Cities Index.
Agenda packet

Redlands City Council
October 4, 2022

Document
Agenda packet
Meeting
October 4, 2022
Body
Redlands City Council
Pages
18
Original file
292.2 MB
Text extracted from the city's file for reading and search. Open the original on s3.us-west-004.backblazeb2.com. That file is the official record.

1. Source of supply

2. Quantity of fuel

3. Quantity of fuel, including sulfur content (percent by weight) cc. Project should exceed Title-24 Building Envelope Energy Efficiency Standards (California Building Standards Code). The following measures can be used to increase energy efficiency:
− Install programmable thermostat timers
− Obtain Third-party HVAC commissioning and verification of energy savings (to be grouped with exceedance of Title 24).
− Install energy efficient appliances (Typical reductions for energyefficient appliances can be found in the Energy Star and Other Climate Protection Partnerships Annual Reports.)
− Install higher efficacy public street and area lighting − Limit outdoor lighting requirements
− Replace traffic lights with LED traffic lights
− Establish onsite renewable or carbon neutral energy systems – generic, solar power and wind power
SCEA
City of Redlands The Grand Project
55 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project − Utilize a combined heat and power system
− Establish methane recovery in Landfills and Wastewater Treatment Plants. − Locate project near bike path/bike lane
− Provide pedestrian network improvements, such as interconnected street network, narrower roadways and shorter block lengths, sidewalks, accessibility to transit and transit shelters, traffic calming measures, parks and public spaces, minimize pedestrian barriers.
− Provide traffic calming measures, such as:
i. Marked crosswalks
ii. Count-down signal timers
iii. Curb extensions
iv. Speed tables
v. Raised crosswalks
vi. Raised intersections
vii. Median islands
viii. Tight corner radii
ix. Roundabouts or mini-circles
x. On-street parking
xi. Chicanes/chokers
− Create urban non-motorized zones
− Provide bike parking in non-residential and multi-unit residential projects
− Dedicate land for bike trails
− Limit parking supply through:
i. Elimination (or reduction) of minimum parking requirements ii. Creation of maximum parking requirements
iii. Provision of shared parking
SCEA
City of Redlands The Grand Project
56 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project − Require residential area parking permit.
− Provide ride-sharing programs
i. Designate a certain percentage of parking spacing for ride sharing vehicles
ii. Designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles
iii. Providing a web site or messaging board for coordinating rides iv. Permanent transportation management association membership and finding requirement.

Impact AQ-5: Result in other
emissions (such as those leading to
odors) adversely affecting a
substantial number of people.

No mitigation is required. No mitigation is required.

Biological Resources
Impact BIO-1: Have a substantial
adverse effect, either directly or
through habitat modification, 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 US Fish and
Wildlife Service.

PMM BIO-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 related to threatened and endangered species. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Require project design to avoid occupied habitat, potentially suitable habitat, and designated critical habitat, wherever practicable and feasible. b) Where avoidance is determined to be infeasible, provide conservation measures to fulfill the requirements of the applicable authorization for incidental take pursuant to Section 7 or 10(a) of the federal ESA, Section 2081 of the California ESA to support issuance of an incidental take permit, and/or as identified in local or regional plans. Conservation strategies to protect the survival and recovery of federally and state-listed endangered and local special status species may include:
i. Impact minimization strategies
ii. Contribution of in-lieu fees for in-kind conservation and mitigation efforts
iii. Use of in-kind mitigation bank credits
Pursuant to CEQA Guidelines Section 15126.4, subd.
(a)(4)(A)–(B), there must be a nexus between PMM BIO-1 and environmental impacts from the proposed Project. No
mitigation is required as Project impacts would be less than significant. The site does not contain any candidate, sensitive, or special status species or any native habitat. However, the Project would be substantially in conformance with this mitigation measure for the following reasons:

The Project site is an infill site located in an urban area that is fully disturbed and fully developed. The Project site does not contain any critical habitat or support any species identified or designated as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife (CDFW) or U.S. Fish and Wildlife Service (USFWS).

This mitigation measure is not incorporated because the City has determined that the existing regulatory compliance
measures listed below would apply to the Project and ensure potential impacts are less than significant.

Applicable regulations:

SCEA
City of Redlands The Grand Project
57 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project iv. Funding of research and recovery efforts
v. Habitat restoration
vi. Establishment of conservation easements
vii. Permanent dedication of in-kind habitat
c) Design projects to avoid desert native plants protected under the California Desert Native Plants Act, salvage and relocate desert native plants, and/or pay in lieu fees to support off-site long-term conservation strategies. d) Temporary access roads and staging areas will not be located within areas containing sensitive plants, wildlife species or non-native habitat wherever feasible, so as to avoid or minimize impacts to these species e) Develop and implement a Worker Environmental Awareness Program (environmental education) to inform project workers of their responsibilities to avoid and minimize impacts on sensitive biological resources. f) Retain a qualified botanist to document the presence or absence of special status plants before project implementation.
g) Appoint a qualified biologist to monitor construction activities that may occur in or adjacent to occupied sensitive species’ habitat to facilitate avoidance of resources not permitted for impact.
h) Appoint a qualified biologist to monitor implementation of mitigation measures. i) Schedule construction activities to avoid sensitive times for biological resources (e.g. steelhead spawning periods during the winter and spring, nesting bird season) and to avoid the rainy season when erosion and sediment transport is increased. j) Develop an invasive species control plan associated with project construction k) If construction occurs during breeding seasons in or adjacent to suitable habitat, include appropriate sound attenuation measures required for sensitive avian species and other best management practices appropriate for potential local sensitive wildlife
l) Conduct pre-construction surveys to delineate occupied sensitive species’ habitat to facilitate avoidance.
m) Where projects are determined to be within suitable habitat and may impact listed or sensitive species that have specific field survey protocols or guidelines outlined by the USFWS, CDFW, or other local agency, conduct preconstruction • Federal Endangered Species Act
• Migratory Bird Treaty Act
• California Endangered Species Act
• California Native Plant Protection Act
• California Desert Native Plants Act
• Lists from the CDFW:
o Species of Special Concern
o Fully Protected Animals Lists
o Special Vascular Plants, Bryophytes and
Lichens List
o California Sensitive Natural Communities
o Inventory of Rare and Endangered Plants
by the California Native Plant Society
SCEA
City of Redlands The Grand Project
58 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project surveys that follow applicable protocols and guidelines and are conducted by qualified and/or certified personnel.
n. Project design should address the protection of habitat on both sides of a freeway to improve effectiveness of the crossings.
o. Project sponsors shall consider the impacts of nitrogen deposition on sensitive species.

Impact BIO-2: 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.

PMM BIO-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 reduce substantial adverse effects related to riparian habitats and other sensitive natural communities. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Consult with the USFWS and NMFS where such state-designated sensitive or riparian habitats provide potential or occupied habitat for federally listed rare, threatened, and endangered species afforded protection pursuant to the federal ESA.
b) Consult with the USFS where such state-designated sensitive or riparian habitats provide potential or occupied habitat for federally listed rare, threatened, and endangered species afforded protection pursuant to the federal ESA and any additional species afforded protection by an adopted Forest Land Management Plan or Resource Management Plan for the four national forests in the six-county area: Angeles, Cleveland, Los Padres, and San Bernardino. c) Consult with the CDFW where such state-designated sensitive or riparian habitats provide potential or occupied habitat for state-listed rare, threatened, and endangered species afforded protection pursuant to the California ESA, or Fully Protected Species afforded protection pursuant to the State Fish and Game Code.
d) Consult with the CDFW pursuant to the provisions of Section 1600 of the State Fish and Game Code as they relate to Lakes and Streambeds. e) Consult with the USFWS, USFS, CDFW, and counties and cities in the SCAG region, where state-designated sensitive or riparian habitats are occupied by birds afforded protection pursuant to the MBTA during the breeding season. f) Consult with the CDFW for state-designated sensitive or riparian habitats where furbearing mammals, afforded protection pursuant to the provisions of the State Pursuant to CEQA Guidelines Section 15126.4, subd.
(a)(4)(A)–(B), there must be a nexus between PMM BIO-2 and environmental impacts from the proposed Project. No
mitigation measures are required. The Project is located in a developed, urban area. The Project site is fully developed with commercial uses. This mitigation measure is not incorporated because the Project site does not contain any wetlands, riparian habitats, sensitive natural community or critical habitat, or support any species identified or designated as candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by CDFW or the U.S.

Fish and Wildlife Service. No impacts related to this issue would occur.

SCEA
City of Redlands The Grand Project
59 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Fish and Game Code for fur-beaming mammals, are actively using the areas in conjunction with breeding activities.
g) Require project design to avoid sensitive natural communities and riparian habitats, wherever practicable and feasible. Where practicable and feasible, require upland buffers that sufficiently minimize impacts to riparian corridors. h) Where avoidance is determined to be infeasible, develop sufficient conservation measures through coordination with local agencies and the regulatory agency (i.e., USFWS or CDFW) to protect sensitive natural communities and riparian habitats and develop appropriate compensatory mitigation, where required. i) Appoint a qualified wetland biologist to monitor construction activities that may occur in or adjacent to sensitive communities.
j) Appoint a qualified wetland biologist to monitor implementation of mitigation measures.
k) Schedule construction activities to avoid sensitive times for biological resources and to avoid the rainy season when erosion and sediment transport is increased. l) When construction activities require stream crossings, schedule work during dry conditions and use rubber-wheeled vehicles, when feasible. Have a qualified wetland scientist determine if potential project impacts require a Notification of Lake or Streambed Alteration to CDFW during the planning phase of projects. m) Consult with local agencies, jurisdictions, and landowners where such statedesignated sensitive or riparian habitats are afforded protection pursuant an adopted regional conservation plan.
n) Install fencing and/or mark sensitive habitat to be avoided during construction activities.
o) Salvage and stockpile topsoil (the surface material from 6 to 12 inches deep) and perennial native plants, when recommended by the qualified wetland biologist, for use in restoring native vegetation to areas of temporary disturbance within the project area. Salvage of soils containing invasive species, seeds and/or rhizomes will be avoided as identified by the qualified wetland biologist. p) Revegetate with appropriate native vegetation following the completion of construction activities. as identified by the qualified wetland biologist. q) Complete habitat enhancement (e.g., through removal of non-native invasive wetland species and replacement with more ecologically valuable native species).

SCEA
City of Redlands The Grand Project
60 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project r) Use Best Management Practices (BMPs) at construction sites to minimize erosion and sediment transport from the area. BMPs include encouraging growth of native vegetation in disturbed areas, using straw bales or other silt-catching devices, and using settling basins to minimize soil transport.

Impact BIO-3: 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.

PMM BIO-3: 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 related to wetlands. Such measures may include the following or other comparable measures identified by the Lead Agency.
a) Require project design to avoid federally protected aquatic resources consistent with the provisions of Sections 404 and 401 of the CWA, wherever practicable and feasible.
b) Where the lead agency has identified that a project, or other regionally significant project, has the potential to impact other wetlands or waters, such as those considered Waters Of the State of California under the State Wetland Definition and Procedures for Dischargers of Dredged or Fill Material to Waters of the State, not protected under Section 404 or 401 of the CWA, seek comparable coverage for these wetlands and waters in consultation with the SWRCB, applicable RWQCB, and CDFW.
c) Where avoidance is determined to be infeasible, develop sufficient conservation measures to fulfill the requirements of the applicable authorization for impacts to federal and state protected aquatic resource to support issuance of a permit under Section 404 of the CWA as administered by the USACE. The use of an authorized Nationwide Permit or issuance of an individual permit requires the project applicant to demonstrate compliance with the USACE’s Final Compensatory Mitigation Rule. The USACE reviews projects to ensure environmental impacts to aquatic resources are avoided or minimized as much as possible. Consistent with the administration’s performance standard of “no net loss of wetlands” a USACE permit may require a project proponent to restore, establish, enhance or preserve other aquatic resources in order to replace those affected by the proposed project. This compensatory mitigation process seeks to replace the loss of existing aquatic resource functions and area. Project proponents required to complete mitigation are encouraged to use a watershed approach and watershed planning information. The new rule establishes performance standards, sets timeframes for decision making, and to the extent possible, establishes equivalent requirements and standards for the three sources of compensatory mitigation:
• Permittee-responsible mitigation
• Contribution of in-kind in-lieu fees
Pursuant to CEQA Guidelines Section 15126.4, subd.
(a)(4)(A)–(B), there must be a nexus between PMM BIO-3 and environmental impacts from the proposed Project. No
mitigation measures are required. The Project site is fully developed with commercial uses and is not located on
federally or state protected wetlands or water features.

SCEA
City of Redlands The Grand Project
61 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project • Use of in-kind mitigation bank credits
• Where avoidance is determined to be infeasible and
d) Where avoidance is determined to be infeasible and proposed projects’ impacts exceed an existing Nationwide Permit (NWP) and/or California SWRCBcertified NWP, the lead agency should provide USACE and SWRCB (where applicable) an alternative analysis consistent with the Least Environmentally Damaging Practicable Alternatives in this order of priorities:
• Avoidance
• Impact Minimization
• On-site alternatives
• Off-site alternatives
e) Require review of construction drawings by a certified wetland delineator as part of each project-specific environmental analysis to determine whether aquatic resources will be affected and, if necessary, perform formal wetland delineation.

Impact BIO-4: 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.

See PMM BIO-1 through PMM BIO-3.

PMM BIO-4: 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 related to wildlife movement. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Consult with the USFS where impacts to migratory wildlife corridors may occur in an area afforded protection by an adopted Forest Land Management Plan or Resource Management Plan for the four national forests in the six-County area:

Angeles, Cleveland, Los Padres, and San Bernardino.
b) Consult with counties, cities, and other local organizations when impacts may occur to open space areas that have been designated as important for wildlife movement related to local ordinances or conservation plans. c) Prohibit construction activities within 500 feet of occupied breeding areas for wildlife afforded protection pursuant to Title 14 § 460 of the California Code of Regulations protecting furbearing mammals, during the breeding season. d) Conduct a survey to identify active raptor and other migratory nongame bird nests by a qualified biologist at least two weeks before the start of construction at project sites from February 1 through August 31.

Sections PMM BIO-4 d through f are applicable to the
proposed Project and would be incorporated through Project specific MM BIO-1.

The Project site is developed with commercial uses and fully disturbed and is in an urbanized area in the City of Redlands.

No wildlife corridors or native wildlife nursery sites are present on the Project site or in the surrounding area. Further, due to the urbanized nature of the Project area, the potential for native resident or migratory wildlife species movement through the site is extremely limited.

Nonetheless, areas along Eureka Street, Third Street, and Redlands Boulevard contain multiple ornamental trees that could support raptor and/or songbird nests. Migratory
nongame native bird species are protected under the Federal Migratory Bird Treaty Act (MBTA) of 1918 (50 CFR Section

10.13). California Fish and Wildlife Code Sections 3503, 3503.5, and 3513 prohibit take of all birds and their active nests (as listed under the Federal MBTA). The removal of vegetation with nesting birds during the breeding season is considered a potentially significant impact.

The Applicant will be required to ensure compliance with all applicable laws and regulations to ensure that no significant SCEA
City of Redlands The Grand Project
62 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project e) Prohibit construction activities with 250 feet of occupied nest of birds afforded protection pursuant to the Migratory Bird Treaty Act, during the breeding season. f) Ensure that suitable nesting sites for migratory nongame native bird species protected under the Migratory Bird Treaty Act and/or trees with unoccupied raptor nests should only be removed prior to February 1, or following the nesting season.
g) When feasible and practicable, proposed projects will be designed to minimize impacts to wildlife movement and habitat connectivity and preserve existing and functional wildlife corridors.
h) Conduct site-specific analyses of opportunities to preserve or improve habitat linkages with areas on- and off-site.
i) Long linear projects with the possibility of impacting wildlife movement should analyze habitat linkages/wildlife movement corridors on a broad scale to avoid critical narrow choke points that could reduce function of recognized movement corridor.
j) Require review of construction drawings and habitat connectivity mapping by a qualified biologist to determine the risk of habitat fragmentation. k) Pursue mitigation banking to preserve habitat linkages and corridors (opportunities to purchase, maintain, and/or restore offsite habitat). l) When practicable and feasible design projects to promote wildlife corridor redundancy by including multiple connections between habitat patches. m) Evaluate the potential for installation of overpasses, underpasses, and culverts to create wildlife crossings in cases where a roadway or other transportation project may interrupt the flow of species through their habitat. Provide wildlife crossings in accordance with proven standards, such as FHWA’s Critter Crossings or Ventura County Mitigation Guidelines and in consultation with wildlife corridor authorities.
n) Install wildlife fencing where appropriate to minimize the probability of wildlife injury due to direct interaction between wildlife and roads or construction. o) Where avoidance is determined to be infeasible, design sufficient conservation measures through coordination with local agencies and the regulatory agency (i.e., USFWS or CDFW) and in accordance with the respective counties and cities general plans to establish plans to mitigate for the loss of fish and wildlife movement corridors and/or wildlife nursery sites. The consideration of conservation impacts to nesting birds would occur due to the removal of the existing trees located on the Project site. As included in Projectspecific MM BIO-1, 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 are 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.

Therefore, with adherence to existing regulations and
incorporation of Project-specific MM BIO-1, impacts would be less than significant.

SCEA
City of Redlands The Grand Project
63 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project measures may include the following measures, in addition to the measures outlined in MM-BIO-1(b), where applicable:
• Wildlife movement buffer zones
• Corridor realignment
• Appropriately spaced breaks in center barriers
• Stream rerouting
• Culverts
• Creation of artificial movement corridors such as freeway under- or overpasses
• Other comparable measures
p) Where the lead agency has identified that a RTP/SCS project, or other regionally significant project, has the potential to impact other open space or nursery site areas, seek comparable coverage for these areas in consultation with the USFWS, CDFW, NMFS, or other local jurisdictions.
q. Incorporate applicable and appropriate guidance (e.g. FHWA-HEP-16-059), as well as best management practices, to benefit pollinators with a focus on native plants.
r. Implement berms and sound/sight barriers at all wildlife crossings to encourage wildlife to utilize crossings. Sound and lighting should also be minimized in developed areas, particularly those that are adjacent to or go through natural habitats.
s. Reduce lighting impacts on sensitive species through implementation of mitigation measures such as, but not limited to:
− Use high pressure sodium and/or cut-off fixtures instead of typical mercury vapor fixtures for outdoor lighting.
− Design exterior lighting to confine illumination to the project site − Provide structural and/or vegetative screening from light-sensitive uses. − Use non-reflective glass or glass treated with a non-reflective coating for all exterior windows and glass used on building surfaces.
− Architectural lighting shall be directed onto the building surfaces and have low reflectivity to minimize glare and limit light onto adjacent properties. t. Reduce noise impacts to sensitive species through implementation of mitigation measures such as, but not limited to:

SCEA
City of Redlands The Grand Project
64 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project − Install temporary noise barriers during construction. − Include permanent noise barriers and sound-attenuating features as part of the project design. Barriers could be in the form of outdoor barriers, sound walls, buildings, or earth berms to attenuate noise at adjacent sensitive uses. − Ensure that construction equipment are properly maintained per manufacturers’ specifications and fitted with the best available noise suppression devices (e.g., improved mufflers, equipment redesign, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds silencers, wraps). All intake and exhaust ports on power equipment shall be muffled or shielded. − Use hydraulically or electrically powered tools (e.g., jack hammers, pavement breakers, and rock drills) for project construction to avoid noise associated with compressed air exhaust from pneumatically powered tools. However, where use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust should be used; this muffler can lower noise levels from the exhaust by up to about 10 dBA. External jackets on the tools themselves should be used, if such jackets are commercially available, and this could achieve a further reduction of 5 dBA. Quieter procedures should be used, such as drills rather than impact equipment, whenever such procedures are available and consistent with construction procedures.
− Using rubberized asphalt or “quiet pavement” to reduce road noise for new roadway segments, roadways in which widening or other modifications require repavement, or normal reconstruction of roadways where repavement is planned − Use equipment and trucks with the best available noise control techniques (e.g., improved mufflers, equipment redesign, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds, wherever feasible) for project construction.
− Use techniques such as grade separation, buffer zones, landscaped berms, dense plantings, sound walls, reduced-noise paving materials, and traffic calming measures.
u. Require large buffers between sensitive uses and freeways. v. Create corridor redundancy to help retain functional connectivity and resilience.

Impact BIO-5: Conflict with any
local policies or ordinances
protecting biological resources,
See PMM BIO-1 through PMM BIO-4.

PMM BIO-5: 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 conflicts with local policies and Pursuant to CEQA Guidelines Section 15126.4, subd.
(a)(4)(A)–(B), there must be a nexus between PMM BIO-1
through PMM BIO-5 and environmental impacts from the
proposed Project. Mitigation is not required because Project SCEA
City of Redlands The Grand Project
65 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project such as a tree preservation policy
or ordinance.
ordinances protecting biological resources. Such measures may include the following or other comparable measures identified by the Lead Agency. a) Consult with the appropriate local agency responsible for the administration of the policy or ordinance protecting biological resources. b) Prioritize retention of trees on-site consistent with local regulations. Provide adequate protection during the construction period for any trees that are to remain standing, as recommended by an International Society of Arboriculture (ISA) certified arborist.
c) If specific project area trees are designated as “Protected Trees,” “Landmark Trees,” or “Heritage Trees,” obtain approval for encroachment or removals through the appropriate entity, and develop appropriate mitigation measures at that time, to ensure that the trees are replaced. Mitigation trees shall be locally collected native species, as directed by a qualified biologist. d) Appoint an ISA certified arborist to monitor construction activities that may occur in areas with trees are designated as “Protected Trees,” “Landmark Trees,” or “Heritage Trees,” to facilitate avoidance of resources not permitted for impact.

Before the start of any clearing, excavation, construction or other work on the site, securely fence off every protected tree deemed to be potentially endangered by said site work. Keep such fences in place for duration of all such work. Clearly mark all trees to be removed.
e) Establish a scheme for the removal and disposal of logs, brush, earth and other debris that will avoid injury to any protected tree. Where proposed development or other site work could encroach upon the protected perimeter of any protected tree, incorporate special measures to allow the roots to breathe and obtain water and nutrients. Minimize any excavation, cutting, filing, or compaction of the existing ground surface within the protected perimeter. Require that no change in existing ground level occur from the base of any protected tree at any time. Require that no burning or use of equipment with an open flame occur near or within the protected perimeter of any protected tree.
f) Require that no storage or dumping of oil, gas, chemicals, or other substances that may be harmful to trees occur from the base of any protected trees, or any other location on the site from which such substances might enter the protected perimeter. Require that no heavy construction equipment or construction materials be operated or stored within a distance from the base of any protected trees.

Require that wires, ropes, or other devices not be attached to any protected tree, except as needed for support of the tree. Require that no sign, other than a tag showing the botanical classification, be attached to any protected tree. impacts would be less than significant with the implementation of regulatory compliance measures. Nevertheless, the Project would be in substantial conformance with these mitigation measures for the reasons stated below.

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.

Any trees removed from the Project site, would be subject to applicable regulatory compliance measures. Any tree
removals within the public right-of-way would require permit approval from the City’s Public Works Director. With
adherence to Municipal Code Chapter 12.52, impacts would be less than significant.

SCEA
City of Redlands The Grand Project
66 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project g) Thoroughly spray the leaves of protected trees with water periodically during construction to prevent buildup of dust and other pollution that would inhibit leaf transpiration, as directed by the certified arborist.
h) If any damage to a protected tree should occur during or as a result of work on the site, the appropriate local agency will be immediately notified of such damage. If, such tree cannot be preserved in a healthy state, as determined by the certified arborist, require replacement of any tree removed with another tree or trees on the same site deemed adequate by the local agency to compensate for the loss of the tree that is removed. Remove all debris created as a result of any tree removal work from the property within two weeks of debris creation, and such debris shall be properly disposed of in accordance with all applicable laws, ordinances, and regulations. Design projects to avoid conflicts with local policies and ordinances protecting biological resources
i) Where avoidance is determined to be infeasible, sufficient conservation measures to fulfill the requirements of the applicable policy or ordinance shall be developed, such as to support issuance of a tree removal permit. The consideration of conservation measures may include:
• Avoidance strategies
• Contribution of in-lieu fees
• Planting of replacement trees
• Re-landscaping areas with native vegetation post-construction • Other comparable measures developed in consultation with local agency and certified arborist.

Impact BIO-6: Conflict with the
provisions of an adopted Habitat
Conservation Plan, Natural
Community Conservation Plan, or
other approved local, regional, or
state habitat conservation plan.

See PMM BIO-1 through PMM BIO-5.

PMM BIO-6: 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 HCPs and NCCPs. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Consult with the appropriate federal, state, and/or local agency responsible for the administration of HCPs or NCCPs.
b) Wherever practicable and feasible, the project shall be designed to avoid lands preserved under the conditions of an HCP or NCCP. c) Where avoidance is determined to be infeasible, sufficient conservation measures to fulfill the requirements of the HCP and/or NCCP, which would include but not be limited to applicable authorization for incidental take pursuant to Pursuant to CEQA Guidelines Section 15126.4, subd.
(a)(4)(A)–(B), there must be a nexus between PMM BIO-1
through PMM BIO-6 and environmental impacts from the
proposed Project. No mitigation measures are required. The Project site is not located in or subject to provisions of any adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan.

SCEA
City of Redlands The Grand Project
67 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Section 7 or 10(a) of the federal Endangered Species Act or Section 2081 of the California ESA, shall be developed to support issuance of an incidental take permit or any other permissions required for development within the HCP/NCCP boundaries. The consideration of additional conservation measures would include the measures outlined in SMM-BIO-2, where applicable.

Cultural Resources
Impact CULT-1: Cause a
substantial adverse change in the
significance of a historical resource
pursuant to § 15064.5.

PMM CULT-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 related to historical resources. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Pursuant to CEQA Guidelines Section 15064.5, conduct a record search during the project planning phase at the appropriate Information Center to determine whether the project area has been previously surveyed and whether historical resources were identified.
b) During the project planning phase, retain a qualified architectural historian, defined as an individual who meets the Secretary of the Interior’s (SOI) Professional Qualification Standards (PQS) in Architectural History, to conduct historic architectural surveys if a built environment resource greater than 45 years in age may be affected by the project or if recommended by the Information Center.
c) Comply with Section 106 of the National Historic Preservation Act (NHPA) including, but not limited to, projects for which federal funding or approval is required for the individual project. This law requires federal agencies to evaluate the impact of their actions on resources included in or eligible for listing in the National Register. Federal agencies must coordinate with the State Historic Preservation Officer in evaluating impacts and developing mitigation. These mitigation measures may include, but are not limited to the following:
• Employ design measures to avoid historical resources and undertake adaptive reuse where appropriate and feasible. If resources are to be preserved, as feasible, carry out the maintenance, repair, stabilization, rehabilitation, restoration, preservation, conservation or reconstruction in a manner consistent with the Secretary of the Interior’s Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings. If resources would be impacted, impacts should be minimized to the extent feasible.

The Project would be substantially in conformance with SCAG PMM CULT-1 a through l, as provided below.

In its existing setting, the Project site is fully developed with a commercial furniture store. 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 21 cultural resources have been recorded within one mile of the Project site. One historic-era cultural resource, a portion of the historic Redlands Chinatown, is potentially located subsurface within 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 potential presence of the subsurface remains of the historic Redlands Chinatown, the potential for archaeological resources onsite is considered low to moderate.

However, Mitigation Measure CUL-1 has been included to
require an Archaeological Testing and Data Recovery
Program to ensure the Project would not result in significant impacts to potential subsurface archaeological resources.

Mitigation Measure CUL-1 requires retention of an
archaeologist that would prepare an Archaeological Testing and Data Recovery Program to be implemented after existing structure are demolished and prior to Project-related ground disturbance. Following development of the Archaeological SCEA
City of Redlands The Grand Project
68 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project • Where feasible, noise buffers/walls and/or visual buffers/landscaping should be constructed to preserve the contextual setting of significant built resources.
d) If a project requires the relocation, rehabilitation, or alteration of an eligible historical resource, the Secretary of the Interior’s Standards for the Treatment of Historic Properties should be used to the maximum extent possible to ensure the historical significance of the resource is not impaired. The application of the standards should be overseen by an architectural historian or historic architect meeting the SOI PQS. Prior to any construction activities that may affect the historical resource, a report, meeting industry standards, should identify and specify the treatment of character-defining features and construction activities and be provided to the Lead Agency for review and approval. e) If a project would result in the demolition or significant alteration of a historical resource eligible for or listed in the National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR), or local register, recordation should take the form of Historic American Buildings Survey (HABS), Historic American Engineering Record (HAER), or Historic American Landscape Survey (HALS) documentation, and should be performed by an architectural historian or historian who meets the SOI PQS. Recordation should meet the SOI Standards and Guidelines for Architectural and Engineering, which defines the products acceptable for inclusion in the HABS/HAER/HALS collection at the Library of Congress. The specific scope and details of documentation should be developed at the project level in coordination with the Lead Agency. f) During the project planning phase, obtain a qualified archaeologist, defined as one who meets the SOI PQS for archaeology, to conduct a record search at the appropriate Information Center of the California Historical Resources Information System (CHRIS) to determine whether the project area has been previously surveyed and whether resources were identified.
g) Contact the NAHC to request a Sacred Lands File search and a list of relevant Native American contacts who may have additional information. h) During the project planning phase, obtain a qualified archaeologist or architectural historian (depending on applicability) to conduct archaeological and/or historic architectural surveys as recommended by the qualified professional, the Lead Agency, or the Information Center. In the event the records indicate that no previous survey has been conducted, the qualified professional or Information Center will make a recommendation on whether a survey is warranted based on the sensitivity of the project area for archaeological resources.

Testing and Data Recovery Plan, archaeological testing will occur ahead of Project-related ground disturbance to identify the presence, or lack, of archaeological resources within the Project area. Should any potentially significant archaeological deposits be identified during testing efforts, an archaeological data recovery program will be implemented. Additionally, Mitigation Measure CUL-2 requires archaeological monitoring during initial grading and ground disturbance. With
implementation of Mitigation Measure CUL-1 and Mitigation Measure CUL-2, impacts related to archaeological resources would be less than significant.

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69 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project i) If potentially significant archaeological resources are identified through survey, and impacts to these resources cannot be avoided, a Phase II Testing and Evaluation investigation should be performed by a qualified archaeologist prior to any construction-related ground-disturbing activities to determine significance.

If resources determined significant or unique through Phase II testing, and avoidance is not possible, appropriate resource-specific mitigation measures should be established by the lead agency and undertaken by qualified personnel.

These might include a Phase III data recovery program implemented by a qualified archaeologist and performed in accordance with the OHP’s Archaeological Resource Management Reports (ARMR): Recommended Contents and Format and Guidelines for Archaeological Research Designs. Additional options can include 1) interpretative signage, or 2) educational outreach that helps inform the public of the past activities that occurred in this area. Archaeological materials collected from a significant resource should be curated with a recognized scientific or educational repository
j) If a record search or archaeological assessment indicates that the project is located in an area sensitive for archaeological resources, as determined by the Lead Agency in consultation with a qualified archaeologist, retain an archaeological monitor to observe ground disturbing operations, including but not limited to grading, excavation, trenching, or removal of existing features of the subject property. The archaeological monitor should be supervised by an archaeologist meeting the SOI PQS
k) Conduct construction activities and excavation to avoid cultural resources (if identified). If avoidance is not feasible, further work may be needed to determine the importance of a resource. Retain a qualified archaeologist, and/or as appropriate, a qualified architectural historian who should make recommendations regarding the work necessary to assess significance. If the cultural resource is determined to be significant under state or federal guidelines, impacts to the cultural resource will need to be mitigated.
l) Stop construction activities and excavation in the area where cultural resources are found until a qualified archaeologist can determine whether these resources are significant. If the archaeologist determines that the discovery is significant, it should be curated with a recognized scientific or educational repository.

Impact CULT-2: Cause a
substantial adverse change in the
significance of an archaeological
resource pursuant to § 15064.5.

See PMM CULT-1.

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70 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Impact CULT-3: Disturb human
remains, including those interred
outside of dedicated cemeteries.

PMM CULT-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 reduce substantial adverse effects related to human remains. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) In the event of discovery or recognition of any human remains during construction or excavation activities associated with the project, in any location other than a dedicated cemetery, cease further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until the coroner of the county in which the remains are discovered has been informed and has determined that no investigation of the cause of death is required. b) If any discovered remains are of Native American origin:
• Contact the County Coroner to contact the NAHC to designate a Native American Most Likely Descendant (MLD). The MLD should make a recommendation to the landowner or the person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods. This may include obtaining a qualified archaeologist or team of archaeologists to properly excavate the human remains
• If the NAHC is unable to identify a MLD, or the MLD fails to make a recommendation within 48 hours after being notified by the commission, or the landowner or his representative rejects the recommendation of the MLD and the mediation by the NAHC fails to provide measures acceptable to the landowner, obtain a culturally affiliated Native American monitor, and an archaeologist, if recommended by the Native American monitor, and rebury the Native American human remains and any associated grave goods, with appropriate dignity, on the property and in a location that is not subject to further subsurface disturbance.

The Project substantially complies with this mitigation measure.

If human remains are encountered during construction, State Health and Safety Code Section 7050.5, included as PPP CUL1, states that no further disturbance shall occur until the County coroner has made the necessary findings as to origin and disposition, pursuant to PRC Section 5097.98. If the county coroner concludes that the remains are of Native American descent, the Native American Heritage Commission must be notified within 24 hours, and NAHC guidelines would be
adhered to in the treatment and handling of the remains. With regulatory compliance, included as PPP CUL-1, any potential significant impacts of the Project related to this threshold would be less than significant.

Energy
Impact ENR-1: Result in potentially
significant environmental impact
due to wasteful, inefficient, or
unnecessary consumption of energy
resources, during project
construction or operation.

No mitigation is required. No mitigation is required.

Impact ENR-2: Conflict with or
obstruct a state or local plan for
No mitigation is required. No mitigation is required.

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71 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project renewable energy or energy
efficiency.

Geology and Soils
Impact GEO-1: 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) seismicrelated ground failure, including liquefaction; (iv) landslides.

No mitigation is required. No mitigation is required.

Impact GEO-2: Result in substantial
soil erosion or the loss of topsoil
PMM-GEO-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 related to historical resources. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Consistent with the CBC and local regulatory agencies with oversight of development associated with the Plan, ensure that site-specific geotechnical investigations conducted by a qualified geotechnical expert are conducted to ascertain soil types prior to preparation of project designs. These investigations can and should identify areas of potential failure and recommend remedial geotechnical measures to eliminate any problems.
b) Consistent with the requirements of the State Water Resources Control Board (SWRCB) for projects over one acre in size, obtain coverage under the General Construction Activity Storm Water Permit (General Construction Permit) issued by the SWRCB and prepare a stormwater pollution prevention plan (SWPPP) and submit the plan for review and approval by the Regional Water Quality Control Board (RWQCB). At a minimum, the SWPPP should include a description of construction materials, practices, and equipment storage and maintenance; a list The Project would result in less than significant impacts as a result of compliance with regulatory requirements, but
nonetheless substantially conforms with this mitigation measure.

The Project would require approval of a SWPPP to minimize soils erosion from stormwater during construction. Additionally, the Project would require a Water Quality Management Plan in order to reduce soil erosion from stormwater during Project operation. With implementation of the SWPP and Water
Quality Management Plan, impacts related to soil erosion or loss of topsoil would be less than significant.

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72 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project of pollutants likely to contact stormwater; site-specific erosion and sedimentation control practices; a list of provisions to eliminate or reduce discharge of materials to stormwater; best management practices (BMPs); and an inspection and monitoring program.
c) Consistent with the requirements of the SWRCB and local regulatory agencies with oversight of development associated with the Plan, ensure that project designs provide adequate slope drainage and appropriate landscaping to minimize the occurrence of slope instability and erosion. Design features should include measures to reduce erosion caused by storm water. Road cuts should be designed to maximize the potential for revegetation.
d) Consistent with the CBC and local regulatory agencies with oversight of development associated with the Plan, ensure that, prior to preparing project designs, new and abandoned wells are identified within construction areas to ensure the stability of nearby soils.

Impact GEO-3: Be located on a
geologic unit or soil that is unstable,
or that would become unstable as
a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading,
subsidence, liquefaction, or
collapse.

No mitigation is required. No mitigation is required.

Impact GEO-4: Be located on
expansive soil, as defined in Table
18-1-B of the Uniform Building
Code (1994), creating substantial
risks to life or property.

No mitigation is required. No mitigation is required.

Impact GEO-5: 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 mitigation is required. No mitigation is required.

Impact GEO-6: Directly or
indirectly destroy a unique
PMM-GEO-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 The Project substantially conforms to PMM-GEO 1 measures 1 through h. A Paleontological Resources Report was prepared for the Project by MCC in May 2022 which includes review of SCEA
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73 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project paleontological resource or site or
unique geologic feature.
related to paleontological resources. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Ensure compliance with the Paleontological Resources Preservation Act, the Federal Land Policy and Management Act, the Antiquities Act, Section 5097.5 of the Public Resources Code (PRC), adopted county and city general plans, and other federal, state and local regulations, as applicable and feasible, by adhering to and incorporating the performance standards and practices from the 2010 Society for Vertebrate Paleontology (SVP) standard procedures for the assessment and mitigation of adverse impacts to paleontological resources. b) Obtain review by a qualified paleontologist (e.g., who meets the SVP standards for a Principal Investigator or Project Paleontologist or the Bureau of Land Management (BLM) standards for a Principal Investigator), to determine if the project has the potential to require ground disturbance of parent material with potential to contain unique paleontological or resources, or to require the substantial alteration of a unique geologic feature. The assessment should include museum records searches, a review of geologic mapping and the scientific literature, geotechnical studies (if available), and potentially a pedestrian survey, if units with paleontological potential are present at the surface. c) Avoid exposure or displacement of parent material with potential to yield unique paleontological resources.
d) Where avoidance of parent material with the potential to yield unique paleontological resources is not feasible:
1) All on-site construction personnel receive Worker Education and Awareness Program (WEAP) training prior to the commencement of excavation work to understand the regulatory framework that provides for protection of paleontological resources and become familiar with diagnostic characteristics of the materials with the potential to be encountered.
2) A qualified paleontologist prepares a Paleontological Resource Management Plan (PRMP) to guide the salvage, documentation and repository of unique paleontological resources encountered during construction. The PRMP should adhere to and incorporate the performance standards and practices from the 2010 SVP Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources. If unique paleontological resources are encountered during construction, use a qualified paleontologist to oversee the implementation of the PRMP.
the Project’s potential for sensitivity of encountering paleontological resources. The Paleontological Resources Report describes that Project excavation has the potential to impact paleontologically sensitive older Quaternary
sediments. As such, the Project will incorporate Project-specific Mitigation Measure PAL-1, which requires preparation of a Paleontological Resource Mitigation Program (PRMP) and
paleontological monitoring for ground disturbing activities occurring past five feet in depth within native soil, as determined by the Project paleontologist. With
implementation of MM PAL-1, impacts related to this threshold would be less than significant.

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74 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project 3) Monitor ground disturbing activities in parent material, with a moderate to high potential to yield unique paleontological resources using a qualified paleontological monitor meeting the standards of the SVP or the BLM to determine if unique paleontological resources are encountered during such activities, consistent with the specified or comparable protocols.
4) Identify where ground disturbance is proposed in a geologic unit having the potential for containing fossils and specify the need for a paleontological monitor to be present during ground disturbance in these areas.
e) Avoid routes and project designs that would permanently alter unique geological features.
f) Salvage and document adversely affected resources sufficient to support ongoing scientific research and education.
g) Significant recovered fossils should be prepared to the point of curation, identified by qualified experts, listed in a database to facilitate analysis, and deposited in a designated paleontological curation facility. h) Following the conclusion of the paleontological monitoring, the qualified paleontologist should prepare a report stating that the paleontological monitoring requirement has been fulfilled and summarize the results of any paleontological finds. The report should be submitted to the lead CEQA and the repository curating the collected artifacts, and should document the methods and results of all work completed under the PRMP, including treatment of paleontological materials, results of specimen processing, analysis, and research, and final curation arrangements.

Greenhouse Gases
Impact GHG-1: Generate
greenhouse gas emissions, either
directly or indirectly, that may
have a significant impact on the
environment.

PMM-GHG-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 related to greenhouse gas emissions. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Integrate green building measures consistent with CALGreen (California Building Code Title 24), local building codes and other applicable laws, into project design including:

Mitigation is not required because Project impacts would be less than significant. Nevertheless, the Project substantially conforms to this mitigation measure as discussed below.

The Project would incorporate energy efficiency measures of Title 24 of the California Building Code. Additionally, the Project would provide a residential building within onequarter mile from the Arrow Line and provide pedestrian SCEA
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75 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project i. Use energy efficient materials in building design, construction, rehabilitation, and retrofit.
ii. Install energy-efficient lighting, heating, and cooling systems (cogeneration); water heaters; appliances; equipment; and control systems.
iii. Reduce lighting, heating, and cooling needs by taking advantage of light-colored roofs, trees for shade, and sunlight.
iv. Incorporate passive environmental control systems that account for the characteristics of the natural environment.
v. Use high-efficiency lighting and cooking devices.
vi. Incorporate passive solar design.
vii. Use high-reflectivity building materials and multiple glazing. viii. Prohibit gas-powered landscape maintenance equipment. ix. Install electric vehicle charging stations.
x. Reduce wood burning stoves or fireplaces.
xi. Provide bike lanes accessibility and parking at residential developments.
b) Reduce emissions resulting from projects through implementation of project features, project design, or other measures, such as those described in Appendix F of the State CEQA Guidelines.
c) Include off-site measures to mitigate a project’s emissions. d) Measures that consider incorporation of Best Available Control Technology (BACT) during design, construction and operation of projects to minimize GHG emissions, including but not limited to:
i. Use energy and fuel-efficient vehicles and equipment; ii. Deployment of zero- and/or near zero emission technologies; iii. Use lighting systems that are energy efficient, such as LED technology; iv. Use the minimum feasible amount of GHG-emitting construction materials;
paseos to promote walkability, which would reduce VMT and greenhouse gas emissions.

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76 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project v. Use cement blended with the maximum feasible amount of flash or other materials that reduce GHG emissions from cement production; vi. Incorporate design measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse; vii. Incorporate design measures to reduce energy consumption and increase use of renewable energy;
viii. Incorporate design measures to reduce water consumption; ix. Use lighter-colored pavement where feasible;
x. Recycle construction debris to maximum extent feasible; xi. Plant shade trees in or near construction projects where feasible; and xii. Solicit bids that include concepts listed above.
e) Measures that encourage transit use, carpooling, bike-share and car-share programs, active transportation, and parking strategies, including, but not limited to the following:
i. Promote transit-active transportation coordinated strategies; ii. Increase bicycle carrying capacity on transit and rail vehicles; iii. Improve or increase access to transit;
iv. Increase access to common goods and services, such as groceries, schools, and day care;
v. Incorporate affordable housing into the project;
vi. Incorporate the neighborhood electric vehicle network; vii. Orient the project toward transit, bicycle and pedestrian facilities; viii. Improve pedestrian or bicycle networks, or transit service; ix. Provide traffic calming measures;
x. Provide bicycle parking;
xi. Limit or eliminate park supply through:
i. Elimination (or reduction) of minimum parking requirements ii. Creation of maximum parking requirements
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77 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project iii. Provision of shared parking.
xii. Unbundle parking costs;
xiii. Provide parking cash-out programs;
xiv. Implement or provide access to commute reduction program; f) Incorporate bicycle and pedestrian facilities into project designs, maintaining these facilities, and providing amenities incentivizing their use; and planning for and building local bicycle projects that connect with the regional network; g) Improving transit access to rail and bus routes by incentives for construction of transit facilities within developments, and/or providing dedicated shuttle service to transit stations; and
h) Adopting employer trip reduction measures to reduce employee trips such as vanpool and carpool programs, providing end-of-trip facilities, and telecommuting programs including but not limited to measures that:
i. Provide car-sharing, bike sharing, and ride-sharing programs; ii. Provide transit passes;
iii. Shift single occupancy vehicle trips to carpooling or vanpooling, for example providing ride-matching services;
iv. Provide incentives or subsidies that increase that use of modes other than single occupancy vehicle;
v. Provide on-site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms;
vi. Provide employee transportation coordinators at employment sites; vii. Provide a guaranteed ride home service to users of non-auto modes. i) Designate a percentage of parking spaces for ride-sharing vehicles or highoccupancy vehicles, and provide adequate passenger loading and unloading for those vehicles;
j) Land use siting and design measures that reduce GHG emissions, including:
i. Developing on infill and brownfields sites;
ii. Building compact and mixed-use developments near transit; SCEA
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78 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project iii. Retaining on-site mature trees and vegetation, and planting new canopy trees;
iv. Measures that increase vehicle efficiency, encourage use of zero and low emissions vehicles, or reduce the carbon content of fuels, including constructing or encouraging construction of electric vehicle charging stations or neighborhood electric vehicle networks, or charging for electric bicycles; and
v. Measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse.
k. Consult the SCAG Environmental Justice Toolbox for potential measures to address impacts to low-income and/or minority communities. The measures provided above are also intended to be applied in low income and minority communities as applicable and feasible.
l. Require at least five percent of all vehicle parking spaces include electric vehicle charging stations, or at a minimum, require the appropriate infrastructure to facilitate sufficient electric charging for passenger vehicles and trucks to plug-in. m. Encourage telecommuting and alternative work schedules, such as:
i. Staggered starting times
ii. Flexible schedules
iii. Compressed work weeks
n. Implement commute trip reduction marketing, such as:
i. New employee orientation of trip reduction and alternative mode options
ii. Event promotions
iii. Publications
o. Implement preferential parking permit program
p. Implement school pool and bus programs
q. Price workplace parking, such as:
i. Explicitly charging for parking for its employees;
ii. Implementing above market rate pricing;
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79 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project iii. Validating parking only for invited guests;
iv. Not providing employee parking and transportation allowances; and v. Educating employees about available alternatives.

Impact GHG-2: Conflict with an
applicable plan, policy, or
regulation adopted for the
purpose of reducing the emissions
of greenhouse gases
See PMM GHG-1.

Hazards and Hazardous Materials
Impact HAZ-1: Create a
significant hazard to the public or
the environment through the routine
transport, use, or disposal of
hazardous materials.

PMM HAZ-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 related to the routine transport, use, or disposal of hazardous materials, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Where the construction or operation of projects involves the transport of hazardous material, provide a written plan of proposed routes of travel demonstrating use of roadways designated for the transport of such materials. b) Specify Project requirements for interim storage and disposal of hazardous materials during construction and operation. Storage and disposal strategies must be consistent with applicable federal, state, and local statutes and regulations.

Specify the appropriate procedures for interim storage and disposal of hazardous materials, anticipated to be required in support of operations and maintenance activities, in conformance with applicable federal, state, and local statutes and regulations, in the business plan for projects as applicable and appropriate. c) Submit a Hazardous Materials Business/Operations Plan for review and approval by the appropriate local agency. Once approved, keep the plan on file with the Lead Agency (or other appropriate government agency) and update, as applicable. The purpose of the Hazardous Materials Business/Operations Plan is to ensure that employees are adequately trained to handle the materials and provides information to the local fire protection agency should emergency response be required. The Hazardous Materials Business/Operations Plan should include the following:

The Project’s impacts with respect to hazardous materials are less than significant. Pursuant to CEQA Guidelines Section 15126.4, subd. (a)(4)(A)–(B), there must be a nexus between PMM HAZ-1 and environmental impacts from the proposed
Project. However, the Project would nevertheless substantially conform to this mitigation measure as set forth in the 2020- 2045 RTP/SCS.

Like the majority of construction projects, construction of the Project would involve the temporary use of hazardous
substances in the form of paint, adhesives, surface coatings, cleaning materials, fuels and oils. However, all materials would be used, stored, and disposed of in accordance with
applicable laws and regulations and manufacturers’
instructions. Also, construction work would be performed in compliance with applicable federal Occupational Safety and Health Administration (OSHA) Safety and Health Standards and CalOSHA requirements to ensure the safety of
construction workers.

As the existing onsite buildings were constructed prior to the 1978 federal regulations banning the use of lead-based
paints (LBPs). Therefore, there is potential for the presence of LBPs in the onsite buildings. Should lead-based paint materials be identified, standard handling and disposal practices shall be implemented pursuant to CalOSHA regulations. All
construction activities would occur in adherence with these regulations guiding such activities to minimize any upset or accident release of hazardous materials into the environment.

With regulatory compliance, the risk related to any existing SCEA
City of Redlands The Grand Project
80 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project • The types of hazardous materials or chemicals stored and/or used onsite, such as petroleum fuel products, lubricants, solvents, and cleaning fluids.
• The location of such hazardous materials.
• An emergency response plan including employee training information. • A plan that describes the way these materials are handled, transported and disposed.
d) Follow manufacturer’s recommendations on use, storage, and disposal of chemical products used in construction.
e) Avoid overtopping construction equipment fuel gas tanks. f) Properly contain and remove grease and oils during routine maintenance of construction equipment.
g) Properly dispose of discarded containers of fuels and other chemicals. h) Prior to shipment remove the most volatile elements, including flammable natural gas liquids, as feasible.
i) Identify and implement more stringent tank car safety standards. j) Improve rail transportation route analysis, and modification of routes based on that analysis.
k) Use the best available inspection equipment and protocols and implement positive train control.
l) Reduce train car speeds to 40 miles per hour when passing through urbanized areas of any size.
m) Limit storage of crude oil tank cars in urbanized areas of any size and provide appropriate security in storage yards for all shipments. n) Notify in advance county and city emergency operations offices of all crude oil shipments, including a contact number that can provide real-time information in the event of an oil train derailment or accident.
o) Report quarterly hazardous commodity flow information, including classification and characterization of materials being transported, to all first response agencies (49 Code Fed. Regs. 15.5) along the mainline rail routes used by trains carrying crude oil identified.

LBPs at the Project Site would be reduced to acceptable levels, and the Project would result in no impact with regard to LBPs.

As the onsite structures were built before the 1978 federal regulations banning the use of asbestos containing building materials (ACBMs) were enacted, there is a potential for the presence of ACBMs in the onsite buildings. The EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) requires that an asbestos survey adhering to Asbestos Hazard Emergency Response Act (AHERA) sampling protocol be
performed prior to demolition or renovation activities that may disturb ACMs. This requirement may be enforced by the local air pollution control or air quality management district and specifies that all suspect asbestos-containing materials (ACMs) be sampled to determine the presence or absence of asbestos prior to any renovation or demolition activities to prevent potential exposure to workers and/or residential occupants.

With regulatory compliance, the risk related to any existing ACBMs at the Project Site would be reduced to acceptable levels, and the Project would result in no impact with regard to ACBMs.

Operation of the Project’s residential uses would involve the use and storage of small quantities of potentially hazardous materials in the form of typical cleaning solvents, painting supplies, pesticides for landscaping, and pool maintenance.

The use of these materials would be in small quantities and in accordance with the manufacturers’ instructions for use, storage, and disposal of such products. Therefore, with compliance with applicable regulations, the Project’s potential impacts would be less than significant.

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81 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project p) Fund training and outfitting emergency response crews that includes the cost of backfilling personnel while in training.
q) Undertake annual emergency responses scenario/field-based training including Emergency Operations Center Training activations with local emergency response agencies.

Impact HAZ-2: 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.

See PMM HAZ-1.

PMM HAZ-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 reduce hazards related to the reasonably foreseeable upsets and accidents involving the release of hazardous materials, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Removal of the most volatile elements, including flammable natural gas liquids, prior to shipment;
b) More stringent tank car safety standards;
c) Improved rail transportation route analysis, and modification of routes based on that analysis;
d) Utilization of the best available inspection equipment and protocols, and implementation of positive train control;
e) Reduced train car speeds to 40 miles per hour when passing through urbanized areas of any size;
f) Limitations on storage of hazardous materials tank cars in urbanized areas of any size and provide appropriate security in storage yards for all shipments; g) Advance notification to county and city emergency operations offices of all crude oil and hazardous materials shipments, including a contact number that can provide real-time information in the event of an oil train derailment or accident; h) Quarterly hazardous commodity flow information, including classification and characterization of materials being transported, to all first response agencies (49 Code Fed. Regs. 15.5) along the mainline rail routes used by trains carrying hazardous materials.

The Project’s impacts with respect to hazardous materials are less than significant. Pursuant to CEQA Guidelines Section 15126.4, subd. (a)(4)(A)–(B), there must be a nexus between PMM HAZ-2 and environmental impacts from the proposed
Project. However, the Project would nevertheless substantially conform to this mitigation measure as set forth in the 2020- 2045 RTP/SCS.

Construction of the Project would involve the temporary use of hazardous substances in the form of paint, adhesives, surface coatings and other finishing materials, and cleaning agents, fuels, and oils typical of construction projects. However, all materials would be used, stored, and disposed of in
accordance with applicable laws and regulations and
manufacturers’ instructions. Also, all construction work would be performed consistent with applicable federal Occupational Safety and Health Administration (OSHA) Safety and Health Standards and CalOSHA requirements to ensure the safety and well-being of construction workers.

As the majority of the onsite structures were built before the 1978 federal regulations banning the use of asbestos
containing building materials (ACBMs) were enacted, there is a potential for the presence of ACBMs in the onsite buildings.

If ACBMs are found to be present, they would be abated in compliance with the SCAQMD Rule 1403 and other
applicable State and federal rules and regulations. With regulatory compliance, the risk related to any existing ACBMs at the Project site would be reduced to acceptable levels, and the Project would result in no impact with regard to ACBMs.

As the existing onsite buildings were constructed prior to the 1978 federal regulations banning the use of lead-based
paints (LBPs). Therefore, there is potential for the presence of LBPs in the onsite buildings. Should lead-based paint materials be identified, standard handling and disposal practices shall SCEA
City of Redlands The Grand Project
82 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project be implemented pursuant to CalOSHA regulations. With
regulatory compliance, the risk related to any existing LBPs at the Project site would be reduced to acceptable levels, and the Project would result in no impact with regard to LBPs.

The City has determined that, with compliance with applicable regulations, the Project’s potential impacts would be less than significant.

Impact HAZ-3: Emit hazardous
emissions or handle hazardous or
acutely hazardous materials,
substances, or waste within onequarter mile of an existing or proposed school
See PMM HAZ-1 and PMM HAZ-2.

PMM HAZ-3: 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 related to the release of hazardous materials within one-quarter mile of schools, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Where the construction and operation of projects involves the transport of hazardous materials, avoid transport of such materials within one-quarter mile of schools, when school is in session, wherever feasible.
b) Where it is not feasible to avoid transport of hazardous materials, within onequarter mile of schools on local streets, provide notifications of the anticipated schedule of transport of such materials
Mitigation is not required because Project impacts would be less than significant as the Project site is not within a quarter mile of a school. Nevertheless, the Project substantially conforms with this mitigation measure. Construction of the Project would involve the temporary use of hazardous
substances in the form of paint, adhesives, surface coatings and other finishing materials, and cleaning agents, fuels, and oils typically used in construction.

The types of potentially hazardous substances and materials that would be used in association with the operation of the Project would include those typical of residential
developments, such as small quantities of cleaning solvents, painting supplies, pesticides for landscaping, and pool maintenance. However, all such substances and materials would be used, stored, and disposed of in accordance with applicable laws and regulations and manufacturers’
instructions.

With compliance to applicable laws, regulations, and
manufacturers’ instructions, construction of the Project would not create a significant risk of exposure to hazardous
materials for schools.

Impact HAZ-4: 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.

PMM HAZ-4: 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 related to projects that are located on a site which is included on the Cortese List, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) For any listed sites or sites that have the potential for residual hazardous materials as a result of historic land uses, complete a Phase I Environmental Site Assessment, including a review and consideration of data from all known The Project’s impacts with respect to hazardous materials are less than significant. Pursuant to CEQA Guidelines Section 15126.4, subd. (a)(4)(A)–(B), there must be a nexus between PMM HAZ-4 and environmental impacts from the proposed
Project. However, the Project would nevertheless substantially conform to this mitigation measure as set forth in the 2020- 2045 RTP/SCS.

According to the California Department of Toxic Substances Control (DTSC) EnviroStor database, the Project site is not SCEA
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83 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project databases of contaminated sites, during the process of planning, environmental clearance, and construction for projects.
b) Where warranted due to the known presence of contaminated materials, submit to the appropriate agency responsible for hazardous materials/wastes oversight a Phase II Environmental Site Assessment report if warranted by a Phase I report for the project site. The reports should make recommendations for remedial action, if appropriate, and be signed by a Registered Environmental Assessor, Professional Geologist, or Professional Engineer.
c) Implement the recommendations provided in the Phase II Environmental Site Assessment report, where such a report was determined to be necessary for the construction or operation of the project, for remedial action. d) Submit a copy of all applicable documentation required by local, state, and federal environmental regulatory agencies, including but not limited to: permit applications, Phase I and II Environmental Site Assessments, human health and ecological risk assessments, remedial action plans, risk management plans, soil management plans, and groundwater management plans.
e) Conduct soil sampling and chemical analyses of samples, consistent with the protocols established by the U.S. EPA to determine the extent of potential contamination beneath all underground storage tanks (USTs), elevator shafts, clarifiers, and subsurface hydraulic lifts when on-site demolition or construction activities would potentially affect a particular development or building. f) Consult with the appropriate local, state, and federal environmental regulatory agencies to ensure sufficient minimization of risk to human health and environmental resources, both during and after construction, posed by soil contamination, groundwater contamination, or other surface hazards including, but not limited to, underground storage tanks, fuel distribution lines, waste pits and sumps. g) Obtain and submit written evidence of approval for any remedial action if required by a local, state, or federal environmental regulatory agency. h) Cease work if soil, groundwater, or other environmental medium with suspected contamination is encountered unexpectedly during construction activities (e.g., identified by odor or visual staining, or if any underground storage tanks, abandoned drums, or other hazardous materials or wastes are encountered), in the vicinity of the suspect material. Secure the area as necessary and take all appropriate measures to protect human health and the environment, including but not limited to, notification of regulatory agencies and identification of the nature and extent of contamination. Stop work in the areas affected until the measures located on a federal Superfund site, State response site, voluntary cleanup site, school cleanup site, corrective action site, or tiered permit site (DTSC 2022). Additionally, according to the State Water Resource Control Board’s Geotracker
database, the Project site is not located on a Leaking UST Cleanup Site, Cleanup Program Site, Military Cleanup Site, Military Privatized Site, or Military UST site (SWRCB 2022).

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.

SCEA
City of Redlands The Grand Project
84 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project have been implemented consistent with the guidance of the appropriate regulatory oversight authority.
i) Soil generated by construction activities should be stockpiled on-site in a secure and safe manner. All contaminated soils determined to be hazardous or nonhazardous waste must be adequately profiled (sampled) prior to acceptable reuse or disposal at an appropriate off-site facility. Complete sampling and handling and transport procedures for reuse or disposal, in accordance with applicable local, state and federal laws and policies.
j) Groundwater pumped from the subsurface should be contained on-site in a secure and safe manner, prior to treatment and disposal, to ensure environmental and health issues are resolved pursuant to applicable laws and policies. Utilize engineering controls, which include impermeable barriers to prohibit groundwater and vapor intrusion into the building.
k) As needed and appropriate, prior to issuance of any demolition, grading, or building permit, submit for review and approval by the Lead Agency (or other appropriate government agency) written verification that the appropriate federal, state and/or local oversight authorities, including but not limited to the Regional Water Quality Control Board (RWQCB), have granted all required clearances and confirmed that the all applicable standards, regulations, and conditions have been met for previous contamination at the site. l) Develop, train, and implement appropriate worker awareness and protective measures to assure that worker and public exposure is minimized to an acceptable level and to prevent any further environmental contamination as a result of construction.
m) If asbestos-containing materials (ACM) are found to be present in building materials to be removed, submit specifications signed by a certified asbestos consultant for the removal, encapsulation, or enclosure of the identified ACM in accordance with all applicable laws and regulations, including but not necessarily limited to: California Code of Regulations, Title 8; Business and Professions Code; Division 3; California Health and Safety Code Section 25915- 25919.7; and other local regulations.
n) Where projects include the demolitions or modification of buildings constructed prior to 1978, complete an assessment for the potential presence or lack thereof of ACM, lead based paint, and any other building materials or stored materials classified as hazardous waste by state or federal law.
o) Where the remediation of lead-based paint has been determined to be required, provide specifications to the appropriate agency, signed by a certified SCEA
City of Redlands The Grand Project
85 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Lead Supervisor, Project Monitor, or Project Designer for the stabilization and/or removal of the identified lead paint in accordance with all applicable laws and regulations, including but not necessarily limited to: California Occupational Safety and Health Administration’s (Cal OSHA’s) Construction Lead Standard, Title 8 California Code of Regulations (CCR) Section 1532.1 and Department of Health Services (DHS) Regulation 17 CCR Sections 35001–36100, as may be amended.

If other materials classified as hazardous waste by state or federal law are present, the project sponsor should submit written confirmation to the appropriate local agency that all state and federal laws and regulations should be followed when profiling, handling, treating, transporting, and/or disposing of such materials.

Impact HAZ-5: 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
See PMM NOISE-1. No mitigation is required. There are no private or public airstrips within the vicinity of the Project area. The closest airport is the Redlands Municipal Airport, at 1755 Sessums Drive, Redlands, CA, which is approximately 2.45 miles from the Project site. As such, the Project is not within the airport’s land use plan, noise contours, or influence area, and the Project would not result in an airport-related safety hazard for people residing or working in the Project area.

Impact HAZ-6: Impair
implementation of or physically
interfere with an adopted
emergency response plan or
emergency evacuation plan
PMM HAZ-5: 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 which may impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Continue to coordinate locally and regionally based on ongoing review and integration of projected transportation and circulation conditions. b) Develop new methods of conveying projected and real time information to citizens using emerging electronic communication tools including social media and cellular networks;
c) Continue to evaluate lifeline routes for movement of emergency supplies and evacuation.

Future driveway and building configurations would comply with applicable fire code requirements for emergency
evacuation including proper emergency exits for visitors, employees, and residents. Project site access and circulation plans would be subject to review and approval by the
Redlands Fire Department (RFD). Furthermore, the Project would comply with City of Redlands General Plan Policy 5- A.15, which requires two means of ingress/egress into new residential communities. In addition, the City of Redlands has completed this Hazard Mitigation Plan in accordance with 44 Code of Federal Regulations (44 CFR Parts 201 and 206). The Project would not interfere with the City’s Hazard Mitigation Plan.

Impact HAZ-7: Expose people or
structures, either directly or
indirectly, to a significant risk of
See Wildfire, Impact WF-2. No mitigation measures are required. The Project site is located in a fully urbanized area and is not within a High Fire Hazard Severity Zone and is not near a wildland fire hazard.

SCEA
City of Redlands The Grand Project
86 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project loss, injury or death involving
wildland fires.

Hydrology and Water Quality
Impact HYD-1: Potential to violate
any water quality standards or
waste discharge requirements or
otherwise substantially degrade
surface or groundwater quality
PMM HYD-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 from violation of any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Complete, and have approved, a Stormwater Pollution Prevention Plan (SWPPP) prior to initiation of construction.
b) Implement Best Management Practices to reduce the peak stormwater runoff from the project site to the maximum extent practicable. c) Comply with the Caltrans storm water discharge permit as applicable; and identify and implement Best Management Practices to manage site erosion, wash water runoff, and spill control.
d) Complete, and have approved, a Standard Urban Stormwater Management Plan, prior to occupancy of residential or commercial structures. e) Ensure adequate capacity of the surrounding stormwater system to support stormwater runoff from new or rehabilitated structures or buildings. f) Prior to construction within an area subject to Section 404 of the Clean Water Act, obtain all required permit approvals and certifications for construction within the vicinity of a watercourse:
g) Where feasible, restore or expand riparian areas such that there is no net loss of impervious surface as a result of the project.
h) Install structural water quality control features, such as drainage channels, detention basins, oil and grease traps, filter systems, and vegetated buffers to prevent pollution of adjacent water resources by polluted runoff where required by applicable urban storm water runoff discharge permits, on new facilities. i) Provide operational best management practices for street cleaning, litter control, and catch basin cleaning are implemented to prevent water quality degradation in compliance with applicable storm water runoff discharge permits; and ensure treatment controls are in place as early as possible, such as during the acquisition The Project’s impacts would be less than significant as a result of the implementation of regulatory compliance measures.

Nevertheless, the Project substantially conforms with this mitigation measure because the Project is subject to regulatory compliance measures such as NPDES and SWPPP regulations that are capable of avoiding or reducing the potential impacts on water quality. The Project would comply with waste
discharge requirements that are within the jurisdiction and authority of the Regional Water Quality Control Board and other regulatory agency requirements including, but not limited to, the NPDES permitting requirements.

SCEA
City of Redlands The Grand Project
87 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project process for rights-of-way, not just later during the facilities design and construction phase.
j) Comply with applicable municipal separate storm sewer system discharge permits as well as Caltrans’ storm water discharge permit including long-term sediment control and drainage of roadway runoff.
k) Incorporate as appropriate treatment and control features such as detention basins, infiltration strips, and porous paving, other features to control surface runoff and facilitate groundwater recharge into the design of new transportation projects early on in the process to ensure that adequate acreage and elevation contours are provided during the right-of-way acquisition process. l) Upgrade stormwater drainage facilities to accommodate any increased runoff volumes. These upgrades may include the construction of detention basins or structures that will delay peak flows and reduce flow velocities, including expansion and restoration of wetlands and riparian buffer areas. System designs shall be completed to eliminate increases in peak flow rates from current levels. m) Encourage Low Impact Development (LID) and incorporation of natural spaces that reduce, treat, infiltrate and manage stormwater runoff flows in all new developments, where practical and feasible.

Impact HYD-2: Potential to
substantially decrease
groundwater supplies or interfere
substantially with groundwater
recharge such that the project may
impede sustainable groundwater
management of the basin.

PMM HYD-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 reduce substantial adverse effects from violation of any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Avoid designs that require continual dewatering where feasible.

For projects requiring continual dewatering facilities, implement monitoring systems and long-term administrative procedures to ensure proper water management that prevents degrading of surface water and minimizes adverse impacts on groundwater for the life of the project, Construction designs shall comply with appropriate building codes and standard practices including the Uniform Building Code.
b) Maximize, where practical and feasible, permeable surface area in existing urbanized areas to protect water quality, reduce flooding, allow for groundwater recharge, and preserve wildlife habitat. Minimize new impervious surfaces, including the use of in-lieu fees and off-site mitigation.

The Project’s impacts would be less than significant, and no mitigation is required. Nevertheless, Project substantially conforms with this mitigation measure because the Project Site is located in an urbanized area that does not contain any significant groundwater recharge areas. Additionally, the Project site is currently almost entirely impervious, with the exception of planters. As discussed in the Preliminary Water Quality Management Plan, included as Appendix H, the
Project would maximize permeable surfaces in order to
promote groundwater recharge.

SCEA
City of Redlands The Grand Project
88 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project c) Avoid construction and siting on groundwater recharge areas, to prevent conversion of those areas to impervious surface. d) Reduce hardscape to the extent feasible to facilitate groundwater recharge as appropriate.

Impact HYD-3a: 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 result in
substantial erosion or siltation onor off-site.

See PMM HYD-1. The Project’s impacts would be less than significant as a result of the implementation of regulatory compliance measures.

Nevertheless, the Project substantially conforms to this mitigation measure, because the Project is required to comply with regulatory requirements including NPDES and City
requirements, including those requiring the preparation of a Project-specific Stormwater Pollution Prevention Plan (SWPPP) and Water Quality Management Plan (WQMP). The
proposed stormwater Best Management Practices (BMPs)
would include multiple planter boxes for stormwater
infiltration and a detention basin under the proposed parking area.

Impact HYD-3b: 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 substantially
increase the rate or amount of
flooding on- or off-site.

See PMM HYD-1 and PMM HYD-2. The Project’s impacts would be less than significant as a result of the implementation of regulatory compliance measures.

Nevertheless, the Project substantially conforms to this mitigation measure, because the Project is required to comply with regulatory requirements including NPDES and City
requirements, including those requiring the preparation of a Project-specific SWPPP and WQMP. The proposed
stormwater BMPs would include multiple planter boxes for stormwater infiltration and a detention basin under the proposed parking area.

Impact HYD-3c: 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 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.

See PMM HYD-1 and PMM HYD-2. The Project’s impacts would be less than significant as a result of the implementation of regulatory compliance measures.

Nevertheless, the Project substantially conforms to this mitigation measure, because the Project is required to comply with regulatory requirements including NPDES and City
requirements, including those requiring the preparation of a Project-specific SWPPP and WQMP. The proposed
stormwater BMPs would include multiple planter boxes for stormwater infiltration and a detention basin under the proposed parking area.

SCEA
City of Redlands The Grand Project
89 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Impact HYD-4: In flood hazard,
tsunami, or seiche zones, risk
release of pollutants due to project
inundation.

PMM-HYD-4: 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 capable of avoiding or reducing the potential impacts of locating structures that would impede or redirect flood flows, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Ensure that all roadbeds for new highway and rail facilities be elevated at least one foot above the 100-year base flood elevation. Since alluvial fan flooding is not often identified on Federal Emergency Management Agency (FEMA) flood maps, the risk of alluvial fan flooding should be evaluated and projects should be sited to avoid alluvial fan flooding. Delineation of floodplains and alluvial fan boundaries should attempt to account for future hydrologic changes caused by global climate change.

According to FEMA flood insurance rate maps, the Project site is located within flood Zone AO, which would have an
approximate flood depth of 1 foot. However, the Project is required to comply with City Municipal Code Chapter 15.32, which includes regulations for development within flood hazard areas. Regulations include requiring any new
occupiable finished floor to be 2 feet above the 100-year flood elevation. With adherence to Municipal Code Chapter

15.32, the Project would not risk release of pollutants due to inundation in a flood hazard zone. Additionally, the Project site is not located in a seiche or tsunami flood hazard area.

Impact HYD-5: Conflict with or
obstruct implementation of a water
quality control plan or sustainable
groundwater management plan.

See PMM HYD-2. The Project’s impacts would be less than significant as a result of the implementation of regulatory compliance measures.

Nevertheless, the Project substantially conforms to this mitigation measure, because the Project is required to comply with regulatory requirements including NPDES and City
requirements, including those requiring the preparation of a Project-specific SWPPP and WQMP. The proposed
stormwater BMPs would include detention basins and planter boxes to filter and infiltrate stormwater.

The Project would not interfere with a groundwater
management plan as it would increase the pervious surfaces onsite and would not reduce groundwater levels.

Land Use
Impact LU-1: Potential for the
Project to physically divide an
established community
PMM LU-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 that physically divide a community, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Facilitate good design for land use projects that build upon and improve existing circulation patterns
b) Encourage implementing agencies to orient transportation projects to minimize impacts on existing communities by:

No mitigation is required. The Project site is currently developed with a commercial building and surface parking.

The Project vicinity is highly urbanized and generally built out.

The local vicinity is characterized by a blend of commercial, residential, and office uses. The Project would provide a new multi-family residential development that would include 146 apartments. As such, the Project would be an infill project providing uses consistent with the mixed-use character of the surrounding area. Given the type of uses in the Project site vicinity, and the infill character of the Project, it would not physically divide an established community. The Project would SCEA
City of Redlands The Grand Project
90 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project • Selecting alignments within or adjacent to existing public rights of way. • Design sections above or below-grade to maintain viable vehicular, cycling, and pedestrian connections between portions of communities where existing connections are disrupted by the transportation project. • Wherever feasible incorporate direct crossings, overcrossings, or under crossings at regular intervals for multiple modes of travel (e.g., pedestrians, bicyclists, vehicles).
c) Where it has been determined that it is infeasible to avoid creating a barrier in an established community, consider other measures to reduce impacts, including but not limited to:
• Alignment shifts to minimize the area affected.
• Reduction of the proposed right-of-way take to minimize the overall area of impact.
• Provisions for bicycle, pedestrian, and vehicle access across improved roadways.
not disrupt or divide an established community through a change in street or land use patterns within the community.

Impact LU-2: 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
PMM LU-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 reduce substantial adverse effects that physically divide a community, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) When an inconsistency with the adopted general plan policy or land use regulation (adopted for the purpose of avoiding or mitigating an impact) is identified modify the transportation or land use project to eliminate the conflict; or, determine if the environmental, social, economic, and engineering benefits of the project warrant an amendment to the general plan or land use regulation.

No mitigation is required as the proposed Project would not conflict with the City of Redlands General Plan, as shown in Table LU-1.

Mineral Resources
Impact MIN-1: Potential to 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.

PMM MIN-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 the use of mineral resources that could be of value to the region, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Provide for the efficient use of known aggregate and mineral resources or locally important mineral resource recovery sites, by ensuring that the consumptive use of aggregate resources is minimized and that access to recoverable sources of No mitigation is required. The Project site is located within an urbanized area of the City of Redlands. According to
Redlands General Plan Figure 6-4, the Project site is
designated as MRZ-3, which contains areas with known or inferred mineral occurrences of undetermined mineral resource significance. The Project site is not zoned for mineral extraction use and has not been historically used for mineral resource extraction.

SCEA
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91 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project aggregate is not precluded, as a result of construction, operation and maintenance of projects.
b) Where avoidance is infeasible, minimize impacts to the efficient and effective use of recoverable sources of aggregate through measures that have been identified in county and city general plans, or other comparable measures such as:
1) Recycle and reuse building materials resulting from demolition, particularly aggregate resources, to the maximum extent practicable. 2) Identify and use building materials, particularly aggregate materials, resulting from demolition at other construction sites in the SCAG region, or within a reasonable hauling distance of the project site. 3) Design transportation network improvements in a manner (such as buffer zones or the use of screening) that does not preclude adjacent or nearby extraction of known mineral and aggregate resources following completion of the improvement and during long-term operations. 4) Avoid or reduce impacts on known aggregate and mineral resources and mineral resource recovery sites through the evaluation and selection of project sites and design features (e.g., buffers) that minimize impacts on land suitable for aggregate and mineral resource extraction by maintaining portions of MRZ-2 areas in open space or other general plan land use categories and zoning that allow for mining of mineral resources.

Impact MIN-2 Potential to result in
the loss of availability of a locally
important mineral resource
recovery site delineated on a local
general plan, specific plan or other
land use plan.

See PMM MIN-1. No mitigation is required. The Project site is located within an urbanized area of the City of Redlands. According to
Redlands General Plan Figure 6-4, the Project site is
designated as MRZ-3, which contains areas with known or inferred mineral occurrences of undetermined mineral resource significance. The Project site is not zoned for mineral extraction use and has not been historically used for mineral resource extraction.

Noise
Impact NOISE-1: 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
PMM NOISE-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 that physically divide a community, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:

The Project’s impacts would be less than significant as a result of the implementation of regulatory compliance measures.

Nevertheless, the Project substantially conforms to this mitigation measure. The Project is required to comply with regulatory control measures in City of Redlands Municipal Code Section 8.06.120, which regulates noise from
construction activities (e.g. construction activities will occur SCEA
City of Redlands The Grand Project
92 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project applicable standards of other
agencies.
a) Install temporary noise barriers during construction. b) Include permanent noise barriers and sound-attenuating features as part of the project design. Barriers could be in the form of outdoor barriers, sound walls, buildings, or earth berms to attenuate noise at adjacent sensitive uses. c) Schedule construction activities consistent with the allowable hours pursuant to applicable general plan noise element or noise ordinance d) Post procedures and phone numbers at the construction site for notifying the Lead Agency staff, local Police Department, and construction contractor (during regular construction hours and off-hours), along with permitted construction days and hours, complaint procedures, and who to notify in the event of a problem. e) Notify neighbors and occupants within 300 feet of the project construction area at least 30 days in advance of anticipated times when noise levels are expected to exceed limits established in the noise element of the general plan or noise ordinance.
f) Designate an on-site construction complaint and enforcement manager for the project.
g) Ensure that construction equipment is properly maintained per manufacturers’ specifications and fitted with the best available noise suppression devices (e.g., improved mufflers, equipment redesign, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds silencers, wraps). All intake and exhaust ports on power equipment shall be muffled or shielded. h) Use hydraulically or electrically powered tools (e.g., jack hammers, pavement breakers, and rock drills) for project construction to avoid noise associated with compressed air exhaust from pneumatically powered tools. However, where use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust should be used; this muffler can lower noise levels from the exhaust by up to about 10 dBA. External jackets on the tools themselves should be used, if such jackets are commercially available, and this could achieve a further reduction of 5 dBA. Quieter procedures should be used, such as drills rather than impact equipment, whenever such procedures are available and consistent with construction procedures.
i) Where feasible, design projects so that they are depressed below the grade of the existing noise-sensitive receptor, creating an effective barrier between the roadway and sensitive receptors.
between the hours of 7:00 a.m. and 6:00 p.m. on weekdays, including Saturdays, with no activities taking place on Sundays or federal holidays; Municipal Code Section 8.06.070,
Exterior Noise Limits, which sets exterior noise limits based on land use; and Municipal Code Section 8.06.080, which sets interior noise limits based on land use. Additionally,
procedures and phone numbers would be posted at the
construction site for notifying City of Redlands staff, Redlands Police Department, and the construction contractor to notify regarding complaints.

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City of Redlands The Grand Project
93 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project j) Where feasible, improve the acoustical insulation of dwelling units where setbacks and sound barriers do not provide sufficient noise reduction. k) Using rubberized asphalt or “quiet pavement” to reduce road noise for new roadway segments, roadways in which widening or other modifications require repavement, or normal reconstruction of roadways where re-pavement is planned l) Projects that require pile driving or other construction noise above 90 dBA in proximity to sensitive receptors, should reduce potential pier drilling, pile driving and/or other extreme noise generating construction impacts greater than 90 dBA; a set of site-specific noise attenuation measures should be completed under the supervision of a qualified acoustical consultant.
m) Use land use planning measures, such as zoning, restrictions on development, site design, and buffers to ensure that future development is compatible with adjacent transportation facilities and land uses;
n) Monitor the effectiveness of noise reduction measures by taking noise measurements and installing adaptive mitigation measures to achieve the standards for ambient noise levels established by the noise element of the general plan or noise ordinance.
o) Use equipment and trucks with the best available noise control techniques (e.g., improved mufflers, equipment redesign, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds, wherever feasible) for project construction.
p) Stationary noise sources can and should be located as far from adjacent sensitive receptors as possible and they should be muffled and enclosed within temporary sheds, incorporate insulation barriers, or use other measures as determined by the Lead Agency (or other appropriate government agency) to provide equivalent noise reduction.
q) Use of portable barriers in the vicinity of sensitive receptors during construction. r) Implement noise control at the receivers by temporarily improving the noise reduction capability of adjacent buildings (for instance by the use of sound blankets), and implement if such measures are feasible and would noticeably reduce noise impacts.
s) Monitor the effectiveness of noise attenuation measures by taking noise measurements.

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City of Redlands The Grand Project
94 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project t) Maximize the distance between noise-sensitive land uses and new roadway lanes, roadways, rail lines, transit centers, park-and-ride lots, and other new noisegenerating facilities. u) Construct sound reducing barriers between noise sources and noise-sensitive land uses.
v) Stationary noise sources can and should be located as far from adjacent sensitive receptors as possible and they should be muffled and enclosed within temporary sheds, incorporate insulation barriers, or use other measures as determined by the Lead Agency (or other appropriate government agency) to provide equivalent noise reduction.
w) Use techniques such as grade separation, buffer zones, landscaped berms, dense plantings, sound walls, reduced-noise paving materials, and traffic calming measures.
x) Locate transit-related passenger stations, central maintenance facilities, decentralized maintenance facilities, and electric substations away from sensitive receptors to the maximum extent feasible.

Impact NOISE-2: Generation of
excessive groundborne vibration
or groundborne noise levels.

See PMM NOISE-1.

PMM-NOISE-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 reduce substantial adverse effects related to violating air quality standards. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) For projects that require pile driving or other construction techniques that result in excessive vibration, such as blasting, determine the potential vibration impacts to the structural integrity of the adjacent buildings within 50 feet of pile driving locations.
b) For projects that require pile driving or other construction techniques that result in excessive vibration, such as blasting, determine the threshold levels of vibration and cracking that could damage adjacent historic or other structure, and design means and construction methods to not exceed the thresholds. c) For projects where pile driving would be necessary for construction due to geological conditions, utilize quiet pile driving techniques such as predrilling the piles to the maximum feasible depth, where feasible. Predrilling pile holes will reduce the number of blows required to completely seat the pile and will The Project’s impacts would be less than significant as a result of the implementation of regulatory compliance measures.

Nevertheless, the Project substantially conforms to this mitigation measure. The Project is required to comply with regulatory control measures in City of Redlands Municipal Code Section 8.06.120, which regulates noise from
construction activities (e.g., construction activities will occur between the hours of 7:00 a.m. and 6:00 p.m. on weekdays, including Saturdays, with no activities taking place on Sundays or federal holidays. Additionally, procedures and phone numbers would be posted at the construction site for notifying City of Redlands staff, Redlands Police Department, and the construction contractor to notify regarding complaints.

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City of Redlands The Grand Project
95 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project concentrate the pile driving activity closer to the ground where pile driving noise can be shielded more effectively by a noise barrier/curtain. d) Restrict construction activities to permitted hours in accordance with local jurisdiction regulation.
e) Properly maintain construction equipment and outfit construction equipment with the best available noise suppression devices (e.g., mufflers, silences, wraps). f) Prohibit idling of construction equipment for extended periods of time in the vicinity of sensitive receptors.

Impact NOISE-3: 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.

See PMM NOISE-1. No mitigation is required. There are no private or public airstrips within the vicinity of the Project area. The closest airport is the Redlands Municipal Airport, at 1755 Sessums Drive, Redlands, CA, which is approximately 2.45 miles from the Project site. The Project site is outside the noise contours for the airport. As such, the Project would not expose people residing or working in the area to excessive noise levels.

Population and Housing
Impact POP-1: Induce substantial
unplanned population growth to
areas of the region either directly
(e.g., by proposing new homes and
businesses) or indirectly (e.g., by
extending roads and other
infrastructure)
There are no project-level mitigation measures. No mitigation is required. The Project would provide infill development within a currently developed urban setting. It would not add new infrastructure beyond that required to connect the Project to existing utility lines and adjacent roadways. Therefore, the Project would not open new areas to development or promote new development in an area not otherwise expected to be developed.

The Project’s 146 residential units are expected to result in an increase of 205 residents onsite. The Project’s estimated housing, population, and employment growth would be within SCAG’s 2045 growth projections based on the 2020-2045
RTP/SCS and would occur on a Project site located within a HQTA and TPA.

Impact POP-2: Displace
substantial numbers of existing
people or housing, necessitating
PMM-POP-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 the displacement of existing No mitigation is required. The Project site is currently developed with commercial uses and does not contain any existing housing. Therefore, development of the Project would not displace existing people or housing.

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City of Redlands The Grand Project
96 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project the construction of replacement
housing elsewhere.
housing, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Evaluate alternate route alignments and transportation facilities that minimize the displacement of homes and businesses. Use an iterative design and impact analysis where impacts to homes or businesses are involved to minimize the potential of impacts on housing and displacement of people. b) Prioritize the use existing ROWs, wherever feasible. c) Develop a construction schedule that minimizes potential neighborhood deterioration from protracted waiting periods between right-of-way acquisition and construction.
d) Review capacities of available urban infrastructure and augment capacities as needed to accommodate demand in locations where growth is desirable to the local lead Agency and encouraged by the SCS (primarily TPAs, where applicable). e) When General Plans and other local land use regulations are amended or updated, use the most recent growth projections and RHNA allocation plan.

Fire Services
Impact PSF-1: Result in substantial
adverse physical impacts
associated with the provision of
new or physically altered fire
protection facilities, need for new
or physically altered fire
protection facilities, the
construction of which could cause
significant environmental impacts in
order to maintain acceptable
service ratios, response times, or
other performance objectives.

See PMM PSP-1. Mitigation is not required because Project impacts would be less than significant with implementation of regulatory requirements. The Project would be subject to compliance with fire protection design standards per the California Building Code, California Fire Code, Municipal Code, and City of Redlands Fire Department (RFD), to ensure adequate fire protection.

Existing facilities are capable of providing acceptable response times for fire protection and emergency response services. The closest fire station is Station 261 located at 525 East Citrus Avenue, which is approximately 0.6 roadway mile 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 roadway mile from the
Project site. Additionally, the Project would be subject to the existing regulations in the City’s Fire Code related to emergency access and would be required to pay development fees pursuant to the Municipal Code. Therefore, the Project SCEA
City of Redlands The Grand Project
97 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project would not result in new or physically altered government facilities.

Police Services
Impact PSP-1: Result in substantial
adverse physical impacts
associated with the provision of
new or physically altered police
facilities, need for new or
physically altered police facilities,
the construction of which could
cause significant environmental
impacts in order to maintain
acceptable service ratios, response
times, or other performance
objectives.

PMM PSP-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 of constructing new emergency response facilities, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Coordinate with emergency response agencies to ensure that there are adequate governmental facilities to maintain acceptable service ratios, response times or other performance objectives for emergency response services and that any required additional construction of buildings is incorporated into the project description.
b) Where current levels of services at the project site are found to be inadequate, provide fair share contributions towards infrastructure improvements, as appropriate and applicable, to mitigate identified CEQA impacts. c) Project sponsors can and should develop traffic control plans for individual projects. Traffic control plans should include information on lane closures and the anticipated flow of traffic during the construction period. The basic objective of each traffic control plan (TCP) is to permit the contractor to work within the public right of way efficiently and effectively while maintaining a safe, uniform flow of traffic. The construction work and the public traveling through the work zone in vehicles, bicycles or as pedestrians must be given equal consideration when developing a traffic control plan.

The Project’s impacts would be less than significant.

Nevertheless, the Project substantially conforms to this mitigation measures because the Project is not expected to result in a substantial increase in demand for police protection services that would require the need for a new or physically altered police facility to maintain service ratios. In addition, existing facilities are capable of providing acceptable response times and payment of development impact fees are equally effective in minimizing impacts to police service. The Project site is currently served by the Redlands Police Department (RPD). The main police station is located at 1270 West Park Avenue, with four other divisions located citywide, including one at 30 Cajon Street, in close vicinity to the Project site. The Project would incorporate crime prevention features into the design of the buildings and public spaces, such as lighting of entryways and public spaces. The Project would feature the following:
• Security cameras
• Perimeter lighting to supplement the street lighting
and to provide increased visibility and security
Schools
Impact PSS-1: Result in substantial
adverse physical impacts
associated with the provision of
new or physically altered
educational facilities, need for new
or physically altered educational
facilities, the construction of which
could cause significant
environmental impacts in order to
maintain acceptable service ratios,
PMM PSS-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 of constructing new or physically altered school facilities, as applicable and feasible.

Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Where construction or expansion of school facilities is required to meet public school service ratios, require school district fees, as applicable.

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
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98 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project response times, or other
performance objectives.
appropriate school districts at the time building permits are issued; and payment of the adopted fees provides full and complete mitigation of school impacts.

Library Services
Impact PSL-1: Result in substantial
adverse physical impacts
associated with the provision of
new or physically altered library
facilities, need for new or
physically altered library facilities,
the construction of which could
cause significant environmental
impacts in order to maintain
acceptable service ratios, response
times, or other performance
objectives.

PMM PSL-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 of construction of new or altered library facilities, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Where construction or expansion of library facilities is required to meet public library service ratios, require library fees, as appropriate and applicable, to mitigate identified CEQA impacts
The proposed 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 residents, 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. Furthermore, the Applicant would be required to pay Developer Impact Fees to offset any impacts to public services.

Recreation
Impact REC-1: Potential to
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.

PMM REC-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 the use of existing neighborhood and regional parks or other recreational facilities, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Prior to the issuance of permits, where projects require the construction or expansion of recreational facilities or the payment of equivalent Quimby fees, consider increasing the accessibility to natural areas and lands for outdoor recreation from the proposed project area, in coordination with local and regional open space planning and/or responsible management agencies. b) Prior to the issuance of permits, where projects require the construction or expansion of recreational facilities or the payment of equivalent Quimby fees, encourage patterns of urban development and land use which reduce costs on infrastructure and make better use of existing facilities, using strategies such as:
i. Increasing the accessibility to natural areas for outdoor recreation ii. Utilizing “green” development techniques
iii. Promoting water-efficient land use and development No mitigation is required. However, the Project would
substantially conform with PMM REC-1. The Project would provide 22,948 SF of open space and would be compliant
with open space requirements. The Project applicant would be responsible for meeting any park fee requirements pursuant to the Quimby Act and in accordance with Municipal Code Chapter 3.32.

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99 Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project iv. Encouraging multiple uses, such as the joint use of schools v. Including trail systems and trail segments in General Plan recreation standards
Impact REC-2: Result in substantial
adverse physical impacts
associated with the provision of
new or physically altered park
facilities, need for new or
physically altered park facilities,
the construction of which could
cause significant environmental
impacts in order to maintain
acceptable service ratios, or other
performance objectives. Include
recreational facilities or require
the construction or expansion of
recreational facilities which might
have an adverse physical effect on
the environment.

See PMM REC-1, PMM AQ-2, and PMM NOISE-1. No mitigation is required. The Project would provide 22,948 SF of common open space. These recreational amenities
include multiple courtyards, a pool, and a roof deck. Impacts related to construction of these common open space areas are analyzed throughout this SCEA and would not result in an adverse environmental impact. Furthermore, the Applicant would be required to pay Developer Impact Fees to offset any impacts to recreational facilities.

Transportation, Traffic, and Safety
Impact TRA-1: Conflict with a
program, plan, ordinance or policy
addressing the circulation system,
including transit, roadway, bicycle,
and pedestrian facilities.

No mitigation is required. No mitigation is required.

Impact TRA-2: Conflict or be
inconsistent with CEQA Guidelines
section 15064.3(b).

PMM-TRA-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 related to transportation-related impacts. Such measures may include the following or other comparable measures identified by the Lead Agency:
• Transportation demand management (TDM) strategies should be incorporated into individual land use and transportation projects and plans, as part of the planning process. Local agencies should incorporate strategies identified in the Federal Highway Administration’s publication:

Integrating Demand Management into the Transportation Planning Process: A Desk Reference (August 2012) into the planning process (FHWA 2012). For example, the following strategies may be included to No mitigation is required as Project impacts would be less than significant. However, the Project would substantially conform with PMM-TRA-1. Due to the Project’s location in a transit priority area and its size, impacts related to VMT would be less than significant. Additionally, the Project would include d sidewalks along all street frontages. Additionally, the Project would include bike lockers to promote bike use. Furthermore, the Project would provide convenient and direct pedestrian access to the nearby Downtown train station less than onequarter mile to the north.

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project encourage use of transit and non-motorized modes of transportation and reduce vehicle miles traveled on the region’s roadways:
o include TDM mitigation requirements for new developments; o incorporate supporting infrastructure for non-motorized modes, such as, bike lanes, secure bike parking, sidewalks, and crosswalks;
o provide incentives to use alternative modes and reduce driving, such as, universal transit passes, road and parking pricing; o implement parking management programs, such as parking cash-out, priority parking for carpools and vanpools;
o develop TDM-specific performance measures to evaluate project-specific and systemwide performance;
o incorporate TDM performance measures in the decision-making process for identifying transportation investments;
o implement data collection programs for TDM to determine the effectiveness of certain strategies and to measure success over time; and
o set aside funding for TDM initiatives.
o The increase in per capita VMT on facilities experiencing LOS F represents a significant impact compared to existing conditions.

To assess whether implementation of these specific mitigation strategies would result in measurable traffic congestion reductions, implementing actions may need to be further refined within the overall parameters of the proposed Plan and
matched to local conditions in any subsequent project-level environmental analysis.

Impact TRA-3: Substantially
increase hazards due to geometric
design feature (e.g., sharp curves
or dangerous intersections) or
incompatible uses (e.g., farm
equipment).

No mitigation is required. No mitigation is required.

Impact TR-4: Result in inadequate
emergency access.

Impact WF-1: Substantially impair
an adopted emergency response
plan or emergency evacuation
plan
PMM TRA-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 reduce substantial adverse effects which may substantially impair implementation of an adopted emergency response plan or emergency evacuation plan, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:

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 emergency access to the site would be provided by the existing street system, and the Project is designed and would be constructed in accordance with City of Redlands requirements to ensure proper emergency access. In addition, SCEA
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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project • Prior to construction, project implementation agencies can and should ensure that all necessary local and state road and railroad encroachment permits are obtained. The project implementation agency can and should also comply with all applicable conditions of approval. As deemed necessary by the governing jurisdiction, the road encroachment permits may require the contractor to prepare a traffic control plan in accordance with professional engineering standards prior to construction.

Traffic control plans can and should include the following requirements:
o Identification of all roadway locations where special construction techniques (e.g., directional drilling or night construction) would be used to minimize impacts to traffic flow. o Development of circulation and detour plans to minimize impacts to local street circulation. This may include the use of signing and flagging to guide vehicles through and/or around the
construction zone.
o Scheduling of truck trips outside of peak morning and evening commute hours.
o Limiting of lane closures during peak hours to the extent possible. o Usage of haul routes minimizing truck traffic on local roadways to the extent possible.
o Inclusion of detours for bicycles and pedestrians in all areas potentially affected by project construction.
o Installation of traffic control devices as specified in the California Department of Transportation Manual of Traffic Controls for Construction and Maintenance Work Zones.
o Development and implementation of access plans for highly sensitive land uses such as police and fire stations, transit stations, hospitals, and schools. The access plans would be developed with the facility owner or administrator. To minimize disruption of emergency vehicle access, affected jurisdictions can and should be asked to identify detours for emergency vehicles, which will then be posted by the contractor. Notify in advance the facility owner or operator of the timing, location, and duration of construction activities and the locations of detours and lane closures.
o Storage of construction materials only in designated areas. o Coordination with local transit agencies for temporary relocation of routes or bus stops in work zones, as necessary. o Ensure the rapid repair of transportation infrastructure in the event of an emergency through cooperation among public
agencies and by identifying critical infrastructure needs the Applicant will submit a parking and driveway plan for review by the City of Redlands staff and the Redlands Fire Department to ensure compliance with all applicable coderequired site access and circulation requirements as well as code-required emergency access.

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project necessary for: a) emergency responders to enter the region, b) evacuation of affected facilities, and c) restoration of utilities. o Enhance emergency preparedness awareness among public agencies and with the public at large.

Tribal Cultural Resources
Impact TCR-1: Cause a substantial
adverse change in the significance
of a tribal cultural resource
defined in Public Resources Code
section 21074 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), or
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.

See PMM CULT-1.

PMM TCR-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 tribal cultural resources. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Avoidance and preservation of the resources in place, including, but not limited to, planning and construction to avoid the resources and protect the cultural and natural context, or planning greenspace, parks, or other open space, to incorporate the resources with culturally appropriate protection and management criteria
b) Treating the resource with culturally appropriate dignity taking into account the tribal cultural values and meaning of the resource, including, but not limited to, the following: protecting the cultural character and integrity of the resource; protecting the traditional use of the resource; and protecting the confidentiality of the resource;
c) Permanent conservation easements or other interests in real property, with culturally appropriate management criteria for the purposes of preserving or utilizing the resources or places; and protecting the resource.

The Project substantially conforms to this mitigation measure.

In compliance with AB 52 and SB 18 requirements, April 26, 2022, the City sent letters to 23 Native American tribes that may have knowledge regarding tribal cultural resources in the Project vicinity.

The Gabrieleno Band of Mission Indians – Kizh Nation and Agua Caliente Band of Cahuilla Indians requested consultation regarding the proposed Project. Agua Caliente deferred to the Gabrieleno Band of Mission Indians – Kizh Nation The Gabrieleno Band of Mission Indians – Kizh Nation considers the area sensitive for cultural resources. 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 tribe requested inclusion of mitigation due to the potential of the Project to unearth previously undocumented tribal cultural resources during construction.

Mitigation Measures TCR-1 through TCR-3 have been included to require Native American monitoring of excavation and grading activities to avoid potential impacts to tribal cultural resources that may be unearthed by Project construction activities.

Solid Waste
Impact USSW-1: 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.

PMM USSW-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 reduce the generation of solid waste, as applicable and feasible. Such measures may include the following or other comparable measures identified by the Lead Agency:

Integrate green building measures consistent with CALGreen (California Building Code Title 24) into project design including, but not limited to the following:

The Project’s impacts would be less than significant as a result of the implementation of regulatory requirements.

Nevertheless, the Project substantially conforms to this mitigation measure because the Project would comply with Municipal Code Chapter 15.16, which 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 SCEA
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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project Impact USSW-2: Comply with
federal, state, and local
management and reduction
statutes and regulations related to
solid waste.
a) Reuse and minimization of construction and demolition (C&D) debris and diversion of C&D waste from landfills to recycling facilities. b) Inclusion of a waste management plan that promotes maximum C&D diversion. c) Source reduction through (1) use of materials that are more durable and easier to repair and maintain, (2) design to generate less scrap material through dimensional planning, (3) increased recycled content, (4) use of reclaimed materials, and (5) use of structural materials in a dual role as finish material (e.g., stained concrete flooring, unfinished ceilings, etc.).
d) Reuse of existing structure and shell in renovation projects. e) Development of indoor recycling program and space.
f) Discourage the siting of new landfills unless all other waste reduction and prevention actions have been fully explored. If landfill siting or expansion is necessary, site landfills with an adequate landfill-owned, undeveloped land buffer to minimize the potential adverse impacts of the landfill in neighboring communities.
g) Discourage exporting of locally generated waste outside of the SCAG region during the construction and implementation of a project. Encourage disposal within the county where the waste originates as much as possible. Promote green technologies for long-distance transport of waste (e.g., clean engines and clean locomotives or electric rail for waste-by-rail disposal systems) and consistency with SCAQMD and Connect SoCal policies can and should be required. h) Encourage waste reduction goals and practices and look for opportunities for voluntary actions to exceed the 80 percent waste diversion target. i) Encourage the development of local markets for waste prevention, reduction, and recycling practices by supporting recycled content and green procurement policies, as well as other waste prevention, reduction and recycling practices. j) Develop ordinances that promote waste prevention and recycling activities such as: requiring waste prevention and recycling efforts at all large events and venues; implementing recycled content procurement programs; and developing opportunities to divert food waste away from landfills and toward food banks and composting facilities.
k) Develop and site composting, recycling, and conversion technology facilities that have minimum environmental and health impacts.
l) Integrate reuse and recycling into residential industrial, institutional and commercial projects.
percent of operational solid waste. Additionally, the proposed Project would be required comply with 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.

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project m) Provide education and publicity about reducing waste and available recycling services.
n) Implement or expand city or county-wide recycling and composting programs for residents and businesses. This could include extending the types of recycling services offered (e.g., to include food and green waste recycling) and providing public education and publicity about recycling services.

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 City 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 City 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 16,760 gpd of wastewater per day.

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project All new residential development that connects to the system is required to pay its applicable Development Impact Fee(s), as set forth in the General Plan’s “Principles of Managed
Development,”1 and in the City’s resolution establishing development impact fees, Resolution No. 7951, adopted April 2, 2019.2. As such, the Redlands Wastewater Treatment
Facility would have adequate capacity to serve the Project.

Water Supply
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
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 1 City of Redlands General Plan 2035, p. 4-4.
2 City of Redlands Resolution No. 7951, https://cityofredlands.org/sites/main/files/file-attachments/7951.pdf accessed 11-21-19.

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project foreseeable future development
during normal, dry and multiple
dry years.
projected water supply available during normal, single-dry water years as included in the 25-year projection contained in its adopted 2020 Urban Water Management Plan (UWMP)
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 34.3 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 Development Impact Fee(s).

Wildfire
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
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.

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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project 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
− 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.

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.

Impact WF-4: Expose people or
structures to significant risks,
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 SCEA
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Topic 2020-2045 RTP/SCS PEIR Project Level Mitigation Measure Applicability to the Project including downslope or
downstream flooding or landslides,
as a result of runoff, post-fire slope
stability, or drainage changes.
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 wil l 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.
[8:1 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). 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.
110
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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 impact 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 Than 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 Impact 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 to have 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 SCEA
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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 multi-family residential infill project located in a TPA. The Project includes redevelopment 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 HQTA by the 2020-2045 RTP/SCS. The nearest rail station is the Arrow Line Downtown Redlands Station that is located approximately 0.11 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.

Additionally, while the Project would result in the Specific Plan Amendment of the Downtown Specific Plan to increase the maximum building height to four stories, the entirety of the Downtown Specific Plan is located within a TPA. As such, impacts related to aesthetics and the potential increase in height from future residential, mixed-use, commercial, and office developments within the Downtown Specific Plan would not be considered significant effects on the environment pursuant to Public Resources Code Section 21099.

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.

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

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 with a commercial furniture store 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 2022). 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 SP45/TC-H. Therefore, redevelopment 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 fully developed with a commercial furniture store. The Project site and vicinity are void of forest land or timberland. As described previously, the Project site is currently zoned SP45/TC-H 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 ornamental trees that would be replaced by the Project 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 mixed-use area of the City of Redlands and is fully developed with a commercial furniture store. 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.

Existing Plans, Programs, or Policies
None.

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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

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 Grand Air Quality Impact Analysis prepared by Urban Crossroads, June 13, 2022, 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 (SCAB) 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, 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 SCEA
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commercial building and develop 146 luxury apartment units. As further described in Section 14, Population and Housing, the 146 new residences would result in a 0.5 percent increase in the total number of residential units in the city, and a 3.3 percent increase in the number of the multi-family residential units (5+ units) within the city. 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 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 (reactive organic gases (ROG), carbon monoxide (CO), nitrogen oxides (NOx), sulfur oxides (SOx), particulate matter 10 microns in diameter or less (PM10), and particulate matter 2.5 microns in diameter or less (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.

Additionally, approximately 3,200 tons of debris would be crushed onsite. For purposes of analysis, crushing activities would overlap with grading. As such, emissions associated with the crushing operation were added to grading activities. 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. As shown in Table AQ2, CalEEMod results indicate that construction emissions generated by the proposed Project would not exceed SCAQMD regional thresholds with implementation of PPP AQ-1 and PPP AQ-2. 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
2023 2.76 46.90 33.10 0.15 15.19 6.40
2024 2.23 14.20 24.20 0.03 2.61 1.04
2025 n/a n/a n/a n/a n/a n/a
Winter
2023 2.30 15.10 22.30 0.03 2.76 1.12
2024 2.18 14.30 21.40 0.03 2.61 1.04
2025 65.70 19.70 21.40 0.04 3.26 1.44
Maximum Daily Emissions 65.70 46.90 33.10 0.15 15.19 6.40 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
Source: Urban Crossroads, 2022 (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 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.

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Table AQ-3: Project Operational Emissions and Regional Thresholds Source
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Area Source 8.59 3.52 34.20 0.09 2.95 0.57
Energy Source 4.98 2.53 12.50 0.02 0.20 0.21
Mobile Source 0.02 0.41 0.17 < 0.005 0.03 0.03
Total Maximum Daily Emissions 13.59 6.46 46.87 0.11 3.18 0.81 SCAQMD Regional Threshold 55 550 150 150 550 55
Threshold Exceeded? NO NO NO NO NO NO
Winter
Area Source 8.37 3.79 27.90 0.08 2.95 0.57
Energy Source 3.72 2.42 1.03 0.02 0.20 0.20
Mobile Source 0.02 0.41 0.17 < 0.005 0.03 0.03
Total Maximum Daily Emissions 12.11 6.62 29.10 0.10 3.18 0.80 SCAQMD Regional Threshold 55 550 150 150 550 55
Threshold Exceeded? NO NO NO NO NO NO
Source: Urban Crossroads, 2022 (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 distance between the Project site boundary and the closest existing residential structure, located at 321 West State Street is approximately 458 feet (140 meters) southwest of the Project. The nearest industrial/commercial use to the Project site is used to determine construction and operational LST air impacts for emissions of NOX and CO as the averaging periods for these pollutants are shorter (8 hours or less) and it is reasonable to assumed that an individual could be present at these sites for periods of one to 8 hours.

The nearest receptor used for evaluation of localized impacts of NOX and CO is represented by location R5 which represents the Look Dine-In Cinema located at 340 North Eureka Street, approximately 38 feet (12 meters) north of the Project site. 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) SCEA
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to the nearest receptor should use the LSTs for receptors located at 25 meters.” As the existing residence is located 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. 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 Construction
Activity Year Scenario
Emissions (lbs/day)
NOX CO PM10 PM2.5
Demolition 2023
Summer 22.50 18.80 5.04 1.76
Winter 1.23 1.03 0.27 0.10
Maximum Daily Emissions 22.50 18.80 5.04 1.76
SCAQMD Localized Threshold 170 1,174 62 20
Threshold Exceeded? NO NO NO NO
Site
Preparation 2023
Summer 18.40 15.50 8.58 4.37
Winter n/a n/a n/a n/a
Maximum Daily Emissions 18.40 15.50 8.58 4.37
SCAQMD Localized Threshold 153 1,024 59 18
Threshold Exceeded? NO NO NO NO
Grading 2023
Summer 21.50 18.00 9.47 4.67
Winter n/a n/a n/a n/a
Maximum Daily Emissions 21.50 18.00 9.47 4.67
SCAQMD Localized Threshold 170 1,174 62 20
Threshold Exceeded? NO NO NO NO
Source: Urban Crossroads, 2022 (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. According to SCAQMD LST methodology, LSTs would apply to the operational phase of a proposed project, if the project includes stationary sources, or attracts mobile sources that may spend long periods queuing and idling at the site (e.g., transfer facilities and warehouse buildings). The proposed Project does not include such uses, and thus, due to the lack of significant stationary source emissions, no long-term localized significance threshold analysis is needed. As such, impacts from operation of the Project to sensitive receptors would be less than significant.

CO Hot Spot Analysis
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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 parts per million (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 47 new vehicle trips (26 inbound trips and 21 outbound trips) during the weekday AM peak hour. During the weekday PM peak hour, the Project is expected to generate 42 new vehicle trips (18 inbound trips and 24 outbound trips). Over a 24-hour period, the Project is forecast to generate approximately 694 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. 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.

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.

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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 and fully developed with a commercial furniture store and surface parking lot. In its existing condition, the Project site contains ornamental vegetation, including ornamental trees, on the Project site perimeter. The existing trees on Eureka Street and Redlands Boulevard have the potential to provide habitat for nesting migratory birds. Many of these trees would be removed and replaced 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 SCEA
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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 fully developed with a commercial furniture store and associated surface parking lot. According to the National Wetlands Inventory managed by the USFWS, the Project site does not contain riparian habitat (USFWS 2022). 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 2022). 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, offsite areas contain 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?
Less than Significant Impact. Chapter 12.52, Trees and Tree Protection Along Streets and in Public Places, of the Municipal Code regulates trees and tree protection in the City. As part of the Project, multiple trees around the perimeter of the Project site would be removed and replaced with a variety of trees and ornamental landscaping. The Project would be required obtain permits for tree removal and replacement within the Redlands Avenue and Eureka Street public sidewalk. With compliance with Municipal Code Chapter 12.52, Project impacts to public trees would be less than significant.

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 impact would be less than significant.
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.

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, prepared by Material Culture Consulting, May 2022 (MCC 2022), Appendix B; and the Historical Resource Summary for 200 West Redlands Boulevard, Redlands, CA, prepared by Urbana Preservation & Planning, LLC, May 2022 (Urbana 2022), Appendix C.
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 (CRHR) 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, Historic and Scenic Preservation, of the 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.

As described previously, the Project site is currently developed with a commercial retail building that was constructed in 1975. The building has historically operated and currently operates as a furniture storeroom.

Based on the age of the onsite building, a Historical Resource Assessment was prepared for the Project.

Under CRHR Criterion 1, the onsite building represents a commercial development in the City of Redlands during a time of rapid suburban growth following the postwar population boom in California. It is one of many commercial buildings constructed in the area between 1950 and 1980. While the existing building is associated with this period in Redlands’s history, the site lacks sufficient significance to be found eligible under CRHR Criterion 1. The building was not identified as maintaining an association with the lives of persons significant in national, state, or local history, and does not appear eligible under CRHR Criterion 2. The building was constructed in 1975 as a furniture showroom and has not been significantly altered since that time, but the building’s design and construction is very common for the period and does not exhibit any distinguishing features or design elements. Therefore, it is ineligible under CRHR Criterion 3. Additionally, further study of the building is not likely to yield information important in prehistory or history of the local area. It is not eligible under CRHR Criterion 4 (Urbana 2022). Therefore, the Historical Resource Assessment concluded that the property is not eligible for inclusion on the CRHR or eligible for local listing. Therefore, the onsite building does not meet the definition of a historical resource pursuant to CEQA. Thus, impacts related to historic resources 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 Impact with Mitigation Incorporated. In its existing setting, the Project site is fully developed with a commercial furniture store. 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 21 cultural resources have been recorded within one mile of the Project site. One historic-era cultural resource, a portion of the historic Redlands Chinatown, is potentially located subsurface within the Project site.

As described previously, the Project site has been routinely disturbed from various past uses that involve grading, installation of utility infrastructure, and building construction. However, due to the potential presence of the subsurface remains of the historic Redlands Chinatown, the potential for archaeological resources onsite is considered low to moderate. Mitigation Measure CUL-1 has been included to require an Archaeological Testing and Data Recovery Program to ensure the Project would not result in significant SCEA
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impacts to potential subsurface archaeological resources. Mitigation Measure CUL-1 requires retention of an archaeologist that would prepare an Archaeological Testing and Data Recovery Program to be implemented after existing structure are demolished and prior to Project-related ground disturbance. Following development of the Archaeological Testing and Data Recovery Plan, archaeological testing will occur ahead of Project-related ground disturbance to identify the presence, or lack, of archaeological resources within the Project area. Should any potentially significant archaeological deposits be identified during testing efforts, an archaeological data recovery program will be implemented. Additionally, Mitigation Measure CUL-2 requires archaeological monitoring during initial grading and ground disturbance. With implementation of Mitigation Measure CUL-1 and Mitigation Measure CUL-2, 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 Impact. 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, 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 PPP CUL-1, would ensure that impacts to human remains would be less than significant.

Existing Plans, Programs, or Policies
PPP CUL-1: Human Remains. Should human remains be discovered during project construction, the project will be required to comply with State Health and Safety Code Section 7050.5, which states that no further disturbance may occur in the vicinity of the body until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are determined to be prehistoric, the Coroner will notify the Native American Heritage Commission, which will determine the identity of and notify a Most Likely Descendant (MLD). With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD must complete the inspection within 48 hours of notification by the NAHC.

Mitigation Measures
MM CUL-1: Archaeological Testing and Data Recovery Plan. Prior to approval of any grading permit, the Project Applicant shall retain a qualified archaeologist to prepare an Archaeological Testing and Data Recovery Program. The Archaeological Testing and Data Recovery Program shall be implemented after existing onsite buildings are demolished and prior to ground disturbance and grading. The Archaeological Testing and Data Recovery Program shall include, at minimum, the following procedures:
• Development of an Archaeological Testing and Data Recovery Plan, which shall include:
o Background research and anticipated resource types
o Research questions that can be addressed by the collection of data from the defined resource types
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o Field methods and procedures
o Cataloging and laboratory analysis
o Findings and interpretation
• Following the development of the Archaeological Testing and Data Recovery Plan, the Archaeological Testing and Data Recovery Plan shall be provided to the City of Redlands Development Services Director for review and approval. Archaeological testing shall occur, with oversight by the qualified archaeologist, ahead of Projectrelated ground disturbance to identify the presence of archaeological resources within the Project area.
• If no significant archaeological deposits are encountered during testing efforts, Projectrelated ground disturbance may continue. Archaeological monitoring shall occur during all Project-related ground disturbance, as stipulated in MM CUL-2. A final Archaeological Monitoring Report shall be prepared upon completion of ground disturbance.
• Should potentially significant archaeological deposits be identified during testing efforts, archaeological data recovery shall be implemented by the Project archaeologist. Any excavation and recovery of identified resources shall be performed using standard archaeological techniques and the requirements stipulated in the Archaeological Testing and Data Recovery Plan. Any excavations, testing, and/or recovery of resources shall be conducted by a qualified archaeologist. Following the completion of data recovery Project-related ground disturbance may continue.

Archaeological monitoring shall occur during all Project-related ground disturbance, as stipulated in MM CUL-2. A final Archaeological Monitoring Report shall be prepared upon completion of ground disturbance.

MM CUL-2: 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.

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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 Grand Energy Analysis, prepared by Urban Crossroads, June 13, 2022, included as Appendix D.
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 multi-family development and the associated infrastructure is not expected to result in demand for fuel on a per-unit-of-development basis greater than other development projects in Southern California. Table E-1 details the construction fuel usage over the Project’s 20-month construction period. The Project would use approximately 78,863 kilowatt-hours (kWh) of electricity during construction. As shown in Table E-1, Project construction would require the consumption of 43,893 gallons of diesel fuel.

Table E-1: Construction Equipment Fuel Consumption Estimates Construction
Activity
Duration
(Days) Equipment HP Rating Quantity Usage Hours
Load
Factor
HPhrs/dayTotal Fuel
Consumption
Demolition 20
Concrete/Industrial Saws 33 1 8 1 193 21
Crawler Tractors 87 3 8 0 898 97
Rubber Tired Dozers 367 1 8 0 1,174 127
Site
Preparation 2
Crawler Tractors 87 1 8 0 299 32
Graders 148 1 8 0 485 52
Rubber Tired Dozers 367 1 8 0 1,174 127
Grading 4 Crawler Tractors 87 2 8 0 599 129
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Graders 148 1 8 0 485 105
Rubber Tired Dozers 367 1 8 0 1,174 254
Building
Construction 420
Cranes 367 1 8 0 851 19,330
Crawler Tractors 87 1 8 0 299 6,794
Forklifts 82 1 8 0 131 2,979
Generator Sets 14 1 8 1 83 1,882
Welders 46 3 8 0 497 11,279
Paving 10
Cement and Mortar Mixers 10 1 8 1 45 24
Crawler Tractors 87 1 8 0 299 162
Pavers 81 1 8 0 272 147
Paving Equipment 89 1 8 0 256 139
Rollers 36 1 8 0 109 59
Architectural
Coating
20 Air Compressors 37 1 8 0 142 154
CONSTRUCTION FUEL DEMAND (GALLONS DIESEL FUEL) 43,893
Source: Urban Crossroads, 2022 (Appendix D)
Table E-2 shows the energy consumption for construction worker light-duty auto (LDA) vehicles and lightduty-trucks (LDT). As shown, construction worker trips would consume 39,147 gallons of gasoline.

Table E-2: Construction Worker Fuel Consumption Estimates Year Construction Activity Duration
(Days)
Worker
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy (mpg)
Estimated Fuel
Consumption
(gallons)
2023
LDA
Demolition 20 7 14.7 2,058 30.68 67
Site Preparation 2 4 18.5 148 30.68 5
Grading 4 5 18.5 370 30.68 12
Building Construction 126 68 18.5 158,508 30.68 5,166
LDT1
Demolition 20 4 14.7 1,176 24.14 49
Site Preparation 2 2 18.5 74 24.14 3
Grading 4 3 18.5 222 24.14 9
Building Construction 126 34 18.5 79,254 24.14 3,283
LDT2
Demolition 20 4 14.7 1,176 23.82 49
Site Preparation 2 2 18.5 74 23.82 3
Grading 4 3 18.5 222 23.82 9
Building Construction 126 34 18.5 79,254 23.82 3,327
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Year Construction Activity Duration
(Days)
Worker
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy (mpg)
Estimated Fuel
Consumption
(gallons)
2024
LDA
Building Construction 262 68 18.5 329,596 31.57 10,439
LDT1
Building Construction 262 34 18.5 164,798 24.59 6,701
LDT2
Building Construction 262 34 18.5 164,798 24.51 6,725
LDA
Building Construction 32 68 18.5 40,256 32.57 1,236
Paving 10 7 18.5 1,295 32.57 40
Architectural Coating 20 14 18.5 5,180 32.57 159
LDT1
Building Construction 32 34 18.5 20,128 25.11 801
Paving 10 4 18.5 740 25.11 29
Architectural Coating 20 7 18.5 2,590 25.11 103
LDT2
Building Construction 32 34 18.5 20,128 25.24 798
Paving 10 4 18.5 740 25.24 29
Architectural Coating 20 7 18.5 2,590 25.24 103
TOTAL CONSTRUCTION WORKER FUEL CONSUMPTION 39,147
Source: Urban Crossroads, 2022 (Appendix D)
Table E-3 shows 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. As shown, construction vendor and hauling would consume 17,248 gallons of fuel.

Table E-3: Construction Vendor & Hauling Fuel Consumption Estimates Year Construction Activity Duration
(Days)
Vendor/
Hauling
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy (mpg)
Estimated Fuel
Consumption
(gallons)
2023
MHDT
Demolition 20 1 6.9 138 8.30 17
Site Preparation 2 1 10.2 20 8.30 2
Grading 4 1 10.2 41 8.30 5
Building Construction 126 13 10.2 16,708 8.30 2,014
HHDT (Vendor)
Demolition 20 1 6.9 138 5.94 23
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Site Preparation 2 1 10.2 20 5.94 3
Grading 4 1 10.2 41 5.94 7
Building Construction 126 13 10.2 16,708 5.94 2,812
HHDT (Hauling)
Demolition 20 4 20 1,600 5.94 269
Grading 4 72 20 5,760 5.94 970
2024
MHDT
Building Construction 262 13 10.2 34,741 8.34 4,165
HHDT (Vendor)
Building Construction 262 13 10.2 34,741 6.03 5,766
2025
MHDT
Building Construction 32 13 10.2 4,243 8.43 503
HHDT (Vendor)
Building Construction 32 13 10.2 4,243 6.13 692
TOTAL CONSTRUCTION VENDOR/HAULING FUEL CONSUMPTION 17,248 Source: Urban Crossroads, 2021 (Appendix D)
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-4, vehicles and trucks traveling to and from the operational Project site would consume 152,474 gallons of fuel.

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Table E-4: Total Project-generated Traffic Annual Fuel Consumption Vehicle Type Average Vehicle Fuel
Economy (mpg) Annual VMT Estimated Annual Fuel Consumption (gallons) LDA 32.57 1,843,785 56,615
LDT1 25.11 149,130 5,938
LDT2 25.24 751,521 29,777
MDV 20.54 566,367 27,572
LHDT1 16.22 106,228 6,551
LHDT2 15.27 28,874 1,891
MHDT 8.43 63,768 7,562
HHDT 6.13 64,704 10,555
OBUS 6.20 2,275 367
UBUS 4.86 1,157 238
MCY 42.15 77,592 1,841
SBUS 6.44 4,025 625
MH 5.77 16,977 2,941
TOTAL ANNUAL FUEL CONSUMPTION 3,676,403 152,474
MDV = Medium Duty Trucks; LHDT1 = Light-Duty Trucks (Vehicles under the LHDT1 category have a GVWR of 8,501 to 10,000 lbs.); LHDT2 = Light-Duty Trucks (Vehicles under the LHDT2 category have a GVWR of 10,001 to 14,000 lbs.); OBUS = Other Buses; UBUS = Urban Buses; MCY = Motorcycle; SBUS = School Bus; MH = Motorhome Source: Urban Crossroads, 2022 (Appendix D)
As shown in Table E-5, the Project would result in an annual natural gas demand of 1,611,428 thousand British thermal units (kBTU) of natural gas, and approximately 630,160 kWh of electricity.

Table E-5: Project Annual Operational Energy Demand Summary Land Use Natural Gas Demand
(kBTU/year)
Electricity Demand
(kWh/year)
Apartments Mid Rise 1,611,428 630,160
Enclosed Parking with Elevator 0 0
Other Asphalt Surfaces 0 0
TOTAL PROJECT ENERGY DEMAND 1,611,428 630,160
Source: Urban Crossroads, 2022 (Appendix D)
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 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 SCEA
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renewable energy and energy efficiency, including the implementation of solar energy. 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 be less than significant.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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The discussion below is based on the Report of Geotechnical Investigations, prepared by Soils Southwest, Inc, May 30, 2022 (Soils 2022) included as Appendix E and the Cultural and Paleontological Resources Assessment for The Grand Residential Project, prepared by Material Culture Consulting, May 2022 (MCC 2022) 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. According to the Geotechnical Report, 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 (Soils 2022). 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 Municipal Code Chapter 15.04, California Building Code. 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 SCEA
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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, Liquefaction, 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 Investigation, historic groundwater levels are at least 50 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, Liquefaction and Landslides, 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 commercial building, stand-alone commercial building, parking lots, and ornamental vegetation. The Project would involve the demolition of the existing commercial uses and construction of a multi-family residential 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 Investigation for the proposed Project, the depth of groundwater is anticipated to be at a depth of 50 feet or greater, therefore, the potential for liquefaction to occur is low to non-existent (Soils, 2022). 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.

According to the Geotechnical Investigation, near grade soils are considered collapsible in nature (Soils, 2022). With implementation of the requirements of the CBC, included as PPP GEO-1, the potential for settlement or collapse of soils is considered low. 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 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 Geotechnical Investigation found that the site soils have a very low expansion potential and 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 since the proposed Project would connect to existing public wastewater infrastructure.

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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 Impact 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 Holocene-age very young wash deposits (Qw), old alluvial-fan 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 five 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.

Existing Plans, Programs, or Policies
PPP GEO-1: California Building Code. The Project is required to comply with the California Building Code (CBC) as included in the City’s Municipal Code Chapter 15.04 to preclude significant adverse effects associated with seismic hazards. CBC 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
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 qualified professional paleontologist pursuant to the 2010 Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources by the Society for Vertebrate Paleontology (SRV), stating that the paleontologist has been retained to SCEA
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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 pursuant to the 2010 Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources by the SRV 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 Grand Greenhouse Gas Analysis, prepared by Urban Crossroads, June 13, 2022, included as Appendix F.

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 hexafluoride1F0F

3. 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 kWh energy usage of the dwelling2F1F

4. 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), which was adopted December 5, 2017, however the CAP does not itself establish a numeric threshold of significance for determining impacts with respect to GHG emissions. Notwithstanding, the City has utilized a screening threshold of 3,000 metric tons of carbon dioxide equivalent (MTCO2e) per year to determine if a potential GHG related impact would 3 Section 38505(g), Health and Safety Code; and Section 21083.05, Public Resources Code 4 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 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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occur from a project. This approach is a widely accepted screening threshold used by the City of Redlands and numerous agencies in the SCAB.

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 1,643.84 MT CO2e/yr as summarized in Table GHG-1. This would be below the 3,000 MTCO2e 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 R Total CO2e
Annual construction-related emissions
amortized over 30 years 33.10 1.67E-03 1.33E-03 0.03 33.67 Mobile Source 1,337.00 0.06 0.06 22.29 1,360.00
Area Source 38.80 <0.005 <0.005 - 38.90
Energy Source 185.00 0.02 <0.005 - 186.00
Water Usage 8.48 0.20 <0.005 - 14.90
Waste 2.91 0.29 0.00 - 10.20
Refrigerants - - - 0.17 0.17
Total CO2e (All Sources) 1,643.84
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b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less than Significant Impact. The Project’s consistency with SB 32 (2017 Scoping Plan) and the City’s CAP are described below.

SB 32/2017 Scoping Plan Consistency. The 2017 Scoping Plan Update reflects the 2030 target of a 40 percent reduction below 1990 levels, set by Executive Order B-30-15 and codified by SB 32. As summarized in Table GHG-2, the Project will not conflict with any of the provisions of the Scoping Plan and in fact supports seven of the action categories.

Table GHG-2: 2017 Scoping Plan Consistency Summary
Action Responsible Parties Consistency
Implement SB 350 by 2030
Increase the Renewables Portfolio Standard
to 50% of retail sales by 2030 and ensure
grid reliability.

CPUC, CEC,
CARB
Consistent. This measure is not directly
applicable to development projects, but the
proposed Project would use energy from
Southern California Edison (SCE), which has
committed to diversify its portfolio of
energy sources by increasing energy from
wind and solar sources.

Establish annual targets for statewide
energy efficiency savings and demand
reduction that will achieve a cumulative
doubling of statewide energy efficiency
savings in electricity and natural gas end
uses by 2030.

Consistent. The Project would be
constructed in compliance with current
California Building Code requirements.

Specifically, new buildings must achieve
compliance with the current Building and
Energy Efficiency Standards and the current
California Green Building Standards
requirements. The proposed Project includes
energy efficient field lighting and fixtures
that meet the current Title 24 Standards
throughout the Project Site and would be a
modern development with energy efficient
boilers, heaters, and air conditioning
systems.

Reduce GHG emissions in the electricity
sector through the implementation of the
above measures and other actions as
modeled in Integrated Resource Planning
(IRP) to meet GHG emissions reductions
planning targets in the IRP process. Loadserving entities and publicly- owned utilities meet GHG emissions reductions planning
targets through a combination of measures
as described in IRPs.

Implement Mobile Source Strategy (Cleaner Technology and Fuels) At least 1.5 million zero emission and plug-in
hybrid light-duty electric vehicles by 2025.

CARB, California
State Transportation
Agency (CalSTA),
Strategic Growth
Council (SGC),
California
Department of
Transportation
(Caltrans), CEC,
OPR, Local Agencies
Consistent. These are CARB enforced
standards; vehicles that access the Project
that comply with the standards will comply
with the strategy.

At least 4.2 million zero emission and plug-in
hybrid light-duty electric vehicles by 2030.

Consistent. These are CARB enforced
standards; vehicles that access the Project
that comply with the standards will comply
with the strategy.

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Action Responsible Parties Consistency
Further increase GHG stringency on all lightduty vehicles beyond existing Advanced Clean cars regulations.

Consistent. These are CARB enforced
standards; vehicles that access the Project
that comply with the standards will comply
with the strategy
Medium- and Heavy-Duty GHG Phase 2.

Consistent. These are CARB enforced
standards; vehicles that access the Project
that comply with the standards will comply
with the strategy
Innovative Clean Transit: Transition to a suite
of to-be-determined innovative clean transit
options. Assumed 20% of new urban buses
purchased beginning in 2018 will be zero
emission buses with the penetration of zeroemission technology ramped up to 100% of new sales in 2030. Also, new natural gas
buses, starting in 2018, and diesel buses,
starting in 2020, meet the optional heavyduty low-NOX standard.

Not applicable. This measure is not within
the purview of this Project.

Last Mile Delivery: New regulation that would
result in the use of low NOX or cleaner
engines and the deployment of increasing
numbers of zero-emission trucks primarily for
class 3-7 last mile delivery trucks in
California. This measure assumes ZEVs
comprise 2.5% of new Class 3–7 truck sales
in local fleets starting in 2020, increasing to
10% in 2025 and remaining flat through
2030.

Not applicable. This Project is not
responsible for implementation of SB 375
and would therefore not conflict with this
measure.

Further reduce vehicle miles traveled (VMT)
through continued implementation of SB 375
and regional Sustainable Communities
Strategies; forthcoming statewide
implementation of SB 743; and potential
additional VMT reduction strategies not
specified in the Mobile Source Strategy but
included in the document “Potential VMT
Reduction Strategies for Discussion.”
Not applicable. This Project is not
responsible for implementation of SB 375
and would therefore not conflict with this
measure.

Increase stringency of SB 375 Sustainable
Communities Strategy (2035 targets). CARB
Not applicable. The Project is not within the
purview of SB 375 and would therefore
not conflict with this measure.

By 2019, adjust performance measures used to select and design transportation facilities Harmonize project performance with
emissions reductions and increase
competitiveness of transit and active
transportation modes (e.g. via guideline
documents, funding programs, project
selection, etc.).

CalSTA, SGC, OPR,
CARB, Governor’s
Office of Business
and Economic
Development (GOBiz), California
Infrastructure and
Economic
Development Bank
(IBank), Department
of Finance (DOF),
Not applicable. Although this is directed
towards CARB and Caltrans, the proposed
Project would be designed to promote and
support pedestrian activity on-site and in the
Project area by providing pedestrian access
from the Project site to nearby commercial
uses.

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Action Responsible Parties Consistency
California
Transportation
Commission (CTC),
Caltrans
By 2019, develop pricing policies to support
low-GHG transportation (e.g. low-emission
vehicle zones for heavy duty, road user,
parking pricing, transit discounts).

CalSTA, Caltrans,

CTC, OPR, SGC,
CARB
Not applicable. This Project is not
responsible for developing pricing policies
to support low-GHG transportation.

Implement California Sustainable Freight Action Plan
Improve freight system efficiency.

CalSTA, CalEPA,

CNRA, CARB,
Caltrans, CEC,
GO-Biz
When adopted, this measure would apply
to all trucks accessing the Project site, this
may include existing trucks or new trucks that
are part of the statewide goods movement
sector.

Deploy over 100,000 freight vehicles and
equipment capable of zero emission
operation and maximize both zero and nearzero emission freight vehicles and equipment powered by renewable energy by 2030.

Not applicable. This measure is not within
the purview of this Project.

Adopt a Low Carbon Fuel Standard with a
Carbon Intensity reduction of 18%. CARB
LCFS, with an increased stringency (18% by
2030). When adopted, this measure would
apply to all fuel purchased and used by the
Project in the state.

Implement the Short-Lived Climate Pollutant Strategy by 2030 40% reduction in methane and
hydrofluorocarbon emissions below 2013
levels. CARB,
CalRecycle,
CDFA,
SWRCB,
Local Air Districts
When adopted, the Project would be
required to comply with this measure and
reduce SLPS accordingly.
50% reduction in black carbon emissions
below 2013 levels.

Not applicable. This measure is not within
the purview of this Project.

By 2019, develop regulations and programs
to support organic waste landfill reduction
goals in the SLCP and SB 1383.

CARB, CalRecycle,

CDFA SWRCB,
Local Air Districts
Not applicable. This measure is not within
the purview of this Project.

Implement the post-2020 Cap-and-Trade
Program with declining annual caps. CARB
When adopted, the Project would be
required to comply with the Cap-and-Trade
Program if it generates emissions from
sectors covered by Cap-and-Trade.

By 2018, develop Integrated Natural and Working Lands Implementation Plan to secure California’s land base as a net carbon sink
Protect land from conversion through
conservation easements and other incentives.

CNRA, Departments
Within CDFA,
CalEPA, CARB
Not applicable. This measure is not within
the purview of this Project.

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Action Responsible Parties Consistency
Increase the long-term resilience of carbon
storage in the land base and enhance
sequestration capacity
Not applicable. This measure is not within
the purview of this Project.

Utilize wood and agricultural products to
increase the amount of carbon stored in the
natural and built environments
Not applicable. This measure is not within
the purview of this Project.

Establish scenario projections to serve as the
foundation for the Implementation Plan
Not applicable. This measure is not within
the purview of this Project.

Establish a carbon accounting framework for
natural and working lands as described in
SB 859 by 2018
CARB Not applicable. This measure is not within
the purview of this Project.

Implement Forest Carbon Plan
CNRA, California
Department of
Forestry and Fire
Protection (CAL
FIRE), CalEPA and
Departments Within
Not applicable. This measure is not within
the purview of this Project.

Identify and expand funding and financing
mechanisms to support GHG reductions
across all sectors.

State Agencies &
Local Agencies
Not applicable. This measure is not within
the purview of this Project.

Consistency with the Redlands CAP. The City of Redlands adopted its CAP in December 2017. The CAP did not identify any required measure to achieve the 2030 emission targets. However, the CAP did recommend several measures that would achieve GHG reductions including providing solar photovoltaic systems, increasing energy efficiency 5 percent over 2016 standards, and using high efficiency lighting, and reducing GHG emissions associated with water delivery and treatment by 10 percent In support of these measures the Project would increase energy efficiency approximately 30 percent over 2016 standards primarily through high efficiency of lighting. Additionally, the Project would comply with CALGreen indoor water requirements, which represent a 20 percent reduction in water use, and the Redlands’s Model Water Efficient Landscape Ordinance (MWELO), which would reduce outdoor water use. Thus, the Project would not obstruct the City of Redlands CAP GHG reduction and would therefore have a less than significant impact.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
None.

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The discussion below is based on the Phase I Environmental Site Assessment, prepared by Force Environmental, November 13, 2015, included as Appendix G. 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 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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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 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 146 multi-family residential units. Residential uses typically do not present a hazard associated with the accidental release of hazardous substances into the environment because residents 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 building. 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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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 and associated recreational 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.
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 multi-family residential 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 0.54- mile from the Project site, and Redlands High School located at 840 E. Citrus Avenue, which is 0.7-mile from the Project site. As such, the Project site is not located within one-quarter mile of any existing or proposed SCEA
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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 2022). Additionally, according to the State Water Resource Control Board’s Geotracker database, the Project site is not located on a Leaking UST Cleanup Site, Cleanup Program Site, Military Cleanup Site, Military Privitized Site, or Military UST site (SWRCB 2022). 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. The nearest airport to the Project site is Redlands Municipal Airport, approximately 2.45 miles to the southwest. 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 multifamily residential development would be a maximum of four stories and approximately 55 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.

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 full closure of Eureka Street, Third Street, or Redlands Boulevard. 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 Eureka Street and Third Street.

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. Additionally, the SCEA
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drive aisles would be a minimum of 20-feet-wide, which would ensure adequate spacing for 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, Fire Code. 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 Redlands Boulevard to the south, Third Street to the east, Eureka Street to the west, and a commercial use to the north. 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 2022). 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.

Existing Plans, Programs, or Policies
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 Hicks & Hartwick, Inc., July 2019 (Hicks 2019), included as Appendix H. 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 the existing commercial building, pavement, infrastructure, and construction of a multi-family residential 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 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 HYD-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, 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 postconstruction (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 drywell 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 additional types of BMPs that would be implemented as part of the proposed project are listed in Table HYD-1.

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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 drywell system.

Use pervious surfaces: Planter boxes are incorporated into the Project design to increase the amount of pervious area and onsite retention of stormflows.

Source
Control
Storm Drain Stenciling: All inlets/catch basins would be stenciled with the words “No Dumping – Drains to River,” 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 drywell system 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 H) 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 Hill Subbasin and Yucaipa Subbasin (UWMP 2020). As of 2020, the groundwater from Bunker Hill totals

48.4 percent and the groundwater from Yucaipa Subbasin totals 1.1 percent of the City’s annual water production. Water pumping from the Bunker Hill Subbasin is adjudicated, which limits the allowable SCEA
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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 63,074.48 square feet of impervious surfaces on the Project site. However, the Project would install an onsite storm drain system that would convey runoff to a drywell system within the parking area. In addition, the Project includes areas of landscaping that would infiltrate stormwater onsite. Stormwater capture would be compliant with the Design Capture Volume (DCV) requirements of the San Bernardino County Stormwater Program through the implementation of infiltration and biotreatment. 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 HYD-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 planter boxes or to an underground drywell system that would capture and filter runoff. 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 5,799 cubic feet of stormwater, DMA 2 has been designed to accommodate 390 cubic feet of stormwater (Hicks, 2019). Additional stormwater capture and treatment methods such as biotreatment 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 HYD-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 related to the provision of substantial additional sources of polluted runoff would be less than significant, and no mitigation is required.

The Project would install new storm drain lines throughout the site. Additionally, the Project would install multiple planter boxes for stormwater infiltration and an underground drywell system within the parking SCEA
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area. 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 the applicable Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) Flood Map, 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 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. The proposed Project would construct living areas 3 feet above the existing grade level in order to comply with Municipal Code Chapter 15.32. 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 the FEMA FIRM, 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 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 fully developed, and the proposed Project would result in an increase of impervious surfaces. 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 the onsite underground drywell system 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 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.

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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 impacts would be less than significant.

Existing Plans, Programs, or Policies
PPP HYD-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, Storm Drains. 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 HYD-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, Storm Drains, 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 a commercial building and parking lot within an urbanized portion of the city surrounded by commercial, public institution, and residential uses. The proposed Project consists of infill development and would develop the site to provide a multi-family residential development with 146 multi-family dwelling units, recreational areas, and associated parking. The Project would not physically divide an established community and would 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. The documents regulating land use for the Project site and immediate vicinity are the City’s General Plan and the Downtown Specific Plan. The proposed Project’s relationship to these planning documents is described below.

Downtown Specific Plan. The Project site has a Specific Plan designation of SP45/TC-H, which allows for development at up to a 2.0 FAR maximum and has a maximum building height limit of 55 feet. The Project would include a Specific Plan Amendment of the Downtown Specific Plan to increase maximum building height to four stories. The Downtown Specific Plan does not have the purpose of avoiding or mitigating an environmental effect.

General Plan. The Project site has a General Plan designation on Commercial. 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 multi-family development with a FAR of 2.0. The Commercial designation allows for residential development, which the Project would be consistent with.

Table LU-1: General Plan Consistency
General Plan Policies Project Consistency
Distinctive City
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,
Consistent. The Project would develop the
underutilized, infill site with a multi-family
development. Project development includes design
features to ensure sensitivity to surrounding historical architecture.

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professional services, and offices that meet the
community’s needs. Build a sense of community in
these commercial areas.
2-A.10 Permit densities, design, and uses that will
help preserve the character and amenities of
existing neighborhoods.

Consistent. The Project would develop the
underutilized, infill site with a multi-family residential development. The Project would result in a residential
density of 98.7 du/ac. 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.
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 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 structure 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 Project site is currently developed with a commercial retail building that was constructed in
1975. The building has historically operated and
currently operates as a furniture storeroom. Based on
the age of the onsite building, a Historical Resource
Assessment was prepared for the Project. Under CRHR
Criterion 1, the onsite building represents a
commercial development in the City of Redlands
during a time of rapid suburban growth following the
postwar population boom in California. It is one of
many commercial buildings constructed in the area
between 1950 and 1980. While the existing building
is associated with this period in Redlands’s history, the site lacks sufficient significance to be found eligible under CRHR Criterion 1. The building was not
identified as maintaining an association with the lives of persons significant in national, state, or local history, and does not appear eligible under CRHR Criterion 2.

The building was constructed in 1975 as a furniture
showroom and has not been significantly altered since
that time, but the building’s design and construction is very common for the period and does not exhibit any
distinguishing features or design elements. Therefore,
it is ineligible under CRHR Criterion 3. Additionally,
further study of the building is not likely to yield
information important in prehistory or history of the
local area. It is not eligible under CRHR Criterion 4
(Urbana 2022). Therefore, the Historical Resource
Assessment concluded that the property is not eligible
for inclusion on the CRHR or eligible for local listing.

Therefore, the onsite building does not meet the
definition of a historical resource pursuant to CEQA.

Thus, impacts related to historic resources would be
less than significant.
2-A.35 Establish standards for the evaluation of
exterior lighting for new development and
redevelopment to ensure that exterior lighting
Consistent. The proposed Project would include
exterior lighting in the public open space and
surrounding the Project building. All exterior lighting SCEA
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(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.
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. 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
potential presence of the subsurface remains of the
historic Redlands Chinatown, the potential for
archaeological resources onsite is considered low to
moderate. However, Mitigation Measure CUL-1 has
been included to require an Archaeological Testing
and Data Recovery Program to ensure the Project
would not result in significant impacts to potential
subsurface archaeological resources.

Mitigation Measure CUL-1 requires retention of an
archaeologist that would prepare an Archaeological
Testing and Data Recovery Program to be
implemented after existing structure are demolished
and prior to Project-related ground disturbance.

Following development of the Archaeological Testing
and Data Recovery Plan, archaeological testing will
occur ahead of Project-related ground disturbance to
identify the presence, or lack, of archaeological
resources within the Project area. Should any
potentially significant archaeological deposits be
identified during testing efforts, an archaeological
data recovery program will be implemented.

Additionally, Mitigation Measure CUL-2 requires
archaeological monitoring during initial grading and
ground disturbance. With implementation of
Mitigation Measure CUL-1 and Mitigation Measure
CUL-2, impacts related to archaeological resources
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.
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 April 26 2022, 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
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yielded positive results for known tribal cultural
resources or sacred lands within a 1-mile radius of the Project site. The Gabrieleno Band of Mission Indians –
Kizh Nation and Agua Caliente Band of Cahuilla
Indians requested consultation regarding the
proposed Project. Agua Caliente deferred to the
Gabrieleno Band of Mission Indians – Kizh Nation The
Gabrieleno Band of Mission Indians – Kizh Nation
considers the area sensitive for cultural resources.

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 tribe requested inclusion of mitigation
due to the potential of the Project to unearth
previously undocumented tribal cultural resources
during construction.

Mitigation Measures TCR-1 through TCR-3 have been
included to require 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 consist of younger and older surficial deposits, more specifically
Holocene-age very young wash deposits (Qw), old
alluvial-fan 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:
• 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.

Prosperous Economy
3-A.37 Ensure adequate parking Downtown and
efficiency in traffic flow to enable the continued
revitalization of the commercial core
Consistent. The Project would include a parking
garage for resident with approximately 183 parking
spaces.

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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 develop an
underutilized site within Downtown and would not
affect any agricultural land within the City as the
existing Project site is developed with a commercial
furniture store.
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.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 146
multi-family dwelling units located Downtown which
would be accessible to transit.
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.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 develop an underutilized site
with multi-family dwelling units and amenity areas.
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 develop an underutilized
site with a multi-family development that would be
similar to the surrounding uses.
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 to facilitate pedestrian
accessibility to and from the Project site. The Project would undergo City review which would ensure
appropriate emergency vehicle access and circulation
is provided.
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, Consistent. The proposed Project include two ingressegress driveways, one along Eureka Street and one along Third Street. The Project would undergo City
review to ensure adequate emergency access is
provided throughout the Project site.

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adequate turning radius, and other requirements
per the California Fire Code.
5-A.68 Provide for direct pedestrian paths and
access from new developments to the nearest public
transportation stop.

Consistent. Omnitrans Routes 8 and 19 have stops
within 100 feet from the Project site on Redlands
Boulevard. New sidewalks would be provided along
Eureka Street, Redlands Boulevard, and Third Street
which would provide access to the bus stop and
connect to existing sidewalks.
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, a parking
garage would be provided for residents with 183
spaces, which would be adequate for residents and
guests.
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. Pursuant to City of Redlands
Ordinance No. 2930, the Project would require 146
parking spaces. The Project would include 183
parking spaces onsite and 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 H.
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 H. The
hydrology report ensures that post-development peak
stormwater runoff discharge rates would not exceed
the estimated pre-development rates.

Healthy Community
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, the building would be designed
to be above the flood line in order to minimize impacts related to flooding. Living areas would be raised
three feet above the current site grade to limit
flooding impacts.
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, California Building
Code, of the City’s Municipal Code.

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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 E. 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 E. The geotechnical report
addresses geologic concerns on the site and provides
recommendations for Project grading and construction.
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
site with a multi-family residential development. As
discussed in Section 6.3.9, Hazards, the Project site
does not contain any contaminated soils.
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 develop 146
multi-family residential units. The proposed Project
would not emit hazardous air emissions or handle
extremely hazardous substances. In addition, the
closest schools are McKinley Elementary School,
located approximately 0.55 miles south of the Project
site, and Redlands High School, located
approximately 0.63 miles southeast 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 I. 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
Consistent. As mentioned above, a noise study was
prepared for the proposed Project included as
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noise exposure would be other than “clearly” or
“normally compatible” as specified in Table 7-10
Appendix I. 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.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 multifamily residential development would not exceed operational Air Quality or GHG thresholds and 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.

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8-A.9 Encourage the use of construction, roofing
materials, and paving surfaces with solar
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.

Consistent. As discussed above, the Project would
comply with the California Green Building Standards
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., California Green Building Standards
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Code, and 15.04, California Building Code, of the
Municipal Code.

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, Mineral Resources, of the City’s General Plan, the Project site is located within MRZ3. 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 a commercial building and paved parking lot. 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.

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, June 13, 2022, included as Appendix I.

Noise Element of the General Plan
The City’s General Plan Noise Element 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, Exterior Noise Limits, and Section 8.06.080, Interior Noise Standards, of the 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
Source: City of Redlands’s Municipal Code Sections 8.06.070 and 8.06.080 SCEA
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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, Exemptions, of the 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 I), to identify the existing ambient noise level environment, 24-hour noise level measurements were taken at four 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 Daytime Nighttime
L1 Located northwest of the Project site near singlefamily residence at 509 Lawton Street. 63.7 56.4 L2
Located northeast of the Project site near Historic
Redlands Train Station at 383-389 Orange
Street.

70.4 63.9
L3 Located south of the Project site near single-family residence at 124 West Vine Street. 59.9 60.1
L4 Located southwest of the Project site near singlefamily residence at 321 West State Street. 50.9 48.1 1 See Exhibit N-1 for the noise level measurement locations. 2 Energy (logarithmic) average levels. The long-term 24-hour measurement worksheets are included in Appendix I. "Daytime" = 7:00 a.m. to 10:00 p.m.; "Nighttime" = 10:00 p.m. to 7:00 a.m.

Source: Urban Crossroads, 2022 (Appendix I)
Sensitive receptors adjacent to the Project site are shown in Figure N-2, Receiver Locations.

R1: Location R1 represents existing noise sensitive residence at 511 Third Street, approximately 698 feet north of the Project site. Receiver R1 is placed at the private outdoor living areas (backyards) facing the Project site. A 24-hour noise measurement was taken near this location, L1, to describe the existing ambient noise environment.

R2: Location R2 represents the existing noise sensitive Historic Redlands Train Station at 383- 389 Orange Street, approximately 407 feet northeast of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receiver R2 is placed at the building façade. A 24-hour noise measurement was taken near this location, L2, to describe the existing ambient noise environment.

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R3: Location R3 represents the existing noise sensitive residence at 124 West Vine Street, approximately 854 feet south of the Project site. Receiver R3 is placed at the private outdoor living areas (backyards) facing the Project site. A 24-hour noise measurement was taken near this location, L3, to describe the existing ambient noise environment.

R4: Location R4 represents the existing noise sensitive residence at 321 West State Street, approximately 458 feet southwest of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receiver R4 is placed at the building façade.

A 24-hour noise measurement was taken near this location, L4, 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
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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, the General Plan and Municipal Code do not identify specific construction noise level limits and Section 8.06.120, Exemptions, of the 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 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 constructionrelated NIOSH noise level threshold of 85 dBA Leq is used (Urban Crossroads, 2022).

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.

The noise volumes in Table N-3 were applied to the locations of the closest sensitive receptors. 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 N4, the unmitigated highest construction noise levels are expected to range from 57.3 to 61.4 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
Demolition Exceeded?
Site
Preparation Grading
Building
Construction Paving
Architectural
Coating
Highest
Levels2
R1 51.0 57.0 59.0 52.0 50.0 47.0 59.0 85 No
R2 53.4 59.4 61.4 54.4 52.4 49.4 61.4 85 No
R3 49.3 55.3 57.3 50.3 48.3 45.3 57.3 85 No
R4 53.1 59.1 61.1 54.1 52.1 49.1 61.1 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, 2022 (Appendix I)
Operations
Development of the proposed Project would result in a residential development with 146 multi-family dwelling units and associated common spaces. Potential long-term noise impacts associated with Project operation would include exterior traffic noise, operational noise, and stationary equipment noise.

Traffic Noise
The Project would generate 694 weekday daily trips, with 47 trips produced in the weekday AM peak hour and 42 trips produced in the weekday PM peak hour (EPD, 2022). 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.

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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 0.1 to 0.2 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
CNEL at Receiving
Land Use (dBA)2
Incremental Noise Level
Increase Threshold3
No
Project
With
Project
Project
Addition Limit Exceeded?
1 Redlands Blvd. w/o Eureka St. 68.0 68.1 0.1 1.5 No
2 Redlands Blvd. e/o Eureka St. 68.0 68.2 0.2 1.5 No
3 Eureka St. n/o Redlands Blvd. 65.8 66.0 0.2 1.5 No
4 Eureka St. s/o Redlands Blvd. 65.0 65.1 0.1 1.5 No
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 receiving land use. 3 Does the Project create an incremental noise level increase exceeding the significance criteria? Source: Urban Crossroads, 2022 (Appendix I)
Table N-6 shows that the Project offsite traffic noise level increases range from 0.1 to 0.2 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
CNEL at Receiving
Land Use (dBA)2
Incremental Noise Level
Increase Threshold3
No
Project
With
Project
Project
Addition Limit Exceeded?
1 Redlands Blvd. w/o Eureka St. 68.6 68.7 0.1 1.5 No
2 Redlands Blvd. e/o Eureka St. 68.5 68.7 0.2 1.5 No
3 Eureka St. n/o Redlands Blvd. 66.3 66.5 0.2 1.5 No
4 Eureka St. s/o Redlands Blvd. 65.4 65.6 0.2 1.5 No
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 receiving land use. 3 Does the Project create an incremental noise level increase exceeding the significance criteria? Source: Urban Crossroads, 2022 (Appendix I)
Operational Noise
The on-site Project-related noise sources would include sources such as roof-top air conditioning units, trash enclosure activity, parking lot vehicle movements, outdoor gatherings, and outdoor pool/spa activity. Using the reference noise levels to represent the proposed Project operations, operational source noise levels were SCEA
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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. Municipal Code Section 8.06.070, Exterior Noise Limits, 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 41.5 to 45.5 dBA Leq. The nighttime hourly noise levels at the off-site receiver locations are expected to range from 37.5 to 41.5 dBA Leq.

Table N-7: Project Operational Noise Level Compliance
Receiver
Location1
Project Operational Noise
Levels
(dBA Leq)
Noise Level Standards
(dBA Leq)2
Noise Level Standards
Exceeded?3
Daytime Nighttime Daytime Nighttime Daytime Nighttime
R1 42.1 38.2 60 55 No No
R2 44.1 40.2 60 55 No No
R3 41.5 37.5 60 55 No No
R4 45.5 41.5 60 55 No No
1 See Exhibit N-2 for the receiver locations.
2 City of Redlands Municipal Code, Section 8.06.070 (Appendix 3.1) 3 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, 2022 (Appendix I)
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, courtyards, 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 I 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 0.2 dBA Leq at the nearby receiver locations. Projectrelated operational noise level contributions at the sensitive receiver locations would be less than significant.

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?
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R1 42.1 L1 63.7 63.7 0.0 3.0 No
R2 44.1 L2 70.4 70.4 0.0 1.5 No
R3 41.5 L2 70.4 70.4 0.0 1.5 No
R4 45.5 L3 59.9 60.1 0.2 5.0 No
1 See Exhibit N-2 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, 2022 (Appendix I)
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 38.2 L1 56.4 56.5 0.1 5.0 No
R2 40.2 L2 63.9 63.9 0.0 3.0 No
R3 37.5 L2 63.9 63.9 0.0 3.0 No
R4 41.5 L3 60.1 60.2 0.1 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, 2022 (Appendix I)
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’s 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, Exterior Noise Limits, 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.
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 groundborne vibration from Project construction activities would cause only intermittent, localized intrusion. The proposed Project’s construction activities most likely to cause vibration impacts are:

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• 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.

Groundborne 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 groundborne 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, groundborne 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 be approximately 0.000 PPV at sensitive receivers, 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 Municipal Code requirements, thereby eliminating potential vibration impact during the sensitive nighttime hours. As such, construction vibration impacts would be less than significant.

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 698' 0.00 0.00 0.00 0.00 0.00 0.04 No
R2 407' 0.00 0.00 0.00 0.00 0.00 0.04 No
R3 854' 0.00 0.00 0.00 0.00 0.00 0.04 No
R4 458' 0.00 0.00 0.00 0.00 0.00 0.04 No
1 Construction receiver locations are shown on Exhibit 11-A. 2 Distance from receiver location to Project construction boundary. 3 Based on the Vibration Source Levels of Construction Equipment (Table 11-4). 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, 2022 (Appendix I)
Operation
The proposed multi-family residential 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 SCEA
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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.

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

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 146 multifamily rental dwelling units. According to the City of Redlands General Plan EIR, the city has an average of

2.65 persons per household and is expected to increase 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 27 studios and 119 one-bedroom residential units. The size of the units would range size from 517 SF studios to approximately 829 one-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 couples that differ significantly in demographic features from the average Redlands household size of approximately 2.65 members per household, which reflects family households occupying single-family residences.

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 27 1.31 36
One-bedroom 119 1.42 169
Total 146 - 205
1Persons per unit retrieved from Census American Community Survey (ACS) 2019 Microdata Sample (PUMS)
The 205 residents at full occupancy would constitute a 0.3 percent increase over the 2022 City of Redlands population of 72,585 (DOF 2022). In addition, the 146 new multi-family units would constitute a 0.5 percent increase in the total number of residential units in the city, and a 3.3 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 SCEA
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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 146 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. 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 146 multi-family dwelling units. Therefore, there would be no impacts related to the displacement of substantial numbers of existing people or housing.

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 52 total sworn personnel, (including 44 firefighter/paramedics and 16 firefighter/EMTs) and covers an area of 37 square miles.

RFD operates four fire stations in the city and has mutual aid 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), which are facilitated by a consolidated dispatch center operated by CONFIRE. CONFIRE is a multi-agency 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.

There are three fire stations within 2 miles of the site, which include the following:

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• Station 261 located at 525 East Citrus Avenue, is approximately 0.6 roadway miles from the Project site. Station 261 was originally built in 1948 but was remodeled in 2002. The station provides daily staffing of 7 personnel with a medic fire engine, medic fire truck, battalion vehicle, an OES, and a reserve engine (Citygate).
• Station 264 is located at 1270 West Park Avenue, approximately 1.0 roadway miles from the Project site. The station consists of a portable building that was installed in 2009 and is staffed with 5 personnel with a medic fire engine, medic squad truck, reserve medic squad truck, and a brush engine (Citygate).
• Station 263 is located at 10 West Pennsylvania Avenue, approximately 1.2 roadway miles from the Project site. This station was developed in 1986 is staffed with three personnel daily with a medic fire engine, water tender, incident support vehicle, and a reserve engine (Citygate).

The City currently has plans to acquires sites for and to construct two new fire stations (Stations 265 and 266) in different parts of the City and relocate Station 264 based on the annual increase in calls for service and location of service need. Thus, future facilities are planned by the City to expand service coverage in other portions of the City, and would reduce the geographical coverage of the existing stations.

In 2021, RFD received 11,836 calls for service and had 72,933 residents (California Department of Finance), which results in 0.16 calls per resident. The calls for service increased by an average by 6.65 percent in the three years between October 2016 and September 2019. Additionally, approximately 45 percent of the calls for service occur simultaneously. A majority of the increased calls were for emergency medical services (Citygate), which is consistent with the City’s Fire Department Assessment and Deployment Study (2020) that details that 63 percent of service calls in 2018/2019 were for emergency medical services. The RFD currently has a goal response time of 7 minutes, 90 percent of the time (Citygate, 2020).

The Project site is located within 2 miles of three existing fire stations. Per the Redlands Fire Department Deployment/Assessment Study, the Project site is within the 4-minute response time with congestion area (Citygate, 2020), and in the area that would meet the response time goal of 7 minutes, 90 percent of the time.

The proposed Project develop 146 multi-family residences on the site. 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 15.20 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 for fire safety. Additionally, the proposed Project would be required to comply with City fire suppression standards including the current California Fire Code, which evaluates the Project for adequate emergency access. Thus, fire and emergency access hazards resulting in a need for additional fire services would not occur.

As described in the Section 14, Population and Housing, the Project would result in 191 new residents, which is a 0.18 percent increase in the City’s population and within the City’s projected growth. The additional population would generate an incremental increase in calls for fire and emergency medical services. Because the Project site is within 2.0 miles of three existing fire stations, the Project would be served by the existing stations, and the Project would not result in the need to construct or expand a new fire station. Thus, impacts would be less than significant.

Should the calls for service from the Project coincide with call for service from another parcel within in the same fire station response area, an increase in response times could occur. However, to reduce cumulative impacts related to fire and emergency medical services, such as response times, the General Plan EIR (page

3.13-27) directs that fire protection equipment and staffing be augmented by the City development impact fees that all development projects are required to pay. Also, as set forth in the General Plan’s “Principles of Managed Development,” and in the City’s resolution establishing development impact fees, Resolution No. 7951, adopted April 2, 2019), the fees are to expand fire protection and emergency medical staffing and SCEA
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equipment provided from existing stations and better accommodate simultaneous service calls. Further, 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 to fund the City’s Public Facility Program, which includes a budget for RFD facilities.

Thus, the project would be required to pay the existing City fees to be used exclusively for the planned expansion and improvement of fire protection and emergency medical services provided by RFD.

Overall, because there are three existing fire stations within 2.0 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, cumulative impacts related to the expanded fire protection facilities and staffing needed from population growth are planned to be augmented through development fees that are required by Chapter 3.60 of the Municipal Code and the General Plan EIR prior to the issuance of building permits. 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 (Redlands GP EIR 2017).

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 205 residents and based on the Police Department’s staffing of 1.1 officers per 1,000 residents, the proposed Project would require 0.23 of an additional officer.

Since the need by the Project is less than one officer, the Project would not require the construction or expansion of the City’s existing policing facilities and the payment of 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 as set forth in the General Plan’s “Principles of Managed Development,” and in the City’s resolution establishing development impact fees, Resolution No. 7951, 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:
• Mariposa Elementary School located at 30800 Palo Alto Drive, which is 3.75 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 146 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 SCEA
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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
2021-2022
Enrollment1
Existing
Remaining
Capacity
Students
Generated by
Project
Remaining
Capacity with
Project
Mariposa
Elementary
School
594 439 155 31 124
Cope Middle
School
1,507 1,287 220 9 211
Redlands High
School
3,930 2,233 1,697 14 1,683
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; 2021-2022 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 most recent (as of 2016) parkland acreage 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 0.33 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 0.49 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 0.84 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 multi-family residential development which would result in 146 new multifamily residences, 205 new residents, and an increase in the use of public parks. The Project would result in a demand for 1.03 acres of parkland/open space. The proposed Project would include 22,948 SF (0.53 acres) of open space which includes courtyards, a private pool, and roof top. A portion of the Project’s park demand would be met onsite with the provision of 22,948 SF of open space area, consisting of a pool, sitting areas, and courtyards. In addition, the Project would be required to pay parkland fees pursuant to Municipal SCEA
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Code Chapter 3.32, Open Space and Park Fees, 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 146 residential units within an area that would redevelop a commercial retail furniture store. 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.

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.

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 residential development including a 146-unit multi-family residential development, which would result in 205 new residents and a modest increase in the use of public parks. Based on this formula, the Project would result in a demand for 1.03 acres of parkland/recreational space. The Project would be required to pay parkland fees pursuant to Municipal Code Chapter 3.32, Open Space and Park Fees, 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 22,984 SF of open space area, consisting of a pool, sitting areas, and courtyards 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 recreational areas 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 SCEA
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construction as required for the Project, 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.

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 Trip Generation & VMT Screening Analysis for the Grand Residential Project (CRA 911), prepared by EPD Solutions, April 2022, 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 multi-family residential development with 146 multi-family dwelling units and amenity areas. Vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project area.

A VMT Screening Analysis, dated April 2022, was prepared for the Project by EPD Solutions (EPD, 2022).

As shown on Table T-1, the multi-family residential development would generate approximately 694 weekday daily trips, with 47 trips produced in the weekday AM peak hour and 42 trips produced in the weekday PM peak hour when compared to the existing land uses (EPD, 2022).

Table T-1: Project Trip Generation
Land Use
AM Peak Hour PM Peak Hour
In Out Total In Out Total Daily
Trip Generation 26 21 47 18 24 42 694
Source: (Appendix J)
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, as set forth in the General Plan’s “Principles of Managed Development,” and in the City’s resolution establishing development impact fees, Resolution No. 7951. 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
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The proposed Project would construct onsite sidewalks and pedestrian paseos to provide access to the Arrow Line located approximately 0.11-mile north of the Project site. Additionally, the Project site is located less than 300 feet from a bus stop serving Omnitrans Routes 9 and 18. The Project would construct new sidewalks along Third Street, Redlands Boulevard, and Eureka Street. As such, the proposed Project would enhance pedestrian 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 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); • 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. However, the Project would not meet the SCEA
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aforementioned secondary criteria as the Project would have more parking than required by City Ordinance Number 2930. The Project would meet the criteria for Screening Criteria 3 as it would generate less than 3,000 MTCO2e. 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 Third Street and Eureka Avenue. Vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project area. Any needed street improvements along Eureka Street would be reviewed by the City and would be required to meet all City development standards. The Project would not include any street improvements to Redlands Boulevard or Third Street. Additionally, the driveways from Eureka Street and Third 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, Eureka Street, and Third Street 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 ingress/egress driveways from Eureka Street and Third 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 Redlands Boulevard, Third 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.

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, May 2022 (MCC 2022), 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 April 26, 2022, 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
The Gabrieleno Band of Mission Indians – Kizh Nation and Agua Caliente Band of Cahuilla Indians requested consultation regarding the proposed Project. The Gabrieleno Band of Mission Indians – Kizh Nation consulted with the City via email on June 29, 2022 and considers the area sensitive for cultural resources. While no evidence was provided of potential impacts to tribal cultural resources, the consulting tribe requested inclusion of mitigation due to the potential of the Project to unearth previously undocumented tribal cultural resources during construction. The Agua Caliente Band of Cahuilla Indians consulted with the City on July 7, 2022 and considers the area sensitive for cultural resources, but deferred to the Gabrieleno Band of Mission Indians – Kizh Nation.
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 Impact with Mitigation Incorporated. As discussed in Section 6.3.5 of this document, Response 6.3.5(a), the records search revealed that 21 cultural resources have been recorded within one mile of the Project site. One historic-era cultural resource, a portion of the historic Redlands Chinatown, is potentially located subsurface within the Project site. Additionally, the Gabrieleno Band of Mission Indians – Kizh Nation considers the area sensitive for cultural resources. Therefore, the tribe requests that in addition to MM CUL-1 and MM CUL-2 a tribal monitor be retained to monitor any ground disturbing activities for the Project. Mitigation Measures TCR-1 through TCR-3 have been included to require 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).
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 SCEA
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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 Impact with Mitigation Incorporated. As discussed above, to avoid potential adverse effects to tribal cultural resources, Mitigation Measures CUL-1, CUL-2, and TCR-1 through TCR-3 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 PPP CUL-1 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-3, and MM CUL-1 through CUL-2, impacts to TCRs would be less than significant.

Existing Plans, Programs, or Policies
None.

Mitigation Measures
MM TCR-1: Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities.

A. The Project Applicant/Lead Agency shall retain a Native American Monitor from or approved by the Consulting Tribe(s), Gabrieleño Band of Mission Indians – Kizh Nation. The monitor shall be retained prior to commencement of any “ground-disturbing activity” for the subject Project at all Project locations (i.e., both onsite and any offsite locations that are included in the Project description/definition and/or required in connection with the Project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

B. A copy of the executed monitoring agreement shall be submitted to the Lead Agency prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

C. The monitor will complete daily monitoring logs that will provide descriptions of the relevant grounddisturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”) as well as any discovered Native American (ancestral) human remains and burial goods.

Copies of monitor logs will be provided to the Project Applicant/Lead Agency upon written request to the Tribe.

D. Onsite tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Kizh from a designated point of contact for the Project Applicant/Lead Agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the Project site or in connection with the Project are complete; or (2) a determination and written notification by the Kizh to the Project SCEA
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Applicant/Lead Agency that no future, planned construction activity, and/or development/construction phase at the Project site possesses the potential to impact Kizh TCRs.

E. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Consulting Tribe(s), Kizh monitor and/or Kizh archaeologist. The Consulting Tribe(s) or Kizh will recover and retain all discovered TCRs in the form and/or manner the Consulting Tribe(s) deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

TCR-2: Unanticipated Discovery of Human Remains and Associated Funerary Objects.

A. Native American human remains are defined in PRC 5097.98(d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98 are also to be treated according to this statute.

B. If Native American human remains and/or grave goods are discovered or recognized on the Project site, then all construction activities shall immediately cease. Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determinate the nature of the remains. If the coroner recognized the human remains to be those of a Native American, or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

D. Construction activities may resume in other parts of the Project site at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Kizh determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the Project manager express consent of that determination (along with any other mitigation measures the Kizh monitor and/or archaeologist deems necessary). (CEQA Guidelines Section 15064.5(f).)
E. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any historic archaeological material that is not Native American in origin (non-TCR) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

F. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

TCR-3: Procedures for Burials and Funerary Remains.

A. As the Most Likely Descendant (“MLD”), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains.

B. If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

C. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered SCEA
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as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

D. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24- hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the Project cannot be diverted, it may be determined that burials will be removed.

E. In the event preservation in place is not possible despite good faith efforts by the Project Applicant/developer and/or landowner, before ground-disturbing activities may resume on the Project site, the landowner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects.

F. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags.

All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery.

The site of reburial/repatriation shall be on the project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

G. The Consulting Tribe(s) will work closely with the Project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Consulting Tribe(s), documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recovery-related forms of documentation shall be approved in advance by the Consulting Tribe(s). If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

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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?
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 that would connect to existing12- inch water lines in Eureka Street and to the existing 8-inch water lines in Redlands Boulevard and Third Street. Additionally, the Project would install fire water lines onsite that would connect to the existing 12- inch and 8-inch water lines in the rights-of-way. 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.

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Table UT-1: Proposed Project Estimated Water Demand
Land Use Type DU/Acreage Unit Water
Demand Factor1
Daily Water
Usage (gpd)
Annual Water
Usage (AFY)
Residential MultiFamily 146 DU 210 gpd/DU 30,660 gpd 34.3 AFY Total Water Demand 34.3 AFY
1City of Redlands “Water and Sewer Demands Spreadsheet” (May 8, 2019) As shown, the proposed Project would result in a water demand of 34.3 acre-feet per year (AFY). The proposed Project would continue to receive water supplies through the existing water lines located within the Redlands Boulevard, Third Street, and Eureka Street rights-of-way 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 install onsite sewer lines that would connect to the existing 12-inch sewer line in Redlands Boulevard.

Wastewater demand associated with the proposed Project would be typical of residential and restaurant wastewater usage in the City of Redlands. As shown in Table UT-2, Proposed Project Estimated Wastewater Generation, the proposed Project would generate approximately 16,760 gallons per day (gpd) of wastewater.

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

6.75 million gallons per day (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-2: Proposed Project Estimated Wastewater Generation Use Size Generation Rate
(gpd/unit)
Total Wastewater
(gpd)
Studio 19 du 80 gpd/du 1,520
One Bedroom 127 du 120 gpd/du 15,240
Total Project Wastewater Generation: 16,760 gpd
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, SCEA
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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 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
As discussed in Section 6.3.10 of this document, the proposed Project would increase the impervious surface area on the Project site by 4,897.5 square feet 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 onsite improvements included as part of the proposed Project. All new residential development that connects to the system is required to pay its applicable 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 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 Project would have a demand of 34.3 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 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 mgd with a capacity of 9.5 mgd. As discussed above, the proposed Project would generate approximately 16,760 gpd. All new development that connects to the system is required to pay its applicable 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? SCEA
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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 2022). 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 2022).

Construction
Construction of the proposed Project would require demolition of the existing onsite building, grading, and construction of new buildings and infrastructure. 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 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 residential development with 146 multi-family dwelling units that would result in an increase of approximately 205 residents on the Project site. As shown on Table UT-3, it is anticipated that the proposed Project would generate a total of approximately 0.046 ton of solid waste per day (16.79 tons per year) during Project operation.

Table UT-3: Solid Waste Generation during Project Operation Land Use Quantity Generation Rate Solid Waste Demand
Multi-Family Units1 146 units 0.46 tons/unit/year 67.16 tons per year Total Solid Waste 67.16 tons per year
Annual Landfill Disposal with AB 341 (75% Reduction) 16.79 tons per year Weekly Landfill Disposal with AB 341 (75% Reduction) 0.32 tons per week 1CalRecyle Estimated Solid Waste Generation Rates
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.

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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 the 2022 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 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.

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.

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 located in a Local Responsibility Area and 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 2022). 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 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, 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 RFD. The size and location of fire suppression facilities (e.g., hydrants) and fire access routes would be required to conform to City and RFD standards. The Project would provide adequate emergency access to the proposed building SCEA
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via driveways from Eureka Street and Third Street. 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 146 multi-family residential dwelling units. As discussed in Section 6.3.14 of this SCEA, the Project is anticipated to result in a population increase of approximately 205 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 multi-family residential 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 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.

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.

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

Compliance with the proposed operational BMPs would ensure onsite storm drain facilities would be sized to accommodate stormwater runoff from the Project site so that onsite flooding would not occur. Additionally, as required by Municipal Code Section 15.32.110, Construction Standards, 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.

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 potentially contains portions of Historic China Town. In addition, as described previously, the Project site has been previously disturbed from various past uses that involve grading and installation of utility infrastructure. However, Mitigation Measure CUL-1 has been included to require Phase 2 archaeological testing and Mitigation Measure CUL-2 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 through CUL-2 and Mitigation Measures TCR-1 through TCR-3 would reduce potential impacts to important examples of California prehistory to a less than significant level. 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 SCEA
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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 Impact with Mitigation Incorporated. As presented in this document, potential Projectrelated 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 Impact 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.

Konnie Dobreva, JD
Meaghan Truman
Megan Rupard
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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.” 2022. https://gis.data.ca.gov/datasets/789d5286736248f69c4515c04f58f414 Citygate Associates, LLC. Fire Department Assessment and Deployment Study. 25 June 2020. https://destinyhosted.com/redladocs/2020/CC/20200901_218/2879_Vol_1_- _Final_Redlands_FD_Assessment_and_Deployment_Study_Technical_Report_%2806-25-20%29.pdf 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 EPD Solutions. “Trip Generation & VMT Screening.” 26 April 2022. Appendix J.

Force Environmental. “Phase I Environmental Assessment.” 13 November 2015. Appendix G.

Hicks & Hartwick, Inc. “Preliminary Water Quality Management Plan.” Appendix H.

Material Culture Consulting. “Cultural and Paleontological Resources Assessment.” May 2022. Appendix B.

San Bernardino Countywide Plan. 2020.
https://www.arcgis.com/apps/webappviewer/index.html?id=5864a434814c4e53adc74101b34b1905 Soils Southwest, Inc. “Report of Geotechnical Investigations.” 30 May 2022. (Soils 2022). Appendix E 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://rdp.scag.ca.gov/helpr/?page=page_0
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 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.” 23 May 2022. https://www.fws.gov/wetlands/data/mapper.html
Urbana Preservation & Planning, LLC. “Historical Resource Summary.” 3 May 2022. Appendix C.

Urban Crossroads. Air Quality Impact Analysis. 13 June 2022. Appendix A.

Urban Crossroads. Energy Analysis. 13 June 2022. Appendix D.

Urban Crossroads. Greenhouse Gas Analysis. 13 June 2022. Appendix F.

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Urban Crossroads. Noise Impact Analysis. 13 June 2022. Appendix I.

The Grand Project Chapter 2. Response to Public Comments

2. 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 Grand Project during the public review period, which began July 14, 2022 and closed August 12, 2022 (SCH No. 2022070225). 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. Yuhaaviatam of San Manuel Nation, Received August 11, 2022 (1 page) O2. Lozeau Drury LLP, Received August 11, 2022 (23 pages) I1. T. Allen Jolliff, Received July 30, 2022 (1 page)
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 Grand SCEA.

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 Grand Project Chapter 2. Response to Public Comments City of Redlands 2-2
Final SCEA
August 2022
Letter O1: Yuhaaviatam of San Manuel Nation, Received August 11, 2022 The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-3
Final SCEA
August 2022
RESPONSE TO LETTER O1: Yuhaaviatam of San Manuel Nation Comment O1.1: This comment states that the Tribe agrees with the cultural resources report’s recommendation for an archaeological testing plan that would occur after all existing structures have been removed and that the Tribe hopes to continue to consult on the Project as it moves forward. Written notice was previously provided to the Yuhaaviatam of San Manuel Nation in accordance with California Government Code §65352.3 and Public Resources Code §21080.3.1 in the letter mailed to the Tribe on April 26, 2022. The Tribe responded on May 25, 2022 stating that the Tribe did not have any input on the Project and no additional consultation under SB 18 was required. Tribal consultation for the Project is discussed in Section 6.3.18 of the SCEA (see pages 195-199). Furthermore, Mitigation Measures TCR-1 through TCR-3 are included, which reduce any potential impacts to tribal cultural resources to a less than significant level. The comment does not raise any further environmental concerns or questions; therefore, no further response is warranted. The comment will be forward to City decision-makers.

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Letter O2: Lozeau Drury, LLP, on behalf of Supporters Alliance for Environmental Responsibility Received August 11, 2022
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RESPONSE TO COMMENT LETTER O2: Lozeau Drury, LLP
Response to Comment O2.1: This comment provides background on the Project and introduces the comment letter. Comment O2.1 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.1 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.2: This comment states that SAFER requests that the Planning Division refrain from taking any action on the Project and SCEA because the SCEA’s conclusions about the Project’s impacts to air quality are not supported by substantial evidence. In addition, the comment requests that the City prepare an EIR for the Project. Comment O2.2 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA.

Comment O2.2 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.3: This comment provides a summary of the proposed Project description.

Comment O2.3 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.3 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.4: This comment provides a background summary of the purpose, use, and legal background of a SCEA and provides a summary of SCAG’s 2020-2045 RTP/SCS. Comment O2.4 is introductory in nature and does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.4 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.5: This comment states that air quality experts reviewed the SCEA and found that the SCEA’s conclusions related to the Project’s air quality impacts are not supported by substantial evidence. The comment provides an introduction to Exhibit A to the comment letter, which details Mr.

Offerman’s assessment that the SCEA failed to address and mitigate the human health impacts from indoor emissions of formaldehyde. Comment O2.5 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA.

Comment O2.5 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.6: This comment states that the SCEA fails to disclose, analyze and mitigate the significant health risks posed by the Project from formaldehyde, a toxic air contaminant (TAC) to future residents and employees of the Project. The comment further states that emissions of indoor formaldehyde would surpass SCAQMD’s threshold for TACs and the Project would have a significant adverse impact and that carcinogenic formaldehyde emissions are not an existing environmental condition. The comment concludes by stating that the City must include an analysis of formaldehyde associated health risks within an EIR and identify appropriate mitigation measures. As stated within the SCEA on page 135, the proposed Project would be required to comply with the California Green Building Standards Code (CALGreen) Sections

4.504.5 and 5.504.4.5. Furthermore, composite wood products used within the Project must be compliant with the California Air Resource Board (CARB) Airborne Toxic Control Measures Phase II or Toxic Substances Control Act (TSCA) Title VI. These state regulations along with Cal/OSHA are the main regulators of indoor formaldehyde products.

The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-28
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The comment does not describe how the asserted formaldehyde related cancer risk of 120 per million would occur and does not identify any Project-specific conditions (other than the fact that the Project' s construction may use wood building materials) that would lead to impacts. Current federal and state regulations exist, which limit the potential formaldehyde emissions from building materials. On June 1, 2018, the U. S. Toxic Substances Control Act (TSCA) Title VI was implemented, which requires composite wood products sold, supplied, offered for sale, manufactured, or imported in the United States are required to meet new emission standards for formaldehyde from composite wood products to reduce exposures to formaldehyde and avoid adverse health effects. Typical composite wood products include hardwood plywood, medium-density fiberboard, and particleboard, as well as household and other finished goods containing these products.

The new emission limits include the following:
• Hardwood Plywood: 0.05 parts per million (ppm)
• Particleboard: 0.09 ppm
• Medium - density fibreboard: 0. 1 1 ppm
• Thin Medium -density fibreboard: 0. 13 ppm
These emission levels were determined to be in compliance with and result in less exposure (e. g., daily intake) than the California Proposition 65 safe harbor level for formaldehyde (40 μg/ day), which is based on Proposition 65' s risk criterion of 1 in 100, 000. Thus, products manufactured to TSCA Title VI and California Proposition 65 safe harbor standards, which is now required by the U. S. EPA for all products manufactured or imported into the United States, would not generate formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million.

CARB identifies that these standards are projected to lead to a reduction in statewide formaldehyde emissions of 500 tons per year. Reduced risk of cancer from formaldehyde exposure is also a resulting benefit, and implementation of these standards is estimated to reduce excess cancer cases per million people from formaldehyde exposure by about 40 percent1. The CalGreen Building Code also includes similar formaldehyde limits for building products.

The Project would be implemented pursuant to these formaldehyde requirements, as all products manufactured or imported in the United States would be required to meet these regulations. This would limit the potential of human health and cancer risks to a less than significant level pursuant to the SCAQMD significance threshold of 10 per million. Thus, building material manufacturer compliance with existing regulations would avoid potentially significant impacts related to formaldehyde. Thereby, the Project would also result in less than significant impacts. Comment O2.6 does not provide accurate evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA.

Comment O2.6 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.7: This comment states that an EIR should be prepared for the proposed Project or the SCEA should be revised prior to any further action on the Project. As substantiated by Response to Comments O2.1 through O2.6 and O2.8 through O2.17, none of the comments within the organization’s comment letter provide evidence of significant impacts that would require preparation of an EIR or that would require substantial changes to the SCEA. No further response is warranted.

Response to Comment O2.8: This comment provides a summary of indoor air pollutants. The commenter is referred to the discussion in Response to Comment O2.6. Comment O2.8 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review 1 https:// www.arb.ca.gov/ toxics/ compwood/ implementation/ faq.htm# G The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-29
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SCEA. Comment O2.8 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.9: This comment provides a summary of indoor formaldehyde concentrations in new construction and its associated cancer risks. The commenter is referred to the discussion in Response to Comment O2.6. Comment O2.9 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.9 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.10: This comment states that residential occupants and employees of the Project would have a continuous exposure to formaldehyde, which would result in significant cancer risks. The commenter is referred to the discussion in Response to Comment O2.6. Furthermore, the commenter significantly overestimates the amount of daily formaldehyde exposure to residents. First, the commenter assumes that residential occupants would inhale 20 cubic meters of air per day yet cites no evidence to substantiate this assumption. According to the American Lung Association, the average person inhales approximately 2,000 gallons of air per day, or roughly 7.57 cubic meters per day.2 Second, the commenter incorrectly applies an entire 70-year average lifetime (24 hours per day from birth to death) to calculate residential formaldehyde exposure, thus vastly overestimating any potential formaldehyde exposure to residents who would occupy the Project. This means that residents would live in their units 24 hours per day for their entire lives. Estimates of how many times a person living in the United States moves in his or her lifetime have ranged from 9 times to 11 times, depending on age, race, and socioeconomic status, among other categories.3 Thus, it is speculative and inaccurate to assume that the initial residents who occupy the Project would remain for the remaining duration of their lives. Therefore, the commenter does not provide credible evidence of significant impacts related to indoor air quality.

Moreover, within Appendix A, the commenter is speculating that composite wood materials would be used in the interior of the building. Indoor building materials will not be known until the building permit stage. As such, any further analysis on the content of indoor building materials would be speculative.

Therefore, Comment O2.10 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.10 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.11: This comment provides a formaldehyde emissions assessment that the commenter states should be used in the SCEA. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.11 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.11 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.12: This comment states that outdoor ventilation is an important factor influencing the indoor concentrations of air contaminants. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.12 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.12 and 2 American Lung Association, How Your Lungs Get the Job Done, website: https://www.lung.org/blog/how-yourlungs-work, accessed February 2022. 3 United States Census Bureau, Calculating Migration Expectancy Using ACS Data, website:
https://www.census.gov/topics/population/migration/guidance/calculating-migration-expectancy.html, accessed February 2022; FiveThirtyEight, How Many Times Does The Average Person Move, website:
https://fivethirtyeight.com/features/how-many-times-the-average-person-moves/, accessed February 2022 .

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this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.13: This comment states that the Project is close to roads with moderate to high traffic as well as air traffic from the San Bernardino International Airport. The comment states that as a result of the high outdoor noise levels, the Project will require a mechanical supply of outdoor air ventilation to allow for a habitable indoor environment. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.13 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.13 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.14: The comment states that an air quality analysis should be conducted to determine the concentrations of PM2.5. This comment states that based on the traffic in the area, the Project may warrant the installation of high efficiency air filters. The commenter is requesting the installation of MERV 13 or higher, this is now a Title 24 requirement by which the Project will comply. The commenter is referred to the 2019 Title 24 Building Energy Efficiency Standards Section 120.14. Comment O2.14 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.14 and this response will be forwarded to all decisionmaking bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.15: This comment provides recommended mitigation measures to minimize impacts to indoor air quality from formaldehyde. As impacts are less than significant, no mitigation measures are warranted. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10.

Comment O2.15 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.15 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.16: This comment provides recommended mitigation measures for outdoor air ventilation. As impacts are less than significant, no mitigation measures are warranted. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.16 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.16 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.17: This comment provides recommended mitigation measures for air filtration.

The commenter is requesting the installation of MERV 13 or higher, this is now a Title 24 requirement by which the Project will comply. The commenter is referred to the 2019 Title 24 Building Energy Efficiency Standards Section 120.15. Comment O2.17 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.17 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.
4 https://energycodeace.com/site/custom/public/reference-ace2019/index.html#!Documents/section1201requirementsforventilationandindoorairquality.htm) 5 https://energycodeace.com/site/custom/public/reference-ace2019/index.html#!Documents/section1201requirementsforventilationandindoorairquality.htm) The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-31
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Letter I1: T. Allen Jolliff, Received July 30, 2022
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RESPONSE TO LETTER I1: T. Allen Jolliff
Comment I1.1: This comment states that if these units are multi-family, there should be at least two parking spaces per unit. In addition, the comment states that there is no mention of how bikes would be secured if families are supposed to rely on bikes.

Parking or a lack of parking is not considered an environmental impact under CEQA. However, pursuant to City of Redlands Municipal Code Section 18.92.080, with a Conditional Use Permit, only 1 parking space is required for units up to 999 square feet (SF), 1.5 space is required for units 1,000 to 1,499 SF, and 2 spaces are required for units greater than 1,500 SF. As discussed within the SCEA and shown on Figure 3-1, Conceptual Site Plan, Parking Level, the Project would include multiple bike storage rooms and bike maintenance rooms adjacent to the parking garage. This comment does not raise a specific issue with the adequacy of the SCEA or raise any other CEQA issues. Therefore, no further response is required.

The Grand Project Chapter 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-1
August 2022

3. 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 Grand Project (Project). The City of Redlands is 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 Grand Project. The table identifies the Plans, Programs, Policies (PPPs) 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 and mitigation measures are completed, the compliance monitor will sign and date the MMRP, indicating that the required actions have been completed.

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TABLE 1: MITIGATION MONITORING AND REPORTING PROGRAM

THE GRAND PROJECT
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials

AIR QUALITY
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 Redlands Building
and Safety Division
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 Building
Permits.

City of Redlands Building
and Safety Division
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August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials

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 Redlands Planning
Division

CULTURAL RESOURCES
PPP CUL-1: Human Remains. Should human remains be discovered during project construction, the project will be required to comply with State Health and Safety Code Section 7050.5, which states that no further disturbance may occur in the vicinity of the body until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. The County Coroner must be notified of the find immediately.

If the remains are determined to be prehistoric, the Coroner will notify the Native American Heritage Commission, which will determine the identity of and notify a Most Likely Descendant (MLD). With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD must complete the inspection within 48 hours of notification by the NAHC.

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

City of Redlands Planning
Division
MM CUL-1: Archaeological Testing and Data Recovery Plan. Prior to approval of any grading permit, the Project Applicant shall retain a qualified archaeologist to prepare an Archaeological Testing and Data Recovery Program. The Archaeological Testing and Data Recovery Program shall be Note in Construction Plans
and Specifications. Prior
to Grading Permits.

City of Redlands Planning
Division
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Plan, Program, Policy / Mitigation Measure Timing
Responsible for
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Verification
Date Completed
and Initials
implemented after existing onsite buildings are demolished and prior to ground disturbance and grading. The Archaeological Testing and Data Recovery Program shall include, at minimum, the following procedures:
• Development of an Archaeological Testing and Data Recovery Plan, which shall include:
o Background research and anticipated resource types
o Research questions that can be addressed by the collection of data from the defined resource types
o Field methods and procedures
o Cataloging and laboratory analysis
o Findings and interpretation
• Following the development of the Archaeological Testing and Data Recovery Plan, the Archaeological Testing and Data Recovery Plan shall be provided to the City of Redlands Development Services Director for review and approval. Archaeological testing shall occur, with oversight by the qualified archaeologist, ahead of Projectrelated ground disturbance to identify the presence of archaeological resources within the Project area.
• If no significant archaeological deposits are encountered during testing efforts, Project-related ground disturbance may continue.

Archaeological monitoring shall occur during all Project-related ground disturbance, as stipulated in MM CUL-2. A final Archaeological Monitoring Report shall be prepared upon completion of ground disturbance.
• Should potentially significant archaeological deposits be identified during testing efforts, archaeological data recovery shall be implemented by the Project archaeologist. Any excavation and recovery of identified resources shall be performed using standard archaeological techniques and the requirements stipulated in the The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-6
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
Archaeological Testing and Data Recovery Plan. Any excavations, testing, and/or recovery of resources shall be conducted by a qualified archaeologist. Following the completion of data recovery Project-related ground disturbance may continue. Archaeological monitoring shall occur during all Project-related ground disturbance, as stipulated in MM CUL-2. A final Archaeological Monitoring Report shall be prepared upon completion of ground disturbance.

MM CUL-2: 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 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.

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

City of Redlands Planning
Division

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
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August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
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 qualified professional paleontologist pursuant to the 2010 Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources by the Society for Vertebrate Paleontology (SRV), 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 pursuant to the 2010 Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources by the SRV 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 Note in Construction Plans
and Specifications. Prior
to Grading Permits.

City of Redlands Planning
Division
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Plan, Program, Policy / Mitigation Measure Timing
Responsible for
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Verification
Date Completed
and Initials
repository. The paleontologist shall have a repository agreement in hand prior to initiating recovery of the resource.

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 SWPPP and permit periodic inspection of the construction site by City of Redlands staff or its designee to confirm compliance.

In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Building
and Safety Division
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.

In Construction Plans and
Specifications. Prior to
Grading Permit.

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

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-9
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
Development Impact Fees (DIF) pursuant to the Redlands Municipal Code and/or adopted fee schedules.

TRIBAL CULTURAL RESOURCES
MM TCR-1: Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities.

A. The Project Applicant/Lead Agency shall retain a Native American Monitor from or approved by the Consulting Tribe(s), Gabrieleño Band of Mission Indians – Kizh Nation. The monitor shall be retained prior to commencement of any “ground-disturbing activity” for the subject Project at all Project locations (i.e., both onsite and any offsite locations that are included in the Project description/definition and/or required in connection with the Project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

B. A copy of the executed monitoring agreement shall be submitted to the Lead Agency prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

C. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”) as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the Project Applicant/Lead Agency upon written request to the Tribe.

D. Onsite tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Kizh from a designated point of contact for the Project Applicant/Lead Agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the Project site or in connection with the Project are complete; or (2) a determination and written notification by the Kizh to the Project Applicant/Lead Agency that no future, planned construction In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-10
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
activity, and/or development/construction phase at the Project site possesses the potential to impact Kizh TCRs.

E. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Consulting Tribe(s), Kizh monitor and/or Kizh archaeologist. The Consulting Tribe(s) or Kizh will recover and retain all discovered TCRs in the form and/or manner the Consulting Tribe(s) deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

MM TCR-2: Unanticipated Discovery of Human Remains and Associated Funerary Objects.

A. Native American human remains are defined in PRC 5097.98(d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98 are also to be treated according to this statute.

B. If Native American human remains and/or grave goods are discovered or recognized on the Project site, then all construction activities shall immediately cease. Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determinate the nature of the remains. If the coroner recognized the human remains to be those of a Native American, or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

D. Construction activities may resume in other parts of the Project site at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Kizh determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the Project manager express consent of that determination (along with any other mitigation measures the Kizh monitor and/or archaeologist deems necessary). (CEQA Guidelines Section 15064.5(f).) In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-11
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
E. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any historic archaeological material that is not Native American in origin (non-TCR) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

F. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

MM TCR-3: Procedures for Burials and Funerary Remains.

A. As the Most Likely Descendant (“MLD”), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains.

B. If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

C. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

D. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24- hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-12
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
protected. If the Project cannot be diverted, it may be determined that burials will be removed.

E. In the event preservation in place is not possible despite good faith efforts by the Project Applicant/developer and/or landowner, before ground-disturbing activities may resume on the Project site, the landowner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects.

F. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. The site of reburial/repatriation shall be on the project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

G. The Consulting Tribe(s) will work closely with the Project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Consulting Tribe(s), documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recovery-related forms of documentation shall be approved in advance by the Consulting Tribe(s). If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

The Grand Project Chapter 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-1
August 2022

3. 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 Grand Project (Project). The City of Redlands is 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 Grand Project. The table identifies the Plans, Programs, Policies (PPPs) 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 and mitigation measures are completed, the compliance monitor will sign and date the MMRP, indicating that the required actions have been completed.

The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-2
August 2022
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The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-3
August 2022
TABLE 1: MITIGATION MONITORING AND REPORTING PROGRAM

THE GRAND PROJECT
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials

AIR QUALITY
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 Redlands Building
and Safety Division
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 Building
Permits.

City of Redlands Building
and Safety Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-4
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials

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 Redlands Planning
Division

CULTURAL RESOURCES
PPP CUL-1: Human Remains. Should human remains be discovered during project construction, the project will be required to comply with State Health and Safety Code Section 7050.5, which states that no further disturbance may occur in the vicinity of the body until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. The County Coroner must be notified of the find immediately.

If the remains are determined to be prehistoric, the Coroner will notify the Native American Heritage Commission, which will determine the identity of and notify a Most Likely Descendant (MLD). With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD must complete the inspection within 48 hours of notification by the NAHC.

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

City of Redlands Planning
Division
MM CUL-1: Archaeological Testing and Data Recovery Plan. Prior to approval of any grading permit, the Project Applicant shall retain a qualified archaeologist to prepare an Archaeological Testing and Data Recovery Program. The Archaeological Testing and Data Recovery Program shall be Note in Construction Plans
and Specifications. Prior
to Grading Permits.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-5
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
implemented after existing onsite buildings are demolished and prior to ground disturbance and grading. The Archaeological Testing and Data Recovery Program shall include, at minimum, the following procedures:
• Development of an Archaeological Testing and Data Recovery Plan, which shall include:
o Background research and anticipated resource types
o Research questions that can be addressed by the collection of data from the defined resource types
o Field methods and procedures
o Cataloging and laboratory analysis
o Findings and interpretation
• Following the development of the Archaeological Testing and Data Recovery Plan, the Archaeological Testing and Data Recovery Plan shall be provided to the City of Redlands Development Services Director for review and approval. Archaeological testing shall occur, with oversight by the qualified archaeologist, ahead of Projectrelated ground disturbance to identify the presence of archaeological resources within the Project area.
• If no significant archaeological deposits are encountered during testing efforts, Project-related ground disturbance may continue.

Archaeological monitoring shall occur during all Project-related ground disturbance, as stipulated in MM CUL-2. A final Archaeological Monitoring Report shall be prepared upon completion of ground disturbance.
• Should potentially significant archaeological deposits be identified during testing efforts, archaeological data recovery shall be implemented by the Project archaeologist. Any excavation and recovery of identified resources shall be performed using standard archaeological techniques and the requirements stipulated in the The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-6
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
Archaeological Testing and Data Recovery Plan. Any excavations, testing, and/or recovery of resources shall be conducted by a qualified archaeologist. Following the completion of data recovery Project-related ground disturbance may continue. Archaeological monitoring shall occur during all Project-related ground disturbance, as stipulated in MM CUL-2. A final Archaeological Monitoring Report shall be prepared upon completion of ground disturbance.

MM CUL-2: 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 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.

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

City of Redlands Planning
Division

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
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-7
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
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 qualified professional paleontologist pursuant to the 2010 Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources by the Society for Vertebrate Paleontology (SRV), 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 pursuant to the 2010 Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources by the SRV 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 Note in Construction Plans
and Specifications. Prior
to Grading Permits.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-8
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
repository. The paleontologist shall have a repository agreement in hand prior to initiating recovery of the resource.

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 SWPPP and permit periodic inspection of the construction site by City of Redlands staff or its designee to confirm compliance.

In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Building
and Safety Division
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.

In Construction Plans and
Specifications. Prior to
Grading Permit.

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

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-9
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
Development Impact Fees (DIF) pursuant to the Redlands Municipal Code and/or adopted fee schedules.

TRIBAL CULTURAL RESOURCES
MM TCR-1: Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities.

A. The Project Applicant/Lead Agency shall retain a Native American Monitor from or approved by the Consulting Tribe(s), Gabrieleño Band of Mission Indians – Kizh Nation. The monitor shall be retained prior to commencement of any “ground-disturbing activity” for the subject Project at all Project locations (i.e., both onsite and any offsite locations that are included in the Project description/definition and/or required in connection with the Project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

B. A copy of the executed monitoring agreement shall be submitted to the Lead Agency prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

C. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”) as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the Project Applicant/Lead Agency upon written request to the Tribe.

D. Onsite tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Kizh from a designated point of contact for the Project Applicant/Lead Agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the Project site or in connection with the Project are complete; or (2) a determination and written notification by the Kizh to the Project Applicant/Lead Agency that no future, planned construction In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-10
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
activity, and/or development/construction phase at the Project site possesses the potential to impact Kizh TCRs.

E. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Consulting Tribe(s), Kizh monitor and/or Kizh archaeologist. The Consulting Tribe(s) or Kizh will recover and retain all discovered TCRs in the form and/or manner the Consulting Tribe(s) deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

MM TCR-2: Unanticipated Discovery of Human Remains and Associated Funerary Objects.

A. Native American human remains are defined in PRC 5097.98(d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98 are also to be treated according to this statute.

B. If Native American human remains and/or grave goods are discovered or recognized on the Project site, then all construction activities shall immediately cease. Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determinate the nature of the remains. If the coroner recognized the human remains to be those of a Native American, or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

D. Construction activities may resume in other parts of the Project site at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Kizh determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the Project manager express consent of that determination (along with any other mitigation measures the Kizh monitor and/or archaeologist deems necessary). (CEQA Guidelines Section 15064.5(f).) In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-11
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
E. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any historic archaeological material that is not Native American in origin (non-TCR) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

F. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

MM TCR-3: Procedures for Burials and Funerary Remains.

A. As the Most Likely Descendant (“MLD”), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains.

B. If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

C. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

D. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24- hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and In Construction Plans and
Specifications. Prior to
Grading Permit.

City of Redlands Planning
Division
The Grand Project 3. Mitigation Monitoring and Reporting Program City of Redlands
Final SCEA 3-12
August 2022
Plan, Program, Policy / Mitigation Measure Timing
Responsible for
Ensuring Compliance /
Verification
Date Completed
and Initials
protected. If the Project cannot be diverted, it may be determined that burials will be removed.

E. In the event preservation in place is not possible despite good faith efforts by the Project Applicant/developer and/or landowner, before ground-disturbing activities may resume on the Project site, the landowner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects.

F. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. The site of reburial/repatriation shall be on the project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

G. The Consulting Tribe(s) will work closely with the Project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Consulting Tribe(s), documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recovery-related forms of documentation shall be approved in advance by the Consulting Tribe(s). If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

The Grand Project Chapter 2. Response to Public Comments

2. 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 Grand Project during the public review period, which began July 14, 2022 and closed August 12, 2022 (SCH No. 2022070225). 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. Yuhaaviatam of San Manuel Nation, Received August 11, 2022 (1 page) O2. Lozeau Drury LLP, Received August 11, 2022 (23 pages) I1. T. Allen Jolliff, Received July 30, 2022 (1 page)
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 Grand SCEA.

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 Grand Project Chapter 2. Response to Public Comments City of Redlands 2-2
Final SCEA
August 2022
Letter O1: Yuhaaviatam of San Manuel Nation, Received August 11, 2022 The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-3
Final SCEA
August 2022
RESPONSE TO LETTER O1: Yuhaaviatam of San Manuel Nation Comment O1.1: This comment states that the Tribe agrees with the cultural resources report’s recommendation for an archaeological testing plan that would occur after all existing structures have been removed and that the Tribe hopes to continue to consult on the Project as it moves forward. Written notice was previously provided to the Yuhaaviatam of San Manuel Nation in accordance with California Government Code §65352.3 and Public Resources Code §21080.3.1 in the letter mailed to the Tribe on April 26, 2022. The Tribe responded on May 25, 2022 stating that the Tribe did not have any input on the Project and no additional consultation under SB 18 was required. Tribal consultation for the Project is discussed in Section 6.3.18 of the SCEA (see pages 195-199). Furthermore, Mitigation Measures TCR-1 through TCR-3 are included, which reduce any potential impacts to tribal cultural resources to a less than significant level. The comment does not raise any further environmental concerns or questions; therefore, no further response is warranted. The comment will be forward to City decision-makers.

The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-4
Final SCEA
August 2022
Letter O2: Lozeau Drury, LLP, on behalf of Supporters Alliance for Environmental Responsibility Received August 11, 2022
The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-5
Final SCEA
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RESPONSE TO COMMENT LETTER O2: Lozeau Drury, LLP
Response to Comment O2.1: This comment provides background on the Project and introduces the comment letter. Comment O2.1 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.1 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.2: This comment states that SAFER requests that the Planning Division refrain from taking any action on the Project and SCEA because the SCEA’s conclusions about the Project’s impacts to air quality are not supported by substantial evidence. In addition, the comment requests that the City prepare an EIR for the Project. Comment O2.2 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA.

Comment O2.2 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.3: This comment provides a summary of the proposed Project description.

Comment O2.3 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.3 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.4: This comment provides a background summary of the purpose, use, and legal background of a SCEA and provides a summary of SCAG’s 2020-2045 RTP/SCS. Comment O2.4 is introductory in nature and does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.4 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.5: This comment states that air quality experts reviewed the SCEA and found that the SCEA’s conclusions related to the Project’s air quality impacts are not supported by substantial evidence. The comment provides an introduction to Exhibit A to the comment letter, which details Mr.

Offerman’s assessment that the SCEA failed to address and mitigate the human health impacts from indoor emissions of formaldehyde. Comment O2.5 is introductory in nature does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA.

Comment O2.5 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.6: This comment states that the SCEA fails to disclose, analyze and mitigate the significant health risks posed by the Project from formaldehyde, a toxic air contaminant (TAC) to future residents and employees of the Project. The comment further states that emissions of indoor formaldehyde would surpass SCAQMD’s threshold for TACs and the Project would have a significant adverse impact and that carcinogenic formaldehyde emissions are not an existing environmental condition. The comment concludes by stating that the City must include an analysis of formaldehyde associated health risks within an EIR and identify appropriate mitigation measures. As stated within the SCEA on page 135, the proposed Project would be required to comply with the California Green Building Standards Code (CALGreen) Sections

4.504.5 and 5.504.4.5. Furthermore, composite wood products used within the Project must be compliant with the California Air Resource Board (CARB) Airborne Toxic Control Measures Phase II or Toxic Substances Control Act (TSCA) Title VI. These state regulations along with Cal/OSHA are the main regulators of indoor formaldehyde products.

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The comment does not describe how the asserted formaldehyde related cancer risk of 120 per million would occur and does not identify any Project-specific conditions (other than the fact that the Project' s construction may use wood building materials) that would lead to impacts. Current federal and state regulations exist, which limit the potential formaldehyde emissions from building materials. On June 1, 2018, the U. S. Toxic Substances Control Act (TSCA) Title VI was implemented, which requires composite wood products sold, supplied, offered for sale, manufactured, or imported in the United States are required to meet new emission standards for formaldehyde from composite wood products to reduce exposures to formaldehyde and avoid adverse health effects. Typical composite wood products include hardwood plywood, medium-density fiberboard, and particleboard, as well as household and other finished goods containing these products.

The new emission limits include the following:
• Hardwood Plywood: 0.05 parts per million (ppm)
• Particleboard: 0.09 ppm
• Medium - density fibreboard: 0. 1 1 ppm
• Thin Medium -density fibreboard: 0. 13 ppm
These emission levels were determined to be in compliance with and result in less exposure (e. g., daily intake) than the California Proposition 65 safe harbor level for formaldehyde (40 μg/ day), which is based on Proposition 65' s risk criterion of 1 in 100, 000. Thus, products manufactured to TSCA Title VI and California Proposition 65 safe harbor standards, which is now required by the U. S. EPA for all products manufactured or imported into the United States, would not generate formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million.

CARB identifies that these standards are projected to lead to a reduction in statewide formaldehyde emissions of 500 tons per year. Reduced risk of cancer from formaldehyde exposure is also a resulting benefit, and implementation of these standards is estimated to reduce excess cancer cases per million people from formaldehyde exposure by about 40 percent1. The CalGreen Building Code also includes similar formaldehyde limits for building products.

The Project would be implemented pursuant to these formaldehyde requirements, as all products manufactured or imported in the United States would be required to meet these regulations. This would limit the potential of human health and cancer risks to a less than significant level pursuant to the SCAQMD significance threshold of 10 per million. Thus, building material manufacturer compliance with existing regulations would avoid potentially significant impacts related to formaldehyde. Thereby, the Project would also result in less than significant impacts. Comment O2.6 does not provide accurate evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA.

Comment O2.6 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.7: This comment states that an EIR should be prepared for the proposed Project or the SCEA should be revised prior to any further action on the Project. As substantiated by Response to Comments O2.1 through O2.6 and O2.8 through O2.17, none of the comments within the organization’s comment letter provide evidence of significant impacts that would require preparation of an EIR or that would require substantial changes to the SCEA. No further response is warranted.

Response to Comment O2.8: This comment provides a summary of indoor air pollutants. The commenter is referred to the discussion in Response to Comment O2.6. Comment O2.8 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review 1 https:// www.arb.ca.gov/ toxics/ compwood/ implementation/ faq.htm# G The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-29
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SCEA. Comment O2.8 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.9: This comment provides a summary of indoor formaldehyde concentrations in new construction and its associated cancer risks. The commenter is referred to the discussion in Response to Comment O2.6. Comment O2.9 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.9 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.10: This comment states that residential occupants and employees of the Project would have a continuous exposure to formaldehyde, which would result in significant cancer risks. The commenter is referred to the discussion in Response to Comment O2.6. Furthermore, the commenter significantly overestimates the amount of daily formaldehyde exposure to residents. First, the commenter assumes that residential occupants would inhale 20 cubic meters of air per day yet cites no evidence to substantiate this assumption. According to the American Lung Association, the average person inhales approximately 2,000 gallons of air per day, or roughly 7.57 cubic meters per day.2 Second, the commenter incorrectly applies an entire 70-year average lifetime (24 hours per day from birth to death) to calculate residential formaldehyde exposure, thus vastly overestimating any potential formaldehyde exposure to residents who would occupy the Project. This means that residents would live in their units 24 hours per day for their entire lives. Estimates of how many times a person living in the United States moves in his or her lifetime have ranged from 9 times to 11 times, depending on age, race, and socioeconomic status, among other categories.3 Thus, it is speculative and inaccurate to assume that the initial residents who occupy the Project would remain for the remaining duration of their lives. Therefore, the commenter does not provide credible evidence of significant impacts related to indoor air quality.

Moreover, within Appendix A, the commenter is speculating that composite wood materials would be used in the interior of the building. Indoor building materials will not be known until the building permit stage. As such, any further analysis on the content of indoor building materials would be speculative.

Therefore, Comment O2.10 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.10 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.11: This comment provides a formaldehyde emissions assessment that the commenter states should be used in the SCEA. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.11 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.11 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.12: This comment states that outdoor ventilation is an important factor influencing the indoor concentrations of air contaminants. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.12 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.12 and 2 American Lung Association, How Your Lungs Get the Job Done, website: https://www.lung.org/blog/how-yourlungs-work, accessed February 2022. 3 United States Census Bureau, Calculating Migration Expectancy Using ACS Data, website:
https://www.census.gov/topics/population/migration/guidance/calculating-migration-expectancy.html, accessed February 2022; FiveThirtyEight, How Many Times Does The Average Person Move, website:
https://fivethirtyeight.com/features/how-many-times-the-average-person-moves/, accessed February 2022 .

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this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.13: This comment states that the Project is close to roads with moderate to high traffic as well as air traffic from the San Bernardino International Airport. The comment states that as a result of the high outdoor noise levels, the Project will require a mechanical supply of outdoor air ventilation to allow for a habitable indoor environment. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.13 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.13 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.14: The comment states that an air quality analysis should be conducted to determine the concentrations of PM2.5. This comment states that based on the traffic in the area, the Project may warrant the installation of high efficiency air filters. The commenter is requesting the installation of MERV 13 or higher, this is now a Title 24 requirement by which the Project will comply. The commenter is referred to the 2019 Title 24 Building Energy Efficiency Standards Section 120.14. Comment O2.14 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.14 and this response will be forwarded to all decisionmaking bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.15: This comment provides recommended mitigation measures to minimize impacts to indoor air quality from formaldehyde. As impacts are less than significant, no mitigation measures are warranted. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10.

Comment O2.15 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.15 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.16: This comment provides recommended mitigation measures for outdoor air ventilation. As impacts are less than significant, no mitigation measures are warranted. The commenter is referred to the discussion in Response to Comment O2.6 and O2.10. Comment O2.16 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.16 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Response to Comment O2.17: This comment provides recommended mitigation measures for air filtration.

The commenter is requesting the installation of MERV 13 or higher, this is now a Title 24 requirement by which the Project will comply. The commenter is referred to the 2019 Title 24 Building Energy Efficiency Standards Section 120.15. Comment O2.17 does not provide evidence of significant impacts that require the preparation of an EIR or that would require changes to the Public Review SCEA. Comment O2.17 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.
4 https://energycodeace.com/site/custom/public/reference-ace2019/index.html#!Documents/section1201requirementsforventilationandindoorairquality.htm) 5 https://energycodeace.com/site/custom/public/reference-ace2019/index.html#!Documents/section1201requirementsforventilationandindoorairquality.htm) The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-31
Final SCEA
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Letter I1: T. Allen Jolliff, Received July 30, 2022
The Grand Project Chapter 2. Response to Public Comments City of Redlands 2-32
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RESPONSE TO LETTER I1: T. Allen Jolliff
Comment I1.1: This comment states that if these units are multi-family, there should be at least two parking spaces per unit. In addition, the comment states that there is no mention of how bikes would be secured if families are supposed to rely on bikes.

Parking or a lack of parking is not considered an environmental impact under CEQA. However, pursuant to City of Redlands Municipal Code Section 18.92.080, with a Conditional Use Permit, only 1 parking space is required for units up to 999 square feet (SF), 1.5 space is required for units 1,000 to 1,499 SF, and 2 spaces are required for units greater than 1,500 SF. As discussed within the SCEA and shown on Figure 3-1, Conceptual Site Plan, Parking Level, the Project would include multiple bike storage rooms and bike maintenance rooms adjacent to the parking garage. This comment does not raise a specific issue with the adequacy of the SCEA or raise any other CEQA issues. Therefore, no further response is required. -1-
RESOLUTION NO. 8389

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS

ADOPTING THE INITIAL STUDY AND SUSTAINABLE COMMUNITIES

ENVIRONMENTAL ASSESSMENT (SCEA) DOCUMENT PREPARED FOR
THE PROPOSED “THE GRAND” MULTIFAMILY RESIDENTIAL PROJECT.

WHEREAS, Vantage One Real Estate Investments (“Applicant”) has submitted a development application for Commission Review & Approval No. 911 to construct 145 apartment units in a four-story building including subterranean and surface level structured parking, courtyard, and common space amenities on approximately 1.49 acres located at 200-206 West Redlands Boulevard (APNs: 0169-281-30-0000 and 0169-281-31-0000); and WHEREAS, the Applicant has submitted a legislative application for Specific Plan Amendment No. 23 to the Downtown Specific Plan (Specific Plan No. 45); and WHEREAS, the Applicant has submitted an application for Tentative Parcel Map No. 20175 to consolidate two parcels into one parcel 1.49-acres in size for development purposes; and
WHEREAS, the above-referenced applications filed with the City of Redlands are referred to hereinafter as the “Project” and “Project Entitlements;” and WHEREAS, the State of California adopted Senate Bill 375 (SB 375), also known as “The Sustainable Communities and Climate Protection Act of 2008,” which outlines growth strategies that better integrate regional land use and transportation planning, and that help meet the State’s greenhouse gas (GHG) emission reduction mandates; and
WHEREAS, SB 375 provides various California Environmental Quality Act (CEQA) streamlining provisions for projects that are consistent with an adopted applicable “sustainable communities strategy” and meet certain objective criteria, and one such CEQA streamlining tool is the Sustainable Communities Environmental Assessment (SCEA) process; and WHEREAS, the Southern California Association of Governments (SCAG) is the metropolitan planning organization for the County of San Bernardino including the City of Redlands, and SCAG’s Regional Council adopted the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020-2045 RTP/SCS) on September 3, 2020; and WHEREAS, SB 375 allows the City of Redlands, acting as the CEQA Lead Agency, to prepare a SCEA as the environmental CEQA clearance for “transit priority projects” that are consistent with SCAG’s 2020-2045 RTP/SCS; and
WHEREAS, SB 375 provides CEQA streamlining benefits to qualifying “transit priority projects.” For purposes of projects in the SCAG region, a qualifying transit priority project is a project that meets the following four criteria (see Public Resources Code §21155 (a) and (b)), and the proposed State Street Village project meets these criteria:
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a. Is consistent with the general use designation, density, building intensity, and applicable policies specified for the project area in the SCAG 2020-2045 RTP/SCS; b. Contains at least 50 percent residential use, based on total building square footage and, if the project contains between 26 and 50 percent nonresidential uses, a floor area ratio of not less than 0.75;
c. Provides a minimum net density of at least 20 dwelling units per acre; and d. Is within one-half mile of a major transit stop or high-quality transit corridor included in a regional transportation plan.

WHEREAS, qualifying transit priority projects that have incorporated all feasible mitigation measures, performance standards, or criteria set forth in the prior applicable EIR (SCAG’s 2020- 2045 Regional Transportation Plan/Sustainable Communities Strategy Program EIR), and that are determined to not result in significant and unavoidable environmental impacts, may be approved with a Sustainable Communities Environmental Assessment (SCEA); and WHEREAS, pursuant to section 21067 of the Public Resources Code, and section 15367 of the State California Environmental Quality Act (“CEQA”) Guidelines (Cal. Code Regs., title 14, § 15000 et seq.), the City of Redlands is the lead agency for the proposed Project; and WHEREAS, the proposed Initial Study/SCEA prepared for the proposed Project was circulated for a public review/comment period of thirty (30) days beginning on July 14, 2022, and ending on August 12, 2022; and
WHEREAS, the Notice of Availability (NOA) and Notice of Intent (NOI) to adopt a Sustainable Communities Environmental Assessment was published in the Redlands Daily Facts, a newspaper of general circulation, on July 13, 2022; and WHEREAS, the Notice of Availability (NOA) and Notice of Intent (NOI) to adopt a Sustainable Communities Environmental Assessment was posted for public review/comment by the San Bernardino County Clerk of the Board on July 13, 2022, and by the State Clearinghouse website on July 14, 2022 (SCH No. 2022070225); and
WHEREAS, consistent with CEQA and the State CEQA Guidelines, the City prepared a Final Sustainable Communities Environmental Assessment (“Final SCEA”), consisting of the Draft SCEA, all technical appendices prepared in support of the Draft SCEA, all comment letters received on the Draft SCEA, written responses to all comment letters received on the Draft SCEA, and errata to the Draft SCEA and technical appendices; and
WHEREAS, the Sustainable Communities Environmental Assessment consists of the Final SCEA and its attachments and appendices, as well as the Draft SCEA and its attachments and appendices (as modified by the Final SCEA); and
WHEREAS, on August 30, 2022, the Planning Commission held a public hearing at the City Council Chambers on at a special meeting, notice of said public hearing having been duly given as required by law and in accordance with the provisions of the Government Code and Redlands -3-
Municipal Code, and considered the Initial Study/SCEA, written comments submitted during the 30- day public review period, and the testimony and any written evidence submitted by members of the public; and
WHEREAS, on September 23, 2022, notice of the public hearing before the City Council for the Project and Initial Study/SCEA was published in the Redlands Daily Facts and notices were mailed to property owners within a 300-foot radius, and notice of said public hearing having been duly given as required by law and in accordance with the provisions of the Government Code and Redlands Municipal Code; and
WHEREAS, on October 4, 2022, the City Council held a public hearing at the City Council Chambers, and considered the Initial Study/SCEA, written comments submitted during the 30-day public review period, and the testimony and any written evidence submitted by members of the public.

NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS AS FOLLOWS:

SECTION 1. CALIFORNIA ENVIRONMENTAL QUALITY ACT. The proposed Project is subject to the California Environmental Quality Act (CEQA), the City has prepared an Initial Study and Sustainable Communities Environmental Assessment (SCEA) for the Project, exercised its own independent judgment and analysis and there is no substantial evidence that the proposed project may have any significant effects on the environment, the custodian of records is the Planning Division of the Development Services Department, and the SCEA document has been prepared in accordance with Public Resources Code Section 21155.2(b) and applicable provisions of the State CEQA Guidelines.

SECTION 2. INDEPENDENT JUDGMENT OF LEAD AGENCY. The Sustainable Communities Environmental Assessment (SCEA) prepared for the Project reflects the City’s independent judgment and analysis. The City has exercised independent judgment and analysis in accordance with Public Resources Code Section 21082.1(c)(3) in managing as appropriate the environmental consultant, and directing the consultant in the preparation of the SCEA and related technical studies and analyses. The City Council has independently reviewed and analyzed the SCEA and accompanying technical studies/reports, and finds that the SCEA reflects the independent judgment and analysis of the City.

SECTION 3. REQUIRED FINDINGS. The City of Redlands finds, based on the information contained in Section 2 (Environmental Setting), Section 3 (Project Description), Section 4 (Sustainable Communities Environmental Assessment Criteria), Section 5 (Incorporation of 2020- 2045 RTP/SCS Program EIR Mitigation Measures), and Section 6 (Sustainable Communities Environmental Analysis/Checklist) of the Initial Study/SCEA, that preparation of a Sustainable Communities Environmental Assessment (SCEA) in accordance with Public Resources Code Section 21155.2(b) is appropriate for the Project for the following reasons:
a. The Project is consistent with the general use designations, density, building intensity, and applicable policies specified for the area of the Project site in the 2020- -4-
2045 RTP/SCS prepared by SCAG, which is the metropolitan planning organization for the City of Redlands;
b. The State Air Resources Board, pursuant to subparagraph (H) of paragraph (2) of subdivision (b) of Section 65080 of the Government Code, has accepted SCAG’s determination that the sustainable communities strategy adopted by SCAG in the 2020-2045 RTP/SCS would, if implemented, achieve the GHG emission reduction targets;
c. The Project qualifies as a transit priority project pursuant to Public Resources Code Section 21155, in that: the Project contains more than 50 percent residential use; provides a minimum net density greater than 20 units an acre; and is within one-half mile of a major transit stop or high-quality transit corridor included in a regional transportation plan;
d. The Project is a residential or mixed-use project as defined by Public Resources Code Section 21159.28(d);
e. The Project incorporates all feasible mitigation measures, performance standards, or criteria set forth in the prior environmental reports and adopted findings made pursuant to PRC Section 21081, including the 2020-2045 RTP/SCS Program EIR; f. All potentially significant or significant effects required to be identified and analyzed pursuant to CEQA in an Initial Study have been identified and analyzed in an Initial Study; and,
g. As outlined in detail in Section 6, Sustainable Communities Environmental Analysis/Checklist, changes or alterations have been required in or incorporated into the Project that avoid or mitigate the significant effects to a level of less than significant.

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