construction-related NIOSH noise level threshold of 85 dBA Leq is used (Urban Crossroads, 2020).

The highest construction noise levels are expected to occur when the temporary construction activities take place at the closest point for the center of Project construction activity to each of any nearby sensitive receiver locations. Noise generated by construction equipment would include a combination of trucks, power tools, concrete mixers, and portable generators that when combined can reach high levels, as shown on Table N3. Construction of the proposed Project is anticipated to occur in the following stages:
• Demolition
• Site Preparation
• Grading
• Building Construction
• Paving
• Architectural Coating
The noise generated from construction of the Project has been estimated using reference construction equipment noise levels and the CadnaA noise prediction model, which are listed in Table N-4, below. For each phase of construction, the nearest piece of equipment was analyzed at the closest distance of the proposed activity to the nearest sensitive receptor. Construction noise would be temporary in nature as the operation of each piece of construction equipment would not be constant throughout the construction day, and equipment would be turned off when not in use. The typical operating cycle for a piece of construction equipment involves one or two minutes of full power operation followed by three or four minutes at lower power settings.

Table N-3: Construction Equipment Noise Levels
Construction
Stage
Reference
Construction Activity1
Reference Noise
Level @ 50 Feet
(dBA Leq)
Highest Reference
Noise Level
(dBA Leq)
Demolition
Loaders 71
Demolition Equipment 69 71
Excavators 64
Site
Preparation
Crawler Tractors 77
77 Hauling Trucks 71
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Rubber Tired Dozers 71
Grading
Graders 79
Excavators 64 79
Compactors 67
Building
Construction
Cranes 67
Tractors 72 72
Welders 65
Paving
Pavers 70
Paving Equipment 69 70
Rollers 69
Architectural
Coating
Cranes 67
Air Compressors 67 67
Generator Sets 67 1 Update of noise database for prediction of noise on construction and open site expressed in hourly average Leq based on estimated usage factor.

Source: Urban Crossroads, 2021 (Appendix H)
The noise volumes in Table N-3 were applied to the locations of the closest sensitive receptors, the closest of which is R3, the backyard of the existing residence on Vine Street. To assess the worst-case construction noise levels, the Project construction noise analysis relies on the highest noise level impacts when the equipment with the highest reference noise level is operating at the closest point from the edge of primary construction activity (Project site boundary) to each receiver location. As shown in Table N-4, the unmitigated construction noise levels are expected to range from 62.0 to 74.4 dBA Leq, which would satisfy the 85 dBA Leq significance threshold. Therefore, the noise impacts due to Project construction noise would be less than significant at all noise sensitive receiver locations.

Table N-4: Construction Equipment Noise Level Compliance Receiver
Location1
Construction Noise Levels (dBA Leq)
Threshold
(dBA Leq)
Threshold
Exceeded?
Site
Preparation Grading
Building
Construction Paving
Architectural
Coating
Highest
Levels2
R1 51.7 62.0 46.7 44.7 41.7 62.0 85 No
R2 53.7 66.3 48.7 46.7 43.7 66.3 85 No
R3 52.7 74.4 47.7 45.7 42.7 74.4 85 No
R4 69.5 65.1 64.5 62.5 59.5 69.5 85 No
R5 62.1 72.7 57.1 55.1 52.1 72.7 85 No 1 Construction noise source and receiver locations are shown on Exhibit N-2 2 Construction noise level calculations based on distance from the Project site boundaries (construction activity area) to nearby receiver locations. CadnaA construction noise model inputs are included in Appendix H Source: Urban Crossroads, 2021 (Appendix H)
Operations
Development of the proposed Project would result in a mixed-use development with 700 multi-family dwelling units, 71,778 SF of ground-floor retail, approximately 12,238 SF of office space, amenity areas, community building, a 1,721 SF rooftop restaurant space with a rooftop deck, and a 14,500 SF drugstore.

Potential long-term noise impacts associated with Project operation would include exterior traffic noise, operational noise, and stationary equipment noise.

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Traffic Noise
The Project would generate 1,866 weekday daily trips, with 682 trips produced in the weekday AM peak hour and 217 trips produced in the weekday PM peak hour (Urban 2021). The noise generated from these vehicular trips has been identified through utilization of the FHWA Roadway Noise Model, and a comparison of noise generated by traffic volumes with and without the Project is provided in Table N-5.

Neither the General Plan nor Municipal Code quantifies what constitutes a significant degradation of the future acoustic environment. Therefore, thresholds from the FTA Transit Noise and Vibration Impact Assessment (2018) have been utilized, which identifies noise impacts by comparing the existing noise levels and the future noise levels with the proposed Project. Based on the FTA guidance, a substantial increase in ambient noise from vehicular traffic could occur when the noise levels at noise-sensitive land uses (e.g., residential, etc.) are less than 60 dBA CNEL and the Project creates an increase of 3 dBA CNEL or greater noise level increase; or when noise levels range from 60 to 65 dBA CNEL and the Project creates 2 dBA CNEL or greater noise level increase.

Table N-5 shows that in existing year, the cumulative plus Project off-site traffic noise level increases range from 0.0 to 0.3 dBA CNEL. Therefore, land uses adjacent to the study area roadway segments would experience less than significant noise level impacts due to unmitigated Project-related traffic noise levels.

Table N-5: Existing Cumulative With Project Traffic Noise Level Increases ID Road Segment Receiving
Land Use1
CNEL at Nearest Receiving
Land Use
(dBA)2
No
Project
With
Project
Project
Addition
1 Orange St. n/o Redlands Bl. Non-Sensitive 66.4 66.7 0.3 2 Brookside Av. w/o Eureka St. Sensitive 65.8 65.8 0.0
3 Citrus Av. e/o Orange St. Non-Sensitive 62.9 63.0 0.1 1 Based on a review of existing aerial imagery. Noise sensitive uses limited to existing residential land uses. 2 The CNEL is calculated at the boundary of the right-of-way of each roadway and the property line of the nearest receiving land use.

Source: Urban Crossroads, 2021 (Appendix H)
Table N-6 shows that the Project offsite traffic noise level increases range from 0.0 to 0.3 dBA CNEL in buildout year 2025. Therefore, land uses adjacent to the Project area roadway segments would experience less than significant noise level impacts due to unmitigated Project-related traffic noise levels in 2025.

Table N-6: 2025 Cumulative With Project Traffic Noise Level Increases ID Road Segment Receiving
Land Use1
CNEL at Nearest Receiving
Land Use
(dBA)2
No
Project
With
Project
Project
Addition
1 Orange St. n/o Redlands Bl. Non-Sensitive 66.9 67.2 0.3 2 Brookside Av. w/o Eureka St. Sensitive 66.3 66.3 0.0
3 Citrus Av. e/o Orange St. Non-Sensitive 63.3 63.4 0.1 1 Based on a review of existing aerial imagery. Noise sensitive uses limited to existing residential land uses. 2 The CNEL is calculated at the boundary of the right-of-way of each roadway and the property line of the nearest receiving land use.

Source: Urban Crossroads, 2021 (Appendix H)
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Operational Noise
It is expected the on-site Project-related noise sources would include sources such as roof-top air conditioning units, commercial loading dock activity, trash enclosure activity, parking lot vehicle movements, courtyard/paseo activity, and outdoor pool/spa activity. Using the reference noise levels to represent the proposed Project operations, operational source noise levels were calculated that are expected to be generated at the Project site and the Project-related noise level increases that would be experienced at each of the sensitive receiver locations. The City’s Municipal Code Section 8.06.070 does not allow exterior noise to substantially exceed 50 dBA between 10:00 p.m. and 7:00 a.m., and 60 dBA between 7:00 a.m. and 10:00 p.m. As shown in Table N-7, the daytime hourly noise levels at the off-site receiver locations are expected to range from 34.8 to 56.6 dBA Leq. The nighttime hourly noise levels at the off-site receiver locations are expected to range from 42.5 to 47.7 dBA Leq.

Table N-7: Project Operational Noise Level Compliance
Receiver
Location1
Project Operational Noise
Levels
(dBA Leq)2
Noise Level Standards
(dBA Leq)3
Noise Level Standards
Exceeded?4
Daytime Nighttime Daytime Nighttime Daytime Nighttime
R1 34.8 34.8 60 55 No No
R2 37.2 37.2 60 55 No No
R3 56.6 48.6 60 55 No No
R4 37.7 37.6 60 55 No No
R5 37.8 37.8 60 55 No No 1 See Exhibit 9-A for the receiver locations. 2 Proposed Project operational noise levels as shown on Table 10-1. 3 City of Redlands Municipal Code, Section 8.06.070 (Appendix 3.1) 4 Do the estimated Project operational noise source activities exceed the noise level standards? "Daytime" = 7:00 a.m. to 10:00 p.m.; "Nighttime" = 10:00 p.m. to 7:00 a.m.

Source: Urban Crossroads, 2021 (Appendix H)
Table N-7 shows the operational noise levels associated with the Project would satisfy the City’s 60 dBA Leq daytime and 50 dBA Leq nighttime exterior noise level standards at all nearby receiver locations. The differences between the daytime and nighttime noise levels are largely related to the duration of noise activity. Noise activity associated with the trash enclosures, courtyard, paseo, and pool/spa are expected to be limited to the daytime hours between 7:00 a.m. and 10:00 p.m. The Noise Impact Analysis prepared by Urban Crossroads, included as Appendix H includes the detailed noise analysis of operational noise levels from each noise source and activity, as well as model inputs including the existing perimeter walls used to estimate the Project operational noise levels presented in this section.

To describe the Project operational noise level contributions, the Project operational noise levels were combined with the existing ambient noise levels measurements for the nearby receiver locations to determine the Project increase. The Federal Interagency Committee on Noise (FICON) developed guidance to be used for the assessment of project-generated increases in noise levels that consider the ambient noise level. FICON identifies a readily perceptible 5 dBA or greater project-related noise level increase is considered a significant impact when the noise criteria for a given land use is exceeded. Per the FICON, in areas where the without project noise levels range from 60 to 65 dBA, a 3 dBA barely perceptible noise level increase appears to be appropriate for most people. When the without project noise levels already exceed 65 dBA, any increase in community noise louder than 1.5 dBA or greater is considered a significant impact if the noise criteria for a given land use is exceeded, since it likely contributes to an existing noise exposure exceedance.

As indicated on Tables N-8 and N-9, the Project would generate an unmitigated daytime and nighttime operational noise level increases ranging from 0.0 to 1.7 dBA Leq at the nearby receiver locations. Projectrelated operational noise level contributions the increases at the sensitive receiver locations would be less than significant.

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Table N-8 Daytime Project Operational Noise Level Contributions Receiver
Location1
Total Project
Operational
Noise Level2
Measurement
Location3
Reference
Ambient
Noise
Levels4
Combined
Project
and
Ambient5
Project
Increase6
Increase
Criteria
Increase
Criteria
Exceeded?
R1 34.8 L1 63.9 63.9 0.0 3.0 No
R2 37.2 L2 65.0 65.0 0.0 1.5 No
R3 56.6 L2 65.0 65.6 0.6 1.5 No
R4 37.7 L3 55.4 55.5 0.1 5.0 No
R5 37.8 L4 65.0 65.0 0.0 1.5 No 1 See Exhibit 9-A for the receiver locations. 2 Total Project daytime operational noise levels as shown on Table N-7 3 Reference noise level measurement locations as shown on Figure N-1 4 Observed daytime ambient noise levels as shown on Table N-2 5 Represents the combined ambient conditions plus the Project activities. 6 The noise level increase expected with the addition of the proposed Project activities.

Source: Urban Crossroads, 2021 (Appendix H)
Table N-9 Nighttime Operational Noise Level Contributions Receiver
Location1
Total Project
Operational
Noise Level2
Measurement
Location3
Reference
Ambient
Noise
Levels4
Combined
Project
and
Ambient5
Project
Increase6
Increase
Criteria
Increase
Criteria
Exceeded?
R1 34.8 L1 56.4 56.4 0.0 5.0 No
R2 37.2 L2 65.0 65.0 0.0 1.5 No
R3 48.6 L2 65.0 65.1 0.1 1.5 No
R4 37.6 L3 53.8 53.9 0.1 5.0 No
R5 37.8 L4 61.4 61.4 0.0 3.0 No 1 See Figure N-2 for the receiver locations. 2 Total Project nighttime operational noise levels as shown on Table N-7 3 Reference noise level measurement locations as shown on Figure N-1. 4 Observed nighttime ambient noise levels as shown on Table N-2 5 Represents the combined ambient conditions plus the Project activities. 6 The noise level increase expected with the addition of the proposed Project activities.

Source: Urban Crossroads, 2021 (Appendix H)
Therefore, the operational noise impacts are considered less than significant at the nearby noise-sensitive receiver locations.

The Project is required to satisfy the City of Redlands 45 dBA CNEL residential interior noise level standards as a part of the permit issuance and building plan check process. Additionally, operational noise from HVAC units would be required to comply with the Municipal Code Section 8.06.070, which does not allow exterior noise to substantially exceed 50 dBA for residential uses and 60 dBA for commercial uses between 10:00 p.m. and 7:00 a.m., and 60 dBA for residential uses and 65 dBA for commercial uses between 7:00 a.m. and 10:00 p.m. Compliance with the Municipal Code would ensure that a substantial permanent increase in ambient noise levels would not occur, and noise related to HVAC units would be less than significant.

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b) Generation of excessive groundborne vibration or groundborne noise levels? Less Than Significant Impact.

Construction
Construction activity can result in varying degrees of ground vibration, depending on the equipment and methods used, distance to the affected structures and soil type. It is expected that ground-borne vibration from Project construction activities would cause only intermittent, localized intrusion. The proposed Project’s construction activities most likely to cause vibration impacts are:
• Heavy Construction Equipment: Although all heavy mobile construction equipment has the potential of causing at least some perceptible vibration while operating close to buildings, the vibration is usually short-term and is not of sufficient magnitude to cause building damage. • Trucks: Trucks hauling building materials to construction sites can be sources of vibration intrusion if the haul routes pass through residential neighborhoods on streets with bumps or potholes.

Repairing the bumps and potholes generally eliminates the problem.

Ground-borne vibration levels resulting from construction activities occurring within the Project site were estimated by data published by the Federal Transit Administration (FTA). Construction activities that would have the potential to generate low levels of ground-borne vibration within the Project site include grading.

Table N-10 presents the expected Project related vibration levels at each of the sensitive receiver locations.

There are several different methods that are used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal. The PPV is most frequently used to describe vibration impacts to buildings. Decibel notation (VdB) is commonly used to measure RMS. The City of Redlands Municipal Code, Section 8.06.020, defines the vibration perception threshold as 0.01 inches per second (in/sec) RMS. Based on FTA methodology, an RMS of 0.01 in/sec equates to 0.04 in/sec PPV.

Decibel notation (VdB) serves to reduce the range of numbers used to describe human response to vibration.

Typically, ground-borne vibration generated by man-made activities attenuates rapidly with distance from the source of the vibration. Sensitive receivers for vibration include structures (especially older masonry structures), people (especially residents, the elderly, and sick), vibration-sensitive equipment and/or activities. Based on the reference vibration levels provided by the FTA, a large bulldozer represents the peak source of vibration with a reference velocity of 0.089 in/sec PPV at 25 feet. Table N-10 shows the highest construction vibration levels in PPV are expected to range from 0.000 to 0.036, which would be below the City’s vibration threshold of 0.040 PPV. In addition, the impacts at the site of the closest sensitive receivers are unlikely to be sustained during the entire construction period and would only occur during the times that heavy construction equipment is operating adjacent to the Project site perimeter. Furthermore, construction at the Project site would be restricted to daytime hours consistent with City’s Municipal Code requirements, thereby eliminating potential vibration impact during the sensitive nighttime hours. As such, construction vibration impacts would be less than significant.

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Table N-10 Project Construction Vibration Levels
Receiver
Location1
Distance to
Const.

Activity
(Feet)2
Typical Construction Vibration Levels
PPV (in/sec)3 Thresholds
PPV
(in/sec)4
Thresholds
Exceeded?5
Small
bulldozer
JackhammerLoaded
Trucks
Large
Bulldozer
Highest
Vibration
Level
R1 987' 0.000 0.000 0.000 0.000 0.000 0.040 No
R2 399' 0.000 0.001 0.001 0.001 0.001 0.040 No
R3 46' 0.001 0.014 0.030 0.036 0.036 0.040 No
R4 494' 0.000 0.000 0.001 0.001 0.001 0.040 No
R5 83' 0.000 0.006 0.013 0.015 0.015 0.040 No
1 Construction receiver locations are shown on Figure N-2 2 Distance from receiver location to Project construction boundary. 3 Based on the Vibration Source Levels of Construction Equipment 4 City of Redlands Municipal Code Section 8.06.020
5 Does the peak vibration exceed the acceptable vibration thresholds? "PPV" = Peak Particle Velocity
Source: Urban Crossroads, 2021 (Appendix H)
Operation
The proposed mixed-use Project would not include any equipment that would result in high vibration levels, which are more typical for large industrial projects. While groundborne vibration within and surrounding the Project site may occur from heavy-duty vehicular travel (e.g., refuse trucks and delivery trucks) on the nearby local roadways, this would not result in significant vibration impacts to the proposed Project or surrounding sensitive uses. As such, vibration impacts associated with operation of the proposed Project would be less than significant.
c) For a project located within the vicinity of a private airstrip or 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 expose people residing or working in the project area to excessive noise levels?
No Impact. The proposed Project is not within an airport land use plan. The proposed Project is located approximately 2.45 miles southwest from the Redlands Municipal Airport; however, the Project site is located outside of the 60 and 65 dBA CNEL noise contours of the Redlands Municipal Airport. In addition, there are no private airstrips within the Project’s vicinity. Therefore, proposed Project would not expose people residing or working in the Project area to excessive noise levels from aircraft. No impacts would occur from aircraft noise.

Project Design Features
None.

Existing Plans, Programs, or Policies
PPP N-1: The Project plans shall state the Project is required to comply with construction hours of operation outlined in Section 8.06.120 of the City’s Municipal Code; construction activities shall take place between the hours of 7:00 am and 8:00 pm on weekdays, including Saturdays, with no activity taking place at any time on Sundays or federal holidays. In Redlands Joint Special Meeting of the
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addition, all motorized equipment used in such activities are required to be equipped with functioning mufflers.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

14. POPULATION 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)?
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
a) Induce substantial unplanned population growth in an area, either directly or indirectly? Less Than Significant Impact. The proposed Project would redevelop the Project site to provide 700 multifamily dwelling units, 71,778 SF of ground-floor retail, approximately 12,328 SF of office space, amenity areas, community building, a 1,721 SF rooftop restaurant space with a rooftop deck, and a 14,500 SF drugstore. According to the City of Redlands General Plan EIR, the city has an average of 2.65 persons per household and is expected to by 4,355 residential units and 10,964 persons by 2035 with buildout of the General Plan, according. However, this 2.65 person per household ratio considers all housing types within the city, including single-family residences, which consists of 68 percent of the housing within the city and typically attracts and accommodates larger household sizes.

The proposed Project’s unit mix consists of 7 live/work units, 52, zero-bedroom, 91 studios, 338 onebedroom, 178 two-bedroom, and 34 three-bedroom residential units. The size of the units would range size from 450 SF studios to approximately 1,500 SF three-bedroom units. These are smaller multi-family units that would not accommodate or attract large households. The proposed unit mix and smaller unit size of the Project suggests an orientation towards singles and young families that differ significantly in demographic features from the relatively large average Redlands household size of approximately 2.65 members per household.

Therefore, a more accurate calculation of the anticipated population that would be generated by the proposed Project was determined by utilizing U.S. Census data for a market area that represents similar multi-family residential housing types and costs of rent. As shown in Table POP-1, at full occupancy the Project would house approximately 1,192 residents.

Table POP-1: Anticipated Residents at Full Occupancy
Unit Type Number of
Units
Persons per
Unit1
Total
Residents
Studio/Live-Work/
Zero-bedroom2
150 1.31 197
One-bedroom 338 1.42 480
Two-bedroom 178 2.26 402
Three-bedroom 34 3.33 113
Total 700 - 1,192 1Persons per unit retrieved from Census American Community Survey (ACS) 2019 Microdata Sample (PUMS)
2For purposes of this analysis, Live-Work units, Zero-bedroom units, and studio units were tabulated together
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The 1,192 residents at full occupancy would constitute a 1.6 percent increase over the 2020 City of Redlands population of 73,168 (US Census). In addition, the 700 new multi-family units would constitute a 2.5 percent increase in the total number of residential units in the city, and a 12.3 percent increase in the number of the multi-family residential units (5+ units) within the city.

It is projected that the city will experience a population increase of approximately 11,300 residents or approximately 16.3 percent from 2016 to 2045. Thus, the population of the Project would be within the projected population growth, based on the US Census and within the growth projected in the City’s General Plan EIR. Similarly, SCAG anticipates the number of housing units throughout the County would increase by 6,400 units or approximately 26.2 percent from 2016 to 2045. Thus, the 700 new multi-family units would also be within the SCAG projected growth. The Project would also help provide the needed numbers and types of housing units identified in the City’s 2013-2021 Housing Element as well as those included in the draft 2021-2019 Housing Element Update.

Based on employee generation factors utilized by SCAG, the Project would result in 1 employee for every 124 square feet of retail space and 1 employee for every 697 square feet of office space. Thus, the proposed 87,999 SF of retail space, including the ground floor retail, restaurants, and drugstore, would generate approximately 710 employees at full occupancy of the retail space. The proposed 12,328 SF of office space would generate approximately 18 employees. As of 2017, the City of Redlands had approximately 41,609 jobs (SCAG 2019). Therefore, the additional 728 employment opportunities would be 1.7 percent of the existing jobs within the city; and therefore, would not result in induced unplanned employment growth. As such, the proposed Project would not induce substantial unplanned population growth in the area, and impacts would be less than significant. b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The proposed Project would not displace a substantial number of existing people or housing, as no housing currently exists onsite. The Project site would construct 700 multi-family dwelling units. Therefore, there would be no impacts related to the displacement of substantial numbers of existing people or housing.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

15. PUBLIC 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 service ratios, response times or
other performance objectives for any of the
public services:

Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for:

Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
Fire Protection – Less than Significant Impact. Fire protection services in the Project area are provided by the Redlands Fire Department (RFD). The Fire Department provides services including fire prevention and suppression, emergency medical services, technical rescue, and hazardous materials response. The Fire Department consists of approximately 55 total sworn personnel, (including 18 firefighter/paramedics and 37 firefighter/EMTs) and covers an area of 37 square miles. Each year, Redlands averages 264 fires, including 64 vegetation fires, 53 structure fires, 47 vehicle fires, and 100 miscellaneous fires.

RFD operates four fire stations in the city. Additionally, the RFD has automatic mutual aid agreements with all surrounding fire agencies. The City’s agreements with Loma Linda Stations 251 and 252 (to the west) and San Bernardino County Fire (Mentone Station 9 to the east, City of San Bernardino Station 228 and 231 to the northwest) are facilitated by a consolidated dispatch center operated by CONFIRE. CONFIRE is a multiagency organization that functions as the result of a 25-year Joint Powers Agreement for the collective provision of fire, rescue, and emergency medical dispatch services.

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The closest fire station is Station 261 located at 525 East Citrus Avenue, which is approximately 0.4 roadway miles from the Project site. Station 263 is located at 10 W Pennsylvania Avenue approximately 1.2 roadway miles from the Project site. In addition, Station 264 is located at 1270 West Park Avenue approximately

1.3 roadway miles from the Project site.

The proposed Project would remove the existing Redlands Mall and develop a mixed-use development including 700 multi-family dwelling units, 71,778 SF of ground-floor retail, 12,328 SF of office space, amenity areas, community building, a 14,500 SF drugstore, and a 1,721 SF rooftop restaurant space with a rooftop deck located downtown. Implementation of the Project would be required to adhere to California Fire Code (Title 24, Part 9 of the California Code of Regulations) included in Chapter 15.04 of the City’s Municipal Code, which regulates fire-resistant construction, emergency planning, fire protection system, and appropriate emergency access throughout the site. As part of the permitting process, the Project plans would be reviewed by the City’s Fire Department and the Building Division (part of the Development Services Department) to ensure that the Project plans meet the fire protection requirements. Additionally, the proposed Project would be required to comply with City fire suppression standards including current California Building Code and adequate fire access.

The calls for service from the additional population at the Project site could result in an increase in response times, if the calls coincide with other calls for service. However, fire protection equipment and staffing can be augmented by the City as needed (with assistance from revenue provided by the Project and the development impact fees required for the proposed Project) to expand fire protection and emergency medical staffing and equipment provided from existing stations and better accommodate simultaneous service calls.

Because the Project site is within 2.7 miles of four existing fire stations and the Project site is within a developed area that is currently served by these stations, the Project would not result in the requirement to construct a new fire station. In addition, Chapter 3.60 of the City’s Municipal Code requires a public facility fee to be collected prior to the issuance of a building permit. The purpose of the public facility fee is to ensure public facilities are available concurrent with the need for such facilities caused by new development within the city.

Overall, with the four existing fire stations within 2.7 miles of the Project site, the area has adequate nearby fire facilities to serve the proposed Project in addition to the existing service needs of the area; and construction of a new or expanded fire station would not be required as a result of the proposed Project.

Thus, the Project would not result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered fire protection facilities. Also, existing fire protection facilities and staffing could be augmented as needed (with assistance from revenue provided by the Project and the public facilities fee required prior to the issuance of building permits per Chapter 3.60 of the Municipal Code) to expand fire protection and emergency medical staffing and equipment provided from existing stations. Therefore, impacts related to fire protection services would be less than significant.

Police Protection – Less Than Significant Impact. The City of Redlands receives public safety services from the Redlands Police Department. The main police station is located at 1270 West Park Avenue, with four other divisions located citywide. The Police Department personnel is made up of approximately 100 volunteers, 80 sworn officers and 58 full and part-time civilians, resulting in a service level of 1.12 officers per 1,000 residents. In 2020, the Department had an average response time of 9.08 minutes for Priority one police service calls and a service ratio of 1.1 officers per 1,000 residents. Although there are no industry standards for response time to emergency calls, according to the Redlands Police Department, a response time of 4.5 minutes is desirable in a city of this size.

Due to the increase in onsite people that would occur from implementation of the Project, an incremental increase in demand for police protection would occur. As described previously, the residential population of the Project site at full occupancy would be approximately 1,192 residents and based on the Police Department’s staffing of 1.1 officers per 1,000 residents, the proposed Project would require 1.31 additional officers.

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Since the need by the Project is approximately one officer, the Project would not require the construction or expansion of the City’s existing policing facilities and development impact fees would contribute to the cost of hiring one additional officer. Thus, substantial adverse physical impacts associated with the provision of new or expanded facilities would not occur. In addition, the Project Applicant/Developer would be required to pay any applicable development impact fees pursuant to the Redlands Municipal Code, included as PPP PS-3 below. Therefore, impacts related to police services would be less than significant.

Schools – Less Than Significant Impact. The Project site is located within the Redlands Unified School District (RUSD), which serves Redlands and the surrounding communities of Mentone and Crafton, as well as Loma Linda and the eastern portion of Highland. There are currently 17 elementary schools, five middle schools, and six high schools within the RUSD. The schools that serve the site are listed below:
• Franklin Elementary School located at 850 E Colton Avenue, which is 1.1 miles from the Project site. • Cope Middle School located at 1000 W Cypress Avenue, which is 1.6 miles from the Project site. • Redlands High School located at 840 E Citrus Avenue, which is 0.9 miles from the Project site.

The Project would develop 700 multi-family residences. The RUSD student generation rate for multi-family residences is 0.21 students per residence for grades K-6; 0.06 students per residence for grades 7-8; and

0.09 students per residence for grades 9-12. As shown in Table PS-1 below, based on the existing capacity of the schools serving the Project area, and the number of students that would be generated by the Project, the existing elementary, middle, and high school would be able to serve the Project.

Table PS-1: School Capacity and Project Generated Students School Enrollment
Capacity
2020-2021
Enrollment1
Existing
Remaining
Capacity
Students
Generated by
Project
Remaining
Capacity with
Project
Franklin
Elementary
School
749 596 153 147 6
Cope Middle
School
1,507 1,329 178 42 136
Redlands High
School
3,930 2,340 1,590 63 1,527
1 Source: City of Redlands Revised Draft Environmental Impact Report of the Redlands General Plan Update and Climate Action Plan, Table 3.13- 3: Redlands Unified School District Enrollment; 2020-2021 Enrollment Data obtained from the California Department of Education, Accessed:
https://dq.cde.ca.gov/dataquest/
As shown, the schools serving the Project have additional capacity to serve the population increase associated with the proposed Project. In addition, pursuant to Government Code Section 65995 et seq., the need for additional school facilities is addressed through compliance with school impact fee assessment. SB 50 (Chapter 407 of Statutes of 1998) sets forth a state school facilities construction program that includes restrictions on a local jurisdiction’s ability to condition a project on mitigation of a project’s impacts on school facilities in excess of fees set forth in the Government Code. These fees are collected by school districts at the time of issuance of building permits for development projects. Pursuant to Government Code Section 65995 applicants shall pay developer fees to the appropriate school districts at the time building permits are issued; and payment of the adopted fees provides full and complete mitigation of school impacts.

Therefore, with implementation of PPP PS-1, which would require the payment of applicable school development impact fees pursuant to Government Code Section 65995, impacts related to school facilities would be less than significant.

Parks – Less Than Significant Impact. As discussed in Response 6.3.16(a) below, according to the City’s General Plan Parks and Recreational Open Space Element (Section 7.2), there are several different kinds of parks in Redlands, including community parks, neighborhood parks, and pocket parks. The City establishes a parkland/recreational space standard of 5 acres per 1,000 residents, consistent with State law. The Redlands Joint Special Meeting of the
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current (as of 2016) parkland exceeds this standard with a total parkland area of 424.2 acres. The parks closest to the Project site include the following:
• Smiley Park located at 101 Parkwood Drive, which is 0.3 miles from the Project site. This park is

9.42 acres and contains the following facilities: trails, benches, restrooms, and open grassy areas. • Jennie Davis Park located at 899 Redlands Boulevard, which is 0.5 miles from the Project site. This park is 5.2 acres and contains the following facilities: picnic tables, seating, open grassy area, and a playground.
• Sylvan Park located at 601 N University St, which is 1 mile from the Project site. This park is 23 acres and contains the following facilities: baseball/softball fields, horseshoe pits, lawn bowling, open grassy areas, picnic areas, playground equipment, restrooms, shuffleboards, a stage/bandstand area, trails/nature study, and volleyball.

The Project would develop a new mixed-use development which would result in 700 new multi-family residences and an increase in the use of public parks. The Project would result in a demand for 5.96 acres of parkland/open space. The proposed Project would include 102,525 SF (2.35 acres) of open space which includes landscaped plazas, courtyards, a private pool, and pedestrian paseos. A portion of the Project’s Park demand would be met onsite with the provision of 102,525 SF of open space area, consisting of a pool, sitting areas, garden areas, walkways, and courtyards. In addition, the Project would be required to pay parkland fees pursuant to Municipal Code Chapter 3.32, which requires that open space and parks fees shall be collected from all applicants for development projects (included as PPP PS-2), which would be used for the purpose of acquiring, developing, improving and expanding open space and park lands identified in the City's open space and park lands acquisition and development capital improvement plan in accordance with the amounts established by resolution of the City Council. The city currently has over 424.2 acres of parkland, with 37.6 acres within one mile of the Project site. Therefore, with implementation of PPP PS-2, which would require the payment of applicable park related fees, impacts related to the need to provide new or altered park and recreation facilities in order to maintain acceptable service ratios would be less than significant.

Other Services – Less Than Significant Impact. The proposed Project would redevelop the Project site with 700 residential units within an area that would redevelop the Redlands Mall. The new residences would result in a limited incremental increase in the need for additional services, such as public libraries and post offices, etc. Because the Project area is already served by other services and the Project would result in a limited increase in residences, the Project would not result in the need for new or physically altered facilities to provide other services, the construction of which could cause significant environmental impacts. Therefore, impacts would be less than significant.

Project Design Features
None.

Existing Plans, Programs, or Policies
PPP PS-1: Schools Development Impact Fees. Prior to issuance of building permit, the Developer shall pay applicable school development impact fees levied by the Redlands Unified School District pursuant to the School Facilities Act (Senate Bill [SB] 50, Stats. 1998, c.407).

PPP PS-2: Park Fees. As a Condition of Approval of a tentative map, the Developer shall pay applicable park related fees pursuant to Redlands Municipal Code Chapter 3.32.

PPP PS-3: Development Impact Fees. As a standard requirement and included as a Condition of Approval for the Project, and prior to issuance of any building permits for the Project, the Developer shall pay all applicable City of Redlands Development Impact Fees (DIF) pursuant to the Redlands Municipal Code and/or adopted fee schedules.

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Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

16. RECREATION.
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?
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?
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that physical deterioration of the facility would be accelerated? Less Than Significant Impact. According to the City’s General Plan Parks and Recreational Open Space Element (Section 7.2), there are several different kinds of parks in Redlands, including community parks, neighborhood parks, and pocket parks. In addition to parks, the City of Redlands contains various recreational facilities, including the Redlands Community Center, the Community Senior Center, the Joslyn Senior Center, neighborhood community gardens, and the Carriage House. This also includes large open spaces, including the San Timoteo Canyon, Live Oak Canyon, and the Crafton Hills, which also provide recreational space.

The City establishes a parkland/recreational space standard of five acres per 1,000 residents, consistent with State law. As discussed previously, the Project would develop a new mixed-use development including a 700-unit multi-family residential development, which would result in 1,192 new residences and a modest increase in the use of public parks. Based on this formula, the Project would result in a demand for 5.96 acres of parkland/recreational space. The Project would be required to pay parkland fees pursuant to Municipal Code Chapter 3.32, which requires that open space and parks fees shall be collected from all applicants for development projects (included as PPP PS-2), which would be used for the purpose of acquiring, developing, improving and expanding open space and park lands identified in the City's open space and park lands acquisition and development capital improvement plan in accordance with the amounts established by resolution of the City Council. In addition, as described previously, the city currently has over 424.2 acres of parkland, with 37.6 acres within one mile of the Project site. Therefore, impacts related to the increase the use of existing parks and recreational facilities, such that physical deterioration of the facility would be accelerated would be less than significant.
b) Require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Less than Significant Impact. The proposed Project would include 102,525 SF of open space area including recreational community amenities consisting of a pool, sitting areas, garden area, walkways, and gathering spaces for use by residents within the complex. In addition, private patio space would be available to residents in designated floor plans. The impacts of development of the park are considered part of the impacts of the proposed Project as a whole and are analyzed throughout the various sections of this document. For example, activities such as excavation, grading, and construction as required for the Project, Redlands Joint Special Meeting of the
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including open space areas, are analyzed in the Air Quality, Greenhouse Gas Emissions, Noise, and Transportation Sections.

In addition, as discussed above, the Project would contribute park development fees pursuant to Municipal Code Chapter 3.32 to be used towards the future expansion or maintenance parks and recreational facilities, these fees are standard with every residential development, and the proposed Project would not require the construction or expansion of other recreational facilities that might have an adverse physical effect on the environment. As a result, impacts would be less than significant.

Project Design Features
None.

Existing Plans, Programs, or Policies
PPP PS-2: Park Fees. Listed previously in Section 15, Public Services.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

17. TRANSPORTATION. Would the Project:
a) Conflict with a program, plan, ordinance or
policy addressing the circulation system, including
transit, roadway, bicycle and pedestrian
facilities?
b) Would the project conflict or be inconsistent
with CEQA Guidelines section 15064.3,
subdivision (b)?
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses
(e.g., farm equipment)?
d) Result in inadequate emergency access?
The discussion below is based on the Traffic Analysis, State Street Village-Redlands, July 30, 2021, prepared by Urban Crossroads, included as Appendix I and the State Street Village Vehicle Miles Travelled (VMT) Screening Evaluation, prepared by Urban Crossroads included as Appendix J. a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Less Than Significant Impact. The proposed Project involves the construction of a mixed-use development with 700 multi-family dwelling units, 71,778 SF of ground-floor retail, 14,500 SF drug store, 12,328 SF of office space, amenity areas, community building, and a 1,721 SF rooftop restaurant space with a rooftop deck. Vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project area. Additionally, the Project would expand 3rd Street south to Citrus Avenue and State Street west to 3rd Street, in line with circulation plans in the City of Redlands General Plan.

A Traffic Analysis, dated July 2021, was prepared for the Project by Urban Crossroads (Urban, 2021). As shown on Table T-1, the mixed-use development would generate approximately 1,866 net weekday daily trips, with 682 net trips produced in the weekday AM peak hour and 217 net trips produced in the weekday PM peak hour when compared to the existing land uses (Urban, 2021).

Table T-1: Project Trip Generation
Land Use
AM Peak Hour PM Peak Hour
In Out Total In Out Total Daily
Existing Land Uses1 57 31 88 156 163 319 3,718
Proposed Project 396 374 770 312 225 536 5,584
Net Trip Generation 339 343 682 156 62 217 1,866
1 Based on existing driveway counts observed for the existing land uses.

Source: Urban Crossroads, 2021 (Appendix I)
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The Project has been designed to construct onsite roadway improvements consistent with the City guidelines.

Additionally, the Project would pay Development Impact Fees as conditioned by the City. The fees shall be collected and utilized as needed by the City to construct the improvements necessary to maintain the required Level of Service (LOS) and build or improve roads to their build-out level.

Alternative Transportation
The proposed Project would construct onsite sidewalks and pedestrian paseos to provide access to the Arrow Line located approximately 0.16-mile from the Project site. Additionally, the Project would restripe Citrus Avenue to include a Class II bike lane. As such, the proposed Project would enhance pedestrian and bicycle access in the Project vicinity. Therefore, the Project would not conflict with alternative transportation and Project impacts to transit, bicycle, and pedestrian facilities would be less than significant. b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less Than Significant Impact. Senate Bill 743 (SB 743) was signed into law on September 27, 2013 and changed the way that public agencies evaluate transportation impact under CEQA. A key element of this law is the elimination of using auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant transportation impacts under CEQA. The legislative intent of SB 743 was to "more appropriately balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas (GHG) emissions." According to the law, "traffic congestion shall not be considered a significant impact on the environment" within CEQA transportation analysis.

SB 743 does not prevent a city or county from continuing to analyze delay or LOS as part of other plans (i.e., a city’s General Plan), studies, congestion management and transportation improvements, but these metrics may no longer constitute the basis for transportation impacts under CEQA analysis as of July 1, 2020.

For example, in the City, the General Plan identifies LOS as being a required analysis, and even though it will no longer be a requirement of CEQA, unless the General Plan is amended, LOS will continue to be analyzed as part of project review independent of CEQA analysis.

The Governor's Office of Planning and Research (OPR) updated the CEQA Guidelines to establish new criteria for determining the significance of transportation impacts. Based on input from the public, public agencies, and various organizations, OPR recommended that Vehicle Miles Traveled (VMT) be the primary metric for evaluating transportation impacts under CEQA.

The City of Redlands has prepared Draft VMT analysis guidelines, which were accepted by the City Council on July 21, 2020; therefore, the City’s adopted guidelines were consulted to determine whether a VMT analysis would be required for the Project. The City Guidelines provides details on appropriate “screening thresholds” that can be used to identify when a proposed land use project is anticipated to result in a lessthan-significant impact without conducting a more detailed analysis. Screening thresholds are broken into the following three types:
• Step 1: Transit Priority Area (TPA) Screening
• Step 2: Low VMT Area Screening
• Step 3: Project Type Screening
Consistent with guidance identified in the Technical Advisory and City Guidelines, projects located within a Transit Priority Area (TPA) (i.e., within ½ mile of an existing “major transit stop” or an existing stop along a “high-quality transit corridor”) may be presumed to have a less than significant impact absent substantial evidence to the contrary. However, the presumption may not be appropriate if a project:
• Has a Floor Area Ratio (FAR) of less than 0.75;
• Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking); Redlands Joint Special Meeting of the
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• Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization); or • Replaces affordable residential units with a smaller number of moderate- or high-income residential units.

As previously discussed throughout this document, the Project site is located within 0.5-mile of an existing major transit stop, and along a high-quality transit corridor. Additionally, the Project would meet the aforementioned secondary criteria of having a FAR of greater than 0.75, the parking supplied by the Project is not in excess of the City’s parking code, the Project is consistent with the adopted RTP/SCS, and the Project is not replacing affordable residential units with a smaller number of market rate residential units. Therefore, the Project would meet the VMT Screening Criteria, and it is presumed that the Project would have a less than significant impact related to VMT.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less Than Significant Impact. Vehicular access to the Project site would be provided via ingress and egress driveways connecting to Redlands Boulevard, 3rd Street, Eureka Avenue, and the public alleyway. Vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project area. Additionally, the Project would extend 3rd Street and State Street to meet in the middle of the Project site. The proposed street improvements would be reviewed by the City and would be required to meet all City development standards. For example, the design of 3rd Street and State Street would be reviewed to ensure fire engine accessibility is provided to the fire code standards. As a result, impacts related to vehicular circulation would be less than significant. d) Result in inadequate emergency access?
Less Than Significant Impact.

Construction
The proposed construction activities, including equipment and supply staging and storage, would occur within the project site, and would not restrict access of emergency vehicles to the Project site or adjacent areas.

The expansion of streets and connections to existing infrastructure systems that would be implemented during construction of the proposed Project could require the temporary closure of one side or portions of Redlands Boulevard, Orange Street, Eureka Street, and Citrus Avenue for a short period of time (i.e., hours or a few days). However, the construction activities would be required to ensure emergency access in accordance with Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9), which would be ensured through the City’s permitting process. Thus, implementation of the Project through the City’s permitting process would ensure existing regulations are adhered to and would reduce potential construction related emergency access impacts to a less than significant level.

Operation
As described previously, the proposed Project area would be accessed via the State Street and 3rd Street extensions. Project parking lots would be accessed from Citrus Avenue, Redlands Boulevard, Orange Street, and Eureka Street. The construction permitting process would provide adequate and safe circulation to, from, and through the Project area, and would provide routes for emergency responders to access different portions of the Project area. Roadways in the vicinity (including Citrus Avenue, Redlands Boulevard, Orange Street, and Eureka Street) would normally remain open and accessible to all vehicle traffic including emergency responders, except for possibly interim or partial closures for construction activities for a few hours or days with a City permit. Because the Project is required to comply with all applicable City codes, as verified by the City, potential impacts related to inadequate emergency access would be less than significant.

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Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

18. TRIBAL CULTURAL RESOURCES.

Would the Project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources 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:
a) 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)?
b) 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?
The discussion below is based on the Cultural and Paleontological Resources Assessment, prepared by Material Culture Consulting, 2021 (MCC 2021), included as Appendix B.

AB 52 & SB 18 Requirements
The Project would be required to comply with AB 52 and SB 18 regarding tribal consultation. Chapter 532, Statutes of 2014 (i.e., AB 52), requires that Lead Agencies evaluate a project’s potential to impact “tribal cultural resources.” Such resources include sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are eligible for inclusion in the California Register or included in a local register of historical resources (PRC Section 21074). AB 52 also gives Lead Agencies the discretion to determine, supported by substantial evidence, whether a resource falling outside the definition stated above nonetheless qualifies as a “tribal cultural resource.” SB 18 requires cities and counties acting as Lead Agency to contact and consult with California Native American tribes before adopting or amending a General Plan. The intent of SB 18 is to establish meaningful consultation between tribal governments and local governments at the earliest possible point in the planning process and to enable tribes to manage “cultural places.” Cultural places are defined as a Native American sanctified cemetery, place of worship, religious or ceremonial site, or sacred shrine (PRC Section 5097.9), or a Native American historic, cultural, or sacred site, that is listed or may be eligible for listing in the California Register, including any historic or prehistoric ruins, any burial ground, or any archaeological or historic site (PRC Section 5097.993).

In compliance with these requirements, on March 30 and April 8, 2021, the City sent letters to the following Native American tribes that may have knowledge regarding tribal cultural resources in the Project vicinity. • Agua Caliente Band of Cahuilla Indians
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• Augustine Band of Cahuilla Mission Indians
• Big Pine Paiute Tribe of Owens Valley
• Cabazon Band of Mission Indians
• Cahuilla Band of Indians
• Chemehuevi Indian Tribe
• Colorado River Indian Tribes of the Colorado River Indian Reservation • Fort Mojave Indian Tribe
• Los Coyotes Band of Cahuilla and Cupeño Indians
• Kern Valley Indian Community
• Gabrieleno Band of Mission Indians – Kizh Nation
• Gabrieleno/Tongva San Gabriel Band of Mission Indians • Gabrielino/Tongva Nation
• Morongo Band of Mission Indians
• Pechanga Band of Luiseño Indians
• Quechan Tribe of the Fort Yuma Reservation
• Ramona Band of Cahuilla Tribe
• San Manuel Band of Mission Indians
• Santa Rosa Band of Mission Indians
• Serrano Nation of Mission Indians
• Soboba Band of Luiseno Indians
• Torres-Martinez Desert Cahuilla Indians
• Twenty-Nine Palms Band of Mission Indians
Additionally, on September 11, 2020, Material Culture Consulting requested a Sacred Lands File (SLF) search from the Native American Heritage Commission. On September 14, 2020, the NAHC responded that the SLF search yielded positive results for known tribal cultural resources or sacred lands within a 1-mile radius of the Project site. The Soboba Band of Luiseño Indians and San Manuel Band of Mission Indians requested consultation regarding the proposed Project. The Soboba Band of Luiseño Indians consulted with City on September 9, 2021 and considers the area sensitive for cultural resources as several sites are located nearby. Furthermore, due to the presence of a portion of the Mill Creek Zanja onsite, the Soboba Band of Luiseño Indians described that there is a potential of encountering historic and prehistoric resources near the Zanja. As such, the consulting tribes requested inclusion of mitigation due to the potential of the Project to unearth previously undocumented tribal cultural resources during construction. a) 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)? Less Than Significant with Mitigation Incorporated. As discussed in Section 6.3.5 of this document, Response

6.3.5(a), the records search revealed that 408 cultural resources have been recorded within one-half mile of the Project site. One cultural resource, the Mill Creek Zanja, is located under the northwest portion of the Project site. However, the Zanja will not be affected by the Project as the existing Zanja easement will remain in place. Additionally, the Soboba Band of Luiseño Indians considers the area sensitive for cultural resources as several sites are located nearby. Therefore, the tribe requests that in addition to MM CUL-1:

Inadvertent Discoveries, a tribal monitor be retained to monitor any ground disturbing activities for the Project. Mitigation Measures TCR-1 through TCR-5 have been included to require a Monitoring and Treatment Plan and Native American monitoring of excavation and grading activities to avoid potential impacts to tribal cultural resources that may be unearthed by Project construction activities. Therefore, the proposed Project would not cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5 of the State CEQA Guidelines or PRC Section 5020.1(k).

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b) 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? Less Than Significant with Mitigation Incorporated. As discussed above, to avoid potential adverse effects to tribal cultural resources, Mitigation Measures CUL-1 and TCR-1 through TCR-5 have been included to provide for Native American monitoring of excavation and grading activities to avoid potential impacts to tribal cultural resources that may be unearthed by Project construction activities. No information has been provided to the Lead Agency indicating any likelihood of uncovering tribal cultural resources on the Project site, there are no known tribal cultural resources on or adjacent to the Project site, and no potentially significant impacts are anticipated. The following mitigation measures are included in the event of any inadvertent discoveries during construction activities.

Additionally, as described previously California Health and Safety Code, Section 7050.5 and MM TCR-5 requires that if human remains are discovered in the Project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation. If the coroner determines that the remains are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Therefore, with implementation of Mitigation Measures TCR-1 through TCR-5, and MM CUL-1, impacts to TCRs would be less than significant.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
MM TCR-1: The archaeologist shall develop a Cultural Resources Management Plan and include the specifics as to how each Project mitigation measure will be carried out. Any and all cultural documents created as a part of the project (Tribal Cultural Resources Management Plan, Monitoring and Treatment Plans, isolate records, site records, survey reports, testing reports, etc.) shall be supplied to the applicant and Lead Agency and disseminated to consulting tribe(s) for review. The Cultural Resource Management Plan shall incorporate:

A. Project grading and development scheduling. Native American Monitor(s) should attend and be present at the pre-construction meeting to establish communication protocols, cultural sensitivity, and provide information and/or training to construction contractors.

B. A schedule for monitoring during initial ground-disturbing activities (Ground disturbance is defined as any activity that compacts or disturbs the ground within a project area, including: the actual construction activities, permanent easements, temporary construction easements, staging areas for supplies and equipment, and borrow pits. Ground disturbance can also be caused by the use of hand tools, heavy equipment and heavy trucks. Trenching, bulldozing, excavating, scraping, and plowing are typical examples of ground disturbance activities), this may include, but is not limited to, archaeological testing, and data recovery on the Project site, if determined appropriate. The Cultural Resource Management Plan shall include scheduling, safety requirements, and duties, based on the scope of work, and address the Native American Tribal Monitors’ authority to stop and redirect grading activities in coordination with the Project Archaeologist.

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C. The protocols and stipulations that the Applicant, Native American Tribal Monitor(s), Project Archaeologist, and City of Redlands shall follow in the event that cultural resources, items of Native American cultural patrimony, or tribal cultural resources are inadvertently discovered during the course of Project related ground disturbing activities.

MM TCR-2: If significant tribal cultural resources are discovered and avoidance or relocation cannot be ensured, the City shall engage in discussions with the Consulting Tribes to determine the best course of action for preservation of the resource.

MM TCR-3: Designated Native American Monitor(s) from the consulting tribe(s), who wish to partake in the monitoring program, shall be present during all initial ground-disturbing activities (Ground disturbance is defined as any activity that compacts or disturbs the ground within a project area, including: the actual construction activities, permanent easements, temporary construction easements, staging areas for supplies and equipment, and borrow pits. Ground disturbance can also be caused by the use of hand tools, heavy equipment and heavy trucks. Trenching, bulldozing, excavating, scraping, and plowing are typical examples of ground disturbance activities), which may include but is not limited to testing, and date recovery if determined appropriate. If initial ground-disturbing activities yield no discoveries of tribal cultural resources, the Consulting Tribe(s) may limit, suspend or terminate monitoring efforts at their discretion. The Monitoring Agreement(s) with the consulting tribe(s) shall be provided to the City of Redlands Development Services Department prior to issuance of any demolition, grading, or construction permits.

MM TCR-4: In the event that cultural resources, including historic and pre-contact materials, items of Native American cultural patrimony, or Tribal Cultural Resources are discovered during the course of ground disturbance, the following procedures shall be implemented:

1. All work in the immediate vicinity of the find (within a 50-foot buffer) shall cease and the find shall be assessed by a qualified archaeologist in coordination with the Native American Monitor(s) from the Consulting Tribe(s). Work on the other portions of the Project, outside of the buffered area, may continue during this assessment period.

2. Notification and information regarding the nature of the find shall be made to the representatives of all consulting tribe(s).

3. Temporary Curation and Storage: During construction, any cultural resources discovered shall be temporarily curated in a secure onsite location, as determined appropriate with consideration of input from consulting tribe(s). The removal of any cultural resources from the Project site shall be thoroughly inventoried and overseen by the Native American Tribal Monitor(s).

4. Treatment and Final Disposition: The land owner(s) shall relinquish ownership of all items of Native American cultural patrimony and tribal cultural resources (including but not limited to sacred items, burial goods, archaeological artifacts, and non-human remains) that may be discovered. The land owner(s) shall relinquish ownership of tribal cultural resources and items of Native American Cultural Patrimony through one or more of the following methods and provide the City of Redlands with evidence of same:

A. Accommodate the process for on-site reburial of the discovered items with the Participating Tribes. This shall include measures and provisions to protect the future reburial area from any future impacts. Reburial shall not occur until all cataloguing and recordation have been completed. A final report which includes associated State DPR Forms, containing an inventory of the items reburied, along with UTM parameters for the reburial location, shall be completed and provided to the City, the Consulting Tribes and filed with the California Historical Resource Information System (CHRIS).

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B. A curation agreement with an appropriate qualified repository that meets federal standards per 36 CFR Part 79 and therefore would be professionally curated and made available to other archaeologists or researchers for further study. The collections and associated records shall be transferred, including title and associated fees, to an appropriate curation facility.

C. If more than one Native American Tribe or Band is involved with the Project and cannot come to a consensus as to the disposition of tribal cultural resources within one hundred and twenty (120) days from the initial recovery of the items, the cultural resources shall be curated at the San Bernardino County Museum. A curation agreement with an appropriate qualified repository shall be developed between the landowner and museum that legally and physically transfers the collections and associated records to the facility. This agreement shall stipulate the payment of fees necessary for permanent curation of the collections and associated records and the obligation of the Project developer/applicant to pay for those fees.

MM TCR-5: Discovery of Human Remains. In the event that human remains are encountered on the Project site, the construction contractor’s designated Native American Tribal Monitor shall immediately stop all work within 100 feet of the discovery. The Developer shall immediately notify the San Bernardino County Coroner, the City of Redlands Police Department, and the City of Redlands Development Services Department. The County Coroner shall be permitted to examine the remains consistent with the requirements of California Code of Regulations (CCR) §15064.5(e). California Health & Safety Code §7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code (PRC) §5097.98. If the remains are determined to be Native American, the County Coroner shall notify the Native American Heritage Commission (NAHC), which shall determine and notify a Most Likely Descendant (MLD). The MLD shall complete the inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site.

The specific location of Native American burials and reburials will be proprietary and not disclosed to the general public. The locations will be documented by the Project Archaeologist in conjunction with the various stakeholders and a report of findings will be filed with the Eastern Information Center (EIC).

According to California Health & Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052).

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

19. UTILITIES AND SERVICE SYSTEMS.

Would the Project:
a) Require or result in the relocation or
construction of new or expanded water or
wastewater treatment facilities or expansion of
existing facilities, the construction of which could
cause significant environmental effects?
b) Have sufficient water supplies available to
serve the project and reasonably foreseeable
future development during normal, dry and
multiple dry years?
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?
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?
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
The discussion below is based on the Water Supply Assessment for State Street Village, prepared by Charles Marr Consulting, July 2021 (Marr 2021), included as Appendix K. a) Require or result in the relocation or construction of new or expanded water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?
Less Than Significant Impact.

Water Infrastructure
The Municipal Utilities and Engineering Department (MUED) maintains the water system in the City of Redlands. The proposed Project would redevelop the Project site, which is currently served by MUED’s water infrastructure, and would install new onsite potable water infrastructure and install 12-inch domestic water lines within the 3rd Street and State Street extensions that would connect to existing 12-inch domestic water lines in Redlands Boulevard, Eureka Street, Citrus Avenue, and Orange Street. The new onsite water system would convey water supplies to the proposed residences and landscaping through plumbing/landscaping fixtures that are compliant with the CalGreen Plumbing Code for efficient use of water.

A Water Supply Assessment was prepared for the proposed Project by Charles Marr Consulting (Marr 2021) and is included as Appendix K. According to the Water Supply Assessment, the Project would result in a net water demand of 198 acre-feet per year, which is significantly less than the City’s proposed water demand projections. The proposed Project would continue to receive water supplies through the existing Redlands Joint Special Meeting of the
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water lines located within Redlands Boulevard, Eureka Street, Citrus Avenue, and Orange Street rights-ofway that have the capacity to provide the increased water supplies needed to serve the proposed Project, and no expansions of the water pipelines that convey water to the Project site would be required. Installation of the new water distribution lines would only serve the proposed Project and would not provide new water supplies to any offsite areas.

The construction activities related to the onsite water infrastructure that would be needed to serve the proposed Project is included as part of the Project and would not result in any physical environmental effects beyond those identified throughout this document. For example, analysis of construction emissions for excavation and installation of the water infrastructure is included in Sections 6.3.3, Air Quality and 6.3.8, Greenhouse Gas Emissions. Therefore, the proposed Project would not result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects, and impacts would be less than significant.

Wastewater Treatment
The Project would remove the existing 8-inch sewer line in Lot 2 and Lot 6 and install new 8-inch sewer lines in the 3rd Street and State Street extensions that would connect to the existing 21-inch sewer line in Citrus Avenue. The Project would also construct onsite connections to the existing sewer line in Redlands Boulevard.

Wastewater demand associated with the proposed Project would be typical of residential wastewater usage in the City of Redlands. As shown in Table UT-1, Proposed Project Estimated Wastewater Generation, the proposed Project would generate a demand for approximately 113,804 gallons per day (gpd).

According to the City’s General Plan EIR, the City of Redlands has projected average wastewater flows of

6.75 mgd at buildout of the proposed General Plan. This projection was based on current flow per customer, scaled to the projected number of customers at buildout. As the projected flow is within the 9.5-mgd secondary treatment capacity and 7.2-mgd tertiary treatment capacity, no new or expanded treatment facilities would be needed to serve the population at buildout. In addition, all new residential development that connects to the system is required to pay its applicable fair-share Development Impact Fee(s).

Table UT-1: Proposed Project Estimated Wastewater Generation Use Size Water Demand Rate
(gpd/unit)
Total Water Demand
(gpd)
Commercial Use1 87,999 SF 80 gpd/1,000 SF 7,039.92
Office Space 12,328 SF 150 gpd/1,000 SF 1,849.2
Health Club/Spa2 21,344 SF 800 gpd/1,000 SF 17,075.2
Studio/Live-Work/Zerobedroom 150 du 80 gpd/du 12,000
One Bedroom 338 du 120 gpd/du 40,560
Two Bedroom 178 du 160 gpd/du 28,480
Three Bedroom 34 du 200 gpd/du 6,800
Total Project Water Generation: 113,804 gpd 1Includes 14,500 SF drugstore 2includes s lobby area, workout floors, aerobic rooms, swimming pools, jacuzzi, sauna, locker rooms, showers, and restrooms City of Los Angeles, CEQA Thresholds Guide, 2006, Exhibit M.2-12 Prior to issuance of building permits, a sewer capacity study will be prepared by the Project Applicant and submitted to the City MUED. The construction activities related to installation of the onsite sewer infrastructure that would serve the proposed Project, is included as part of the proposed Project and would not result in any physical environmental effects beyond those identified throughout this document. For example, construction emissions for excavation and installation of the sewer infrastructure is included in Section 6.3.3, Air Quality and 6.3.8, Greenhouse Gas Emissions, and noise volumes from these activities are evaluated in Section 6.3.13, Noise. As the proposed Project includes facilities to serve the proposed development, it would Redlands Joint Special Meeting of the
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not result in the need for construction of other new wastewater facilities or expansions, the construction of which could cause significant environmental effects. Therefore, impacts would be less than significant.

Stormwater Drainage
The proposed Project would increase the overall impervious surface area on the Project site compared to existing condition. As discussed in Section 6.3.10 of this document, the proposed Project would increase the impervious surface area on the Project site compared to existing condition, however, with implementation of BMPs, the proposed Project would install drainage features that would handle and treat all potential stormwater runoff from the Project site. Furthermore, the proposed Project would not require or result in the construction of new stormwater drainage facilities or expansion of existing facilities beyond the on‐site improvements included as part of the proposed Project. All new residential development that connects to the system is required to pay its applicable fair-share Development Impact Fee(s). Therefore, impacts to stormwater drainage facilities would be less than significant. b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Less Than Significant Impact. Water service would be provided to the proposed project site by the City of Redlands MUED. The 2020 San Bernardino Valley Regional UWMP, adopted in June 2021, was prepared for the City of Redlands and therefore accounts for the water usage that would be attributed to development of the Project site, consistent with its existing land use designation and zoning classification.

According to the UWMP, the City has four sources of water to provide to its service area: purchased imported water from the State Water Project; groundwater from the Bunker Hill Subbasin and the Yucaipa Subbasin; surface water from the Mill Creek and Santa Ana River watersheds; and recycled water (UWMP 2020).

The Water Supply Reliability Assessment within the UWMP concludes that the City has adequate supplies to meet projected demands under multiple dry year scenarios, taking into account the recent prolonged drought (UWMP 2020). Additionally, the Water Supply Assessment prepared for the proposed Project concluded that the Project would have a demand of 189 acre-feet per year, which is within the projected water demands and supplies as analyzed in the UWMP. Therefore, water demand from the proposed Project would be within the City’s current and projected water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years. All new residential development that connects to the system is required to pay its applicable fair-share Development Impact Fee(s). Thus, impacts related to water supplies would be less than significant. 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?
Less Than Significant Impact. According to the General Plan Livable Community Element, most wastewater generated by sewered development within the Planning Area is treated at the Redlands Wastewater Treatment Facility. The Redlands Wastewater Treatment Facility treats approximately 6 million gallons per day (mgd) with a capacity of 9.5 mgd. As discussed above, the proposed Project would generate approximately 113,546 gpd. All new development that connects to the system is required to pay its applicable fair-share Development Impact Fee(s). As such, the Redlands Wastewater Treatment Facility would have adequate capacity to serve the Project. The proposed Project would connect to and operate under capacity of the current water treatment facility, allowing for sufficient service to the Project area. The quality of sewage discharged from indoor plumbing fixtures would be similar to the quality of other residential dwelling units in the vicinity that currently discharge to the City’s sewer system. The Project would not result in any of the wastewater treatment plants discussed above exceeding wastewater treatment requirements. Therefore, impacts related to wastewater generation are less than significant. 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? Redlands Joint Special Meeting of the
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Less Than Significant Impact. The City of Redlands Quality of Life Department provides a wide range of services to the city, including waste collection. Solid waste from Redlands is primarily disposed of at the California Street Landfill and the San Timoteo Sanitary Landfill operated by the County, both within the city limits. These have more than adequate capacity to meet the City’s needs for the foreseeable future. Solid waste collected from the Project site would be anticipated to be hauled to the California Street Landfill, which is located at 2151 Nevada Street and encompasses 115 acres. Its design capacity is 11.4 million cubic yards, and its maximum permitted capacity is 10 million cubic yards. It has a maximum permitted throughput of 829 tons per day. In 2019, California Street Landfill received approximately 142 tons per day on average. As such, California Street Landfill has an additional capacity of approximately 687 tons per day. It has a remaining capacity of 5,168,182 cubic yards and is permitted to operate through 2042 (CalRecycle 2021). Additionally, the San Timoteo Sanitary Landfill is located on San Timoteo Canyon Road and is 366 acres in size. It has a permitted capacity of 20,400,000 cubic yards and a maximum permitted daily throughput of 2,000 tons. In 2019, San Timoteo Landfill received approximately 758 tons per day on average. As such, San Timoteo Landfill has an additional capacity of approximately 1,242 tons per day.

As of CalRecycle’s 2021 estimate, the remaining capacity was 12,360,396 cubic yards and is permitted to operate through 2039 (CalRecycle 2021).

Construction
Construction of the proposed Project would require demolition of the commercial buildings, as well as the removal of the existing parking lot. The majority of waste generated during demolition and construction activities would be building materials (e.g., concrete, dirt, and waste generated by construction workers).

Nonhazardous waste from Project construction activities would be recycled to the extent feasible. As stated in the City’s Municipal Code Section 13.66.040, Construction and Demolition Recycling Requirements, no demolition permit or building permit shall be issued for any development activity subject to this chapter unless the construction and demolition recycling plan has been approved by the municipal utilities director.

Thus, the proposed Project would be required to meet the City’s waste diversion requirements as they pertain to Project construction. Furthermore, construction waste is anticipated to be minimal compared to waste generated throughout the lifetime of the Project during operation.

Operation
As described previously in Section 6.3.14 of this document, the proposed Project includes the construction of a provide 700 multi-family dwelling units, 71,778 SF of ground-floor retail, 12,328 SF of office space, a 14,500 SF drugstore, amenity areas, community building, and a 1,721 SF rooftop restaurant space with a rooftop deck with a rooftop deck that would result in an increase of approximately 1,192 residents on the Project site. As shown on Table UT-2, it is anticipated that the proposed Project would generate a total of approximately 0.26 ton of solid waste per day (94 tons per year) during Project operation.

Table UT-2: Solid Waste Generation during Project Operation Land Use Quantity Generation Rate Solid Waste Demand
Multi-Family Units 700 units 0.46 tons/unit/year 322 tons per year Commercial Retail1 87,999 SF 0.46 tons/1,000
SF/year

40.5 tons per year
Office 12,328 SF 1.095 tons/1,000
SF/year

13.5 tons per year
Total Solid Waste 376 tons per year
Annual Landfill Disposal with AB 341 (75% Reduction) 94 tons per year Weekly Landfill Disposal with AB 341 (75% Reduction) 1.8 tons per week 1Includes 14,500 SF drugstore
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As the California Street Landfill has the capacity to process an additional 687 tons of solid waste per day, the solid waste generated by the Project would be within the capacity of the landfill. Thus, the proposed Project would be served by a landfill with sufficient permitted capacity to accommodate the Project’s solid waste disposal needs and the Project would not impair the attainment of solid waste reduction goals. Impacts related to landfill capacity would be less than significant. e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Less Than Significant Impact. The proposed Project would result in new development that would generate an increased amount of solid waste. All solid waste-generating activities within the City is subject to the requirements set forth in Section 5.408.1 of the 2019 California Green Building Standards Code that requires demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste, and AB 341 that requires diversion of a minimum of 75 percent of operational solid waste.

In addition, as stated in Response 6.3.19(d) above, the proposed Project would be required comply with the City’s Municipal Code Section 13.66.040, Construction and Demolition Recycling Requirements, which requires that no demolition permit or building permit shall be issued for any development activity subject to this chapter unless the construction and demolition recycling plan has been approved by the municipal utilities director. In addition, the proposed Project would be required to comply with all federal, State, and local regulations related to solid waste. Furthermore, the proposed Project would comply with all standards related to solid waste diversion, reduction, and recycling during Project construction and operation.

Therefore, the proposed Project is anticipated to result in less than significant impacts related to potential conflicts with federal, State, and local management and reduction statutes and regulations pertaining to solid waste.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

20. WILDFIRES. 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?
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?
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?
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?
a) Substantially impair an adopted emergency response plan or emergency evacuation plan? Less Than Significant Impact. According to the CAL FIRE Fire Hazard Severity Zone map, the Project site is not within an area identified as a Fire Hazard Area that may contain substantial fire risk or a Very High Fire Hazard Severity Zone (VHFHSZ) (Cal Fire 2021). The proposed Project would not substantially impair an adopted emergency response plan or emergency evacuation plan. As stated in Section 6.3.9 of this document, the proposed Project would not physically interfere with an adopted emergency response plan or emergency evacuation plan. The City’s General Plan Safety Element (Section 7.4) discusses Emergency Management, which outlines goals and policies aimed at emergency preparedness to protect the health, safety, and welfare of the general public during and after natural, man-made, or attack-related emergencies. Additionally, the proposed Project does not include any characteristics (e.g., permanent road closures or long-term blocking of road access) that would substantially impair or otherwise conflict with an emergency response plan or emergency evacuation plan. Therefore, the impacts related to emergency response and evacuation plans associated with construction of the proposed Project would be less than significant.

The proposed Project does not include any changes to public or private roadways that would physically impair or otherwise conflict with an emergency response plan or emergency evacuation plan. Further, the proposed Project would not obstruct or alter any transportation routes that could be used as evacuation routes during emergency events. In addition, during the operational phase of the proposed Project, site access would be required to comply with standards established by the City and the Redlands Fire Department. The size and location of fire suppression facilities (e.g., hydrants) and fire access routes would be required to conform to City and Fire Department standards. The Project would provide adequate Redlands Joint Special Meeting of the
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emergency access to the proposed buildings via driveways from Redlands Boulevard, Eureka Street, the proposed Third Street extension, and the public alley. Further, access to and from the Project site for emergency vehicles would be reviewed and approved by the Redlands Fire Department and the City as part of the Project approval process to ensure the proposed Project is compliant with all applicable codes and ordinances for emergency vehicle access. Because the Project is required to comply with all applicable City codes, as verified by the City, any potential impacts related to emergency response or evacuation (if any) would be less than significant.
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?
No Impact. The proposed Project involves the redevelopment of the site with 700 multi-family dwelling units, 71,778 SF of ground-floor retail, 14,500 SF drug store, 12,328 SF of office space, amenity areas, community building, and a 1,721 SF rooftop restaurant space with a rooftop deck. As discussed in Section

6.3.14 of this SCEA, the Project is anticipated to result in a population increase of approximately 1,192 residents. As stated previously, the Project site is not located within a VHFHSZ. Additionally, the Project site and surrounding area are currently developed, and therefore, lack the combustible materials and vegetation necessary for the uncontrollable spread of a wildfire.

The Project site is relatively flat and there are limited elevation changes in the Project vicinity. The Project proposes a mixed-use development in an area characterized by existing commercial, institutional, and residential uses. As such, the Project itself would not exacerbate wildfire risks as compared to existing conditions because it is representative of the existing development in the area and is replacing existing commercial uses. Thus, no impact related to other factors that would expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire would occur from the Project. 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? No Impact. The Project does not require the installation or maintenance of associated infrastructure (including roads, fuel breaks, emergency water sources, power lines, or other utilities) that would exacerbate fire risk or that would result in impacts to the environment. Although the Project includes driveways and the extension of 3rd Street and State Street, these changes to public roadways would not exacerbate fire risk or result in ongoing impacts to the environment besides impacts discussed throughout this SCEA. Although utility improvements, including domestic water, recycled water, sanitary sewer, and storm drain lines proposed as part of the Project would be extended throughout the Project site, these utility improvements would be underground and would not exacerbate fire risk. Project design and implementation of utility improvements would be reviewed and approved by the City part of the Project approval process to ensure the proposed Project is compliant with all applicable design standards and regulations. Therefore, the proposed Project would not include infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities), that would exacerbate fire risk or that would result in impacts to the environment. 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? Less Than Significant Impact. According to the City of Redlands General Plan, Figure 7-3, Flood Hazards, the Project site is within Zone AO and is within a 100-year floodplain. Additionally, in its existing condition, the Project site contains an average slope of less than two percent from the southeast corner of the site to the northwest corner of the site.

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As established in Section 6.3.10 of this document, during Project construction soil would be compacted and drainage patterns would be temporarily altered due to grading, and there would be an increased potential for flooding compared to existing conditions. However, as stated in PPP WQ-1, construction BMPs would be identified and implemented as part of the proposed Project. Implementation of construction BMPs would control and direct surface runoff to prevent flooding, and as such, Project construction would not expose people or structures to significant risks related to downslope and downstream flooding. Therefore, impacts would be less than significant.

During operation, the proposed Project would not substantially alter the existing on-site drainage patterns.

Compliance with the proposed operational BMPs would ensure on-site storm drain facilities would be sized to accommodate stormwater runoff from the Project site so that on-site flooding would not occur. Additionally, as required by Redlands Municipal Code Section 15.32.110 sets forth construction standards for new development within flood hazard areas. With implementation of the requirements set forth in Code Section

15.32.110, operation of the Project would not expose people or structures to significant risks, including downslope or downstream flooding. Therefore, impacts would be less than significant.

As established in Section 6.3.7 of this document, there are no landslide zones close to or within the boundaries of the Project site. The Project site is relatively flat; therefore, the risk of slope failure represents a limited level of concern on the Project site. Further, implementation of PPP GEO-1 requires compliance with the CBC, which would include the incorporation of: 1) seismic safety features to minimize the potential for significant effects as a result of earthquakes; 2) proper building footings and foundations; and 3) construction of the building structures so that it would withstand the effects of strong ground shaking. These features would reduce potential impacts related to landslides to a less than significant level. Therefore, with implementation of PPP GEO-1, the Project would not expose people or structures to significant risks, including downslope or downstream landslides, and impacts (if any) would be less than significant.

Project Design Features
None.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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21. MANDATORY FINDINGS OF
SIGNIFICANCE.

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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?
b) Does the project have impacts that are
individually limited, but cumulatively considerable?
("Cumulatively considerable" means that the
incremental 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)?
c) Does the project have environmental effects which
will cause substantial adverse effects on human
beings, either directly or indirectly?
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? Less Than Significant Impact with Mitigation Incorporated. Based on the discussion in Section 6.3.4, Biological Resources, of this document, the proposed Project is anticipated to result in less than significant impacts related to habitat, wildlife species, and/or plant and animal communities. The proposed Project would not eliminate a plant or animal community, nor would it substantially reduce the number or restrict the range of a rare or endangered plant or animal. However, MM BIO-1 has been included to comply with the provisions of the MBTA as there are ornamental trees onsite.

As described in Section 6.3.5, Cultural Resources, the Project site does not contain any buildings or structures that meet any of the California Register of Historical Resources (California Register) criteria or qualify as “historical resources” as defined by CEQA. Therefore, the proposed Project would not cause a substantial adverse change in the significance of a historical resource. However, the Project site contains part of the Mill Creek Zanja, portions of which are listed on the California Register of Historical Resources. In addition, as described previously, the Project site has been previously disturbed from various past uses that involve grading and installation of utility infrastructure. As a result, the potential for archaeological resources exists on site are low to moderate. However, Mitigation Measure CUL-1 has been included to require archaeological monitoring of ground disturbing activities to ensure that inadvertent discovery of resources during ground-disturbing activities are less than significant. Implementation of Mitigation Measure CUL-1 and Mitigation Measures TCR-1 through TCR-5 would reduce potential impacts to important examples of California prehistory to a less than significant level.

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b) Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental 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)?
Less Than Significant with Mitigation Incorporated. As presented in this document, potential Project-related impacts are either less than significant or would be less than significant with mitigation incorporated. Based on the analysis contained in this document, Project-related impacts would be reduced to less than significant levels with the incorporation of mitigation measures. Given that the potential Project-related impacts would be mitigated to a less than significant level, implementation of the proposed Project would not result in impacts that are cumulatively considerable when evaluated with the impacts of other current projects, or the effects of probable future projects. Therefore, the proposed Project’s contribution to any significant cumulative impacts would be less than cumulatively considerable. As discussed in Sections 6.3.1 through

6.3.20 of this document, mitigation would be required and incorporated as necessary. Therefore, impacts would be less than significant with mitigation incorporated. c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Less Than Significant with Mitigation Incorporated. Based on the Project Description and the preceding responses in Sections 6.3.1 through 6.3.20 of this document, implementation of the proposed Project would not cause substantial adverse effects to human beings because all potentially significant impacts of the proposed Project would be mitigated to a less than significant level. Therefore, since all potentially significant impacts of the proposed Project are expected to be mitigated to a less than significant level, implementation of the proposed Project would not cause substantial adverse effects on human beings.

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7 Document Preparers and Contributors
Lead Agency:

City of Redlands
35 Cajon Street
Redlands, CA 92373
CEQA Document Preparer:

EPD Solutions, Inc.

Brooke Blandino
Konnie Dobreva, JD
Meaghan Truman
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8 References
California Air Resources Board. “Connect SoCal SCS Evaluation Packet.” 3 October 2020. https://scag.ca.gov/sites/main/files/file-attachments/carb-2020-scs-evaluation-packet.pdf?1606337689 California State Geoportal. “California Fire Hazard Severity Zone Viewer.” 2020. https://gis.data.ca.gov/datasets/789d5286736248f69c4515c04f58f414 Charles Marr Consulting. Water Supply Assessment for State Street Village. 29 July 2021. Appendix K.

City of Los Angeles (2006). L.A. CEQA Thresholds Guide. Website:
https://planning.lacity.org/eir/CrossroadsHwd/deir/files/references/A07.pdf (accessed April 12, 2021).

Department of Toxic Substances Control. “Envirostor.”
https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=Redlands Material Culture Consulting. Cultural and Paleontological Resources Assessment. September 2021.

Appendix B.

Partner Engineering and Science, Inc. Phase I Environmental Site Assessment. 17 December 2013.

Appendix F.

Proactive Engineering Consultants, Inc. Preliminary Water Quality Management Plan. 6 October 2021.

Appendix G.

San Bernardino Countywide Plan. 2020.
https://www.arcgis.com/apps/webappviewer/index.html?id=5864a434814c4e53adc74101b34b1905 Southern California Association of Governments. “Demographics and Growth Forecast.” 3 September 2020. https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-andgrowth-forecast.pdf?1606001579 Southern California Association of Governments. “Housing Element Parcel Tool.” 2020. https://maps.scag.ca.gov/helpr/
Southern California Association of Governments. “2019 Local Profile City of Redlands.” 2019 https://scag.ca.gov/sites/main/files/file-attachments/redlands_localprofile.pdf?1606014831 State Water Resources Control Board. “Geotracker.” Accessed 24 August 2021. https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0607100096 Terracon GeoReport. Geotechnical Engineering Report. 30 September 2021. Appendix D.

The Natelson Company, Inc. “Employment Density Study Summary Report.” 31 October 2001. https://docplayer.net/30300085-Employment-density-study-summary-report-october-31-prepared-forsouthern-california-association-of-governments.html U.S. Fish and Wildlife Service. “National Wetlands Inventory.” 8 March 2021. https://www.fws.gov/wetlands/data/mapper.html
Urban Crossroads. Air Quality Impact Analysis. 26 October 2021. Appendix A.

Urban Crossroads. Energy Analysis. 26 October 2021. Appendix C.

Urban Crossroads. Greenhouse Gas Analysis. 26 October 2021. Appendix E.

Urban Crossroads. Traffic Analysis. 30 July 2021. Appendix I.

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Urban Crossroads. State Street Village Vehicle Miles Travelled (VMT) Screening Evaluation. 2 June 2021.

Appendix J.

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Attachment O-2
Due to the number and size of technical studies,
the documents are made available on the City of Redlands webpage here:
https://www.cityofredlands.org/post/environmental-documents OR
State Clearinghouse webpage here:
https://ceqanet.opr.ca.gov/2021110117
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State Street Village Project Chapter 4
City of Redlands
Final SCEA 4-1
January 2022
Mitigation Monitoring and Reporting Program
Introduction
The California Environmental Quality Act (CEQA) requires a lead or public agency that approves or carries out a project for which an Mitigated Negative Declaration has been certified which identifies one or more significant adverse environmental effects and where findings with respect to changes or alterations in the project have been made, to adopt a “…reporting or monitoring program for the changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment” (CEQA, Public Resources Code Sections 21081, 21081.6).

A Mitigation Monitoring and Reporting Program (MMRP) is required to ensure that adopted mitigation measures are successfully implemented for the State Street Village Project (Project). The City of Redlandsis the Lead Agency for the Project and is responsible for implementation of the MMRP. This report describes the MMRP for the Project and identifies the parties that will be responsible for monitoring implementation of the individual mitigation measures in the MMRP.

Mitigation Monitoring and Reporting Program
The MMRP for the Project will be active through all phases of the Project, including design, construction, and operation. The attached table identifies the mitigation program required to be implemented by the City for the Core5 Rider Business Center Project. The table identifies the Plans, Programs, Policies (PPPs); Project Design Features (PDFs); and mitigation measures required by the City to mitigate or avoid significant adverse impacts associated with the implementation of the project, the timing of implementation, and the responsible party or parties for monitoring compliance.

The MMRP also includes a column that will be used by the compliance monitor (individual responsible for monitoring compliance) to document when implementation of the measure is completed. As individual Plan, Program, Policies; Project Design Features; and mitigation measuresare completed, the compliance monitor will sign and date the MMRP, indicating that the required actionshave been completed.

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State Street Village Project Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 4-2
January 2022
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State Street Village Project Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 4-3
January 2022
TABLE 1: MITIGATION MONITORING AND REPORTING PROGRAM

THE STATE STREET VILLAGE PROJECT
Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials

AIR QUALITY
PDF AQ-1: Tier III Equipment. Project construction will utilize equipment during demolition, grading, and site preparation phases that equal or exceed Environmental Protection Agency (EPA) and California Air Resource Board (CARB) Tier III engine emissions standards
Note in Construction Plans
and Specifications. Prior
to Demolition and
Grading Permits.

City of Redlands Building
and Safety Division
PPP AQ-1: Rule 403. All applicable measures included in Rule 403, shall be incorporated into Project plans and specifications as implementation of Rule 403, which include but are not limited to (1):
 All clearing, grading, earth-moving, or excavation activities shall cease when winds exceed 25 mph per SCAQMD guidelines in order to limit fugitive dust emissions.
 The contractor shall ensure that traffic speeds on unpaved roads and Project site areas are limited to 15 miles per hour or less.  The contractor shall ensure that all disturbed unpaved roads and disturbed areas within the Project are watered at least three (3) times daily during dry weather. Watering, with complete coverage of disturbed areas, shall occur at least three times a day, preferably in the mid-morning, afternoon, and after work is done for the day.

Note in Construction Plans
and Specifications. Prior
to Demolition and
Grading Permits.

City of Redlands Building
and Safety Division
PPP AQ-2: Rule 1113. The following measures shall be incorporated into Project plans and specifications as implementation of SCAQMD Rule 1113 (2):
 Only “Low-Volatile Organic Compounds (VOC)” paints (no more than 50 gram/ liter of VOC) consistent with SCAQMD Rule 1113 shall be used.

Note in Construction Plans,
Specifications, and
Permits. Prior to
Demolition and Grading
Permits.

City of RedlandsBuilding
and Safety Division
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State Street Village Project Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 4-4
January 2022
Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
PPP AQ-3: Rule 445. The following measures shall be incorporated into Project plans and specifications as implementation of SCAQMD Rule 445 (3):
 Rule 445 prohibits the use of wood burning stoves and fireplaces in new developments.

Note in Construction Plans,
Specifications, and
Permits. Prior to
Demolition Permits.

City of RedlandsBuilding
and Safety Division

BIOLOGICAL RESOURCES
MM BIO-1: Pre‐construction Nesting Bird Survey. Construction plans and Project specifications shall state that if construction or other Project activities are scheduled to occur during the bird breeding season (February through August for raptors and March through August for most migratory bird species), a pre‐construction nesting bird survey shall be conducted by a qualified biologist to ensure that active bird nests, will not be disturbed or destroyed.

The survey shall be completed no more than three days prior to initial ground disturbance. The nesting bird survey shall include the Project area and adjacent areas where proposed Project activities have the potential to affect active nests, either directly or indirectly due to construction activity or noise. If an active nest is identified, a qualified biologist shall establish an appropriate disturbance limit buffer around the nest using flagging or staking. Construction activities shall not occur within any disturbance limit buffer zones until the nest is deemed inactive by the qualified biologist.

Note in Construction Plans
and Specifications. Prior
to Demolition and
Grading Permits.

City of RedlandsPlanning
Division

CULTURAL RESOURCES
MM CUL-1: Archaeological Monitoring. The Applicant shall retain a qualified archaeologist to perform archaeological monitoring and the archaeologist shall be present during initial ground-disturbing activities (e.g., site preparation, demolition of historic structures, and grading up to ten feet below surface) to identify and assess any known or suspected archaeological and/ or cultural resource. The qualified archaeologist shall develop a Cultural Resources Management Plan to address the details, timing, and responsibility of all archaeological and cultural resource activities that occur on the Project site. The plan shall include a scope of work, project grading and development scheduling, pre-construction meeting (with consultants, contractors, and monitors), a monitoring schedule during all initial ground-disturbance related activities, safety requirements, and protocols to follow in the event of Note in Construction Plans
and Specifications. Prior
to Demolition and
Grading Permits.

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Division
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State Street Village Project Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 4-5
January 2022
Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
previously unknown cultural resources discoveries that could be subject to a cultural resources evaluation. The plan shall be submitted to the City and the Consulting Tribe(s) for review and comment, prior to final approval by the City. The Monitoring and Treatment Plan shall incorporate the components described in Mitigation Measure TCR-1.

GEOLOGY AND SOILS
PPP GEO-1: California Building Code. The Project is required to comply with the California Building Code as included in the City’s Municipal Code Chapter

15.04 to preclude significant adverse effects associated with seismic hazards.

California Building Code related and geologist and/ or civil engineer specifications for the Project are required to be incorporated into grading plans and specifications as a condition of Project approval.

Note in Construction Plans
and Specifications. Prior
to Building Permits.

City of Redlands Building
and Safety Division
MM PAL-1: Paleontological Resources. Prior to the issuance of the first grading permit, the applicant shall provide a letter to the City of Redlands Planning Department, or designee, from a paleontologist selected from the roll of qualified paleontologists maintained by the County, stating that the paleontologist has been retained to provide services for the project. The paleontologist shall develop a Paleontological Resources Impact Mitigation Plan (PRIMP) to mitigate the potential impacts to unknown buried paleontological resources that may exist onsite for the review and approval by the City. The PRIMP shall require that the paleontologist be present at the pre-grading conference to establish procedures for paleontological resource surveillance. The PRIMP shall also require paleontological monitoring for ground disturbing activities greater than five feet in depth within native soil, as determined by the Project paleontologist.

Note in Construction Plans
and Specifications. Prior
to Grading Permits.

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State Street Village Project Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 4-6
January 2022
Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
Criteria for discard of specific fossil specimens will be made explicit. If a qualified paleontologist determines that impacts to a sample containing significant paleontological resources cannot be avoided by project planning, then recovery may be applied. Actions may include recovering a sample of the fossiliferous material prior to construction, monitoring work and halting construction if an important fossil needs to be recovered, and/ or cleaning, identifying, and cataloging specimens for curation and research purposes.

HAZARDS AND HAZARDOUS MATERIALS
PPP HAZ-1: California UST Regulations. Underground storage tank (UST) repairs and/ or removals will be conducted in accordance with the California UST Regulations (Title 23, Chapter 16 of the California Code of Regulations). Any unauthorized release of hazardous materials will require release reporting, initial abatement, and corrective actions that will be completed with oversight from the Regional Water Quality Control Board, Department of Toxic Substances Control, Riverside County Environmental Health Division, South Coast Air Quality Management District, and/ or other regulatory agencies, as necessary. Use of existing USTs will also have to be conducted (i.e., used, maintained and monitored) in accordance with the California UST Regulations (Title 23, Chapter 16 of the California Code of Regulations).

In Construction Plans and
Specifications. Prior to
Demolition Permit.

City of Redlands Building
and Safety Division

HYDROLOGY AND WATER QUALITY
PPP WQ-1: Prior to grading permit issuance, the project developer shall have a Stormwater Pollution Prevention Plan (SWPPP) prepared by a QSD (Qualified SWPPP Developer) pursuant to the Municipal Code Chapter 13.54. The SWPPP shall incorporate all necessary Best Management Practices (BMPs) and other City requirements to comply with the National Pollutant Discharge Elimination System (NPDES) requirements to limit the potential of polluted runoff during construction activities. Project contractors shall be required to ensure compliance with the In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Building
and Safety Division
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Final SCEA 4-7
January 2022
Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
SWPPP and permit periodic inspection of the construction site by City of Redlands staff or its designee to confirm compliance.

13.54 and the Municipal Separate Storm Sewer System (MS4) permit requirements in effect for the Regional Water Quality Control Board (RWQCB) at the time of grading permit to control discharges of sediments and other pollutants during operations of the Project.

In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Building
and Safety Division
NOISE
PPP N-1: The Project plans shall state the Project is required to comply with construction hours of operation outlined in Section 8.06.120 of the City’s Municipal Code; construction activities shall take place between the hours of 7:00 am and 8:00 pm on weekdays, including Saturdays, with no activity taking place at any time on Sundays or federal holidays. In addition, all motorized equipment used in such activities are required to be equipped with functioning mufflers.

In Construction Plans and
Specifications. Prior to
Demolition, Grading, and
Building Permits.

City of Redlands Building
and Safety Division

PUBLIC SERVICES
PPP PS-1: Schools Development Impact Fees. Prior to issuance of building permit, the Developer shall pay applicable school development impact fees levied by the Redlands Unified School District pursuant to the School Facilities Act (Senate Bill [SB] 50, Stats. 1998, c.407).

Note in Construction Plans
and Specifications. Prior
to Building Permits.

City of Redlands Planning
Division
PPP PS-2: Park Fees. As a Condition of Approval of a tentative map, the Developer shall pay applicable park related fees pursuant to Redlands Municipal Code Chapter 3.32.

Note in Construction Plans
and Specifications. Prior
to Building Permits.

City of Redlands Planning
Division
PPP PS-3: Development Impact Fees. As a standard requirement and included as a Condition of Approval for the Project, and prior to issuance of any building permits for the Project, the Developer shall pay all applicable City of Redlands Development Impact Fees (DIF) pursuant to the Redlands Municipal Code and/ or adopted fee schedules.

Note in Construction Plans
and Specifications. Prior
to Building Permits.

City of Redlands Planning
Division
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Final SCEA 4-8
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Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials

TRIBAL CULTURAL RESOURCES
MM TCR-1: The archaeologist shall develop a Cultural Resources Management Plan and include the specifics as to how each Project mitigation measure will be carried out. Any and all cultural documents created as a part of the project (Tribal Cultural Resources Management Plan, Monitoring and Treatment Plans, isolate records, site records, survey reports, testing reports, etc.) shall be supplied to the applicant and Lead Agency and disseminated to consulting tribe(s) for review. The Cultural Resource Management Plan shall incorporate:

C. The protocols and stipulations that the Applicant, Native American Tribal Monitor(s), Project Archaeologist, and City of Redlands shall follow in the event that cultural resources, items of Native American cultural patrimony, or tribal cultural resources are inadvertently In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
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Final SCEA 4-9
January 2022
Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
discovered during the course of Project related ground disturbing activities.

In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
MM TCR-3: Designated Native American Monitor(s) from the consulting tribe(s), who wish to partake in the monitoring program, shall be present during all initial ground-disturbing activities (Ground disturbance is defined as any activity that compacts or disturbs the ground within a project area, including: the actual construction activities, permanent easements, temporary construction easements, staging areas for supplies and equipment, and borrow pits. Ground disturbance can also be caused by the use of hand tools, heavy equipment and heavy trucks.

Trenching, bulldozing, excavating, scraping, and plowing are typical examples of ground disturbance activities), which may include but is not limited to testing, and date recovery if determined appropriate. If initial ground-disturbing activities yield no discoveries of tribal cultural resources, the Consulting Tribe(s) may limit, suspend or terminate monitoring efforts at their discretion. The Monitoring Agreement(s) with the consulting tribe(s) shall be provided to the City of Redlands Development Services Department prior to issuance of any demolition, grading, or construction permits.

In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
MM TCR-4: In the event that cultural resources, including historic and pre-contact materials, items of Native American cultural patrimony, or Tribal Cultural Resources are discovered during the course of ground disturbance, the following procedures shall be implemented:

In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
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Final SCEA 4-10
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Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials

2. Notification and information regarding the nature of the find shall be made to the representatives of all consulting tribe(s).

B. A curation agreement with an appropriate qualified repository that meets federal standards per 36 CFR Part 79 and therefore would be professionally curated and made available to other archaeologists or researchers for further study. The collections and associated records shall be transferred, including title and associated fees, to an appropriate curation facility.

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Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
C. If more than one Native American Tribe or Band is involved with the Project and cannot come to a consensus as to the disposition of tribal cultural resources within one hundred and twenty (120) days from the initial recovery of the items, the cultural resources shall be curated at the San Bernardino County Museum. A curation agreement with an appropriate qualified repository shall be developed between the landowner and museum that legally and physically transfers the collections and associated records to the facility. This agreement shall stipulate the payment of fees necessary for permanent curation of the collections and associated records and the obligation of the Project developer/ applicant to pay for those fees.

In Construction Plans and
Specifications. Prior to
Grading Permit.

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Division
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Plan, Program, Policy / Project Design Feature / Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
According to California Health & Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052).

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Cff

FINAL

SUSTAINABLE COMMUNITIES

ENVIRONMENTAL ASSESSMENT

FOR THE

STATE STREET VILLAGE PROJECT
Lead Agency:

City of Redlands
35 Cajon Street
Redlands, CA 92373
Project Applicant:

Village Partners Ventures, LLC
4340 Von Karman Avenue, Suite 110
Newport Beach, CA 92660

CEQA Consultant:
2355 Main Street, Suite 100
Irvine, CA 92614
April 2022
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Table of Contents
CH. 1 RESPONSE TO PUBLIC COMMENTS............................................................................................. 1-1 CH. 2 ERRATA....................................................................................................................................... 2-1 ATTACHMENT A. TRIP GENERATION COMPARISON MEMO
ATTACHMENT B. AIR QUALITY AND GREENHOUSE GAS EMISSIONS MEMO Redlands Joint Special Meeting of the
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1. Response to Comments on the Public Review Draft SCEA This memo contains responses to the comments that the City of Redlands (Lead Agency) received on the Sustainable Communities Environmental Assessment (SCEA) for the State Street Village Project during the public review period, which began November 5, 2021and closed December 6, 2021 (SCH No. 2021110117). This document has been prepared in accordance with California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.) and the State CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.) and represents the independent judgment of the Lead Agency. This document and the circulated Public Review SCEA together comprise the Final SCEA.

The following public comments were submitted to the City of Redlands during the public review period:

O1. Gabrieleno Band of Mission Indians-Kizh Nation, Received November 22, 2021(1 page) O2. Mitchell M. Tsai, Attorney at Law, on behalf of the Southwest Regional Council of Carpenters, Received December 6, 2021 (51 pages)
O3. Lozeau Drury, LLP, on behalf of Supporters Alliance for Environmental Responsibility, Received December 6, 2021 (43 pages)
The public comments and responses to comments are included in the public record and are available to the Lead Agency decision-makers for their review and consideration prior to making their decision. Pursuant to CEQA Statute Section 21155.2(b)(5), none of the comments provide substantial evidence that the Project will have significant environmental effects which would require preparation of an Environmental Impact Report. None of this new material indicates that the Project will result in a significant environmental impact or an increase in a less than significant impact previously disclosed in the State Street Village SCEA.

This Response to Comments includes minor revisions to the Public Review Draft SCEA based upon:
(1) clarifications required to prepare a response to a specific comment; and/or (2) typographical errors. These revisions do not alter any impact significance conclusions as disclosed in the SCEA.

Changes made to the SCEA are identified here in strikeout text to indicate deletions and in underlined text to signify additions. These revisions are also outlined in Chapter 2, Errata.

Although CEQA Statute Section 21155 does not require a Lead Agency to prepare written responses to comments received, the City of Redlands has elected to prepare the following written responses with the intent of conducting a comprehensive and meaningful evaluation of the proposed Project. The number designations in the responses are correlated to the bracketed and identified portions of each comment letter. The comment letters and response to comment letters are found on the following pages:

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Redlands City CouncilMay 10, 2022

Redlands City Council
May 10, 2022