Cities Index.
Agenda packet

Redlands City Council
October 18, 2022

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Agenda packet
Meeting
October 18, 2022
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Redlands City Council
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12
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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.

In 2020, 6,620 AF of wastewater was treated at the City’s Wastewater Treatment Plant. In 2020, 3,813 AF were treated to a secondary level and released to spreading basins east of the City’s Wastewater Treatment Plant for percolation into the Bunker Hill groundwater basin, while 1,806 AF were treated to a tertiary level and distributed as recycled water (UWMP 2020).

The wastewater system has one lift station that serves the western-most portion of the city south of Interstate 10 (I-10). The collections system in the City of Redlands consists of approximately 250 miles of pipelines.

Within the TVSP area, wastewater pipelines range from 6-inches to 48-inches in diameter.

Stormwater
The City of Redlands’ stormwater drainage system serves an area of approximately 37 square miles. The Downtown stormwater drainage system is composed of reinforced concrete pipe (RCP) and corrugated metal pipe (CMP) with diameters ranging from 8 inches to 96 inches, box culverts, covered rubble rock and concrete channels, and concrete and natural drains. Stormwater runoff from the City’s drainage systems flows by gravity into the Mission Channel, Morrey Arroyo Creek, and San Timoteo Canyon, and discharges to the Santa Ana River.

Drainage throughout the TVSP area is generally from east to west to one of two main existing major stormwater drainage facilities. The existing stormwater drainage system within the TVSP area lacks capacity, as evidenced by flooding within the Downtown area during storm events. The main cause of flooding within the TVSP area is the lack of capacity in the Zanja, the Redlands Boulevard Storm Drain, and the Oriental Storm Drain. With a stormwater capacity of approximately 2,400 cubic feet per second (cfs), the Redlands Boulevard Storm Drain can receive approximately 4,200 cfs from the Zanja and the Carrot Storm Drain and 4,000 cfs from the Reservoir Canyon and Oriental Storm Drains. These tributaries result in a confluence of stormwater within the Redlands Boulevard Storm Drain near the intersection of Redlands Boulevard and Ninth Street, which can lead to flooding. In 2017, the City adopted the 2017 Master Plan of Drainage.

Solid Waste
Solid waste collection services are provided within the TVSP area by the City of Redlands. The City’s Quality of Life Department provides residential waste collection, green waste collection for yard waste, and curbside recycling. Hazardous and electronic waste is managed by the Redlands Fire Department, which operates a household hazardous and electronic waste disposal site on a weekly basis.

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Redlands General Plan Transit Villages District and Specific Plan Project 4. Environmental Setting City of Redlands, CA 4-26
Draft EIR
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Solid waste from the TVSP area is primarily disposed of at the California Street Landfill operated by the City of Redlands Quality of Life Department and the San Timoteo Sanitary Landfill operated by the County, both within the city limits. The California Street Landfill is located at 2151 Nevada Street and encompasses 115 acres and is permitted to operate through 2042. The California Street Landfill design capacity is 11.4 million cubic yards, and its maximum permitted throughput is 829 tons per day. It has a remaining capacity of 5,168,182 cubic yards. In 2020, the California Street Landfill received an average throughput of 146 tons per day (CalRecycle, 2022). Based on the average throughput received per day, the California Street Landfill has an approximate extra capacity of 683 tons per day.

The San Timoteo Sanitary Landfill is located on San Timoteo Canyon Road and is 366 acres in size and is permitted to operate through 2039. It has a permitted capacity of 23,685,785 cubic yards and a maximum permitted daily throughput of 2,000 tons. It has a remaining capacity of 12,360,396 cubic yards. In 2020, the San Timoteo Sanitary Landfill received an average throughput of 772 tons per day (CalRecycle, 2022).

Based on the average throughput received per day, the San Timoteo Sanitary Landfill has an approximately extra capacity of 1,228 tons per day.

REFERENCES
City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/post/planning-divisiongeneral-plan City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Jurisdictional Disposal and Alternative Daily Cover Tons by Facility. CalRecycle. https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFacility Landfill Tonnage Reports. CalRecycle. https://www2.calrecycle.ca.gov/LandfillTipFees/ Material Cultural Consulting. Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments (MCC 2022). January 2022. Appendix C.

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Redlands General Plan Transit Villages District and Specific Plan Project 5. Environmental Impact Analysis City of Redlands, CA 5-1
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5.0 Environmental Impact Analysis
Chapter 5 examines the environmental setting of the Project, analyzes its effects and the significance of its impacts, and recommends mitigation measures to reduce or avoid impacts. This chapter has a separate section for each environmental issue area that was determined to need further study in the Draft EIR. This scope was determined in the Initial Study and Notice of Preparation (NOP), which was published September 1, 2021, and through public and agency comments received during the NOP comment period that ended on September 30, 2021 (see Appendix A). Environmental issues and their corresponding sections are:

5.1 Aesthetics

5.2 Air Quality

5.9 Land Use and Planning

5.10 Noise

5.3 Cultural Resources 5.11 Population and Housing

5.4 Energy

5.5 Geology and Soils

5.6 Greenhouse Gas

5.7 Hazards and Hazardous Materials

5.8 Hydrology and Water Quality

5.12 Public Services

5.13 Recreation

5.14 Transportation

5.15 Tribal Cultural Resources

5.16 Utilities and Service Systems
This Draft EIR evaluates the direct and indirect impacts resulting from the planning, construction, and operations of the Project. Under CEQA, EIRs are intended to focus their discussion on significant impacts and may limit discussion of other impacts to a brief explanation of why the impacts are not significant.

Format of Environmental Topic Sections
Each environmental topic section generally includes the following main subsections:
• Introduction: This describes the purpose of analysis for the environmental topic and referenced documents used to complete the analysis. This subsection may define terms used. • Regulatory Setting: This subsection describes applicable federal, state, and local plans, policies, and regulations that the Project must address and may affect its implementation. • Environmental Setting: This subsection describes the existing physical environmental conditions (environmental baseline) related to the environmental topic being analyzed. • Thresholds of Significance: This subsection sets forth the thresholds of significance (significance criteria) used to determine whether impacts are “significant.” The thresholds of significance used to assess the significant of impacts are based on those provided in Appendix G of the CEQA Guidelines.
• Methodology: This subsection provides a description of the methods used to analyze the impact and determine whether it would be significant or less than significant. • Environmental Impacts: This subsection provides an analysis of the impact statements for each identified significance threshold. The analysis of each impact statement is organized as follows:
o A statement of the CEQA threshold being analyzed,
o The Draft EIR’s conclusion as to the significance of the impact.

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Redlands General Plan Transit Villages District and Specific Plan Project 5. Environmental Impact Analysis City of Redlands, CA 5-2
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o An impact assessment that evaluates the changes to the physical environment that would result from the Project.
o An identification of significance comparing identified impacts of the Project to the significance threshold with implementation of existing regulations, prior to implementation of any required mitigation.
• Cumulative Impacts: This subsection describes the potential cumulative impacts that would occur from the Project’s environmental effects in combination with other cumulative projects (See Table 4- 8).
• Existing Regulations and Regulatory Requirements. A list of applicable laws and regulations that would reduce potentially significant impacts.
• Level of Significance Before Mitigation. A determination of the significance of the impacts after the application of applicable existing regulations and regulatory requirements. • Mitigation Measures. For each impact determined to be potentially significant after the application of applicable laws and regulations, feasible mitigation measure(s) to be implemented are provided.

Mitigation measures include enforceable actions to:
o avoid a significant impact;
o minimize the severity of a significant impact;
o rectify an impact by repairing, rehabilitating, or restoring the effected physical environment;
o reduce or eliminate the impact over time through preservation and/or maintenance operations during the life of the project; and/or
o compensating for the impact by replacing or providing substitute resources or environmental conditions.
• Level of Significance after Mitigation. This section provides the determination of the impact’s level of significance after the application of regulations, regulatory requirements, and mitigation measures.

Impact Significance Classifications
The below classifications are used throughout the impact analysis in this Draft EIR to describe the level of significance of environmental impacts. Although the criteria for determining significance are different for each topic area, the environmental analysis applies a uniform classification of the impacts based on definitions consistent with CEQA and the CEQA Guidelines. • No Impact. The Project would not change the environment. • Less Than Significant. The Project would not cause any substantial, adverse change in the environment.
• Less Than Significant with Mitigation Incorporated. The Draft EIR includes mitigation measures that avoid substantial adverse impacts on the environment.
• Significant and Unavoidable. The Project would cause a substantial adverse effect on the environment, and no feasible mitigation measures are available to reduce the impact to a less than significant level.

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Redlands General Plan Transit Villages District and Specific Plan Project 5.1 Aesthetics City of Redlands, CA 5.1-1
Draft EIR
July 2022

5.1 Aesthetics

5.1.1 INTRODUCTION
This section describes the existing visual setting and aesthetic character of the Project site and vicinity and evaluates the potential for the Project to impact scenic vistas, visual character and quality, and light and glare. This analysis focuses on changes that would be seen from public viewpoints and provides an assessment of whether aesthetic changes from implementation of the Project would result in substantially degraded aesthetic conditions. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035, December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), Dyett & Bhatia, July 2017; and
• City of Redlands Municipal Code.

Aesthetics Terminology
• Aesthetic Resources include a combination of numerous elements, such as landforms, vegetation, water features, urban design, and/or architecture, that provide an overall visual impression that is pleasing to, or valued by, its observers. Factors important in describing the aesthetic resources of an area include visual character, scenic resources, and scenic vistas. These factors together not only describe the intrinsic aesthetic appeal of an area, but also communicate the value placed upon a landscape or scene by its observers.
• Scenic Resources are visually significant hillsides, ridges, water bodies, and buildings that are critical in shaping the visual character and scenic identity of the area and surrounding region. • Scenic Vistas are defined as panoramic views of important visual features, as seen from public viewing areas. This definition combines visual quality with information about view exposure to describe the level of interest or concern that viewers may have for the quality of a particular view or visual setting.
• Visual Character broadly describes the unique combination of aesthetic elements and scenic resources that characterize a particular area. The quality of an area’s visual character can be qualitatively assessed considering the overall visual impression or attractiveness created by the particular landscape characteristics. In urban settings, these characteristics largely include land use type and density, urban landscaping and design, architecture, topography, and background setting.

5.1.2 REGULATORY SETTING

5.1.2.1 Local Regulations
City of Redlands General Plan 2035
City policies pertaining to visual character are contained in the Distinctive City, Livable Community, and Vital Environment Chapters of the Redlands General Plan. The following goals and policies from the Redlands General Plan are relevant to the proposed Project:

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Redlands General Plan Transit Villages District and Specific Plan Project 5.1 Aesthetics City of Redlands, CA 5.1-2
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Principle 2-P.8 Identify, maintain, protect, and enhance Redlands’ cultural, historic, social, economic, architectural, agricultural, archaeological, and scenic heritage. In so doing, Redlands will preserve its unique character and beauty, foster community pride, conserve the character and architecture of its neighborhoods and commercial and rural areas, enable citizens and visitors to enjoy and learn about local history, and provide a framework for making appropriate physical changes.

Principle 2-P.13Encourage preservation of and public access to defined and established significant scenic vistas, viewpoints, and view corridors.

Action 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.

Action 2-A.28 Develop strategies or guidelines to enhance the public realm and context sensitive landscapes in the historic and scenic districts.

Action 2-A.29 Retain existing easements and rights of way for use as viewpoints, turnouts, and scenic walkways where feasible.

Action 2-A.30 Identify historic design features characteristic of the city and its individual neighborhoods that can be used to establish themes and design guidelines.

Action 2-A.34 Uphold the designation of the following streets within the city as scenic highways, drives, and historic streets. Special development standards have been adopted by Resolution for these streets. The streets are:
• Brookside Avenue, from Lakeside Avenue to Eureka Street; • Olive Avenue, from Lakeside Avenue to Cajon Street;
• Center Street, from Brookside Avenue to Crescent Avenue; • Highland Avenue, from Serpentine Drive to Cajon Street; • Sunset Drive, from Serpentine Drive to Edgemont Drive; • Cajon Street;
• Mariposa Drive, between Halsey and Sunset Drive; and
• Dwight Street, between Pepper Street and Mariposa Drive.

In addition, consider designating the following roads as scenic drives within the community as neighborhood connectors and recreational routes for drivers and bike riders. • Riverview Drive along the Santa Ana River Wash;
• Live Oak Canyon Road;
• San Timoteo Canyon Road;
• Sylvan Boulevard;
• Nevada Street, from the Orange Blossom Trail to Barton Road; • Pioneer Avenue, from River Bend Drive to Judson Street; and • Rural roads in Crafton.

Action 2-A.35 Establish standards for the evaluation of exterior lighting for new development and redevelopment to ensure that exterior lighting (except traffic lights, navigational lights, and other similar safety lighting) is minimized, restricted to low-intensity fixtures, shielded, and concealed to the maximum feasible extent, and that high-intensity perimeter lighting and Redlands Regular Meeting of 10-18-22 715 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 5.1 Aesthetics City of Redlands, CA 5.1-3
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lighting for sports and other private recreational facilities is limited to reduce light pollution visible from public viewing areas.

Action 2-A.38 Use exemplary design quality and sensitivity to surrounding historic structures in new City construction, public works, entry ways, and City signs.

Action 2-A.39 Ensure that permanent changes to the exterior or setting of a designated historic resource be done in accordance with the Secretary of the Interior standards for historic properties.

Action 2-A.42 Should demolition of a designated historic resource occur, endeavor to ensure that a building of equal or greater design quality and/or use of equal or greater benefit to the community be constructed. Require that a report documenting the history of the property and archivalquality drawings and/or photographic records be prepared to document the historic resource.

Action 2-A.49 Encourage compatibility of new land uses and new construction adjacent to historical buildings. Encourage construction that is physically and aesthetically complementary to the historic buildings in architectural features and relationship to adjoining structures.

Action 2-A.67 Permit densities, design, and uses that will help preserve the character and amenities of existing older neighborhoods.

Principle 2-P.21 Encourage conservation and preservation of citrus groves and farms, especially those that have cultural or scenic significance. Encourage retention of existing privately-owned citrus groves of all sizes.

Principle 2-P.23Incorporate citrus trees, in groves of sufficient size and depth to be a viable grove, as part of streetscapes and scenic views, and encourage their conservation in historic neighborhoods.

Action 2-A.92 Provide public improvements for traffic and pedestrian circulation, flood control, utility services, and aesthetic amenities that will attract new private investment and economic development.

Action 2-A.100 Encourage public art and community gatherings through a wide range of visual and physical forms—from banners on light posts, paving and artwork on sidewalks, murals, light displays at night, music, and sculptures, to the design and shaping of public spaces and plazas—all of which set the stage for people to gather, play, and observe. Build on existing activities and events and incorporate facilities to support them.

Principle 4-P.10Ensure that the scale and character of new development is appropriate for surrounding terrain and the character of existing development.

Action 4-A.32 Discourage larger-scale warehouses and big box architecture that would negatively impact aesthetics such as long, blank walls. Break up the massing of larger structures through setbacks and indentation of facades, appropriate fenestration of windows and doors, and a variety of architectural treatments.

Principle 4-P.40Encourage the revitalization of the commercial corridors on Colton Avenue at Orange Street by providing opportunities for a variety of commercial uses and providing guidelines for site design to create a more welcoming visual environment.

Principle 4-P.51Complete a Transit Village Plan that will define: village character, design guidelines for architecture and site development, permitted and conditional uses, building setbacks and heights, yards, interfaces with the public streets and sidewalks, security measures, and transitions to existing neighborhoods.

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Redlands General Plan Transit Villages District and Specific Plan Project 5.1 Aesthetics City of Redlands, CA 5.1-4
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Action 4-A.102 Create a “sense of arrival” at the city’s western gateway through aesthetic improvements such as landscaping, citrus groves, and signage.

City of Redlands Municipal Code
Chapter 2.24, Historic and Scenic Preservation Commission Chapter 2.24 of the Redlands Municipal Code establishes the City’s Historic and Resource Preservation Commission. The Commission has the responsibility of making a recommendation to the City Council on the formation of a Historic District, a geographical area that has a significant architectural enclave of historic buildings or scenic vistas. Properties of scenic significance, as defined by the Municipal Code, may include landscaping, light standards, trees, curbing, and signs that contribute aesthetically to the scenic heritage of the city.

Section 18.12.170, Architectural Review; Criteria
City of Redlands architectural review criteria pursuant to Section 18.12.170 of the City of Redlands Municipal Code establishes architectural criteria for development located within the City. These criteria are intended to provide design professionals, property owners, residents, staff, and decision makers with a clear and common understanding of the City’s expectations for the planning, design, and review of development proposals. According to RMC Section 18.12.170(B), conformance is to be evaluated based on consideration of the following criteria:

1. Site layout, orientation, location of structures and relationship to one another, as well as open spaces and topography;

2. Harmonious relationship of building with existing and proposed adjoining developments;

3. Maximum height, area, setbacks and overall mass of buildings, as well as other structures such as walls, screens, towers or signs, and effective concealment of all mechanical equipment;

4. Harmony of construction materials and colors in relation to all exterior elevations;

5. Location and type of planting, with due regard for the preservation of specimen trees upon a site;

6. Design and appropriateness of signs in relation to the architectural style of the building;

7. Glazing or image reflective surfaces (specular reflectance) shall be limited to a maximum reflectance value of twenty five percent (25%). "Specular reflectance" means any mirror like reflection, as contrasted to diffused reflection from such surfaces as concrete or vegetation.

However, the criteria contained in RMC 18.12.170 do not constitute “objective design standards” as defined in the Housing Crisis Act of 2019 (i.e., Senate Bill 330).

In addition, the City also uses a document titled “Architectural Design Guidelines” that contains examples of architectural design that is sensitive to the cultural and historic character of Redlands. Topics covered in the Guidelines include building articulation, windows, the pedestrian realm, entryways, building materials, contextual design, signage, energy efficient design, adaptive reuse of structures, public art, site design, and landscaping, among others. However, these general guidelines do not constitute “objective design standards” as defined in the Housing Crisis Act of 2019 (i.e., Senate Bill 330).

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Redlands General Plan Transit Villages District and Specific Plan Project 5.1 Aesthetics City of Redlands, CA 5.1-5
Draft EIR
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5.1.3 ENVIRONMENTAL SETTING
Aesthetic resources include a combination of numerous elements, such as landforms, vegetation, water features, urban design, and/or architecture, that impart an overall visual impression that is pleasing to, or valued by, its observers. Factors important in describing the aesthetic resources of an area include visual character, scenic resources, and scenic vistas. These factors together not only describe the intrinsic aesthetic appeal of an area, but also communicate the value placed upon a landscape or scene by its observers.

State Scenic Highway
There are no officially designated state scenic highways traversing the TVSP area; however, State Route 38 is an eligible, albeit not officially designated, state scenic highway. State Route 38 traverses the Downtown Transit Village area as Orange Street north of the I-10 to Lugonia Avenue. State Route 38 then continues outside of the Project area easterly as Lugonia Avenue, which then turns into Mentone Boulevard and Mill Creek Road as the highway continues into the San Bernardino Mountains.

City Scenic Roadways
The City of Redlands has designated numerous roadway segments as scenic highways, drives, and historic streets subject to special development standards (GP2035 EIR, p. 3.1-11). Table 5.1-1, Scenic Roadways in the City, lists the City-designated scenic roadways and roadways being considered for scenic designation as well as their relationship to the TVSP area.

Table 5.1-1: Scenic Roadways in the City
Scenic Roadway Scenic Segment Relationship to TVSP Area Brookside Avenue from Lakeside Avenue to Eureka Street
A small portion of the easternmost terminus of
this roadway segment at the intersection of
Eureka Street enters the Project area in the
Downtown Transit Village
Olive Avenue from Lakeside Avenue to Cajon Street
A small portion of the easternmost terminus of
this roadway segment at the intersection of
Cajon Street enters the Project area in the
Downtown Transit Village
Center Street from Brookside Avenue to Crescent
Avenue Outside of the TVSP area
Highland Avenue from Serpentine Drive to Cajon Street Outside of the TVSP area Sunset Drive from Serpentine Drive to Edgemont
Drive Outside of the TVSP area
Cajon Street (Whole street)
The northern terminus of this segment at Citrus
Avenue/Orange Street south to Clark Street is
within the Project area in the Downtown Transit
Village
Mariposa Drive between Halsey and Sunset Drive Outside of the TVSP area Dwight Street between Pepper Street and Mariposa
Drive Outside of the TVSP area
Roadways Being Considered for Scenic Designations
Riverview Drive Along the Santa Ana River wash Outside of the TVSP area Live Oak Canyon
Drive (Whole street) Outside of the TVSP area
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Scenic Roadway Scenic Segment Relationship to TVSP Area San Timoteo Canyon
Road (Whole street) Outside of the TVSP area
Sylvan Boulevard (Whole street)
The western terminus at the intersection of
University Street east to Judson Street is within
the Project area in the University Transit Village
Nevada Street from Orange Blossom Trail to Barton
Road Outside of the TVSP area
Pioneer Avenue from River Bend Drive to Judson Street Outside of the TVSP area Rural roads in Crafton area Outside of the TVSP area
Visual Character of the Project Site
Existing setting of the New York Street/Esri Transit Village area. The area around this station is car oriented. Large blocks generally comprise the area with commercial and light industrial buildings set back away from the street behind parking lots or landscaped front yards. The I-10 and SR-210 interchange is to the northwest of this transit village. The transit village is traversed east-west by the railways, which run along the north side of Redlands Boulevard, until New York Street, where they branch off from one another as they proceed eastward.

The Arrow station will be located along the north side of Redlands Boulevard at New York Street. To the south of the station site and Redlands Boulevard is Esri’s campus headquarters, and to the southeast (across the intersection) from the station site is Jennie Davis Park, a 5.2-acre neighborhood park. Land uses to the west of the Esri campus (across Tennessee Street) consist primarily of light industrial warehouse buildings and commercial services or office uses. To the south of the Esri campus is a neighborhood of apartments and multifamily buildings.

North of the railway, existing development consists of car-oriented uses, strip mall shopping centers, fastfood restaurants, hotels, and recreational facilities. North of the I-10 are commercial and single-family residences. Buildings within this area range from one to three-story buildings. Many of the one-story light industrial and retail buildings are tall one-story buildings facing the street. The parcels surrounding the station are largely vacant.

Existing setting of the Downtown Transit Village area. This area includes the City’s urban core and the historic Santa Fe Depot. The station site will be at the north side of the Santa Fe Depot (for the new Arrow platform) and immediately west of the Depot (for the new Metrolink platform). Blocks located east of Orange Street within Downtown are small and promote walkability, with commercial and mixed-use buildings built adjacent to and accessed directly from the sidewalk. Blocks west of Orange Street are larger and less pedestrian-friendly with buildings and site designs that are more car-oriented, with buildings located behind street-facing parking lots.

Many parcels west of the Downtown Station are vacant. Additionally, a few vacant remnant packinghouse buildings exist to the north and south of the Santa Fe Depot. Most of the contemporary buildings and extant historic buildings within this transit village are one- and two-story in height. A notable exception is the Citibank building, which is six stories tall. In addition, many of the old packinghouse buildings surrounding the Santa Fe Depot are one-story buildings with tall interiors.

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The historical setting of the downtown core (i.e., along Orange Street and State Street in the general vicinity of the historic Santa Fe Depot and other no longer extant railroad stops) included several three- and fourstory buildings. Historical photos from the City Archives at the A.K. Smiley Public Library show multiple hotels, commercial buildings, and mixed-use buildings with residential upper floors along Orange Street, West State Street, and East State Street. Such buildings were demolished long ago and included: Casa Loma Hotel; Windsor Hotel (also known as the I.O.O.F. Building); Alvarado Hotel; La Posada Hotel; P.O. Block building (also known as the Atwood Block); the Elks Club; First National Bank building; Bank of America building; The Academy of Music building; and others as shown in historical photos of the area.

Existing setting of the University Transit Village area. This area includes the portion of the University of Redlands campus located south of Sylvan Boulevard and Sylvan Park (which is 18-acres). Land uses located north of the I-10 and west of University Street include Sylvan Park, single-family residences, and some multifamily buildings. The southeast portion of the village primarily consists of multi-family buildings. Most of the buildings within this transit village area are one- and two-story in height. Several prominent buildings on the University campus (and near the new University train station) are three- and four-stories high, such as the Administration Building, the Chapel, as well as other buildings such as residence halls. Single-family residences in the neighborhoods around the University campus are mostly one-story and multi-family buildings are two stories. Most of the land immediately surrounding the station site (to the east and south) is vacant and unimproved.

Visual Character of Adjacent Areas
The existing visual character of the area surrounding the TVSP area is urban and suburban. There is no consistent architectural or visual theme within the surrounding area. However, multiple areas surrounding the TVSP area include historic and scenic districts, such as the Smiley Park Neighborhood District and Scenic District, and the East Fern Avenue Historic and Scenic District, located south of the Downtown Village area.

Areas to the north of the TVSP area generally include light industrial uses, commercial buildings, single-family residences and neighborhoods, and the University of Redlands campus. Areas to the east of TVSP area, directly east of Judson Street, include one-story single-family residences and a mobile home park. Areas south of the TVSP area include one- to two-story single-family residences and neighborhoods, Redlands High School, multi-family residential units, Smiley Park, and commercial uses. Areas west of the TVSP area include multi-family residences, commercial uses, and light industrial uses.

Light and Glare
The TVSP area is mostly developed with a limited number of vacant parcels and includes multiple sources of nighttime lighting. Additionally, the TVSP area is surrounded by sources of nighttime lighting that include streetlights along roadways, illumination from vehicle headlights, offsite exterior residential, commercial, and industrial lighting, and interior illumination passing through windows. Sensitive receptors relative to lighting and glare include residents, motorists, and pedestrians passing through the TVSP area.

Glare can emanate from many different sources, some of which include direct sunlight, sunlight reflecting from cars or buildings, and bright outdoor or indoor lighting. Glare in the TVSP vicinity is generated by building and vehicle windows reflecting light. Substantial sources of glare within the TVSP area include windows of taller buildings, such as the six-story Citibank building. However, the majority of buildings within the TVSP area are shorter one- to two-story buildings that are constructed of non-reflective materials and Redlands Regular Meeting of 10-18-22 720 of 1815
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are not surfaced with a substantial number of windows adjacent to one another that would create a large reflective area.

5.1.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the State CEQA Guidelines indicates that a project could have a significant effect if it were to:

AE-1 Have a substantial adverse effect on a scenic vista? AE-2 Substantially damage scenic resources, including, trees, rock outcroppings, and historic buildings within a state scenic highway?
AE-3 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? AE-4 Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
The Initial Study established that the proposed Project would not result in impacts related to Threshold AE1; and no further assessment of these impacts is required in this Draft EIR.

5.1.5 METHODOLOGY
Aesthetic resources were assessed based on the visual quality of the TVSP area and surrounding area and the changes that would occur from implementation of the proposed Project. The evaluation of aesthetics character identifies the proposed Specific Plan’s development characteristics and the expected appearance of full buildout pursuant to the TVSP and compares it to the TVSP area’s existing appearance and character, compared to the character of adjacent existing and future planned uses to determine whether and/or to what extent a degradation of the visual character of the area could occur. Factors considered include the blending/contrasting of new and existing buildings given the proposed uses, density, height, bulk, setbacks, signage, etc. An impact would be considered significant if the Project would result in development that is incompatible with existing uses in relation to type of use or scale or is inconsistent with adopted policies regarding visual and urban design quality.

The EIR recognizes that assessment of whether changes in the character of development from existing conditions would be comparatively better (substantially improved) or worse (substantially degraded) is largely subjective. The following analysis, therefore, focuses in a factual manner on the extent to which new development pursuant to the proposed TVSP would be compatible or conflict with the area’s existing character or features.

The analysis of light and glare identifies light-sensitive land uses and describes the Project’s proposed light and glare sources, and the extent to which lighting, including illuminated signage from implementing projects, could spill off the implementing project site onto adjacent existing and future light-sensitive areas. The analysis also considers the potential for sunlight to reflect off building surfaces (glare) and the extent to which such glare would interfere with the operation of motor vehicles or other activities.

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5.1.6 ENVIRONMENTAL IMPACTS
State Transit Priority Regulations
Public Resources Code (PRC) Section 21099(d) (Senate Bill 743 (2013)) sets forth guidelines for evaluating project transportation impacts under CEQA, as follows: “Aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area (TPA) shall not be considered significant impacts on the environment.” PRC Section 21099 defines a “transit priority area” as an area within 0.5-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.”
PRC 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.”
PRC Section 21099 defines an “employment center project” as “a project located on property zoned for commercial uses with a floor area ratio of no less than 0.75 and that is located within a transit priority area.”
PRC Section 21099 defines an “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.

The under-construction Arrow stations constitute major transit stops as they will serve rail transit. The Project area within a half-mile of each Arrow station is a TPA (see Figure 3-16, Transit Villages Specific Plan and Transit Priority Areas). Accordingly, PRC Section 21099 applies to these areas. There are no other major transit stops in the City. Therefore, individual development projects under the TVD within the TVSP that are within a TPA are exempt from aesthetic impacts under CEQA.

However, the following analysis analyzes impacts to aesthetics from Project implementation. While portions of the TVSP area are within TPAs, the following analysis analyzes impacts to aesthetics from future development in areas of the TVSP inside and outside of TPAs.

IMPACT AE-2: THE PROJECT WOULD NOT SUBSTANTIALLY DAMAGE SCENIC RESOURCES,

INCLUDING TREES, ROCK OUTCROPPINGS, AND HISTORIC BUILDINGS WITHIN A STATE SCENIC HIGHWAY.

Less than Significant with Mitigation Incorporated. As previously discussed, there are no officially designated state scenic highways traversing the TVSP area; however, State Route 38 is an eligible state scenic highway. State Route 38 traverses the Downtown Transit Village area as Orange Street north of the I-10 to Lugonia Avenue. State Route 38 then continues outside of the Project area easterly as Lugonia Avenue, which then turns into Mentone Boulevard and Mill Creek Road as the highway continues into the San Bernardino Mountains. Parcels along the eligible portion of Orange Street include two undeveloped parcels, commercial uses, one- to two-story single-family residences, a gas station, and the Redlands Unified School District buildings. Per the City of Redlands General Plan, most parcels along the eligible portion of Orange Street are designated for Commercial (C) and a few parcels for Public/Institutional (PI) uses. Additionally, the parcels along the eligible portion of Orange Street are zoned Highway Commercial (C-4) and Educational (E).

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As shown in Figure 3-8, Regulating Plan, upon implementation of the TVSP parcels along Orange Street north of the I-10 to Lugonia Avenue would be designated as Village General (VG), Village Corridor (COR), and Special District 1 (SD1). Individual development projects proposed under the Project could be built along State Route 38 per the design guidelines and standards set forth in the TVSP. The TVSP would guide infill development, which would alter the existing visual character of the State Route 38 corridor over the plan implementation period (through 2040) by introducing additional commercial, residential, and/or mixed-use development to the Orange Street area. However, as previously discussed, the majority of the State Route 38 corridor along Orange Street is already developed with commercial, residential, and institutional uses, and all of the parcels along the corridor area already designated for Commercial or Public/Institutional development by the City of Redlands General Plan. As discussed above, parcels along the eligible portion of Orange Street are zoned Highway Commercial (C-4), which does not prescribe a building height limit, and Educational (E), which does not prescribe a building height limit and requires a Conditional Use Permit for structures over 35 feet. The TVSP would designate these parcels as Village General (VG), which prescribes an average building height of three stories, Village Corridor (COR), which prescribes a building height of two stories maximum, and Special District 1 (SD1). The majority of parcels along the eligible portion of Orange Street, besides those adjacent to the freeway, would be designated as Village Corridor (COR), which would limit height of new development to two stories, consistent with existing building heights.

Therefore, structures resulting from the TVSP would be generally within the heights of the existing developed parcels, as allowed by the Redlands General Plan and Municipal Code, along State Route 38 and would not block views of scenic resources, such as the San Bernardino foothills, as implementing project structures would be consistent with views presently found in the area. As shown on Figure 2-1 of the City of Redlands General Plan, three properties along the State Route 38 corridor within the TVSP Area are Local Historic Landmarks/Resources. Any future development projects that might affect or alter historic or scenic resources must first be reviewed and approved by the City’s Historic and Scenic Preservation Commission.

Moreover, the City has designated numerous roadway segments as scenic highways, drives, and historic streets subject to special development standards (GP2035 EIR, p. 3.1-11). As discussed above in Table 5.1- 1, portions of Brookside Avenue, Olive Avenue, and Cajon Street, which are designated by the City as scenic roadways are within the Project Area. Additionally, a portion of Sylvan Boulevard, which is being considered by the City for scenic designation, is within the TVSP area. As shown on General Plan Figure 2-1, one property along Sylvan Boulevard is a Local Historic Landmark/Resource (Redlands Lawn Bowling Club within Sylvan Park). Three properties along Cajon Street are Local Historic Landmarks/Resources. Six properties along Olive Avenue are considered Local Historic Landmarks/Resources. Any future development projects that might affect or alter historic or scenic resources must first be reviewed and approved by the City’s Historic and Scenic Preservation Commission.

As such, the adoption of the TVSP would not substantially damage scenic resources, trees, rock outcroppings within a state scenic highway, but could potentially result in substantial changes to historic buildings if future development projects are proposed on those properties. As discussed further in Section 5.3, Cultural Resources, implementing projects would be required to adhere to Mitigation Measure CUL-1, which requires preparation of historical resource assessments for any implementing project which impacts buildings over 50 years old. Furthermore, pursuant to TVSP Section 4.1.2 F, all rehabilitations and additions to historic buildings within the TVSP area must first be reviewed and approved by the city’s Historic and Scenic Preservation Commission, and shall conform to the recommendations of the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings and the Redlands Historic Architectural Design Guidelines (both of which are incorporated by reference in the TVSP Chapter 4). Therefore, with implementation of the historic design standards that would be implemented as part of the TVSP (provided as PPP CUL-1) and Mitigation Measure CUL-1, impacts related to damaging historic resources within a state scenic highway would be less than significant.

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IMPACT AE-3: THE PROJECT IS LOCATED WITHIN AN URBAN AREA AND WOULD NOT CONFLICT

WITH APPLICABLE ZONING AND OTHER REGULATIONS GOVERNING SCENIC QUALITY.

Less than Significant Impact. As defined by Public Resources Code Section 21071; “Urbanized area” means either of the following:
(a) An incorporated city that meets either of the following criteria:
(1) Has a population of at least 100,000 persons.
(2) Has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.

According to the California Department of Finance E-5 Population Estimates in January 2021, the City of Redlands has a current population of 71,154. Combined with the adjacent cities of Loma Linda, Highland, San Bernardino, and Yucaipa, the population exceeds 100,000 persons thus qualifying the City as being in an “Urbanized Area” (CDF, 2022). Therefore, a significant impact would occur if an implementing project under the TVSP conflicts with applicable zoning and other regulations governing scenic quality.

The proposed Project would guide infill development, which would alter the existing visual character of the TVSP area over the plan implementation period (through 2040) by introducing additional mixed-use development to the area. The proposed Project does not call for any substantial changes to land use or building design in comparison to existing Redlands Municipal Code architectural review criteria for most commercial districts and residential neighborhoods within the TVSP area and includes provisions to preserve or improve the existing visual character of the city. Proposed land use designations and policies would direct new development into underutilized or previously developed areas, where any proposed changes in land use and physical design are intended to increase visual quality. The TVSP provides design standards (including objective architectural design standards), which includes requirements and guidelines for specific development sites, new community amenities, and architectural designs specific to each of the regulating zones. The design standards in the TVSP provide for compatibility with existing uses to enhance the aesthetics and character of the TVSP area. Infill development in the area would be compatible with surrounding buildings to provide consistency in scale within the TVSP area and surrounding pre-World War II residential neighborhoods. The TVSP would create building height and development standards that would be substantially similar to the existing zoning standards. The TVSP provides design and development standards for streetscape improvements that includes a specified palette of street trees, street furniture (planters, benches, bicycle parking, trash receptacles, etc.), wayfinding signage, and open space areas.

Implementation of the TVSP’s design criteria with improvements to existing streetscapes, would enhance the existing visual character of the TVSP area as the TVSP’s design standards would promote compatibility for new improvements with the area.

Redlands General Plan. The Redlands General Plan designates the TVSP area with a mix of land uses including: Medium Density Residential (up to 15 dwelling units per acre), High Density Residential (up to 27 dwelling units per acre), Office, Commercial, Commercial/Industrial, Industrial, Public/Institutional, and Parks.

The proposed Project includes a General Plan Amendment to change the designation parcels within the TVSP area to a “Transit Village (TV)” District. The new Transit Village (TV) land use designation would encourage development in the center of town by providing a plan for introducing new residential and commercial uses located within approximately 0.5 mile of each of these three new train stations.

California law (Government Code §65450-§65453) allows cities to develop and administer specific plans as an implementation tool for their General Plan. As a requirement of state law, specific plans must demonstrate consistency in regulations, guidelines and programs with the goals, objectives, policies, Redlands Regular Meeting of 10-18-22 724 of 1815
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standards, programs and uses that are established in the General Plan. The proposed TVSP would implement General Plan policies related to infill development, providing for mixed use, transit-oriented development within the core area of the City and increasing use of alternative methods of transportation (especially walking, bicycling, bus and train, rideshare, electric vehicles, and other modes that reduce motor vehicle trips). Chapter 1 of the TVSP addresses the consistency of the TVSP with the City’s General Plan and said analysis is incorporated by reference into this Draft EIR. As shown, the proposed Project would be consistent with the City’s General Plan.

The Project would advance the Redlands General Plan’s present Transit Village Strategy and Concept by amending the Redlands General Plan to establish the new Transit Village (TV) land use designation to encourage development in the center of town by providing a plan for introducing new residential and commercial uses located within 0.5 mile of each of these three new train stations. The proposed adoption of the Transit Village (TV) district, along with the implementing TVSP, will set regulations for the community’s long-term vision for compact, efficient, responsible, and environmentally sustainable development. As a formbased code, the TVSP will emphasize building form, a mix and density of different uses, strong pedestrian orientation and transit-oriented development, and public realm improvements and amenities. Therefore, implementation of the Project would not result in conflict with the City’s General Plan, and impacts would not occur.

City of Redlands Municipal Code. Existing residential zoning within the TVSP area is primarily Multi-Family Residential (R-2 and R-3); however, there are two small areas with existing single-family zoning. The parcels on 11th Street between the I-10 and Colton Avenue in the Downtown Transit Village are zoned Single-Family Residential (R-1) and the parcels in the University Street Transit Village bounded by the I-10, East Cypress Avenue, and East Citrus Avenue are zoned Suburban Residential (R-S). See Figure 3-7, Existing Zoning Districts. Non-residential zoning in the TVSP area include Industrial (I-P), Light Industrial (M-1), Planned Industrial (M-P), Administrative and Professional Office (A-P), Neighborhood Stores (C-1), General Commercial (C-3), Highway Commercial (C-4), Commercial (C-M), Educational (E), Transitional (T), Open Land (O), Floodplain (FP), East Valley-General Commercial (EV/CG), and East Valley-Public Institutional (EV/PI). The Downtown Specific Plan (Specific Plan No. 45), located in the proposed Downtown Village, governs the parcels in the downtown area (which is divided into Town Center, Town Center-Historic, and Service-Commercial districts within SP No. 45). The objective of the Downtown Specific Plan is to create a compact, pedestrian-oriented environment, although new mixed-use developments and transit-oriented developments have not come to fruition under the existing Downtown Specific Plan. The proposed Project would replace the current zones within the TVSP area with the “Specific Plan” zone, which then would implement the TVSP’s Regulating Plan districts, as shown in Figure 3-8, Regulating Plan.

TVSP Chapter 4, Development Code, provides detailed regulations for development and new land uses within the TVSP area, and describes how these regulations would be used as part of the City’s development review process. These provisions supersede and replace regulations under the City of Redlands Zoning Code (Title 18 of the Municipal Code). Where specific provisions are not set forth for development standards within the TVSP, or where otherwise applicable requirements of the Zoning Code are not covered by the TVSP Development Code, implementing projects within the TVSP area would be subject to current or future Municipal Code regulations. However, while regulations within the TVSP supersede regulations set forth by the current Municipal Code, the majority of regulations align with the development standards set forth throughout the Municipal Code. For example, the R-3 Multiple Family Residential District set forth in Chapter

18.60 of the Municipal Code allows for development of buildings and structure with a height of no greater than four stories. As discussed in Section 3, Project Description, of this Draft EIR, buildings within the Village Center (VC) district would have a maximum height of four stories and buildings within the Village General (VG) district would be required to have an average height of three stories. Therefore, the new building Redlands Regular Meeting of 10-18-22 725 of 1815
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standards, such as those for building height, provided for by the TVSP would largely remain consistent with existing Municipal Code development standards.

As previously discussed in Section 3.0, Project Description, the TVSP provides a road map for buildout of the TVSP area through 2040 and beyond. There are a number of vacant parcels located within the TVSP area, mostly concentrated along and near the railway right-of-way, as well as other developed or vacant parcels near the train stations. Full buildout of the TVSP area would potentially result in the development of up to 2,400 dwelling units, up to 265,000 SF of commercial space, up to 238,000 SF of office space, up to 220 hotel rooms, and up to 280,000 SF of parkland throughout all three transit villages. However, the TVSP as a form-based code would achieve preferred building forms and design, promote compact and walkable urban form in the vicinity of the train stations, introduce a greater variety of transportation options, and provide more public open space and amenities, among other aesthetic and community benefits. These goals also have associated environmental benefits and long-term reduction of cumulative environmental effects, as summarized in the City’s certified General Plan Update and Climate Action Plan Environmental Impact Report.

Implementing projects pursuant to the TVSP would undergo development review in order to ensure that the project would meet all applicable development standards pursuant to the Redlands General Plan, TVSP, and Redlands Municipal Code. Overall, the TVSP area is located within an urbanized area and would not conflict with applicable zoning and other regulations governing scenic quality. Hence, the proposed Project would not degrade the visual character of the TVSP area and surrounding area; and impacts would be less than significant.

IMPACT AE-4: THE PROJECT WOULD NOT CREATE A NEW SOURCE OF SUBSTANTIAL LIGHT OR GLARE WHICH WOULD ADVERSELY AFFECT DAY OR NIGHTTIME VIEWS IN THE AREA.

Less than Significant with Mitigation Incorporated. Light and glare sensitive uses include the existing residences, motorists, and pedestrians and the proposed residences, motorists, and pedestrians that are located within the TVSP area.

Construction
Limited, if any, nighttime lighting would be needed during construction projects allowed by the Project because RMC Section 8.06.120 limits construction activities to the hours of 7:00 a.m. and 6:00 p.m. on a weekday and Saturdays. Construction activities may be permitted outside of those limitations identified in the case of urgent necessity or upon a finding that such approval will not adversely impact adjacent properties and the health, safety and welfare of the community if a temporary exception is granted. Thus, most construction activity would occur during daytime hours, and construction-related low-level illumination would be used for safety and security purposes only, as provided by Mitigation Measure AES-1. In addition, construction activities do not include any materials or machinery that would generate offsite glare. Therefore, with implementation of Mitigation Measure AES-1, impacts related to lighting and glare during construction activities would be less than significant.

Operation
Lighting
The proposed TVSP area is urbanized and includes a mix of residential, commercial, industrial, and office land uses. As shown on Figure 3-17, the majority of the TVSP area is developed with few vacant parcels.

Sources of light include interior and exterior building lighting, parking lot lighting, vehicular lighting, street lighting, and landscape lighting. Implementation of the proposed Project would increase overall nighttime lighting because it would result in greater intensity and density of land uses than currently exists. New lighting would accompany all new development, including exterior lighting for streetlights, parking lots, signs, Redlands Regular Meeting of 10-18-22 726 of 1815
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walkways, and interior lighting, which could be visible through windows to the outside. In addition, existing and proposed residential uses, considered light-sensitive receptors, would be located throughout the TVSP area.

Section 4.11 of the TVSP sets requirements related to lighting and shielding of light sources limit the potential for increased lighting on sensitive uses. Light emanating from new uses within the TVSP area would be required to be shielded to focus lighting and prevent lighting from spilling onto adjacent sensitive uses, such as residential, or from streaming directly into streets, which could impair views of drivers on streets at night.

With compliance with the TVSP, which would be checked by the City through the building plan check and project permitting process, impacts related to increased sources of light would be less than significant.

Glare
Glare can emanate from many different sources, some of which include direct sunlight, sunlight reflecting from cars or buildings, and bright outdoor or indoor lighting. Glare from reflective surfaces could occur if development uses large expanses of glass, metal, and other reflective surfaces for building façades.

However, the TVSP area is currently developed with similar urban land uses, and implementation of the Project would not result in a substantial net increase in daytime glare, even though an increase in building area would occur over current conditions, due to proposed design criteria set forth in the TVSP.

Implementation of the TVSP’s design criteria, Section 4.7.E, Design Standards would encourage use of traditional materials including brick, stone, and wood and discourage the use of reflective materials.

Furthermore, all implementing projects would require design review, which would ensure that reflective surfaces that would result in glare are not used in projects implemented pursuant to the proposed TVSP.

Section 4.11 of the TVSP sets requirements related to lighting and requires shielding of light sources to minimize glare. Thus, with compliance with the TVSP’s design criteria that are checked by the City through the design review, plan check and development permit process, and compliance with the Redlands Municipal Code, impacts related to increased sources of glare would be less than significant.

5.1.7 CUMULATIVE IMPACTS
Visual Character
The cumulative aesthetics analysis area for the proposed TVSP area is the viewshed that the TVSP area lies within. Like the TVSP area, the cumulative analysis area has been long developed with urban uses and is defined by a grid system of roadways. Thus, cumulative development would be characterized as infill, and would primarily consist of increasing existing development intensities. As a result, cumulative development would reinforce the existing urban and developed character of the area. Future cumulative development would result in changes to the existing development intensities through conversion of vacant land to developed uses, as well as through the conversion of existing land uses to higher development intensities.

However, because the General Plan, Municipal Code, and TVSP set forth policies to protect the character of existing development (as previously listed), it is anticipated that cumulative projects adopted in a manner consistent with those General Plan, Municipal Code, and TVSP policies would not cumulatively degrade the existing character of area land uses. As a result, there would be no significant cumulative impact to which implementation of the proposed Project could contribute.

The cumulative change in visual condition that would result from the proposed Project, in combination with nearby projects, would not be considered adverse because, as described previously, the proposed Project would provide design criteria with respect to architecture, landscaping, parking, and other related items.

The design criteria have the goal of improving the visual quality of the TVSP area by providing requirements and guidelines to ensure consistent, quality development. Thus, with implementation of the proposed TVSP’s associated development standards and design criteria (and the Redlands Municipal Code where the TVSP Redlands Regular Meeting of 10-18-22 727 of 1815
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is directing and/or silent), implementation of the proposed Project would result in a less than significant cumulatively considerable impact related to degradation of the existing visual character or quality of the site and its surroundings.

Light and Glare
The cumulative study area for light and glare for the proposed TVSP area is immediately adjacent to lands that could receive light or glare from new development within the TVSP area or could generate daytime glare or nighttime lighting that would be visible within the TVSP area. All such areas contain a variety of sources of nighttime lighting, such as roadways, vehicle lights, exterior security lighting, as well as sources of daytime glare, such as glass windows on buildings. Because cumulative projects would result in more intense development than currently exists, the proposed Project in combination with past, present, and reasonably foreseeable future projects could create potentially significant cumulative nighttime lighting and daytime glare impacts. However, application of the Redlands Municipal Code regulations and the TVSP’s design criteria would avoid potentially significant effects. These regulations state that lighting shall be shielded to prevent light from shining onto adjacent properties and exclude features that could create excessive glare.

With implementation of the existing City regulations and the TVSP’s development and design standards, the future developments that could occur by the implementation of the Project would not result in a cumulatively considerable contribution of light and glare. Thus, the cumulative effects of development from the Project in combination with cumulative projects related to light and glare are less than significant.

5.1.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• City of Redlands GP2035
• City of Redlands Municipal Code
Standard Conditions
None.

Plans, Programs, or Policies
PPP CUL-1, as further detailed in Section 5.3, Cultural Resources.

5.1.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements and the proposed Project’s design criteria, Impact AE-3 would be less than significant. Without mitigation, Impacts AE-2 and AE-4 would be potentially significant.

5.1.10 MITIGATION MEASURES
Mitigation Measure CUL-1 as detailed in Section 5.3, Cultural Resources.

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Mitigation Measure AES-1: Construction Lighting. The developer and construction contractors shall install all temporary construction lighting such that: (a) lamps and reflectors do not illuminate upon areas beyond the implementing project site, including any off-site security buffer areas; (b) lighting does not cause excessive reflected glare; (c) direct lighting does not illuminate the nighttime sky; (d) illumination of the project site and its immediate vicinity is minimized; and (e) lighting is directed toward construction work areas and shielded from offsite areas.

5.1.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Implementation of Mitigation Measure CUL-1 would reduce impacts to historical resources within a scenic highway to less than significant. Implementation of Mitigation Measure AES-1 would reduce impacts related to construction lighting to less than significant.

REFERENCES
California Department of Finance. E-1 Population Estimates for Cities, Counties, and the State – January 1, 2020 and 2021. Accessed: https://www.dof.ca.gov/Forecasting/Demographics/Estimates/e-1/ California State Scenic Highway System Map. California Department of Transportation.

City of Redlands (City Zoning 2021), Zoning Map, https://www.cityofredlands.org/sites/main/files/fileattachments/zoning.pdf?1633557844 (accessed December 6, 2021) City of Redlands (GP2035 EIR), General Plan 2035 Environmental Impact Report, https://www.cityofredlands.org/post/planning-division-general-plan (accessed December 3, 2021) City of Redlands (GP2035), General Plan 2035, https://www.cityofredlands.org/post/planning-divisiongeneral-plan (accessed December 3, 2021) City of Redlands, Draft Transit Villages Specific Plan, http://redlandstransitvillages.org Redlands Regular Meeting of 10-18-22 729 of 1815
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5.2 Air Quality

5.2.1 INTRODUCTION
This section provides an overview of the existing air quality within the TVSP area and surrounding region, a summary of applicable regulations, and analyses of potential short-term and long-term air quality impacts from implementation of the proposed TVSP. Mitigation measures are recommended as necessary to reduce significant air quality impacts. This analysis is based on the following City documents and report prepared by Urban Crossroads (UC 2022) that is included in Appendix B to this Draft EIR:
• City of Redlands 2035 General Plan, 2017
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (GP EIR), 2017
• City of Redlands Municipal Code
• Transit Villages District and Specific Plan Air Quality Impact Analysis, Urban Crossroads, 2022, Appendix B.

5.2.2 REGULATORY SETTING

5.2.2.1 Federal Regulations
United States Environmental Protection Agency
Criteria Air Pollutants
At the federal level, the United States Environmental Protection Agency (USEPA) has been charged with implementing national air quality programs. The USEPA’s air quality mandates are drawn primarily from the federal Clean Air Act (CAA), which was enacted in 1970. The most recent major amendments to the CAA were made by Congress in 1990.

The CAA requires the USEPA to establish National Ambient Air Quality Standards (NAAQS). The USEPA has established primary and secondary NAAQS for the following criteria air pollutants: ozone, CO, NO2, SO2, PM10, PM2.5, and lead. Table 5.2-1 shows the NAAQS for these pollutants. The CAA also requires each state to prepare an air quality control plan, referred to as a state implementation plan (SIP). The CAA Amendments of 1990 (CAAA) added requirements for states with nonattainment areas to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is modified periodically to reflect the latest emissions inventories, planning documents, and rules and regulations of the air basins, as reported by their jurisdictional agencies. The USEPA is responsible for reviewing all SIPs to determine whether they conform to the mandates of the CAA and its amendments, and to determine whether implementing the SIPs will achieve air quality goals. If the USEPA determines a SIP to be inadequate, a federal implementation plan that imposes additional control measures may be prepared for the nonattainment area.

The USEPA also has regulatory and enforcement jurisdiction over emission sources beyond state waters (outer continental shelf), and those that are under the exclusive authority of the federal government, such as aircraft, locomotives, and interstate trucking. The USEPA’s primary role at the state level is to oversee state air quality programs. The USEPA sets federal vehicle and stationary source emissions standards and provides research and guidance in air pollution programs.

Hazardous Air Pollutants
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The USEPA has programs for identifying and regulating hazardous air pollutants (HAPs). Title III of the CAAA directed the USEPA to promulgate national emissions standards for HAPs (NESHAP). The NESHAP may differ for major sources than for area sources of HAPs. Major sources are defined as stationary sources with potential to emit more than 10 tons per year (tpy) of any HAP or more than 25 tpy of any combination of HAPs; all other sources are considered area sources. The emissions standards are to be promulgated in two phases. In the first phase (1992–2000), the USEPA developed technology-based emission standards designed to produce the maximum emission reduction achievable. These standards are generally referred to as requiring maximum achievable control technology (MACT). For area sources, the standards may be different, based on generally available control technology. In the second phase (2001–2008), the USEPA promulgated health-risk-based emissions standards that were deemed necessary to address risks remaining after implementation of the technology-based NESHAP standards.

Table 5.2-1: Ambient Air Quality Standards for Criteria Pollutants Pollutant Averaging Time
State
Standard
National
Standard
Pollutant Health and Atmospheric
Effects Major Pollutant Sources
Ozone 1 hour 0.09 ppm --- High concentrations can directly affect lungs, causing irritation.

Long-term exposure may cause
damage to lung tissue.

Formed when ROG and NOX react in
the presence of sunlight. Major sources
include on-road motor vehicles, solvent
evaporation, and commercial/industrial
mobile equipment.
8 hours 0.07 ppm 0.075 ppm
Carbon
Monoxide
(CO)
1 hour 20 ppm 35 ppm Classified as a chemical
asphyxiant, carbon monoxide
interferes with the transfer of fresh
oxygen to the blood and deprives
sensitive tissues of oxygen.

Internal combustion engines, primarily
gasoline-powered motor vehicles.
8 hours 9.0 ppm 9 ppm
Nitrogen
Dioxide
(NOx)
1 hour 0.18 ppm 0.100 ppm Irritating to eyes and respiratory tract. Colors atmosphere reddishbrown.

Motor vehicles, petroleum refining
operations, industrial sources, aircraft,
Annual ships, and railroads.

Arithmetic Mean

0.030 ppm 0.053 ppm
Sulfur
Dioxide
(SO2)
1 hour 0.25 ppm 75 ppb Irritates upper respiratory tract; injurious to lung tissue. Can yellow
the leaves of plants, destructive to
marble, iron, and steel. Limits
visibility and reduces sunlight.

Fuel combustion, chemical plants, sulfur
recovery plants, and metal processing.
3 hours --- 0.50 ppm
24 hours 0.04 ppm 0.14 ppm
Annual
Arithmetic Mean
--- 0.03 ppm
Respirable
Particulate
Matter
(PM10)
24 hours 50 µg/m3 150 µg/m3 May irritate eyes and respiratory tract, decreases in lung capacity,
cancer and increased mortality.

Produces haze and limits visibility.

Dust and fume-producing industrial and
agricultural operations, combustion,
atmospheric photochemical reactions,
and natural activities (e.g., wind-raised
dust and ocean sprays).

Annual
Arithmetic Mean
20 µg/m3 ---
Fine
Particulate
Matter
(PM2.5)
24 hours --- 35 µg/m3 Increases respiratory disease, lung damage, cancer, and premature
death. Reduces visibility and results
in surface soiling.

Fuel combustion in motor vehicles,
equipment, and industrial sources;
residential and agricultural burning;
Also, formed from photochemical
reactions of other pollutants, including
NOx, sulfur oxides, and organics.

Annual
Arithmetic Mean
12 µg/m3 12 µg/m3
Lead (Pb) 30 Day Average 1.5 µg/m3 --- Disturbs gastrointestinal system, and causes anemia, kidney disease,
and neuromuscular and
neurological dysfunction (in severe
cases).

Present source: lead smelters, battery
manufacturing and recycling facilities.

Past source: combustion of leaded
gasoline.

Calendar
Quarter
--- 1.5 µg/m3
Rolling 3-Month
Average
--- 0.15 µg/m3
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Pollutant Averaging Time
State
Standard
National
Standard
Pollutant Health and Atmospheric
Effects Major Pollutant Sources
Hydrogen
Sulfide
1 hour 0.03 ppm … Nuisance odor (rotten egg smell),
headache and breathing difficulties
(higher concentrations)
Geothermal power plants, petroleum
production and refining
Sulfates
(SO4)
24 hour 25 µg/m3 … Decrease in ventilatory functions;
aggravation of asthmatic
symptoms; aggravation of cardiopulmonary disease; vegetation damage; degradation of visibility;
property damage.

Industrial processes.

Visibility
Reducing
Particles
8 hour Extinction of

0.23/km;
visibility of
10 miles or
more
… Reduces visibility, reduced airport
safety, lower real estate value,
and discourages tourism.

See PM2.5.
ppm = parts per million; ppb = parts per billion; µg/m3 = micrograms per cubic meter.

Source: AQ, 2022 (Appendix B)
The CAAA also required the USEPA to promulgate vehicle or fuel standards containing reasonable requirements that control toxic emissions of, at a minimum, benzene and formaldehyde. Performance criteria were established to limit mobile-source emissions of toxics, including benzene, formaldehyde, and 1,3- butadiene. In addition, Section 219 required the use of reformulated gasoline in selected areas with the most severe ozone nonattainment conditions to further reduce mobile-source emissions.

5.2.2.2 State Regulations
California Air Resources Board
Criteria Air Pollutants
The California Air Resources Board (CARB), a department of the California Environmental Protection Agency, oversees air quality planning and control throughout California. CARB is responsible for coordination and oversight of state and local air pollution control programs in California and for implementation of the California Clean Air Act (CCAA). The CCAA, which was adopted in 1988, requires CARB to establish the California Ambient Air Quality Standards (CAAQS). CARB has established CAAQS for sulfates, hydrogen sulfide, vinyl chloride, visibility-reducing particulate matter, and the above-mentioned criteria air pollutants.

Applicable CAAQS are shown in Table 5.2-1.

The CCAA requires all local air districts in the state to endeavor to achieve and maintain the CAAQS by the earliest practical date. The act specifies that local air districts shall focus particular attention on reducing the emissions from transportation and area-wide emission sources and provides districts with the authority to regulate indirect sources.

Among CARB’s other responsibilities are overseeing compliance by local air districts with California and federal laws, approving local air quality plans, submitting SIPs to the USEPA, monitoring air quality, determining and updating area designations and maps, and setting emissions standards for new mobile sources, consumer products, small utility engines, off-road vehicles, and fuels.

Toxic Air Contaminants
Air quality regulations also focus on toxic air contaminants (TACs). In general, for those TACs that may cause cancer, there is no concentration that does not present some risk. In other words, there is no safe level of exposure. This contrasts with the criteria air pollutants, for which acceptable levels of exposure can be determined and for which the ambient standards have been established. Instead, the USEPA and CARB Redlands Regular Meeting of 10-18-22 732 of 1815
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regulate HAPs and TACs, respectively, through statutes and regulations that generally require the use of the MACT or best available control technology (BACT) for toxics and to limit emissions. These statutes and regulations, in conjunction with additional rules set forth by the districts, establish the regulatory framework for TACs.

TACs in California are regulated primarily through the Tanner Air Toxics Act (Assembly Bill [AB] 1807 [Chapter 1047, Statutes of 1983]) (Health and Safety Code Section 39650 et seq.) and the Air Toxics Hot Spots Information and Assessment Act (Hot Spots Act) (AB 2588 [Chapter 1252, Statutes of 1987]) (Health and Safety Code Section 44300 et seq.). AB 1807 sets forth a formal procedure for CARB to designate substances as TACs. This includes research, public participation, and scientific peer review before CARB can designate a substance as a TAC. To date, CARB has identified more than 21 TACs and adopted the USEPA’s list of HAPs as TACs. Most recently, diesel PM was added to the CARB list of TACs. Once a TAC is identified, CARB then adopts an airborne toxics control measure (ATCM) for sources that emit that particular TAC. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure below that threshold. If there is no safe threshold, the measure must incorporate BACT to minimize emissions.

The Air Toxics Hot Spots Information and Assessment Act requires existing facilities emitting toxic substances above a specified level to prepare a toxic-emission inventory, prepare a risk assessment if emissions are significant, notify the public of significant risk levels, and prepare and implement risk reduction measures.

CARB published the Air Quality and Land Use Handbook: A Community Health Perspective (Handbook), which provides guidance concerning land use compatibility with TAC sources. Although it is not a law or adopted policy, the Handbook offers advisory recommendations for the siting of sensitive receptors near uses associated with TACs, such as freeways and high-traffic roads, commercial distribution centers, rail yards, ports, refineries, dry cleaners, gasoline stations, and industrial facilities, to help keep children and other sensitive populations out of harm’s way. In addition, CARB has promulgated the following specific rules to limit TAC emissions:
• CARB Rule 2485 (13 CCR, Chapter 10 Section 2485), Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling
• CARB Rule 2480 (13 CCR Chapter 10 Section 2480), Airborne Toxic Control Measure to Limit School Bus Idling and Idling at Schools
• CARB Rule 2477 (13 CCR Section 2477 and Article 8), Airborne Toxic Control Measure for In-Use Diesel Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets and Facilities Where TRUs Operate
California Assembly Bill 1493– Pavley
In 2002, the California Legislature adopted AB 1493 requiring the adoption of regulations to develop fuel economy standards for the transportation sector. In September 2004, pursuant to AB 1493, the CARB approved regulations to reduce fuel use and emissions from new motor vehicles beginning with the 2009 model year (Pavley Regulations). CARB, EPA, and the U.S. Department of Transportation’s National Highway Traffic and Safety Administration (NHTSA) have coordinated efforts to develop fuel economy standards for model 2017-2025 vehicles, which are incorporated into the “Low Emission Vehicle” (LEV) Regulations.

California Code of Regulations (CCR) Title 13, Motor Vehicles, Section 2449(d)(3) No vehicle or engines subject to this regulation may idle for more than 5 consecutive minutes. The idling limit does not apply to:
• idling when queuing,
• idling to verify that the vehicle is in safe operating condition, Redlands Regular Meeting of 10-18-22 733 of 1815
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• idling for testing, servicing, repairing or diagnostic purposes, • idling necessary to accomplish work for which the vehicle was designed (such as operating a crane),
• idling required to bring the machine system to operating temperature, and • idling necessary to ensure safe operation of the vehicle.

Title 24 Energy Efficiency Standards and California Green Building Standards California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code (CalGreen) was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption.

CALGreen is updated on a regular basis, with the most recent approved update consisting of the 2019 California Green Building Code Standards that became effective January 1, 2020.

The CEC anticipates that single-family homes built with the 2019 standards will use approximately 7% less energy compared to the residential homes built under the 2016 standards. Additionally, after implementation of solar photovoltaic systems, homes built under the 2019 standards will use about 53% less energy than homes built under the 2016 standards. Nonresidential buildings will use approximately 30% less energy due to lighting upgrade requirements. The 2019 CALGreen standards that are applicable to the proposed Project include, but are not limited to, the following:
• Short-term bicycle parking. Provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with a minimum of one two-bike capacity rack. • Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenantoccupants, provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility.
• Designated parking for clean air vehicles. Provide designated parking for any combination of lowemitting, fuel-efficient and carpool/van pool vehicles as shown in Title 24 Part 6 Table 5.106.5.2. • Electric vehicle charging stations. Facilitate the future installation of electric vehicle supply equipment. The compliance requires empty raceways for future conduit and documentation that the electrical system has adequate capacity for the future load. • Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight and glare ratings per Title 24 Part 6 Table 5.106.8. • Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the nonhazardous construction and demolition waste.
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reused or recycled. • Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified for the depositing, storage and collection of non-hazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals. • Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed

1.28 gallons per flush
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o Urinals. The effective flush volume of wall-mounted urinals shall not exceed

0.125 gallons per flush. The effective flush volume of floor-mounted or other urinals shall not exceed 0.5 gallons per flush.
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons per minute and 80 psi. When a shower is served by more than one showerhead, the combine flow rate of all showerheads and/or other shower outlets controlled by a single valve shall not exceed 1.8 gallons per minute at 80 psi. o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not more than 0.5 gallons per minute at 60 psi. Kitchen faucets shall have a maximum flow rate of not more than 1.8 gallons per minute of 60 psi. Wash fountains shall have a maximum flow rate of not more than 1.8 gallons per minute. Metering faucets shall not deliver more than

0.20 gallons per cycle. Metering faucets for wash fountains shall have a maximum flow rate not more than 0.20 gallons per cycle.
• Outdoor portable water use in landscaped areas. Nonresidential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources’ Model Water Efficient (MWELO), whichever is more stringent. • Water meters. Separate submeters or metering devices shall be installed for new buildings or where any tenant within a new building or within an addition that is project to consume more than 1,000 gallons per day.
• Outdoor water use in rehabilitated landscape projects equal or greater than 2,500 sf.

Rehabilitated landscape projects with an aggregate landscape area equal to or greater than 2,500 sf requiring a building or landscape permit.
• Commissioning. For new buildings 10,000 sf and over, building commissioning shall be included in the design and construction processes of the building project to verify that the building systems and components meet the owner’s or owner representative’s project requirements.

The 2019 CalGreen Building Standards Code has been adopted by the City of Redlands in Municipal Code Chapter 15.16.

5.2.2.3 Regional Regulations
SCAQMD
Criteria Air Pollutants
The South Coast Air Quality Management District (SCAQMD) attains and maintains air quality conditions in the Basin through a comprehensive program of planning, regulation, enforcement, technical innovation, and promotion of the understanding of air quality issues. The clean air strategy of SCAQMD includes preparation of plans for attainment of ambient air quality standards, adoption and enforcement of rules and regulations concerning sources of air pollution, and issuance of permits for stationary sources of air pollution. SCAQMD also inspects stationary sources of air pollution and responds to citizen complaints; monitors ambient air quality and meteorological conditions; and implements programs and regulations required by the CAA, CAAA, and CCAA. Air quality plans applicable to the proposed Project are discussed below.

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Air Quality Management Plan
SCAQMD and the Southern California Association of Governments (SCAG) are responsible for preparing the air quality management plan (AQMP), which addresses federal and state CAA requirements. The AQMP details goals, policies, and programs for improving air quality in the Basin.

The 2012 AQMP was adopted by the SCAQMD Governing Board on December 12, 2012. The purpose of the 2012 AQMP for the Basin is to set forth a comprehensive and integrated program that will lead the region into compliance with the federal 24-hour PM2.5 air quality standard, and to provide an update to the Basin’s commitment towards meeting the federal 8-hour ozone standards. The AQMP would also serve to satisfy recent USEPA requirements for a new attainment demonstration of the revoked 1-hour ozone standard, as well as a vehicle miles travelled (VMT) emissions offset demonstration.1 The 2012 AQMP, as approved by CARB, serves as the official SIP submittal for the federal 2006 24-hour PM2.5 standard. In addition, the AQMP updates specific new control measures and commitments for emissions reductions to implement the attainment strategy for the 8-hour ozone SIP. The 2012 AQMP set forth programs which require integrated planning efforts and the cooperation of all levels of government: local, regional, state, and federal.

In March 2017 AQMD finalized the 2016 AQMP, which continues to evaluate integrated strategies and control measures to meet the NAAQS, as well as explore new and innovative methods to reach its goals.

Some of these approaches include utilizing incentive programs, recognizing existing co-benefit programs from other sectors, and developing a strategy with fair-share reductions at the federal, state, and local levels. Similar to the 2012 AQMP, the 2016 AQMP incorporates scientific and technological information and planning assumptions, including the 2016 RTP/SCS and updated emission inventory methodologies for various source categories. The 2022 AQMP is currently being developed by SCAQMD to address the EPA’s strengthened ozone standard. Development of the 2022 AQMP is in its early stages and no formal timeline for completion and adoption is currently known.

SCAQMD Rules and Regulations
All projects are subject to SCAQMD rules and regulations. Specific rules applicable to the proposed Project include the following:

Rule 203 – Permit to Operate. A person shall not operate or use any equipment or agricultural permit unit, the use of which may cause the issuance of air contaminants, or the use of which may reduce or control the issuance of air contaminants, without first obtaining a written permit to operate from the Executive Officer or except as provided in Rule 202. The equipment or agricultural permit unit shall not be operated contrary to the conditions specified in the permit to operate.

Rule 401 – Visible Emissions. A person shall not discharge into the atmosphere from any single source of emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in any 1 hour that is as dark or darker in shade as that designated No. 1 on the Ringelmann Chart, as published by the United States Bureau of Mines.

Rule 402 – Nuisance. A person shall not discharge from any source whatsoever such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any such persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. The provisions of this rule do not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals. 2 Additional sources of information on the health effects of criteria pollutants can be found at CARB and USEPA’s websites at http://www.arb.ca.gov/research/health/health.htm and http://www.epa.gov/air/airpollutants.html, respectively.

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Rule 403 – Fugitive Dust. SCAQMD Rule 403 governs emissions of fugitive dust during and after construction. Compliance with this rule is achieved through application of standard Best Management Practices, such as application of water or chemical stabilizers to disturbed soils, covering haul vehicles, restricting vehicle speeds on unpaved roads to 15 miles per hour, sweeping loose dirt from paved site access roadways, cessation of construction activity when winds exceed 25 mph, and establishing a permanent ground cover on finished sites.

Rule 403 requires project applicants to control fugitive dust using the best available control measures such that dust does not remain visible in the atmosphere beyond the property line of the emission source. In addition, Rule 403 requires implementation of dust suppression techniques to prevent fugitive dust from creating an offsite nuisance. Applicable Rule 403 dust suppression (and PM10 generation) techniques to reduce impacts on nearby sensitive receptors may include, but are not limited to, the following:
• Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for 10 days or more). • Water active sites at least three times daily. Locations where grading is to occur shall be thoroughly watered prior to earthmoving.
• Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 0.6 meters (2 feet) of freeboard (vertical space between the top of the load and top of the trailer) in accordance with the requirements of California Vehicle Code Section 23114. • Reduce traffic speeds on all unpaved roads to 15 miles per hour (mph) or less. • Suspend all grading activities when wind speeds (including instantaneous wind gusts) exceed 25 mph.
• Provide bumper strips or similar best management practices where vehicles enter and exit the construction site onto paved roads, or wash off trucks and any equipment leaving the site each trip. • Replant disturbed areas as soon as practical.
• Sweep onsite streets (and offsite streets if silt is carried to adjacent public thoroughfares) to reduce the amount of particulate matter on public streets. All sweepers shall be compliant with SCAQMD Rule 1186.1, Less Polluting Sweepers.

Rule 481 – Spray Coating. This rule applies to all spray painting and spray coating operations and equipment and states that a person shall not use or operate any spray painting or spray coating equipment unless one of the following conditions is met:
• The spray coating equipment is operated inside a control enclosure, which is approved by the Executive Officer. Any control enclosure for which an application for permit for new construction, alteration, or change of ownership or location is submitted after the date of adoption of this rule shall be exhausted only through filters at a design face velocity not less than 100 feet per minute nor greater than 300 feet per minute, or through a water wash system designed to be equally effective for the purpose of air pollution control.
• Coatings are applied with high-volume low-pressure, electrostatic and/or airless spray equipment. • An alternative method of coating application or control is used which has effectiveness equal to or greater than the equipment specified in the rule.

Rule 1108 - Volatile Organic Compounds. This rule governs the sale, use, and manufacturing of asphalt and limits the volatile organic compound (VOC) content in asphalt used in the Basin. This rule also regulates the VOC content of asphalt used during construction. Therefore, all asphalt used during construction of the Project must comply with SCAQMD Rule 1108.

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Rule 1113 – Architectural Coatings. No person shall apply or solicit the application of any architectural coating within the SCAQMD with VOC content in excess of the values specified in a table incorporated in the Rule.

Rule 1143 – Paint Thinners and Solvents. This rule governs the manufacture, sale, and use of paint thinners and solvents used in thinning of coating materials, cleaning of coating application equipment, and other solvent cleaning operations by limiting their VOC content. This rule regulates the VOC content of solvents used during construction. Solvents used during the construction phase must comply with this rule.

5.2.2.4 Local Regulations
City of Redlands 2035 General Plan
The General Plan Healthy Community Element contains the following policies related to air quality that are applicable to the Project:

Principle 7-P.44 Protect air quality within the city and support efforts for enhanced regional air quality.

Principle 7-P.45 Aim for a diverse and efficiently-operated ground transportation system that generates the minimum amount of pollutants feasible.

Principle 7-P.46 Increase average vehicle ridership during peak commute hours as a way of reducing vehicle miles traveled and peak period auto travel.

Principle 7-P.47 Cooperate in efforts to expand bus, rail, and other forms of mass transit in the portion of the South Coast Air Basin within San Bernardino County.

Principle 7-P.49 Protect sensitive receptors from exposure to hazardous concentrations of air pollutants.

Action 7-A.147 Cooperate with the ongoing efforts of the U.S. Environmental Protection Agency, the South Coast Air Quality Management District, and the State of California Air Resources Board in improving air quality in the regional air basin.

Action 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 Action 7-A.152 Enforce regulations to prevent trucks from excessive idling in residential areas.

Action 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.

Action 7-A.154 Require applicants for sensitive land uses within a Proposition 65 warning contour to conduct a health risk assessment and mitigate any health impacts to a less than significant level.

5.2.3 ENVIRONMENTAL SETTING
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Climate and Meteorology
The TVSP area is located within the South Coast Air Basin (Basin), which is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The Basin is a 6,600-square-mile coastal plain bounded by the Pacific Ocean to the southwest and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The Basin includes the non-desert portions of Los Angeles, Riverside, and San Bernardino counties, and all of Orange County.

The ambient concentrations of air pollutants are determined by the amount of emissions released by sources and the atmosphere’s ability to transport and dilute such emissions. Natural factors that affect transport and dilution include terrain, wind, atmospheric stability, and sunlight. Therefore, existing air quality conditions in the area are determined by such natural factors as topography, meteorology, and climate, in addition to the amount of emissions released by existing air pollutant sources.

Atmospheric conditions such as wind speed, wind direction, and air temperature gradients interact with the physical features of the landscape to determine the movement and dispersal of air pollutants. The topography and climate of Southern California combine to make the Basin an area of high air pollution potential. The Basin is a coastal plain with connecting broad valleys and low hills, bounded by the Pacific Ocean to the west and high mountains around the rest of the perimeter. The general region lies in the semipermanent high-pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool sea breezes with light average wind speeds. The usually mild climatological pattern is disrupted occasionally by periods of extremely hot weather, winter storms, or Santa Ana winds. During the summer months, a warm air mass frequently descends over the cool, moist marine layer produced by the interaction between the ocean’s surface and the lowest layer of the atmosphere. The warm upper layer forms a cap over the cool marine layer and inhibits the pollutants in the marine layer from dispersing upward. In addition, light winds during the summer further limit ventilation. Furthermore, sunlight triggers the photochemical reactions which produce ozone.

Criteria Air Pollutants
The California Air Resources Board (CARB) and the United States Environmental Protection Agency (USEPA) currently focus on the following air pollutants as indicators of ambient air quality: ozone, carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), respirable particulate matter with an aerodynamic diameter of 10 micrometers or less (PM10), fine particulate matter with an aerodynamic diameter of 2.5 micrometers or less (PM2.5), and lead. These pollutants are referred to as “criteria air pollutants” because they are the most prevalent air pollutants known to be injurious to human health. Extensive health-effects criteria documents regarding the effects of these pollutants on human health and welfare have been prepared over the years.
2 Standards have been established for each criteria pollutant to meet specific public health and welfare criteria set forth in the federal Clean Air Act (CAA). California has generally adopted more stringent ambient air quality standards for the criteria air pollutants (referred to as State Ambient Air Quality Standards, or state standards) and has adopted air quality standards for some pollutants for which there is no corresponding national standard, such as sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles.

Ozone
Ozone, the main component of photochemical smog, is primarily a summer and fall pollution problem. Ozone is not emitted directly into the air; but is formed through a complex series of chemical reactions involving other compounds that are directly emitted. These directly emitted pollutants (also known as ozone precursors) include reactive organic gases (ROGs) or volatile organic compounds (VOCs), and oxides of nitrogen (NOx). 2 Additional sources of information on the health effects of criteria pollutants can be found at CARB and USEPA’s websites at http://www.arb.ca.gov/research/health/health.htm and http://www.epa.gov/air/airpollutants.html, respectively.

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While both ROGs and VOCs refer to compounds of carbon, ROG is a term used by CARB and is based on a list of exempted carbon compounds determined by CARB. VOC is a term used by the USEPA and is based on its own exempt list. The time period required for ozone formation allows the reacting compounds to spread over a large area, producing regional pollution problems. Ozone concentrations are the cumulative result of regional development patterns rather than the result of a few significant emission sources.

Once ozone is formed, it remains in the atmosphere for one or two days. Ozone is then eliminated through reaction with chemicals on the leaves of plants, attachment to water droplets as they fall to earth (“rainout”), or absorption by water molecules in clouds that later fall to earth with rain (“washout”).

Short-term exposure to ozone can irritate the eyes and cause constriction of the airways. In addition to causing shortness of breath, ozone can aggravate existing respiratory diseases such as asthma, bronchitis, and emphysema.

Carbon Monoxide
CO is a colorless, odorless gas produced by the incomplete combustion of carbon-containing fuels, such as gasoline or wood. CO concentrations tend to be the highest during the winter morning, when little to no wind and surface-based inversions trap the pollutant at ground levels. Because CO is emitted directly from internal combustion engines, unlike ozone, motor vehicles operating at slow speeds are the primary source of CO in the Basin. The highest ambient CO concentrations are generally found near congested transportation corridors and intersections.

Nitrogen Dioxide
NO2 is a reddish-brown gas that is a by-product of combustion processes. Automobiles and industrial operations are the main sources of NO2. Combustion devices emit primarily nitric oxide (NO), which reacts through oxidation in the atmosphere to form NO2. The combined emissions of NO and NO2 are referred to as NOx, which are reported as equivalent NO2. Aside from its contribution to ozone formation, NO2 can increase the risk of acute and chronic respiratory disease and reduce visibility. NO2 may be visible as a coloring component of a brown cloud on high pollution days, especially in conjunction with high ozone levels.

Sulfur Dioxide
SO2 is a colorless, extremely irritating gas or liquid that enters the atmosphere as a pollutant mainly as a result of burning high sulfur-content fuel oils and coal, and from chemical processes occurring at chemical plants and refineries. When SO2 oxidizes in the atmosphere, it forms sulfur trioxide (SO3). Collectively, these pollutants are referred to as sulfur oxides (SOx).

Major sources of SO2 include power plants, large industrial facilities, diesel vehicles, and oil-burning residential heaters. Emissions of SO2 aggravate lung diseases, especially bronchitis. This compound also constricts the breathing passages, especially in people with asthma and people involved in moderate to heavy exercise. SO2 potentially causes wheezing, shortness of breath, and coughing. Long-term SO2 exposure has been associated with increased risk of mortality from respiratory or cardiovascular disease.

Particulate Matter
PM10 and PM2.5 consist of particulate matter that is 10 microns or less in diameter and 2.5 microns or less in diameter, respectively (a micron is one-millionth of a meter). PM10 and PM2.5 represent fractions of particulate matter that can be inhaled into the air passages and the lungs and can cause adverse health effects. Acute and chronic health effects associated with high particulate levels include the aggravation of chronic respiratory diseases, heart and lung disease, and coughing, bronchitis and respiratory illnesses in children.

Particulate matter can also damage materials and reduce visibility. One common source of PM2.5 is diesel exhaust emissions.

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PM10 consists of particulate matter emitted directly into the air (e.g., fugitive dust, soot, and smoke from mobile and stationary sources, construction operations, fires, and natural windblown dust) and particulate matter formed in the atmosphere by condensation and/or transformation of SO2 and ROG. Traffic generates particulate matter emissions through entrainment of dust and dirt particles that settle onto roadways and parking lots. PM10 and PM2.5 are also emitted by burning wood in residential wood stoves and fireplaces and open agricultural burning. PM2.5 can also be formed through secondary processes such as airborne reactions with certain pollutant precursors, including ROGs, ammonia (NH3), NOx, and SOx.

Lead
Lead is a metal found naturally in the environment and present in some manufactured products. There are a variety of activities that can contribute to lead emissions, which are grouped into two general categories, stationary and mobile sources. On-road mobile sources include light-duty automobiles; light-, medium-, and heavy-duty trucks; and motorcycles.

Emissions of lead have dropped substantially over the past 40 years. The reduction before 1990 is largely due to the phase-out of lead as an anti-knock agent in gasoline for on-road automobiles. Substantial emission reductions have also been achieved due to enhanced controls in the metals processing industry. In the Basin, atmospheric lead is generated almost entirely by the combustion of leaded gasoline and contributes less than one percent of the material collected as total suspended particulates.

Toxic Air Contaminants
Concentrations of toxic air contaminants (TACs), or in federal parlance, hazardous air pollutants (HAPs), are also used as indicators of ambient air quality conditions. A TAC is defined as an air pollutant that may cause or contribute to an increase in mortality or in serious illness, or that may pose a hazard to human health.

TACs are usually present in minute quantities in the ambient air; however, their high toxicity or health risk may pose a threat to public health even at low concentrations.

According to the California Almanac of Emissions and Air Quality, the majority of the estimated health risk from TACs can be attributed to relatively few compounds, the most important being particulate matter from diesel-fueled engines (DPM). DPM differs from other TACs in that it is not a single substance, but rather a complex mixture of hundreds of substances. Although DPM is emitted by diesel-fueled internal combustion engines, the composition of the emissions varies depending on engine type, operating conditions, fuel composition, lubricating oil, and whether an emission control system is present.

Unlike the other TACs, no ambient monitoring data are available for DPM because no routine measurement method currently exists. However, CARB has made preliminary concentration estimates based on a particulate matter exposure method. This method uses the CARB emissions inventory’s PM10 database, ambient PM10 monitoring data, and the results from several studies to estimate concentrations of diesel PM.

In addition to diesel PM, the TACs for which data are available that pose the greatest existing ambient risk in California are benzene, 1,3-butadiene, acetaldehyde, carbon tetrachloride, hexavalent chromium, paradichlorobenzene, formaldehyde, methylene chloride, and perchloroethylene.

CO Hotspots
An adverse CO concentration, known as a “hot spot” is an exceedance of the state one-hour standard of 20 ppm or the eight-hour standard of 9 ppm. It has long been recognized that CO hotspots are caused by vehicular emissions, primarily when idling at congested intersections. In response, vehicle emissions standards have become increasingly stringent in the last twenty years. Currently, the allowable CO emissions standard in California is a maximum of 3.4 grams/mile for passenger cars (there are requirements for certain vehicles that are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation of increasingly sophisticated and efficient emissions control technologies, CO concentration in the SCAB is now designated as attainment, and CO concentrations in the region have steadily declined (AQ 2022).

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Odorous Emissions
Odors are generally regarded as an annoyance rather than a health hazard. However, manifestations of a person’s reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache). Offensive odors are unpleasant and can lead to public distress generating citizen complaints to local governments. Although unpleasant, offensive odors rarely cause physical harm. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source, wind speed, direction, and the sensitivity of receptors.

EXISTING CONDITIONS
SCAQMD maintains monitoring stations within district boundaries, Source/Receptor Areas (SRAs), that monitor air quality and compliance with associated ambient standards. The TVSP area is located within SRA 35, East San Bernardino. The East San Bernardino monitoring station is located approximately 0.5 mile east of the TVSP area and reports air quality statistics for O3 and PM10. The East San Bernardino Valley monitoring station does not provide information for CO, NO2, and PM2.5, as such, statistics were obtained from the Central San Bernardino 2 monitoring station. The Central San Bernardino monitoring station is located within SRA 34 that is located 4.6 miles northwest of the TVSP area. The most recent 3 years of data is shown on Table 5.2-2 and identifies the number of days ambient air quality standards were exceeded in the area.

Additionally, data for SO2 has been omitted as attainment is regularly met in the South Coast Air Basin and few monitoring stations measure SO2 concentrations.

In 2020, the federal and state ambient air quality standards (NAAQS and CAAQS) were exceeded on one or more days for ozone and PM10 at most monitoring locations. No areas of the SCAB exceeded federal or state standards for NO2, SO2, CO, sulfates, or lead. See Table 5.2-3, for attainment designations for the SCAB.

Table 5.2-2: Air Quality Monitoring Summary 2018-2020
Pollutant Standard
Year
2018 2019 2020
O3
Maximum Federal 1-Hour Concentration (ppm) .136 0.137 0.173 Maximum Federal 8-Hour Concentration (ppm) .114 0.117 0.136 Number of Days Exceeding State 1-Hour Standard > 0.09 ppm 3 73 104 Number of Days Exceeding State/Federal 8-Hour Standard > 0.070 ppm 4 109 141 CO
Maximum Federal 1-Hour Concentration > 35 ppm 2.7 1.3 1.9 Maximum Federal 8-Hour Concentration > 20 ppm 2.5 1.1 1.4 NO2
Maximum Federal 1-Hour Concentration > 0.100 ppm 0.057 0.059 0.054 Annual Federal Standard Design Value 0.016 0.014 0.015
PM10
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Maximum Federal 24-Hour Concentration (µg/m3) > 150 µg/m3 4 4 7 Annual Federal Arithmetic Mean (µg/m3) 25.9 21.2 23.4
Number of Days Exceeding Federal 24-Hour Standard > 150 µg/m3 Number of Days Exceeding State 24-Hour Standard > 50 µg/m3 PM2.5
Maximum Federal 24-Hour Concentration (µg/m3) > 35 µg/m3 30.10 34.80 25.70 Annual Federal Arithmetic Mean (µg/m3) > 12 µg/m3 11.17 10.06 11.6 Number of Days Exceeding Federal 24-Hour Standard > 35 µg/m3 0 0 0 ppm = Parts Per Million
µg/m3 = Microgram per Cubic Meter
Source: AQ, 2022 (Appendix B)
Both CARB and the USEPA use this type of monitoring data to designate areas with air quality problems and to initiate planning efforts for improvement. The three basic designation categories are nonattainment, attainment, and unclassified. Nonattainment is defined as any area that does not meet, or that contributes to ambient air quality in a nearby area that does not meet the primary or secondary ambient air quality standard for the pollutant. Attainment is defined as any area that meets the primary or secondary ambient air quality standard for the pollutant. Unclassifiable is defined as any area that cannot be classified on the basis of available information as meeting or not meeting the primary or secondary ambient air quality standard for the pollutant. California designations include a subcategory of nonattainment-transitional, which is given to nonattainment areas that are progressing and nearing attainment.

Table 5.2-3: Attainment Status of Criteria Pollutants in the South Coast Air Basin (SCAB) Criteria Pollutant State Designation Federal Designation O3 – 1-hour standard Nonattainment --
O3 – 8-hour standard Nonattainment Nonattainment
PM10 Nonattainment Attainment
PM2.5 Nonattainment Nonattainment
CO Attainment Unclassifiable/Attainment
NO2 Attainment Unclassifiable/Attainment
SO2 Unclassifiable/Attainment Unclassifiable/Attainment Pb3 Attainment Unclassifiable/Attainment
Source: AQ, 2022 (Appendix B).

The TVSP area consists of approximately 947 acres of land that surrounds three proposed Arrow stations.

The area is current developed with a mix of commercial, industrial, and residential uses (including Redlands’ downtown business district and a segment of Interstate 10 freeway). Air quality emissions are currently generated by operation of these existing uses and the related vehicular trips. 3 The federal nonattainment designation for lead is only applicable towards the Los Angeles County portion of the SCAB.

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Sensitive Land Uses
Land uses such as schools, children’s daycare centers, hospitals, and convalescent homes are considered to be more sensitive to poor air quality than the general public because the population groups associated with these uses have increased susceptibility to respiratory distress. In addition, residential uses are considered more sensitive to air quality conditions than commercial and industrial uses, because people generally spend longer periods of time at their residences, resulting in greater exposure to ambient air quality conditions.

Recreational land uses are considered moderately sensitive to air pollution. Exercise places a high demand on respiratory functions, which can be impaired by air pollution, even though exposure periods during exercise are generally short. In addition, noticeable air pollution can detract from the enjoyment of recreation. Existing sensitive receptors within and in the vicinity of the TVSP area consists of residences.

5.2.4 THRESHOLDS OF SIGNIFICANCE
According to Appendix G of the CEQA Guidelines, a project could have a significant adverse effect on air quality resources if it would:

AQ-1 Conflict with or obstruct implementation of the applicable air quality plan; AQ-2 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;
AQ-3 Expose sensitive receptors to substantial pollutant concentrations; or AQ-4 Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

The Initial Study established that the proposed Project would not result in impacts related to Threshold AQ4; and no further assessment of this impact is required in this EIR.

Regional Thresholds
The SCAQMD’s most recent regional significance thresholds from April 2019 for regulated pollutants are listed in Table 5.2-4. The SCAQMD’s CEQA air quality methodology provides that any projects that result in daily emissions that exceed any of the thresholds in Table 5.2-4 would be considered to have both an individually (project-level) and cumulatively significant air quality impact.

Table 5.2-4: SCAQMD Regional Air Quality Thresholds
Pollutant Construction Operations
NOx 100 lbs/day 55 lbs/day
VOC 75 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
PM2.5 55 lbs/day 55 lbs/day
SOx 150 lbs/day 150 lbs/day
CO 550 lbs/day 550 lbs/day
Lead 3 lbs/day 3 lbs/day
Source: AQ, 2022 (Appendix B)
Localized Significance Thresholds
SCAQMD developed LSTs to determine if emissions of NO2, CO, PM10, or PM2.5 generated at a project site would expose sensitive receptors to substantial concentrations of criteria air pollutants. LSTs are the maximum emissions from a project’s onsite activities that will not cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard at the nearest residence or sensitive Redlands Regular Meeting of 10-18-22 744 of 1815
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receptor. However, an LST analysis can only be conducted at a development project level, as LST thresholds are based on specific project site data points such as graded acres per day and distance to sensitive receptors, and quantification of LSTs is not applicable for this program-level environmental analysis. For informational purposes, Table 5.2-5, provides the localized significance thresholds for projects in the South Coast Air Basin.

Table 5.2-5: SCAQMD Localized Significance Thresholds
Air Pollutant (Relevant AAQS) Concentration
1-Hour CO Standard (CAAQS) 20 ppm
8-Hour CO Standard (CAAQS) 9.0 ppm
1-Hour NO2 Standard (CAAQS) 0.18 ppm
Annual NO2 Standard (CAAQS) 0.03 ppm
24-Hour PM10 Standard – Construction (SCAQMD) 10.4 µg/m3 24-Hour PM2.5 Standard – Construction (SCAQMD) 10.4 µg/m3 24-Hour PM10 Standard – Operation (SCAQMD) 2.5 µg/m3
24-Hour PM2.5 Standard – Operation (SCAQMD) 2.5 µg/m3
Annual Average PM10 Standard (SCAQMD) 1.0 µg/m3
Source: SCAQMD 2015
CO Hotspots
Areas of vehicle congestion have the potential to create pockets of CO called hotspots. These pockets have the potential to exceed the state one-hour standard of 20 ppm or the eight-hour standard of 9 ppm. Because CO is produced in greatest quantities from vehicle combustion and does not readily disperse into the atmosphere, adherence to ambient air quality standards is typically demonstrated through an analysis of localized CO concentrations. Hotspots are typically produced at intersections, where traffic congestion is highest because vehicles queue for longer periods and are subject to reduced speeds. With the turnover of older vehicles and introduction of cleaner fuels as well as implementation of control technology on industrial facilities, CO concentrations in the South Coast Air Basin and the state have steadily declined. The analysis of CO hotspots compares the volume of traffic that has the potential to generate a CO hotspot and the volume of traffic generated by the proposed Project.

5.2.5 METHODOLOGY
This analysis focuses on the nature and magnitude of the change in the air quality environment due to implementation of the proposed Project, based on the maximum development assumptions that are outlined in Section 3.0, Project Description.

Air pollutant emissions associated with the proposed Project would result from construction equipment usage and from construction-related traffic. Additionally, emissions would be generated from operations of the future residential and business uses and from traffic volumes generated by these new uses. The net increase in emissions generated by these activities and other secondary sources have been quantitatively estimated and compared to the applicable thresholds of significance recommended by SCAQMD.

Although the Project would comply with all of the applicable AQMD requirements, it should be noted that emission reductions associated with Rules 402, 1301, 1401, and 2305 cannot be quantified in the California Emissions Estimator Model (CalEEMod) and are therefore not reflected in the emissions presented herein.

Conversely, Rule 403 (Fugitive Dust) and Rule 1113 (Architectural Coatings) can be modeled in CalEEMod.

As such, credit for Rule 403 and Rule 1113 have been taken in the analysis.

AQMP Consistency
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SCAQMD’s CEQA Handbook suggests an evaluation of the following two criteria to determine whether a project involving a legislative land use action (such as the proposed General Plan land use and zoning designation changes) would be consistent or in conflict with the AQMP:

1. The project would not generate population and employment growth that would be inconsistent with SCAG’s growth forecasts.

2. The project would not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP.

Consistency Criterion No. 1 refers to the SCAG’s growth forecast and associated assumptions included in the AQMP. The future air quality levels projected in the AQMP are based on SCAG’s growth projections, which are based, in part, on the general plans of cities and counties located within the SCAG region. Therefore, if the level of housing or employment related to the proposed Project are consistent with the applicable assumptions used in the development of the AQMP, the Project would not jeopardize attainment of the air quality levels identified in the AQMP.

Consistency Criterion No. 2 refers to the California Ambient Air Quality Standards. An impact would occur if the long-term emissions associated with the proposed Project would exceed SCAQMD’s regional significance thresholds for operation-phase emissions.

Construction
Buildout of the TVSP is anticipated to occur over 18 years (2022 through 2040), with the location, type, and timing of site-specific development projects and construction activities determined by market demand.

Because of the uncertainty of the specific timing and methods of construction activities for future site-specific development projects that would occur by the proposed TVSP, a worst-case construction scenario is analyzed in this EIR. It was conservatively assumed that construction would occur throughout the 18-year period, and the emissions that would be generated from buildout of the proposed TVSP was averaged over this timeframe. Given a 18-year buildout, it is conservatively assumed that project-related development might be undergoing some stage of onsite activity (demolition, site preparation, and construction) on the theoretical “maximum construction day.” In addition, an estimate of the construction equipment that might be active on the theoretical “maximum construction day” was identified based on the size of parcels and type of existing development within the TVSP area. Further, it was assumed that construction from several projects could overlap. Thus, the EIR identifies the potentially worst case scenario.

Construction-generated emissions of criteria air pollutants and ozone precursors were assessed in accordance with methods recommended by SCAQMD. The proposed Specific Plan’s regional emissions were modeled using the California Emissions Estimator Model (CalEEMod), as recommended by SCAQMD. CalEEMod was used to determine whether construction-related emissions of criteria air pollutants associated with the proposed TVSP could exceed applicable regional thresholds and if mitigation would be required.

Operations
Long-term (i.e., operational) regional emissions of criteria air pollutants and precursors, including mobileand area-source emissions from the Project, were also quantified using the CalEEMod computer model. Areasource emissions were modeled according to the size and type of the land uses proposed. Mass mobilesource emissions were modeled based on the increase in daily vehicle trips that would result from the proposed Project. Predicted long-term operational emissions were compared with applicable SCAQMD thresholds for determination of significance.

5.2.6 ENVIRONMENTAL IMPACTS
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As detailed in Section 3.0, Project Description, the proposed Project would provide a form-based code that would allow development of up to 2,400 residential units; 613,000 square feet of retail commercial, hotel, and office space; and 280,000 square feet of open space and parks within the TVSP area. However, the timing of development and operation of the development pursuant to the TVSP would be dependent upon market conditions and development applications for new projects. Due to the unknown nature and incremental timing of the Project, the air quality impact analysis includes conservative assumptions that provides for identification of the maximum potential impacts.

IMPACT AQ-1: THE PROJECT WOULD CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF AN

APPLICABLE AIR QUALITY PLAN
Significant and Unavoidable Impact. The SCAQMD’s 2016 AQMP is the applicable air quality plan for the proposed TVSP area. Pursuant to Consistency Criterion No. 1, the SCAQMD’s 2016 AQMP is the applicable air quality plan for the proposed Project. Projects that are consistent with the regional population, housing, and employment forecasts identified by SCAG are considered to be consistent with the AQMP growth projections, since the forecast assumptions by SCAG forms the basis of the land use and transportation control portions of the AQMP. Additionally, because SCAG’s regional growth forecasts are based upon, among other things, land uses designated in general plans, a project that is consistent with the land use designated in a general plan would also be consistent with the SCAG’s regional forecast projections, and thus also with the AQMP growth projections.

The proposed TVSP includes amending the GP2035 to establish a new TVD land use designation to provide for infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations. The form-based code that would be implemented by the proposed TVSP emphasizes building form, a mix and density of different transit-oriented development, pedestrian circulation, and public realm improvements and amenities. This includes a network of complete, multi-modal streets that provide for pedestrians, bicyclists, transit patrons, and motorists.

As detailed in Section 5.11, Population and Housing, buildout of the proposed TVSP would allow development of 2,400 residential units and 613,000 square feet of retail commercial, hotel, and office space, representing a population of approximately 6,360 persons and 1,226 employees at buildout and full occupancy (maximum impact condition). Development pursuant to the proposed TVSP would consist mostly of infill, mixed-use, and redevelopment projects that are market and need dependent. Because the employment land designated areas in the TVSP area are existing and would not change with implementation of the TVSP, the 1,226 jobs expected in the TVSP area are included in the SCAG projections.

The SCAG 2020 RTP/SCS projections for the City of Redlands anticipate a 32.2 percent increase in employment in the City between 2016 and 2045 (an increase of 13,700 jobs). The 1,226 jobs that are anticipated to occur within the TVSP area would be approximately 8.9 percent of the anticipated job growth, and within the growth assumptions of the SCAG AQMP.

The housing added by the Specific Plan would help to meet housing demands from projected employment growth in the City while maintaining a healthy vacancy rate. The provision of housing within walking distance to the three new Arrow stations and community retail would reduce vehicle miles traveled and the related air quality emissions. In addition, the TVSP implements infill development, located in an urbanized area with existing infrastructure, near transit, and implements bicycle and pedestrian infrastructure; all of which are intended to reduce vehicle miles traveled and vehicular emissions. This is consistent with the SCAG objective to “Encourage patterns of urban development and land use that reduce costs in infrastructure construction and make better use of existing facilities.” Thus, the proposed TVSP would support AQMP objectives to reduce trips, promote infill development, and balance jobs and housing, and would not conflict with implementation of the AQMP. As a result, the proposed TVSP would comply with AQMD AQMP Consistency Criterion No. 1.

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Regarding Consistency Criterion No. 2, which evaluates the potential of the proposed Project to increase the frequency or severity of existing air quality violations; as described previously, an impact related to Consistency Criterion No. 2 would occur if the long-term emissions associated with the proposed Project would exceed SCAQMD’s regional significance thresholds for operation-phase emissions. As detailed below in Impact AQ-2, the Project would result in regional operational-source emissions that would exceed the thresholds of significance for CO, VOC, and NOX emissions after implementation of regulatory requirements and Mitigation Measures AQ-8 through AQ-10; and therefore, would result in an increase in the frequency or severity of existing air quality violations and contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP. Therefore, the proposed Project would result in an impact related to Consistency Criterion No. 2.

Overall, despite the Project’s consistency with SCAG’s regional growth forecasts, the Project would lead to increased regional air quality emissions that would exceed thresholds. Therefore, the proposed TVSP would result in a conflict with, or obstruct, implementation of the AQMP and impacts would be significant and unavoidable after implementation of the mitigation measures detailed below.

IMPACT AQ-2: THE PROJECT WOULD RESULT IN A CUMULATIVELY CONSIDERABLE NET INCREASE OF

A CRITERIA POLLUTANT FOR WHICH THE PROJECT REGION IS NON-ATTAINMENT

UNDER AN APPLICABLE FEDERAL OR STATE AMBIENT AIR QUALITY STANDARD Construction
Significant and Unavoidable Impact. Construction activities associated with the Project would result in emissions of CO, VOCs, NOx, SOx, PM10, and PM2.5. Pollutant emissions associated with construction would be generated from the following construction activities: (1) demolition, grading, and excavation; (2) construction workers traveling to and from the TVSP area; (3) delivery and hauling of construction supplies to, and debris from, the TVSP area; (4) fuel combustion by onsite construction equipment; (5) building construction; application of architectural coatings; and paving. These construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants.

As described previously, the timing of development and operation of the development pursuant to the TVSP would be dependent upon market conditions and development applications for new projects. Thus, construction activities associated with buildout of the proposed TVSP would likely occur sporadically over an 18-year period or longer. Due to the uncertainty of the specific timing and methods of construction activities related to TVSP development projects, the maximum daily emissions are based on a very conservative scenario that construction could occur throughout the TVSP implementation period, based on maximum equipment use, and multiple future TVSP development projects overlapping. The construction modeling of potential construction impacts assumed the following construction equipment would be used during construction of TVSP development projects.

Table 5.2-6: Construction Equipment Assumptions
Construction Activity Equipment Amount Hours Per Day
Demolition
Concrete/Industrial Saws 1 8
Excavators 3 8
Rubber Tired Dozers 2 8
Site Preparation Crawler Tractors 4 8
Rubber Tired Dozers 3 8
Grading
Crawler Tractors 2 8
Excavators 2 8
Graders 1 8
Rubber Tired Dozers 1 8
Scrapers 2 8
Building Construction Cranes 1 8
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Forklifts 3 8
Generator Sets 1 8
Tractors/Loaders/Backhoes 3 8
Welders 1 8
Paving
Pavers 2 8
Paving Equipment 2 8
Rollers 2 8
Architectural Coating Air Compressors 1 8
Source: AQ, 2022 (Appendix B).

The maximum daily construction emissions for the proposed TVSP were estimated using CalEEMod; and the modeling includes compliance with SCAQMD Rules 403 and 1113 (described above). Table 5.2-7 provides the maximum daily emissions of criteria air pollutants from construction under the scenario of multiple development projects being implemented simultaneously. As shown, under this scenario emissions from construction would exceed thresholds established by the SCAQMD for emissions of VOCs and NOX.

Table 5.2-7: Maximum Peak Construction Emissions Without Mitigation Construction Activity Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Demolition 21.19 219.81 206.38 0.41 16.69 10.76
Site Preparation 24.85 287.64 147.08 0.37 73.31 40.27
Grading 34.10 384.79 249.01 0.65 55.35 29.27
Building Construction 48.18 288.26 532.02 1.45 94.37 32.79 Paving 7.08 65.36 105.42 0.17 4.33 3.26
Architectural Coating 590.53 13.78 33.00 0.07 5.20 1.89 Winter
Demolition 21.21 220.19 205.88 0.41 16.69 10.76
Site Preparation 24.87 287.67 146.63 0.37 73.31 40.27
Grading 34.12 385.10 248.40 0.64 55.35 29.27
Building Construction 49.49 292.42 508.98 1.41 94.37 32.79 Paving 7.10 65.38 105.12 0.17 4.33 3.26
Architectural Coating 590.61 13.85 31.72 0.07 5.20 1.89 Maximum Daily Emissions 590.61 385.10 532.02 1.45 94.37 40.27 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? Yes Yes No No No No
Source: AQ, 2022 (Appendix B).

As shown in Table 5.2-7, emissions resulting from construction would exceed criteria pollutant thresholds for VOC and NOx. Development projects would be required, through City review and construction permitting, to implement SCAQMD rules, including: Rule 401, Rule 402, Rule 403, Rule 481, Rule 1108, Rule 1113, and Rule 1143 (described previously) that would reduce construction related emissions. Also, Mitigation Measures AQ-1 through AQ-7 are included to require the construction activities to utilize “Super-Compliant” low VOC paints that have no more than 10g/L of VOC, which exceeds the regulatory VOC limits put forth by SCAQMD’s Rule 1113, require all construction equipment greater than 150 horsepower (>150 HP) to be CARB certified tier 3 or higher, use of electrical and alternative fueled equipment, and other similar measures. With implementation of Mitigation Measures AQ-1 through AQ-6, emissions of VOC and NOx from construction activities would be reduced and emissions from most TVSP developments would be reduced to below the SCAQMD significance thresholds. However, due to the potential overlap of development projects and construction activities, it cannot be assured that the mitigation measures would reduce emissions below the SCAQMD significance thresholds. As shown in Table 5.2-7, VOC emissions have the potential to be 7.9 times higher than the threshold, and NOX emissions have the potential to be over 3.8 times higher Redlands Regular Meeting of 10-18-22 749 of 1815
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than the threshold, with this level of potential emissions exceedances during overlapping construction projects, construction emissions could continue to exceed thresholds with implementation of Mitigation Measures AQ1 through AQ-6. Therefore, based on the very conservative scenario of construction timing and construction equipment use, impacts related to construction emissions would remain significant and unavoidable.

Operation
Significant and Unavoidable. Development pursuant to the proposed TVSP would consist mostly of infill, mixed-use, and redevelopment projects that are market and need dependent. Additionally, the residential development that would occur would help to meet housing demands from projected employment growth in the City and be in the proximity to transit and commercial uses that would reduce dependence of vehicles and result in a reduction in vehicle miles traveled.

The new development identified by the TVSP would generate in long-term emissions of criteria air pollutants from area sources generated by vehicular emissions, natural gas consumption, landscaping, applications of architectural coatings, and use of consumer products, which are typical of residential, commercial, and office uses. As shown in Table 5.2-8, operation of the land uses included in the TVSP at buildout and full occupancy would generate emissions that would exceed the applicable SCAQMD thresholds for CO, VOC, and NOX.

Table 5.2-8: Summary of Peak Operational Emissions
Area Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
State Street Village 26.07 10.36 110.85 0.13 11.36 0.76 The Grand Apartments 5.52 4.66 29.63 0.06 5.40 1.68
City Center Mixed-Use 6.38 5.16 35.94 0.07 7.47 2.22
Downtown Village Future Projects 15.19 11.18 96.27 0.20 24.41 6.82 University Village 45.99 36.52 245.15 0.47 47.53 14.42
New York Street Village 18.34 12.06 97.36 0.20 24.32 6.88 Total Maximum Daily Emissions 117.49 79.95 615.20 1.13 120.48 32.78 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? Yes Yes Yes No No No
Winter
State Street Village 25.80 10.74 110.20 0.13 11.36 0.76 The Grand Apartments 5.47 4.77 29.25 0.06 5.40 1.68
City Center Mixed-Use 6.27 5.33 35.59 0.07 7.47 2.22
Downtown Village Future Projects 14.78 11.76 95.36 0.19 24.41 6.82 University Village 45.31 37.57 242.81 0.46 47.53 14.42
New York Street Village 17.99 12.61 96.11 0.19 24.32 6.88 Total Maximum Daily Emissions 115.61 82.78 609.31 1.09 120.48 32.78 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? Yes Yes Yes No No No
Source: AQ, 2022 (Appendix B).

As a result, Mitigation Measure AQ-7 would be implemented to require development projects in the TVSP area to achieve 5 percent efficiency beyond the incumbent California Building Code Title 24 requirements; and Mitigation Measure AQ-8 would require enhanced water conservation for TVSP development projects.

However, similar to the analysis presented in the General Plan EIR, even with implementation of Mitigation Measures AQ-7 and AQ-8, emissions would continue to exceed regional thresholds of significance established by the SCAQMD, and impacts would be significant and unavoidable.

It is important to note that the majority of VOC emissions are derived from consumer products. For analytical purposes, consumer products include cleaning supplies, aerosols, and other consumer products. As such, the Project applicant cannot meaningfully control the use of consumer products by future building users via Redlands Regular Meeting of 10-18-22 750 of 1815
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mitigation. On this basis, it is concluded that Project operational-source VOC emissions cannot be definitively reduced below applicable SCQMD thresholds.

Additionally, it should be noted that the majority of the Project’s CO and NOX emissions are derived from vehicle usage. Since neither future project applicants nor the City have regulatory authority to control tailpipe emissions, no feasible mitigation measures exist that would reduce these emissions to levels that are lessthan-significant.

Health Impacts of Exceeded Criteria Pollutant Emissions. The Draft EIR identifies a significant and unavoidable impact with respect to CO, NOx, and VOC emissions, due largely to the use of consumer products and vehicle trips. NOx is a “criteria” pollutant, a pollutant that is regulated by the US EPA pursuant to the federal Clean Air Act. The potential health impacts of criteria pollutants are analyzed on a regional level, not on a facility/project level. The SCAQMD and the San Joaquin Valley Unified Air Pollution Control District (SJVAPD), experts in the area of air quality, both recognize that a meaningful, accurate analysis of potential health impacts resulting from criteria pollutants is not currently possible and not likely to yield substantive information that promotes informed decision making. The SJVAPD, in its amicus curiae brief for the recent California Supreme Court decision in Sierra Club v. County of Fresno (2018)6 Cal.5th 502, explained that “it is not feasible to conduct a [health impact analysis] for criteria air pollutants because currently available computer modeling tools are not equipped for this task.” The SJVAPD described a project-specific health impact analysis as “not practicable and not likely to yield valid information” because “currently available modeling tools are not well suited for this task.” The SJVAPD further noted that “…the CEQA air quality analysis for criteria pollutants is not really a localized, project-level impact analysis but one of regional” cumulative impacts.

It should also be noted that CO, NOx, and VOCs are “precursor” pollutants, which makes analysis of potential health impacts even more difficult. CO, NOx, and VOCs are precursors to ozone, which is formed in the atmosphere from the chemical reaction of CO, NOx, and VOCs in the presence of sunlight. As explained by the SCAQMD in its amicus curiae brief for Sierra Club v. County of Fresno, it takes time and the influence of meteorological conditions for these reactions to occur, so ozone may be formed at a distance downwind from the sources.” Given this, “…it takes a large amount of additional precursor emissions to cause a modeled increase in ambient ozone levels over an entire region.” Therefore, SCAQMD opined that while it “may be feasible” for large, regional projects with very high emissions of CO, NOx, and VOCs to conduct an accurate health impact analysis, SCAQMD staff does not currently know of a way to accurately quantify ozone-related health impacts caused by CO, NOx, or VOC emissions from relatively small projects.

Thus, the difficulties with preparing potential health impact analysis related to the Project’s CO, NOx, and VOC emissions are twofold. First, current modeling is not capable of correlating emissions of criteria pollutants to concentrations that can be reasonably linked to specific health impacts. Second, CO, NOx, and VOCs are precursor emissions and concentrations of CO, NOx, and VOC are impacted by regional atmospheric conditions. CO, NOx, and VOCs emitted by the Project may, depending upon interactions with the sun and other emissions, convert to ozone by complex chemical processes. Thus, there is a significant level of unpredictability associated with such conversion to ozone, as noted by the SCAQMD and the SJVAPD. It should also be noted that the EIR does identify health concerns related to CO and NOx emissions. Table 5.2- 1 includes a list of criteria pollutants and summarizes common sources and effects. Thus, the EIR’s analysis is reasonable and intended to foster informed decision making.

IMPACT AQ-3: THE PROJECT WOULD NOT EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL

POLLUTANT CONCENTRATIONS
CO Hotspots
Less than Significant Impact. An adverse CO concentration, known as a “hot spot”, would occur if an exceedance of the State’s one-hour standard of 20 ppm or the eight-hour standard of 9 ppm were to occur.

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The 2003 AQMP estimated traffic volumes that could generate CO concentrations to result in a “hot spot”.

As shown in Table 5.2-10, the Wilshire-Veteran intersection had a daily traffic volume of approximately 100,000 vehicles per day, and the 1-hour CO concentration was 4.6 ppm. This indicates that, even with a traffic volume of 400,000 vehicles per day, CO concentrations (4.6 ppm x 4= 18.4 ppm) would still not exceed the most stringent 1-hour CO standard (20.0 ppm).4 Table 5.2-10: Traffic Volumes for Intersections Evaluated in 2003 AQMP Intersection Location
Peak Traffic Volumes (vph)
Eastbound
(a.m./p.m.)
Westbound
(a.m./p.m.)
Southbound
(a.m./p.m.)
Northbound
(a.m./p.m.)
Total
(a.m./p.m.)
Wilshire-Veteran 4,954/2,069 1,830/3,317 721/1,400 560/933 8,062/7,719 Sunset-Highland 1,417/1,764 1,342/1,540 2,304/1,832 1,551/2,238 6,614/5,374 La Cienega-Century 2,540/2,243 1,890/2,728 1,384/2,029 821/1,674 6,634/8,674 Long Beach-Imperial 1,217/2,020 1,760/1,400 479/944 756/1,150 4,212/5,514 Source: AQ, 2022 (Appendix B).

Operation of the proposed Project at buildout during AM peak hour would result in a total of 1,896 trips throughout the TVSP area and a total of 1,816 trips in the PM peak hour throughout the TVSP area. These trips distributed throughout the TVSP area would not result in daily traffic volumes of 100,000 vehicles per day or more. As such, Project-related traffic volumes are less than the traffic volumes identified in the 2003 AQMP; and are not high enough to generate a CO “hot spot”. Therefore, impacts related to CO “hot spots” from operation of the proposed Project would be less than significant.

Localized Construction Air Quality Impacts
Less than Significant with Mitigation Incorporated. As described previously, an LST analysis can only be conducted at a development project level, and quantification of LST’s is not applicable for this programlevel environmental analysis. However, implementation of developments pursuant to the TVSP could result in localized emissions that exceed air quality standards. Thus, implementation of the TVSP could result in a significant impact related to LST’s. As a result, Mitigation Measure AQ-9 is included, which requires development projects to provide modeling of the regional and the localized emissions (NOX, CO, PM10, and PM2.5) associated with the maximum daily grading activities for the proposed development; and requires grading activity to be limited to ensure that there would be no impacts related to LST’s. Therefore, impacts related to localized construction air quality impacts would be less than significant with implementation of Mitigation Measure AQ-9.

Toxic Air Contaminants
Less than Significant with Mitigation Incorporated. CARB has issued advisory recommendations for siting new sensitive land uses in proximity to sources associated with Toxic Air Contaminants (TAC’s) and recommends performing site specific environmental evaluations. However, it is currently unknown what development projects that could include a sensitive receptor would be proposed next to an existing TAC, such as warehouses, industrial areas, freeways, roadways, and rail lines with traffic volumes over 10,000 vehicle per day. Therefore, consistent with CARB guidance, Mitigation Measure AQ-10 is included to require a site-specific evaluation prior to approving any sensitive land use in proximity to an existing TAC within the TVSP area. Implementation of Mitigation Measure AQ-10 would reduce potential impacts related to TACs to a less than significant level.

5.2.7 CUMULATIVE IMPACTS
4 Based on the ratio of the CO standard (20.0 ppm) and the modeled value (4.6 ppm).

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As described previously, per SCAQMD’s methodology, if an individual project would result in air emissions of criteria pollutants that exceeds the SCAQMD’s thresholds for project-specific impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants.

As described in Impact AQ-2 above, emissions from construction of the proposed Project could exceed SCAQMD’s threshold for VOC and NOx after implementation of SCAQMD Rules and mitigation measures if several development projects within the TVSP area overlap.

Also, emissions from operation of the proposed Project at buildout would exceed SCAQMD’s threshold for CO, VOC, and NOx after implementation of mitigation measures. Because the large majority of operationalsource CO and NOx emissions (by weight) would be generated by project vehicles, and the VOC emissions would be generated by consumer products that neither future project applicants nor the City have the ability to reduce emissions of. Therefore, similar to the analysis presented in the General Plan EIR, operationalsource CO, VOC, and NOx emissions from implementation of the proposed Project would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable.

5.2.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
State
• Airborne Toxic Control Measure to Limit Diesel-Fuel Commercial Vehicle Idling (13 CCR 2485) • In-Use Off-Road Diesel Idling Restriction (13 CCR 2449) • California Green Building Standards Code (Code of Regulations, Title 24 Part 6) Regional
• SCAQMD Rule 201: Permit to Construct
• SCAQMD Rule 402: Nuisance Odors
• SCAQMD Rule 403: Fugitive Dust
• SCAQMD Rule 1108: Volatile Organic Compounds
• SCAQMD Rule 1113: Architectural Coatings
• SCAQMD Rule 1143: Paint Thinners and Solvents
Standard Conditions
None.

Plans, Programs, or Policies
None.

5.2.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, the following impacts would be potentially significant:

Impact AQ-1: Buildout of the proposed TVSP would increase the frequency or severity of existing air quality violations, and an impact regarding AQMP Consistency Criterion No. 2 would occur.

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Impact AQ-2: Construction and operation associated with buildout of the proposed TVSP would generate a substantial increase in criteria air pollutant emissions that exceed the threshold criteria and would cumulatively contribute to the nonattainment designations of the SCAB.

Impact AQ-3: Buildout of the proposed TVSP could result in new sources of criteria air pollutant emissions and/or toxic air contaminants proximate to existing or planned sensitive receptors.

5.2.10 MITIGATION MEASURES
Mitigation Measure AQ-1: Tier 3 Construction Equipment. Construction plans and specifications and construction permitting for developments within the TVSP area shall include the requirement that for construction equipment greater than 150 horsepower (>150 HP), the Construction Contractor shall use offroad diesel construction equipment that complies with Environmental Protection Agency (EPA)/California Air Resources Board (CARB) Tier 3 emissions standards during all construction phases and will ensure that all construction equipment be tuned and maintained in accordance with the manufacturer’s specifications.

Mitigation Measure AQ-2: Low VOC Paints. Construction plans and specifications and construction permitting for developments within the TVSP area shall include the requirement that “Super-Compliant” low VOC paints shall be utilized that have been reformulated to exceed the regulatory VOC limits put forth by SCAQMD’s Rule 1113. Super-Compliant low VOC paints shall be no more than 10 grams per liter (g/L) of VOC. Alternatively, the applicant may utilize tilt-up concrete buildings that do not require the use of architectural coatings.

Mitigation Measure AQ-3: Electric Construction Equipment. Construction plans and specifications and construction permitting for developments within the TVSP area shall include the requirement that contract specifications for construction activities rely on the electricity infrastructure surrounding the construction site, if available rather than electrical generators powered by internal combustion engines.

Mitigation Measure AQ-4: Alternative Fueled Construction Equipment. Construction plans and specifications and construction permitting for developments within the TVSP area shall include the requirement to use of alternative fueled, engine retrofit technology, after-treatment products (e.g., diesel oxidation catalysts, diesel particulate filters), and/or other options as they become available, including all off-road and portable diesel-powered equipment.

Mitigation Measure AQ-5: Construction Equipment Maintenance. Construction plans and specifications and construction permitting for developments within the TVSP area shall include the requirement that construction equipment be maintained in good operating condition pursuant to manufacturer specifications to reduce emissions. The Construction Contractor shall ensure that all construction equipment is being properly serviced and maintained as per the manufacturer’s specification. Maintenance records shall be available at the construction site for City verification.

Mitigation Measure AQ-6: Construction Vehicle Management Plan. Prior to the issuance of any grading permits for developments within the TVSP area, the applicant and/or building operators shall submit construction plans and a construction vehicle management plan to the City of Redlands denoting the proposed schedule and projected equipment use. The construction vehicle management plan shall include such things as: idling time requirements; requiring hour meters on equipment; documenting the serial number, horsepower, age, and fuel of all onsite equipment. The plan shall include that California state law requires equipment fleets to limit idling to no more than 5 minutes. Construction contractors shall provide evidence that low emission mobile construction equipment will be utilized, or that their use was investigated and found to be infeasible for the project as determined by the City. Contractors shall also conform to any construction measures imposed by the SCAQMD as well as City Planning Staff.

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Mitigation Measure AQ-7: Enhanced Energy Efficiency. Prior to the issuance of building permits, the Project applicant shall submit energy usage calculations to the Planning Division showing that the Project is designed to achieve 5 percent (%) efficiency beyond the incumbent California Building Code Title 24 requirements.

Example of measures that reduce energy consumption include, but are not limited to, the following (it being understood that the items listed below are not all required and merely present examples; the list is not allinclusive and other features that reduce energy consumption also are acceptable):
• Increase in insulation such that heat transfer and thermal bridging is minimized; • Limit air leakage through the structure and/or within the heating and cooling distribution system; • Use of energy-efficient space heating and cooling equipment; • Installation of electrical hook-ups at loading dock areas; • Installation of dual-paned or other energy efficient windows; • Use of interior and exterior energy efficient lighting that exceeds then incumbent California Title 24 Energy Efficiency performance standards;
• Installation of automatic devices to turn off lights where they are not needed; • Application of a paint and surface color palette that emphasizes light and off-white colors that reflect heat away from buildings;
• Design of buildings with “cool roofs” using products certified by the Cool Roof Rating Council, and/or exposed roof surfaces using light and off-white colors; • Design of buildings to accommodate photo-voltaic solar electricity systems or the installation of photo-voltaic solar electricity systems;
Installation of ENERGY STAR-qualified energy-efficient appliances, heating and cooling systems, office equipment, and/or lighting products.

Mitigation Measure AQ-8: Enhanced Water Conservation. To reduce water demands and associated energy use, subsequent development proposals within the TVSP area shall incorporate a Water Conservation Strategy and demonstrate a minimum 30% reduction in outdoor water usage when compared to baseline water demand (total expected water demand without implementation of the Water Conservation Strategy)5 .

Development proposals within the TVSP area shall also implement the following:
• Landscaping palette emphasizing drought tolerant plants; • Use of water-efficient irrigation techniques;
• U.S. EPA Certified WaterSense labeled or equivalent faucets, high-efficiency toilets (HETs), and water-conserving shower heads.
• Use of recycled water when available.

Mitigation Measure AQ-9: Localized Emissions. For implementing projects within the TVSP area, the applicant shall be responsible for submitting a focused project-level air quality assessment that includes the modeling of localized on-site emissions associated with daily grading activities anticipated for the proposed development. During the City’s review process of development applications in the TVSP area, the applicant shall conduct or shall have conducted modeling of the regional and the localized emissions (nitrogen oxides [NOX], carbon monoxide [CO], Particulate Matter 10 microns in diameter or less [PM10], and Particulate Matter 2.5 microns in diameter or less [PM2.5]) associated with the maximum daily grading activities estimated for the proposed individual developments. If the modeling shows that emissions would exceed the 5 The analysis includes a reduction of 20% indoor water usage consistent with the current CALGreen Code (11) for residential and non-residential land uses. Per CALGreen, the reduction shall be based on the maximum allowable water use per plumbing fixture and fittings as required by the California Building Standards Code.

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SCAQMD’s significance thresholds for those emissions, the maximum daily grading activities of the proposed development shall be limited to the extent that could occur without resulting in emissions in excess of SCAQMD’s significance thresholds for those emissions.

Mitigation Measure AQ-10: Toxic Air Contaminants. Applicants for residential and other sensitive land use projects (e.g., hospitals, nursing homes, day care centers) in the TVSP area within 1,000 feet of a major sources of TACs (e.g., warehouses, industrial areas, freeways, roadways, and rail lines with traffic volumes over 10,000 vehicle per day), as measured from the property line of the project to the property line of the source/edge of the nearest travel lane, shall submit a health risk assessment (HRA) to the City of Redlands prior to future discretionary project approval. The HRA shall be prepared in accordance with policies and procedures of CEQA and the SCAQMD. If the HRA shows that the incremental cancer risk exceeds ten in one million (10E-06), PM10 concentrations exceed 2.5 microgram per cubic meter (µg/m3), PM2.5 concentrations exceed 2.5 µg/m3, or the appropriate noncancer hazard index exceeds 1.0, the applicant will be required to identify and demonstrate that mitigation measures are capable of reducing potential cancer and noncancer risks to an acceptable level (i.e., below ten in one million or a hazard index of 1.0), including appropriate enforcement mechanisms. Measures to reduce risk may include but are not limited to:
• Air intakes located away from high volume roadways and/or truck loading zones. • Heating, ventilation, and air conditioning systems of the buildings provided with appropriately sized maximum efficiency rating value (MERV) filters (e.g., MERV 13 or better).

5.2.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact AQ-1: Land use change of the Project would not result in an exceedance of SCAG’s growth projections, but the Project would result in an increase of criteria pollutants that would exceed regional thresholds after implementation of mitigation. Therefore, the proposed Project would result in a conflict with, or obstruct, implementation of the AQMP and impacts would be significant and unavoidable.

Impact AQ-2: Emissions from the construction of the implementing projects have the potential to overlap, which could result in a significant impact after implementation of SCAQMD Rules and Mitigation Measures AQ-1 through AQ-7.

Emissions from operation of the proposed TVSP at buildout would exceed SCAQMD’s thresholds for CO, VOC, and NOx after implementation of regulations and mitigation measures. Because a majority of operational-source CO and NOx emissions (by weight) would be generated by vehicle trips, and the VOC emissions would be generated by consumer products that neither future Project applicants nor the City have the ability to reduce emissions of. Therefore, operational-source CO, VOC, and NOx emissions from implementation of the proposed Project would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable.

Impact AQ-3: After implementation of Mitigation Measures AQ-9 and AQ-10, localized and toxic air contaminant emissions would not exceed the SCAQMD’s localized significance threshold for any of the pollutants or TAC related threshold. Thus, impacts would be less than significant.

REFERENCES
City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report 2017.

Accessed: https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands 2035 General Plan, 2017. Accessed: https://www.cityofredlands.org/post/planningdivision-general-plan Redlands Regular Meeting of 10-18-22 756 of 1815
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City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 SCAG 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction. Accessed:
https://scag.ca.gov/sites/main/files/fileattachments/2016_2040rtpscs_finalgrowthforecastbyjurisdiction.pdf?1605576071 Urban Crossroads. “Transit Villages District and Specific Plan Air Quality Impact Analysis” 2022. Appendix B.

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5.3 Cultural Resources

5.3.1 INTRODUCTION
This section addresses potential environmental effects of the Project related to cultural resources, which include historic and archaeological resources. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035, December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), Dyett & Bhatia, July 2017;
• City of Redlands Municipal Code;
• Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments, Material Culture Consulting, February 2022 (Appendix C).

In accordance with Public Resources Code Section 15120(d), certain information and communications that disclose the location of archaeological sites and sacred lands are allowed to be exempt from public disclosure.

Cultural Resources Terminology
• Archaeological resources include any material remains of human life or activities that are at least 100 years of age, and that are of scientific interest. A unique or significant archaeological resource is an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it (1) contains information needed to answer important scientific research questions and there is a demonstrable public interest in that information; (2) has a special and particular quality, such as being the oldest of its type or the best available example of its type; and (3) is directly associated with a scientifically recognized important prehistoric or historic event or person. • Cultural resources are defined as buildings, sites, structures, or objects, each of which may have historic, architectural, archaeological, cultural, or scientific importance, according to the California Environmental Quality Act (CEQA).
• Historic building or site is one that is noteworthy for its significance in local, state, or national history or culture, its architecture or design, or its works of art, memorabilia, or artifacts. • Historic context refers to the broad patterns of historical development in a community or its region that is represented by cultural resources. A historic context statement is organized by themes such as economic, residential, and commercial development.
• Historic integrity is defined as “the ability of a property to convey its significance.” • Historical resources are defined as “a resource listed or eligible for listing on the California Register of Historical Resources” (CRHR) (Public Resources Code, Section 5024.1; 14 CCR 15064.5). Under CEQA Guidelines Section 15064.5(a), the term “historical resources” includes the following:
(1) A resource listed in or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Public Resources Code, Section 5024.1).

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(2) A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public Resources Code or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
(3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (Public Resources Code Section 5024.1) including the following:
(A) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; (B) Is associated with the lives of persons important in California’s past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
(D) Has yielded, or may be likely to yield, information important in prehistory or history. (4) The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to Section 5020.1(k) of the Public Resources Code), or identified in a historical resources survey (meeting the criteria in Section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code Sections 5020.1(j) or 5024.1.

5.3.2 REGULATORY SETTING

5.3.2.1 Federal Regulations
National Historic Preservation Act
The National Historic Preservation Act of 1966 (NHPA) established the National Register of Historic Places (National Register), which is the official register of designated historic places. The National Register is administered by the National Park Service, and includes listings of buildings, structures, sites, objects, and districts that possess historical, architectural, engineering, archaeological, or cultural significance at the national, state, or local level.

To be eligible for the National Register, a property must be significant under one or more of the following criteria per 36 Code of Federal Regulations Part 60:
a) Properties that are associated with events that have made a significant contribution to the broad patterns of our history;
b) Properties that are associated with the lives of persons significant in our past; Redlands Regular Meeting of 10-18-22 759 of 1815
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c) Properties that embody the distinctive characteristics of a type, period or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or d) Properties that have yielded, or may be likely to yield, information important in prehistory or history.

In addition to meeting one or more of the aforementioned criteria, an eligible property must also possess historic “integrity,” which is “the ability of a property to convey its significance.” The National Register criteria recognize seven qualities that define integrity: location, design, setting, materials, workmanship, feeling, and association.

Structures, sites, buildings, districts, and objects over 50 years of age can be listed in the National Register as significant historical resources. Properties under 50 years of age that are of exceptional importance or are contributors to a district can also be included in the National Register.

Properties listed in or eligible for listing in the NRHP are also eligible for listing in the California Register of Historic Resources, and as such, are considered historical resources for CEQA purposes.

National Register of Historic Places
The National Register of Historic Places (NRHP) was established by the NHPA of 1966 as “an authoritative guide to be used by Federal, State, and local governments, private groups and citizens to identify the Nation’s cultural resources and to indicate what properties should be considered for protection from destruction or impairment.” The NRHP recognizes properties that are significant at the national, state, and local levels. To be eligible for listing in the NRHP, a resource must be significant in American history, architecture, archaeology, engineering, or culture. Districts, sites, buildings, structures, and objects of potential significance must also possess integrity of location, design, setting, materials, workmanship, feeling, and association.

A property is eligible for the NRHP if it is significant under one or more of the following criteria:

Criterion A: It is associated with events that have made a significant contribution to the broad patterns of our history;
Criterion B: It is associated with the lives of persons who are significant in our past; Criterion C: It embodies the distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic values, or represents a significant and distinguishable entity whose components may lack individual distinction; and/or
Criterion D: It has yielded, or may be likely to yield, information important in prehistory or history.

Archaeological Resources Protection Act
The Archaeological Resources Protection Act (ARPA) of 1979 regulates the protection of archaeological resources and sites on federal and Indian lands. The ARPA regulates authorized archaeological investigations on federal lands; increased penalties for looting and vandalism of archaeological resources; required that the locations and natures of archaeological resources be kept confidential in most cases. In 1988, amendments to the ARPA included a requirement for public awareness programs regarding archaeological resources.

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5.3.2.2 State Regulations
California Register of Historical Resources
Eligibility for inclusion in the California Register of Historical Resources (CRHR) is determined by applying the following criteria:
1) It is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;
2) It is associated with the lives of persons important in California’s past; 3) embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic value; or 4) It has yielded or is likely to yield information important in prehistory or history. The Register includes properties which are listed or have been formally determined to be eligible for listing in the National Register, State Historical Landmarks, and eligible Points of Historical Interest (PRC §5024.1).

In addition to meeting one or more of the above criteria, the CRHR requires that sufficient time has passed since a resource’s period of significance to “obtain a scholarly perspective on the events or individuals associated with the resources.” (CCR 4852 [d][2]). The California Register also requires that a resource possess integrity. This is defined as the ability for the resource to convey its significance through seven aspects: location, setting, design, materials, workmanship, feeling, and association.

California Health and Safety Code, Section 7050.5
This code requires that if human remains are discovered on a project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation into the circumstances, manner, and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative. If the coroner determines that the remains are not subject to his or her authority and recognizes or has reason to believe the human remains are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.

Public Resources Code Section 5097.98
Public Resources Code Section 5097.98 provides guidance on the appropriate handling of Native American remains. Once the NAHC receives notification from the Coroner of a discovery of Native American human remains, the NAHC is required to notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permission of the owner of the land, or his or her authorized representative, inspect the site of discovery of the Native American human remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. According to Public Resources Code Section 5097.98(k), the NAHC is authorized to mediate disputes arising between landowners and known descendants relating to the treatment and disposition of Native American human burials, skeletal remains, and items associated with Native American burials.

CEQA Guidelines Section 15064.5
Section 15064.5 provides guidelines for determining the significance of impacts to archaeological and historical resources. The section provides the definition of historical resources, and how to analyze impacts to Redlands Regular Meeting of 10-18-22 761 of 1815
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resources that are designated or eligible for designation as a historical resource. Section 15064.5 additionally provides provisions for the accidental discovery or recognition of human remains in any location other than a dedicated cemetery.

5.3.2.3 Local Regulations
City of Redlands General Plan 2035
The GP2035 Distinctive City Element contains the following policies and actions related to historical and archaeological resources that are applicable to the proposed Project:

Principle 2-P.8 Identify, maintain, protect, and enhance Redlands’ cultural, historic, social, economic, architectural, agricultural, archaeological, and scenic heritage. In so doing, Redlands will preserve its unique character and beauty, foster community pride, conserve the character and architecture of its neighborhoods and commercial and rural areas, enable citizens and visitors to enjoy and learn about local history, and provide a framework for making appropriate physical changes.

Principle 2-P.9 Provide incentives to protect, preserve, and maintain the City’s heritage Principle 2-P.11 Encourage retention of the character of existing historic structures and urban design elements that define the built environment of the City’s older neighborhoods.

Principle 2-P.12 Encourage retention of historic structures in their original use or reconversion to their original use where feasible. Encourage sensitive, adaptive reuse where the original use is no longer feasible.

Principle 2-P.14 Coordinate preservation of historic resources with policies designed to preserve neighborhoods and support the affordability of housing in historical structures.

Principle 2-P.15 Balance the preservation of historic resources with the desire of property owners of historic structures to adopt energy efficient strategies.

Action 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.

Action 2-A.26 Provide development standards and guidelines to encourage conversion of historic structures to alternative uses without compromising the quality of the neighborhood if preservation of the original use is an economic hardship.

Action 2-A.34 Uphold the designation of the following streets within the city as scenic highways, drives, and historic streets. Special development standards have been adopted by Resolution for these streets. The streets are:
• Brookside Avenue, from Lakeside Avenue to Eureka Street; • Olive Avenue, from Lakeside Avenue to Cajon Street;
• Center Street, from Brookside Avenue to Crescent Avenue; • Highland Avenue, from Serpentine Drive to Cajon Street; • Sunset Drive, from Serpentine Drive to Edgemont Drive; • Cajon Street;
• Mariposa Drive, between Halsey and Sunset Drive; and
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• Dwight Street, between Pepper Street and Mariposa Drive.

In addition, consider designating the following roads as scenic drives within the community as neighborhood connectors and recreational routes for drivers and bike riders.
• Riverview Drive along the Santa Ana River Wash;
• Like Oak Canyon Road;
• San Timoteo Canyon Road;
• Sylvan Boulevard;
• Nevada Street, from the Orange Blossom Trail to Barton Road; • Pioneer Avenue, from River Bend Drive to Judson Street; and • Rural roads in Crafton.

Action 2-A.37 Maintain and improve City-owned historic buildings and houses in an architecturally and environmentally sensitive manner.

Action 2-A.38 Use exemplary design quality and sensitivity to surrounding historic structures in new City construction, public works, entry ways, and City signs.

Action 2-A.39 Ensure that permanent changes to the exterior or setting of a designated historic resource be done in accordance with the Secretary of the Interior standards for historic properties.

Action 2-A.41 Encourage appropriate adaptive reuse of historic resources in order to prevent disuse, disrepair, and demolition, taking care to protect surrounding neighborhoods from disruptive intrusions.

Action 2-A.42 Should demolition of a designated historic resource occur, endeavor to ensure that a building of equal or greater design quality and/or use of equal or greater benefit to the community be constructed. Require that a report documenting the history of the property and archival-quality drawings and/or photographic records be prepared to document the historic resource.

Action 2-A.43 Institute an architectural salvage program to preserve architectural artifacts from buildings that are demolished.

Action 2-A.48 Establish design review guidelines for historic areas to ensure that new architecture will relate to and respect the historical and environmental context.

Action 2-A.70 Encourage preservation of historic public and private improvements, such as street curbs, street trees, specimen trees, streetlights, hitching posts, masonry walls, unpaved and early paved sidewalks, etc.

City of Redlands Historic and Scenic Preservation Ordinance The City of Redlands maintains its own local designation program for historic and scenic properties within the city. The Redlands Historic and Scenic Preservation Commission was established in 1986 to make recommendations, decisions, and determinations regarding the designation and protection of the historical, scenic, and cultural resources in Redlands. The Historic and Scenic Preservation Commission also reviews any exterior modifications to a designated historic resource or the demolition of a designated resource or any structure over fifty years old.

Redlands has eight locally-designated historic districts:

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• Eureka Street Historic District
• West Highland Avenue Historic and Scenic District
• Early Redlands Historic and Scenic District
• Normandie Court Historic District
• East Fern Avenue Historic and Scenic District
• Garden Hill Historic and Scenic District
• La Verne Street Historic and Scenic District
• Smiley Park Historic and Scenic District
Redlands Historic Architectural Design Guidelines
The City of Redlands has drafted an update to the City of Redlands Historic Architectural Design Guidelines (currently under review since January 2021). The Redlands Historic Architectural Design Guidelines provide historic preservation standards and resources for property owners, design professionals, the City of Redlands Planning Department, and the Historic and Scenic Preservation Committee. The Design Guidelines provide standards for best preservation practices and contextual design when undertaking an exterior alteration or addition, changes to site or accessory features, restoration or rehabilitation of a historic building, or new construction on or adjacent to a historic site, historic and/or scenic district, or Character Category. The Design Guidelines also inform the reviews of demolition permit applications for structures that may be eligible or potentially eligible for local designation or preservation.

5.3.3 ENVIRONMENTAL SETTING
Archaeological Resources
A total of 53 cultural studies have been performed within a 0.5-mile radius of the TVSP area. Of these, 33 have been conducted within the TVSP area, with only one of the reports having been conducted within the last five years. The records search conducted for the Project identified one (1) previously recorded prehistoric archaeological resource, one (1) historic archaeological resource with a prehistoric component, and twentyfour (24) historic archaeological resources within TVSP area. The prehistoric archaeological resources are shown in Table 5.3-1, Recorded Prehistoric Archaeological Resources.

Table 5.3-1: Recorded Prehistoric Archaeological Resources Primary No. Description Location
P-36-012014/CASBR-012014HOne mano, a refuse dump, and a septic tank. The site was removed by construction activities in 2004.

Within TVSP
area
P-36-032951 Prehistoric isolate. Within TVSP
area
Source: MCC, 2022, Appendix C.

Historic Setting
An asistencia was established in Redlands in 1819 to help facilitate the Mission San Gabriel Arcángel’s control and colonization of the surrounding rancheria. Missionaries instructed Serrano, Gabrielino, and Cahuilla workers to build the Mill Creek Zanja, a 12-mile long irrigation ditch routing water from Mill Creek to Guachama Rancheria, which served as the area’s first stable water resource. In 1842, the Lugo family, including José del Carmen Lugo, José María Lugo, Vicente Lugo, and Diego Sepulveda, received a land grant, Rancho San Bernardino, which encompassed the San Bernardino and Yucaipa valleys, including present day City of Redlands.

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In 1881, E.G. Judson and Frank E. Brown formed the Redlands Water Company and began construction of a water canal to supply future citrus groves. During the development, the pair noticed the red-colored adobe soil and gave the new town its name, Redlands. Three years later, Brown built the Bear Valley Dam and reservoir, securing a steady supply of water for the town and associated citrus groves. With a stable water source and booming railways, the City of Redlands experienced a development boom with the creation of paved streets, sidewalks, sewage, and electricity systems. The City was officially incorporated in 1888. For 75 years, citrus growing was the main economic source for the City. The citrus industry eventually declined and agricultural areas were replaced with subdivisions. The former 15,000 acres of citrus groves, spanning the entirety of the city, have been reduced to only one grove left today, the Redlands Foothill Grove (CUL, 2022).

Historic Resources
There are 182 historic properties located within the TVSP area, with most of the eligible historic properties located in Downtown Redlands. The California Office of Historic Preservation’s (OHP) Built Environment Resources Directory (BERD) for San Bernardino County, the City of Redlands’ General Plan EIR (2017a), the City of Redlands’ Downtown Specific Plan (2017b), the City of Redlands’ List of Historic Resources (2019), the National Register (NR), the California Register of Historic Places (CR), California Historic Landmarks, and California Point of Historical Interest identify 114 historic properties within the TVSP area. Of these historic resources, 25 historic properties are listed in the National Register (NR) and/or the California Register (CR), three properties appear eligible for NR or CR, and 63 properties are designated as local historic resources.

Eleven properties have been determined ineligible for listing or designation and 13 properties have not been evaluated for NR or NR or need evaluation. In addition, there are two historic districts located within the TVSP area, the Smiley Park Historic District and Santa Fe Depot Historic District, as outlined on Table

5.3-2.

Table 5.3-2: List of Historical Properties within TVSP Area Name Address NR/CR Eligibility
Smiley Park Historic District
Michigan, Buena Vista, Parkwood,
Alvarado, Grant, Eureka, Fourth,
and Cajon Streets between Palm,
Cypress, Home Place, Fern, Clark,
Olive, Vine, and Brookside Streets 1S
n/a 251 S Fourth St SPHD, HD8
n/a 255 S Fourth St SPHD, HD8
n/a 201 Brookside Ave 5S2
n/a 122 Cajon St 5S2
n/a 123 Cajon St 5S2
Charles G. Rohrer House 131 Cajon St 5S2
n/a 215 Cajon St 1D, 5S2
n/a 243 Cajon St 1D, 5S2
n/a 248 Cajon St 6X
n/a 256 Cajon St 1D
n/a 261 Cajon St 1D, 5S2
A Harvey Collins House, Trolley Car
Barn 746 E Citrus Ave 7N, NR, HL27
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Name Address NR/CR Eligibility
Gold Banner Packing, Packing House
Antiques 1 E Olive Ave 7N
Star Grocery 1 E Redlands Blvd 5S2
Redlands Photographers 109 E State St 5S2
n/a 112 E State St 5S2
Frame N Lens 101 E Olive Ave 5S2
Underpinings 219 E Olive Ave 5S2
n/a 255 E Olive Ave 5S2
McMahan's 37 E Olive Ave 5S2
Rose of Sharon Salon 21 E Redlands Blvd 5S2
Goodie Shop 214 E Redlands Blvd 5S2
Children’s Carousel 215 E Redlands Blvd 7N
n/a 1 E State St 5S2
Citrograph house 10 E State St 5S2
J.C. Penney 104 E Olive Ave 5S2
Sligers Music 108 E Olive Ave 5S2
n/a 124 E Olive Ave 5S2
L And T Hobby 204 E Olive Ave 5S2
Pizza Chalet 208 E Olive Ave 5S2
Greg Wolfin Co. Grocery 213 E Olive Ave 5S2
Branch-Cooch Real Estate, Wilmouth
House 214 E Olive Ave 5S2, SPHD, HR26
Patio Shop 215 E Olive Ave 5S2, SPHD, HD8
Norris House 110 E State St 5S2
Medical Arts Building, Courtyard 113 E State St 5S2
Redlands Motorcycle Club, Redlands
Copies And Card 114 E State St 5S2
J.W. Hollett House 122 E State St 7N
Frank Meyer House 27 E State St 7N
Mission Gables Apartments 117 E State St 1D, 7N
E.D. Donham 120 E State St 7R
W.P. Griffitts House 14 E State St 7N
Walter Lynn House 15 E State St 7N
Daniel Cotcher House 17 E State St 7N
Dr. M. M. Horton House 18 E State St 7N
n/a 2 E State St 5S2
n/a 204 E State St 5S2
n/a 22 E State St 5S2
Buster Building 24 E State St 5S2, HR33
n/a 25 E State St 5S2
n/a 28 E State St 5S2
Cousin House 430 E State St 5S2
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Name Address NR/CR Eligibility
n/a 6 E State St 5S2
n/a 609 E State St 5S2
n/a 150 E Vine St 5S2
I.N. Hoag House 816 E High Ave HR13
Charles Midgley House 612 Lawton St 7N
Ferndinand Montiegel House 214 Myrtle St 7N
C.J. Crafts House 14 N 5th St 7N
Charles A. Nicholas House 345 N 5th St 7N
n/a 220 Nordina St 7N
Redlands Santa Fe Depot Historic
District Orange St 1S
Pioneer Transfer 348 (1001) Orange St 1D, 3D, SFDD
Atchison, Topeka, and Santa Fe Railway
Redlands Station 108 Orange St 1D,3B,7P
C.C. McCarty House 1101 Orange St 1D, 3D, HR82
Packard Motor Company Sales Office,
Coast Federal 415 (1157) Orange St 1D, SFDD
Home Oil Company 118 Orange St 5S2
E F Edwards Photography Shop 120 Orange St 5S
Lombard Building, Hamilton Block 206 Orange St 5S2, SFDD Levine’s 208 Orange St SFDD, 6Y
Gregg Block 216 Orange St SFDD, 5S2
Phinney Block 220 Orange St SFDD, HL34, 5S
E.J. Martin Home and Nursery 328 Orange St SFDD, 6X1
Gregory Packing House, Hamilton Block 330 Orange St SFDD, 3D, 6X 203 Oriental Ave, Beacon Printery 336 Orange St SFDD, 6X Redland Fruit Association Warehouse,
Worley Bldg 338 Orange St SFDD, 1D
Poundstone & Hamilton Building,
Oriental Street 342 Orange St SFDD, HL37, 7R
Palace Livery Stable 346 Orange St SFDD, 5S2
Santa Fe Railroad Station 351 Orange St SFDD, 5S2
Pioneer Transfer, Nordoff Home 348 Orange St SFDD, 3S, 7P Redlands City Transfer, Lite House,
Wade House 360 Orange St SFDD, 1D, 7N
Kohlman House, Packard Motor Co.

Sales Office 415 Orange St SFDD. 6X
n/a 418 Orange St 1D, 7N
Willard And Alice Cannady House 501 Orange St 1D
Kimberly Crest 921 Orange St 1C, 1D, 3S
Pergola, Major David Shaw House 928 Orange St HR75, 6X
Semi-Circular Pergola 930 Orange St 1CL, 1D
La Casada, Edward C Sterling Mansion 812 Stillman Ave 3S n/a 107 W Colton Ave 1D
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Name Address NR/CR Eligibility
J.H. Logie House 206 W Colton Ave 1D, 5S2, SPHD, HD8
n/a 208 W Colton Ave 1D, 5S2
W.F. Holt House 2 W Olive Ave 1D, 3S
C.C. Ames House 24 W Olive Ave 1D, 5S2
n/a 329 W State St 5S2
Cope Commercial Co. Warehouse 21 W Stuart Ave 1D, SFDD
Rettig Machine Shop 205 W Stuart Ave 2B
Property Acquistion And Rehabilitation 816 Clay St 6Y
n/a 411 N University St HR124
Second Baptist Church 420 E Stuart Ave Significant Historic Properties (City of
Redlands 2017b)
First Presbyterian Church 100 Cajon St 2S2
n/a 816 Clay St 5S2
n/a 1131 Columbia St 6Y
n/a 812 Stillman Ave 6Y
Old Chamber of Commerce 347 Orange St HL 40
Deming Building 526-528 Orange St Local Listing
Joseph E. Brown House 124 Eleventh St HR63
n/a 314 W Colton Ave HR110
Reasoner Residence 620 W Colton Ave HR83
Boettger House 809 E High Ave HR92
William Risch House 47 First St HR129
n/a 30 Cajon St HR109
YWCA Building 201 Cajon St HD8
n/a 237 S Fourth St HD8
n/a 254 S Fourth St HD8
Source: MCC, 2022, Appendix C.

5.3.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:

CUL-1 Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5;
CUL-2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5;
CUL-3: Disturb any human remains, including those interred outside of formal cemeteries.

The initial study established that the proposed Project would result in less than significant impacts related to Threshold CUL-3; and no further assessment of these impacts is required in this Draft EIR.

Historic Resources Thresholds
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Historic resources are usually 50 years old or older and must meet at least one of the criteria for listing in the California Register (such as association with historical events, important people, or architectural significance), in addition to maintaining a sufficient level of physical integrity (CEQA Guidelines Section 15064.5[a][3]). Additionally, CEQA Guidelines Section 15064.5(b), states that a project with an effect that may cause a substantial adverse change in the significance of a historical resource is a project that would have a significant effect on the environment. A substantial adverse change in the significance of a historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired. The significance of a historical resource is materially impaired when a project:
a) Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources; or
b) Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the Public Resources Code or its identification in an historical resources survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or
c) Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.

5.3.5 METHODOLOGY
To determine whether a historic related impact would result from the proposed Project, the analysis includes consideration of the history of use and development of the TVSP area, and whether any of the existing structures are older than 50 years of age. The analysis combines these factors to identify the potential of implementing projects to impact any historic resources in the TVSP area.

In determining whether an archaeological related impact would result from the proposed Project, the analysis includes consideration of the archaeologic sensitivity of the TVSP area and the past disturbance within the TVSP area. The analysis combines these factors to identify the potential of construction from implementing projects to impact any unknown archaeological resources.

As part of preparation of the Cultural Assessment for the proposed Project a records search was completed on September 22, 2020 at the South Central Coast Information Center (SCCIC), California State University at Fullerton. Other sources consulted include the National Register of Historic Places, California Register of Historical Resources, California Inventory of Historic Resources, Bureau of Land Management General Land Office Records, California Historical Landmarks, California Points of Historical Interest, and Redlands Historical Preservation Program.

5.3.6 ENVIRONMENTAL IMPACTS
IMPACT CUL-1: THE PROJECT WOULD NOT CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE

SIGNIFICANCE OF A HISTORICAL RESOURCE PURSUANT TO CEQA GUIDELINES SECTION 15064.5.

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Less than Significant with Mitigation Incorporated. The TVSP area has a rich history, and as listed above, contains 25 historic properties are listed in the California Register of Historical Resources and the National Register of Historic Places. In addition, other structures are eligible or potentially eligible for a historic designation (however, application for local designation would require the property owner’s authorization).

Also, the Specific Plan would be built out through 2040, and over that time additional buildings and/or structures in the city could become 50 years of age or more, and therefore potentially historic resources if certain criteria are met.

Recognizing the important role of historic resources in Redlands, the proposed TVSP intends to preserve the City’s historic resources and enhance their role in future development styles by implementing historic architectural styles and reestablishing the historic downtown street layout of Redlands. As described in the proposed TVSP, development within the TVSP area shall be based on the historic architectural styles found throughout the proposed villages. Furthermore, buildings adjacent to historic structures shall be designed in a manner that safeguards the prominence and integrity of the historic structure, as detailed in the Secretary of the Interior’s Standards and the City’s design guidelines for historic resources. Additionally, the proposed TVSP sets forth restrictions for historic residential structures, as listed below to support the preservation of historic resources.

Historic residential structures are subject to the following provisions:

1. All rehabilitations and additions to historic buildings shall conform to the applicable recommendations of the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings and/or the Redlands Historic Architectural Design Guidelines.

2. Buildings on project sites located immediately adjacent to lots (i.e., that share side or rear property lines) that have designated or eligible historic structures on them shall be designed per the requirements of this Specific Plan and per the recommendations of the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings s and/or the Redlands Historic Architectural Design Guidelines.

In addition, all implementing projects within the TVSP area are subject to the Redlands Historic Architectural Design Guidelines and any project altering a historic resource would be subject to a Certificate of Appropriateness application reviewed by the Historic and Scenic Preservation Commission, and a demolition permit application for a structure over 50 years of age is subject to review by the Redlands Historic and Scenic Preservation Commission, as described previously. Although no historically significant buildings are planned for alteration or demolition, and the proposed TVSP aims to ensure preservation of historic resources, implementation of site-specific development projects pursuant to the proposed TVSP could cause a substantial adverse change in the significance of a historical resource by altering a historical resource’s physical characteristics, which convey its historical significance. Adherence to Redlands Municipal Code Section 2.62.200 and Certificate of Appropriateness procedures, would address unidentified, potential historical resources (buildings, structures, and features aged 50 years and older) and would ensure preservation of known historic resources as new development within the TVSP area occurs. A project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings is considered to have a less than significant impact. Furthermore, Mitigation Measure CUL-1 is included to require evaluation of potential historic resources for implementing projects that could potentially impact a building or structure in excess of 50 years of age. Therefore, with implementation of the historic design standards that would be implemented Redlands Regular Meeting of 10-18-22 770 of 1815
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as part of the proposed TVSP, Mitigation Measure CUL-1, and Redlands Municipal Code Section 2.62.200 (provided as PPP CUL-1), impacts related to a substantial adverse change in the significance of a historic resource would be less than significant.

IMPACT CUL-2: THE PROJECT WOULD NOT CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE

SIGNIFICANCE OF AN ARCHAEOLOGICAL RESOURCE PURSUANT TO CEQA GUIDELINES SECTION 15064.5.

Less than Significant with Mitigation Incorporated. The records search conducted for the Project identified that 53 cultural resources investigations have been previously completed within a 0.5-mile radius of the TVSP area. Of these, 33 of the previously conducted investigations are directly within the TVSP area (MCC 2022).

The records search conducted for the Project identified one previously recorded prehistoric archaeological resource, one historic archaeological resource with a prehistoric component, and twenty-four historic archeological resources within TVSP area (MCC 2022).

The Specific Plan is located in an urbanized area, with a limited number of vacant parcels that have been previously disturbed by past development activities. While the TVSP area has been previously disturbed and developed, future site-specific development projects pursuant to the TVSP could involve grading and excavation to greater depths than previously undertaken. In addition, infill development would occur on vacant parcels, some of which may not have been previously exposed to ground disturbing activities, and therefore could result in the disturbance of unknown archaeological resources.

Because future site-specific development pursuant to the proposed TVSP could involve grading and excavation to greater depths than was previously undertaken, such future development could disturb buried archaeological resources. Thus, Mitigation Measures CUL-2 through CUL-9 are included to reduce the potential for archaeological resources to be impacted during earthmoving activities and provides for preservation of any identified resources. With implementation of these mitigation measures, impacts related to a substantial adverse change in the significance of an archaeological resource would be less than significant.

5.3.7 CUMULATIVE IMPACTS
Cumulative effects involving cultural resources occur as the result of multiple projects affecting cultural resources involving a resource type or theme, such as historic ethnic sites or an industry (e.g., Santa Fe Depot), that occur within a larger geographic context than a site-specific development project site. Thus, this analysis considers cumulative development projects that are located immediately adjacent to the TVSP area.

Historic Resources
Because all historical resources are unique and nonrenewable members of finite classes, all adverse effects or negative impacts erode a dwindling resource base. Federal and state laws and regulations protect historical resources when feasible. However, it is not always feasible to protect historical resources, particularly when an historic building has deteriorated beyond repair. For this reason, the cumulative effects of development on historical resources from cumulative projects in the region are considered significant.

However, the proposed TVSP requirements and special use restrictions include provisions related to preservation of historic resources, as described above. In addition, projects within the TVSP area are required to adhere to the City of Redlands Historic Architectural Design Guidelines, described previously.

Furthermore, implementation of PPP CUL-1 would avoid demolition of historically significant structures and would ensure that adaptive reuse of historically significant structures comply with Secretary of the Interior Standards and thereby protect the historic integrity of the structure’s façade. Furthermore, Mitigation Redlands Regular Meeting of 10-18-22 771 of 1815
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Measure CUL-1 requires preparation of historical resource analyses for future developments that have the potential of impacting a building over 50 years in age. Thus, with the application of PPP CUL-1 and Mitigation Measure CUL-1, and the applicable Specific Plan design criteria, the proposed Project’s contribution to the cumulative effect to historic resources in the region would be less than cumulatively considerable.

Archaeological Resources
As described above, there is a possibility that ground-disturbing activities during future construction may uncover or disturb unknown archaeological resources. However, the Project has included Mitigation Measures CUL-2 through CUL-9 that would reduce the potential impact to unknown resources. The likelihood of uncovering multiple currently unknown resources within the previously developed area that is sufficient to create a significant cumulative impact is low given the built nature of the TVSP area and few archaeological resources that have been found in the area to date. Thus, the cumulative effects of development on archaeological resources from implementation of the proposed Project in combination with other projects would be less than significant.

5.3.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• City of Redlands Municipal Code Chapter 2.62
Standard Conditions
None.

Plans, Programs, or Policies
PPP CUL-1: The City of Redlands Historic Architectural Design Guidelines shall apply to all projects within the TVSP area. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings may also be applicable to properties or projects that may affect historic buildings and resources.

5.3.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, Impacts CUL-1 and CUL-2 would be potentially significant.

5.3.10 MITIGATION MEASURES
Mitigation Measure CUL-1: Historical Properties. Prior to issuance of a permit for a development project within the TVSP area that could directly or indirectly impact a building/structure in excess of 50 years of age, the City shall determine whether the affected building/structure is historically significant. The evaluation of historic architectural resources shall be based on criteria such as age, location, context, association with an important person or event, uniqueness, or structural integrity. Preferred mitigation for historic buildings or structures shall be to avoid significant impacts to the resource through project redesign. If the resource cannot be entirely avoided, all prudent and feasible measures to minimize harm to the resource shall be taken. An historical resource assessment report shall be prepared by a qualified architectural historian meeting the U.S. Secretary of the Interior standards for each project to document the methods used to determine the Redlands Regular Meeting of 10-18-22 772 of 1815
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presence or absence of historical resources, to identify potential impacts from a project, and to evaluate the significance of any historical resources identified. If potentially significant impacts to a historical resource are identified, the report will also recommend appropriate mitigation to reduce the impacts to below a significant degree, where possible. If mitigation is required, mitigation programs can also be included in the report. Depending upon project impacts, measures shall include, but are not limited to:
• Preparing a historic resource management plan;
• Adding new construction that is compatible in size, scale, materials, color, and workmanship to the historical resource (such additions, whether portions of existing buildings or additions to historic districts, shall be clearly distinguishable from historic fabric); • Repairing damage according to the Secretary of the Interior's Standards for Rehabilitation; • Screening incompatible new construction from view through the use of berms, walls, and landscaping in keeping with the historic period and character of the resource; and • Shielding historic properties from noise generators through the use of sound walls, double glazing, and air conditioning.

Mitigation Measure CUL-2: Desktop Review. During environmental review for future projects located within the TVSP area, a qualified archaeologist will prepare a brief letter report to determine the likelihood for the project site to contain archaeological resources. This letter report will contain the results of background research and will tier off the research conducted in the Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments prepared by Material Culture Consulting, Inc. Additional reference material will be reviewed, including project area specific historic photographs, topographic maps and existing historic information. The background information provided in the Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments will be valid for five (5) years, after which time an updated search of the CHRIS will be required and submitted as an addendum to the original document. If there is any evidence that the project site has an increased sensitivity for archaeological or tribal cultural resources, based on existing onsite historic-age buildings or structures, or if previously identified resources are present within the project area or vicinity, then Mitigation Measure CUL-4 through Mitigation Measure CUL-6 shall be implemented.

Mitigation Measure CUL-3: Native American Coordination. Where a recorded Native American archaeological site is identified, the City shall initiate coordination with identified California Indian tribes. It should be noted that during the coordination process, tribal representative(s) will be directly involved in making recommendations regarding the significance of a prehistoric archaeological site, which could be considered a historic tribal cultural resource 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).

Mitigation Measure CUL-4: Phase 2 Archaeological Site Testing. If previously identified archaeological resources are present within the project area, a Phase 2 Archaeological Site Testing program shall be recommended, which would include evaluating the horizontal and vertical dimensions of a site, the chronological placement, site function, artifact/ecofact density and variability, presence/absence of subsurface features, and research potential. Results of the testing program, in tandem with the Native American coordination process required by Mitigation Measure CUL-3 will determine the historic significance of the resource.

When appropriate, the final testing report must be submitted to the City for eligibility determination and possible designation. An agreement on the appropriate form of mitigation is required prior to distribution of a draft environmental document, should one be required. If no significant resources are found, and site Redlands Regular Meeting of 10-18-22 773 of 1815
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conditions are such that there is no potential for further discoveries, then no further action is required.

Resources found to be non-significant as a result of a survey and/or assessment will require no further work beyond documentation of the resources on the appropriate Department of Parks and Recreation site forms and inclusion of results in the survey and/or assessment report. If no significant resources are found but results of the initial evaluation and testing phase indicate there is still a potential for resources to be present in portions of the property that could not be tested, then development of a mitigation and monitoring program is required.

Mitigation Measure CUL-5: Data Recovery Program. If significant cultural resources are present within a given Project Area, preferred mitigation for significant cultural resources is avoidance through project redesign. If the resource cannot be entirely avoided, all prudent and feasible measures to minimize harm shall be taken. For archaeological resources where preservation is not an option, a Data Recovery Program is required, which includes a Collections Management Plan. The program and plan will be subject to City review and approval prior to implementation. The data recovery program shall be based on a written research design and is subject to the provisions as outlined in CEQA Section 21083.2. The data recovery program must be reviewed and approved by the City Development Services Department.

Mitigation Measure CUL-6: Archaeological Resources Management Plan (ARMP). If resources are discovered within a given TVSP area, or if there is a high potential for encountering resources, an Archaeological Resources Management Plan (ARMP) will be required. In this case, the ARMP should include the following, at a minimum:

At least 90 days prior to issuance of grading permits, the project permittee/owner shall retain a qualified archaeological monitor to prepare the ARMP and to monitor all ground-disturbing activities in an effort to identify any unknown archaeological resources. Qualified archaeological monitor(s) will have a minimum of a bachelor’s degree, verifiable training and one year of monitoring experience in Southern California on similar projects. Prior to grading, the project permittee/owner shall provide to the City Development Services Department verification that a qualified monitor has been retained. Monitors will report to the Project Archaeologist for the Project and may work in collaboration with Native American monitors for tribal cultural resources that may be a historical resource as defined in Public Resources Code section 5020.1(k). • The Project Archaeologist shall meet the U.S. Secretary of the Interior Standards. • Any newly discovered archaeological resource deposits shall be subject to a formal significance evaluation.
• The Project Archaeologist will work in coordination with consulting tribes, the permittee/owner, and the City on the ARMP to address the details, timing, and responsibility of all archaeological activities that will occur on the project site. Details in the plan shall include, at a minimum:
a. Project grading and development scheduling;
b. The development of a schedule in coordination with the permittee/owner/consulting Native American tribes and the Project Archaeologist during grading, excavation and ground-disturbing activities on the site: including the scheduling, safety requirements, duties, scope of work, and Native American tribal monitors’ authority to stop and redirect grading activities in coordination with all project archaeologists; and, c. The protocols and stipulations that the permittee/owner, City, tribes, and Project Archaeologist will follow in the event of inadvertent archaeological resource discoveries, including any newly discovered archaeological resource deposits that shall be subject to a archaeological resources evaluation.
• A final report documenting the monitoring activity and disposition of any recovered archaeological resources shall be submitted to the City of Redlands, South Central Coast Information Center (SCCIC), and consulting tribes within 60 days of completion of monitoring.

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A. Pregrading Conference
The Project Archaeologist and/or designee shall participate in a pre-grading conference with development staff and construction operations, to ensure an understanding of the monitoring requirements and implementation procedures to be utilized during construction. This meeting shall take place before the initiation of major ground-disturbing activities. Training at this meeting shall inform all construction personnel of the procedures to be followed upon the discovery of archaeological resources, general archaeological items, including the archaeology and culture history of the area, as well as pictures of typical artifacts, sites, and resources that can be found during construction. This training should stress applicable state, federal, and local laws, and include information on what to do in case an unanticipated discovery is made by a worker.

All construction personnel should be instructed to stop work within a 50-foot radius of the find and immediately inform their field supervisor upon any discovery in the TVSP area. The Project Archaeologist and Native American monitors shall be called to assess the find to determine if additional monitors should be mobilized to the TVSP area to examine and evaluate the resources.

B. Archaeological Monitoring
An adequate number of qualified archaeological monitors shall be present to ensure that all earth moving activities are observed and shall be on-site during all grading activities for areas to be monitored, including off-site improvements. Inspections will vary based on the rate of excavation, the materials excavated, and the presence and abundance of artifacts and features. The frequency and location of inspections will be determined by the Project Archaeologist.

Archaeological monitoring will include inspection of exposed cut surfaces and spoils piles. Monitors maintain close communication with the on-site construction personnel to maintain a safe working environment and to be fully appraised of the upcoming Project activity areas and any schedule changes. All monitors shall complete daily documentation of all construction activities requiring monitoring, including the location of monitoring activities throughout the day, observations of sediment type and distribution, observations regarding resources, collection of resources and other information. This documentation will be prepared by each monitor on each shift, in a Daily Field Monitoring Summary and Daily Artifact Collection log, as relevant to the discoveries each day. The monitor shall photograph ground disturbing activities, sediment, and resources for documentation purposes and will fill out a Photograph Log each day. The Daily Field Monitoring Summary, Daily Artifact Collection Log and/or Photograph Log comprise the field notes. These notes shall be filed weekly with the Project Archaeologist and be made available to the Proponent and City upon request.

C. Monitor’s Authority to Temporarily Halt Project Activities Archaeological monitors have the authority to initiate a temporary work stoppage of construction activities to assess and/or recover a potentially significant discovery. It is important that all earthmoving contractor personnel recognize the authority of the monitor(s) to redirect Project construction activities. The monitor(s) will attempt to minimize schedule impacts, however, in cases of significant discovery, this process can be quite lengthy, and recent discoveries in the region have shown the area to be highly sensitive for cultural materials.

The monitor(s) will stay with the discovery and notify the construction foreman and the Project Archaeologist.

If phone communication is problematic, the monitor will demarcate a 50-ft buffer zone around the specimen using flagging pins until the find is assessed and potential impacts to archaeological resources are avoided, minimized, or mitigated.

D. Unanticipated Discovery Protocol
If inadvertent discoveries of subsurface archaeological resources are discovered during grading, the Project Archaeologist shall assess the significance of such resources and shall meet and confer with the City Redlands Regular Meeting of 10-18-22 775 of 1815
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Development Services Department and designated Native American monitors from consulting tribes regarding the mitigation for such resources.

E. Data Recovery Plan for Archaeological Resources
The following plan identifies protocol for assessing newly discovered resources. This section follows state guidelines for management of archaeological resources, as well as current best practices and industry standards for cultural resource management professional. Please note that when inadvertent discoveries of Native American archaeological resources occur, coordination with consulting Native American tribes/affiliations should be completed prior to removal or treatment of these resources, to ensure proper treatment and disposition, as outlined in Mitigation Measures TCR-3. The Project Archaeologist shall be contacted to flag the area in the field and determine if the archaeological deposits meet the CEQA definition of historical (State CEQA Guidelines 15064.5(a)) and/or unique archaeological resource (Public Resources Code 21083.2(g)). If the find is considered a “resource” the archaeologist shall pursue either protection in place or recovery, salvage and treatment of the deposits.

F. Isolates
Less than three artifacts in one location are defined as isolates. These may consist of, for example, a single projectile point, a culturally modified animal bone, or a glass bottle. When isolates are discovered, the monitor carefully examines the surrounding area to ensure that other artifacts are not present. Subsequently, the monitor photographs the isolate with a scale bar, obtains GPS coordinates of the location and records the isolate using standard California Department of Parks and Recreation (DPR) series 523 forms.

I. Archaeological Sites
Archaeological sites consist of more than three artifacts in one location. In addition, sites may have features such as rock ovens, burials, and other human-created alterations of the natural environment - with or without the presence of artifacts. Sites and features require evaluation to determine if they meet significance criteria as per CEQA. An archaeological site is considered significant if it is eligible or potentially eligible for listing in the CRHR. When an archaeological site is discovered during any Project activity, the archaeological monitor will divert construction away from the area at a minimum distance of 50 ft from the find and establish an exclusionary zone (flagging pins/tape) around the resource. The archaeological monitor(s) will then notify the Project Archaeologist for direction on how to proceed. Regardless of the outcome of the significance and CRHR eligibility assessment, every feature and site require a standard set of data collection for analysis and recordation on standard DPR forms. Features or sites older than 50 years must be delineated and photographed, GPS coordinates must be taken, and features and site records are completed including production of field maps and sketch map drawings. Thorough mapping is required for all features or sites, and include an accurate elevation measurement, the depth the deposit extends below surface and true north reading.

Recovery, salvage and treatment protocols shall be developed in accordance with applicable provisions of Public Resource Code Section 21083.2 and State CEQA Guidelines 15064.5 and 15126.4. If unique archaeological resources cannot be preserved in place or left in an undisturbed state, recovery, salvage and treatment shall be required at the applicant’s expense. All recovered and salvaged resources shall be prepared to the point of identification and permanent preservation by the archaeologist. Resources shall be identified and curated into an established accredited professional repository, at the Western Science Center in Hemet. Excavation as a treatment option will be restricted to those parts of the unique archaeological resource that would be damaged or destroyed by the project. All items found in association with Native American human remains shall be considered grave goods and sacred in origin and subject to special handling pursuant to Mitigation Measure TCR-4.

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Mitigation Measure CUL-7: Human Remains. Procedures taken upon discovery of human remains will be consistent with State Law (California Health and Safety Code Section 7050.5; California PRC Section 5907.98) and CR-3. If human remains are encountered during project grading, no further disturbance shall occur until the San Bernardino County Coroner has made the necessary findings as to origin. Further, pursuant to California Public Resources Code Section 5097.98(b) remains shall be left in place and free from disturbance until a final decision as to the treatment and disposition has been made. The monitor(s) will immediately divert work a minimum of 100 feet and place an exclusion zone (flagging pins) around the burial. In-place preservation and protection from further disturbance shall always be the preferred approach. If the San Bernardino County Coroner determines the remains to be Native American, the NAHC shall be contacted within a twenty-four (24) hour timeframe. Subsequently, the NAHC shall identify the “most likely descendant.” The most likely descendant (MLD) shall then make recommendations and engage in consultations concerning the treatment of the remains as provided in Public Resources Code 5097.98.

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

If the coroner determines the remains represent a historic-era, non-Native American burial, standard noninvasive analysis of the skeletal remains and any artifacts will be performed on any burials removed.

Reburial in place is preferred, but if burials are removed, they will be reinterred in an appropriate setting.

If the coroner determines the remains to be modern, the coroner will take custody of the remains. Reburial locations will be formally recorded on standard DPR forms as an Archaeological Redeposit. The site record will include maps of the original and reburial locations. The record will include dates of excavation and interment and a list of individuals (with affiliation) present during reburial. A burial treatment report will be prepared separately from any other reports and will be a confidential document. Copies will be filed with the Eastern Information Center, the MLD and the NAHC (latter two for Native American burials only). Any skeletal analysis or artifact analysis will be included in the final monitoring compliance report for the Project.

Mitigation Measure CUL-8: Monitoring Compliance Report. The Project Archaeologist shall prepare a final archaeological report prior to issuance of final building inspection, or other City milestone, to verify compliance with project conditions and mitigation measures. The report shall follow industry standard guidelines and City of Redlands requirements and shall include at a minimum: a discussion of monitoring methods and techniques uses, the results of the monitoring program including any artifacts recovered, an inventory of any resources recovered, updated DPR forms, if any, and any other site(s) identified, final disposition of the resources, and any additional recommendations. A final copy shall be submitted to the City of Redlands Development Services Department and the South Central Coast Information Center (SCCIC).

Mitigation Measure CUL-9: Curation of Archaeological Resources. All archaeological materials, including original maps, field notes, non-burial related artifacts, catalog information, and final reports recovered during public and/or private development projects must be permanently curated with an appropriate institution, one that has the proper facilities and staffing for ensuring research access to the collections consistent with state and federal standards. In the event that a prehistoric and/or historic deposit is encountered during construction monitoring, a collections management plan would be required in accordance with the project Mitigation and Monitoring Program.

The disposition of human remains and burial-related artifacts that cannot be avoided or are inadvertently discovered is governed by state (i.e., Assembly Bill 2641 [Coto] and California Native American Graves Protection and Repatriation Act of 2001 [Health and Safety Code 8010-8011]) and federal (i.e., Native American Graves Protection and Repatriation Act [U.S. Code 3001-3013]) law, and must be treated in a dignified and culturally appropriate manner with respect for the deceased individual(s) and their descendants. Any human bones and associated grave goods of Native American origin shall be turned over Redlands Regular Meeting of 10-18-22 777 of 1815
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to the appropriate Native American group for repatriation, as further stipulated in Mitigation Measures TCR-3 and TCR-4.

Arrangements for long-term curation of all recovered artifacts, with the exception of tribal cultural resources, must be established between the applicant/property owner and the consultant prior to the initiation of the Phase 2 Archaeological Site Testing Program. This information must then be included in the archaeological survey, testing, and/or data recovery report submitted to the City for review and approval. Curation must be accomplished in accordance with the California State Historic Resources Commission’s Guidelines for the Curation of Archaeological Collection (dated May 7, 1993) and, if federal funding is involved, Title 36 of the Code of Federal Regulations, Part 79.

5.3.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts CUL-1 and CUL-2 would be less than significant after mitigation.

REFERENCES
City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/post/planning-divisiongeneral-plan City of Redlands Historic Architectural Design Guidelines. Accessed:
https://www.cityofredlands.org/sites/main/files/file-attachments/attachment_bexhibit_to_resolution_historic_design_guidelines.pdf?1612492494 City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Material Cultural Consulting. Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments (MCC 2022). January 2022. Appendix C.

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5.4 Energy

5.4.1 INTRODUCTION
This section of the Draft EIR assesses the significance of the use of energy, including electricity, natural gas and gasoline, and diesel fuels, that would result from implementation of the TVSP. It discusses existing energy use patterns and examines whether the proposed TVSP (including development and operation) would result in the consumption of large amounts of fuel or energy or use such resources in a wasteful manner.

Refer to Section 5.6, Greenhouse Gas Emissions, for a discussion of the relationship between energy consumption and greenhouse gas (GHG) emissions, and Section 5.16, Utilities and Service Systems, for a discussion of water consumption. This section includes data from the following City documents and reports:
• City of Redlands 2035 General Plan, 2017
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (GP EIR), 2017
• City of Redlands Municipal Code
• Transit Villages District and Specific Plan Energy Tables, Urban Crossroads, 2022, Appendix D.

5.4.2 REGULATORY SETTING

5.4.2.1 Federal Regulations
Energy Independence and Security Act, Corporate Average Fuel Efficiency Standards On December 19, 2007, the Energy Independence and Security Act of 2007 was signed into law, requiring an increased Corporate Average Fuel Economy (CAFÉ) standard of 35 miles per gallon (mpg) for the combined fleet of cars and light trucks by the 2020 model year.

In addition to setting increased CAFÉ standards for motor vehicles, the Energy Independence and Security Act includes the following additional provisions:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301–325) • Building Energy Efficiency (Sections 411–441)
Additional provisions of the Act address energy savings in government and public institutions, promoting research for alternative energy, additional research in carbon capture, international energy programs, and the creation of green jobs.

5.4.2.2 State Regulations
California Code of Regulations (CCR) Title 13, Motor Vehicles, Section 2449(d)(3) No vehicle or engines subject to this regulation may idle for more than 5 consecutive minutes. The idling limit does not apply to:
• idling when queuing,
• idling to verify that the vehicle is in safe operating condition, • idling for testing, servicing, repairing or diagnostic purposes, • idling necessary to accomplish work for which the vehicle was designed (such as operating a crane), Redlands Regular Meeting of 10-18-22 780 of 1815
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• idling required to bring the machine system to operating temperature, and • idling necessary to ensure safe operation of the vehicle.

Title 24 Energy Efficiency Standards and California Green Building Standards California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code (CalGreen) is updated every three years. The most recent update is the 2019 California Green Building Code Standards that became effective January 1, 2020.

The CEC anticipates that single-family homes built with the 2019 standards will use approximately 7% less energy compared to the residential homes built under the 2016 standards. Additionally, after implementation of solar photovoltaic systems, homes built under the 2019 standards will use about 53% less energy than homes built under the 2016 standards. Nonresidential buildings will use approximately 30% less energy due to lighting upgrade requirements.

The 2019 CALGreen standards that are applicable to the TVSP include, but are not limited to, the following:
• Electric vehicle charging stations. Facilitate the future installation of electric vehicle supply equipment. The compliance requires empty raceways for future conduit and documentation that the electrical system has adequate capacity for the future load. • Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight and glare ratings per Title 24 Part 6 Table 5.106.8. • Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads).
• Outdoor portable water use in landscaped areas. Nonresidential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources’ Model Water Efficient (MWELO), whichever is more stringent.

The 2019 CalGreen Building Standards Code has been adopted by the City of Redlands in Municipal Code Chapter 15.16.

5.4.2.3 Local Regulations
City of Redlands 2035 General Plan
The General Plan Sustainable Community Element contains the following policies related to greenhouse gas emissions that are applicable to the Project:

Principle 8-P.1 Promote energy efficiency and conservation technologies and practices that reduce the use and dependency of nonrenewable resources of energy by both City government and the community.

Action 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.

Action 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.

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5.4.3 ENVIRONMENTAL SETTING
Electricity
The Southern California Edison Company (SCE) is the electrical purveyor in the City of Redlands. SCE provides electricity service to more than 14 million people in a 50,000 square-mile area of central, coastal and Southern California. California utilities are experiencing increasing demands that require modernization of the electric distribution grid to, among other things, accommodate two-way flows of electricity and increase the grid's capacity. SCE is in the process of implementing infrastructure upgrades to ensure the ability to meet future demands. In addition, as described by the Edison International 2020 Annual Report, the SCE electrical grid modernization effort supports implementation of California Senate Bill 32 that requires the state to cut greenhouse gas emissions 40 percent below 1990 levels by 2030 and 80 percent from the same baseline by 2050 in order to help achieve carbon neutrality by 2045. It describes that in 2020 approximately 43% of power that SCE delivered to customers came from carbon-free resources (SCE 2020).

The Project site is currently served by the electricity distribution systems that exists along the roadways throughout the TVSP area.

Natural Gas
The Southern California Gas Company (SoCalGas) is the natural gas purveyor in the City of Redlands and is the principal distributor of natural gas in Southern California. SoCalGas estimates that gas demand will decline at an annual rate of 1 percent each year through 2035 due to modest economic growth, mandated energy efficiency standards and programs, renewable electricity goals, and conservation savings linked to advanced metering infrastructure (CGEU 2020). The gas supply available to SoCalGas is regionally diverse and includes supplies from California sources (onshore and offshore), Southwestern U.S. supply sources, the Rocky Mountains, and Canada (CGEU 2020). SoCalGas designs its facilities and supplies to provide continuous service during extreme peak demands and has identified the ability to meet peak demands through 2035 in its 2020 report (CGEU 2020).

The TVSP area is currently served by the natural gas distribution system that exists within the roadways throughout the TVSP area.

5.4.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a project could have a significant effect if it were to:

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

E-2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

5.4.5 METHODOLOGY
A number of factors are considered when weighing whether a project would use a proportionately large amount of energy or whether the use of energy would be wasteful in comparison to other projects. Factors such as the use of on-site renewable energy features, energy conservation features or programs, and relative use of transit are considered.

According to Appendix F of the CEQA Guidelines, conserving energy is defined as decreasing overall per capita energy consumption, decreasing reliance on natural gas and oil, and increasing reliance on renewable Redlands Regular Meeting of 10-18-22 782 of 1815
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energy sources. Neither Appendix F of the CEQA Guidelines nor Public Resources Code Section 21100(b)(3) offer a numerical threshold of significance that might be used to evaluate the potential significance of energy consumption of a project. Rather, the emphasis is on reducing “the wasteful, inefficient, and unnecessary consumption of energy.”
Construction activities would result in wasteful, inefficient, or unnecessary use of energy if construction equipment is old or not well maintained, if equipment is left to idle when not in use, if travel routes are not planned to minimize vehicle miles traveled, or if excess lighting or water is used during construction activities.

Energy usage during project operation would be considered “wasteful, inefficient, and unnecessary” if the project were to violate federal, state, and/or local energy standards, including Title 24 of the California Code of Regulations, inhibit pedestrian or bicycle mobility, inhibit access to transit, or inhibit feasible opportunities to use alternative energy sources, such as solar energy, or otherwise inhibit the conservation of energy.

5.4.6 ENVIRONMENTAL IMPACTS
As detailed in Section 3.0, Project Description, the proposed Project would provide a form-based code that would allow development of up to 2,400 residential units; 613,000 square feet of retail commercial, hotel, and office space; and 280,000 square feet of open space and parks within the TVSP area. However, the timing of development and operation of the development pursuant to the TVSP would be dependent upon market conditions and development applications for new projects. However, buildout of the Project is evaluated to occur by 2040 to provide a conservative analysis.

IMPACT E-1: THE PROJECT WOULD NOT RESULT IN POTENTIALLY SIGNIFICANT ENVIRONMENTAL

IMPACT DUE TO WASTEFUL, INEFFICIENT, OR UNNECESSARY CONSUMPTION OF

ENERGY RESOURCES, DURING PROJECT CONSTRUCTION OR OPERATION Construction
Less than Significant Impact. During construction of the proposed TVSP development projects energy would be consumed in three general forms:

1. Petroleum-based fuels used to power off-road construction vehicles and equipment, construction worker travel to and from the TVSP area, 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 infill and redevelopment projects in the TVSP area and the associated infrastructure from implementation of the TVSP are not expected to result in demand for fuel greater on a per-unit-of-development basis than other development projects in Southern California as the main intention of all development is to reduce costs, which can be done by reducing energy usage. Furthermore, future construction within the TVSP area would occur in an area served by existing utility infrastructure and would not require extensive energy from construction in remote locations. Demolition of existing structures that would be required for the TVSP would generate demolition materials, 65 percent of which are required to be recycled per existing state regulations. Also, CCR Title 13, Motor Vehicles, section 2449(d)(3) Idling, limits idling times of construction vehicles to no more than 5 minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction trucks and equipment. The energy analysis modeling for buildout of the TVSP (included as Appendix D) details that the total construction electricity usage for would be approximately 2,282,064 kWh, as detailed in Table 5.4-1.

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Table 5.4-1: Estimated Construction Electricity Usage for Buildout of the TVSP TVSP Area Electricity Usage (kWh)
City Center Mixed-Use 30,299
Downtown Village Future Projects 71,290
New York Street Village 74,308
State Street Village 918,450
The Grand Apartments 29,830
University Village 1,157,886
Total Construction Electricity Usage 2,282,064
Source: Energy, Appendix D.

Table 5.4-2 shows that construction equipment used for buildout of the TVSP would use approximately 661,217 gallons of diesel fuel.

Table 5.4-2: Estimated Construction Equipment Fuel for Buildout of the TVSP Construction
Activity
Duration
(Days) Equipment HP Rating Quantity Usage Hours Load Factor HP-hrs/day Total Fuel Consumption City Center Mixed-Use
Demolition 20
Concrete/Industrial Saws 81 1 8 0.73 473 511
Excavators 158 3 8 0.38 1,441 1,558
Rubber Tired Dozers 247 2 8 0.4 1,581 1,709
Site Preparation 10 Crawler Tractors 212 4 8 0.43 2,917 1,577 Rubber Tired Dozers 247 3 8 0.4 2,371 1,282
Grading 20
Crawler Tractors 212 3 8 0.43 2,188 2,365
Excavators 158 1 8 0.38 480 519
Graders 187 1 8 0.41 613 663
Rubber Tired Dozers 247 1 8 0.4 790 854
Building
Construction 230
Cranes 231 1 8 0.29 536 6,663
Forklifts 89 3 8 0.2 427 5,311
Generator Sets 84 1 8 0.74 497 6,182
Tractors/Loaders/Backhoes 97 3 8 0.37 861 10,709
Welders 46 1 8 0.45 166 2,059
Paving 20
Pavers 130 2 8 0.42 874 944
Paving Equipment 132 2 8 0.36 760 822
Rollers 80 2 8 0.38 486 526
Architectural
Coating 20 Air Compressors 78 1 8 0.48 300 324
Downtown Village
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Construction
Activity
Duration
(Days) Equipment HP Rating Quantity Usage Hours Load Factor HP-hrs/day Total Fuel Consumption Demolition 20
Concrete/Industrial Saws 81 1 8 0.73 473 511
Excavators 158 3 8 0.38 1,441 1,558
Rubber Tired Dozers 247 2 8 0.4 1,581 1,709
Site Preparation 10 Crawler Tractors 212 4 8 0.43 2,917 1,577 Rubber Tired Dozers 247 3 8 0.4 2,371 1,282
Grading 30
Crawler Tractors 212 2 8 0.43 1,459 2,365
Excavators 158 2 8 0.38 961 1,558
Graders 187 1 8 0.41 613 995
Rubber Tired Dozers 247 1 8 0.4 790 1,282
Scrapers 367 2 8 0.48 2,819 4,571
Building
Construction 300
Cranes 231 1 8 0.29 536 8,691
Forklifts 89 3 8 0.2 427 6,928
Generator Sets 84 1 8 0.74 497 8,064
Tractors/Loaders/Backhoes 97 3 8 0.37 861 13,968
Welders 46 1 8 0.45 166 2,685
Paving 20
Pavers 130 2 8 0.42 874 944
Paving Equipment 132 2 8 0.36 760 822
Rollers 80 2 8 0.38 486 526
Architectural
Coating 20 Air Compressors 78 1 8 0.48 300 324
New York Street Village
Demolition 20
Concrete/Industrial Saws 81 1 8 0.73 473 511
Excavators 158 3 8 0.38 1,441 1,558
Rubber Tired Dozers 247 2 8 0.4 1,581 1,709
Site Preparation 10 Crawler Tractors 212 4 8 0.43 2,917 1,577 Rubber Tired Dozers 247 3 8 0.4 2,371 1,282
Grading 30
Crawler Tractors 212 2 8 0.43 1,459 2,365
Excavators 158 2 8 0.38 961 1,558
Graders 187 1 8 0.41 613 995
Rubber Tired Dozers 247 1 8 0.4 790 1,282
Scrapers 367 2 8 0.48 2,819 4,571
Building
Construction 300
Cranes 231 1 8 0.29 536 8,691
Forklifts 89 3 8 0.2 427 6,928
Generator Sets 84 1 8 0.74 497 8,064
Tractors/Loaders/Backhoes 97 3 8 0.37 861 13,968
Welders 46 1 8 0.45 166 2,685
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Construction
Activity
Duration
(Days) Equipment HP Rating Quantity Usage Hours Load Factor HP-hrs/day Total Fuel Consumption Paving 20
Pavers 130 2 8 0.42 874 944
Paving Equipment 132 2 8 0.36 760 822
Rollers 80 2 8 0.38 486 526
Architectural
Coating 20 Air Compressors 78 1 8 0.48 300 324
State Street Village
Demolition 84
Concrete/Industrial Saws 81 2 8 0.73 946 4,296
Excavators 158 5 8 0.38 2,402 10,905
Rubber Tired Dozers 247 3 8 0.4 2,371 10,767
Site Preparation 125 Crawler Tractors 97 4 8 0.43 1,335 9,018 Rubber Tired Dozers 247 3 8 0.4 2,371 16,022
Grading 130
Crawler Tractors 97 2 8 0.43 667 4,690
Excavators 158 3 8 0.38 1,441 10,126
Graders 187 1 8 0.41 613 4,310
Rubber Tired Dozers 247 1 8 0.4 790 5,554
Scrapers 367 2 8 0.48 2,819 19,806
Building
Construction 865
Cranes 231 1 8 0.29 536 25,058
Forklifts 89 3 8 0.2 427 19,974
Generator Sets 84 1 8 0.74 497 23,251
Tractors/Loaders/Backhoes 97 3 8 0.37 861 40,274
Welders 46 1 8 0.45 166 7,743
Paving 125
Pavers 130 2 8 0.42 874 5,903
Paving Equipment 132 2 8 0.36 760 5,137
Rollers 80 2 8 0.38 486 3,286
Architectural
Coating 125 Air Compressors 78 1 8 0.48 300 2,024
The Grand Apartments
Demolition 20
Concrete/Industrial Saws 81 1 8 0.73 473 511
Excavators 158 3 8 0.38 1,441 1,558
Rubber Tired Dozers 247 2 8 0.4 1,581 1,709
Site Preparation 10 Crawler Tractors 212 4 8 0.43 2,917 1,577 Rubber Tired Dozers 247 3 8 0.4 2,371 1,282
Grading 20
Crawler Tractors 212 3 8 0.43 2,188 2,365
Excavators 158 1 8 0.38 480 519
Graders 187 1 8 0.41 613 663
Rubber Tired Dozers 247 1 8 0.4 790 854
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Construction
Activity
Duration
(Days) Equipment HP Rating Quantity Usage Hours Load Factor HP-hrs/day Total Fuel Consumption Building
Construction 230
Cranes 231 1 8 0.29 536 6,663
Forklifts 89 3 8 0.2 427 5,311
Generator Sets 84 1 8 0.74 497 6,182
Tractors/Loaders/Backhoes 97 3 8 0.37 861 10,709
Welders 46 1 8 0.45 166 2,059
Paving 20
Pavers 130 2 8 0.42 874 944
Paving Equipment 132 2 8 0.36 760 822
Rollers 80 2 8 0.38 486 526
Architectural
Coating 20 Air Compressors 78 1 8 0.48 300 324
University Village
Demolition 70
Concrete/Industrial Saws 81 1 8 0.73 473 1,790
Excavators 158 3 8 0.38 1,441 5,452
Rubber Tired Dozers 247 2 8 0.4 1,581 5,981
Site Preparation 40 Crawler Tractors 212 4 8 0.43 2,917 6,307 Rubber Tired Dozers 247 3 8 0.4 2,371 5,127
Grading 110
Crawler Tractors 212 2 8 0.43 1,459 8,673
Excavators 158 2 8 0.38 961 5,712
Graders 187 1 8 0.41 613 3,647
Rubber Tired Dozers 247 1 8 0.4 790 4,700
Scrapers 367 2 8 0.48 2,819 16,759
Building
Construction 1110
Cranes 231 1 8 0.29 536 32,155
Forklifts 89 3 8 0.2 427 25,632
Generator Sets 84 1 8 0.74 497 29,837
Tractors/Loaders/Backhoes 97 3 8 0.37 861 51,682
Welders 46 1 8 0.45 166 9,936
Paving 75
Pavers 130 2 8 0.42 874 3,542
Paving Equipment 132 2 8 0.36 760 3,082
Rollers 80 2 8 0.38 486 1,972
Architectural
Coating 75 Air Compressors 78 1 8 0.48 300 1,214
Total Construction Fuel Demand (Gallons Diesel Fuel) 661,217 Source: Energy, Appendix D.

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Table 5.4-3 shows that construction workers would use approximately 864,212 gallons of fuel to travel to and from the TVSP area. Table 5.4-4 shows that approximately 291,668 gallons of fuel would be used by vendor trucks (vehicles that deliver materials to the site during construction) and hauling during construction.

Table 5.4-3: Estimated Construction Worker Fuel Consumption for TVSP Buildout Area Duration
(Days)
Worker
Trips/Day
Trip Length
(miles) VMT
Estimated
Fuel
Consumption
(gallons)
Light Duty Autos
City Center Mixed-Use 320 115 14.7 187,425 5,753
Downtown Village 400 206 14.7 336,777 10,279
New York Street Village 400 278 14.7 484,071 14,773
State Street Village 1,454 1,681 14.7 5,096,931 149,865 The Grand Apartments 582 193 14.7 454,406 13,943
University Village 1,480 2,110 14.7 6,587,144 188,263
Light Duty Trucks 1
City Center Mixed-Use 320 59 14.7 93,933 3,423
Downtown Village 400 105 14.7 170,814 6,193
New York Street Village 400 140 14.7 242,256 8,782
State Street Village 1,454 843 14.7 2,550,920 89,499
The Grand Apartments 582 141 14.7 393,872 14,345
University Village 1,480 1,056 14.7 3,294,417 112,719
Light Duty Trucks 2
City Center Mixed-Use 320 59 14.7 93,933 3,633
Downtown Village 400 105 14.7 170,814 6,563
New York Street Village 400 140 14.7 242,256 9,307
State Street Village 1,454 843 14.7 2,550,920 94,017
The Grand Apartments 582 141 14.7 393,872 15,225
University Village 1,480 1,056 14.7 3,294,417 117,631
Total Construction Worker Fuel Consumption 864,212
Source: Energy, Appendix D.

Table 5.4-4: Estimated Construction Vendor and Hauling Fuel Consumption TVSP Area Duration
(Days)
Vendor/
Hauling
Trips/Day
Trip Length
(miles) VMT
Average
Vehicle Fuel
Economy
(mpg)
MHDT
City Center Mixed-Use 320 8 6.9 12,696 1,333
Downtown Village 386 16 6.9 6,182 639
New York Street Village 400 28 6.9 10,819 1,118
State Street Village 865 352 6.9 525,228 53,893
The Grand Apartments 346 28 6.9 44,436 4,666
University Village 1,110 455 6.9 497,835 50,213
HHDT (Vendor)
City Center Mixed-Use 320 8 6.9 12,696 1,839
Downtown Village 386 16 6.9 6,182 884
New York Street Village 400 28 6.9 10,819 1,547
State Street Village 865 352 6.9 525,228 74,538
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TVSP Area Duration
(Days)
Vendor/
Hauling
Trips/Day
Trip Length
(miles) VMT
Average
Vehicle Fuel
Economy
(mpg)
The Grand Apartments 346 28 6.9 44,436 6,436
University Village 1,110 455 6.9 497,835 69,478
HHDT (Hauling)
City Center Mixed-Use 320 0 20 0 0
Downtown Village 386 0 20 0 0
New York Street Village 400 0 20 0 0
State Street Village 865 104 20 171,840 25,085
The Grand Apartments 346 0 20 0 0
University Village 1,110 0 20 0 0
Total Construction Vendor/Hauling Fuel Consumption 291,668 Source: Energy, Appendix D.

Construction contractors are required to demonstrate compliance with applicable California Air Resources Board (CARB) regulations governing the accelerated retrofitting, repowering, or replacement of heavy-duty diesel on- and off-road equipment. In addition, compliance with existing CARB idling restrictions and the use of newer engines and equipment would reduce fuel combustion and energy consumption.

Overall, construction activities would require limited energy consumption in comparison to operational energy consumption. Additionally, construction energy consumption related to buildout of the TVSP area would be consistent with construction energy usage throughout Southern California, would comply with all existing regulations, and would therefore not be expected to use large amounts of energy or fuel in a wasteful manner.

Thus, impacts related to construction energy usage would be less than significant.

Operation
Less than Significant Impact. Once operational, the new developments within the TVSP area would generate demand for electricity, natural gas, as well as gasoline for motor vehicle trips. Operational use of energy includes the heating, cooling, and lighting of buildings, water heating, operation of electrical systems and plugin appliances within buildings, 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.

As detailed in Table 5.4-5, operation of the TVSP at buildout is estimated to annually use 1,535,977 gallons of fuel. CCR Title 13, Motor Vehicles, section 2449(d)(3) Idling, limits idling times of vehicles to no more than 5 minutes. The idling restrictions would preclude unnecessary and wasteful consumption of fuel due to unproductive idling of trucks.

Table 5.4-5: Estimated Annual Operational Vehicle Fuel Consumption at Buildout TVSP Area Annual VMT Estimated Annual Fuel
Consumption (gallons)
City Center Mixed-Use 2,729,821 102,440
Downtown Village 8,226,402 308,706
New York Street Village 8,446,360 316,960
State Street Village 4,191,505 145,892
The Grand Apartments 2,324,950 87,247
University Village 17,171,689 574,733
Total Fuel Consumption 43,090,727 1,535,977
Source: Energy, Appendix D.

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Table 5.4-6 details that operation of the TVSP at buildout would use approximately 47,182,575 thousand British thermal units (kBTU) per year of natural gas and 20,065,361 kWh per year of electricity.

Table 5.4-6: Estimated Operational Annual Natural Gas Demand (kBTU/year) and Electricity (kWh/year) Consumption at Buildout
TVSP Area Natural Gas Demand
(kBTU/year)
Electricity Demand
(kWh/year)
City Center Mixed-Use 2,207,321 693,553
Downtown Village 2,931,934 1,809,216
New York Street Village 5,035,670 3,452,534
State Street Village 17,537,640 7,847,988
The Grand Apartments 2,364,910 601,650
University Village 17,105,100 5,660,420
Total Project Energy Demand 47,182,575 20,065,361
Source: Energy, Appendix D.

Because this use of energy is typical for urban development, no operational activities or land uses would occur that would result in extraordinary energy consumption, and through City permitting assurance would be provided that existing regulations related to energy efficiency and consumption, such as Title 24 regulations and CCR Title 13, Motor Vehicles, section 2449(d)(3) related to idling, would be implemented. Therefore, impacts related to operational energy consumption would be less than significant.

IMPACT E-2: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT A STATE OR LOCAL PLAN

FOR RENEWABLE ENERGY OR ENERGY EFFICIENCY
No Impact. As described previously, the development that would occur pursuant to the proposed TVSP would be required to meet the CCR Title 24 energy efficiency standards in effect during permitting of future development projects. The City’s administration of the CCR 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. In addition, as described in Section 5.2 Air Quality, the TVSP would be implemented to require development projects in the TVSP area to surpass state and local plans for energy efficiency and achieve 5 percent efficiency beyond the incumbent California Building Code Title 24 requirements, and enhanced water conservation (per Mitigation Measures AQ-7 and AQ-8). These mitigation measures would further ensure adherence to energy efficiency and renewable energy regulations. Furthermore, the TVSP would not conflict with or obstruct opportunities to use renewable energy, such as solar energy. The non-residential buildings would be solar ready and residences would have solar infrastructure as required by CCR Title 24 requirements. Thus, the TVSP would not obstruct use of renewable energy or energy efficiency. Overall, the TVSP would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

5.4.7 CUMULATIVE IMPACTS
The geographic context for analysis of cumulative impacts regarding energy includes past, present, and future development within southern California because energy supplies (including electricity, natural gas, and petroleum) are generated and distributed throughout the southern California region.

All development projects throughout the region would be required to comply with the energy efficiency standards in the Title 24 requirements. Additionally, some of the developments could provide for additional reductions in energy consumption by use of solar panels, sky lights, or other LEED type energy efficiency Redlands Regular Meeting of 10-18-22 790 of 1815
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infrastructure. With implementation of the existing energy conservation regulations, cumulative electricity and natural gas consumption would not be cumulatively wasteful, inefficient, or unnecessary.

Petroleum consumption associated with the proposed mixed uses would be primarily attributable to transportation, especially vehicular use. However, state fuel efficiency standards and alternative fuels policies (per AB 1007 Pavely) would contribute to a reduction in fuel use, and the federal Energy Independence and Security Act and the state Long Term Energy Efficiency Strategic Plan would reduce reliance on non-renewable energy resources. For these reasons, the consumption of petroleum would not occur in a wasteful, inefficient, or unnecessary manner and would be less than cumulatively considerable.

5.4.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND PLANS,

PROGRAMS, OR POLICIES
Existing Regulations
The following standard regulations would reduce potential impacts related to energy:
• California Energy Code (Code of Regulations, Title 24 Part 6). • CalGreen Building Standards Code as included in the City’s Municipal Code in Chapter 15.16.

Standard Conditions
None.

Plans, Programs, or Policies
None.

5.4.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impacts E-1and E-2 would be less than significant.

5.4.10 MITIGATION MEASURES
Impacts related to energy would be less than significant and no mitigation measures are required.

5.4.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts related to energy would be less than significant.

REFERENCES
California Air Pollution Control Officers Association. “Quantifying Greenhouse Gas Mitigation Measures.” 2010. Accessed at: http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-QuantificationReport-9-14-Final.pdf.

California Energy Commission. “2019 Title 24 Building Energy Standards” (CEC 2019). Accessed:
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2019- building-energy-efficiency
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California Gas and Electric Utilities 2020 California Gas Report (CGEU 2020). Accessed:
https://www.socalgas.com/regulatory/cgr.shtml.

Edison International 2020 Annual Report (SCE 2020). Accessed:
https://www.edison.com/home/investors/sec-filings-financials/annual-reports.html Southern California Edison. Accessed: http://sce.com/wps/portal/home/about-us/reliability.

City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report 2017. Accessed:
https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands 2035 General Plan, 2017. Accessed: https://www.cityofredlands.org/post/planningdivision-general-plan City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 SCAG 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction. Accessed:
https://scag.ca.gov/sites/main/files/fileattachments/2016_2040rtpscs_finalgrowthforecastbyjurisdiction.pdf?1605576071 Urban Crossroads. “Transit Villages District and Specific Plan Energy Tables” 2022. Appendix D.

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5.5 Geology and Soils

5.5.1 INTRODUCTION
This section addresses potential environmental effects of the proposed Project related to geology, soils, seismicity, and paleontological resources. The impacts examined include risks related to geologic hazards such as earthquakes, landslides, liquefaction, expansive soils; impacts on the environment related to soil erosion and sedimentation; and impacts related to paleontological resources. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035, December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), Dyett & Bhatia, July 2017;
• City of Redlands Municipal Code;
• Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments, Material Culture Consulting, February 2022 (Appendix C)

5.5.2 REGULATORY SETTING

5.5.2.1 Federal Regulations
Society of Vertebrate Paleontology
The Society of Vertebrate Paleontology’s Handbook for Society of Vertebrate Paleontology and Official Society Policy and Guidelines outlines practices and guidelines for practicing paleontologists. Additionally, the Society provides standard procedures for the assessment and mitigation of adverse impacts to paleontological resources.

5.5.2.2 State Regulations
Public Resources Code (PRC) Section 5097.5
Requirements for paleontological resource management are included in the PRC Division 5, Chapter 1.7, Section 5097.5, and Division 20, Chapter 3, Section 30244, which states: No person shall knowingly and willfully excavate upon, or remove, destroy, injure or deface any historic or prehistoric ruins, burial grounds, archaeological or vertebrate paleontological site, including fossilized footprints, inscriptions made by human agency, or any other archaeological, paleontological or historical feature, situated on public lands, except with the express permission of the public agency having jurisdiction over such lands. Violation of this section is a misdemeanor. These statutes prohibit the removal, without permission, of any paleontological site or feature from lands under the jurisdiction of the state or any city, county, district, authority, or public corporation, or any agency thereof. As a result, local agencies are required to comply with PRC 5097.5 for their own activities, including construction and maintenance, as well as for permit actions (e.g., encroachment permits) undertaken by others. PRC Section 5097.5 also establishes the removal of paleontological resources as a misdemeanor, and requires reasonable mitigation of adverse impacts to paleontological resources from developments on public (state, county, city, and district) lands.

5.5.2.3 Local Regulations
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City of Redlands General Plan 2035
The following policies contained in the City of Redlands General Plan 2035 are relevant to implementing projects within the proposed TVSP related to paleontological resources:

Principle 2-P.16Work with local paleontologists to identify significant non-renewable paleontological resources.

Action 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.

Action 2-A.76 Establish a procedure for the management of paleontological materials found onsite 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.

5.5.3 ENVIRONMENTAL SETTING
Paleontological Resources
Paleontological resources include any fossilized remains, traces, or imprints of organisms, preserved in or on the earth’s crust, that are of paleontological interest and that provide information about the history of life on earth, except that the term does not include any materials associated with an archaeological resource or any cultural item defined as Native American human remains. Significant paleontological resources are defined as fossils or assemblages of fossils that are unique, unusual, rare, uncommon, or important to define a particular time frame or geologic strata, or that add to an existing body of knowledge in specific areas, in local formations, or regionally.

The Specific Plan Area is situated at the foot of the San Bernardino Mountains, a part of the Transverse Ranges Geomorphic Province. The mountains within the province, including the San Gabriel and San Bernardino mountains to the north and northeast, were uplifted by tectonic activity, and provide a major sedimentary source for the alluvium basins of the adjacent areas.

The geologic units underlying the Specific Plan Area are mapped as younger and older Quaternary surficial deposits, more specifically very young wash deposits, active (Qvyw), young axial-valley deposits, Unit 3 (Qya3), 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 Redlands Regular Meeting of 10-18-22 795 of 1815
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(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 Plio-Pleistocene San Timoteo Formation is located south of the Specific Plan Area in more elevated terrain and may underlie younger and older Quaternary deposits in the Specific Plan Area (MCC 2022).

5.5.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:

GEO-1 Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

GEO-1i 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 4),
GEO-1ii Strong seismic ground shaking,
GEO-1iii Seismic-related ground failure, including liquefaction; GEO-1iv Landslides;
GEO-2 Result in substantial soil erosion or the loss of topsoil; 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;
GEO-4 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; 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; or GEO-6 Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

The Initial Study established that the proposed Project would not result in impacts related to Thresholds GEO1i, GEO-1iv, and GEO-5 and less than significant impacts related to Thresholds GEO-1ii, GEO-1iii, GEO-2, GEO-3, and GEO-4. No further assessment of these impacts is required in this Draft EIR.

5.5.5 METHODOLOGY
In determining whether a paleontological related impact would result from the proposed Project, the analysis includes consideration of the types of soils that exist within the Specific Plan Area, the paleontological sensitivity of those soils, the past disturbance on the site, and the proposed excavation. The analysis combines these factors to identify the potential of construction from implementing projects within the Specific Plan Area to impact any unknown paleontological resources.

5.5.6 ENVIRONMENTAL IMPACTS
IMPACT GEO-6: THE PROJECT WOULD NOT DIRECTLY OR INDIRECTLY DESTROY A UNIQUE PALEONTOLOGICAL RESOURCE OR SITE OR UNIQUE GEOLOGIC FEATURE.

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Less than Significant Impact with Mitigation Incorporated.

Unique Geologic Feature
Notable geological features in the Valley Region of San Bernardino County include the San Andreas Fault at the southwest foot of the San Bernardino Mountains, the San Jacinto Fault at the southwest edge of the San Bernardino Basin, and the Cucamonga Fault at the southern foot of the San Gabriel Mountains. However, there are no unique geological features in the vicinity of the Specific Plan Area (PlaceWorks, 2019). As such, construction of implementing projects pursuant to the TVSP would not result in impacts to unique geologic features.

Paleontological Resources
The paleontological record search did not yield any fossil localities within the Specific Plan Area and no fossil localities within one mile of the Specific Plan Area. However, nine fossil localities from similar sedimentary deposits have been recorded within a 70-mile radius of the Specific Plan Area. The closest fossil locality from the LACM Records Search is LACM IP 437, located approximately 20-miles east of the Specific Plan Area. The locality came from an unknown Pleistocene formation and consisted of invertebrates 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 south-southeast of the Specific Plan. These eight localities are the closest fossils to the Specific Plan Area. Additionally, 11 localities from the San Timoteo Formation and 13 localities from the Mount Eden Formation are located approximately 13 to 18 miles southeast of the Specific Plan Area, near the city of Beaumont (MCC 2022).

Additionally, Older Quaternary alluvium, similar to the old alluvial-fan and very old axial-valley deposits mapped within the Specific Plan Area, have produced significant Pleistocene fossils throughout Southern California. While the younger deposits typically do not contain significant fossils within the uppermost layers, it is likely they are underlain by older Quaternary deposits and, potentially, Plio-Pleistocene San Timoteo Formation. Therefore, excavations have the potential to impact paleontologically sensitive sediments throughout the Specific Plan Area (both at the surface and in the subsurface) and potentially destroy the fossil resources contained within. Therefore, Mitigation Measure GEO-1 is included to require preparation of paleontological resources management program (PRMP) for future projects that propose subsurface disturbance greater than five feet deep within areas mapped as low sensitivity or any subsurface disturbance within an area mapped as a high sensitivity geologic unit. With implementation of Mitigation Measure GEO-1, impacts related to paleontological resources would be less than significant.

5.5.7 CUMULATIVE IMPACTS
Impacts to paleontological resources are also site-specific rather than cumulative. Soils within the Valley Region of San Bernardino County, including the Specific Plan Area, are sensitive for paleontological resources. However, with incorporation of Mitigation Measure GEO-1, which protects paleontological resources from loss or destruction and requires that new development within the Specific Plan Area include appropriate measures to preserve the quality and integrity of these resources, avoid them when possible, and salvage and preserve them if avoidance is not possible, cumulative impacts would be less than significant.

5.5.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
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Existing Regulations
None.

Standard Conditions
None.

Plans, Programs, or Policies
None.

5.5.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, Impact GEO-6 would be potentially significant.

5.5.10 MITIGATION MEASURES
Mitigation Measure GEO-1: Paleontological Resources Management Program (PRMP). If a project proposes subsurface disturbance within an area mapped as a high sensitivity geologic unit (i.e., older alluvial deposits), or subsurface disturbance greater than 5 feet deep within an area mapped at the surface as a low sensitivity geologic unit (i.e., younger alluvial deposits), a paleontological resource management program (PRMP) is required unless a qualified paleontologist retained by a Project Proponent provides a letter to the City verifying that a PRMP is not warranted based on the results of a project-specific assessment.

The PRMP will be reviewed and approved by the City prior to the issuance of a grading permit. The PRMP will be designed and implemented prior to any ground disturbance activities to monitor, salvage, and curate any recovered fossils associated with the project area, should these be unearthed. It is recommended that, if necessary, a project’s PRMP implement the following standard procedures:

1. The applicant shall retain a qualified paleontologist (Project Paleontologist) approved by the City to create and implement a project-specific plan for monitoring site grading/earthmoving activities. As per Society of Vertebrate Paleontology (SVP) guidelines, a qualified paleontological monitor is an individual who has demonstrated sufficient paleontological training and field experience to have acceptable knowledge and experience of fossil identification, salvage and collection methods, paleontological techniques, and stratigraphy. An undergraduate degree in geology or paleontology is preferable but is less important than documented experience performing paleontological monitoring. The paleontological monitor must work under the direction of the Project Paleontologist.

2. The project paleontologist retained shall review the approved development plan and grading plan and conduct any pre-construction work necessary to render appropriate monitoring requirements as appropriate. These requirements shall be documented by the project paleontologist in a paleontological resource management program (PRMP). This PRMP shall be submitted to the City for approval prior to issuance of a grading permit. Information to be contained in the PRMP, at a minimum and in addition to other industry standards and Society of Vertebrate Paleontology standards, are as follows:
a. The Project Paleontologist shall participate in a pre-construction project meeting with development staff and construction operations to ensure an understanding of any monitoring measures required during construction, as applicable.

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b. Paleontological monitoring of earthmoving activities will be conducted on an as-needed basis by the project paleontologist during all earthmoving activities that may expose sensitive strata. Earthmoving activities in areas of the project area where previously undisturbed strata will be buried but not otherwise disturbed will not be monitored. The project paleontologist or his/her assign will have the authority to reduce monitoring once he/she determines the probability of encountering fossils has dropped below an acceptable level.
c. If the Project Paleontologist finds fossil remains, earthmoving activities will be diverted temporarily around the fossil site until the remains have been evaluated, documented, and recovered. Earthmoving will be allowed to proceed through the site when the Project Paleontologist determines the fossils have been recovered and/or the site mitigated to the extent necessary.
d. If fossil remains are encountered by earthmoving activities when the Project Paleontologist is not onsite, these activities will be diverted around the fossil site and the Project Paleontologist called to the site immediately to evaluate, document, and recover the remains.
e. If fossil remains are encountered, fossiliferous rock and soil will be recovered from the fossil site and processed to allow for the recovery of smaller fossil remains. Test samples may be recovered from other sampling sites in the geologic unit if appropriate. f. Any recovered fossil remains will be prepared to the point of identification and identified to the lowest taxonomic level possible by knowledgeable paleontologists. The remains then will be curated (assigned and labeled with museum* repository fossil specimen numbers and corresponding fossil site numbers, as appropriate; placed in specimen trays and, if necessary, vials with completed specimen data cards) and catalogued, an associated specimen data and corresponding geologic and geographic site data will be archived (specimen and site numbers and corresponding data entered into appropriate museum repository catalogs and computerized data bases) at the museum repository by a laboratory technician. The remains will then be accessioned into the museum* repository fossil collection, where they will be permanently stored, maintained, and, along with associated specimen and site data, made available for future study by qualified scientific investigators.
g. A qualified paleontologist shall prepare a report of findings made during all site grading activity with an appended itemized list of fossil specimens recovered during grading (if any). This report shall be submitted to the Development Services Department for review and approval prior to building final inspection as described elsewhere in these conditions.

A. Pregrading Conference
The Project Paleontologist and/or designee shall participate in a pre-grading conference with development staff and construction operations, to ensure an understanding of the monitoring requirements and implementation procedures to be utilized during construction. This meeting shall take place before the initiation of major ground-disturbing activities. Training at this meeting shall inform all construction personnel of the procedures to be followed upon the discovery of paleontological resources, general paleontological items, including the paleontology and geology of the area, as well as pictures of typical fossils that can be found during construction. This training should stress applicable state, federal, and local laws, and include Redlands Regular Meeting of 10-18-22 799 of 1815
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information on what to do in case an unanticipated discovery is made by a worker. All construction personnel should be instructed to stop work within a 50-foot radius of the find and immediately inform their field supervisor upon any discovery in the project area. The Project Paleontologist shall be called to assess the find to determine if monitors should be mobilized to the project area to examine and evaluate the fossils.

B. Paleontological Monitoring
Paleontological monitoring of earthmoving activities within older Quaternary alluvial deposits will be initially conducted on a full-time basis, and earthmoving activities below five feet within younger Quaternary alluvial deposits will be conducted on a part-time (spot-checking) basis by the paleontological monitor. The Project Paleontologist may re-evaluate the necessity for paleontological monitoring after initial examination of the affected sediments during excavation, which may result in part-time or spot-checking the remainder of excavations, or cessation of monitoring. Paleontological monitoring of construction excavations involves field inspection of trenches, spoils piles, scraped or graded surfaces. Monitors shall maintain close communication with the on-site construction personnel to maintain a safe working environment and to be fully appraised of the upcoming Project activity areas and any schedule changes. All monitors shall complete daily documentation of all construction activities requiring monitoring, including the location of monitoring activities throughout the day, observations of sediment type and distribution, observations regarding paleontological resources, collection of resources and other information. This documentation will be prepared by each monitor on each shift, in a Daily Field Monitoring Summary and Daily Paleontological Locality Collection log, as relevant to the discoveries each day. The monitor shall photograph ground disturbing activities, sediment, and resources for documentation purposes and will fill out a Photograph Log each day. The Daily Field Monitoring Summary, Daily Paleontological Locality Collection Log and/or Photograph Log shall comprise the field notes. These notes shall be filed weekly with the Project Paleontologist and be made available to the Proponent and City upon request.

C. Monitor’s Authority to Temporarily Halt Project Activities Paleontological monitors have authority to initiate a temporary work stoppage of construction activities to assess and/or recover paleontological discoveries. It is important that all earthmoving contractor personnel recognize the authority of the paleontological monitor(s) to redirect project construction activities. The monitor(s) will attempt to minimize schedule impacts, however, in cases of large discoveries, this process can be quite lengthy, and recent discoveries in the region have shown the area to be highly sensitive for paleontological materials. The monitor(s) will stay with the discovery and notify the construction foreman and the Project Paleontologist. The monitor will demarcate a 50-foot buffer zone around the specimen using flagging or other high-visibility methods until the find is assessed and potential impacts to paleontological resources are avoided, minimized, or mitigated.

D. Data Recovery Plan for Paleontological Resources
If fossils are discovered, the qualified paleontological monitor shall recover them. In the instance of an extended salvage period, the Project Paleontologist shall work with the construction manager to temporarily direct, divert, or halt earthwork to allow recovery of fossil remains in a timely manner. If the find is too large to be managed by one monitor, additional assistance will be called upon to expedite the process. Because of the potential for the recovery of small fossil remains, it may be necessary to collect bulk samples (up to 6,000 pounds) of sedimentary rock matrix. Screen-washing will only occur in the event of a significant discovery. The Project Paleontologist will consult with the Project Applicant/Proponent prior to collecting any bulk samples. Scientifically significant fossils of microscopic size consisting of vertebrates, invertebrates, Redlands Regular Meeting of 10-18-22 800 of 1815
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plants, or trace fossils, may be in sediments that produce significant finds. The locations of any significant discoveries should be sampled and later screen-washed and picked in the paleontological laboratory to fully document the microfaunal or microfloral diversity of the locality.

Construction activities shall continue outside of a 50-foot buffer to the discovery site based on the size of the fossil and in consultation with the foreperson and other construction leads. All scientifically important fossils shall be salvaged and fully documented within a detailed stratigraphic framework as construction conditions and safety considerations permit. Fossils will only be retrieved from within the project boundaries. Once the fossils have been partially prepared in the laboratory, non-significant resources such as bone fragments lacking identifiable features (processes or definable skeletal structures) shall be discarded or used only for educational or public outreach purposes.

F. Monitoring Compliance Report
The Project Paleontologist shall prepare a final paleontological report prior to issuance of final building inspection, or other City milestone, to verify compliance with project conditions and mitigation measures. The report shall follow industry standard guidelines and City of Redlands requirements and shall include at a minimum: a discussion of monitoring methods and techniques uses, the results of the monitoring program including any fossils recovered, an inventory of any resources recovered, locality forms, if any, final disposition of the resources, and any additional recommendations.

G. Curation of Paleontological Resources
Fossil remains collected during monitoring and salvage shall be cleaned, repaired, sorted, and catalogued as part of the monitoring program. When potentially scientifically significant fossil discoveries are made by paleontological monitors, they should be quickly and professionally explored, assessed, and evaluated to minimize construction delays; the City Development Services Department and Project Paleontologist will be notified immediately. Additional paleontologists will be brought in to assist with the salvage as needed.

Salvages may consist of the relatively rapid removal of small isolated fossils from an active cut, to handquarrying of larger fossils over several hours, to excavations of large fossils or large numbers of smaller fossils from a bone bed over several days or weeks.

At each paleontological locality, the Project Paleontologist or paleontological monitor will record the field number, date of discovery and date of collection, geographic coordinates, elevation, formation, stratigraphic provenance, lithologic description of sediment that produced the fossil(s), type(s) of fossils and type(s) of element(s), taphonomic and paleoenvironmental interpretations, associations with other fossils, photograph(s), and collector(s). All fossils and matrix samples must be properly labeled prior to removal from the locality where they were discovered and taken to a secure laboratory for preparation to the point of identification and curation.

5.5.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Implementation of Mitigation Measure GEO-1 would reduce potential impacts associated unique paleontological resource impacts to a level that is less than significant. Therefore, no significant unavoidable adverse impacts related to geology and soils and paleontological resources would occur.

REFERENCES
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City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/post/planning-divisiongeneral-plan City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Material Cultural Consulting. Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments (MCC 2022). January 2022. Appendix C.

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5.6 Greenhouse Gases

5.6.1 INTRODUCTION
This section evaluates the potential for implementation of the proposed Specific Plan to cumulatively contribute to greenhouse gas (GHG) emissions impacts. Because no single project is large enough to result in a measurable increase in global concentrations of GHG emissions, impacts of the proposed Specific Plan are considered on a cumulative basis. This evaluation is based on the methodology recommended by the South Coast Air Quality Management District (SCAQMD). This section also addresses the Specific Plan’s consistency with applicable plans, policies, and public agency regulations adopted for the purpose of reducing the emissions of greenhouse gases. The analysis within this section is based on the following City documents and the technical report prepared for the Project:
• City of Redlands 2035 General Plan, 2017
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (GP EIR), 2017
• City of Redlands Municipal Code
• Transit Villages District and Specific Plan Greenhouse Gas Impact Analysis, Urban Crossroads, 2022, Appendix E.

5.6.2 REGULATORY SETTING

5.6.2.1 State Regulations
California Assembly Bill 1493– Pavley
In 2002, the California Legislature adopted AB 1493 requiring the adoption of regulations to reduce GHG emissions in the transportation sector. In September 2004, pursuant to AB 1493, the CARB approved regulations to reduce GHG emissions from new motor vehicles beginning with the 2009 model year (Pavley Regulations). In September 2009, CARB adopted amendments to the Pavley Regulations to reduce GHG from 2009 to 2016. CARB, EPA, and the U.S. Department of Transportation’s National Highway Traffic and Safety Administration (NHTSA) have coordinated efforts to develop fuel economy and GHG standards for model 2017-2025 vehicles. The GHG standards are incorporated into the “Low Emission Vehicle” (LEV) Regulations.

California Executive Order S‐3‐05 – Statewide Emission Reduction Targets Executive Order S-3-05 was signed by Governor Arnold Schwarzenegger in June 2005. Executive Order S-3-05 establishes statewide emission reduction targets through the year 2050:
• By 2010, reduce GHG emissions to 2000 levels;
• By 2020, reduce GHG emissions to 1990 levels; and
• By 2050, reduce GHG emissions to 80 percent below 1990 levels.

California Assembly Bill 32 (AB 32), Global Warming Solutions Act of 2006 (Chapter 488, Statutes of 2006) In 2006, the Legislature passed the California Global Warming Solutions Act of 2006 [Assembly Bill 32 (AB 32)], which created a comprehensive, multi-year program to reduce greenhouse gas (GHG) emissions in California. AB 32 required the California Air Resources Board (CARB or Board) to develop a Scoping Plan Redlands Regular Meeting of 10-18-22 804 of 1815
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that describes the approach California will take to reduce GHGs to achieve the goal of reducing emissions to 1990 levels by 2020. The Scoping Plan was first approved by the Board in 2008 and must be updated at least every five years. Since 2008, there have been two updates to the Scoping Plan. Each of the Scoping Plans have included a suite of policies to help the State achieve its GHG targets, in large part leveraging existing programs whose primary goal is to reduce harmful air pollution. The 2017 Scoping Plan identifies how the State can reach the 2030 climate target to reduce greenhouse gas (GHG) emissions by 40 percent from 1990 levels, and substantially advance toward the 2050 climate goal to reduce GHG emissions by 80 percent below 1990 levels.

The AB 32 Scoping Plan also anticipates that local government actions will result in reduced GHG emissions because local governments have the primary authority to plan, zone, approve, and permit development to accommodate population growth and the changing needs of their jurisdictions. The Scoping Plan also relies on the requirements of Senate Bill 375 (discussed below) to align local land use and transportation planning for achieving GHG reductions.

The Scoping Plan must be updated every five years to evaluate AB 32 policies and ensure that California is on track to achieve the 2020 GHG reduction goal. In 2014, CARB released the First Update to the Scoping Plan, which builds upon the Initial Scoping Plan with new strategies and recommendations. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments. This update defines CARB’s climate change priorities for the next five years and sets the groundwork to reach long-term goals set forth in Executive Order S-3-

05. The update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals in the original 2008 Scoping Plan. It also evaluates how to align the state's “longer-term” GHG reduction strategies with other state policy priorities for water, waste, natural resources, clean energy, transportation, and land use.

In 2017, CARB released the proposed Second Update to the Scoping Plan, which identifies the State’s post2020 reduction strategy. The Second Update would reflect the 2030 target of a 40 percent reduction below 1990 levels, set by Executive Order B-30-15 and codified by SB 32. Key programs that the proposed Second Update builds upon include the Cap-and-Trade Regulation, the Low Carbon Fuel Standard, and much cleaner cars, trucks and freight movement, utilizing cleaner, renewable energy, and strategies to reduce methane emissions from agricultural and other wastes.

Senate Bill 375 (Chapter 728, Statutes of 2008)
In August 2008, the Legislature passed, and on September 30, 2008, Governor Schwarzenegger signed, SB 375, which addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. Regional GHG reduction targets for the automobile and light-truck sector for 2020 and 2035, as determined by CARB, are required to consider the emission reductions associated with vehicle emission standards (see SB 1493), the composition of fuels (see Executive Order S1-07), and other CARB-approved measures to reduce GHG emissions. Regional metropolitan planning organizations (MPOs) will be responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a development plan for the region, which, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, an MPO must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies. SB 375 provides incentives for streamlining CEQA requirements by substantially reducing the requirements for “transit priority projects,” as specified in SB 375, and eliminating the analysis of the impacts of certain residential projects on global warming and the growth-inducing impacts of those projects when the projects Redlands Regular Meeting of 10-18-22 805 of 1815
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are consistent with the SCS or Alternative Planning Strategy. On September 23, 2010, CARB adopted the SB 375 targets for the regional MPOs.

Executive Order B‐30‐15 – 2030 Statewide Emission Reduction Target Executive Order B-30-15 was signed by Governor Jerry Brown on April 29, 2015, establishing an interim statewide GHG reduction target of 40 percent below 1990 levels by 2030, which is necessary to guide regulatory policy and investments in California in the midterm, and put California on the most cost-effective path for long-term emission reductions. Under this Executive Order, all state agencies with jurisdiction over sources of GHG emissions are required to continue to develop and implement emissions reduction programs to reach the state’s 2050 target and attain a level of emissions necessary to avoid dangerous climate change.

According to the Governor’s Office, this Executive Order is in line with the scientifically established levels needed in the United States to limit global warming below 2°C - the warming threshold at which scientists say there will likely be major climate disruptions such as super droughts and rising sea levels.

Senate Bill 32 (Chapter 249, Statutes of 2016)
Senate Bill 32 was signed on September 8, 2016 by Governor Jerry Brown. SB 32 requires the state to reduce statewide GHG emissions to 40 percent below 1990 levels by 2030, a reduction target that was first introduced in Executive Order B-30-15. The new legislation builds upon the AB 32 goal of 1990 levels by 2020 and provides an intermediate goal to achieving S-3-05, which sets a statewide GHG reduction target of 80 percent below 1990 levels by 2050. A related bill that was also approved in 2016, AB 197 (Chapter 250, Statutes of 2016) creates a legislative committee to oversee regulators to ensure that ARB is not only responsive to the Governor, but also the Legislature.

Senate Bill 97 (Chapter 185, Statutes of 2007)
SB 97 (Health and Safety Code Section 21083.5) was adopted in 2007 and required the Office of Planning and Research to prepare amendments to the CEQA Guidelines for the mitigation of GHG impacts. The amendments became effective on March 18, 2010. The CEQA Amendments provide guidance to public agencies regarding the analysis and mitigation of the effects of GHG emissions in CEQA documents. A new section, CEQA Guidelines Section 15064.4, was added to assist agencies in determining the significance of GHG emissions. The CEQA Section gives discretion to the lead agency whether to: (1) use a model of methodology to quantify GHG emissions resulting from a project, and which model or methodology to use; or (2) rely on a qualitative analysis or performance-based standards. CEQA does not provide guidance to determine whether the project’s estimated GHG emissions are significant or cumulatively considerable.

Also amended were CEQA Guidelines Sections 15126.4 and 15130, which address mitigation measures and cumulative impacts respectively. However, GHG mitigation measures are referenced in general terms, and no specific measures are identified. Additionally, the revision to the cumulative impact discussion requirement (Section 15130) simply directs agencies to analyze GHG emissions in an EIR when a project’s incremental contribution of emissions may be cumulatively considerable, however it does not answer the question of when emissions are cumulatively considerable.

Section 15183.5 permits programmatic GHG analysis and later project-specific tiering, as well as the preparation of Greenhouse Gas Reduction Plans. Compliance with such plans can support a determination that a project’s cumulative effect is not cumulatively considerable, according to proposed Section 15183.5(b).

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Title 24 Energy Efficiency Standards and California Green Building Standards California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code (CalGreen) is updated every three years. The most recent update was the 2019 California Green Building Code Standards that became effective January 1, 2020.

The CEC anticipates that single-family homes built with the 2019 standards will use approximately 7% less energy compared to the residential homes built under the 2016 standards. Additionally, after implementation of solar photovoltaic systems, homes built under the 2019 standards will use about 53% less energy than homes built under the 2016 standards. Nonresidential buildings will use approximately 30% less energy due to lighting upgrade requirements.

The 2019 CALGreen standards that reduce GHG emissions and are applicable to the proposed Project include, but are not limited to, the following:
• Bicycle parking at new buildings to encourage non-vehicular transportation. • Designated parking for clean air vehicles. Provide designated parking for any combination of lowemitting, fuel-efficient and carpool/van pool vehicles per Title 24 Part 6 Table 5.106.5.2. • Electric vehicle charging stations. The regulation requires empty raceways for future conduit and documentation that the electrical system has adequate capacity for the future load. • Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight and glare ratings per Title 24 Part 6 Table 5.106.8. • Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the nonhazardous construction and demolition waste.
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reused or recycled. • Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified for the depositing, storage and collection of non-hazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals. • Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) meeting Title 24 standards shall be installed. • Outdoor portable water use in landscaped areas. Nonresidential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources’ Model Water Efficient (MWELO), whichever is more stringent.

The 2019 CalGreen Building Standards Code has been adopted by the City of Redlands in Municipal Code Chapter 15.16.

5.6.2.2 Local Regulations
City of Redlands 2035 General Plan
The General Plan Sustainable Community Element contains the following policies related to greenhouse gas emissions that are applicable to the Project:

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Principle 8-P.1 Promote energy efficiency and conservation technologies and practices that reduce the use and dependency of nonrenewable resources of energy by both City government and the community.

Action 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.

Action 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.

Action 8-A.10 Integrate trees and shade into the built environment to mitigate issues such as stormwater runoff and the urban heat island effect.

Principle 8-P.8 Promote sustainability by reducing the community’s greenhouse gas (GHG) emissions and fostering green development patterns – including buildings, sites, and landscapes.

City of Redlands Climate Action Plan
The City of Redlands Climate Action Plan (CAP) was designed to reinforce the City’s commitment to reducing GHG emissions and demonstrate compliance with the State’s GHG emissions reduction standards. The CAP includes goals and policies to promote energy efficiency, waste reduction, and resource conservation and recycling. The CAP’s GHG emission targets and goals were based on meeting the goals in EO B-30-15 and SB 32 and the following guidance established in the 2017 Scoping Plan. The CAP used the 2017 Scoping Plan recommended Plan Level emissions target of 6.0 MTCO2e per capita per year for 2030. Based on the CAP analysis, the City of Redlands will achieve the 2030 target based on state actions and existing development standards and would not require any specific measures to reduce GHG emissions. Regardless, the CAP does recommend some actions including encourage the development of solar photovoltaic systems on residential and non-residential development, increase energy efficiency 5 percent over standards, increase the use of high efficiency lighting, and reduce the intensity of GHG emissions associated with water delivery and treatment.

5.6.3 ENVIRONMENTAL SETTING
Gases that trap heat in the atmosphere are called GHGs. The major concern with GHGs is that increases in their concentrations are contributing to global climate change. Global climate change is a change in the average weather on Earth that can be measured by wind patterns, storms, precipitation, and temperature.

Although there is disagreement as to the rate of global climate change and the extent of the impacts attributable to human activities, most in the scientific community agree that there is a direct link between increased emissions of GHGs and long-term global temperature increases.

The principal GHGs are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs). Because different GHGs have different warming potential, and CO2 is the most common reference gas for climate change, GHG emissions are often quantified and reported as CO2 equivalents (CO2e). For example, SF6 is a GHG commonly used in the utility industry as an insulating gas in circuit breakers and other electronic equipment. SF6, while comprising a small fraction of the total GHGs emitted annually world-wide, is a much more potent GHG, with 22,800 times the global warming potential as CO2. Therefore, an emission of one metric ton (MT) of SF6 could be reported as an Redlands Regular Meeting of 10-18-22 808 of 1815
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emission of 22,800 MT of CO2e. Large emission sources are reported in million metric tons (MMT) of CO2e.

The principal GHGs are described below, along with their global warming potential.

Carbon dioxide: Carbon dioxide (CO2) is an odorless, colorless, natural GHG. Carbon dioxide’s global warming potential is 1. Natural sources include decomposition of dead organic matter; respiration of bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic (manmade) sources are from burning coal, oil, natural gas, and wood.

Methane: Methane (CH4) is a flammable gas and is the main component of natural gas. It has a lifetime of 12 years, and its global warming potential is 28. Methane is extracted from geological deposits (natural gas fields). Other sources are landfills, fermentation of manure, and decay of organic matter.

Nitrous oxide: Nitrous oxide (N2O) (laughing gas) is a colorless GHG that has a lifetime of 121 years, and its global warming potential is 265. Sources include microbial processes in soil and water, fuel combustion, and industrial processes.

Sulfur hexafluoride: Sulfur hexafluoride (SF6) is an inorganic, odorless, colorless, and nontoxic, nonflammable gas that has a lifetime of 3,200 years and a high global warming potential of 23,500. This gas is manmade and used for insulation in electric power transmission equipment, in the magnesium industry, in semiconductor manufacturing, and as a tracer gas.

Perfluorocarbons: Perfluorocarbons (PFCs) have stable molecular structures and only break down by ultraviolet rays about 60 kilometers above Earth’s surface. Because of this, they have long lifetimes, between 10,000 and 50,000 years. Their global warming potential ranges from 7,000 to 11,000. Two main sources of perfluorocarbons are primary aluminum production and semiconductor manufacturing.

Hydrofluorocarbons: Hydrofluorocarbons (HFCs) are a group of GHGs containing carbon, chlorine, and at least one hydrogen atom. Their global warming potential ranges from 100 to 12,000. Hydrofluorocarbons are synthetic manmade chemicals used as a substitute for chlorofluorocarbons in applications such as automobile air conditioners and refrigerants.

Some of the potential effects in California of global warming may include loss in snow pack, sea level rise, more extreme heat days per year, more high ozone days, more forest fires, and more drought years.

Globally, climate change has the potential to impact numerous environmental resources through potential, though uncertain, impacts related to future air temperatures and precipitation patterns. The projected effects of global warming on weather and climate are likely to vary regionally, but are expected to include the following direct effects:
• Higher maximum temperatures and more hot days over nearly all land areas; • Higher minimum temperatures, fewer cold days and frost days over nearly all land areas; • Reduced diurnal temperature range over most land areas; • Increase of heat index over land areas; and
• More intense precipitation events.

Also, there are many secondary effects that are projected to result from global warming, including global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity.

While the possible outcomes and the feedback mechanisms involved are not fully understood and much research remains to be done, the potential for substantial environmental, social, and economic consequences over the long term may be great.

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GHGs are produced by both direct and indirect emissions sources. Direct emissions include consumption of natural gas, heating and cooling of buildings, landscaping activities and other equipment used directly by land uses. Indirect emissions include the consumption of fossil fuels for vehicle trips, electricity generation, water usage, and solid waste disposal.

Existing Project Site Conditions
The TVSP area consists of approximately 947 acres of land that surrounds three proposed Arrow stations.

The area is current developed with a mix of commercial, industrial, and residential uses. The primary GHG emissions in the TVSP area are from on-road transportation; building energy; and waste.

5.6.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:

GHG-1 Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
GHG-2 Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs.

CEQA Guidelines Section 15064.4 provides discretion to the lead agency whether to: (1) use a model of methodology to quantify GHG emissions resulting from a project, and which model or methodology to use; or (2) rely on a qualitative analysis or performance-based standards. In addition, CEQA does not provide guidance to determine whether the project’s estimated GHG emissions are significant, but recommends that lead agencies consider several factors that may be used in the determination of significance of project related GHG emissions, including:
• The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting.
• Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
• The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

CEQA Guidelines Section 15130(f) describes that the effects of GHG emissions are by their very nature cumulative and should be analyzed in the context of CEQA’s requirements for cumulative impact analysis.

Additionally, CEQA Guidelines Section 15064(h)3 states that a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides requirements to avoid or lesson the cumulative problem.

The SCAQMD formed a working group to identify greenhouse gas emissions thresholds for land use projects that could be used by local lead agencies in the Basin in 2008. The working group developed several different options that are contained in the SCAQMD Draft Guidance Document – Interim CEQA Greenhouse Gas Significance Threshold, that could be applied by lead agencies, which includes the following tiered approach:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA.

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• Tier 2 consists of determining whether the project is consistent with a greenhouse gas reduction plan.

If a project is consistent with a qualifying local greenhouse gas reduction plan, it does not have significant greenhouse gas emissions.
• Tier 3 consists of screening values, which the lead agency can choose, but must be consistent with all projects within its jurisdiction. A project’s construction emissions are averaged over 30 years and are added to the project’s operational emissions. If a project’s emissions are below one of the following screening thresholds, then the project is less than significant:
o All land use types: 3,000 MTCO2E per year
o Based on land use type:
 Residential: 3,500 MTCO2E per year
 Commercial: 1,400 MTCO2E per year
 Mixed use: 3,000 MTCO2E per year
• Tier 4 has the following options:
o Option 1: Reduce business as usual emissions by a certain percentage; this percentage is currently undefined.
o Option 2: Early implementation of applicable AB 32 Scoping Plan measures. o Option 3, 2020 Target: For service populations (SP), including residents and employees, 4.8 MTCO2E/SP/year for projects and 6.6 MTCO2E/SP/year for plans. o Option 3, 2035 Target: 3.0 MTCO2E/SP/year for projects and 4.1 MTCO2E/SP/year for plans.

The SCAQMD’s interim thresholds used the Executive Order S-3-05-year 2050 goal as the basis for the Tier 3 screening level. Achieving the Executive Order’s objective would contribute to worldwide efforts to cap CO2 concentrations at 450 ppm, thus stabilizing global climate.

The SCAQMD defines the Service Population (SP) as used under Tier 4 thresholds the total residents and employees associated with a project. The origin of the SP is based on CARB’s 2008 Scoping Plan. The 2008 Scoping Plan identified that based on the GHG emissions inventories for the state, the people of California generate approximately 14 tons of GHG emissions per capita and would need to reduce annual emissions to approximately 10 tons per capita in order to meet the GHG reduction target of AB 32.

The SP threshold is widely accepted and used by numerous cities in the basin and is based on the SCAQMD staff’s proposed GHG screening threshold for stationary source emissions for non-industrial projects, as described in the SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans.

The SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans identifies a screening threshold to determine whether additional analysis is required. As noted by the SCAQMD:
“…the…screening level for stationary sources is based on an emission capture rate of 90 percent for all new or modified projects...the policy objective of [SCAQMD’s] recommended interim GHG significance threshold proposal is to achieve an emission capture rate of 90 percent of all new or modified stationary source projects. A GHG significance threshold based on a 90 percent emission capture rate may be more appropriate to address the long-term adverse impacts associated with global climate change because most projects will be required to implement GHG reduction measures.

Further, a 90 percent emission capture rate sets the emission threshold low enough to capture a substantial fraction of future stationary source projects that will be constructed to accommodate future statewide population and economic growth, while setting the emission threshold high enough to exclude small projects that will in aggregate contribute a relatively small fraction of the Redlands Regular Meeting of 10-18-22 811 of 1815
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cumulative statewide GHG emissions. This assertion is based on the fact that [SCAQMD] staff estimates that these GHG emissions would account for slightly less than one percent of future 2050 statewide GHG emissions target (85 [MMTCO2e/yr]). In addition, these small projects may be subject to future applicable GHG control regulations that would further reduce their overall future contribution to the statewide GHG inventory. Finally, these small sources are already subject to [Best Available Control Technology] (BACT) for criteria pollutants and are more likely to be single-permit facilities, so they are more likely to have few opportunities readily available to reduce GHG emissions from other parts of their facility.”
Based on the type of programmatic planning project being proposed and the SCAQMD guidance described above, the City has determined that the SCAQMD’s Tier 4, Option 3 project-level efficiency threshold methodology is an appropriate significance criterion by which to determine whether the Project emits a significant amount of GHG due to the threshold’s applicability to programmatic planning projects. The City of Redlands CAP was adopted on December 5, 2017. The CAP was prepared pursuant to Section 15183.5(b) of the CEQA Guidelines to be utilized as a tiering document for the General Plan as well as future projects within the City of Redlands that are consistent with the General Plan. The CAP incorporates the guidelines established in CARB’s 2017 Scoping Plan. The 2017 Scoping Plan was prepared to meet the most current GHG emissions reduction targets set in Executive Order S‐3‐15 and SB 32 that recommends local governments to develop plans to reduce GHG emissions to 6 MTCO2e/yr by the year 2030 and 2 MTCO2e/yr by the year 2050. Since the CAP was prepared in coordination with the General Plan that has a horizon year of 2035, the Redlands CAP also provided a year 2035 target of 5 MTCO2e/yr, which was determined through interpolation of the 2030 and 2050 GHG emissions targets from the 2017 Scoping Plan.

Since the Project is anticipated to be fully operational by 2040, for analysis purposes herein, the service population threshold for the Project’s buildout year of 2040 was calculated by linear interpolation between the 2035 target of 5 MTCO2e/yr and the 2050 target of 2 MTCO2e/yr. As such, the target for the Project’s buildout year of 2040 is 4.0 MTCO2e/yr and the proposed Project would be considered to create a significant cumulative GHG impact if implementation of the Project would exceed this threshold.

5.6.5 METHODOLOGY
The California Emissions Estimator Model (CalEEMod) v2020.4.0 has been used to determine construction and operational GHG emissions for buildout of the proposed Project, based on the maximum development assumptions outlined in Section 3.0, Project Description.

The purpose of this model is to calculate construction-source and operational-source GHG emissions from direct and indirect sources; and quantify applicable air quality and GHG reductions achieved from measures incorporated into the Project to reduce or minimize GHG emissions. For construction phase project emissions, GHGs are quantified and, per SCAQMD methodology, the total GHG emissions for construction activities are divided by 30-years, and then added to the annual operational phase of GHG emissions.

In addition, CEQA requires the lead agency consider the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. Therefore, this section addresses whether the Project complies with various programs and measures designed to reduce GHG emissions.

5.6.6 ENVIRONMENTAL IMPACTS
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As detailed in Section 3.0, Project Description, the proposed Project would provide a form-based code that would allow development of up to 2,400 residential units; 613,000 square feet of retail commercial, hotel, and office space; and 280,000 square feet of open space and parks within the TVSP area. However, the timing of development and operation of the development pursuant to the TVSP would be dependent upon market conditions and development applications for new projects. However, buildout of the Project is evaluated to occur by 2040 to provide a conservative analysis.

IMPACT GHG-1: THE PROJECT WOULD NOT GENERATE GREENHOUSE GAS EMISSIONS, EITHER

DIRECTLY OR INDIRECTLY, THAT MAY HAVE A SIGNIFICANT IMPACT ON THE

ENVIRONMENT
Less than Significant with Mitigation Incorporated.

Construction
Construction activities would occur at different sites throughout the TVSP area through the Plan’s estimated 18-year build out. The site-specific development projects that would occur pursuant to the TVSP would be temporary at any one location, but numerous site-specific development projects are anticipated to occur pursuant to buildout of the proposed TVSP. Construction of site-specific development projects would create new sources of GHG and could contribute to global climate change. Construction activities would result in the emission of GHGs from equipment exhaust, construction-related vehicular activity, and construction worker automobile trips. Emission levels for construction activities would vary depending on the number and type of equipment, duration of use, operation schedules, and the number of construction workers.

Total estimated construction related GHG emissions from build out of the proposed TVSP were amortized over 30 years per SCAQMD methodology, and as shown on Table 5.6-1 would equal approximately 554.66 MT/yr CO2E per year.

Table 5.6-1: TVSP Construction Greenhouse Emissions
TVSP Area Emissions (MT/yr)
CO2 CH4 N2O Total CO2e1
State Street Village 6,532.27 0.69 0.31 6,638.88
The Grand Apartments 552.90 0.11 0.01 557.94
City Center Mixed-Use 547.52 0.11 0.01 552.52
Downtown Village Future
Projects 832.62 0.15 0.02 841.62
University Village 6,959.00 0.66 0.26 7,054.30
New York Street Village 982.08 0.16 0.03 994.59
Total GHG Emissions 16,406.39 1.88 0.64 16,639.84
Amortized Construction
Emissions (MTCO2e) 546.88 0.06 0.02 554.66
Source: GHG, 2022 (Appendix E).

Operation
Long-term operations of uses included in the TVSP would generate GHG emissions from the following primary sources:
• Area Source Emissions. Landscape maintenance equipment would generate emissions from fuel combustion and evaporation of unburned fuel. Equipment in this category would include lawnmowers, 1 CalEEMod reports the most common GHGs emitted which include CO2, CH4, and N2O. These GHGs are then converted into the CO2e by multiplying the individual GHG by the GWP.

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shedders/grinders, blowers, trimmers, chain saws, and hedge trimmers used to maintain the landscaping.
• Energy Source Emissions. GHGs are emitted from buildings as a result of activities for which electricity and natural gas are typically used as energy sources. Combustion of any type of fuel emits CO2 and other GHGs directly into the atmosphere; these emissions are considered direct emissions associated with a building. GHGs are also emitted during the generation of electricity from fossil fuels; these emissions are considered to be indirect emissions. • Mobile Source Emissions. The Project related GHG emissions are derived primarily from vehicle trips generated by the Project, including employee trips to and from the TVSP area, truck trips associated with the proposed uses, and trips related to residential uses. Trip characteristics from the Trip Generation (Appendix H) were utilized to quantify the GHGs from operation of the TVSP at buildout.
• Water Supply, Treatment, and Distribution. Indirect GHG emissions result from the production of electricity used to convey, treat, and distribute water and wastewater. The amount of electricity required depends on the volume of water as well as the sources of the water. For purposes of analysis, CalEEMod default parameters were used in modeling GHGs from Project water demand. • Solid Waste. The proposed land uses would result in the generation and disposal of solid waste. A percentage of this waste would be diverted from landfills by a variety of means, such as reducing the amount of waste generated, recycling, and/or composting. The remainder of the waste not diverted would be disposed of at a landfill. GHG emissions from landfills are associated with the anaerobic breakdown of material. For purposes of analysis, CalEEMod default parameters were used in modeling GHGs from Project generation of solid waste.

Service Population. Based on the 2035 General Plan estimates of 2.65 persons per household, buildout of the TVSP would generate approximately 6,421 people; and the estimate of 1 employee per 500 square feet would generate 1,039 employees, which would result in a total service population of 7,460.

Table 5.6-2: TVSP Service Population
TVSP Area Residents Employees Total
State Street Village 1,916 200 2,116
The Grand Apartments 395 - 395
City Center Mixed-Use 366 21 387
Downtown Village Future Projects 432 178 610
University Village 2,783 220 3,003
New York Street Village 530 420 950
Total Service Population 6,421 1,039 7,460
Source: GHG, 2022 (Appendix E)
The annual GHG emissions from operation of the TVSP at buildout are summarized in Table 5.6-3. As shown, construction and operation of the Project would generate a CO2e per service population of 2.84, which would not exceed the threshold of 4.0. Thus, operational impacts would be significant.

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Table 5.6-3: Operational Greenhouse Emissions
Emission Source Emissions (MT/yr)
CO2 CH4 N2O Total CO2e
Annual construction-related
emissions amortized over 30 years 546.88 0.06 0.02 554.66 State Street Village 4,049.78 11.79 0.13 4,385.13
The Grand Apartments 950.09 1.19 0.04 991.16
City Center Mixed-Use 1,007.15 1.28 0.04 1,052.03
Downtown Village Future Projects 2,869.47 2.82 0.12 2,975.89 University Village 7,273.88 10.17 0.29 7,616.10
New York Street Village 3,463.45 5.24 0.15 3,638.55
Total CO2e (All Sources) 21,213.54
Service Population 7,460
Total CO2e/Service Population 2.84
Screening Threshold (CO2e) 4.0
Threshold Exceeded? NO
Source: GHG, 2022 (Appendix E).

Additionally, Mitigation Measure AQ-7 would be implemented to require development projects in the TVSP area to achieve 5 percent efficiency beyond the incumbent California Building Code Title 24 requirements; and Mitigation Measure AQ-8 would require enhanced water conservation for TVSP development projects.

These measures are designed to reduce Project operational-source emissions of GHGs. However, it should be noted that there is no way to quantify these reductions in the CalEEMod. Therefore, to provide a conservative disclosure of Project emissions, no reductions in emissions are assumed to occur even with implementation of the below measures. As the Project total GHG emissions per service population would not exceed the screening threshold of 4.0 MTCO2e per service population per year, Project related GHG emissions would be less than significant.

IMPACT GHG-2: THE PROJECT WOULD NOT CONFLICT WITH AN APPLICABLE PLAN, POLICY OR

REGULATION ADOPTED FOR THE PURPOSE OF REDUCING THE EMISSIONS OF

GREENHOUSE GASES
Less than Significant Impact. As described previously, the City of Redlands CAP was designed to reinforce the City’s commitment to reducing GHG emissions and demonstrate compliance with the State’s GHG emissions reduction standards. The CAP used the 2017 Scoping Plan recommended Plan Level emissions target of 6.0 MTCO2e per capita per year for 2030. As described in Impact GHG-1, the TVSP would result in GHG emissions per service population that would be less than 4.0 MTCO2e, and therefore would be consistent with the CAP emission goals. Also, the Project would implement CalGreen building standards, as verified through the City’s permitting process, that include requirements such as solar photovoltaic systems, increased energy and water efficiency.

The TVSP development would include contemporary, energy-efficient/energy-conserving design features and operational procedures. The proposed TVSP would not interfere with the state’s implementation of Executive Order B-30-15 and SB 32’s target of reducing statewide GHG emissions to 40 percent below 1990 levels by 2030; or Executive Order S-3-05’s target of reducing statewide GHG emissions to 80 percent below 1990 levels by 2050 because it does not interfere with implementation of the GHG reduction measures listed in CARB’s 2007 Scoping Plan or CARB’s Updated Scoping Plan (2017). CARB’s Updated Scoping Plan reflects the 2030 target of a 40 percent reduction below 1990 levels, set by Executive Order S-3-05, and codified by AB 32.

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The development resulting from the TVSP would include sustainable design features related to reduction of GHG emissions that would be consistent with CARB’s Scoping Plans (the 2007 and 2017) that provide measures to reduce GHG emissions, which the Project is consistent with as discussed below and detailed in Tables 5.6-4 and 5.6-5 and the requirements listed and described below. Thus, the TVSP would not conflict with the CARB Scoping Plans and related regulations.
• Pavley emissions standard and Low Carbon Fuel Standard: Pavley emissions standards (AB 1493) apply to all new passenger vehicles starting with model year 2009, and the Low Carbon Fuel Standard became effective in 2010 and regulates the transportation fuel used. The second phase of implementation of the Pavley regulations per AB 1493 is referred to as the Advanced Clean Car program, which combines the control of smog-causing pollutants and GHG emissions into a single coordinated package of requirements for model years 2017 through 2025. The regulation will reduce GHGs from new cars by 34 percent from 2016 levels by 2025. The TVSP is consistent with these requirements as they apply to all new passenger vehicles and vehicle fuel purchased in California.
• Energy Efficiency – Title 24/CalGreen: The proposed TVSP are subject to the CalGreen Code Title 24 building energy efficiency requirements that offer builders better windows, insulation, lighting, ventilation systems, and other features as listed in Section 5.6.2, Regulatory Setting that reduce energy consumption. Compliance with the CalGreen standards would be verified by the City during building permitting process.
• Renewable Portfolio Standard. As a customer of Southern California Edison (SCE), the development within the TVSP would purchase from an increasing supply of renewable energy sources and more efficient baseload generations, reduce GHG emissions, and be consistent with this requirement. • Million Solar Roofs Program: The TVSP is consistent with this scoping plan measure as the TVSP structures would provide either solar powered or solar ready roofs, as appliable to each structure. • Water Efficiency and Waste Diversion: Development and operation of new development pursuant to the TVSP would be implemented in consistency with water conservation requirements (as included in Title 24) and solid waste recycling and landfill diversion requirements of the State.

Table 5.6-4: Project Consistency with the CARB 2007 Scoping Plan Action Supporting
Measures2 Consistency
Cap-and-Trade
Program --
Not applicable. These programs involve capping emissions from electricity generation, industrial facilities, and broad scoped fuels. Caps do not directly affect residential, office, and commercial projects.

Light-Duty Vehicle
Standards T-1
Not applicable. While these are CARB-enforced measures that are not directly applicable to the Project, vehicles that access the TVSP area are required to comply with the standards and would comply with this strategy.

Electric Vehicle (EV) charging stations within the TVSP area are required to be installed on site per the 2019 Title 24 standards.

Energy Efficiency
E-1
Consistent. The TVSP would implement a variety of building, water, and solid waste efficiencies consistent with the most current CALGreen requirements.

E-2
CR-1
CR-2
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Action Supporting
Measures2 Consistency
Renewables
Portfolio Standard E-3 Not applicable. Establishes the minimum statewide renewable energy mix.

Low Carbon Fuel
Standard T-2 Not applicable. Establishes reduced carbon intensity of transportation fuels.

Regional
TransportationRelated GHG
Targets
T-3 Not applicable. This is a statewide measure and is not within the purview of this Project.

Vehicle Efficiency
Measures T-4 Not applicable. Identifies measures such as minimum tire-fuel efficiency, lower friction oil, and reduction in air conditioning use.

Goods Movement
T-5 Not applicable. Identifies measures to improve goods movement efficiencies such as advanced combustion strategies, friction reduction, waste heat recovery, and electrification of accessories. While these measures are not directly applicable to the Project, any activity associated with Goods Movement would be required to comply with these measures as adopted. As such, the Project would not interfere with their implementation.

T-6
Million Solar Roofs
(MSR) Program E-4
Consistent. The MSR program sets a goal for use of solar systems throughout the state as a whole. While the TVSP does not include solar energy generation, the non-residential building roof structures would be solar ready and residential structures would include solar power, consistent with Title 24 requirements.

Medium- & HeavyDuty Vehicles
T-7 Not applicable. MD and HD trucks and trailers for industrial uses are subject to aerodynamic and hybridization requirements as established by CARB; the Project would not interfere with implementation of these requirements and programs.

T-8
Industrial Emissions
I-1
Not applicable. These measures are applicable to large industrial facilities (> 500,000 MTCO2e/yr) and other intensive uses such as refineries.

I-2
I-3
I-4
I-5
High Speed Rail T-9 Not applicable. Supports increased mobility choice.

Green Building
Strategy GB-1 Consistent. The Project would include a variety of building, water, and solid waste efficiencies consistent with the current CALGreen requirements.

High Global
Warming Potential
Gases
H-1
Not applicable. The Project is not a substantial source of high GWP emissions and would comply with any future changes in air conditioning, fire protection suppressant, and other requirements.

H-2
H-3
H-4
H-5
H-6
H-7
Recycling and
Waste
RW-1 Consistent. The Project would be required to recycle a minimum of 65 percent from construction activities and Project operations per State and City requirements.

RW-2
RW-3
Sustainable Forests F-1 Consistent. The TVSP would support carbon sequestration by providing new trees per the Project landscaping.

Water
W-1
Consistent. The development projects within the TVSP area would be required to install low-flow fixtures and efficient landscaping per State requirements.

W-2
W-3
W-4
W-5
W-6
Agriculture A-1 Not applicable. The Project is not an agricultural use and the TVSP area does not include agricultural uses.

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Table 5.6-5: Project Consistency with the CARB 2017 Scoping Plan Action Responsible Parties Consistency
Implement SB 350 by 2030
Increase the Renewables Portfolio Standard to
50 percent of retail sales by 2030 and ensure
grid reliability.

CPUC,
CEC,
CARB
Consistent. The TVSP area would use energy
from SCE, which has committed to diversify its
portfolio of energy sources by increasing
energy from wind and solar sources. The
TVSP would not interfere with or obstruct SCE
energy source diversification efforts.

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 development projects under
the TVSP would be designed and constructed
to implement the energy efficiency measures.

The TVSP would not interfere with or obstruct
policies or strategies to establish annual
targets for statewide energy efficiency
savings and demand reduction.

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. Load-serving entities and
publicly- owned utilities meet GHG emissions
reductions planning targets through a
combination of measures as described in IRPs.

Consistent. The development projects
pursuant to the TVSP would be designed and
constructed to implement energy efficiency
measures acting to reduce electricity
consumption. The TVSP development would
include energy efficient HVAC, lighting and
equipment that meet the current Title 24
Standards.

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. This is a CARB Mobile Source
Strategy. The TVSP would not obstruct or
interfere with CARB zero emission and plugin hybrid light-duty electric vehicle 2025 targets.

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

Consistent. This is a CARB Mobile Source
Strategy. The TVSP would not obstruct or
interfere with CARB zero emission and plugin hybrid light-duty electric vehicle 2030 targets.

Further increase GHG stringency on all lightduty vehicles beyond existing Advanced Clean cars regulations.

Consistent. This is a CARB Mobile Source
Strategy. The TVSP would not obstruct or
interfere with CARB efforts to further increase
GHG stringency on all light-duty vehicles
beyond existing Advanced Clean cars
regulations.

Medium- and Heavy-Duty GHG Phase 2.

Consistent. This is a CARB Mobile Source
Strategy. The TVSP would not obstruct or
interfere with CARB efforts to implement
Medium- and Heavy-Duty GHG Phase 2
Innovative Clean Transit: Transition to a suite
of to-be-determined innovative clean transit
options. Assumed 20 percent of new urban
buses purchased beginning in 2018 will be
Consistent. This is a CARB Mobile Source
Strategy. The TVSP would not obstruct or
interfere with CARB efforts improve transitsource emissions.

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Action Responsible Parties Consistency
zero emission buses with the penetration of
zero-emission technology ramped up to 100
percent of new sales in 2030. Also, new
natural gas buses, starting in 2018, and diesel
buses, starting in 2020, meet the optional
heavy-duty low-NOX standard.

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 percent of new
Class 3–7 truck sales in local fleets starting in
2020, increasing to 10 percent in 2025 and
remaining flat through 2030.

Consistent. This is a CARB Mobile Source
Strategy. The TVSP would not obstruct or
interfere with CARB efforts to improve last
mile delivery emissions.

Further reduce 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.”
Consistent. The Project implements infill
residential in walkable communities near
transit stations, which that would act to reduce
VMT. Please refer to the Project VMT
Assessment and EIR Section 5.14
Transportation.

Increase stringency of SB 375 Sustainable
Communities Strategy (2035 targets). CARB
Consistent. This is a CARB Mobile Source
Strategy. The TVSP would not obstruct or
interfere with CARB efforts to Increase
stringency of SB 375 Sustainable
Communities Strategy (2035 targets).

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),
California
Transportation
Commission (CTC),
Caltrans
Consistent. The TVSP would not obstruct or
interfere with agency efforts to harmonize
transportation facility project performance
with emissions reductions and increase
competitiveness of transit and active
transportation modes.

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Action Responsible Parties Consistency
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
Consistent. The TVSP would not obstruct or
interfere with agency efforts to develop
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
Consistent. This measure would apply to all
trucks accessing the TVSP area, this may
include existing trucks or new trucks that are
part of the statewide goods movement
sector. The TVSP would not obstruct or
interfere with agency efforts to Improve
freight system efficiency.

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

Consistent. The TVSP would not obstruct or
interfere with agency efforts to deploy over
100,000 freight vehicles and equipment
capable of zero emission operation and
maximize both zero and near-zero emission
freight vehicles and equipment powered by
renewable energy by 2030.

Adopt a Low Carbon Fuel Standard with a
Carbon Intensity reduction of 18 percent.

CARB
Consistent. When adopted, this measure
would apply to all fuel purchased and used
in the state. The TVSP would not obstruct or
interfere with agency efforts to adopt a Low
Carbon Fuel Standard with a Carbon
Intensity reduction of 18 percent.

Implement the Short-Lived Climate Pollutant Strategy (SLPS) by 2030 40 percent reduction in methane and
hydrofluorocarbon emissions below 2013
levels.

CARB,
CalRecycle,
CDFA,
SWRCB,
Local Air Districts
Consistent. The TVSP would be required to
comply with this measure and reduce any
Project-source SLPS emissions accordingly.

The TVSP would not obstruct or interfere
agency efforts to reduce SLPS emissions. 50 percent reduction in black carbon emissions below 2013 levels.

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
Consistent. The TVSP would implement waste
reduction and recycling measures consistent
with State requirements. The TVSP would not
obstruct or interfere agency efforts to
support organic waste landfill reduction
goals in the SLCP and SB 1383.

Implement the post-2020 Cap-and-Trade
Program with declining annual caps. CARB
Consistent. The TVSP would be required to
comply with any applicable Cap-and-Trade
Program provisions. The TVSP would not
obstruct or interfere agency efforts to
implement the post-2020 Cap-and-Trade
Program.

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Action Responsible Parties Consistency
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
Consistent. The TVSP would not obstruct or
interfere agency efforts to protect land from
conversion through conservation easements
and other incentives.

Increase the long-term resilience of carbon
storage in the land base and enhance
sequestration capacity
Consistent. The TVSP area is urban and
disturbed property and does not comprise an
area that would effectively provide for
substantial carbon sequestration. The TVSP
would install landscaping that would enhance
the sequestration capacity and would not
obstruct or interfere agency efforts to
increase the long-term resilience of carbon
storage in the land base and enhance
sequestration capacity.

Utilize wood and agricultural products to
increase the amount of carbon stored in the
natural and built environments
Consistent. Where appropriate, project
designs would incorporate wood or wood
products. The TVSP would not obstruct or
interfere agency efforts to encourage use of
wood and agricultural products to increase
the amount of carbon stored in the natural
and built environments.

Establish scenario projections to serve as the
foundation for the Implementation Plan
Consistent. The TVSP would not obstruct or
interfere agency efforts to establish scenario
projections to serve as the foundation for the
Implementation Plan.

Establish a carbon accounting framework for
natural and working lands as described in SB
859 by 2018
CARB
Consistent. The TVSP would not obstruct or
interfere agency efforts to establish a carbon
accounting framework for natural and
working lands as described in SB 859 by
2018.

Implement Forest Carbon Plan
CNRA,
California
Department of
Forestry and Fire
Protection
(CAL FIRE),
CalEPA and
Departments Within
Consistent. The TVSP would not obstruct or
interfere agency efforts to implement the
Forest Carbon Plan.

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

State Agencies &
Local Agencies
Consistent. The TVSP would not obstruct or
interfere agency efforts to identify and
expand funding and financing mechanisms to
support GHG reductions across all sectors.

Further, the TVSP is consistent with AB 32 and SB 32 through implementation of regulatory requirements that address GHG emissions related to building energy, solid waste management, wastewater, and water conveyance. Thus, the Project would be consistent with the State’s requirements for GHG reductions. In Redlands Regular Meeting of 10-18-22 821 of 1815
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addition, as detailed in Table 5.6-6 below, the Project would not conflict with the relevant General Plan policies related to GHG emissions.

Table 5.6-6: Project Consistency with the City General Plan Sustainable Community Element Policies General Plan Policy Consistency
Principle 8-P.1 Promote energy efficiency and
conservation technologies and practices that reduce the use and dependency of nonrenewable resources of
energy by both City government and the community.

Consistent. As described in previously, the TVSP would
implement a variety of building, water, and solid waste efficiencies consistent with the most current CALGreen
requirements. Therefore, the Project is consistent with Principle 8-P.1.

Action 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. As described previously, the TVSP would
implement the most current CALGreen requirements and
Mitigation Measure AQ-8 requires enhanced energy
efficiency to achieve a 5% efficiency beyond the most
current Title 24 building standards. Therefore, the
proposed TVSP is consistent with Action 8-A.8.

Action 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 described previously, the TVSP would
implement the most current CALGreen requirements and
Mitigation Measure AQ-8 requires enhanced energy
efficiency to achieve a 5% efficiency beyond the most
current Title 24 building standards. This includes use of materials with solar reflectance and thermal emittance
required by Title 24. Therefore, the proposed Project is consistent with Action 8-A.9.

Action 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 includes substantial
landscaping throughout the public realm and requires
landscaping be included in private development
projects. Therefore, the proposed TVSP is consistent with Action 8-A.10.

Principle 8-P.8 Promote sustainability by reducing the
community’s greenhouse gas (GHG) emissions and
fostering green development patterns – including
buildings, sites, and landscapes.

Consistent. As detailed in Section 3.0, Project
Description, the TVSP would implement green
development patterns of mixed-use communities with
pedestrian and bicycle circulation near transit stations.

The pattern of development is intended to reduce vehicle miles traveled while providing for projected growth.

Thus, the proposed TVSP is consistent with Action 8-P.8.

Overall, the proposed TVSP would not result in a conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. The TVSP would be implemented in compliance with state energy standards provided in Title 24, in addition to provision of sustainable design features. The TVSP would not interfere with the state’s implementation of Executive Order B-30-15 and SB 32’s target of reducing statewide GHG emissions to 40 percent below 1990 levels by 2030; or Executive Order S-3-05’s target of reducing statewide GHG emissions to 80 percent below 1990 levels by 2050 because it would be consistent with the CARB 2007 and 2017 Scoping Plans, which are intended to achieve the reduction targets required by the state. In addition, the TVSP would be consistent with the relevant City General Plan policies and the City’s Climate Action Plan. Thus, the proposed TVSP would not result in a Redlands Regular Meeting of 10-18-22 822 of 1815
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conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs.

5.6.7 CUMULATIVE IMPACTS
GHG emissions impacts are assessed in a cumulative context, since no single project can cause a discernible change to climate. Climate change impacts are the result of incremental contributions from natural processes, and past and present human-related activities. Therefore, the area in which a TVSP in combination with other past, present, or future projects, could contribute to a significant cumulative climate change impact would not be defined by a geographical boundary such as a project site or combination of sites, city or air basin. GHG emissions have high atmospheric lifetimes and can travel across the globe over a period of 50 to 100 years or more. Even though the emissions of GHGs cannot be defined by a geographic boundary and are effectively part of the global issue of climate change, CEQA places a boundary for the analysis of impacts at the state’s borders. Thus, the geographic area for analysis of cumulative GHG emissions impacts is the State of California.

Executive Order S-3-05, Executive Order B-30-15, AB 32, and SB 32 recognizes that California is the source of substantial amounts of GHG emissions and recognizes the significance of the cumulative impact of GHG emissions from sources throughout the state and sets performance standards for reduction of GHGs.

The analysis of GHG emission impacts under CEQA contained in this EIR effectively constitutes an analysis of a project’s contribution to the cumulative impact of GHG emissions. As described previously, the estimated GHG emissions from development and operation of the proposed TVSP at buildout would not exceed the service population threshold of 4.0 MTCO2e per year. Therefore, the contribution of the TVSP to significant cumulative GHG impacts is less than significant and not cumulatively considerable.

5.6.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
State
• Clean Car Standards – Pavley Assembly Bill 1493
• California Executive Order S-3-05
• Assembly Bill 32 (Global Warming Solutions Act of 2006) • Senate Bill 375
• California Executive Order B-30-15
• Senate Bill 32
• California Green Building Standards Code (Code of Regulations, Title 24 Part 6) Local
• City of Redlands Climate Action Plan
• City of Redlands General Plan Sustainable Community Element Standard Conditions
None.

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Plans, Programs, or Policies
None.

5.6.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact GHG-1 would be less than significant. As a result of compliance with existing regulatory requirements Impact GHG-2 would be less than significant.

5.6.10 MITIGATION MEASURES
Mitigation measures identified below are also listed in Draft EIR Section 5.2.15, Air Quality.

Mitigation Measure AQ-7: Enhanced Energy Efficiency: Prior to the issuance of building permits, the Project applicant shall submit energy usage calculations to the Planning Division showing that the Project is designed to achieve 5 percent (%) efficiency beyond the incumbent California Building Code Title 24 requirements.

Example of measures that reduce energy consumption include, but are not limited to, the following (it being understood that the items listed below are not all required and merely present examples; the list is not allinclusive and other features that reduce energy consumption also are acceptable):
• Increase in insulation such that heat transfer and thermal bridging is minimized; • Limit air leakage through the structure and/or within the heating and cooling distribution system; • Use of energy-efficient space heating and cooling equipment; • Installation of electrical hook-ups at loading dock areas; • Installation of dual-paned or other energy efficient windows; • Use of interior and exterior energy efficient lighting that exceeds then incumbent California Title 24 Energy Efficiency performance standards;
• Installation of automatic devices to turn off lights where they are not needed; • Application of a paint and surface color palette that emphasizes light and off-white colors that reflect heat away from buildings;
• Design of buildings with “cool roofs” using products certified by the Cool Roof Rating Council, and/or exposed roof surfaces using light and off-white colors; • Design of buildings to accommodate photo-voltaic solar electricity systems or the installation of photo-voltaic solar electricity systems;
Installation of ENERGY STAR-qualified energy-efficient appliances, heating and cooling systems, office equipment, and/or lighting products.

Mitigation Measure AQ-8: Enhanced Water Conservation. To reduce water demands and associated energy use, subsequent development proposals within the TVSP area shall incorporate a Water Conservation Strategy and demonstrate a minimum 30% reduction in outdoor water usage when compared to baseline water demand (total expected water demand without implementation of the Water Conservation Strategy)3.

Development proposals within the TVSP area shall also implement the following:
• Landscaping palette emphasizing drought tolerant plants; 3 The analysis includes a reduction of 20% indoor water usage consistent with the current CALGreen Code (11) for residential and non-residential land uses. Per CALGreen, the reduction shall be based on the maximum allowable water use per plumbing fixture and fittings as required by the California Building Standards Code.

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• Use of water-efficient irrigation techniques;
• U.S. EPA Certified WaterSense labeled or equivalent faucets, high-efficiency toilets (HETs), and water-conserving shower heads.

5.6.113 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Though impacts related to Impact GHG-1 would be below thresholds prior to inclusion of mitigation, Mitigation Measure AQ-7 and AQ-8 would further reduce GHG emissions and impacts would be less than significant.

REFERENCES
City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report 2017.

Accessed: https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands 2035 General Plan, 2017. Accessed: https://www.cityofredlands.org/post/planningdivision-general-plan City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 SCAG 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction. Accessed:
https://scag.ca.gov/sites/main/files/fileattachments/2016_2040rtpscs_finalgrowthforecastbyjurisdiction.pdf?1605576071 Urban Crossroads. “Transit Villages District and Specific Plan Greenhouse Gas Impact Analysis” 2022.

Appendix E.

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5.7 Hazards and Hazardous Materials

5.7.1 INTRODUCTION
This section considers the nature and range of foreseeable hazardous materials and physical hazards/ impacts that would result from implementation of the proposed Project. It identifies the ways that hazardous materials and other types of hazards could expose people and the environment to various health and safety risks during construction activities and operation of proposed Project.

This section also describes routine hazardous materials that are likely to be used, handled, or processed within the Project area, and the potential for upset and accident conditions in which hazardous materials could be released. The impact analysis identifies ways in which hazardous materials might be routinely used, stored, handled, processed, or transported, and evaluates the extent to which existing and future populations could be exposed to hazardous materials. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035, December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), Dyett & Bhatia, July 2017; and
• City of Redlands Municipal Code.

Hazards and Hazardous Materials Terminology
• Hazardous Material. Hazardous material is defined in the California Health and Safety Code, Chapter 6.95, Section 25501(o) as any material that, because of quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment.

5.7.2 REGULATORY SETTING

5.7.2.1 Federal Regulations
Hazardous Materials Management
The primary federal agencies responsible for hazardous materials management include the U.S.

Environmental Protection Agency (USEPA) and the U.S. Department of Labor Occupational Safety and Health Administration (OSHA).

Resource Conservation and Recovery Act of 1976
Federal hazardous waste regulations are generally promulgated under the Resource Conservation and Recovery Act (RCRA). Pursuant to RCRA, the USEPA regulates the generation, transportation, treatment, storage, and disposal of hazardous waste in a “cradle to grave” manner. RCRA was designed to protect human health and the environment, reduce/eliminate the generation of hazardous waste, and conserve energy and natural resources.

The Hazardous and Solid Waste Amendments of 1984 both expanded the scope of RCRA and increased the level of detail in many of its provisions, reaffirming the regulation from generation to disposal and to Redlands Regular Meeting of 10-18-22 826 of 1815
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prohibiting the use of certain techniques for hazardous waste disposal. The USEPA has largely delegated responsibility for implementing the RCRA program in California to the State, which implements this program through the California Hazardous Waste Control Law.

RCRA regulates landfill siting, design, operation, and closure (including identifying liner and capping requirements) for licensed landfills. In California, RCRA landfill requirements are delegated to the California Department of Resources Recycling and Recovery (CalRecycle), which is discussed in detail below.

RCRA allows the USEPA to oversee the closure and post-closure of landfills. Additionally, the federal Safe Drinking Water Act, 40 CFR Part 141, gives the USEPA the power to establish water quality standards and beneficial uses for waters from below- or above-ground sources of contamination. For the Project area, water quality standards are administered by the Regional Water Quality Control Board (RWQCB).

RCRA also allows the USEPA to control risk to human health at contaminated sites. Vapor intrusion presents a significant risk to human populations overlying contaminated soil and groundwater and is considered when conducting human health risk assessments and developing Remedial Action Objectives.

Occupational Safety and Health Act of 1970
Federal and state occupational health and safety regulations also contain provisions regarding hazardous waste management through the Occupational Safety and Health Act of 1970 (amended), which is implemented by OSHA. Title 29 of the Code of Federal Regulations (29 CFR) requires special training of handlers of hazardous materials; notification to employees who work in the vicinity of hazardous materials; acquisition from the manufacturer of material safety data sheets (MSDS), which describe the proper use of hazardous materials; and training of employees to remediate any hazardous material accidental releases.

OSHA regulates administration of 29 CFR.

OSHA also establishes standards regarding safe exposure limits for chemicals to which construction workers may be exposed. Safety and Health Regulations for Construction (29 CFR Part 1926.65 Appendix C) contains requirements for construction activities, which include occupational health and environmental controls to protect worker health and safety. The guidelines describe the health and safety plan(s) that must be developed and implemented during construction, including associated training, protective equipment, evacuation plans, chains of command, and emergency response procedures.

Adherence to applicable hazard-specific OSHA standards is required to maintain worker safety. For example, methane is regulated by OSHA under 29 CFR Part 1910.146 with regard to worker exposure to a “hazardous atmosphere” within confined spaces where the presence of flammable gas vapor or mist is in excess of 10 percent of the lower explosive limit. Title 49 of the CFR governs the manufacture of packaging and transport containers, packing and repacking, labeling, and the marking of hazardous material transport.

Title 42, Part 82 governs solid waste disposal and resource recovery.

Comprehensive Environmental Response, Compensation, and Liability Act The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 (42 USC § 9601 et seq.), commonly known as the Superfund, protects water, air, and land resources from the risks created by past chemical disposal practices such as abandoned and historical hazardous waste sites. It gave the EPA power to seek out the parties responsible for a release and ensure their cooperation in the cleanup.

CERCLA also enabled the revision of the National Contingency Plan, which established the National Priority List (NPL) of sites, known as Superfund sites. CERCLA was amended by the Superfund Amendments and Reauthorization Act (SARA) in 1986 to continue cleanup activities.

Hazardous Materials Transportation Act
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The transportation of hazardous materials is regulated by the Hazardous Materials Transportation Act (HMTA), which is administered by the Research and Special Programs Administration (RSPA) of the US Department of Transportation (USDOT). The Hazardous Materials Transportation Act provides USDOT with a broad mandate to regulate the transport of hazardous materials, with the purpose of adequately protecting the nation against risk to life and property, which is inherent in the commercial transportation of hazardous materials. The Hazardous Materials Transportation Act governs the safe transportation of hazardous materials by all modes, excluding bulk transportation by water. The Research and Special Programs Administration carries out these responsibilities by prescribing regulations and managing a userfunded grant program for planning and training grants for states and Indian tribes. USDOT regulations that govern the transportation of hazardous materials are applicable to any person who transports, ships, causes to be transported or shipped, or are involved in any way with the manufacture or testing of hazardous materials packaging or containers. USDOT regulations pertaining to the actual movement govern every aspect of the movement, including packaging, handling, labeling, marking, placarding, operational standards, and highway routing. Additionally, USDOT is responsible for developing curriculum to train for emergency response and administers grants to states and Indian tribes for ensuring the proper training of emergency responders. Hazardous Materials Transportation Act was enacted in 1975 and was amended and reauthorized in 1990, 1994, and 2005.

Title 49 of the Code of Federal Regulations, Chapter I
Under Code of Federal Regulations (CFR) Title 49, Chapter I, USDOT’s Pipeline and Hazardous Materials Safety Administration regulates the transport of hazardous materials. Title 49, Chapter I sets forth regulations for response to hazardous materials spills or incidents during transport and requirements for shipping and packaging of hazardous materials.

Emergency Planning and Community Right-to-Know Act
Title III of SARA authorized the Emergency Planning and Community Right-to-Know Act (EPCRA)(42 USC § 11001 et seq.) to inform communities and citizens of chemical hazards in their areas by requiring businesses to report the locations and quantities of chemicals stored onsite to state and local agencies; releases to the environment of more than 600 designated toxic chemicals; offsite transfers of waste; and pollution prevention measures and activities and to participate in chemical recycling. The EPA maintains and publishes an online, publicly available, national database of toxic chemical releases and other waste management activities by certain industry groups and federal facilities—the Toxics Release Inventory. To implement EPCRA, each state appointed a state emergency response commission to coordinate planning and implementation activities associated with hazardous materials. The commissions divided their states into emergency planning districts and named a local emergency planning committee for each district. The federal EPCRA program is implemented and administered in California Governor's Office of Emergency Services (Cal OES), a state commission, 6 local committees, and 81 Certified Unified Program agencies. Cal OES coordinates and provides staff support for the commission and local committees.

Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) of 1976 (15 USC § 2601 et seq.) gave the EPA the ability to track the 75,000 industrial chemicals produced or imported into the United States. The EPA repeatedly screens these chemicals; can require reporting or testing of any that may pose an environmental or human health hazard; and can ban the manufacture and import of chemicals that pose an unreasonable risk. The EPA tracks the thousands of new chemicals each year with unknown or dangerous characteristics. The act supplements other federal statutes, including the Clean Air Act and the Toxics Release Inventory under EPCRA.

Code of Federal Regulations Title 29, Section 1926.62
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CFR Title 29, Section 1926.62 provides federal regulations for construction work where an employee may be occupationally exposed to lead. It includes standards for exposure assessment, worker protection, methods of compliance, biological monitoring, and medical surveillance.

Code of Federal Regulations Title 40, Part 761
CFR Title 40, Part 761 provides federal regulations for the manufacturing, processing, distribution, use, and clean up of polychlorinated biphenyls (PCBs). It provides remediation standards for the clean up of PCB waste in soils.

5.7.2.2 State Regulations
Hazardous Materials Management and Waste Handling
In the regulation of hazardous waste management, California law often mirrors or is more stringent than federal law. The California Environmental Protection Agency (CalEPA) and California Occupational Safety and Health Administration (CalOSHA) are the primary state agencies responsible for hazardous materials management. Additionally, the California Emergency Management Agency (CalEMA) administers the California Accidental Release Prevention (CalARP) program. The California Department of Toxic Substances Control (DTSC), which is a branch of CalEPA, regulates the generation, transportation, treatment, storage, and disposal hazardous waste, as well as the investigation and remediation of hazardous waste sites. The California DTSC program incorporates the provisions of both federal (RCRA) and State hazardous waste laws. The California Department of Pesticide Regulation, which is a branch of CalEPA, regulates the sale, use, and cleanup of pesticides (CCR, Title 3).

Excavated soil containing hazardous substances and hazardous building materials would be classified as a hazardous waste if they exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity (CCR, Title 22, Division 4.5, Chapter 11, Article 3). State and federal laws require detailed planning to ensure that hazardous materials are properly handled, used, stored, and disposed of, and in the event that such materials are accidentally released, to prevent or to mitigate injury to health or the environment. These laws and regulations are overseen by a variety of state and local agencies. The California Integrated Waste Management Board and the RWQCB specifically address management of hazardous materials and waste handling in their adopted regulations (CCR, Title 14 and CCR, Title 27).

The primary local agency, known as the Certified Unified Program Agency (CUPA), with responsibility for implementing federal and State laws and regulations pertaining to hazardous materials management is the San Bernardino County Fire Department (SBCFD). The Unified Program is the consolidation of six state environmental regulatory programs into one program under the authority of a CUPA. A CUPA is a local agency that has been certified by Cal-EPA to implement the six state environmental programs within the local agency's jurisdiction. This program was established under the amendments to the California Health and Safety Code made by SB 1082 in 1994. The six consolidated programs are:
• Hazardous Materials Release Response Plan and Inventory (Business Plans) • California Accidental Release Prevention (CalARP)
• Hazardous Waste (including Tiered Permitting)
• Underground Storage Tanks (USTs)
• Above Ground Storage Tanks (Spill Prevention Control and Countermeasures (SPCC) requirements) • Uniform Fire Code (UFC) Article 80 Hazardous Material Management Program (HMMP) and Hazardous Material Identification System (HMIS)
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inspection activities, and enforcement activities throughout San Bernardino County (with the exception of the City of Victorville). This approach strives to reduce overlapping and sometimes conflicting requirements of different governmental agencies independently managing these programs.

Hazardous Materials Release Response Plans and Inventory (Business Plan) This CUPA program provides information to emergency responders and the general public regarding hazardous materials at certain facilities, and coordinates reporting of releases and spill response among businesses and local, state, and federal government authorities. Businesses are required to disclose all hazardous materials and wastes above certain quantities that are used, stored, or handled at their facility.

They are also required to train their employees to safely handle chemicals and to take appropriate emergency response actions. Inspections are conducted periodically to verify the inventory and other information on the business emergency/contingency plan.

California Accidental Release Prevention Program
This program aims to reduce risks involving regulated substances through the evaluation of hazards and consequences and the development of risk management plans and prevention programs. The program requires certain facilities (referred to as "stationary sources") that handle specified chemicals (termed "regulated substances") to take specified actions to prevent and prepare for chemical accidents.

Underground Storage Tank Program
The Hazardous Materials Division oversees the Underground Storage Tank (UST) Program throughout San Bernardino County, with the exception of the city of Victorville. The purpose of this program is to ensure that hazardous substances are not released into the groundwater and/or the environment from UST systems.

Specialists annually inspect tank system components, associated monitoring equipment, and inventory records to ensure that the UST systems comply with applicable laws and regulations.

Aboveground Petroleum Storage Act /Spill Prevention, Control, and Countermeasure Plan Facilities that have cumulative aboveground storage capacities of petroleum products at or exceeding 1,320 gallons are subject to the Aboveground Petroleum Storage Act. Facilities that are subject to this act must prepare a Spill Prevention, Control, and Countermeasure Plan. Facilities handling petroleum or any other hazardous material require a business emergency/contingency plan. Both petroleum and nonpetroleum aboveground storage tanks are subject to the fire code requirements of the authority having fire code jurisdiction.

Hazardous Waste Generation and Onsite Treatment
The Hazardous Waste Inspection Program works to ensure that all hazardous wastes generated by San Bernardino County facilities are properly managed. Specialists in this program inspect facilities that generate hazardous waste, investigate complaints of unlawful hazardous waste disposal, and participate in public education. These programs are designed to provide information about laws and regulations relating to safe management of hazardous waste.

Hazardous Materials Management Plans (HMMPs) and Hazardous Materials Inventory Statements (HMISs) The Uniform Fire Code has a provision for the local fire agency to collect information regarding hazardous materials at facilities for purposes of fire code implementation. A fire chief may require additional information to a Business Plan to meet the California Fire Code HMMP/HMIS requirements.

Hazardous Waste Control Act
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became the model for the federal Resource Conservation and Recovery Act (RCRA). California’s program, however, was broader and more comprehensive than the federal system, regulating wastes and activities not covered by the federal program. California’s Hazardous Waste Control Law was followed by emergency regulations in 1973 that clarified and defined the hazardous waste program, as follows:
• Included definitions of what was a waste and what was hazardous as well as what was necessary for appropriate handling, processing, and disposal of hazardous and extremely hazardous waste in a manner that would protect the public, livestock, and wildlife from hazards to health and safety. • The early regulations also established a tracking system for the handling and transportation of hazardous waste from the point of waste generation to the point of ultimate disposition, as well as a system of fees to cover the costs of operating the hazardous waste management program. • Advancing the newly developing awareness of hazardous waste management issues, the program established a technical reference center for public and private use dealing with all aspects of hazardous waste management.

California Government Code Section 65962.5 (a), Cortese List The Hazardous Waste and Substance Sites List (Cortese List) is a planning document used by the State, local agencies, and developers to comply with CEQA requirements in providing information about the location of hazardous materials release sites. Government Code Section 65962.5 requires the California Environmental Protection Agency (CalEPA) to develop at least annually an updated Cortese List. The Department of Toxic Substances Control is responsible for a portion of the information contained in the Cortese List. Other state and local government agencies are required to provide additional hazardous material release information for the Cortese List.

Title 22 of the California Code of Regulations and Hazardous Waste Control Law, Chapter 6.5 The Department of Toxic Substances Control regulates the generation, transportation, treatment, storage, and disposal of hazardous waste under RCRA and the California Hazardous Waste Control Law. Both laws impose “cradle-to-grave” regulatory systems for handling hazardous waste in a manner that protects human health and the environment. CalEPA has delegated some of its authority under the Hazardous Waste Control Law to county health departments and other Certified Unified Program Agencies.

Title 23, Division 3, Chapter 16 of the California Code of Regulations, Underground Storage Tank Regulations The Title 23, Division 3, Chapter 16 regulations are intended to protect waters of the state from discharges of hazardous substances from underground storage tanks. These regulations establish construction requirements for new underground storage tanks; establish separate monitoring requirements for new and existing underground storage tanks; establish uniform requirements for unauthorized release reporting, and for repair, upgrade, and closure of underground storage tanks.

California Human Health Screening Levels
The California Human Health Screening Levels (CHHSLs or “Chisels”) are concentrations of 54 hazardous chemicals in soil or soil gas that CalEPA considers to be below thresholds of concern for risks to human health.

The CHHSLs were developed by the Office of Environmental Health Hazard Assessment on behalf of CalEPA.

The CHHSLs were developed using standard exposure assumptions and chemical toxicity values published by the EPA and CalEPA. The CHHSLs can be used to screen sites for potential human health concerns where releases of hazardous chemicals to soils have occurred. Under most circumstances, the presence of a chemical in soil, soil gas, or indoor air at concentrations below the corresponding CHHSL can be assumed to not pose Redlands Regular Meeting of 10-18-22 831 of 1815
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a significant health risk to people who may live or work at the site. There are separate CHHSLs for residential and commercial/industrial sites.

Occupational Safety: Title 8 – CalOSHA
CalOSHA administers federal occupational safety requirements and additional state requirements in accordance with California Code of Regulations Title 8. CalOSHA requires preparation of an Injury and Illness Prevention Program (IIPP), which is an employee safety program of inspections, procedures to correct unsafe conditions, employee training, and occupational safety communication. This program is administered via inspections by the local CalOSHA enforcement unit.

CalOSHA regulates lead exposure during construction activities under CCR Title 8, Section 1532.1, Lead, which establishes the rules and procedures for conducting demolition and construction activities such that worker exposure to lead contamination is minimized or avoided.

Compliance with CalOSHA regulations and associated programs would be required for the proposed Project due to the potential hazards posed by onsite construction activities and contamination from former uses.

Emergency Response to Hazardous Materials Incidents
California has developed an emergency response plan to coordinate emergency services provided by federal, state, and local government, and private agencies. The plan is administered by the California Emergency Management Agency and includes response to hazardous materials incidents. The California Emergency Management Agency coordinates the response of other agencies, including CalEPA, California Highway Patrol, California Department of Fish and Wildlife, Regional Water Quality Control Board, South Coast Air Quality Management District, County Fire Department, and the County Health Department.

Hazardous Materials in Structures: Asbestos-Containing Materials and Lead-Based Paint Several regulations and guidelines pertain to abatement of and protection from exposure to asbestoscontaining materials (ACM) and lead-based paint (LBP), including Construction Safety Orders 1529 (pertaining to ACM) and Section 1532.1 (pertaining to LBP) from Title 8 of the California Code of Regulations, and Part 61, Subpart M, of the Code of Federal Regulations (pertaining to ACM). California Health and Safety Code Section 39650 et seq. provides further regulations on airborne toxic control measures. In California, ACM and LBP abatement must be performed and monitored by contractors with appropriate certification from the California Department of Health Services. Asbestos is also regulated as a hazardous air pollutant under the Clean Air Act and a potential worker safety hazard under the authority of Cal/OSHA. Requirements for limiting asbestos emissions from building demolition and renovation are specified in SCAQMD Rule 1403 (Asbestos Emissions from Demolition/Renovation Activities). California Government Code Sections 1529 and 1532.1 provide for exposure limits, exposure monitoring, respiratory protection and good working practice by workers exposed to lead and ACMs.

5.7.2.3 Regional Regulations
Santa Ana RWQCB
The Santa Ana RWQCB issued a Municipal Stormwater (MS4) Permit for the part of the Santa Ana Basin in San Bernardino County in 2010 (Order No. R8-2010-0036). The principal permittee of the MS4 Permit is the San Bernardino County Flood Control District. Priority projects—generally, redevelopment projects that add or replace 5,000 or more square feet of impervious surfaces, and new development projects that create Redlands Regular Meeting of 10-18-22 832 of 1815
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10,000 or more square feet of impervious surfaces—must implement LID BMPs to the maximum extent practicable. The MS4 Permit requires individual priority projects to prepare and implement a water quality management plan (WQMPs) that may include source control BMPs, mitigation measures, and treatment control BMPs.

South Coast Air Quality Management District Rule 1403
SCAQMD Rule 1403 governs the demolition of buildings containing asbestos materials. Rule 1403 specifies work practices to minimize asbestos emissions during building demolition and renovation activities, including the removal and associated disturbance of asbestos containing materials. The requirements for demolition and renovation activities include asbestos surveying, notification, asbestos containing materials removal procedures and time schedules, handling and cleanup procedures, storage, and disposal requirements for asbestos containing waste materials.

5.7.2.4 Local Regulations
County of San Bernardino Emergency Plan
County Fire’s Office of Emergency Services (OES) is responsible for countywide emergency planning, mitigation, response and recovery activities, including planning for the City of Redlands. OES manages the County’s emergency operations center and develops and maintains the County’s emergency operations plan and hazard mitigation plan. The current emergency operations plan, adopted by the County Board of Supervisors in 2013, specifies roles and responsibilities of various County and other local agencies in each of the four phases of emergency management: preparedness/planning, response, recovery, and mitigation.

The San Bernardino County Multi-Jurisdictional Hazard Mitigation Plan, approved by FEMA in July 2017, includes risk assessments for many types of hazards, both natural and man-made; an assessment of community capabilities for hazard mitigation; and mitigation strategies. County-identified evacuation routes consist of major and secondary highways.

San Bernardino County implements an extensive emergency preparedness system that adheres to the National Incident Management System (NIMS), which provides a comprehensive and standardized incident management system. Because San Bernardino County is NIMS compliant, it is eligible for federal preparedness grants. The County also follows the Standardized Emergency Management System (SEMS) adopted by California, which makes it eligible for reimbursement of response-related costs under state disaster assistance programs.

San Bernardino County Multi-Jurisdictional Hazard Mitigation Plan The San Bernardino County Multi-Jurisdictional Hazard Mitigation Plan documents plans for reducing and/or eliminating risk in the unincorporated area of the County and its five Special Districts, including the San Bernardino County Fire Protection District, the San Bernardino County Flood Control District, Big Bear Valley Recreation and Parks District, Bloomington Recreation and Parks District (Districts), and those Board-governed Special Districts administered by the San Bernardino County Special Districts Department.

City of Redlands Hazard Mitigation Plan (HMP)
The City of Redlands adopted a Hazard Mitigation Plan (HMP) in 2015 in accordance with 44 CFR. The purpose of the HMP is to demonstrate the plan for reducing and/or eliminating risk in the city. The HMP assesses risks associated with flooding, earthquake, wildfire, hazardous material, and drought hazards, and identifies mitigation goals, objectives, and projects to reduce the risk.

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City of Redlands General Plan 2035
The City General Plan 2035 includes the following policies related to hazards that are relevant to the proposed Project:

Action 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.

Action 7-A.127 Use the City of Redlands Local Hazard Mitigation Plan as the guide for identifying hazard risks and vulnerabilities, identifying and prioritizing mitigation actions, encouraging the development of local mitigation, and providing technical support for these efforts.

City of Redlands Municipal Code
Chapter 2.52: Emergency Organization. The City of Redlands adopted the standardized emergency management system (SEMS). Under Chapter 2.52 of the Municipal Code, the City provides for the preparation of and carrying out of plans for the protection of persons and property within the city in the event of an emergency. The chapter provides for the direction of the emergency organization and the coordination of emergency functions of the City with all other public agencies, corporations, organizations, and affected private persons.

5.7.3 ENVIRONMENTAL SETTING
In the 2015 Redlands Hazard Mitigation Plan, the probability of future hazardous materials release within the city was determined to be High, with Medium Impact. The California Department of Toxic Substances Control (DTSC) and State Water Resources Control Board (SWRCB) track and identify sites with known or potential contamination. The DTSC Envirostor hazardous waste facility and cleanup sites database identifies sites that have known contamination or potentially contaminated sites requiring further investigation, as well as facilities permitted to treat, store, or dispose of hazardous waste. The SWRCB GeoTracker database tracks hazardous materials sites that impact groundwater or have the potential to impact groundwater.

Data for the analysis was downloaded from Envirostor and GeoTracker databases on February 22, 2022.

A total of 25 sites were identified as permitted hazardous waste facilities, land disposal sites, or USTs by DTSC, the EPA, or SWRCB. Three sites were identified by DTSC as cleanup sites having known or potential hazardous substance release; 23 were identified as such by SWRCB. Sites within the TVSP area are listed below in Table 5.7-1.

Table 5.7-1: Hazardous Materials Sites
Site Name Site Type Database Status Location
Teledyne Battery
Products

HAZ WASTE -

RCRA, LUST
Cleanup SIte
DTSC, SWRCB Closed 840 W Brockton
Ave
So Cal
Gas/Redlands I
Voluntary Cleanup DTSC Active 501-525 W.

Redlands Blvd
Edison/Redlands II Voluntary Cleanup DTSC Active 501-525 W.

Redlands Blvd
California Target
ENTP. #943
LUST Cleanup Site SWRCB Closed 1580 Redlands
Blvd
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Redlands
Corporate Yard
LUST Cleanup Site SWRCB Closed 1270 Park Ave
Argon Fuel Cleanup Program
Site
SWRCB Open 1205/1255
Redlands Blvd
Redlands Oil
Company (former)
Cleanup Program
Site
SWRCB Closed 395 Texas Street
Stop N’ Go LUST Cleanup Site SWRCB Closed 765 W Redlands Blvd
Redlands
Redevelopment
Agency
LUST Cleanup Site SWRCB Closed 325 N Eureka St
Redlands Battery LUST Cleanup Site SWRCB Closed 305 W Colton Ave City of Redlands
31 and 205 West
Stuart Ave
Property
LUST Cleanup Site SWRCB Open 31 W. Stuart Ave
GTE LUST Cleanup Site SWRCB Closed 11 4th St
9 West Colton
Avenue Property
Cleanup Program
Site
SWRCB Open 9 W. Colton Ave
Chevron #9-7222 LUST Cleanup Site SWRCB Closed 1256 Orange St Rich Oil Co., Inc LUST Cleanup Site SWRCB Closed 1029 Orange St Arco Petroleum
Products #9716
LUST Cleanup Site SWRCB Closed 902 Orange St
Thrifty Oil #346 LUST Cleanup Site SWRCB Closed 902 Orange St Tosco/76 Station
#6019
LUST Cleanup Site SWRCB Closed 901 N. Orange
Ave
Stater Bros. Site Cleanup Program
Site
SWRCB Closed 11 E. Colton Ave
Mobil #08-EV5 LUST Cleanup Site SWRCB Closed 604 Orange St Orange Plaza
Cleaners
Cleanup Program
Site
SWRCB Closed 450 Orange St
Redlands Shell LUST Cleanup Site SWRCB Closed 127 Redlands Blvd East
Conoco Phillips LUST Cleanup Site SWRCB Closed 201 Redlands Blvd East
Performance Auto LUST Cleanup Site SWRCB Closed 520 E. State St Arco #6052 LUST Cleanup Site SWRCB Closed 539 E. Redlands Blvd
Sources: DTSC, 2022; SWRCB 2022
Two active hazardous waste sites were identified through Envirostor, meaning that an investigation, remediation, and/or site monitoring is currently in progress and that DTSC is actively involved in a lead or support capacity. An additional permitted hazardous waste facility related to Teledyne Battery Products, received a closed case in 2007 and is cleared for unrestricted, residential land use. Of the 23 sites identified through Geotracker, five are Cleanup Program sites and 18 are LUST Cleanup sites. As shown on Table 5.7- 1, of the five Cleanup Program sites, two sites remain open. Of the 18 LUST Cleanup sites, one remains open.

These open designations mean that an investigation, remediation, and/or site monitoring is currently in progress and SWRCB is actively involved in a lead or support capacity.

The Site Cleanup Program regulates and oversees the investigation and cleanup of non-federally owned sites where recent or historical unauthorized releases of pollutants have occurred. These releases are Redlands Regular Meeting of 10-18-22 835 of 1815
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generally not from USTs and pollutants encountered at these sites can include solvents, pesticides, heavy metals, and fuel constituents.

Leaking underground storage tanks (LUSTs) are a significant source of petroleum impacts on groundwater.

Cleanup is conducted under the direction of the lead regulatory agency and could include product removal, vapor extraction, or soil excavation and disposal.

5.7.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:

HAZ-1 Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials;
HAZ-2 Create a significant hazard to the public or the environment through reasonably foreseeable upset or accident conditions involving the release of hazardous materials into the environment;
HAZ-3 Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances or waste within one-quarter mile of an existing or proposed school; HAZ-4 Be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment;
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? HAZ-6 Impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan; or
HAZ-7 Expose people or structures either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires.

The initial study established that the proposed Project would result in less than significant impacts related to Threshold HAZ-1 through HAZ-3 and HAZ-5 through HAZ-7; no further assessment of these impacts is required in this Draft EIR.

5.7.5 METHODOLOGY
This evaluation of the significance of potential impacts related to hazards and hazardous materials considers both direct effects to the resource and indirect effects in a local or regional context. Potentially significant impacts would generally result in the loss or degradation of public health and safety or conflict with local, state, or federal agency regulations. Information for this section was obtained, in part, from the DTSC’s EnviroStor database and the SWRCB’s GeoTracker database.

5.7.6 ENVIRONMENTAL IMPACTS
IMPACT HAZ-4: THE PROJECT WOULD NOT BE LOCATED ON A SITE WHICH IS INCLUDED ON A

LIST OF HAZARDOUS MATERIALS SITES COMPILED PURSUANT TO
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GOVERNMENT CODE SECTION 65962.5 AND, AS A RESULT, WOULD CREATE A SIGNIFICANT HAZARD TO THE PUBLIC OR THE ENVIRONMENT.

Less than Significant Impact. As discussed above in Section 5.7.3, Environmental Setting, there are numerous sites in the TVSP area that are included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 or that need further investigation (See Table 5.7-1). Several of the sites have reported releases to the ground resulting in soil and groundwater contamination and which are subject to various State and federal laws and regulators, including the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Environmental Protection Agency (EPA), DTSC, and the Regional Water Quality Control Board (RWQCB), and are in various stages of the cleanup process as stipulated by the relevant agencies. Redevelopment of sites with existing soil or groundwater contamination in accordance with the TVSP could potentially pose a significant hazard to the public or the environment through releases of hazardous materials into the environment. However, these sites are being regulated by existing federal and state policies and have been or in the process of being investigated and remediated pursuant to existing regulation. Existing regulations (such as CFR, Title 49, Chapter I; CCR, Title 8; CCR, Title 22; CFR, Title 40, Part 263 that are enforced by the USEPA, USDOT, CalEPA, CalOSHA, DTSC, and the City of Redlands) and CUPA programs would also help by ensuring the reporting and documentation of any hazardous materials incidents in the TVSP area such that property owners could be aware of potential hazards. For future projects, CEQA requires developers to reference the Cortese List and discuss if the project would be located on a listed site. Additionally, the City’s development review process would require preparation of Phase I Environmental Site Assessments (ESAs) for future projects that would identify potential hazardous materials onsite. If future redevelopment is proposed on listed sites, potential contamination at these sites, if not already remediated, would be addressed through the City’s development review requirements and in compliance with applicable state and federal regulations. Compliance with these policies, regulations, and programs would reduce the impact to less than significant.

5.7.7 CUMULATIVE IMPACTS
Cumulative land use changes within the city would have the potential to expose future area residents, employees, and visitors to chemical hazards through redevelopment of sites and structures that may be contaminated from either historic or ongoing uses. The severity of potential hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. All hazardous material users and transporters, as well as hazardous waste generators and disposers, are subject to regulations that require proper transport, handling, use, storage, and disposal of such materials to ensure public safety. Thus, if hazardous materials are found to be present on present or future project sites appropriate remediation activities would be required pursuant to standard federal, state, and regional regulations. Compliance with the relevant federal, state, and local regulations during the construction and operation of related projects would ensure that cumulative impacts from hazardous materials would be less than significant.

5.7.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
Federal
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• United States Code of Federal Regulations Title 42, Sections 6901 et seq.: Resource Conservation and Recovery Act
• United States Code of Federal Regulations Title 42, Sections 11001 et seq.: Emergency Planning & Community Right to Know Act
• United States Code of Federal Regulations Title 49, Parts 101 et seq.: Regulations implementing the Hazardous Materials Transportation Act (United States Code of Federal Regulations Title 49 Sections 5101 et seq.)
• United States Code of Federal Regulations Title 15, Sections 2601 et seq.: Toxic Substances Control Act • US Environmental Protection Agency Asbestos Hazard Emergency Response Act, 40 United States Code of Regulations Section 763
• United States Code of Federal Regulations Title 49, Chapter I • United States Code of Federal Regulations Title 29, Section 1926.62 • United States Code of Federal Regulations Title 40, Part 761 • United States Code of Federal Regulations Title 29, Section 1910.120 State
• California Occupational Safety and Health Administration Regulation 29, CFR Standard 1926.62 • California Code of Regulations Title 24, Part 2: California Building Code • California Code of Regulations Title 24, Part 9: California Fire Code • California Code of Regulations Title 8, Section 1532.1: Lead in Construction Standard • California Code of Regulations Title 23, Chapter 16: Underground Storage Tanks • California Code of Regulations Title 8, Section 1529: Asbestos • California Health and Safety Code Division 20, Chapter 6.9.1, Sections 25400.10 through 25400.47 • California Health and Safety Code Section 39650 et seq.

Regional
• South Coast Air Quality Management District Rule 1403: Asbestos Local
• Municipal Code Chapter 2.52: Emergency Organization.

Standard Conditions
None.

Plans, Programs, or Policies
None

5.7.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, Impact HAZ-4 would be less than significant.

5.7.9 MITIGATION MEASURES
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None.

5.7.10 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Existing regulatory programs described previously would reduce potential impacts associated with hazardous materials for Impact HAZ-4 to a level that is less than significant. Therefore, no significant unavoidable adverse impacts related to hazards and hazardous materials would occur.

REFERENCES
City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/post/planning-divisiongeneral-plan City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Accessed:
https://www.cityofredlands.org/sites/main/files/fileattachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Department of Toxic Substances Control. EnviroStor. Accessed:
https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=Redlands State Water Resources Control Board. GeoTracker. Accessed:
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5.8 Hydrology and Water Quality

5.8.1 INTRODUCTION
This section describes the environmental and regulatory settings and identifies potential impacts for hydrology and water quality resources. The analysis in this section is based, in part, on the following documents and resources:
• CGS Information Warehouse, California Department of Conservation, 2015 • City of Redlands General Plan 2035, City of Redlands, December 2017 • City of Redlands Drainage Master Plan, RBF Consulting, May 15, 2014 • Redlands Transit Village Water Supply Assessment, Fuscoe Engineering, Inc., January 26, 2022 (Appendix F)
• Upper Santa Ana River Watershed Integrated Regional Water Management Plan, Upper Santa Ana Water Resources Association, January 2015

5.8.2 REGULATORY SETTING

5.8.2.1 Federal Regulations
Clean Water Act
The United States Environmental Protection Agency (USEPA) is the federal agency that implements the Clean Water Act (CWA), which is responsible for water quality management. The purpose of the CWA is to protect and maintain the quality and integrity of the nation’s waters by requiring states to develop and implement state water plans and policies.

CWA Section 303, Total Maximum Daily Loads (TMDL): Section 303 of the CWA requires states to establish water quality standards consisting of designated beneficial uses of water bodies and water quality standards to protect those uses for all Waters of the United States. Under Section 303(d) of the CWA, states, territories, and authorized tribes are required to develop lists of impaired waters. Impaired waters are waters that do not meet water quality standards, even after point sources of pollution have installed the minimum required levels of pollution control technology. The law requires that these jurisdictions establish a priority ranking for listed waters and develop action plans to improve their water quality. This process includes development of Total Maximum Daily Loads (TMDL) that set discharge limits for non-point source pollutants.

A TMDL is a calculation of the maximum amount of a pollutant that a waterbody can receive and still safely meet water quality standards. The Ducheny Bill (AB 1740) requires the State Water Resources Control Board (SWRCB) and its nine Regional Water Quality Control Boards (RWQCBs) to post this list and to provide an estimated completion date for each TMDL.

CWA Section 402, National Pollutant Discharge Elimination System (NPDES) Permit: Direct discharges of pollutants into Waters of the United States are not allowed, except in accordance with the NPDES program established in Section 402 of the CWA. The main goal of the NPDES program is to protect human health and the environment. Pursuant to the NPDES program, permits that apply to storm water discharges from municipal storm drain systems, specific industrial activities, and construction activities (one acre [ac] or more) Redlands Regular Meeting of 10-18-22 840 of 1815
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have been issued. NPDES permits establish enforceable effluent limitations on discharges, require monitoring of discharges, designate reporting requirements, and require the permittee to include use of Best Management Practices (BMPs). Industrial (point source) storm water permits are required to meet effluent limitations, while municipal and construction permits are governed by the maximum extent practicable (MEP) or the Best Available Technology (BAT)/Best Control Technology (BCT) application of BMPs. SWRCBs are required to ensure that state-specific permits comply with the NPDES Permit.

5.8.2.2 State Regulations
Porter-Cologne Act
The Porter-Cologne Water Quality Control Act of 1969, codified as Division 7 of the California Water Code, authorizes the State Water Resources Control Board (SWRCB) to provide comprehensive protection for California’s waters through water allocation and water quality protection. The SWRCB implements the requirements of CWA and establishes water quality standards that have to be set for certain waters by adopting water quality control plans under the Porter-Cologne Act. The Porter-Cologne Act establishes the responsibilities and authorities of the 9 Regional Water Quality Control Boards (RWQCB), including preparing water quality plans for areas in the region, and identifying water quality objectives and waste discharge requirements (WDRs). Water quality objectives are defined as limits or levels of water quality constituents and characteristics established for reasonable protection of beneficial uses or prevention of nuisance. Beneficial uses consist of all the various ways that water can be used for the benefit of people and/or wildlife.

The Specific Plan Area is within the Santa Ana River Watershed. The Santa Ana River Basin Water Quality Control Plan was adopted in February 2016. This Basin Plan gives direction on the beneficial uses of the waters, describes the water quality that must be maintained to support such uses, and provides programs, projects, and other actions necessary to achieve the established standards.

California Anti-Degradation Policy
A key policy of California’s water quality program is the State’s Anti-Degradation Policy. This policy, formally known as the Statement of Policy with Respect to Maintaining High Quality Waters in California (SWRCB Resolution No. 68-16), restricts degradation of surface and ground waters. In particular, this policy protects water bodies where existing quality is higher than necessary for the protection of beneficial uses.

Under the Anti-Degradation Policy, any actions that can adversely affect water quality in all surface and ground waters must (1) be consistent with maximum benefit to the people of the state; (2) not unreasonably affect present and anticipated beneficial use of the water; and (3) not result in water quality less than that prescribed in water quality plans and policies (i.e., will not result in exceedances of water quality objectives).

California Construction General Permit
The State of California adopted a Statewide NPDES Permit for General Construction Activity (Construction General Permit) on September 2, 2009 (Order No. 2009-0009-DWQ, as amended by 2010-0014-DWQ and 2012-0006-DWQ). The last Construction General Permit amendment became effective on July 17, 2012. The Construction General Permit regulates construction site stormwater management. Dischargers whose projects disturb one or more acres of soil, or whose projects disturb less than one acre, but are part of a larger common plan of development that in total disturbs one or more acres, are required to obtain coverage under the general permit for discharges of stormwater associated with construction activity.

Construction activity subject to this permit includes clearing, grading, and disturbances to the ground, such as stockpiling or excavation, but does not include regular operational maintenance activities.

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To obtain coverage under this permit, project operators must electronically file Permit Registration Documents, which include a Notice of Intent, a Stormwater Pollution Prevention Plan (SWPPP), and other compliance-related documents, including a risk-level assessment for construction sites, an active stormwater effluent monitoring and reporting program during construction, rain event action plans, and numeric action levels for pH and turbidity as well as requirements for qualified professionals to prepare and implement the plan. An appropriate permit fee must also be mailed to SWRCB.

The Construction General Permit requires project applicants to file a Notice of Intent with the SWRCB to discharge stormwater, and to prepare and implement a SWPPP for projects that will disturb greater than 1 acre of soil. The SWPPP would include a site map, description of stormwater discharge activities, and best management practices (BMPs) taken from the menu of BMPs set forth in the California Stormwater Quality Association BMP Handbook that will be employed to prevent water pollution. The SWPPP is required to include BMPs that will be used to control soil erosion and discharges of other construction-related pollutants (e.g., petroleum products, solvents, paints, cement) that could contaminate nearby water resources. It must demonstrate compliance with local and regional erosion and sediment control standards, identify responsible parties, provide a detailed construction timeline, and implement a BMP monitoring and maintenance schedule. The Construction General Permit also requires the SWPPP to identify BMPs that will be implemented to reduce controlling potential chemical contaminants from impacting water quality. Types of BMPs include erosion control (e.g., preservation of vegetation), sediment control (e.g., fiber rolls), non-stormwater management (e.g., water conservation), and waste management. The SWPPP is also required to include BMPs to reduce pollutants in stormwater discharges after all construction phases have been completed at the site (post-construction BMPs).

California Water Resources Control Board Low Impact Development Policy The SWRCB adopted the Low Impact Development (LID) Policy which, at its core, promotes the idea of “sustainability” as a key parameter to be prioritized during the design and planning process for future development. The SWRCB has directed its staff to consider sustainability in all future policies, guidelines, and regulatory actions. LID is a proven approach to manage stormwater. The RWQCBs are advancing LID in California in various ways, including provisions for LID requirements in renewed Phase I municipal stormwater NPDES permits.

5.8.2.3 Regional Regulations
Santa Ana Regional Water Quality Control Board Water Quality Control Plan The City of Redlands is within the jurisdiction of the Santa Ana RWQCB. The RWQCB sets water quality standards for all ground and surface waters within its region through implementation of a Water Quality Control Plan (Basin Plan). The Basin Plan describes existing water quality conditions and establishes water quality goals and policies. The Basin Plan is also the basis for the Regional Board’s regulatory programs. To this end, the Basin Plan establishes water quality standards for all the ground and surface waters of the region. The term “water quality standards,” as used in the federal Clean Water Act, includes both the beneficial uses of specific water bodies and the levels of quality which must be met and maintained to protect those uses. The Basin Plan includes an implementation plan describing the actions that are necessary to achieve and maintain target water quality standards. The Santa Ana Basin Plan has been in place since 1995, (with updates in 2008, 2011, 2016, and 2019). The goal of the Basin Plan is to protect public health and welfare and maintain or enhance water quality and potential beneficial uses of the water.

Municipal Regional Stormwater NPDES Permit
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Within the San Bernardino County area of the Santa Ana River Basin, management and control of the municipal separate storm sewer system (MS4) is shared by a number of agencies, including the San Bernardino County Flood Control District, San Bernardino County, and the cities of Big Bear Lake, Chino, Chino Hills, Colton, Fontana, Grand Terrace, Highland, Lom a Linda, Montclair, Ontario, Rancho Cucamonga, Redlands, Rialto, San Bernardino, Upland, and Yucaipa. The San Bernardino County Public Works Department is the local enforcing agency of the MS4 NPDES Permit.

On January 29, 2010, the Santa Ana RWQCB issued an area wide MS4 permit to the County and municipalities in San Bernardino County. Waste discharge requirements for stormwater entering municipal storm drainage systems are set forth in the MS4 permit, Order No. R8-2010-0036, NPDES No. CAS618036.

This permit expired on January 29, 2015. On August 1, 2014, the San Bernardino County Flood Control District submitted a Report of Waste Discharge (ROWD) on behalf of San Bernardino County and the 16 incorporated cities within San Bernardino County. The submitted ROWD serves as the permit renewal application for the fifth term MS4 permit for San Bernardino County.

Under the County’s NPDES permit, priority projects—generally, redevelopment projects that add or replace 5,000 or more square feet of impervious surfaces, and new development projects that create 10,000 or more square feet of impervious surfaces—must implement LID BMPs to the maximum extent practicable. The MS4 Permit requires individual priority projects to prepare and implement a water quality management plan (WQMPs) that may include source control BMPs, mitigation measures, and treatment control BMPs.

5.8.2.4 Local Regulations
San Bernardino County Stormwater Program
The Technical Guidance Document for Water Quality Management Plans (WQMPs) for the Santa Ana Region of San Bernardino County is the guidance document for the Project’s stormwater design in compliance with Santa Ana RWQCB requirements for Priority Projects or Transportation Projects. The MS4 Permit requires that a preliminary project-specific WQMP be prepared for review early in the project development process and that a Final WQMP be submitted prior to the start of construction. A project specific WQMP is required to address the following:
• Develop site design measures using Low Impact Development (LID) principles • Evaluate feasibility of on-site LID Best Management Practices (BMPs) • Maximum hydrologic source control, infiltration, and biotreatment BMPs • Select applicable source control BMPs
• Address post-construction BMP maintenance requirements City of Redlands General Plan
The following goals and policies from the City of Redlands General Plan 2035, adopted December 2017, are relevant to the proposed Project:

Policy 6-P.19 Promote the protection of waterways in Redlands from pollution and degradation as a result of urban activities.

Policy 6-P.20 Pursue creative, innovative, and environmentally sound methods to capture and use stormwater and urban runoff for beneficial purposes.

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Policy 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.

Policy 6-A.36 Require measures during construction and post construction to limit land disturbance activities such as clearing and grading and cut-and-fill; avoid steep slopes, unstable areas, and erosive soils; and minimize disturbance of natural vegetation and other physical or biological features important to preventing erosion or sedimentation Policy 6-A.38 Encourage development that reflects an integrated approach to building design, civil engineering, and landscape architecture that maximizes rainwater harvesting and stormwater retention for landscape irrigation.

Policy 6-A.39 Require that new development provides landscaping and re-vegetation of graded or disturbed areas with drought-tolerant native or non-invasive plants.

Policy 6-A.40 Maximize the amount of pervious surfaces in public spaces to permit the percolation of urban runoff.

Policy 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.

City of Redlands Water Efficient Landscape Requirements Chapter 15.54 of the Redlands Municipal Code establishes the City’s Water Efficient Landscape Requirements to promote the benefits provided by landscapes while recognizing the need to use water as efficiently as possible. The chapter requires applicable landscaping projects to submit a landscape documentation package that contains project information, hydrozone information table, water budget calculations, soil management report, and landscape, irrigation, and grading design plans. The chapter establishes requirements for irrigation scheduling, maintenance, and audits to ensure efficient use of water.

The requirements also include provisions for non-potable water irrigation systems and encourage stormwater best management practices to increase on-site retention and infiltration.

City of Redlands Municipal Code Requirements
The City’s Municipal Code, Section 13.54, Storm Drains, provides regulation of discharges into the Redlands storm drain system. This is achieved by elimination of all nonpermitted discharges to Redlands separate storm sewers; control discharges to the Redlands separate storm sewers through prohibition of spills, dumping, or disposal of materials other than stormwater; and reduction of pollutants in stormwater discharges to the maximum extent practicable. City dischargers are required to comply with the applicable NPDES permit and follow the City’s standard BMP practices.

Additionally, the City’s Pretreatment and Regulation of Wastes Ordinance, codified under Section 13.52 of the City Municipal Code, further protects water quality in the City through uniform requirements for all users of the City’s publicly owned treatment works. The ordinance enables the City to comply with all applicable state and federal laws, including the Clean Water Act (33 USC section 1251 et seq.) and the General Pretreatment Regulations (40 CFR part 403).

5.8.3 ENVIRONMENTAL SETTING
Watershed
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The proposed Transit Villages Specific Plan (TVSP, or Specific Plan) area covers approximately 947 acres (approximately 1.5 square miles) and is generally bounded to the west by Kansas Street, Redlands Boulevard, Alabama Street, and Tennessee Street; to the north by the I-10, Colton Avenue, and Sylvan Boulevard; to the east by Judson Street; and to the south by Citrus Avenue, Central Avenue, Redlands Boulevard, Olive Avenue, Brookside Avenue, Ash Street, Pine Avenue, Tennessee Street, and State Street.

The Specific Plan Area is located within the Santa Ana River Watershed. The watershed is located south and east of Los Angeles and includes much of Orange County, the northwestern corner of Riverside County, the southwestern corner of San Bernardino County, and a small portion of Los Angeles County. The watershed is bounded on the south by the Santa Margarita watershed, on the east by the Salton Sea and Southern Mojave watersheds, and on the north and west by the Mojave and San Gabriel watersheds. Disputes over use of water led to the subdivision of the watershed into the Upper and Lower Santa Ana River Watersheds.

The Specific Plan Area is in the Upper Santa Ana River Watershed.

The Upper Santa Ana River Watershed consists of many tributaries flowing to the Santa Ana River. These tributaries range from natural streams to concrete-lined channels. Many of the streams flow through heavily developed areas. The San Bernardino County Flood Control District (SBCFCD) operates and maintains many of the tributary systems that are deemed “regional” (750 cubic feet per second (cfs) or greater flow and/or 640 acres or greater of watershed as well as portions of the Santa Ana River). Smaller-scale control facilities are generally operated by local jurisdictions. This watershed is in an arid region and therefore has little natural perennial surface water. Surface waters start in the upper erosion zone of the watershed, primarily in the San Bernardino and San Gabriel mountains. This upper zone has the highest gradient and soils and geology that do not allow large quantities of percolation of surface water into the ground. A variety of downstream water storage reservoirs (Lake Perris, Lake Mathews, and Big Bear Lake) and flood control areas (Prado Dam area and Seven Oaks Dam area) have been created to hold surface water.

The Santa Ana River watershed is regulated by the Santa Ana RWQCB. The Santa Ana RWQCB manages a large watershed area, which includes most of San Bernardino County to the east and then southwest through northern Orange County to the Pacific Ocean. The Santa Ana RWQCB’s jurisdiction encompasses 2,800 square miles.

Groundwater Basin
The Specific Plan Area is located in the Bunker Hill Subbasin of the Upper Santa Ana Groundwater Basin.

The Bunker Hill Basin encompasses approximately 120 square miles of the Upper Santa Ana River watershed. It lies within San Bernardino County. The Bunker Hill Basin has approximately 5,976,000-acre feet of storage capacity and as of 1998, the total amount of water in storage in the Bunker Hill Subbasin was 5,890,300 acre feet. The Bunker Hill Subbasin contains several contamination plumes. The Redlands plume, located between Judson Street and Mountain Avenue in Redlands, is primarily composed of trichloroethylene (TCE), with lower levels of (tetrachloroethylene) PCE and dibromochloropropane (DBCP), and contaminates approximately 150,000 acre-ft of groundwater. The basin was adjudicated by the Western Judgment in 1969.

Water Quality
Water Quality Impairments: Section 303(d) of the federal CWA requires states to identify water bodies that are “impaired,” or those that do not meet water quality standards and are not supporting their beneficial uses. Total Maximum Daily Loads (TMDLs) are then designed to serve as pollution control plans for these specific pollutants.

The Santa Ana River Watershed drains to the Santa Ana River, extends approximately 100 miles beginning at the crest of the San Bernardino Mountains and ending at the coast near Huntington Beach. Tributaries of Redlands Regular Meeting of 10-18-22 845 of 1815
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the Santa Ana River within the Upper Santa Ana River Watershed include Mill Creek, City Creek, Plunge Creek (a tributary of City Creek), Mission Zanja Creek (located upstream of San Timoteo Creek), San Timoteo Creek, East Twin Creek, Warm Creek, and Lytle Creek. The following tributaries have been placed on the 303(d) list for the identified impairments.

Table 5.8-1: 303(d) Water Quality Impairments
Water Body Impairments
Big Bear Lake Mercury, Noxious Aquatic Plants, Nutrients, PCBs Grout Creek Nutrients
Knickerbocker Creek Pathogens
Lytle Creek Pathogens
Mill Creek, Reach 1 Pathogens
Mill Creek, Reach 2 Pathogens
Mountain Home Creek Pathogens
Mountain Home Creek, East Fork Pathogens
Rathbone (Rathbun) Creek Cadmium, Copper, Nutrients, Sediment/ Siltation Santa Ana River, Reach 6 Cadmium, Copper, Lead
Santa Ana River, Reach 4 Pathogens
Santa Ana River, Reach 3 Copper (wet weather only), Lead, Pathogens Summit Creek Nutrients
Source: Upper Santa Ana River Watershed Integrated Regional Water Management Plan, 2020.

Two TMDLs have been adopted to address the above impairments in the Upper SAR: TMDLs for Bacterial Indicators in the Middle Santa Ana River Watershed (February 3, 2005), which addresses pathogens in the Santa Ana River, Reach 3, and Nutrient TMDL for Dry Hydrological Conditions for Big Bear Lake (April 21, 2006), which addresses nutrients in Big Bear Lake.

The City of Redlands has adopted the EPA’s National Pollutant Discharge Elimination System (NPDES) regulations, which aims to reduce pollutants in urban runoff and stormwater flows. The Santa Ana RWQCB issued the County a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R8-2010-0036), which establishes pollution prevention requirements for planned developments. The County participates in an Area-wide Urban Stormwater Runoff Management Program to comply with the MS4 Permit requirements.

Runoff from the development upland site is managed and regulated under the NDPES MS4 Permit and associated Storm Water Management Program.

Groundwater Supply
The Redlands Planning Area domestic water sources consist of both surface (about 50 percent of total supply) and groundwater (about 50 percent of total supply). The City of Redlands uses 15 wells that pump directly into the system or into reservoirs. Because of contamination, the City has wells that are not used for domestic purposes and are instead used for irrigation. It is anticipated that the contaminant levels will not decrease for many years due to the slow movement of water through the basin. Groundwater from the Bunker Hill Subbasin provides approximately half of Redland’s water supply (13,601 acre-feet [AF] in 2020). A small portion (1,531 AF in 2020) of groundwater is also pumped from the Yucaipa Subbasin. The remaining supply comes from the Santa Ana River, Mill Creek, and the State Water Project (SWP). The basin was adjudicated by the Western Judgment in 1969 to regulate the amount of groundwater that can be pumped from the basin. Western Judgment allocated the Non-Plaintiffs’ (agencies within San Bernardino County including Redlands Regular Meeting of 10-18-22 846 of 1815
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Redlands) rights 167,238 acre-feet per year (AFY), which equates to 72.05 percent of the safe yield. San Bernardino agencies are allowed to extract more than 167,238 AFY from the SBB, as long as they import and recharge a like amount of supplemental water into the basin. The Western-San Bernardino Watermaster provides an annual accounting of both the plaintiff and non-plaintiff extractions and a comparison to the safe yield. The Judgment requires the non-plaintiffs to provide replenishment water whenever the cumulative extractions exceed the cumulative safe yield.

Storm Drainage Facilities
The TVSP area is approximately 947 acres of land that is divided into three planning areas referred to as transit villages, which generally circle each new Arrow station, as shown on Figure 3-4. As shown in Figure 3-3, the Specific Plan Area is developed and urbanized. The existing topography of the Specific Plan Area is relatively flat and, according to the City of Redlands Drainage Master Plan, the area generally drains from the east to the west via the existing storm drain system.

Soil Infiltration
Recharge to the Bunker Hill Subbasin historically has resulted from infiltration of runoff from the San Gabriel and San Bernardino Mountains. The Santa Ana River, Mill Creek, and Lytle Creek contribute more than 60 percent of the total recharge to the groundwater system. The subbasin is also replenished by deep percolation of water from precipitation and resulting runoff, percolation from delivered water, and water spread in streambeds and spreading grounds. The Specific Plan Area is approximately 1.5 miles south of the Santa Ana River and site soils primarily consist of Ramona Sandy Loam, Tujunga Loamy Sand, and Hanford Coarse Sandy Loam. These soils are generally well draining and support stormwater infiltration.

Flood Zone, Tsunami, Seiche
The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps (FIRM) for the Specific Plan Area (06071C8716H and 06071C8712H) shows that the southern portion of the Specific Plan Area is located within “Zone X,” which is an area of minimal flood hazard potential outside of the 0.2 percent annual chance flood. The northern portion of the Specific Plan Area is within “Zone AO”, an area of 1 percent annual flood with flood depth of 1 to 3 feet (usually areas of ponding) where Base Flood Elevations have been determined.

A tsunami is a series of ocean waves caused by a sudden displacement of the ocean floor, most often due to earthquakes. The Specific Plan Area is over 50 miles from the Pacific Ocean, and outside of the Tsunami Hazard Zone identified by the California Department of Conservation Tsunami Hazard Area Map.

A seiche is a surface wave created when a body of water is shaken, usually by earthquake activity. Seiches are of concern relative to water storage facilities because inundation from a seiche can occur if the wave overflows a containment wall, such as the wall of a reservoir, water storage tank, dam, or other artificial body of water. There are no water bodies in the vicinity of the Specific Plan Area, and no existing risks related to seiche flood hazards exist on or near the site.

5.8.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:

WQ-1 Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality;
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WQ-2 Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin;
WQ-3 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:

WQ-3 i) result in substantial erosion or siltation on- or off-site; WQ-3 ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
WQ-3 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
WQ-3 iv) impede or redirect flood flows;
WQ-4 In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation; or
WQ-5 Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

The Initial Study established that the proposed Project would result in less than significant impacts related to Threshold WQ-1 and WQ-5; and no further assessment of these impacts is required in this Draft EIR.

5.8.5 METHODOLOGY
This evaluation of the significance of potential impacts related to hydrology and water quality is based on a review of published information and reports regarding regional hydrology, groundwater conditions, and surface water quality. The potential impacts on hydrology and water quality were evaluated by considering the general type of pollutants that operation of the Project would generate during construction and operation. In determining the level of significance, the analysis recognizes that development under the proposed Project would be required to comply with relevant federal, state, and regional laws and regulations that are designed to ensure compliance with applicable water quality standards and waste discharge requirements. Because the regional and local regulations related to water quality standards have been developed to reduce the potential of pollutants in the water resources (as described in the Regulatory Setting Section above), and are implemented to specific waterbodies, such as 303(d) TMDL requirements, or development projects such as grading and construction permit regulations, implementation of all relevant water quality and hydrology requirements would limit the potential of the proposed Project to a less than significant impact.

5.8.6 ENVIRONMENTAL IMPACTS
IMPACT WQ-2: THE PROJECT WOULD NOT 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. A Water Supply Assessment (WSA) was prepared for the Project in order to coordinate local water supply and land use decisions per Senate Bill 610 (SB 610). Future land uses within Redlands Regular Meeting of 10-18-22 848 of 1815
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the TVSP will utilize water from the local groundwater from the San Bernardino Basin (SBB) (also known as Bunker Hill Basin) and surface water supplies from Mill Creek and the Santa Ana River. Supplemental water is purchased from the State Water Project for direct deliveries only when the local sources cannot provide it or is needed for water quality.

Under the TVSP, it is estimated that buildout of the Specific Plan area would include the development of an additional 2,400 dwelling units, 265,000 square feet of retail commercial, 238,000 square feet of office, 220 hotel rooms, and 280,000 square feet of open space and park area. In 2020, approximately 13,916 AF of groundwater was pumped from the Bunker Hill and Yucaipa basins. The change in land use proposed under the TVSP would result in a net increase of approximately 570,746 gallons per day, or 639 AFY, with a total demand of 1,996 AFY. In 2020, the volume of water pumped from the Bunker Hill Subbasin of the San Bernardino Basin (SBB) and Yucaipa Subbasin was 13,916 AFY. Table 5.8-2 below shows projected groundwater supply sources for the City of Redlands.

Table 5.8-2. Projected Groundwater Supplies (AFY)
Water Supply
Additional
Detail on
Water
Supply
Projected Water Supply
2025 2030 2035 2040 2045
Reasonably
Available
Volume
Reasonably
Available
Volume
Reasonably
Available
Volume
Reasonably
Available
Volume
Reasonably
Available
Volume
Groundwater
(not
desalinated)
Bunker Hill
(part of
SBB)
12,973 13,922 14,861 15,677 16,484
Groundwater
(not
desalinated)
Bunker Hill
(part of
SBB)
3,766 4,015 4,275 4,513 4,760
Groundwater
(not
desalinated)
Yucaipa 1,000 1,000 1,000 1,000 1,000
Total 17,739 18,937 20,136 21,190 22,244
Source: WSA, (Appendix F)
Even with the additional demand of 639 AFY from the proposed TVSP land uses (639 AFY in addition to existing 13,916 AFY is approximately 14,555 AFY), the City will have surplus groundwater supplies available over the next 25 years. The WSA, included as Appendix F, includes an analysis of reliability of the City’s water supplies and concludes with a sufficiency analysis of water supply during normal, single-dry, and multiple dry years. The WSA identifies programs and activities that the City is managing to enforce lowering water demand and assist with sustainable water supply for the future. The City, inclusive of the proposed TVSP Project, will have an adequate supply of water now and 25 years into the future. The Western Judgment would continue to monitor and ensure the basins, as adjudicated, are pumped and replenished in accordance with imposed allocations and rights.

Additionally, the proposed Specific Plan would allow for additional development and redevelopment within the city that would increase the area of impervious surfaces. However, projects proposed within the Specific Plan area would be required to comply with City policies, such as Policy 6-A.40 and Policy 6-A.43, that Redlands Regular Meeting of 10-18-22 849 of 1815
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require post-development stormwater runoff of projects to not exceed pre-development rates and to maximize the amount of pervious surfaces for the percolation of urban runoff. Depending on the type or size of the project, each project would be required to provide a WQMP, or if no WQMP is required, comply with other requirements which would include measures to collect and infiltrate stormwater in compliance with the requirements of the NPDES stormwater permit (NPDES Permit No. CAS618036 and RWCB Order R8- 2010-0036 for San Bernardino County) and support the recharge of the underlying groundwater basins.

Therefore, the Project would not substantially interfere with groundwater recharge, and impacts would be less than significant.

IMPACT WQ-3i: THE PROJECT WOULD NOT SUBSTANTIALLY ALTER THE EXISTING DRAINAGE

PATTERN OF THE AREA, INCLUDING THROUGH THE ALTERATION OF THE

COURSE OF A STREAM OR RIVER, IN A MANNER WHICH WOULD RESULT IN SUBSTANTIAL EROSION OR SILTATION ON- OR OFF-SITE.

Less than Significant Impact. The proposed TVSP includes amending the GP2035 to establish a new land use designation to provide for infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations. The Transit Villages Overlay Zone (TVOZ) boundaries of the New York Street, Downtown, and University stations would be adjusted as part of this Specific Plan process, and the adopted TVSP boundary would be the TVOZ boundary. A form-based code that would be implemented by the proposed TVSP, which emphasizes building form, a mix and density of different transit-oriented development, pedestrian circulation, and public realm improvements and amenities.

The Specific Plan Area is transected by the Mill Creek Zanja (The Zanja) and bordered by the Morey Wash (Morey Arroyo). The Mill Creek Zanja was built in 1819 to convey water from Mentone to the Assistencia de Mission San Gabriel. Today, it carries drainage water and stormwater runoff. It runs through University Street and New York Street. The Morey Arroyo is also an artificial ditch that conveys drainage water and stormwater runoff. As previously identified, the Project site is located within a floodplain. The main cause of the flooding is a lack of conveyance capacities in the Zanja Channel, the Redlands Boulevard storm drain, and the Oriental storm drain.

Construction
Construction of the proposed Project could result in demolition of the existing structures and vegetation removal, that would expose and loosen building materials and sediment, which has the potential to mix with storm water runoff and result in erosion or siltation off-site. However, the Specific Plan Area does not include any steep slopes, which reduces the erosion potential. Additionally, a large majority of soil disturbance would be related to excavation and backfill for installation of building foundations and underground utilities.

The existing NPDES Construction General Permit requires preparation and implementation of a SWPPP by a QSD for the proposed construction activities (included as PPP HYD-1). The SWPPP is required to address site-specific conditions related to potential sources of sedimentation and erosion and would list the required BMPs that are necessary to reduce or eliminate the potential of erosion or alteration of a drainage pattern during construction activities. Common types of construction BMPs include:
• Silt fencing, fiber rolls, or gravel bags
• Street sweeping and vacuuming
• Storm drain inlet protection
• Stabilized construction entrance/exit
• Vehicle and equipment maintenance, cleaning, and fueling • Hydroseeding
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• Material delivery and storage
• Stockpile management
• Spill prevention and control
• Solid waste management
• Concrete waste management

In addition, all grading plans within the City of Redlands require an accompanying set of “stand alone” Erosion Control Plans to minimize water and windborne erosion. Mandatory compliance with the SWPPP and the erosion control plan would ensure that the Project’s implementation does not violate any water quality standards or waste discharge requirements during construction activities implemented as part of the TVSP.

As part of the permitting approval process, construction plans would be required to demonstrate compliance with these regulations to minimize the potential of the Project to result in a degradation of the quality of receiving waters. Plans for grading, drainage, erosion control and water quality would be reviewed by the City’s Public Works Department prior to issuance of grading permits to ensure that the applicable and required BMPs are constructed during implementation of the Project.

Therefore, compliance with the City of Redlands Municipal Code Chapter 13.54, Storm Drains, MS4 Permit, and other applicable requirements, which would be verified during the City’s construction permitting process, would ensure that impacts of future development implemented as part of the TVSP impacts related to construction activities resulting in a degradation of water quality would be less than significant.

Operation
The TVSP provides a land use plan and form-based code for the TVSP area that is anticipated to be developed by the year 2040. The form-based code provided by the TVSP would emphasize regulating the form of the built environment and public realm amenities, as compared to conventional zoning that primarily focuses on the land uses. However, under the TVSP, it is estimated that buildout of the Project Area would include the development of an additional 2,400 dwelling units, 265,000 square feet of retail commercial, 238,000 square feet of office, 220 hotel rooms, and 280,000 square feet of open space and park area.

After completion of Project construction, the site would have a greater amount of impermeable surfaces. The increase in impervious surfaces could result in a potential increase in stormwater volume and peak runoff rates.

The TVSP area has historically experienced flooding during moderate storm events. Portions of the Project area, particularly the majority of the parcels within a quarter mile of the three stations, are located within the flood zone. Per the 2014 Master Plan of Drainage, the causes of the flooding in this area include both local and regional storm drain deficiencies. The main cause of flooding is lack of conveyance capacities in the Mission Zanja, the Redland Boulevard storm drain, and the Oriental storm drain. With a capacity of approximately 2,400 cubic feet per second (cfs), the Redlands Boulevard storm drain receives over 4,200 cfs from the Zanja and the Carrot storm drain, and 4,000 cfs from Reservoir Canyon and the Oriental storm drain. All four of these tributaries experience a confluence near the intersection of Redlands Boulevard and Ninth Street. Over the past three decades, the focus of several studies has been to reduce the flood potential from the Zanja and Reservoir Canyon storm drain. Several alternatives have been investigated and proposed as part of developing the draft TVSP, ranging from multiple detention basins to a downtown underground “bypass” pipeline that would direct Zanja flows around the Redlands Boulevard storm drain.

While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area including:

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• Preparing and processing a Letter of Map Revision based on hydrologic modeling, included as Appendix A to the TVSP, in order to remove approximately 155 properties from being subject to the City’s Floodplain Regulations;
• Implement the 2014 Master Plan of Drainage Alternative 1 for the Downtown Village; • Explore opportunities to implement a diversion drainage system that intercepts Zanja channel flows near or east of North Grove Street, where it would be conveyed parallel to the Zanja and be discharged into the Zanja upstream of the I-10 underpass; and • Increase the size of the Zanja at the Kansas Street, New York Street, and Tennessee Street crossings to increase flow capacity.

Projects built pursuant to the Specific Plan would be required to comply with requirements included under Chapter 3.56 of the City’s Municipal Code, Storm Drain Facilities Fees. Section 3.56.030 of the City’s Municipal Code states that:
“No development permit shall be approved for new development unless the city finds that the storm drain facilities proposed within the development satisfy the requirements of the city's master storm drain plan. To ensure consistency with the plan, the city may impose conditions to approval of the development which are necessary to implement the plan. The requirements of this chapter are imposed as a condition of development to ensure implementation of and consistency with the city's general plan and to protect the public health, safety and welfare by ensuring that adequate public facilities and improvements will be installed and available to serve new development prior to, or concurrently with, the need.”
Additionally, development applicants are required to pay development storm drain impact fees per Section

3.56.040, Storm Drain Fees, established for the purpose of constructing the storm facilities provided in the City's Master Storm Drain Plan.

Development proposed through the Specific Plan would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash. The Project could implement development that could result in substantial changes to existing drainage patterns within the Project area, through direct modification of existing storm drains or indirectly through the anticipated development of 2,400 dwelling units, 265,000 square feet of retail commercial, 238,000 square feet of office, 220 hotel rooms, and 280,000 square feet of open space and park area. However, drainage proposed as part of future development projects would comply with the City’s Master Storm Drain Plan, which would facilitate improvements to the City’s storm drain system.

Additionally, the MS4 permit requires any new development project to prepare a WQMP (included as PPP HYD-2) that includes post-construction BMPs to reduce the potential of erosion and/or sedimentation through site design and structural treatment control BMPs. As part of the permitting approval process for each project, proposed drainage and water quality design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the site-specific design limits the potential for erosion and siltation.

Overall, the proposed drainage system and adherence to the existing regulations would ensure that Project impacts related to alteration of a drainage pattern and erosion/siltation from operational activities would be less than significant.

IMPACT WQ-3ii: THE PROJECT WOULD NOT 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 Redlands Regular Meeting of 10-18-22 852 of 1815
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INCREASE THE RATE OR AMOUNT OF SURFACE RUNOFF IN A MANNER WHICH WOULD RESULT IN FLOODING ON- OR OFF-SITE.

Less than Significant Impact. As described previously, the Specific Plan Area would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash.

Construction
Construction of the proposed Project could require demolition of the existing building structures, including foundations, floor slabs, and utilities systems. These activities could temporarily alter the existing drainage pattern of the site and could result in flooding on- or off-site if drainage is not properly controlled. However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site specific drainage issues related to construction and include BMPs to eliminate the potential of flooding or alteration of a drainage pattern during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to potential alteration of a drainage pattern or flooding on or off-site from development activities. Therefore, impacts would be less than significant.

Operation
As discussed previously, the Project area contains areas of flood risk. Per the Redlands Floodplain Regulations, in a FEMA Flood zone any new “occupiable” finished floor must be at least two feet above the one percent (100-year) base flood elevation. Any floodplain cross-section modifications (earthen platforms) may not cause more than one-foot water surface elevation increase upstream. These floodplain conditions create significant challenges to existing and new development, especially in commercial zones where zerostep entries are required.

The buildout of the Project is anticipated to increase impervious surfaces, which would result in an increase of stormwater runoff volume and peak flow rates. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Improvements would be implemented by the City as regional drainage improvements.

However, projects proposed in implementation of the Specific Plan would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, the proposed drainage system and adherence to the existing NPDES permit regulations would ensure that Project impacts related to alteration of a drainage pattern or flooding from operational activities would be less than significant.

IMPACT WQ-3iii: THE PROJECT WOULD NOT 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 Redlands Regular Meeting of 10-18-22 853 of 1815
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EXISTING OR PLANNED STORMWATER DRAINAGE SYSTEMS OR PROVIDE SUBSTANTIAL ADDITIONAL SOURCES OF POLLUTED RUNOFF.

Less than Significant Impact. As described previously, the Specific Plan Area would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash.

Construction
As described in the previous response, construction of the proposed Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff and polluted runoff if drainage is not properly controlled. However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to increases in runoff and pollution from development activities. Therefore, impacts would be less than significant.

Operation
The existing topography of the Specific Plan area is relatively flat and generally drains from the east to the west. The Project area drains to an existing storm drain network that is discharged to five drainage areas within the City, including Mission Zanja, Reservoir Canyon, Downtown, North City, and South City. The TVSP area has historically experienced flooding during moderate storm events. Development of the Project could increase impervious surface area within the TVSP area, which could result in additional stormwater runoff that could further exceed the existing drainage system and contribute to additional sources of stormwater pollutants. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Additionally, the City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues through incorporation of new stormwater infrastructure and BMPs, such as construction of a large culvert adjacent to Redlands Boulevard and implementation of a bypass structure for the Zanja drainage system. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans.

Additionally, projects would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Proposed project design would be reviewed for consistency during design check by the City.

Additionally, the MS4 permit requires any new development project to prepare a WQMP (included as PPP HYD-2), or if a WQMP is not required, comply with other measures that includes post-construction BMPs to reduce the potential of stormwater runoff pollution through site design and structural treatment control BMPs.

As part of the permitting approval process for each project, proposed drainage and water quality design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the site-specific design would adequately treat and capture onsite stormwater runoff. Overall, with compliance to the Redlands Regular Meeting of 10-18-22 854 of 1815
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existing regulations as verified by the City’s permitting process, Project impacts related to the capacity of the drainage system and polluted runoff would be less than significant.

IMPACT WQ-3iv: THE PROJECT WOULD NOT 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 IMPEDE OR REDIRECT FLOOD FLOWS.

Less than Significant Impact.

Construction
As described in the previous response, construction of the proposed Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff. However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of increased runoff during construction activities.

This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD1) as verified by the City through the construction permitting process would prevent construction-related impacts related to increases in runoff from development activities. Therefore, impacts would be less than significant.

Operation
As discussed previously, the Project area contains areas of flood risk. Per the Redlands Floodplain Regulations, in a FEMA Flood zone any new “occupiable” finished floor must be at least two feet above the one percent (100-year) base flood elevation. Any floodplain cross-section modifications (earthen platforms) may not cause more than one-foot water surface elevation increase upstream. These floodplain conditions create significant challenges to existing and new development, especially in commercial zones where zerostep entries are required.

The buildout of the Project is anticipated to increase impervious surfaces, which would result in an increase of stormwater runoff volume and peak flow rates. The City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues through incorporation of new stormwater infrastructure and BMPs, such as construction of a large culvert adjacent to Redlands Boulevard and implementation of a bypass structure for the Zanja drainage system. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Improvements would be implemented by the City as regional drainage improvements. However, projects proposed in implementation of the Specific Plan would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to address the City’s flooding issues. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, the proposed drainage system and adherence to the existing NPDES permit regulations would ensure that Project impacts related to alteration of a drainage pattern or flooding from operational activities would be less than significant.

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IMPACT WQ-4: THE PROJECT WOULD NOT RISK RELEASE OF POLLUTANTS DUE TO PROJECT INUNDATION WITHIN A FLOOD HAZARD ZONE.

Less than Significant Impact. As described previously, the Specific Plan Area would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash.

Construction
As described in the previous response, construction of the proposed Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased polluted runoff. However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to increases in runoff and pollution from development activities. Therefore, impacts would be less than significant.

Operation
The project would facilitate the development of new residential uses within the TVSP area. Development of the Project could increase impervious surface areas and introduce additional residential uses within the TVSP area, which could result in additional sources of stormwater pollutants. The TVSP has historically experienced flooding and parts of the TVSP area are within a designated floodplain. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Additionally, the City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues through incorporation of new stormwater infrastructure and BMPs, such as construction of a large culvert adjacent to Redlands Boulevard and implementation of a bypass structure for the Zanja drainage system. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans. Additionally, projects would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Proposed project design would be reviewed for consistency during design check by the City.

Additionally, the MS4 permit requires any new development project to prepare a WQMP (included as PPP HYD-2) that includes post-construction BMPs to reduce the potential of stormwater runoff pollution through site design and structural treatment control BMPs. As part of the permitting approval process for each project, proposed drainage and water quality design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the site-specific design would adequately treat and capture onsite stormwater runoff. Overall, with compliance to the existing regulations as verified by the City’s permitting process, Project impacts related to the c release of pollutants due to project inundation would be less than significant.

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5.8.7 CUMULATIVE IMPACTS
Water Quality: The geographic scope for cumulative impacts related to hydrology and water quality includes the Santa Ana Watershed because cumulative projects and developments pursuant to the proposed Project could incrementally exacerbate the existing impaired condition and could result in new pollutant related impairments.

Related developments within the watershed would be required to implement water quality control measures pursuant to the same NPDES General Construction Permit that requires implementation of a SWPPP (for construction), a WQMP (for operation) and BMPs to eliminate or reduce the discharge of pollutants in stormwater discharges, reduce runoff, reduce erosion and sedimentation, and increase filtration and infiltration, in areas permitted. The NPDES permit requirements have been set by the SWRCB and implemented by the RWQCB to reduce incremental effects of individual projects so that they would not become cumulatively considerable. Therefore, overall potential impacts to water quality associated with present and future development in the watershed would not be cumulatively considerable with compliance with all applicable laws, permits, ordinances and plans. As detailed previously, the proposed Project would be implemented in compliance with all regulations, as would be verified during the permitting process.

Therefore, cumulative impacts related to water quality would be less than significant.

Drainage: The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area served by the existing stormwater infrastructure for the City’s Master Drainage Plan area, from capture of runoff through final discharge points. As described above, TVSP does not include specific drainage system improvements; however, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Additionally, the City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans. Additionally, projects would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As a result, the proposed Project would not generate runoff that could combine with additional runoff from cumulative Projects that could cumulatively combine to impact drainage. Thus, cumulative impacts related to drainage would be less than significant.

Groundwater Basin: The geographic scope for cumulative impacts related to the groundwater basin is the Bunker Hill Subbasin of the Upper Santa Ana Groundwater Basin. As described previously, the volume of water that would be needed by the Project is within the anticipated groundwater pumping volumes.

Therefore, the Project would not result in changes to the projected groundwater pumping that would decrease groundwater supplies. As a result, the proposed Project would not generate impacts related to the groundwater basin that have the potential to combine with effects from other projects to become cumulatively considerable. Therefore, cumulative impacts related to the groundwater basin would be less than significant.

5.8.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• Construction General Permit, Order No. 2009-0009-DWQ, as amended by 2010-0014-DWQ and 2012-0006-DWQ
• California Water Resources Control Board Low Impact Development (LID) Policy Redlands Regular Meeting of 10-18-22 857 of 1815
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• Regional MS4 Permit (Order No. R8-2010-0036)
• City Municipal Code, Section 13.52, Pretreatment and Regulation of Wastes Ordinance • City Municipal Code, Section 13.54, Storm Drains
• City Municipal Code Chapter 3.56, Storm Drain Facilities Fees Standard Conditions
None.

Plans, Programs, or Policies
PPP HYD-1 National Pollutant Discharge Elimination System (NPDES). Projects will be constructed in accordance with the NPDES General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities, NPDES No. CAS000002. Compliance requires a risk assessment, a SWPPP, and associated BMPs.

PPP HYD-2 Santa Ana RWQCB MS4 Permit. Projects will be constructed and operated in accordance with the Santa Ana RWQCB Municipal Stormwater (MS4) Permit for the part of the Santa Ana Basin in San Bernardino County in 2010 (Order No. R8-2010-0036). The MS4 Permit requires new development and redevelopment projects to adopt a WQMP to:
• Control contaminants into storm drain systems
• Educate the public about stormwater impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement BMPs and site-specific runoff controls and treatments

5.8.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements Impacts WQ-1 through WQ-7 would be less than significant.

5.8.10 MITIGATION MEASURES
No mitigation measures are required.

5.8.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to hydrology and water quality have been identified and impacts would be less than significant.

REFERENCES
Basin Technical Advisory Committee. Upper Santa Ana River Watershed Integrated Regional Water Management Plan. January 2015. Accessed: https://www.sbvwcd.org/docman-projects/upper-santa-anaintegrated-regional-water-management-plan/3802-usarw-irwmp-2015-ch1-9-final/file California Department of Water Resources. California’s Groundwater (Bulletin 118), Upper Santa Ana Valley Groundwater Basin, Bunker Hill Subbasin. February 27, 2004. Accessed: https://water.ca.gov/- /media/DWR-Website/Web-Pages/Programs/Groundwater-Management/Bulletin-118/Files/2003- Basin-Descriptions/8_002_06_BunkerHillSubbasin.pdf
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City of Redlands. City of Redlands Drainage Master Plan. May 15, 2014. Accessed:
https://www.cityofredlands.org/sites/main/files/fileattachments/drainage_master_plan_2014.pdf?1584549796 City of Redlands. City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. July 21, 2017. Accessed: https://www.cityofredlands.org/sites/main/files/fileattachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 FEMA Flood Map Service Center. Accessed: https://msc.fema.gov/portal/search Redlands Regular Meeting of 10-18-22 859 of 1815
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5.9 Land Use and Planning

5.9.1 INTRODUCTION
This section provides an analysis of the consistency of the proposed Project with applicable land use plans, policies, and regulations that guide development of the Project site and evaluates the relationship of the Project with surrounding land uses. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035, December 2017
• City of Redlands General Plan Update and Climate Action Plan DEIR, July 2017

5.9.2 REGULATORY SETTING

5.9.2.1 Regional Regulations
SCAG Regional Transportation Plan and Sustainable Communities Strategy The Southern California Association of Governments (SCAG) is designated by federal law as a Metropolitan Planning Organization (MPO) and under State law as a Regional Transportation Planning Agency and a Council of Governments. The SCAG region encompasses six counties (Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura) and 191 cities in an area covering more than 38,000 square miles.

SCAG develops transportation and housing strategies for southern California as a whole. On September 3, 2020, SCAG’s Regional Council adopted Connect SoCal - The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020 RTP/SCS), which includes long-range regional transportation plans, regional transportation improvement programs, regional housing needs allocations, and other plans for the region. Most of the plan’s goals are related to regional transportation infrastructure and the efficiency of transportation in the region.

5.9.2.2 Local Regulations
Redlands General Plan 2035
The City of Redlands adopted the 2035 General Plan on December 15, 2017. The General Plan serves as a policy document or blueprint for future development to guide future growth in Redlands. The seven themes in the 2035 General Plan include the following:

1. Distinctive City. This chapter sets policies to preserve and enhance the City’s unique architectural, historical, and cultural resources.

2. Prosperous Economy. This chapter sets forth principles and actions specific to major sectors of Redlands’ economy – including tourism, innovation, and retail, - in order to ensure prosperity and opportunity for all Redlanders.

3. Livable Community. This chapter describes the existing land use pattern and growth management framework. Development and other factors impacting quality of life – including public facilities, public safety, and education – are guided so as to retain the community’s character.

4. Connected City. This chapter includes policies, programs, and standards to maintain efficient circulation for all modes of travel. It identifies future street and traffic improvements, and addresses walking, biking, transit, and parking to enable a multi-model circulation system.

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5. Vital Environment. Redlands is renowned for its natural beauty. This chapter sets forth policies regarding land conservation, open space, agriculture, and water supply, in order to protect the Planning Area’s natural environment.

6. Healthy Community. This chapter shapes policy specific to health outcomes of Redlanders. Topics addressed include recreational activity, public health, safety, and air quality.

7. Sustainable Community. This chapter outlines strategies to preserve Redlands’ natural resources for the benefit of future Redlanders. This chapter incorporates innovative strategies to minimize the environmental footprint associated with water, energy, and resource consumption.

City of Redlands Municipal Code
Chapter 18.16 Districts and Zoning Map
The City’s Code or Ordinances Chapter 18.16, Districts and Zoning Maps establishes the zoning districts and boundaries of those districts within the City.

5.9.3 ENVIRONMENTAL SETTING
The City of Redlands is located near the base of the San Bernardino Mountains in San Bernardino County, approximately 60 miles northeast from the City of Los Angeles and approximately 45 miles west from the City of Palm Springs. The city is situated along the Interstate 10 (I-10) corridor, which links the city with the cities of San Bernardino, Fontana, Ontario, and Los Angeles to the west, and Yucaipa, Beaumont, and Coachella Valley cities to the east.

The proposed Transit Villages Specific Plan (TVSP, or Specific Plan) area generally includes the parcels located within approximately one-half mile, or a 10-minute walk, of the three new Arrow stations in the city.

The entire TVSP area, which covers approximately 947 acres (approximately 1.5 square miles) is generally bounded to the west by Kansas Street, Redlands Boulevard, Alabama Street, and Tennessee Street; to the north by the I-10, Colton Avenue, and Sylvan Boulevard; to the east by Judson Street; and to the south by Citrus Avenue, Central Avenue, Redlands Boulevard, Olive Avenue, Brookside Avenue, Ash Street, Pine Avenue, Tennessee Street, and State Street. The TVSP area also includes the parcels along both sides of Orange Street between Colton Avenue and Lugonia Avenue (see Figure 3-4, Specific Plan Station Areas).

The TVSP area is approximately 947 acres of land that is divided into three planning areas referred to as transit villages, which generally circle each new Arrow station, as shown on Figure 3-4. The New York Street/Esri Transit Village area is generally west of Texas Street and Center Street. The Downtown Transit Village area is generally bounded to the east by Church Street, and to the west by Texas Street, and includes the parcels along both sides of Orange Street between Colton Avenue and Lugonia Avenue. The University Street Transit Village area is located east of Church Street and west of Judson Street.

Existing General Plan and Zoning Designation
The City of Redlands General Plan 2035 (GP2035) designates the TVSP area with a mix of land uses including: Medium Density Residential (up to 15 dwelling units per acre), High Density Residential (up to 27 dwelling units per acre), Office, Commercial, Commercial/Industrial, Industrial, Public/Institutional, and Parks.

Most of the New York Street/Esri Transit Village area consists of non-residential land use designations except for the multi-family residential area in the southern portion of the village. The Downtown Transit Village area is also primarily non-residential, with multi-family allowed along the eastern edge. Land use designations in the University Street Transit Village are primarily medium and high density residential, except the institutional designations associated with the University of Redlands campus to the north of the station site. The General Redlands Regular Meeting of 10-18-22 861 of 1815
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Plan Transit Villages Overlay provides for residential/mixed uses within a half-mile of each station (see Figure 3-5, General Plan Land Use Designation).

The GP2035 Livable Community Element includes a Transit Villages section that provides for the Transit Villages Overlay Zone (TVOZ), which applies to areas within a half-mile radius of the five rail stations that were anticipated in the GP2035, which includes the three new Arrow stations (see Figure 3-6, General Plan Transit Villages).

Existing residential zoning within the TVSP area is primarily Multi-Family Residential (R-2 and R-3); however, there are two small areas with existing single-family zoning. The parcels on 11th Street between the I-10 and Colton Avenue in the Downtown Transit Village are zoned Single-Family Residential (R-1) and the parcels in the University Street Transit Villages bounded by the I-10, East Cypress Avenue, and East Citrus Avenue are zoned Suburban Residential (R-S). See Figure 3-7, Existing Zoning Districts.

Non-residential zoning in the TVSP area include Industrial (I-P), Light Industrial (M-1), Planned Industrial (MP), Administrative and Professional Office (A-P), Neighborhood Stores (C-1), General Commercial (C-3), Highway Commercial (C-4), Commercial (C-M), Educational (E), Transitional (T), Open Land (O), Floodplain (FP), East Valley-General Commercial (EV/CG), and East Valley-Public Institutional (EV/PI).

The Downtown Specific Plan (Specific Plan No. 45), which is located within the proposed Downtown Village, governs the parcels in the downtown area, which is divided into Town Center, Town Center-Historic District, and Service-Commercial District.

The Project area is surrounded by a variety of GP2035 land use designations and zones including industrial, institutional, agricultural, commercial, and single- and multi-family residential as described below. Views of the surrounding GP2035 land use designations can also be seen on Figure 3-5, and views of the surrounding zoning can be seen on Figure 3-7, Existing Zoning Districts.

North: Uses to the north include transitional, commercial, multi-family residential, University of Redlands, and single-family residential.

South: Uses to the south include multi-family residential, University of Redlands, industrial, open space, and administrative buildings.

West: Uses to the west of the Project site include industrial and commercial buildings.

East: Uses to the east primarily consist of single-family residences.

5.9.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:

LU-1 Physically divide an established community; or
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.

The Initial Study established that the proposed Project would not result in impacts related to Threshold LU1; no further assessment of this impact is required in the Draft EIR.

5.9.5 METHODOLOGY
The analysis of land use consistency impacts considers whether the proposed Project physically divide an established community and if the Project would be inconsistent with (or conflict with) with regional and local plans, policies, and regulations that are applicable to the proposed Project and Project site, including the:

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SCAG RTP/SCS, City of Redlands General Plan, and City Municipal Code. Consistent with the scope and purpose of this Draft EIR, this discussion primarily focuses on those goals and policies that relate to avoiding or mitigating environmental impacts, and an assessment of whether any inconsistency with these standards creates a significant physical impact on the environment. Thus, a project’s inconsistency with a policy is only considered significant if such inconsistency would cause significant physical environmental impacts (as defined by CEQA Guidelines Section 15382).

CEQA Guidelines Section 15125(d) requires that an EIR discuss inconsistencies with applicable plans that the decision-makers should address. A project need not be consistent with each and every policy and objective in a planning document. Rather, a project is considered consistent with the provisions of the identified regional and local plans if it meets the general intent of the plans and would not preclude the attainment of the primary goals of the land use plan or policy.

5.9.6 ENVIRONMENTAL IMPACTS
IMPACT LU-2: THE PROJECT WOULD NOT 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.

SCAG Regional Transportation Plan/Sustainable Communities Strategy The 2020 RTP/SCS Goals that are relevant to the proposed Project focus largely on maximizing mobility, encouraging development patterns and densities that reduce infrastructure costs, and provide for efficiency.

The proposed Project would be consistent with the applicable SCAG’s 2020 RTP/SCS goals, as detailed in Table 5.9-1. Therefore, implementation of the proposed Project would not result in conflict with RTP/SCS goals, and impacts would not occur.

Table 5.9-1: Consistency with SCAG Regional Transportation Plan/Sustainable Communities Strategy RTP/SCS Goal Statements Proposed Project Consistency with Applicable Goals RTP/SCS G1: Encourage regional economic prosperity
and global competitiveness.

Consistent. The Project would enhance the region’s
overall economic development and competitiveness.

RTP/SCS G2: Improve mobility, accessibility, reliability, and travel safety for people and goods.

Consistent. As a city-level planning document, the
Project is limited in its ability to maximize mobility and access for people and goods throughout the SCAG
region. However, the Project would not create substantial traffic impediments. Additionally, the Project would
promote development within the 0.5-mile of the Arrow
Line, which would help improve mobility in the City.

RTP/SCS G3: Enhance the preservation, security, and
resilience of the regional transportation system.

Consistent. As a city-level planning document, the
Project is limited in its ability to ensure security and resilience of the regional transportation system. There are no components of the Project that would result in the deterioration of the transportation system. However, as a measure to safeguard security, the Project would
comply with applicable policies included in the City’s
General Plan, including development outside 100-year
flood zones, dam inundation areas, Alquist-Piolo
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RTP/SCS Goal Statements Proposed Project Consistency with Applicable Goals earthquake fault zones, and very high fire severity
zones.

RTP/SCS G4: Increase person and goods movement and
travel choices within the transportation system...

Consistent. As a city-level planning document, the
Project is limited in its ability to maximize the goods movement and travel choices within the SCAG region.

However, the Project would not create substantial traffic impediments. Additionally, the Project would promote
development within the 0.5-mile of the Arrow Line, which would help improve travel choices in the City.

RTP/SCS G5: Reduce greenhouse gas emissions and
improve air quality.

Consistent. While the Project would not improve air
quality or reduce greenhouse gas emissions, it would set standards for infill development adjacent to transit,
which would reduce vehicle trips and associated
emissions. Additionally, it would not prevent SCAG from implementing actions that would improve air quality
within the region and the Project would incorporate
various measures related to building design,
landscaping, and energy systems to promote the efficient use of energy, pursuant to Title 24 CALGreen Code and
Building Energy Efficiency Standards and Consistent with Policy NR-1.9.

RTP/SCS G6: Support healthy and equitable
communities.

Consistent. The Project would comply with Countywide
goal and policies to support healthy and equitable
communities. Additionally, the Project would include
street network improvements, bike lane improvements,
and sidewalk improvements that would increase the
walkability in the Project area.

RTP/SCS G7: Adapt to a changing climate and support
an integrated regional development pattern and
transportation network.

Consistent. This policy would be implemented by cities
and the counties within the SCAG region as part of the
overall planning and maintenance of the regional
transportation system.

RTP/SCS G8: Leverage new transportation technologies
and data-driven solutions that result in more efficient travel.

Consistent. This policy would be implemented by cities
and the counties within the SCAG region as part of the
overall planning and maintenance of the regional
transportation system. The Project would not conflict with this goal.

RTP/SCS G9: Encourage development of diverse housing
types in areas that are supported by multiple
transportation options.

Consistent. The proposed Project would contribute to
meeting the regional goal of developing residential
housing in an area that is supported by multiple
transportation options.

RTP/SCS G10: Promote conservation of natural and
agricultural lands and restoration of habitats
Consistent. The proposed Project would be consistent
with goals and policies of the City’s General Plan and
would not cause significant environmental impacts to
agricultural lands or biological resources. The TVSP area is located within a largely developed, urbanized setting and would not result in the conversion of farmland or
open space.

City of Redlands General Plan 2035
Land Use Consistency: As mentioned above, the City of Redlands General Plan 2035 (GP2035) designates the TVSP area with a mix of land uses including: Medium Density Residential (up to 15 dwelling units per Redlands Regular Meeting of 10-18-22 864 of 1815
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acre), High Density Residential (up to 27 dwelling units per acre), Office, Commercial, Commercial/Industrial, Industrial, Public/Institutional, and Parks.

Areas south of the Project have a General Plan Land Use Designation of low density residential, medium density residential, high density residential, public institutional, commercial, and office. Areas to the north have a General Plan Land Use Designation of low density residential, medium density residential, low medium density residential, and commercial. Areas to the west have a land use designation of commercial/industrial and commercial. Areas to the east have a low density residential General Plan Land Use Designation.

California law (Government Code §65450-§65453) allows cities to develop and administer Specific Plans as an implementation tool for their General Plan. As a requirement of state law, Specific Plans must demonstrate consistency in regulations, guidelines and programs with the goals, objectives, policies, standards, programs and uses that are established in the General Plan. The proposed Specific Plan would implement General Plan policies related to infill development, providing a supply of non-residential development area within the City, provision of housing for employees, and increasing use of alternative methods of circulation. The proposed TVSP provides for infill development that would make use of the existing circulation and utility infrastructure and provide mixed-use and higher density housing opportunities that provide affordability. The TVSP addresses the consistency of the TVSP with the relevant City’s General Plan and said analysis is incorporated by reference into this EIR.

Table 5.9-2, Project Consistency with Applicable General Plan Actions and Policies, lists the policies from the City of Redlands General Plan that are relevant to the proposed Specific Plan. For each topic of the General Plan, the General Plan established policies that consist of principles and actions that form the supporting policies for the goal. As shown in Table 5.9-2 below, the Project would be consistent with the actions and policies of the City’s General Plan.

Table 5.9-2: Project Consistency with Applicable General Plan Actions and Policies General Plan Policy Proposed Project
Policy 2-P.8 Identify, maintain, protect, and enhance
Redlands’ cultural, historic, social, economic, architectural, agricultural, archaeological, and scenic heritage. In so doing, Redlands will preserve its unique character and
beauty, foster community pride, conserve the character
and architecture of its neighborhoods and commercial
and rural areas, enable citizens and visitors to enjoy and learn about local history, and provide a framework for
making appropriate physical changes.

Consistent. The TVSP encourages infill transit-oriented development surrounding three new train stations in the City. Transit-oriented development is a planning concept that provides for residential and commercial uses around a transit station or corridor to facilitate transit use. the proposed TVSP would provide a form-based code to
achieve preferred building forms and design, promote
compact and walkable urban form in the vicinity of the train stations, introduce a greater variety of transportation options (and reduce vehicle trips and vehicle miles
traveled), and provide more public open space and
amenities that provides aesthetic and community benefits.

Policy 2-P.9 Provide incentives to protect, preserve, and maintain the city’s heritage.

Consistent. The proposed TVSP would utilize a form-based code to achieve preferred building forms and design that would maintain the City’s heritage.

Policy 2-P.11 Encourage retention of the character of
existing historic structures and urban design elements that define the built environment of the city’s older
neighborhoods.

Consistent. The proposed Project would require evaluation of potential historic resources for implementing projects that could potentially impact a building or structure in excess of 45 years of age as included as Mitigation Measure CUL-1.

Policy 2-P.12 Encourage retention of historic structures in their original use or reconversion to their original use where feasible. Encourage sensitive, adaptive reuse
where the original use is no longer feasible.

Consistent. Implementing developments could impact
historic structures. However, the proposed Project would require evaluation of potential historic resources for
implementing projects that could potentially impact a
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building or structure in excess of 45 years of age as
included as Mitigation Measure CUL-1.

Policy 2-P.13 Encourage preservation of and public
access to defined and established significant scenic
vistas, viewpoints, and view corridors.

Consistent. As discussed in the Initial Study (Appendix A), the Project area consists of an urbanized environment that does not include or provide scenic vistas. Land use changes that would occur under the TVSP are in or near already
developed areas of the City and coincide with areas
designated for development under the GP2035.

Action 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. Implementing developments could impact
historic structures. However, as discussed above, the
proposed Project would require evaluation of potential
historic resources for implementing projects that could potentially impact a building or structure in excess of 45 years of age as included as Mitigation Measure CUL-1.

Action 2-A.26 Provide development standards and
guidelines to encourage conversion of historic structures to alternative uses without compromising the quality of the neighborhood if preservation of the original use is an economic hardship.

Consistent. Implementing developments would be
consistent with the form-based code provided by the TVSP.

As discussed in Chapter 4 of the TVSP, all rehabilitations and additions to historic buildings shall conform to the recommendations of the Secretary of the Interior’s
Standards for Rehabilitation and Illustrated Guidelines for Rehabilitation of Historic Structures and/or the Redlands Historic Architectural Design Guidelines.

Action 2-A.38 Use exemplary design quality and
sensitivity to surrounding historic structures in new City construction, public works, entry ways, and City signs.

Consistent. Implementing developments would be
consistent with the form-based code provided by the TVSP.

As discussed in Chapter 4 of the TVSP, all rehabilitations and additions to historic buildings shall conform to the recommendations of the Secretary of the Interior’s
Standards for Rehabilitation and Illustrated Guidelines for Rehabilitation of Historic Structures and/or the Redlands Historic Architectural Design Guidelines.

Action 2-A.39 Ensure that permanent changes to the
exterior or setting of a designated historic resource be done in accordance with the Secretary of the Interior
standards for historic properties.

Consistent. Implementing developments would be
consistent with the form-based code provided by the TVSP.

As discussed in Chapter 4 of the TVSP, all rehabilitations and additions to historic buildings shall conform to the recommendations of the Secretary of the Interior’s
Standards for Rehabilitation and Illustrated Guidelines for Rehabilitation of Historic Structures and/or the Redlands Historic Architectural Design Guidelines.

Action 2-A.70 Encourage preservation of historic public and private improvements, such as street curbs, street
trees, specimen trees, street lights, hitching posts,
masonry walls, unpaved and early paved sidewalks, etc
Consistent. Implementing developments would be
consistent with the form-based code provided by the TVSP.

As discussed in Chapter 4 of the TVSP, all rehabilitations and additions to historic buildings shall conform to the recommendations of the Secretary of the Interior’s
Standards for Rehabilitation and Illustrated Guidelines for Rehabilitation of Historic Structures and/or the Redlands Historic Architectural Design Guidelines.

Principle 2-P.18 Reinforce Redlands’ identity as a “Tree City” through cohesive streetscapes that enhance its sense of place and its heritage, and that promote pedestrian
comfort.

Consistent. Section 4.15 of Chapter 4 Development Code
in the TVSP includes street and streetscape design
standards which includes street tree spacing, street tree location, tree species, tree wells, and parkway landscape materials. Implementing developments would be consistent with Section 4.15 of the form-based code.

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Action 2-A.78 Consider creating tree-lined medians on
arterials, boulevards, and collectors where the width of the street is adequate to accommodate the anticipated
traffic flows along with a landscaped median.

Consistent. As discussed above, section 4.15 of Chapter 4 Development Code in the TVSP includes street and
streetscape design standards which includes street tree spacing, street tree location, tree species, tree wells, and parkway landscape materials. Implementing developments
would be consistent with Section 4.15 of the form-based code.

Principle 2-P.24 Promote Downtown as Redlands’
vibrant center for residents, visitors, and workers, infused with thriving commerce and active streets.

Consistent. Implementing developments would comply with the form-based code which includes a mixture of land uses including shops, restaurants, entertainment venues,
workplaces, and residences. The area would be
pedestrian-oriented and frontages would enhance the
pedestrian activity of the streets.

Principle 2-P.25 Encourage a variety of uses and
activities, such as a mix of commercial, office, restaurant, specialty retail, and residential uses, and civic, cultural, and entertainment activities to attract visitors and
residents from across the community by creating a lively, interesting social environment.

Consistent. As discussed above, implementing
developments would comply with the form-based code
which includes a mixture of land uses including shops,
restaurants, entertainment venues, workplaces, and
residences. The area would be pedestrian-oriented and
frontages would enhance the pedestrian activity of the
streets.

Principle 2-P.26 Foster transit-oriented development
that is consistent/compatible with and sensitive to the historical structures in the vicinity of the proposed railway station
Consistent. Implementing developments would comply with the form-based code included as Chapter 4 of the TVSP.

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