Agenda packet — Redlands City Council, October 18, 2022 (part 5 of 8)

on project sites located immediately adjacent to lots that have designated or eligible historic structures on them shall be deigned per the requirements of the Specific Plan and per 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.27 Conserve Downtown’s character and
historic assets while infusing it with new uses, buildings, and activities. New development should proportionately
relate to and complement existing structures and the
pedestrian environment.

Consistent. As discussed above, implementing
developments would comply with the form-based code
included as Chapter 4 of the TVSP. Page 4-2 of the TVSP Development Code states buildings on project sites located immediately adjacent to lots that have designated or
eligible historic structures on them shall be deigned per the requirements of the Specific Plan and per 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.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.

Consistent. Figure 3.9 shows the future street network
improvements that would occur over time from
implementation of the TVSP.

Action 2-A.93 Preserve historic buildings and sites while permitting sensitive adaptive reuse.

Consistent. As discussed previously, 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.94 Encourage mixed-use projects Downtown
that integrate retail, restaurant, office, and residential Consistent. As discussed in Table 3-1 of Section 3.0 Project Description, the TVSP proposed buildout includes
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uses. Permit urban housing at a density up to the HighDensity Residential standard.residential, retail commercial, office, hotel, and open space and parks.

Action 2-A.95 Enhance and extend the civic realm
through vibrant streetscapes.

Consistent. As shown on Figure 3-11, buildout of the TVSP would include street network improvements, landscaping, and building design that is consistent with the TVSP
development code that would be consistent with the
architectural styles throughout the City of Redlands.

Action 2-A.97 Seek an increased presence of both
residents and activity in Downtown with new
development—particularly residential as part of mixeduse development—as well as commercial, entertainment, and cultural uses that serve both residents and visitors.

Consistent. As discussed above and in Table 3-1 of Section

3.0 Project Description, the TVSP proposed buildout includes residential, retail commercial, office, hotel, and open space and parks.

Action 2-A.98 Promote a variety of housing types to
attract a spectrum of households to live Downtown.

Consistent. When fully implemented, the TVSP would allow for development of medium- to high-density residential
buildings.

Action 2-A.99 Ensure that new development along
Redlands Boulevard is pedestrian-oriented.

Consistent. The TVSP would include pedestrian facility
improvements including pedestrian-scaled blocks,
intersection improvements, mid-block intersection crossings, and new signalized intersections.

Action 2-A.101 Address parking demand by finding
additional areas to provide parking for Downtown, and
by developing creative parking management strategies,
such as shared parking, maximum parking standards,
“smart” metering, utilizing on-street parking for reuse of existing buildings, paid parking, etc. Monitor the impacts of new technology such as the autonomous vehicle and
car hire /car share services on the total demand for
parking.

Consistent. The TVSP would introduce a future parking
structure located north of the downtown rail crossing. In addition, parallel parking spaces would be introduced with the future transportation network improvements.

Furthermore, the TVSP would provide parking standards
for shared parking for future developments and park-once methodologies to limit vehicle miles traveled.

Action 2-A.102 Improve connections from Downtown to
adjacent neighborhoods, including areas north of I-10,
through streetscape enhancement and multi-modal
improvements.

Consistent. Figure 3-9, Future Street Network
Improvements, shows the network connections that would
occur from implementation of the TVSP and where the street improvements would connect to adjacent neighborhoods.

Principle 3-P.2 Seek varied, resilient, high-quality office and other commercial uses appropriate to Redlands to
support the projected population.

Consistent. The TVSP would provide a variety of housing, office, and retail opportunities within walking and biking distance of the three proposed Redlands Passenger Rail
stations, the Downtown commercial district, Smiley and
Sylvan Parks, and the Esri and University of Redlands
campuses.

Action 3-A.3 Assist in the expansion and retention of
existing businesses and industries.

Consistent. The TVSP would provide opportunities for
expansion of retail and office businesses through
development of commercial and office space. Existing
businesses would be able to continue to operate as
development occurs.

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

Consistent. The TVSP includes a form-based development
code that would allow for similar architectural styles that would make the commercial and industrial areas more
aesthetically appealing. The future network improvements shown in Figure 3-9 would increase accessibility.

Action 3-A.8 Support design and development of a
transportation system to service the business and
industrial needs of the Planning Area in order to minimize congestion and circuitous travel.

Consistent. As shown in Figure 3-9, future network
improvements would occur upon implementation of the
TVSP.

Action 3-A.10 Encourage mixed-use projects within the
Transit Villages that will attract a wide array of uses including retail, restaurant, entertainment, office,
residential, and cultural offerings.

Consistent. As discussed above and in Table 3-1 of Section

3.0 Project Description, the proposed TVSP buildout includes residential, retail commercial, office, hotel, and open space and parks.

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Principle 3-P.6 Maintain the appropriate land use
balance that fosters and enhances economic
development within the City of Redlands
Consistent. As discussed above, the proposed TVSP
buildout includes residential, retail commercial, office, hotel, and open space and parks.

Principle 3-P.7 Encourage balance between economic
development and all other aspects of community life that make Redlands a desirable place to live, work, and shop.

Consistent. The proposed TVSP buildout includes
residential, retail commercial, office, hotel, and open space and parks.

Action 3-A.12 Encourage the location of commercial
centers according to function and scale regional, general, and neighborhood so that centers of different scales
complement one another and each is accessible to the
primary market it is designed to serve.

Consistent. The 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. The TVSP would include three villages; The New York Street/Esri Village, Downtown
Transit Village, and University Village which would comply with the Development Code included as Chapter 4 of the
TVSP.

Action 3-A.14 Encourage commercial development,
neighborhood retail, and professional offices and
services of the appropriate scale and business types
along neighborhood commercial corridors, such as
Orange Street and Colton Avenue
Consistent. The TVSP would designate the area along
Orange Street and Colton Avenue as Corridor 1 and
Neighborhood 2 which allows for residential and
commercial uses. Chapter 4 of the TVSP provides
development standards that would ensure new
development is appropriately scaled.

Action 3-A.17 Support neighborhood markets of
appropriate size and scale and in the appropriate
locations where there is support from neighborhood and
community groups.

Consistent. In Table 3-1 of Section 3.0 Project Description, the proposed TVSP buildout includes residential, retail commercial, office, hotel, and open space and parks.

Chapter 4 of the TVSP provides development standards
that would ensure new development is sized and scaled in appropriate locations.

Action 3-A.25 Support the development of business
incubators, live-work lofts, and other flexible, multipurpose, and open-office concept workspaces designed to assist entrepreneurs and start-up businesses.

Consistent. The proposed TVSP buildout would include
multip-story office and mixed-use buildings that would
allow for multi-purpose uses. Allowed office types are
identified in Table 4-2 in Chapter 4 of the TVSP.

Principle 3-P.12 Promote Redlands as a destination
where visitors can shop, dine, play, and stay, and help create opportunities for increased visitation, hotel stays, sales tax generation, and employment.

Consistent. In Table 3-1 of Section 3.0 Project Description, the proposed TVSP buildout includes residential, retail commercial, office, hotel, and open space and parks.

Action 3-A.32 Support commercial recreation businesses
as uses that would revitalize older commercial areas and draw new visitors to the city.

Consistent. In Table 3-1 of Section 3.0 Project Description, the proposed TVSP buildout includes residential, retail commercial, office, hotel, and open space and parks. These uses would attract local residents, workers, and regional visitors.

Principle 3-P.16 Strengthen Downtown as a center of
commerce and culture, with attractions for local residents, workers, and regional visitors year-round.

Action 3-A.33 Support efforts to improve the economic
and physical environment in the Downtown area by
enhancing and expanding tourism-related activities and
capital improvements, and generating external in-kind
and monetary support for these efforts.

Consistent. The proposed TVSP buildout would include
retail, commercial, and hotels that would increase tourism.

The network improvements including increasing walkability throughout the area would also expand tourism-related
activities.

Action 3-A.34 Encourage and support unique specialty
retail and restaurant uses in the Downtown core
Consistent. The proposed TVSP buildout would provide
space for retail and restaurant spaces. Shops and
restaurants within walking distance of the New York Street, Downtown, and University Street Passenger Rail Stations.

Action 3-A.36 Support revitalization of underutilized
commercial space throughout Downtown, including the
Redlands Mall, which could create new opportunities for Consistent. The proposed TVSP would introduce areas for commercial and retail uses within walking distance of the New York Street, Downtown, and University Street
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businesses and residents, and provide a critical link to rail.

Passenger Rail Stations which would create new
opportunities for businesses and residents and provide a critical link to rail.

Action 3-A.37 Ensure adequate parking Downtown and
efficiency in traffic flow to enable the continued
revitalization of the commercial core.

Consistent. Figure 3-9 shows the future street network
improvements which would increase efficiency in traffic flow.

Action 3-A.39 Encourage and support the development
of additional housing Downtown to increase the vitality and diversity of Downtown retail and services.

Consistent. Buildout of the TVSP would include medium- to high-density residential buildings.

Action 3-A.40 Enhance and expand the public spaces
Downtown (streetscapes, plazas, parks) to improve the
pedestrian experience.

Consistent. Figure 3-11 shows the streetscapes and parks that would contribute to improving the pedestrian
experience.

Principle 4-P.5 Maintain a land use pattern of various
uses designed and arranged to protect and enhance
Redlands’ unique character.

Consistent. The proposed TVSP buildout includes
residential, retail commercial, office, hotel, and open space and parks. Implementing developments would comply with
Chapter 4 of the TVSP which includes development
standards that would be consistent with Redlands’ unique character.

Principle 4-P.6 Provide for a balance among a variety
of different land uses and their distribution among the city’s neighborhoods.

Consistent. The proposed TVSP buildout includes
residential, retail commercial, office, hotel, and open space and parks which would provide for a balance of different land uses.

Principle 4-P.7 Promote a diversity of compatible land
uses throughout the city, providing opportunities for the development of a range of businesses, services,
residential types, and public facilities to meet the needs of the community.

Consistent. The proposed TVSP buildout includes
residential, retail commercial, office, hotel, and open space and parks which would provide for a balance of different land uses.

Principle 4-P.8 Provide for buffers and transitions
between low- and high-intensity land uses.

Consistent. The proposed TVSP buildout would include
setbacks within the development standards that would
serve as buffers between low- and high-intensity land uses.

Principle 4-P.9 Locate medium- and high-density
development near regional access routes, transit stations, employment centers, shopping areas, and public services.

Consistent. The proposed TVSP buildout would develop
medium- to high-density residential uses within walking distance of the New York Street, Downtown, and University Street Passenger Rail Stations.

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

Consistent. Implementing projects would adhere to the
design guidelines set forth in Chapter 4 of the TVSP, which would ensure that new development in consistent in scale and visual character with existing development.

Principle 4-P.12 In areas planned to accommodate new
growth, such as Downtown and the Transit Villages, use
area plans, design standards and guidelines, and other
tools to ensure cohesive transition in scale to existing neighborhoods.

Principle 4-P.13 Encourage mixed-use development
(two or more uses within the same building or in close
proximity on the same site) in Downtown, the Transit
Villages, and along Redlands Boulevard to promote
vibrancy
Consistent. The proposed TVSP would promote mixed-use
development throughout the TVSP area, with commercial
uses focused on the first floor and multi-family residential uses on higher floors in order to enhance each village area.

Principle 4-P.14 Encourage mixed-use projects
Downtown that integrate retail, restaurant, office, and residential uses. Permit urban housing at a density up to the High Density Residential standard.

Consistent. The proposed TVSP would promote mixed-use
development throughout the TVSP area, with commercial
uses, such as commercial retail or restaurant uses, focused on the first floor and multi-family residential uses or office space on higher floors in order to enhance the Downtown area.

Principle 4-P.16 Promote a variety of housing types to
serve the diverse needs of the community
Consistent. As outlined in Section 3.0, one of the primary objectives of the TVSP is to provide a variety of housing Redlands Regular Meeting of 10-18-22 870 of 1815
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options to accommodate and attract a range of household types in order to meet the City’s housing needs.

Principle 4-P.17 Limit negative impacts to residential
neighborhoods from incompatible uses
Consistent. As shown in Figure 3-8, Regulating Plan, areas within the TVSP area located adjacent to single-family
residential neighborhoods would be in the Village Corridor or Neighborhood General districts. These districts would provide for less intensive uses, with lower heights, that would be compatible with the surrounding single-family
residential uses.

Principle 4-P.18 Provide lands to accommodate a wide
range of office uses to meet the needs of small- and
medium-sized businesses and larger corporations in
sectors such as professional services, medical services, and technology in appropriate locations convenient to
transportation corridors.

Principle 4-P.22 Provide lands to accommodate
neighborhood-scaled commercial centers in residential
areas to serve the everyday needs of nearby residents.

Action 4-A.7 Promote a range of residential densities to encourage a mix of housing types in varying price ranges and rental rates
Consistent. As outlined in Section 3.0, one of the primary objectives of the TVSP is to provide a variety of housing options to accommodate and attract a range of household Action 4-A.8 Promote the development of a greater types in order to meet the City’s housing needs. variety of housing types, including single-family homes on small lots, accessory dwelling units, townhomes, lofts, live-work spaces, and senior and student housing to meet the needs of future demographics and changing family
sizes.

Action 4-A.11 Ensure that opportunities exist for the
development of housing types that are affordable to all segments of the Redlands community and are distributed
equitably throughout the community.

Action 4-A.12 Support new residential development in
Downtown, the Transit Villages, and other focused infill sites accessible to transit and in central parts of the community.

Consistent. The proposed TVSP would promote infill
residential development on areas within the TVSP area that are easily accessible to the new Arrow Line stations.

Action 4-A.14 Discourage changes in residential areas
that would disturb the character of or clearly have a
destabilizing effect on the neighborhood
Consistent. Implementing projects would adhere to the
design guidelines set forth in Chapter 4 of the TVSP, which would ensure that new development in consistent in scale and visual character with existing development in
residential neighborhoods.

Action 4-A.16 Improve vehicular accessibility, traffic
flow, and parking availability as well as pedestrian
access and amenities within office, commercial, and
industrial areas.

Consistent. As shown on Figures 3-9 through 3-11, the
TVSP would include street improvements, along with
pedestrian and bicycle infrastructure improvements in
order to promote accessibility and multiple modes of
transportation within the TVSP area.

Action 4-A.17 Rely on strong landscape treatments,
setbacks, sign controls, and, where feasible, underground utilities and street improvements to prevent visual chaos where businesses are competing for attention.

Consistent. Implementing projects would adhere to the
design guidelines set forth in Chapter 4 of the TVSP, which would ensure that new development provides adequate
landscape treatment, setbacks, and sign controls.

Additionally, as new development occurs within the TVSP area, undergrounding of dry utilities would be required for electrical transmission lines less than 66 kilovolts (kV).

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Action 4-A.18 Focus the development of office space in
transit-accessible locations.

Consistent. The proposed TVSP would promote
development of up to 238,000 SF of office space on
parcels within the TVSP area that are easily accessible to the new Arrow Line stations.

Action 4-A.20 Establish new neighborhood commercial
centers to serve the needs of community members in
areas planned to accommodate new growth, such as
Downtown and the Transit Village areas.

Action 4-A.21 Revitalize neighborhood shopping centers
in neighborhoods where existing centers have reached
the end of their economic life.

Consistent. The proposed TVSP would encourage
redevelopment of blighted neighborhood shopping centers such as the Redlands Mall.

Action 4-A.22 Ensure that neighborhood shopping
centers are designed in a manner compatible with
adjacent residential areas.

Consistent. Implementing commercial retail projects would be required to be consistent with the design standards set forth in Chapter 4 of the TVSP, which would ensure that they are designed in a manner compatible with surrounding development.

Action 4-A.23 Ensure that neighborhood shopping
centers conform to regulations limiting the size, location, and general character of signage and facades so as not
to disrupt the residential or historical character of the neighborhood.

Action 4-A.24 Preserve and encourage neighborhood
stores that enable shoppers to walk or bike for everyday needs, provide access to healthy foods, and promote a
sense of community, such as Olive Market.

Action 4-A.31 Designate areas for the development of
research and development, high tech, and professional
businesses in the Planning Area.

Consistent. The TVSP would promote development of up to 238,000 SF of office space that would provide space for research, technology development, and professional
businesses throughout the TVSP area.

Action 4-A.41 Seek to acquire land to be dedicated as
open space and preserve it from development.

Consistent. As shown on Figure 3-8, the TVSP would include provisions for new open space and parkland within the
TVSP area.

Action 4-A.44 Work with the University to create
needed hotel/conference facilities in Redlands.

Consistent. As described in Section 3.0, the TVSP would promote development of up to 220 hotel rooms in the TVSP area.

Principle 4-P.26 Support the University of Redlands in
the development of its campus and the surrounding area
in a manner that enriches both the University and
Redlands communities.

Consistent. The TVSP would promote mixed-use
development within the University Village area in order to promote development of multi-family units, commercial
space, office space, and hotel rooms near the University Arrow Line station.

Principle 4-P.39 Promote infill and mixed-use
development along Redlands Boulevard to create a
cohesive commercial corridor connecting the Transit
Villages and providing a retail and service destination for community members.

Consistent. The TVSP would promote infill, mixed-use
development along Redlands Boulevard that would connect the New York Street Village with the Downtown Village
and would provide a variety of retail commercial and
restaurant uses. Implementing developments along
Redlands Boulevard would be required to be consistent
with the design guidelines set forth in Chapter 4 of the TVSP in order to ensure new development would be
consistent with the characteristics of each village.

Principle 4-A.87 Promote clusters of mixed-use
development along Redlands Boulevard near the Mixed
Use Cores of the proposed Transit Villages, providing
opportunities for commercial, office, and residential
development consistent with the needs and characteristics specific to each Transit Village
Action 4-A.88 Promote infill development along
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to create a continuous corridor of mixed-use and
commercial activity.

Action 4-A.89 Complete and enhance the sidewalk
system along both East and West Redlands Boulevard.

Make pedestrian enhancements to facilitate the safe
crossing of the street.

Consistent. As discussed in Section 3.0, pedestrian
improvements within the TVSP include enhancement of the sidewalk system along Redlands Boulevard in order to
increase pedestrian connectivity and safety.

Action 4-A.90 Extend and enhance the center median of
Redlands Boulevard with landscaping, public art, and
lighting to improve the aesthetics and enhance its function as a major east-west boulevard.

Consistent. As discussed in Section 3.0, multiple
improvements would occur along Redlands Boulevard in
order to enhance its function as a multi-modal street.

Principle 4-P.40 Encourage 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.

Consistent. The TVSP would designate the area along
Orange Street and Colton Avenue as Corridor 1 and
Neighborhood 2 which allows for residential and
commercial uses. Chapter 4 of the TVSP provides
development standards that would ensure new
development provides a welcoming visual environment with quality architecture and landscaping. The development
guidelines set forth in the TVSP would provide for
regulations that would guide implementing developments
and enhance the street frontages along Orange Street and Colton Avenue.

Action 4-A.91 Develop an area plan for the Colton
Avenue and Orange Street corridors that will improve
the public spaces, enhance the quality of architecture
and landscape architecture, attract a mix of familyfriendly retail and professional businesses to serve the neighborhoods, and improve the overall attractiveness of the areas.

Action 4-A.92 Support the continued presence and new
development of small businesses serving the community
along the commercial corridors of Colton Avenue and
Orange Street.

Action 4-A.93 Seek to improve the mix of office,
professional, and service related businesses along Colton Avenue and Orange Street that will serve the
neighborhood.

Action 4-A.95 Promote infill development to create a
continuous corridor of mixed-use and commercial activity.

Action 4-A.96 Encourage site designs that create an
active street frontage and screen parking from the
Colton Avenue and Orange Street frontages
Action 4-A.97 Encourage the development of bicycle,
pedestrian, and transit access that reduces the need for on-site parking. Improve the pedestrian experience
within these corridors through street trees and
landscaping.

Consistent. As discussed in Section 3.0, Project Description, the TVSP would include various street, bicycle network, and pedestrian improvements that would promote alternative
transportation and reduce the need for onsite parking
within the TVSP area. The TVSP would promote
development of mixed-uses within infill sites that would provide for walkable environments and access to public
transportation.

Principle 4-P.41 Foster a connected, accessible, and
active community by creating attractively designed
pedestrian- and transit-oriented villages with a mix of uses in a compact area
Principle 4-P.42 Provide for new jobs, housing, and
entertainment opportunities in compact, walkable
environments.

Principle 4-P.43 Ensure that each Transit Village has a unique character and identity that reflects its existing assets and unique characteristics, and provides
appropriate services at that location
Consistent. The proposed TVSP would largely maintain the existing character of each Transit Village, while providing design guidelines and infrastructure improvements that
would enhance future developments within each Village
and ensure they are compatible with existing
developments.

Principle 4-P.44 Provide choices for travel options,
including walking, biking, vehicular, and transit.

Consistent. As discussed in Section 3.0, Project Description, the TVSP would include various street, bicycle network, and pedestrian improvements that would promote alternative
transportation and reduce the need for onsite parking
within the TVSP area. The TVSP would promote
Principle 4-P.45 Accommodate all appropriate modes
of transportation in Transit Villages, and promote
seamless transitions between modes.

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Principle 4-P.46 Improve connectivity between Transit
Villages and existing neighborhoods.
development of mixed-uses within infill sites that would provide for walkable and bikeable environments and
access to public transportation.

Principle 4-P.47 Provide for appropriate transitions
between Transit Villages and surrounding neighborhoods
Consistent. Implementing projects would be required to be consistent with the design standards set forth in Chapter 4 of the TVSP, which would ensure that they are designed in a manner compatible with surrounding development.

Principle 4-P.48 Provide development and infill
opportunities as alternatives to building at the edges of the city
Consistent. The TVSP would provide for development of
infill, mixed-use projects within the TVSP area, away from the edges of the City.

Principle 4-P.49 Allow residential and mixed-use
projects in the Mixed Use Core at densities up to the High Density Residential standard.

Consistent. The TVSP would continue to allow for a higher levels of density and density bonuses in areas closer to transit, upon the provision of public benefits.

Principle 4-P.50 Allow for density bonuses in the Transit Village Overlay Zone contingent on the provision of
public benefits. Density bonuses shall be a minimum of 25 percent within a quarter-mile of each transit station, and 10 percent in areas located between a quarter-mile and
a half-mile radius of each transit station. Public benefits may include but are not limited to amenities such as a
public park, plaza, or playground; enhanced
streetscaping; public art; or participation in a voluntary transfer of development rights program.

Principle 4-P.51 Complete 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.

Consistent. The TVSP provides guidelines for village
character, design, permitted and conditional uses, building setbacks and heights, among other provisions.

Action 4-A.98 Create greater opportunity to intensify
and consolidate land uses on adjacent parcels and
connect existing assets through infill development.

Consistent. The TVSP would promote infill, mixed-use
development on underutilized or vacant parcels within the TVSP area.

Action 4-A.99 Promote mixed uses to serve a range of
users, including local workers and visitors to nearby
tourist destinations.

Consistent. The TVSP would provide for a variety of
mixed-uses that would serve residents, local workers, and visitors to the city.

Action 4-A.100 Provide streetscape improvements
along the major corridors of California Street and
Redlands Boulevard to enhance comfort and safety for
all modes of travel.

Action 4-A.103 Preserve citrus groves for visual effect and to distinguish the station area from others
Consistent. The TVSP includes provisions for preservation of existing citrus groves.

Action 4-A.105 Create an active and compact transitoriented core with a mix of residential and commercial/office uses. Allow for the reuse of
commercial sites as office centers.

Consistent. The TVSP would provide for development of
infill, mixed-use projects within the TVSP area, which would promote multi-modal transportation and the reuse of
existing, blighted commercial sites.

Action 4-A.106 Add new streets to create a finer
grained (shorter blocks), pedestrian scaled road
network, connecting residential areas to parks and the
Mixed Use Core.

Consistent. As discussed in Section 3.0, the TVSP includes provisions for the addition of new streets in certain areas in order to provide pedestrian-scaled blocks.

Action 4-A.107 Provide streetscape improvements
along the major corridors of Alabama Street and
Redlands Boulevard to enhance comfort and safety for
all modes of travel and strengthen north-south
connections between major destinations and east-west
routes.

Action 4-A.108 Establish boulevards along Redlands
Boulevard and Colton Avenue with pedestrian-oriented
streetscape improvements and ground-floor active uses.

Consistent. As discussed in Section 3.0, pedestrian
improvements within the TVSP include enhancement of the sidewalk system along Redlands Boulevard and Colton
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Avenue in order to increase pedestrian and bicycle
connectivity and safety and promote multi-modal
transportation.

Action 4-A.109 Ensure that adequate parkland is
available to serve new residents and employees in the
area.

Consistent. As shown on Draft EIR Figure 3-12, the TVSP would include provisions for new open space and parkland within the TVSP area in order to ensure there is adequate parkland to serve new residents and employees within the TVSP area.

Action 4-A.110 Implement bicycle route improvements
that provide strong east-west connections to other Transit Villages and the city’s wider bicycle network. Routes
would include the Orange Blossom Trail and potentially
a trail along Redlands Boulevard in this location.

Consistent. As shown on Draft EIR Figure 3-11, the TVSP would include provisions for various bicycle infrastructure improvements.

Action 4-A.112 Create an active and compact transitoriented core with office uses that provide opportunities for jobs and innovation, as well as commercial and
residential uses to serve the needs of the area’s workers.

Consistent. The TVSP would promote infill, mixed-use
transit-oriented development and include multiple
pedestrian and bicycle network improvements that would
allow for an active and compact core near Arrow Line
stations. This mixed-use development would allow for
office, commercial, and residential uses within the vicinity of public transit.

Action 4-A.113 Provide streetscape improvements
along the major corridors of Colton Avenue, Texas
Street, and Redlands Boulevard to enhance comfort and
safety for all modes of travel and increase accessibility to and from surrounding areas
Consistent. As discussed in Section 3.0, pedestrian
improvements within the TVSP include enhancement of the sidewalk system along Redlands Boulevard, Texas Street, and Colton Avenue in order to increase pedestrian and
bicycle connectivity and safety and promote multi-modal Action 4-A.114 Establish boulevards along Redlands transportation.

Boulevard and Colton Avenue with pedestrian-oriented
streetscape improvements and ground-floor active uses
Action 4-A.115 Provide pedestrian routes between
offices, neighborhoods, and Downtown
Consistent. As shown on Draft EIR Figure 3-10, the TVSP would include various pedestrian network improvements
that would provide connections between office,
neighborhoods, and the Downtown Village.

Action 4-A.116 Implement bicycle route improvements
that provide strong east-west connections to other Transit Villages as well as north-south connections to improve
access to existing neighborhoods to the north. Routes
would include the Orange Blossom Trail, the Lugonia Trail on New York Street, and a route along Texas Street
Consistent. As shown on Draft EIR Figure 3-11, the TVSP would include provisions for various bicycle infrastructure improvements.

Action 4-A.117 Implement intersection improvements,
including pedestrian improvements, at the I-10
undercrossings at New York and Texas Street to increase comfort and safety for all modes of travel
Consistent. As shown on Draft EIR Figure 3-10, the TVSP would include provisions for various pedestrian
infrastructure improvements, including intersection
improvements.

Action 4-A.118 Ensure safe railway crossings at
Tennessee Street, Texas Street, and New York Street for bicyclists and pedestrians
Consistent. As shown on Draft EIR Figures 3-10 and 3-11, the TVSP would include provisions for various pedestrian and bicycle infrastructure improvements, including
provisions for railway crossings.

Action 4-A.119 Maintain single-family residential
neighborhoods designated as low- and low mediumdensity residential in the General Plan within the TVOZ.

Transition higher density housing when adjacent to these neighborhoods.

Consistent. As discussed in Section 3.0, the Village
Neighborhood 1 and Village Neighborhood 2 districts
would provide for smaller form residential uses and would provide a transition from higher density housing to existing residential neighborhoods.

Action 4-A.120 Complete and implement an update of
the Downtown Specific Plan to create a cohesive town
center with amenities and pedestrian-oriented streets.

Consistent. The TVSP would replace the Downtown Specific Plan and would provide for an increase of amenities and pedestrian accessibility in the Downtown area.

Action 4-A.121 Encourage a centrally-located mix of
uses to promote activity and economic vitality.

Consistent. The TVSP would encourage mixed-use, infill
development within the TVSP area that would be centrallylocated to Arrow Line station and promote activity and economic vitality.

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Action 4-A.122 Maintain a distinctive character that
builds on Downtown’s many historic features and its citrus heritage
Consistent. Implementing mixed-use projects would be
required to be consistent with the design standards set forth in Chapter 4 of the TVSP, which would ensure that they are designed in a manner compatible with surrounding
development, including historic buildings.

Action 4-A.123 Promote the reuse of citrus packing
houses, historic warehouses, and other historic commercial buildings to create a destination for residents and tourist Consistent. The TVSP promotes the reuse of existing,
vacant buildings with mixed-use development. Chapter 4
of the TVSP includes provisions for development and reuse of historic buildings and requires that implementing
developments adhere 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 4-A.124 Ensure accessibility within the Transit
Village to arts and cultural venues and programming.

Consistent. The TVSP includes street, bicycle infrastructure, and pedestrian infrastructure improvements that would
enhance multi-modal connections to cultural venues such as the Redlands Bowl and the Smiley Library.

Action 4-A.129 Improve the I-10 undercrossing at
Eureka Street, Orange Street, and 6th Street to increase comfort and safety for all modes of travel and enhance
north-south circulation.

Consistent. As shown on Draft EIR Figure 3-10, the TVSP would include provisions for multiple pedestrian
infrastructure improvements, including improved I-10
undercrossings.

Action 4-A.131 Provide more multi-family housing for
university students, staff, and other members of the
community in the Mixed Use Core and adjacent
residential areas.

Consistent. Buildout of the TVSP would include the
development of up to 2,400 multi-family dwelling units
within the TVSP area, which would provide an increase of housing in the city.

Action 4-A.132 Create opportunities for ground-floor
commercial uses, such as restaurants and cafes, retail, and professional services to serve university students, staff, and neighborhood residents in the Mixed Use Core.

Action 4-A.133 Promote pedestrian circulation between
the station, homes, schools, and parks, with primary
routes along multi-purpose trails (the Orange Blossom
and Mill Creek Zanja trails), Citrus Avenue, and
University Street
Consistent. As shown on Draft EIR Figure 3-10, the TVSP would include provisions for multiple pedestrian
infrastructure improvements in order to enhance pedestrian connectivity in the TVSP area.

Action 4-A.134 Implement bicycle route improvements
that enhance circulation between the station, homes,
schools, and parks and provide connections to Downtown.

Routes would include the Orange Blossom Trail, the Mill Creek Zanja Trail, and routes on Citrus Avenue,
University Street, and Colton Avenue
Consistent. As shown on Draft EIR Figure 3-11, the TVSP would include provisions for multiple bicycle infrastructure improvements in order to enhance bicycle connectivity in the TVSP area.

Action 4-A.135 Improve the I-10 undercrossing at
Sylvan Boulevard to allow safe trail connections along
the Mill Creek Zanja
Consistent. As shown on Draft EIR Figure 3-10, the TVSP would include provisions for multiple pedestrian
infrastructure improvements, including improved I-10
Action 4-A.136 Improve the I-10 undercrossings at undercrossings.

University Street and Citrus Avenue to allow safe and
comfortable access for vehicles, pedestrians, and cyclists Action 4-A.137 Establish a boulevard along University
Street from I-10 to Colton Avenue.

Consistent. As shown on Draft EIR Figure 3-9, the TVSP
would include provisions for multiple street improvements, including transforming University Street into a gateway and multi-modal street.

Principle 4-P.56 Ensure that public facilities and services are provided in a timely manner to adequately serve
new and existing development.

Consistent. As discussed in Section 5.12, Public Services, buildout of the TVSP would not result in significant impacts related to public services from the increased residential or employee population in the TVSP area. Implementing
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fees in order to ensure that the City can continue to provide adequate public services.

Principle 4-P.58 Coordinate with the Redlands Unified
School District to ensure that facilities and services are provided at a high quality and consistent with the
population’s needs.

Consistent. As discussed in Section 5.12, Public Services, buildout of the TVSP would not result in significant impacts related to school services from the increased residential or employee population in the TVSP area. Implementing
projects would be required to pay all school fees in order to ensure that the Redlands Unified School District can continue to provide adequate school facilities for students.

Action 4-A.148 Coordinate future development with the
City’s Capital Improvement Program to ensure adequate
funding and planning for needed public services and
facilities.

Action 4-A.157 Include the Police and Fire departments
in the review of new developments to provide feedback
on building and site design safety
Consistent. As discussed in Section 5.12, Public Services, implementing projects pursuant to the TVSP would be
required to undergo review by the Redlands Police and
Fire Departments in order to ensure they provide adequate safety features.

Principle 5-P.1 Maintain a cohesive circulation system
through a “layered network” approach promoting
complete streets and mobility for all modes while
emphasizing specific transportation modes for specific
corridors and geographic areas
Consistent. As shown on Draft EIR Figures 3-9, 3-10, and 3-11, the TVSP would include provisions for multiple street, pedestrian infrastructure, and bicycle infrastructure
improvements in order to enhance multi-modal
transportation and connectivity in the TVSP area.

Principle 5-P.4 Support transportation infrastructure
improvements such as safer street crossings and
attractive streetscapes to encourage bicyclists, walkers, and users of mobility device
Principle 5-P.6 Support public health by promoting
active living and supporting safe walking and biking
throughout the city
Principle 5-P.10 Require developers to construct or pay their fair share toward improvements for all travel
modes consistent with the layered network.

Consistent. Implementing development projects would be
required to construct or pay their fair share toward street, pedestrian infrastructure, and bicycle infrastructure
improvements upon review of project designs by the City.

Principle 5-P.13 Ensure streets are designed to
accommodate bicyclists per the Bicycle Master Plan.

Consistent. As shown on Draft EIR Figure 3-11, the TVSP would include provisions for bicycle infrastructure
improvements, per the City’s Bicycle Master Plan, in order to enhance multi-modal transportation and connectivity in the TVSP area.

Principle 5-P.14 Design streets to accommodate various
modes according to roadway classification and reduce
conflicts and safety risks between modes per Figure 5-4.

Consistent. As shown on Draft EIR Figures 3-9, 3-10, and 3-11, the TVSP would include provisions for multiple street, pedestrian infrastructure, and bicycle infrastructure
improvements in order to enhance multi-modal
transportation and connectivity in the TVSP area. These improvements would reduce conflicts between various forms of transportation and promote motorist, pedestrian, and bicyclist safety.

Principle 5-P.15 Incorporate green infrastructure into the design of new roadways and retrofit existing roadways
where appropriate
Consistent. Chapter 4 of the TVSP includes design
guidelines for street improvements, such as guidelines for provision of street trees.

Principle 5-P.16 Strengthen active transportation
circulation routes within Downtown and the Transit
Villages, and to/ from adjacent neighborhoods.

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Action 5-A.1 Maintain and update design standards for
each functional roadway classification per Figure 5-4.

These standards are for a typical midblock application.

Additional turn lanes may be needed at some
intersection approaches. Different standards may govern in specific plan areas and variations are permitted given site conditions and right-of-way availability.

Consistent. Chapter 4 of the TVSP contains design
standards for various roadway classifications and
roadway improvements.

Action 5-A.2 Integrate complete streets and a layered
networks approach into all City streets, traffic standards, plans, and details.

Action 5-A.3 Ensure new street design and potential
retrofit opportunities for existing streets minimize traffic volumes and/or speed as appropriate within residential
neighborhoods without compromising connectivity for
emergency vehicles, bicycles, pedestrians, and users of mobility devices. This could be accomplished through:
• Management and implementation of complete street
strategies, including retrofitting existing streets to foster biking and walking as appropriate;
• Short block lengths, reduced street widths, and/or
traffic calming measures; and
• Providing pedestrians and bicyclists with options where motorized transportation is prohibited
Action 5-A.5 As part of street redesigns, plan for the
needs of different modes – such as shade for
pedestrians, lighting at pedestrian scale, modeappropriate signage, transit amenities, etc Action 5-A.6 Add bike and pedestrian facilities on
roads with excess capacity where such facilities do not exist, using supporting transportation plans as guidance.

Excess capacity includes street right-of-ways or
pavement widths beyond the standards, or excess
capacity in roadways based on actual vehicular travel
versus design capacity.

Action 5-A.7 Add new streets to create a finergrained,
pedestrian-scaled road network where the roadway
network is characterized by particularly long blocks,
connecting residential areas to parks and Transit Village cores. Ensure the street systems in Transit Villages support development of connected and accessible communities.

Action 5-A.14 Close the gaps in the sidewalk network
where streets are built out but sidewalks are not
complete.

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

Consistent. Implementing projects would undergo
development plan review, including review of emergency
access points, in order to ensure that proposed roadways or driveways meet the requirements of the California Fire Code.

Principle 5-P.17 Provide a safe, direct, and healthful
pedestrian environment through means such as providing
separate pedestrian-ways in parking lots, avoiding
excessive driveway widths, and providing planting strips between sidewalks and streets where feasible.

Consistent. As shown on Figures 3-9 and 3-10, the TVSP
would include provisions for multiple street and pedestrian infrastructure improvements in order to enhance multimodal transportation and connectivity in the TVSP area. In addition, Chapter 4 of the TVSP provides design guidelines for pedestrian infrastructure improvements that would
serve to enhance the pedestrian network within the TVSP area. The pedestrian network would provide connections
Principle 5-P.18 Encourage creative walking paths
pursuant to City planning codes, local, State, and federal laws.

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Principle 5-P.19 Enhance street lighting for pedestrians where current lighting is inadequate.
between the three Transit Villages and neighborhoods
outside of the TVSP area.

Principle 5-A.20 Provide pedestrian routes between
offices, neighborhoods, Downtown, and Transit Villages.

Plan for direct connections from the interiors of
residential tracts to neighboring parks, schools, retail, and other services using sidewalks, trails, and paseos.

Principle 5-A.22 Include amenities such as shade trees, transit shelters and other transit amenities, benches, trash and recycling receptacles, bollards, public art, and
directional signage that can enhance the pedestrian
experience.

Principle 5-P.20 Establish and maintain a comprehensive network of on- and off-roadway bike routes to
encourage the use of bikes for both commuter and
recreational trips.

Consistent. As shown on Draft EIR Figures 3-9 and 3-11, the TVSP would include provisions for multiple street and bicycle infrastructure improvements in order to enhance multi-modal transportation and connectivity in the TVSP area. In addition, Chapter 4 of the TVSP provides design guidelines for bicycle infrastructure improvements that would serve to enhance the bicycle network within the TVSP area. The bicycle network would provide connections
between the three Transit Villages, Arrow Line station, and neighborhoods outside of the TVSP area.

Principle 5-P.21 Develop bike routes that provide access to rail stations, Downtown, schools, parks, the University, employment, and shopping destinations.

Action 5-A.25 Implement bicycle and trail improvements
that provide strong east-west connections between
Transit Villages and in the city’s wider bicycle network.

Routes would include the Orange Blossom Trail, the
Mission Creek Zanja Trail, routes on Colton Avenue and
Citrus Avenue, Santa Ana River Trail, and the San
Timoteo Canyon Trail.

Action 5-A.26 Implement bicycle and trail improvements
that provide strong north-south connections, especially with major east west trails, including routes on Mountain View Avenue, California Street, Nevada Street,
Alabama Street, Texas Street, New York Street, Orange
Street, Church Street, Dearborn Street, and Wabash
Avenue.

Action 5-A.44 Establish new boulevards Downtown and
in the Transit Villages that include planted center
medians, accommodations for transit, wider sidewalks,
and amenities for pedestrians
Consistent. As shown on Draft EIR Figures 3-9 and 3-10, the TVSP would include provisions for multiple street and pedestrian infrastructure improvements in order to enhance multi-modal transportation and connectivity in the TVSP area. In addition, Chapter 4 of the TVSP provides design guidelines for pedestrian infrastructure improvements that would serve to enhance the pedestrian network within the TVSP area. The pedestrian network would provide
connections between the three Transit Villages, Arrow Line stations, bus routes, and neighborhoods outside of the TVSP area.

Action 5-A.67 Encourage convenient and safe
pedestrian linkages to and from transit service to provide better first-mile and last-mile connectivity
Action 5-A.68 Provide for direct pedestrian paths and
access from new developments to the nearest public
transportation stop.

Action 5-A.73 Provide adequate parking availability
Downtown for residents, commuters, visitors, and
shoppers throughout the day.

Consistent. Chapter 4 of the TVSP includes parking design standards and parking requirements that include provisions for parking structures and shared parking, which would
ensure that there is an adequate parking supply within the TVSP area.

Action 5-A.74 Design parking to meet applicable urban
design goals from area plans and minimize negative
impacts on pedestrians, bicyclists, and transit users.

Action 5-A.77 Encourage developers to meet their
minimum parking requirements via shared parking
between uses, payment of in-lieu fees, joint parking
districts, or off-site parking within a reasonable walking time of 10 minutes or less
Principle 6-P.10 Landscape public areas using native
vegetation where practical.

Consistent. Chapter 4 of the TVSP includes design
guidelines for landscaping, which encourage the use of
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native and drought-tolerant vegetation by implementing
developments.

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

Consistent. As discussed in Section 5.8, Hydrology and
Water Quality, implementing developments would be
required to prepare a Water Quality Management Plan
that includes post-development BMPs and a Stormwater
Pollution Prevention Plan that includes construction BMPs in order to ensure that implementing projects would not result in any water quality issues.

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

Consistent. Chapter 4 of the TVSP includes design
guidelines for landscaping, which encourage the use of
native and drought-tolerant vegetation by implementing
developments.

Action 7-P.1 Promote active lifestyles and community
health by furthering access to trails, parks, public open space, and other recreational opportunities.

Consistent. As shown on Draft EIR Figures 3-9, 3-10, and 3-11, the TVSP would include provisions for multiple street, pedestrian infrastructure, and bicycle infrastructure
improvements in order to enhance multi-modal
transportation and access to trails, parks, and public open space in the TVSP area.

Principle 7-P.10 Equitably share the cost of parkland
creation and maintenance between existing and new
residents, businesses, and property owners
Consistent. As discussed in Section 5.13, Recreation,
buildout of the TVSP would not result in significant impacts related to recreational facilities from the increased
residential or employee population in the TVSP area.

Implementing projects would be required to pay all
development impact fees in order to ensure that the City can continue to provide adequate recreational facilities.

Action 7-A.3 Provide 5 acres of park area for each
1,000 Planning Area residents, and additional parkland
for specialized, and low-use park acreage.

Consistent. As discussed in Section 5.13, Recreation,
buildout of the TVSP would not result in significant impacts related to recreational facilities from the increased
residential or employee population in the TVSP area.

Implementing projects would be required to pay all
development impact fees in order to ensure that the City can continue to provide adequate recreational facilities.

Additionally, as discussed in Section 3.0, buildout of the TVSP would result in the increase of parkland in the TVSP area by 280,000 SF.

Principle 7-P.16 Ensure that all Redlands residents have access to a variety of transportation and physical activity options that enhance health and that work for diverse
lifestyles, incomes, and abilities
Consistent. As shown on Draft EIR Figures 3-9, 3-10, and 3-11, the TVSP would include provisions for multiple street, pedestrian infrastructure, and bicycle infrastructure
improvements in order to enhance multi-modal
transportation and access to trails, parks, and public open space in the TVSP area.

Principle 7-P.17 Achieve more walkable, livable
neighborhoods by expanding the multimodal
transportation system and creating a safe, pedestrianoriented environment Action 7-A.35 Implement street design features that
facilitate walking and biking in both new and established areas. Require a mini - mum standard of these features
for all new developments.

Action 7-A.39 Install appropriate facilities along streets and at roadway intersections to improve and insure
pedestrian safety.

Action 7-A.89 Require adherence to applicable
buildings codes and standards in accordance with Fire
Consistent. Implementing projects pursuant to the TVSP
would undergo development review pursuant to the TVSP
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Hazard Overlay Districts, California Fire Code, and the California Building Code.
in order to ensure that the development would adhere to all applicable building codes and standards. Proposed
development plans would be reviewed by the City’s Fire
Department in order to ensure that new development
minimizes potential fire hazards through building design.

Action 7-A.93 Require that new development minimizes
risks to life and property from fire hazard through:
• Assessing site-specific characteristics such as
topography, slope, vegetation type, wind patterns etc.; • Siting and designing development to avoid hazardous
locations;
• Incorporating fuel modification and brush clearance
techniques in accordance with applicable fire safety
requirements and carried out in a manner which reduces
impacts to environmentally sensitive habitat to the
maximum feasible extent;
• Using appropriate building materials and design
features to ensure the minimum amount of required fuel
modification; and
• Using fire-retardant, native plant species in
landscaping.

Action 7-A.95 Coordinate with the Redlands Fire
Department and other fire prevention agencies to review all applications for new development. The Fire
Department’s review should ensure compliance with fire
safety regulations and assess potential impacts to
existing fire protection services and the need for
additional and expanded services
Principle 7-P.41 Ensure that new development is
compatible with the noise environment by continuing to
use potential noise exposure as a criterion in land use planning
Consistent. As discussed in Section 5.10, Noise, new
development would be required to be compatible with the existing noise environment through implementation of
Mitigation Measures NOI-5 and NOI-6. Implementing
developments within areas where projected noise levels
are higher would be required to submit an acoustical
analysis demonstrating that the project would meet the
applicable noise standards.

Action 7-A.136 Require a noise analysis be conducted
for all development proposals located where projected
noise exposure would be other than “clearly” or
“normally compatible” as specified in Table 7-10.

Action 7-A.137 For all projects that have noise exposure levels that exceed the standards in Table 7-10, require site planning and architecture to incorporate noiseattenuating features. With mitigation, development should meet the allowable outdoor and indoor noise
exposure standards in Table 7-11. When a building’s
openings to the exterior are required to be closed to
meet the interior noise standard, mechanical ventilation shall be provided
Action 7-A.138 Continue to maintain performance
standards in the Municipal code to ensure that noise
generated by proposed projects is compatible with
surrounding land uses
Consistent. As discussed in Section 5.10, Noise, new
development would be required to be compatible with the existing noise environment through implementation of
Mitigation Measure NOI-7. Implementing non-residential
developments would be required to prepare a noise
analysis in order to ensure that the proposed project would not result in impacts to sensitive receptors.

Action 9.0w Limit hours for all construction or demolition work where site-related noise is audible beyond the site boundary
Consistent. As discussed in Section 5.10, Noise, new
development would be constructed pursuant to the
Redlands Municipal Code, which limits hours of construction.

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

Consistent. As discussed in Section 5.2, Air Quality,
Mitigation Measure AQ-10 is included, which requires
development projects to provide modeling of the regional and the localized emissions (NOX, CO, PM10, and PM2.5)
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to be limited to ensure that there would be no impacts to sensitive receptors.

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. Implementing projects pursuant to the TVSP
would be required to implement Mitigation Measure AQ7, which requires projects be designed to achieve 5 percent (%) efficiency beyond the incumbent California Building Code Title 24 requirements.

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. Chapter 4 of the TVSP includes provisions for landscaping, such as street trees, to be included by
implementing projects.

Action 8-A.37 Promote design in new development that
incorporates space for recycling containers and other
waste diversion facilities
Consistent. Implementing projects pursuant to the TVSP
would be required to provide for recycling, in line with City Municipal Code standards.

Action 8-A.39 Continue implementation and
enforcement of the California Building and Energy codes to promote energy efficient building design and
construction.

Environmental Design (LEED) certification program for the design, operation, and construction of high-performance green buildings
City of Redlands Municipal Code
Upon adoption of the proposed Specific Plan, the development regulations and design criteria within the Specific Plan would apply to the project area and would establish the applicable zoning regulations and development standards. The Specific Plan would become the main land use implementation tool for the project area. In the event of any conflict between the requirements of the zoning code and the standards contained within the adopted Specific Plan, the requirements of the Specific Plan shall govern, and when the provisions of a Specific Plan are silent on a specific matter, the regulations set forth in the City’s Municipal Code shall apply. As such, the proposed Specific Plan would not result in conflicts with the City of Redlands zoning code, and impacts would be less than significant.

5.9.7 CUMULATIVE IMPACTS
The geographic context for this cumulative analysis includes the City of Redlands in relation to the City’s General Plan. Cumulative development would result in intensity increases to existing land use patterns through implementation of mixed-use, infill and redevelopment. Cumulative development would also be subject to site-specific environmental and planning reviews that would address consistency with adopted General Plan goals, objectives, and policies, as well as with the City’s Zoning Code. As part of environmental review, projects would be required to provide mitigation for any inconsistencies with the General Plan and environmental policies that would result in adverse physical environmental effects. The cumulative projects as a whole, would result in a more intensely developed built environment than currently exists, and would be required to be consistent with local General Plan policies.

While cumulative projects could include General Plan amendments and/or zone changes, modifications to existing land uses that require such amendments do not necessarily represent an inherent negative effect on the environment, particularly if the proposed changes involve changes in types and intensity of uses, rather than eliminating application of policies that were specifically adopted for the purpose of avoiding or mitigating environmental effects. Determining whether any future project might include such amendments and determining the cumulative effects of any such amendments would be speculative since it cannot be known what applications that are not currently filed might request. Thus, it is expected that the land uses of Redlands Regular Meeting of 10-18-22 882 of 1815
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cumulative projects would be consistent with policies that avoid an environmental effect; therefore, cumulatively considerable impacts from cumulative projects related to policy consistency would not occur.

5.9.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

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

Plans, Programs, or Policies
None.

5.9.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, Impact LU-2 would be less than significant:

5.9.10 MITIGATION MEASURES
No mitigation measures are required.

5.9.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Existing regulatory programs would reduce potential impacts associated with land use and planning to a level that is less than significant. Therefore, no significant unavoidable adverse impacts related to land use and planning would occur.

REFERENCES
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 10-18-22 883 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 5.10 Noise City of Redlands 5.10-1
Draft EIR
July 2022

5.10 Noise

5.10.1 INTRODUCTION
This Draft EIR section evaluates the potential noise and vibration impacts that would result from implementation of the proposed TVSP. It discusses the existing noise environment within and around the TVSP area as well as the regulatory framework for regulation of noise. This section analyzes the effect of the proposed Project on the existing ambient noise environment during demolition, construction, and operational activities; and evaluates the proposed Project’s noise effects for consistency with relevant local agency noise policies and regulations. This section includes data from the following:
• 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 Noise Impact and Vibration Analysis, Urban Crossroads, 2022, Appendix G.

Noise and Vibration Terminology
Various noise descriptors are utilized in this EIR analysis, and are summarized as follows:
dB: Decibel, the standard unit of measurement for sound pressure level. dBA: A-weighted decibel, an overall frequency-weighted sound level in decibels that approximates the frequency response of the human ear.

Leq: The equivalent sound level, which is used to describe noise over a specified period of time, typically 1 hour, in terms of a single numerical value. The Leq of a time-varying signal and that of a steady signal are the same if they deliver the same acoustic energy over a given time. The Leq may also be referred to as the average sound level.

Lmax: The instantaneous maximum noise level experienced during a given period of time.

Lmin: The instantaneous minimum noise level experienced during a given period of time.

Lx: The sound level that is equaled or exceeded “x” percent of a specified time period. The “x” thus represents the percentage of time a noise level is exceeded. For instance, L50 and L90 represents the noise levels that are exceeded 50 percent and 90 percent of the time, respectively.

Ldn: Also termed the “day-night” average noise level (DNL), Ldn is a measure of the average of Aweighted sound levels occurring during a 24-hour period, accounting for the greater sensitivity of most people to nighttime noise by weighting noise levels at night (penalizing” nighttime noises). Noise between 10:00 p.m. and 7:00 a.m. is weighted by adding 10 dBA to take into account the greater annoyance of nighttime noises.

CNEL: The Community Noise Equivalent Level, which, similar to the Ldn, is the average A-weighted noise level during a 24-hour day that is obtained after an addition of 5 dBA to measured noise levels between the hours of 7:00 p.m. to 10:00 p.m. and after an addition of 10 dBA to noise levels between the hours of 10:00 p.m. to 7:00 a.m. to account for noise sensitivity in the evening and nighttime, respectively.

The “ambient noise level” is the background noise level associated with a given environment at a specified time and is usually a composite of sound from many sources from many directions.

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Effects of Noise
Noise is generally loud, unpleasant, unexpected, or undesired sound that is typically associated with human activity that is a nuisance or disruptive. The effects of noise on people can be placed into four general categories:
• Subjective effects (e.g., dissatisfaction, annoyance) • Interference effects (e.g., communication, sleep, and learning interference) • Physiological effects (e.g., startle response)
• Physical effects (e.g., hearing loss)
Although exposure to high noise levels has been demonstrated to cause physical and physiological effects, the principal human responses to typical environmental noise exposure are related to subjective effects and interference with activities. Interference effects refer to interruption of daily activities and include interference with human communication activities, such as normal conversations, watching television, telephone conversations, and interference with sleep. Sleep interference effects can include both awakening and arousal to a lesser state of sleep. With regard to the subjective effects, the responses of individuals to similar noise events are diverse and are influenced by many factors, including the type of noise, the perceived importance of the noise, the appropriateness of the noise to the setting, the duration of the noise, the time of day and the type of activity during which the noise occurs, and individual noise sensitivity.

In general, the more a new noise level exceeds the previously existing ambient noise level, the less acceptable the new noise level will be by those hearing it. With regard to increases in A-weighted noise levels, the following relationships generally occur:
• Except in carefully controlled laboratory experiments, a change of 1 dBA cannot be perceived. • Outside of the laboratory, a 3-dBA change in noise levels is considered to be a barely perceivable difference.
• A change in noise levels of 5 dBA is considered to be a readily perceivable difference. • A change in noise levels of 10 dBA is subjectively heard as doubling of the perceived loudness.

Noise Attenuation
Stationary point sources of noise, including mobile sources such as idling vehicles, attenuate (lessen) at a rate of 6 dBA per doubling of distance from the source over hard surfaces to 7.5 dBA per doubling of distance from the source over hard surfaces, depending on the topography of the area and environmental conditions (e.g., atmospheric conditions, noise barriers [either vegetative or manufactured]). Thus, a noise measured at 90 dBA 50 feet from the source would attenuate to about 84 dBA at 100 feet, 78 dBA at 200 feet, 72 dBA at 400 feet, and so forth. Widely distributed noise, such as a large industrial facility spread over many acres or a street with moving vehicles, would typically attenuate at a lower rate, approximately 4 to 6 dBA per doubling of distance from the source.

Hard sites are those with a reflective surface between the source and the receiver, such as asphalt or concrete surfaces or smooth bodies of water. No excess ground attenuation is assumed for hard sites and the changes in noise levels with distance (drop-off rate) is simply the geometric spreading of the noise from the source. Soft sites have an absorptive ground surface such as soft dirt, grass, or scattered bushes and trees. In addition to geometric spreading, an excess ground attenuation value of 1.5 dBA (per doubling distance) is normally assumed for soft sites. Line sources (such as traffic noise from vehicles) Redlands Regular Meeting of 10-18-22 885 of 1815
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attenuate at a rate between 3 dBA for hard sites and 4.5 dBA for soft sites for each doubling of distance from the reference measurement.

Fundamentals of Vibration
Vibration is energy transmitted in waves through the ground or man-made structures. These energy waves generally dissipate with distance from the vibration source. There are several different methods that are used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal. The PPV is most frequently used to describe vibration impacts to buildings but is not always suitable for evaluating human response (annoyance) because it takes some time for the human body to respond to vibration signals. Instead, the human body responds to average vibration amplitude often described as the root mean square (RMS). The RMS amplitude is defined as the average of the squared amplitude of the signal and is most frequently used to describe the effect of vibration on the human body. Decibel notation (VdB) is commonly used to measure RMS. VdB serves to reduce the range of numbers used to describe human response to vibration. Typically, ground-borne vibration generated by man-made activities attenuates rapidly with distance from the source of the vibration. Sensitive receivers for vibration include structures (especially older masonry structures), people (especially residents, the elderly, and sick), and vibration-sensitive equipment.

The background vibration-velocity level in residential areas is generally 50 VdB. Ground-borne vibration is normally perceptible to humans at approximately 65 VdB. For most people, a vibration-velocity level of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels.

Typical outdoor sources of perceptible ground-borne vibration are construction equipment, steel-wheeled trains, and traffic on rough roads. If a roadway is smooth, the ground-borne vibration is rarely perceptible.

The range of interest is from approximately 50 VdB, which is the typical background vibration-velocity level, to 100 VdB, which is the general threshold where minor damage can occur in fragile buildings.

5.10.2 REGULATORY SETTING

5.10.2.1 Federal Regulations
Federal Highway Administration
Proposed federal or federal-aid highway construction projects at a new location, or the physical alteration of an existing highway that significantly changes either the horizontal or vertical alignment, or increases the number of through-traffic lanes, requires an assessment of noise and consideration of noise abatement per 23 CFR Part 772, “Procedures for Abatement of Highway Traffic Noise and Construction Noise.” The Federal Highway Administration (FHWA) has adopted noise abatement criteria (NAC) for sensitive receivers such as picnic areas, recreation areas, playgrounds, active sport areas, parks, residences, motels, hotels, schools, churches, libraries, and hospitals when “worst-hour” noise levels approach or exceed 67 dBA Leq. Caltrans has further defined approaching the NAC to be 1 dBA below the NAC for noisesensitive receivers identified as Category B activity areas (e.g., 66 dBA Leq is considered approaching the NAC).

US Environmental Protection Agency
In addition to FHWA standards, the United States Environmental Protection Agency (EPA) has identified the relationship between noise levels and human response. The EPA has determined that over a 24-hour period, an Leq of 70 dBA will result in some hearing loss. Interference with activity and annoyance will not occur if exterior levels are maintained at an Leq of 55 dBA and interior levels at or below 45 dBA. While these levels are relevant for planning and design and useful for informational purposes, they are not land Redlands Regular Meeting of 10-18-22 886 of 1815
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use planning criteria because they do not consider economic cost, technical feasibility, or the needs of the community.

The EPA also set 55 dBA Ldn as the basic goal for exterior residential noise intrusion. However, other federal agencies, in consideration of their own program requirements and goals, as well as difficulty of actually achieving a goal of 55 dBA Ldn, have settled on the 65 dBA Ldn level as their standard. At 65 dBA Ldn, activity interference is kept to a minimum, and annoyance levels are still low. It is also a level that can realistically be achieved.

Occupational Health and Safety Administration
The federal government regulates occupational noise exposure common in the workplace through the Occupational Health and Safety Administration (OSHA) under the EPA. Such limitations would apply to the operation of construction equipment and could also apply to any proposed industrial land uses. Noise exposure of this type is dependent on work conditions and is addressed through a facility’s Health and Safety Plan, as required under OSHA, and is therefore not addressed further in this analysis.

US Department of Housing and Urban Development
The US Department of Housing and Urban Development (HUD) has set a goal of 65 dBA Ldn as a desirable maximum exterior standard for residential units developed under HUD funding. (This level is also generally accepted within the State of California.) While HUD does not specify acceptable interior noise levels, standard construction of residential dwellings typically provides in excess of 20 dBA of attenuation with the windows closed. Based on this premise, the interior Ldn should not exceed 45 dBA.

5.10.2.2 State Regulations
Title 24, California Building Code
State regulations related to noise include requirements for the construction of new hotels, motels, apartment houses, and dwellings other than detached single-family dwellings that are intended to limit the extent of noise transmitted into habitable spaces. These requirements are collectively known as the California Noise Insulation Standards and are found in California Code of Regulations, Title 24 (known as the Building Standards Administrative Code), Part 2 (known as the California Building Code), Appendix Chapters 12 and 12A. For limiting noise transmitted between adjacent dwelling units, the noise insulation standards specify the extent to which walls, doors, and floor ceiling assemblies must block or absorb sound. For limiting noise from exterior sources, the noise insulation standards set forth an interior standard of DNL 45 dBA in any habitable room and, where such units are proposed in areas subject to noise levels greater than DNL 60 dBA require an acoustical analysis demonstrating how dwelling units have been designed to meet this interior standard. If the interior noise level depends upon windows being closed, the design for the structure must also specify a ventilation or air conditioning system to provide a habitable interior environment.

The mandatory measures for non-residential buildings states that new construction shall provide an interior noise level that does not exceed an hourly equivalent level of 50 dBA Leq in occupied areas during any hour of operation. Title 24 standards are included in the City’s Municipal Code in Chapter 15 and are enforced through the City’s development permitting process.

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

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Principle 7-P.40 Protect public health and welfare by eliminating existing noise problems where feasible and by preventing significant degradation of the future acoustic environment.

Principle 7-P.41Ensure that new development is compatible with the noise environment by continuing to use potential noise exposure as a criterion in land use planning.

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

Action 7-A.136 Require a noise analysis be conducted for all development proposals located where projected noise exposure would be other than “clearly” or “normally compatible” as specified in Table 7-10.

Action 7-A.137 For all projects that have noise exposure levels that exceed the standards in Table 7-10, require site planning and architecture to incorporate noise-attenuating features. With mitigation, development should meet the allowable outdoor and indoor noise exposure standards in Table 7-11. When a building’s openings to the exterior are required to be closed to meet the interior noise standard, mechanical ventilation shall be provided.

Action 7-A.138 Continue to maintain performance standards in the Municipal code to ensure that noise generated by proposed projects is compatible with surrounding land uses.

Action 7-A.141 Require all future developments within the city that fall within the required noise screening distances, as specified in the Federal Transit Authority (FTA) Noise and Vibration Manual, of the Union Pacific railroad in San Timoteo Canyon to conduct a detailed noise analysis.

Table 7-10 (included as Table 5.10-1) of the General Plan Healthy Community Element identifies the specific criteria to evaluate proposed developments based on exterior and interior noise level limits for land uses and requires a noise analysis to determine needed mitigation measures if necessary. The Healthy Community Element identifies schools, hospitals, places of worship, and homes as a noise-sensitive land use.

Also, as shown on Table 5.10-2, the City of Redlands General Plan has an exterior (outdoor) noise standard of 60 dBA CNEL related to private yards of single-family residences as measured at the property line; multifamily private patios or balconies which is served by a means of exit from inside; mobile home parks; hospital patios; park picnic areas; school playgrounds; hotel and recreational areas.

In addition, the General Plan includes an interior noise level limit of 45 dBA CNEL for residential land uses.

Measure U. The City of Redlands General Plan incorporates the implementing noise polices from Measure U. Measure U was certified by The City of Redlands in 1997 to address impacts from growth. The measure includes Project applicable provisions related to potential noise impacts and mitigation, as listed below.

Measure U 9.0e Use the criteria specified in GP Table 9.1 [Table 7-10] to assess the compatibility of proposed land uses with the projected noise environment and apply the noise standards in GP Table 9.2 [Table 7-11], which prescribe interior and exterior noise standards in relation to specific land uses. Do not approve projects that would not comply with the standards in GP Table 9.2 [Table 7-1]. These tables are the primary tools which allow the City to ensure noise-integrated planning for compatibility between land uses and outdoor noise.

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Measure U 9.0f Require a noise impact evaluation based on noise measurements at the site for all projects in Noise Referral Zones (B, C, or D) as shown on GP Table 9.1 [Table 7-10] and on GP Figure 9.1 [Figure 7-9] or as determined from tables in the Appendix, as part of the project review process. Should measurements indicate that unacceptable noise levels will be created or experienced, require mitigation measures based on a detailed technical study prepared by a qualified acoustical engineer (i.e., a Registered Professional Engineer in the State of California with a minimum of three years’ experience in acoustics).

Measure U 9.0h Minimize potential transportation noise through proper design of street circulation, coordination of routing, and other traffic control measures.

Measure U 9.0i Require construction of barriers to mitigate sound emissions where necessary or where feasible and encourage use of walls and berms to protect residential or other noise sensitive land uses that are adjacent to major roads, commercial, or industrial areas.

Measure U 9.0j Require the inclusion of noise mitigation measures in the design of new roadway projects.

Measure U 9.0s Require mitigation to ensure that indoor noise levels for residential living spaces not exceed 45 dB LDN/CNEL due to the combined effect of all exterior noise sources.

Measure U 9.0t Require proposed commercial projects near existing residential land use to demonstrate compliance with the Community Noise Ordinance prior to approval of the project.

Measure U 9.0u Require all new residential projects or replacement dwellings to be constructed near existing sources of non-transportation noise (including but not limited to commercial facilities or public parks with sports activities) to demonstrate via an acoustical study conducted by a Registered Engineer that the indoor noise levels will be consistent with the limits contained in the Community Noise Ordinance.

Measure U 9.0v Consider the following impacts as possibly “significant”:
• An increase in exposure of four or more dB if the resulting noise level would exceed that described as clearly compatible for the affected land use, as established in GP Table 9.1 [Table 7-10] and GP Table 9.2 [Table 7-11];
• Any increase of six dB or more, due to the potential for adverse community response.

Measure U 9.0w Limit hours for all construction or demolition work where site-related noise is audible beyond the site boundary.

Measure U 9.0y Minimize impacts of loud trucks by requiring that maximum noise levels due to single events be controlled to 50 dB in bedrooms and 55 dB in other habitable spaces.

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Table 5.10-1: City of Redlands General Plan Noise/Land Use Compatibility Matrix Source: City of Redlands General Plan Noise Element, Chapter 7 Healthy Community, Section 7.5 Noise, Table 7-10. land Use Categories
Categories

RESID ENTIAL

COMMERC IAL
Reg ional, District
COM MERCIAL Regiona l, Vill ag e
District, Special

COM MERC IAL

INDUSTRIAL

INSTITUTION AL
COM MERC IAL Recreation

INSTITUTION AL
Civic Center
COMMERCIAL Recreation
COMMERCIAL Gene ral, Special

INDUSTRIAL,

INSTITUTION AL
INSTITUTION AL General

OPEN SPAC E

AGRICU LTU RE
Zone A
Uses
Single Family, Duplex Multiple Family
Mo bile Homes
Hotel, Motel, Transient Lodging
Commercial Retail, Bank, Restaurant, Movie Theater
Office Bu ilding, Rese arch & Dev., Professional Offices, City Office Building
Amphitheater, Concert Hall, Auditorium, Meeting Hall
Childrens Amusement Park, Miniature Golf Course,
Go -c an Track, Equestrian Cente r, Sports Club
Automobil e Service Station, Au to Dealership,
Manufact\J ring, Warehousing , Wholesale, Utilities
Hospital, Chu rch, Library, Schools Classroom
Parks
Go lf Course, Ce mete ries,
Nature Centers, Wildlife Reserves, Wildlife Habitat
Ag riculture
<
A
A
A
A
A
B
A
A
A
A
A
A
60 A
A
A
A
A
A
Community Noise Equivalent l evel ICNELI
65 A
A
B
A
A
A
70 A
A
A
75 80
B
B
A
85 >
B B
B B
A A

CLEAR LY COM PATIBLE
Specified land use is satisfac tory, based upon the ass umption that any buildings involved are of norma l conventional construction wit hout any special noise insu lation re qu irements.

ZONEB

NORMALLY COMPATIBLE
New construction or developme nt should be underta ken only after detailed analysis of the no ise reduction requirements are made and neede d noise insulation features in the design are determi ned. Conve ntiona l construction, with closed windows and fres h air su pply systems or air conditioning, will norma lly suffi ce.

New construction or developme nt should ge nerally be discourage d. If new construction or development does proceed , a detailed analysis of noise reduction require ments must be mad e and needed noise insulation features inc lud ed in the design .

New construction or developme nt should generally not be unden ake n.

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Table 5.10-2: City of Redlands General Plan Interior and Exterior Noise Standards Source: City of Redlands General Plan Noise Element, Chapter 7 Healthy Community, Section 7.5 Noise, Table 7-11.

Land Use Categories
Community Noise Equivalent Level (CNEL) Energy
Average CNEL
Uses lnterior1 Exterior2

RESIDENTIAL
Single Family, Duplex, Multiple Fam ily
Mobile Home

COMMERCIAL, INDUSTRIAL, INSTITUTIONAL
Hotel, Motel, Transient Lodg ing
Commercial Retail, Bank Restau rant
Office Building, Research & Development, Professional
Offices, City Office Building
Amphitheater, Concert Hall, Auditorium, Meeting Hal l
Gymnasium (Mu ltipurpose)
Sports Club
Manufacturing, Wa rehousing, Wholesale, Utilities
Movie Theaters

INSTITUTIONAL
Hospital, Schools classrooms

OPEN SPACE
Parks
Notes:
45 3
45 55
50 45
50 55
60 45
45 * CN EL (Community Noise Equivalent Leve l) - The average equivalent A-we ighted sound level during a 24 hou r day, obtained after addition of approximately five decibels to sound levels in the even ing from 7 pm to 10 pm and ten decibels to sound leve ls at night after 10 pm and before 7 am.

1. Indoor environment excluding bathrooms, toilets, closets, corridors.

2. Outdoor environment limited to private yard of sing le fami ly as measured at the property line; multifamily private patio or balcony which is served by a means of exit from inside; mobile home park; hospital pa tio; park picn ic area; school playground; hotel and recreationa l area.

3. Noise level requirement with open windows, if they are used to meet natural ventilation requirement.

4. Exterior noise level shou ld be such that interior level will not exceed 45 CN EL. 5 . Except those areas affected by aircraft noise.

See also Policy 9.0s
Source: Mestre Greve Associates.
60 604
65'
60 60
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City of Redlands Municipal Code
The City of Redlands Municipal Code Chapter 8.06 establishes noise standards by land use. For the noisesensitive residential uses, Municipal Code Section 8.06.070[A] identifies the base exterior noise level standard of 60 dBA Leq during the daytime hours (7:00 a.m. to 10:00 p.m.) and 50 dBA Leq during the nighttime (10:00 p.m. to 7:00 a.m.) hours. As shown on Table 5.10-3, higher noise levels are allowed for shorter periods of time.

Table 5.10-3: City of Redlands Operational Noise Standards Land
Use
Time
Period
Exterior Noise Level Standards (dBA)
L50
(30 mins)
L25
(15 mins)
L8
(5 mins)
L2
(1 min)
Lmax
(0 min)
Residential Daytime 60 65 70 75 80
Nighttime 50 55 60 65 70
Commercial Daytime 65 70 75 80 85
Nighttime 60 65 70 75 80
Industrial Anytime 75 80 85 90 95
Source: City of Redlands Municipal Code, Section 8.06.070 [A]-Table 1. Section 8.06.070[C] states that if the measured ambient level exceeds the allowable noise exposure standard within any of the first four noise limit categories above, the allowable noise exposure standard shall be adjusted in five dB increments in each category as appropriate to encompass or reflect said ambient noise level. The percent noise level is the level exceeded "n" percent of the time during the measurement period. L50 is the noise level exceeded 50% of the time. "Daytime" = 7:00 a.m. to 10:00 p.m.; "Nighttime" = 10:00 p.m. to 7:00 a.m.

In addition, Municipal Code Section 8.06.080 identifies the maximum permissible interior noise levels. For noise-sensitive residential uses, Municipal Code Section 8.06.080[B] identifies the interior noise level standard of 45 dBA. For commercial uses, Municipal Code Section 8.06.080[B] identifies the interior noise level standard of 50 dBA.

In addition, Municipal Code Section 8.06.070[B] provides noise standards based on the volume of noise and the period of time of the noise, as listed below:

1. The exterior noise standard of the applicable land use category for a cumulative period of 30 minutes in any hour (L50); or

2. The exterior noise standard of the applicable land use category, plus 5 dBA, for a cumulative period of more than 15 minutes in any hour (L₂₅); or

3. The exterior noise standard of the applicable land use category, plus 10 dBA, for a cumulative period of more than 5 minutes in any hour (L8); or

4. The exterior noise standard of the applicable land use category, plus 15 dBA, for a cumulative period of more than 1 minute in any hour (L2).

5. The exterior noise standard for the applicable land use category, plus 20 dBA, or the maximum measured ambient noise level, for any period of time (Lmax).

In addition, Section 8.06.070[C] states that if the measured ambient level exceeds the allowable noise exposure standard within any of the first four noise limit categories above, the allowable noise exposure standard shall be adjusted in five dB increments in each category as appropriate to encompass or reflect said ambient noise level. In the event the ambient noise level exceeds the fifth noise limit category, the maximum allowable noise level under this category shall be increased to reflect the maximum ambient noise level. In effect, when the ambient noise levels exceed the base exterior noise level limits, the noise level standard shall be adjusted as appropriate to encompass or reflect the ambient noise level.

Municipal Code Section 8.06.090(F) states that construction activity is considered exempt from the noise level standards between the hours of 7:00 a.m. to 6:00 p.m. Monday to Saturdays; with no activity allowed on Sundays or holidays.

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Municipal Code, Section 8.06.020, defines the vibration perception threshold as 0.01 inches per second (in/sec) RMS.

5.10.3 ENVIRONMENTAL SETTING
Sensitive Receptors
Noise sensitive receptors are generally defined as locations where people reside or where the presence of unwanted sound could otherwise adversely affect the use of the land. Noise-sensitive land uses are generally considered to include: residences, schools, hospitals, and recreation areas. Sensitive receptors are located throughout the TVSP area.

Existing Noise Levels
To assess the existing noise levels, 24-hour noise level measurements were taken at 10 locations near sensitive receivers in the vicinity of the TVSP area as shown in Figure 5.10-1. The field survey noted that noise within the TVSP area is generally characterized by vehicle traffic on area roadways and operation of the rail line and transit stations. A description of these locations and the existing noise levels are provided in Table 5.10-4. As shown, ambient noise levels range from 62.9 to 73.4 CNEL throughout the TVSP area.

Table 5.10-4: Existing Ambient Noise Measurement Results Location
TVSP
Land
Use
Description
Energy Average
Noise Level
(dBA Leq) CNEL
Daytime Nighttime
L1 Village
General (VG)
Located southwest of the New York
Street/ESRI Station north of Redlands
Boulevard.

69.6 63.6 72.0
L2 Village
Center (VC) Located near Historic Redlands Train Station at 383-389 Orange Street. 69.9 63.1 71.7 L3 Special
District 1 (SD1)
Located west of the University Street
Station north Park Avenue near Frederick
Loewe Theatre.

57.1 57.6 64.4
L4 Village
General (VG)
Located north of Colton Avenue in the Tri
City Shopping Center south of the CVS
Pharmacy.

66.4 62.0 69.7
L5 Civic
Space (CS)
Located northwest of the University Street
Station near Sylvan Park at 601 North
University Street.

64.6 64.0 70.7
L6 Downtown (DT) Located north of East Vine Street and
south of East Citrus Avenue. 57.6 56.0 62.9
L7 Village
Corridor (COR) Located near the single-family residence at 1154 Orange Street. 70.2 65.5 73.4 L8 Neighborhood
General 2 (NG2) Located near the single-family residence at 410 East Stuart Street. 63.1 59.3 66.9 L9 Neighborhood
General 1 (NG1) Located near the single-family residence at 801 Stillman Avenue. 65.1 59.2 67.5 L10 Special
District 1 (SD1)
Located south of the ESRI campus near the
Redlands Adventist Academy at 130
Tennessee Street.

64.4 55.3 65.0
Source: Noise Study, 2022. Appendix G.

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Figure 5.10-1: Noise Measurement Locations
LEGEND:

A Measurement Locations
LJ Transit Villages Specific Plan (TVSP) Boundary
@ Arrow Rail Stations
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The noise measurements identified that ambient noise levels range from 62.9 to 73.4 CNEL throughout the TVSP area. Table 5.10-5 summarizes the existing ambient noise level conditions in relation to the General Plan Noise/Land Use Compatibility Matrix listed in Table 5.10-1.

Table 5.10-5: Existing Noise and Land Use Compatibility Location
TVSP
Land
Use
CNEL
General Plan
Land Use
Category
General Plan
Noise/Land Use
Compatibility
L1 Village
General (VG) 72.0 Commercial Zone A - Clearly Compatible L2 Village
Center (VC) 71.7 Commercial Zone A - Clearly Compatible L3 Special
District 1 (SD1) 64.4 Commercial Zone A - Clearly Compatible L4 Village
General (VG) 69.7 Commercial Zone A - Clearly Compatible L5 Civic
Space (CS) 70.7 Open Space Zone B - Normally Compatible L6 Downtown (DT) 62.9 Commercial Zone A - Clearly Compatible L7 Village
Corridor (COR) 73.4 Residential Zone C - Normally Incompatible Commercial Zone A - Clearly Compatible
L8 Neighborhood
General 2 (NG2) 66.9 Residential Zone C - Normally Incompatible Commercial Zone A - Clearly Compatible
L9 Neighborhood
General 1 (NG1) 67.5 Residential Zone C - Normally Incompatible Commercial Zone A - Clearly Compatible
L10 Special
District 1 (SD1) 65.0 Public/Institutional Zone A - Clearly Compatible Source: Noise Study, 2022. Appendix G.

Table 5.10-5 shows that within the existing ambient noise environment, the TVSP commercial land uses are considered clearly compatible with the Noise/Land Use Compatibility Matrix. Clearly compatible land use is considered satisfactory with normal conventional construction without any special noise insulation requirements.

The existing noise level measurements also show that the future residential land uses located within the Village Corridor, Neighborhood General 1 and Neighborhood General 2 would be considered normally incompatible and new construction or development requires a detailed analysis of noise reduction features to reduce ambient noise upon the new residential development. Commercial uses located within the Village Corridor, Neighborhood General 1, and Neighborhood General 2 would be considered Clearly Compatible.

San Bernardino International Airport
The San Bernardino International Airport is located approximately 2.4 miles northwest of the TVSP area, which is within the Airport Influence Area. The latest aircraft noise contour boundaries for the airport were published as part of the Eastgate Air Cargo Facility Final Environmental Assessment and are included as Figure 5.10-2, which shows the 2024 CNEL contours with approximately 87,500 annual aircraft operations.

As shown on Figure 5.10-2 the TVSP area is located outside of the airport’s 60 dBA CNEL noise level contours in 2024 and is considered normally acceptable by the General Plan Community Noise and Land Use Compatibility guidelines (Table 5.10-1).

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

NOI-1 Generation of a substantial temporary or permanent increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies;
NOI-2 Generate excessive groundborne vibration or groundborne noise levels; NOI-3 For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels.

The Initial Study established that the proposed Project would result in less than significant impacts related to Threshold NOI-3. No further assessment of these impacts is required in this Draft EIR.

Construction Noise and Vibration
• If Project related construction activities:
o Occur between the hours of 6:00 p.m. and 7:00 a.m. of the next day, on Sundays or federal holidays (Municipal Code Section 8.06.090(F)); or
o Create noise levels which exceed the 80 dBA Leq acceptable noise level threshold at the nearby sensitive receiver locations (FTA, 2006);
• If Project-related construction activities generate vibration levels which exceed the Municipal Code, Section 8.06.020, vibration threshold of 0.1 in/sec RMS at receiver locations.

Operational Noise
• If Project related operational increase in ambient noise levels:
o An increase in exposure of four or more dB if the resulting noise level would exceed that described as clearly compatible for the affected land use, as established in GP Table 9.1 [Table 7-10] and GP Table 9.2 [Table 7-11];
o Any increase of six dB or more, due to the potential for adverse community response (Measure U Policy 9.0v).

5.10.5 METHODOLOGY
Construction Noise
To identify the temporary construction noise contribution to the existing ambient noise environment, the construction noise levels anticipated from usage of construction equipment needed to implement the TVSP were analyzed through comparison of construction noise levels to the thresholds listed previously to assess the level of significance associated with temporary construction noise level impacts.

Operational Noise
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The primary source of noise associated with the operation of the TVSP would be from vehicular trips and new stationary sources (such as heating, ventilation, and air conditioning units) associated with the new sitespecific development that would occur by the TVSP. The increase in noise levels generated by these activities have been quantitatively estimated and compared to the applicable noise standards listed previously.

Vibration
Aside from noise levels, groundborne vibration would also be generated during construction of the Project by various construction-related activities and equipment; and could be generated by truck traffic traveling to and from the TVSP area. The potential ground-borne vibration levels resulting from construction activities occurring from the TVSP were estimated by data published by the Federal Transit Administration (FTA).

Thus, the groundborne vibration levels generated by these sources have also been quantitatively estimated and compared to the applicable thresholds of significance listed previously.

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Figure 5.10-2: San Bernardino International Airport Noise Contours --------------.... ... t ,
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LEGEND: San Bernardino lnternationol (SBD) Airport Future Noise level Contour Boundaries [_] Project Site Bou ndary L] 60 dBA CNEL L] 65 dBA CNEL L] 70 dBA CNEL L] 75 dBA CNEL Source: Figure 4-6 of the Eastgate Air Cargo Facility Final Environmental Assessment published by the SB/AA on July 2, 2019.

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5.10.6 ENVIRONMENTAL IMPACTS
IMPACT NOI-1: THE PROJECT WOULD NOT GENERATE A SUBSTANTIAL TEMPORARY OR

PERMANENT INCREASE IN AMBIENT NOISE LEVELS IN EXCESS OF STANDARDS

ESTABLISHED IN THE LOCAL GENERAL PLAN OR NOISE ORDINANCE, OR APPLICABLE STANDARDS OF OTHER AGENCIES.

Construction
Less than Significant with Mitigation Incorporated. The timing of development and various construction activities 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 and include different project specific construction activities. Table 5.10-6 lists construction equipment that would be used during construction of TVSP development projects.

Table 5.10-6: Construction Equipment Assumptions
Construction Activity Equipment
Demolition
Concrete/Industrial Saws
Excavators
Rubber Tired Dozers
Site Preparation Crawler Tractors
Rubber Tired Dozers
Grading
Crawler Tractors
Excavators
Graders
Rubber Tired Dozers
Scrapers
Building Construction
Cranes
Forklifts
Generator Sets
Tractors/Loaders/Backhoes
Welders
Paving
Pavers
Paving Equipment
Rollers
Architectural Coating Air Compressors
Source: EIR Section 5.2, Air Quality, Table 5.2-6 and (Appendix G) Noise generated by the Project construction equipment will include a combination of trucks, power tools, concrete mixers, and portable generators that when combined can reach noise levels ranging from approximately 68 dBA to more than 80 dBA when measured at 50 feet. Hard site conditions are used in the construction noise analysis which result in noise levels that attenuate (or decrease) at a rate of 6 dBA for each doubling of distance from a point source (i.e., construction equipment). For example, a noise level of 80 dBA measured at 50 feet from the noise source to the receiver would be reduced to 74 dBA at 100 feet from the source to the receiver and would be further reduced to 68 dBA at 200 feet from the source to the receiver.

Section 8.06.090(F) of the City’s Municipal Code allows construction noise to exceed the City noise standards provided that construction activities occur between 7:00 a.m. and 6:00 p.m., Monday through Saturday, and not on Sundays and Federal holidays. However, the City construction noise standards do not provide any limits to the noise levels that may be created from construction activities and even with adherence to the City standards, the resultant construction noise levels may result in a significant substantial temporary noise increase to the nearby residents. Therefore, in order to determine if construction activities Redlands Regular Meeting of 10-18-22 902 of 1815
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would create a significant substantial temporary noise increase, the FTA construction noise criteria threshold detailed above has been utilized, which shows that a significant construction noise impact would occur if construction noise exceeds 80 dBA during the daytime at a sensitive receiver, such as a residence.

Because the TVSP includes development of residential uses and existing residential units are located throughout the TVSP area, construction of new developments pursuant to the TVSP that are infill and redevelopment projects could occur adjacent to sensitive receptors, and temporary intermittent construction noise impacts could occur. Therefore, Mitigation Measures NOI-1 through NOI-4 have been included to provide construction measures to reduce potential impacts to a less than significant level.

Operation
Ambient Traffic Noise Impacts to Proposed Sensitive Receptors Less than Significant with Mitigation Incorporated. The proposed TVSP would consist of infill and redevelopment of new mixed uses, including residential, within the Project area. The primary source of noise impacts to the new development within the TVSP would be from the Arrow commuter rail line, and traffic-related noise from the I-10 Freeway, and key arterial roadways such as New York Street, Eureka Street, Orange Street, Church Street, Grove Street, Judson Street, Colton Avenue, Park Avenue, Redlands Boulevard, State Street, and Citrus Avenue.

New noise sensitive land uses adjacent to the Arrow commuter rail line, the I-10 Freeway and these key arterial roadways would experience future unmitigated exterior noise levels greater than 65 dBA CNEL, which represents normally incompatible for residential uses based on the General Plan Noise/Land Use Compatibility Matrix (Table 5.10-1). Therefore, based on the proximity of future noise sensitive land uses, traffic-related noise impacts at future residential uses within the TVSP would be potentially significant and require noise mitigation to reduce potential impacts to less than significant level. Mitigation Measure NOI5 requires that prior to the issuance of a building permit for new residential dwelling units within the TVSP, the Project plans and specifications shall demonstrate compliance with the General Plan 60 dBA CNEL exterior noise level standard, such as through an acoustical analysis.

Interior Noise Impacts to Proposed Sensitive Receptors
Less than Significant with Mitigation Incorporated. The proposed TVSP would consist of infill and redevelopment of lands within the Project area that would provide new residential units that could be within mixed-use buildings adjacent to an arterial roadway or the Arrow commuter rail line.

Typical building construction provides a noise reduction of approximately 12 dBA with "windows open" and a minimum 25 dBA noise reduction with "windows closed." The use of central air conditioning provides noise reduction benefits by permitting windows to kept closed. Typical noise reducing construction methods include: 1) weather-stripped solid core exterior doors; 2) upgraded dual glazed windows; 3) mechanical ventilation/air conditioning; and 4) exterior wall/roof assembles free of cut outs or openings. Each of these methods are included in State Title 24 construction standards that are verified as implemented by the City during the construction permitting process.

Because the exterior noise levels from future noise sensitive land uses adjacent to the arrow commuter rail line, the I-10 Freeway and key arterial roadways exceed 60 dBA CNEL, detailed interior noise analysis based on site-specific architectural floor plans and elevations would be required for future developments that include residential uses to satisfy the City of Redlands General Plan Noise Element, Table 7-11 (Table

5.10-2), 45 dBA CNEL interior noise level standard for residential dwelling units. Therefore, Mitigation Measure NOI-6 is included to require new development projects to demonstrate compliance with the 45 dBA CNEL interior noise level standard, such as through provision of an acoustical analysis, to ensure that impacts would be less than significant.

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Non-Residential Noise Generation
Implementation of the proposed TVSP would include a combination of noise sources related to the proposed residential, commercial, recreation, and other uses included in the TVSP. Buildout of the TVSP would result in noise sources that would include air conditioning units, loading dock activities, parking lots, trash enclosures, and outdoor activities in park and recreation areas. These Project-related noise sources are consistent with existing noise sources observed in the TVSP area. However, new operation of nonresidential uses developed pursuant to the TVSP could result in nuisance noise source activity that could increase the ambient noise levels at sensitive receptors. Therefore, Mitigation Measure NOI-7 is included to ensure future project compliance with Municipal Code Section 8.06.090(F), through conduct of a noise impact analysis, which would ensure that operational noise impacts would be less than significant.

IMPACT NOI-2: THE PROJECT WOULD NOT GENERATE EXCESSIVE GROUND-BORNE VIBRATION OR GROUNDBORNE NOISE LEVELS.

Construction
Less than Significant with Mitigation Incorporated. Construction activities for the infill and redevelopment projects that would occur pursuant to the TVSP are anticipated to include demolition, site preparation, grading, building construction, paving, and application of architectural coatings. Vibration impacts from these construction activities would typically be created from the operation of heavy off-road equipment. Because the TVSP includes development of residential uses and existing residential units are located throughout the TVSP area, construction of new developments pursuant to the TVSP that are infill and redevelopment projects could occur adjacent to sensitive receptors.

As described previously Section 8.06.090(F) of the City’s Municipal Code limits construction to occur between 7:00 a.m. and 6:00 p.m., Monday through Saturday, which also limits the time that construction vibration could occur. Also, Section 8.06.020 identifies the vibration threshold as 0.01 in/sec RMS.

Ground vibration levels associated with various types of construction equipment are summarized in Table

5.10-7. Based on the representative vibration levels presented for various construction equipment types, it is possible to estimate the potential Project construction vibration levels using the following vibration assessment methods defined by the FTA. To describe the human response (annoyance) associated with vibration impacts the FTA provides the following equation: PPVequip = PPVref x (25/D).

Table 5.10-7: Vibration Source Levels for Construction Equipment Equipment PPV (in/sec) at 25 feet
Small bulldozer 0.003
Jackhammer 0.035
Loaded Trucks 0.076
Large bulldozer 0.089
Source: Noise, 2022. Appendix G
The primary source of vibration during infill and redevelopment construction would be from the operation of a bulldozer. As shown in Table 5.10-7, a large bulldozer would create a vibration level of 0.089 inch per second PPV at 25 feet. To describe the RMS vibration level and demonstrate compliance with the Municipal Code perceptible vibration threshold of 0.01 in/sec RMS, PPV velocities are converted to RMS vibration levels based on the Caltrans Transportation and Construction Vibration Guidance Manual conversion factor of 0.71.

Table 5.10-8 lists that anticipated construction related vibration levels at distances ranging from 25 to 150 feet from construction activity. As shown, construction vibration levels would range from 0.004 to

0.063 in/sec RMS that would exceed the perceptible vibration threshold of 0.01 in/sec RMS at distances of less than 100 feet. Therefore, Mitigation Measures NOI-8 and NOI-9 are included to reduce potential Redlands Regular Meeting of 10-18-22 904 of 1815
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vibration impacts to below the vibration threshold of 0.01 in/sec RMS, which would reduce impacts to a less than significant level.

Table 5.10-8: Construction Equipment Vibration Levels
Distance to
Const.

Activity
(Feet)
Receiver Levels (in/sec) PPV Velocity
Levels
(in/sec)
RMS
Threshold
(in/sec)
RMS
Threshold
Exceeded? Small
Bulldozer
JackhammerLoaded
Trucks
Large
Bulldozer
Peak
Vibration
25' 0.0030 0.0350 0.0760 0.0890 0.0890 0.063 0.01 Yes
50' 0.0011 0.0124 0.0269 0.0315 0.0315 0.022 0.01 Yes
100' 0.0004 0.0044 0.0095 0.0111 0.0111 0.008 0.01 No
125' 0.0003 0.0031 0.0068 0.0080 0.0080 0.006 0.01 No
150' 0.0002 0.0024 0.0052 0.0061 0.0061 0.004 0.01 No
Source: Noise, 2022. Appendix G
Operation
Less than Significant. The proposed Project would consist of infill and redevelopment within the TVSP with new residential, commercial, and mixed-use projects. The on-going operation of these types of land uses do not include the operation of any vibration sources other than typical onsite vehicle and truck operations.

Therefore, impacts related to operational vibration would be less than significant.

5.10.7 CUMULATIVE IMPACTS
Cumulative noise assessment considers development of the proposed Project in combination with ambient growth and other development projects within the vicinity of the TVSP area. As noise is a localized phenomenon, and drastically reduces in magnitude as distance from the source increases, only projects and ambient growth in the nearby area could combine with the activities of the TVSP to result in cumulative noise impacts.

Buildout of the TVSP in combination with the related projects would result in an increase in constructionrelated and traffic-related noise. However, Municipal Code Section 8.06.090(F) requires construction activities to not occur within the hours of 6:00 p.m. and 7:00 a.m. on weekdays or anytime on Sundays and federal holidays. Also, construction noise and vibration are localized in nature and decreases substantially with distance. Consequently, in order to achieve a substantial cumulative increase in construction noise and vibration levels, more than one source emitting high levels of construction noise would need to be in close proximity to TVSP construction activity. As the timing of development and various construction activities pursuant to the TVSP would be dependent upon market conditions and development applications for new projects. Construction activities associated with buildout of the proposed TVSP would likely occur sporadically over an 18-year period or longer. Thus, its currently unknown if construction projects would occur adjacent to one another. However, implementation of the construction and vibration mitigation measures provided herein would reduce the potential of noise and vibration levels from different construction projects combining to become cumulatively considerable to a less than significant level. Therefore, with implementation of mitigation, cumulative noise and vibration impacts associated with construction activities would be less than significant.

Development anticipated by the TVSP in combination with other nearby projects would result in an increase in ambient noise. However, all development projects would be subject to the operational noise standards established by the General Plan and Municipal Code, which would ensure that noise from new uses in the TVSP area would stay below City standards and therefore not combine with other development projects to be cumulatively significant. Thus, operational noise from new land uses in the proposed Specific Plan area would result in less than significant cumulative noise impacts.

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Also, as described above, the TVSP area is located outside of the 60 dBA CNEL noise contour boundaries of the San Bernardino International Airport, and developments within the proposed TVSP area would not result in exposure of people residing or working in the area to excessive noise levels from operation of an airport and would not result in an impact that could cumulatively combine. Hence, cumulative impacts related to airport noise would not occur.

5.10.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• California Code of Regulations, Title 24 included in the City’s Municipal Code in Chapter 18. • City’s Municipal Code Section 8.06.090(F), all construction activities shall be limited to the daytime hours of between 7:00 a.m. to 6:00 p.m. Monday to Saturdays; with no activity allowed on Sundays or holidays
• City’s Municipal Code Section 8.06.020, defines the vibration perception threshold as 0.01 inches per second (in/sec) RMS.

Standard Conditions
None.

Plans, Programs, or Policies
None.

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

Impact NOI-1: Buildout of the proposed TVSP could generate of a substantial temporary or permanent increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance.

Impact NOI-2: Buildout of the proposed TVSP could generate excessive groundborne vibration or groundborne noise levels.

5.10.10 MITIGATION MEASURES
Mitigation Measure NOI-1: Construction Equipment: Prior to the issuance of a demolition, grading, or construction permit for new development within the TVSP, the project plans and specifications shall require that construction contractors equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturers’ standards, and all stationary construction equipment shall be placed so that emitted noise is directed away from the noise-sensitive use nearest the construction activity.

Mitigation Measure NOI-2: Construction Staging: Prior to the issuance of a demolition, grading, or construction permit for new development within the TVSP, the project plans and specifications shall require that the construction contractor shall locate equipment staging in areas that will create the greatest distance between construction-related noise sources and noise-sensitive receiver nearest to the construction activity.

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Mitigation Measure NOI-3: Construction Noise Levels: Prior to the issuance of a demolition, grading, or construction permit for new development within the TVSP, the project plans and specifications shall demonstrate that all construction activity within the TVSP will satisfy the exterior construction noise level of 80 dBA Leq at a sensitive receiver (e.g., residential).

Mitigation Measure NOI-4: Construction Noise Barriers: Prior to the issuance of a demolition, grading, or construction permit for new development within the TVSP that could exceed the exterior construction noise level of 80 dBA Leq at a sensitive receiver (e.g. residential), the project plans and specifications shall detail the installation of temporary construction noise barriers for occupied noise-sensitive uses for the duration of construction activities that could exceed the TVSP construction noise level thresholds. The noise control barrier(s) must provide a solid face from top to bottom and shall:
• Provide a minimum transmission loss of 20 dBA and be constructed with an acoustical blanket (e.g., vinyl acoustic curtains or quilted blankets) attached to the construction site perimeter fence or equivalent temporary fence posts;
• Be maintained and any damage promptly repaired. Gaps, holes, or weaknesses in the barrier or openings between the barrier and the ground shall be promptly repaired; and • Be removed and the site appropriately restored upon the conclusion of the construction activity.

Mitigation Measure NOI-5: Residential Exterior Noise: Prior to the issuance of a building permit for new residential dwelling units within the TVSP, the Project plans and specifications shall demonstrate compliance with the 60 dBA CNEL exterior noise level standard as defined by Table 7-11 of the City of Redlands General Plan Healthy Community Element through preparation of an acoustical analysis. The outdoor environment is limited to private yard of single family as measured at the property line; multifamily private patio or balcony which is served by a means of exit from inside; mobile home park; hospital patio; park picnic area; school playground; hotel and recreational area as intended by the General Plan Healthy Community Element.

Mitigation Measure NOI-6: Residential Interior Noise: Prior to the issuance of a building permit for new residential dwelling units within the TVSP, the Project plans and specifications shall demonstrate compliance with the 45 dBA CNEL interior noise level standard as defined by Table 7-11 of the General Plan Healthy Community Element and by Title 24, Part 2, of the California Building Code through preparation of an acoustical analysis.

Mitigation Measure NOI-7: Non-Residential Developments: Prior to the issuance of a building permit for a non-residential development within the TVSP that has the potential to impact noise sensitive residential land uses, the project plans and specifications shall demonstrate compliance with Municipal Code Section

8.06.090(F).

Mitigation Measure NOI-8: Construction Vibration: Prior to approval of a demolition permit, grading plans, and/or issuance of building permits for construction activities within 100 feet of existing residential structures or occupied noise-sensitive uses that require the use of large bulldozers, large loaded trucks, jackhammers, pile drivers, and/or caisson drills, the City of Redlands Building and Safety Division shall ensure that construction plans and specifications state that the use of such vibratory equipment shall be prohibited within 100 feet of existing residential structures or occupied noise-sensitive uses. Instead, small rubber-tired bulldozers shall be used within this area during demolition and/or grading operations to reduce vibration effects. If the use of large bulldozers, loaded trucks, jackhammers, pile drivers, and/or caisson drills is necessary within 100 feet of existing residential structures or occupied noise-sensitive uses, Redlands Regular Meeting of 10-18-22 907 of 1815
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the project Applicant/Developer shall demonstrate compliance with Municipal Code, Section 8.06.020 vibration perception threshold as 0.01 inches per second (in/sec) RMS.

Mitigation Measure NOI-9: Construction Vibration Near Fragile Historic: Any site-specific development project within 25 feet of an extremely fragile historic building shall engage a qualified structural engineer to conduct a pre-construction assessment of the structural integrity of the nearby historic structure(s) and submit evidence to the City of Redlands Building and Safety Division detailing that the operation of vibration-generating equipment associated with the new development would not result in structural damage to the adjacent historic building(s). If recommended by the pre-construction assessment, groundborne vibration monitoring of nearby historic structures shall be required.

5.10.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact NOI-1: After implementation of Mitigation Measures NOI-1 through NOI-7, buildout of the TVSP would not result in a substantial temporary or permanent increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance. Thus, impacts would be less than significant.

Impact NOI-2: After implementation of Mitigation Measures NOI-8 and NOI-9, buildout of the TVSP would not result in excessive groundborne vibration or groundborne noise levels. Thus, impacts would be less than significant.

Therefore, no significant unavoidable adverse impacts related to noise or vibration would occur.

REFERENCES
Caltrans Guidance for Compliance. Accessed: https://dot.ca.gov/programs/environmentalanalysis/standard-environmental-reference-ser/volume-1-guidance-for-compliance/ch-12-noise Federal Transit Administration Transit Noise and Vibration Impact Assessment, May 2006 (FTA, 2006).

Accessed: https://docs.vcrma.org/images/pdf/planning/ceqa/FTA_Noise_and_Vibration_Manual.pdf 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 Urban Crossroads. “Transit Villages District and Specific Plan Noise Impact and Vibration Analysis” 2022.

Appendix G.

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5.11 Population and Housing

5.11.1 INTRODUCTION
This section examines the existing population, housing, and employment conditions in the City of Redlands and assesses the Project’s impacts related to direct and indirect growth and potential displacement of people and housing. The demographic data and analysis in this section is based, in part, on the following documents and resources:
• 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy, SCAG, September 2020
• Local Profiles Report 2019, Profile of the City of Redlands, SCAG, May 2019 • Population Estimates for Cities, Counties, and the State, California Department of Finance (DOF), May 2021
• City of Redlands 2035 General Plan, 2017
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (GP EIR), 2017
Although evaluation of population, housing, and employment typically involves economic and social, rather than physical environmental issues, population, housing, and employment growth are often precursors to physical environmental impacts. According to Section 15382 of the CEQA Guidelines, “[a]n economic or social change by itself shall not be considered a significant impact on the environment.” Socioeconomic characteristics should be considered in an EIR only to the extent that they create adverse impacts on the physical environment.

5.11.2 REGULATORY SETTING

5.11.2.1 State Regulations
California Housing Element Law
California planning and zoning law requires each city and county to adopt a general plan for future growth (California Government Code Section 65300). This plan must include a housing element that identifies housing needs for all economic segments and provides opportunities for housing development to meet that need. At the state level, the California Department of Housing and Community Development Department (HCD) estimates the relative share of California’s projected population growth that would occur in each county based on Department of Finance (DOF) population projections and historical growth trends. These figures are compiled by HCD in a Regional Housing Needs Assessment (RHNA) for each region of California. Where there is a regional council of governments, HCD provides the RHNA to the council. Such is the case for the City of Redlands, which is a member of SCAG. The council, in this case Southern California Association of Governments (SCAG), then assigns a share of the regional housing need to each of its cities and counties.

The process of assigning shares gives cities and counties the opportunity to comment on the proposed allocations. HCD oversees the process to ensure that the council of governments distributes its share of the state’s projected housing need.

Southern California Association of Governments
SCAG is a council of governments representing Orange, Imperial, Los Angeles, Riverside, San Bernardino, and Ventura counties. It is the federally recognized metropolitan planning organization (MPO) for this region, Redlands Regular Meeting of 10-18-22 910 of 1815
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which encompasses over 38,000 square miles. SCAG actions in Orange County are partially the result of input from the Orange County Council of Governments (OCCOG), which offers recommendations regarding SCAG’s initiatives.

Regional Housing Needs Allocation
The Regional Housing Needs Assessment (RHNA) is mandated by state housing law as part of the periodic process of updating housing elements of local general plans. State law requires that housing elements identify RHNA targets set by HCD to encourage each jurisdiction in the state to provide its fair share of very low, low, moderate, and upper income housing. The RHNA is intended to provide a long-term outline for housing within the context of local and regional trends and housing production goals.

SCAG determines total housing need for each community in southern California based on three general factors: 1) the number of housing units needed to accommodate future population and employment growth; 2) the number of additional units needed to allow for housing vacancies; and 3) the number of very low, low, moderate, and above-moderate income households needed. All cities are required to ensure that sufficient sites are planned and zoned for housing, such that area would be available to accommodate the projected housing needs, and to implement proactive programs that facilitate and encourage the production of housing commensurate with its housing needs.

For the 2021–2029 planning period, SCAG determined that the City of Redlands RHNA allocation for very low-income housing units is 967; as shown in Table 5.11-1, 45 percent are allocated to extremely low through low income housing.

Table 5.11-1: City of Redlands SCAG Regional Housing Needs Allocation, 2021-2029 Category Percent of
County Median
2021 Household
Income
2021-2029
Housing Need
Extremely Low-Income Less than 30% Less than $26,500 483 (14%)
Very Low-Income 30-50% $26,500 - $39,500 484
(14%)
Low-Income 50-80% $39,500 - $63,200 615
(17%)
Moderate Income 80-120% $63,200 - $93,000 652
(19%)
Above Moderate Income Over 120% More than $93,000 1,282 (36%)
Total -- 3,516
Source: City of Redlands 2021-2029 Housing Element

5.11.2.2 Regional/Local Regulations
City of Redlands General Plan Housing Element
The Housing Element include the following policies related to population and housing and the Project:

Policy 1.1 Provide adequate capacity to meet the Sites Inventory for Regional Housing Needs Assessment (RHNA).

Policy 1.2 Increase capacity and access to opportunities and services through the adoption of the Transit Villages Specific Plan.

Policy 1.3 Provide housing capacity near public services.

Policy 1.4 Realize capacity potential through minimum densities.

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Policy 1.5 Maintain an up-to-date residential sites inventory and provide to interested developers with information on available development incentives.

Policy 1.6 Support the assembly of small vacant or underutilized parcels to enhance the feasibility of infill development.

Policy 1.7 Ensure that residential development sites have appropriate and adequate services and facilities, including water, wastewater, and neighborhood infrastructure.

Policy 1.8 Incentivize the development of Accessory Dwelling Units as a means of providing a diversity in housing types in all areas within the City.

Policy 1.9 Incentivize efficient buildings and conservation.

City of Redlands General Plan Transit Villages Element
The Transit Villages Element provides for new jobs, housing, and entertainment opportunities in compact, walkable environments; support multiple modes of transit, car travel, walking, and bicycling; and provide new development and infill opportunities include the following policies related to population and housing and the Project:

Policy 4-P.42 Provide for new jobs, housing, and entertainment opportunities in compact, walkable environments.

Policy 4-P.49 Allow residential and mixed-use projects in the Mixed Use Core at densities up to the High Density Residential standard.

5.11.3 ENVIRONMENTAL SETTING
The TVSP area includes approximately 947 acres of urban land that is divided into three planning areas (transit villages). 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. There are a number of vacant parcels located within the TVSP area, mostly concentrated along and near the railroad right-of-way.

Population
The California Department of Finance (DOF) estimates that the City of Redlands population is 71,154, representing approximately 3.3 percent of the County’s total population. SCAG estimates that the City will have a population increase of 13.6 percent between 2021 and 2045, and the County will have population growth rate of over 29 percent over the same period. Table 5.11-2 provides population figures for the City of Redlands and the County in 2021, and SCAG projections for year 2045.

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Table 5.11-2: Population Estimates and Projections, 2021–2045 20211
20452
Projection
2021-2045
Change
City of Redlands 71,154 80,800 13.6%
San Bernardino County 2,175,909 2,815,000 29.4% 1 California Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2021. 2 SCAG 2045 Growth Forecasts.

Housing and Households
The DOF estimates that there were 27,214 housing units in Redlands in 2021, which is 3.7 percent of the County total. The City’s housing stock is 64 percent single-family residential and is estimated to be 93.4 percent occupied. The DOF estimated persons per household is 2.71.

Table 5.11-3: City of Redlands Existing Housing Stock, 2021 Residence Type Number Percentage
Single-Family Detached 17,451 64.1%
Single-Family Attached 1,202 4.4%
Two to Four Units 3,144 11.6%
Five Plus 4,331 15.9%
Mobile Homes 1,086 4.0%
Total 27,214 100%
Occupied 25,405 93.4%
Vacancy 1,809 6.6%
California Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2021.

According to SCAG’s 2020-2045 RTP/SCS, the City of Redlands is projected to add approximately 5,395 households by 2045 (Table 5.11-4). This averages approximately 225 new households annually through 2045.

Table 5.11-4: SCAG Household Projections, 2021–2045
20211
Households
20452
Households
2021-2045
Increase
City of Redlands 25,405 30,800 21.2%
San Bernardino County 649,259 875,000 34.8% 1 California Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2021. 2 SCAG 2045 Growth Forecasts.

Employment
According to SCAG’s 2020-2045 RTP/SCS, the number of jobs within the City is projected to increase from 42,600 jobs in 2016 to 56,300 jobs in 2045 (Table 5.11-5). This represents an increase of over 32 percent, and an average of 472 jobs annually through the year 2045.

Table 5.11-5: SCAG Projected Employment Trends, 2016-2045 2016 2045
2016 – 2045
Increase
City of Redlands 42,600 56,300 13,700
(32.2%)
San Bernardino County 791,000 1,064,000 273,000
(34.5%)
Source: SCAG 2045 Growth Forecasts.

I I I I

I I I I
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In addition, the 2020 Census estimates that 63 percent of the City’s residents that are over 16 years of age are in the labor force and have an average 26.9-minute commute. This is similar to San Bernardino County as a whole, where 60.3 percent of residents over 16 years old are in the labor force and the average commute time was 31.6 minutes.

Jobs – Housing Balance
The jobs-housing ratio is a general measure of the “balance” between the number of jobs and number of housing units within a geographic area, without regard to economic constraints or individual preferences. The ratio expresses quantitatively the relationship between the number of people working and number of dwelling units housing the people living in a given area. Additionally, a well-balanced ratio of jobs and housing reduces commuting trips because more employment opportunities are closer to residential areas.

Such a reduction in vehicle trips lowers air pollutant emissions (including lower greenhouse gas emissions) and causes less congestion on area roadways and intersections. A major focus of SCAG’s regional planning efforts has been to improve this balance. SCAG defines the jobs-housing balance as follows:

Jobs and housing are in balance when an area has enough employment opportunities for most of the people who live there and enough housing opportunities for most of the people who work there. The region as a whole is, by definition, balanced…. Job-rich subregions have ratios greater than the regional average; housing-rich subregions have ratios lower than the regional average. Ideally, job-housing balance would… assure not only a numerical match of jobs and housing but also an economic match in type of jobs and housing.

SCAG considers an area balanced when the jobs-housing ratio is 1.36; communities with more than 1.36 jobs per dwelling unit are considered jobs-rich; those with fewer than 1.36 are “housing rich,” meaning that more housing is provided than employment opportunities in the area (SCAG 2004).

As described above and shown in Table 5.11-6, the City currently has approximately 25,405 households and approximately 34,900 jobs (2022 State of California Employment Development Department Labor Force data), which results in a jobs-to-housing ratio of 1.37 jobs per household. SCAG projects a jobs-tohousing ratio of 1.83 in 2045, which indicates that employees would be commuting into the City for employment, and that additional housing would improve the jobs to housing balance within the City. The City is projected to have a higher percentage of jobs to households in comparison to the County, which is projected to have a jobs to housing ratio of 1.22 in 2045. Table 5.11-6 provides the existing and projected jobs-tohousing ratios for the City and the County.

Table 5.11-6: Existing and Projected Jobs - Housing Balance in the City and County Year Employment Households Jobs-Housing
Ratio
City of Redlands 20221 34,900 25,405 1.37
2045 56,300 30,800 1.83
San Bernardino
County
20221 940,800 649,245 1.45
2045 1,064,000 875,000 1.22
Sources:1Employment Development Department, 2022.

SCAG 2020

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

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POP-1 Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure); or
POP-2 Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

The Initial Study established that the proposed Project would not result in impacts related to Threshold POP2; and no further assessment of this impact is required in this EIR.

5.11.5 METHODOLOGY
State CEQA Guidelines Section 15064(e) states that a social or economic change generally is not considered a significant effect on the environment unless the changes can be directly linked to a physical adverse change.

Additionally, CEQA Guidelines Appendix G indicates that a project could have a significant effect if it would induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure). Therefore, population impacts are considered potentially significant if growth associated with a project would exceed projections for the area and if such an exceedance would have the potential to create a significant adverse physical change to the environment.

The methodology used to determine population, housing, and employment impacts includes data collection of population and housing trends, which was obtained from DOF, the General Plan, and SCAG. The determination of impacts is based on an analysis of the number of residents and employees anticipated at buildout of the proposed Project. The scale of population at buildout is then compared with growth forecasts for the project area. Growth is considered in the context of local and regional plans that include population projections for the City and the County. The SCAG population projections are used to prepare the Regional Transportation Plan /Sustainable Communities Strategy (RTP/SCS) which sets forth land use strategies that help the region achieve state greenhouse gas emission reduction goals and assist the South Coast Air Quality Management District prepare its Air Quality Management Plan (AQMP)If projected growth within the Project area from implementation of the Project would exceed SCAG growth projections, resulting in the project being in conflict with the RTP/SCS and the AQMP, growth would be considered “substantial,” and a significant impact may result.

5.11.6 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.

IMPACT POP-1: THE PROJECT WOULD NOT INDUCE SUBSTANTIAL UNPLANNED POPULATION

GROWTH IN AN AREA, EITHER DIRECTLY (FOR EXAMPLE, BY PROPOSING NEW

HOMES AND BUSINESSES) OR INDIRECTLY (FOR EXAMPLE THROUGH THE EXTENSION OF ROADS OR OTHER INFRASTRUCTURE).

Less Than Significant Impact. The TVSP provides for infill development, redevelopment, and development of a number of vacant parcels located within the Project area. The maximum development that would occur from buildout of the TVSP is 2,400 residential units and 613,000 square feet of retail commercial, hotel, Redlands Regular Meeting of 10-18-22 915 of 1815
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and office space. This amount of new development could currently be constructed in the Project area under the current GP2035 land use designations and zoning designations. Buildout pursuant to the TVSP would be within the buildout provided for within the GP2035. However, the proposed TVSP would provide a formbased 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. Therefore, the Project would not induce population growth, it would just provide for the form and function of future development.

Table 5.11-7 shows that based on the General Plan buildout estimates (General Plan Revised Draft EIR Tables ES-1 and ES-2) of 2.65 persons per household and one employee for every 500 square feet of nonresidential space, buildout of the proposed TVSP would accommodate 6,360 residents and 1,226 employees.

Table 5.11-7: TVSP Proposed Buildout Population & Employee Increase Units at Buildout Quantifier Total
Residential 2,400 units 2.65 persons per household 6,360 residents Retail Commercial 265,000 SF 1 employee for every 500 SF 530 employees Office 238,000 SF 1 employee for every 500 SF 476 employees Hotel 110,000 SF 1 employee for every 500 SF 220 employees Total
6,360 residents
1,226 employees
Residential Development. Table 5.11-7 lists that buildout of the proposed TVSP would result in a population increase of 6,360 residents, which is a citywide increase of 8.9 percent over the 2021 estimated population of 71,154. As listed previously in Table 5.11-2, SCAG forecasts that the City’s population will increase by

13.6 percent (9,646 residents) between 2021 and 2045. The additional 6,360 residents that would be accommodated by buildout of the proposed TVSP would not exceed the amount of growth anticipated to occur within the City. Also, as shown in Table 5.11-4, SCAG household growth projections estimate that by 2045 the number of households within the City will grow by 21.2 percent (5,395 households), and that growth within the County will be higher at 34.8 percent. Assuming that the maximum number of residential units in the proposed TVSP are developed and occupied (no vacancy), the 2,400 additional households in the TVSP area would consist of a 9.4 percent increase of households citywide, which is within the SCAG anticipated growth of both the City and the County. Therefore, the Project would not induce unplanned population growth.

The residential development pursuant to the TVSP would consist mostly of infill, mixed-use, and redevelopment projects that are market and need dependent. Development that would occur under the proposed TVSP would help the City accommodate and balance the land use of anticipated growth as opposed to substantially increasing growth. The residential development that would occur under the proposed Project would help to meet housing demands from projected employment growth in the City while maintaining a healthy vacancy rate. As further described below, implementation of the proposed TVSP would assist to balance the need for additional housing related to employment growth and to improve the future jobs-to-housing balance. Overall, impacts related to residential growth would be less than significant.

Non-Residential Development. Implementation of the TVSP would result in long-term employment opportunities that would be generated from approximately 265,000 square feet of new retail commercial, approximately 238,000 square feet of new office uses, and approximately 110,000 square feet of new hotel uses. Because the future tenants are unknown, the number of jobs generated from operation cannot be precisely determined. However, based on the General Plan estimate of one employee for every 500 square Redlands Regular Meeting of 10-18-22 916 of 1815
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feet of non-residential uses, the Project is estimated to result in approximately 1,226 job opportunities. As described in Table 5.11-5, SCAG projects an increase of 13,700 jobs in the City by 2045. The jobs provided through the TVSP would accommodate 8.9 percent of the anticipated growth. Therefore, the Project would not induce unplanned business or employment growth.

Also, Table 5.11-6 shows that the number of new jobs is anticipated to outpace the number of new households by 2045. The residential units generated from the proposed Project would provide for a balanced ratio of jobs and housing and provide for housing near transit and in a walkable environment. Thus, the housing that would be accommodated by the proposed TVSP would result in a beneficial impact related to the balance of jobs and housing; and impacts related to the jobs-housing balance from implementation of the proposed TVSP would be less than significant.

Construction. Construction of projects that would occur as a result of the proposed TVSP would include a need for construction labor. Due to the employment patterns of construction workers in Southern California, and the large market for construction labor in San Bernardino County, construction workers are not likely to relocate their households as a consequence of the job opportunities presented by construction projects in the TVSP area. The construction industry differs from most other industry sectors in several important ways that are relevant to potential impacts on housing:
• There is no regular place of work. Construction workers commute to job sites that change many times in the course of a year. These often-lengthy daily commutes are made possible by the off-peak starting and ending times of the typical construction work day. • Many construction workers are specialized (e.g., crane operators, steel workers, masons), and move from job site to job site as dictated by the demand for their skills. • The work requirements of most construction projects are also specialized and workers are employed on a job site only as long as their skills are needed to complete a particular phase of the construction process.

It is reasonable to assume that construction workers for developments that would occur pursuant to the proposed TVSP would be drawn from the existing labor force in the surrounding area, and, because a typical construction worker would be employed at several different construction sites during any given year, would not relocate their households’ places of residence as a consequence of working at a particular construction site in the City of Redlands. Therefore, construction related employment that would be generated from implementation of the proposed TVSP would not induce substantial unplanned and impacts would be less than significant.

Infrastructure. The Project provides a framework for development of a walkable, mixed-use environment around the three new Arrow stations. A key component of this framework is a network of complete, multimodal streets that provide for pedestrians, bicyclists, transit patrons, and motorists that includes various roadway improvements, pedestrian improvements, and bicycle route improvements. These circulation improvements do not provide accessibility in new areas that would result in additional growth; these improvements would enhance the existing circulation system to provide for multi-model transportation. The Project includes water system infrastructure improvements to potable and non-potable water mains due to age and size to provide reliable fire suppression and adding non-potable water mains to serve the New York Street/Esri and Downtown station areas. Similarly, sewer system improvements would include replacement of existing lines. The utility improvements included in the Project, do not provide for development in new areas that would result in additional growth. The utility improvements are needed due to aged infrastructure and to provide for the anticipated growth within the urban and developed area of the City on undeveloped and underdeveloped parcels that are within walking distance of transit and employment Redlands Regular Meeting of 10-18-22 917 of 1815
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opportunities. Therefore, the proposed infrastructure included in the TVSP would not induce unplanned population growth either directly or indirectly that could cause substantial adverse physical changes in the environment, and impacts would be less than significant.

5.11.7 CUMULATIVE IMPACTS
Impacts from cumulative population growth are considered in the context of their consistency with local and regional planning efforts. As discussed, SCAG’s 2020-2045 RTP/SCS sets forth land use strategies that help the region achieve state greenhouse gas emission reduction goals and assist the South Coast Air Quality Management District prepare its Air Quality Management Plan (AQMP) The Project would not exceed the SCAG population, housing, and employment growth projections for the City. Based on the growth projections analyzed in SCAG’s 2020-2045 RTP/SCS, full buildout of the Project, including buildout of up to 2,400 additional dwelling units and 613,000 square feet of retail commercial, hotel, and office space would represent approximately 8.9 percent of projected employment growth and 9.2 percent of projected housing growth in the City through 2045.The project is within the growth projections used to prepare RTP/SCS) and AQMP), Thus, impacts related to cumulative growth would be less than significant and not cumulatively considerable.

5.11.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS OR POLICIES
Existing Regulations
None.

Standard Conditions
None.

Plans, Programs, or Policies
None.

5.11.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact POP-1 would be less than significant.

5.11.10 MITIGATION MEASURES
No mitigation measures are required.

5.11.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to population and housing would occur.

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REFERENCES
California Department of Finance. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2011-2021 with 2010 Census Benchmark (DOF 2021). Accessed:
http://www.dof.ca.gov/Forecasting/Demographics/Estimates/E-5/.

City of Redlands 2021-2029 Housing Element. Accessed: https://www.cityofredlands.org/post/2021- 2029-housing-element
SCAG. 2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy (SCAG 2020).

Accessed: https://www.connectsocal.org/Pages/Connect-SoCal-Final-Plan.aspx.

SCAG. 2019 Local Profile for City of Redlands. Accessed: https://scag.ca.gov/sites/main/files/fileattachments/redlands_localprofile.pdf?1606014831 SCAG. Connect SoCal Demographics and Growth Forecast. 2020 September 3. https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growthforecast.pdf?1606001579 United States Census Bureau.
https://data.census.gov/cedsci/map?q=All%20counties%20in%20California&tid=ACSDP5Y2019.DP03& vintage=2019&layer=VT_2019_050_00_PY_D1&cid=DP03_0034E&mode=customize State of California Employment Development Department Labor Force and Unemployment Rate for Cities and Census Designated Places. Accessed: https://www.labormarketinfo.edd.ca.gov/data/labor-force-andunemployment-for-cities-and-census-areas.html Redlands Regular Meeting of 10-18-22 919 of 1815
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5.12 Public Services

5.12.1 INTRODUCTION
This section of the Draft EIR addresses impacts of the Project to public services, including fire protection and emergency services, police protection, school services, park services, and other public services, such as library and health services. This section addresses whether there are physical environmental effects of new or expanded public facilities that are necessary to maintain acceptable service levels. This section analyzes whether any physical changes resulting from a potential increase in service demands from Project implementation could result in significant adverse physical environmental effects. Thus, an increase in staffing associated with public services, an increase in calls for services, would not, by itself, be considered a physical change in the environment. However, physical changes in the environment resulting from the construction of new facilities or an expansion of existing facilities to accommodate the increased staff or equipment needs resulting from the Project could constitute a significant impact. 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.

5.12.2 REGULATORY SETTING

5.12.2.1 Federal Regulations
There are no Federal regulations pertaining to public services that would be applicable to the Project.

5.12.2.2 State Regulations
California Building Code
The California Building Code (CBC) includes fire safety requirements, including the installation of sprinklers in all commercial and residential buildings; the establishment of fire resistance standards for fire doors, building materials, and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildfire hazard areas.

California Fire Code
California Code of Regulations (CCR) Title 24, Part 9 (2016 California Fire Code) contains regulations relating to construction and maintenance of buildings, the use of premises, and the management of wildlandurban interface areas, among other issues. The California Fire Code is updated every three years by the California Building Standards Commission and was last updated in 2016 (adopted January 1, 2017).

The Fire Code sets forth regulations regarding building standards, fire protection and notification systems, fire protection devices such as fire extinguishers and smoke alarms, high-rise building standards, and fire suppression training. It contains regulations relating to construction, maintenance, and use of buildings. Topics addressed in the code also include fire department access, fire hydrants, automatic sprinkler systems, fire alarm systems, fire and explosion hazards safety, hazardous materials storage and use, provisions intended to protect and assist fire responders, industrial processes, and many other general and specialized fireRedlands Regular Meeting of 10-18-22 920 of 1815 Redlands General Plan Transit Villages District and Specific Plan Project 5.12 Public Services City of Redlands, CA 5.12-2
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safety requirements for new and existing buildings and the surrounding premises. Development under the Project would be subject to applicable regulations of the California Fire Code.

Mitigation Fee Act (California Government Code Sections 66000 et seq.) Enacted as Assembly Bill (AB) 1600, the Mitigation Fee Act requires a local agency, such as the City of Redlands to establish, increase, or impose an impact fee as a condition of development to identify the purpose of the fee and the use to which the fee is to be put. The agency must also demonstrate a reasonable relationship between the fee and the purpose for which it is charged, and between the fee and the type of development Project on which it is to be levied. This Act became enforceable on January 1, 1989 (California Legislative Information, 2019).

Quimby Act
The Quimby Act (California Government Code, Section 66477) was established by the California legislature in 1965 to develop new or rehabilitate existing neighborhood or community park or recreation facilities.

This legislation was enacted in response to the need to provide parks and recreation facilities for California’s growing communities. The Quimby Act gives the legislative body of a city or county the authority, by ordinance, to require the dedication of land or payment of in-lieu fees, or a combination of both, for park and recreational purposes as a condition of approval of a tract map or parcel map.

5.12.2.3 Local Regulations
Fire Protection and Emergency Services
City of Redlands General Plan
The Livable Community Element, Connected City Element, and Healthy Community Element of the General Plan set forth the following actions and principles for fire protection and emergency services:

Principle 4-P.30. Require that new development adheres to safety standards to protect against property damage, injury, or loss of life from fire or geological hazards.

Principle 5-P.7. Minimize emergency vehicle response time and improve emergency access.

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

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

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Policy 7-P.12. Create and maintain a system of trails serving both recreational and emergency access needs.

Action 7-A.96. Ensure that all-weather access is provided for all new development, with adequate clearance for emergency vehicles, designed in accordance with the California Fire Code, and ensure that all roads, streets, and major public buildings are identified in a manner that is clearly visible to fire protection and other emergency vehicles.

City of Redlands Fire Fees
The Project is required to comply with the provisions of the City of Redlands Fire Department Fees (Resolution No. 8045), which requires a fee payment for any developments requiring permitting that the City applies to the funding of fire protection facilities.

Police Services
City of Redlands General Plan
The Livable Community Element of the General Plan sets forth the following actions and principles for police services:

Principle 4-P.60. Locate police and fire resources where they can best serve the community.

Principle 4-P.61. Support community partnership and community-based policing strategies to enhance the relationship between the Redlands Police Department and neighborhoods throughout the city.

Action 4-A.153. Ensure that the Police and Fire departments have modern facilities and equipment needed to perform their duties.

Action 4-A.154. Support and expand neighborhood watch organizations and citizen volunteer patrols to assist the police in deterring crime.

Action 4-A.155. Continue to enact mutual aid agreements with neighboring police and fire jurisdictions as well as state agencies.

Action 4-A.156. Encourage the use of police substations throughout the city to increase the police presence in the neighborhoods.

Action 4-A.157. Include the Police and Fire departments in the review of new developments to provide feedback on building and site design safety.

Park Services
City of Redlands General Plan
The Healthy Community Element of the General Plan sets forth the following actions and principles promoting park and recreation facilities and programs:

Principle 7-P.1. Promote active lifestyles and community health by furthering access to trails, parks, public open space, and other recreational opportunities.

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5.12.3 ENVIRONMENTAL SETTING
Redlands Fire Department
The Redlands Fire Department (City Fire) would serve the TVSP area. City Fire provides fire suppression, emergency medical services (paramedic and non-paramedic), ambulance services, hazardous materials (HAZMAT) response, arson investigation, technical rescue, winter rescue operations, hazard abatement, and terrorism and weapons of mass destruction. The Fire Department provides services including fire prevention and suppression, emergency medical services, technical rescue, and hazardous materials response.

According to the Redlands General Plan EIR, the Redlands Fire Department recognizes two response time standards. The two standards include the National Fire Protection Association (NFPA), which recommends that the first arriving unit arrive within four minutes 90 percent of the time, and a more lenient goal of seven minutes 90 percent of the time, as recommended by the 2008 High-Level Fire Department Review for the Redlands Fire. According to the City of Redlands, the current 90 percent response time is nine minutes, which is over twice the NFPA standard and two minutes slower than the more lenient guideline.

The Fire Department consists of approximately 52 total sworn personnel, (including 44 firefighter/paramedics and 16 firefighter/EMTs) and covers an area of 37 square miles. In 2021, RFD received 11,836 calls for service and had 72,933 residents (California Department of Finance), which results in 0.16 calls per resident. The calls for service increased by an average by 6.65 percent in the three years between October 2016 and September 2019. Additionally, approximately 45 percent of the calls for service occur simultaneously. A majority of the increased calls were for emergency medical services (Citygate), which is consistent with the City’s Fire Department Assessment and Deployment Study (2020) that details that 63 percent of service calls in 2018/2019 were for emergency medical services. The RFD currently has a goal response time of 7 minutes, 90 percent of the time (Citygate, 2020). The TVSP area would be served by four fire stations as shown in Table 5.12-1 below. The City currently has plans to acquires sites for and to construct two new fire stations (Stations 265 and 266) in different parts of the City and relocate Station 264 based on the annual increase in calls for service and location of service need.

Table 5.12-1: Fire Stations
Fire Station Location
Station 261 525 East Citrus Avenue
Station 264 1270 West Park Avenue
Station 262 1690 Garden Street
Station 263 10 West Pennsylvania
Avenue
Source: City of Redlands Fire Department 2022
Redlands Police Department
Public safety services in the City, including the TVSP area, are provided by the Redlands Police Department (RPD). RPD’s main police station is located at 1270 West Park Avenue within the boundaries of the New York Street/Esri Transit Village. There are four other divisions located citywide. The Police Department personnel is made up of approximately 100 volunteers, 80 sworn officers and 58 full and part-time civilians, resulting in a service level of 1.12 officers per 1,000 residents. In 2020, the Department had an average response time of 9.08 minutes for Priority one police service calls and a service ratio of 1.1 officers per 1,000 residents. Although there are no industry standards for response time to emergency calls, according to the Redlands Police Department, a response time of 4.5 minutes is desirable in a city of this size. Table

5.12-2 below shows the location and staffing descriptions of the stations within the City.

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Table 5.12-2: Police Stations
Location Staffing Description
1270 W. Park Avenue Patrol, Custody, Dispatch
Records
30 Cajon Street Administration,
Investigations, MET,
Traffic/Special Events,
Crime Analysis,
Community Policing,
Property/Evidence
1150 Brookside Avenue Records Processing
111 W. Lugonia Avenue Community Policing
Officer
504 Kansas Street Animal Control Office Source: RPD, 2022 Park Services
Existing parks within the City include four pocket parks (1.8 acres), eight neighborhood parks (76.8 acres), six community parks (143.2 acres), and three other parks (202.4 acres) for a total of approximately 424.2 acres (GP2035 EIR, Table 3.13-1). At the estimated 2019 population of 71,513 residents, the ratio of existing parkland acres per 1,000 residents is 5.9, which exceeds the GP2035’s parkland/recreational space standard of 5.0 acres per 1,000 residents consistent with state law (Quimby Act). able 5.12-3, Existing Parks within the Project Area, shows the existing parks within the TVSP area as well as additional park information.

Table 5.12-3: Existing Parks within the TVSP Area
Park Type Park Name Location (in Redlands) Park Size Park Details Pocket Park Ed Hales Park 101 E. State St. 0.7 acre Picnic facilities in the downtown central business district
Neighborhood Park
Smiley Park
(Portion) 126 E. Eureka St.

9.2 acres
(Only a portion
located within
TVSP area)
Located at the Redlands Civic Center,
this park is home to A. K. Smiley Public
Library, the Lincoln Memorial Shrine, and
the Redlands Bowl
Jennie Davis Park 923 W. Redlands Blvd. 5.2 acres
Playground facilities and location of the
annual Veteran’s Day Parade and
Celebration
Community Park Sylvan Park
University St. between
Colton Ave. and Park
Ave.

23.3 acres
Open grassy areas, rose garden, picnic
areas, a playground, a
stage/bandstand area, a skate park, a
baseball/softball field, horseshoe pits,
bag toss, lawn bowling, and trails.

Other Park Terrace Park
Between N. Sixth St.
and Church St. on
Colton Ave.

2.4 acres
Linear park featuring landscaped treelined walkway with benches and drinking fountain
Source: City of Redlands, Facilities & Community Services Department, https://www.cityofredlands.org/parks, accessed March 2022.

Other Public Services
Other governmental services include the City’s library system. The A. K. Smiley Public Library, established in 1894, is a 34,000-square-foot facility located at 125 West Vine Street. In addition to its diverse collection of resource materials, the library system offers services and programs for all ages, including an adult literacy program. It also houses a museum, and the Lincoln Memorial Shrine. At the time the GP2035 was drafted, the library was in need of additional storage space for the museums, and plans were underway for an Redlands Regular Meeting of 10-18-22 924 of 1815
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adjunct building at 700 Brookside Avenue (formerly the Redlands Daily Facts building) for the Redlands Historical Museum (GP2035 EIR, p. 3.13-13).

5.12.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

PS-1 – Fire protection
PS-2 – Police protection
PS 3 – Schools
PS 4 – Parks
PS 5 – Other public facilities
The Initial Study established that the proposed Project would not result in impacts related to Threshold PS3; and no further assessment of this impact is required in this Draft EIR.

5.12.5 METHODOLOGY
The evaluation of impacts to public services is based on whether the existing public service can meet the demands of the Project, based on established thresholds, including maintaining acceptable service ratios, staffing levels, adequate equipment, response times, and other performance objectives that results in the need for new or the expansion of existing government services and facilities, including fire and police stations, schools, parks, libraries, community recreation centers, public health facilities, and animal shelters, that would result in significant adverse physical effects on the environment.

5.12.6 ENVIRONMENTAL IMPACTS
IMPACT PS-1: THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS ASSOCIATED WITH THE CONSTRUCTION OR EXPANSION OF FIRE FACILITIES.

Less than Significant Impact. Full buildout of the TVSP area pursuant to the TVSP would increase the demand for fire protection and emergency medical services. The threshold is whether the Project would result in inadequate staffing levels or require additional equipment, response times, and/or increase the demand for services that would then require the construction or expansion of fire station facilities that would have an adverse physical effect on the environment.

Development within the TVSP area would be installed with fire extinguishers, wet and dry sprinkler systems, pre-action sprinkler systems, fire alarm systems, fire pumps, backflow devices, and clean agent waterless fire suppression systems pursuant to the California Fire Code adopted as Chapter 15.20 of the Redlands Municipal Code, CBC, and other existing regulations regarding fire safety. Site access would be reviewed by City planning and the Redlands Fire Department to ensure that the proposed improvements would have adequate access for large fire trucks and vehicles. Future development within the TVSP would be required to meet fire and life safety standards, including smoke and carbon monoxide detectors, fire alarms, and residential fire sprinklers, among other building requirements. Their development plans would also be reviewed by City planning and fire departments to ensure state and county codes and requirements are implemented.

The General Plan EIR stated that the fire services have stated the needs for expansion in order to accommodate continued increase in population. However, development impact fees included as PPP PS-1 Redlands Regular Meeting of 10-18-22 925 of 1815
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would serve to ensure the maintenance of existing facilities and the timely provision of new facilities as needed. The fees collected would ensure the level of fire protection services are maintained and can be applied to the purchase of equipment, maintenance of existing facilities, and the construction of additional facilities, if needed in the future. Furthermore, future developments pursuant to the TVSP would be required to meet fire and life safety standards, including smoke and carbon monoxide detectors, fire alarms, and residential fire sprinklers, among other building requirements. Their development plans would also be reviewed by City planning and fire departments to ensure state and City codes and requirements are implemented.

Whether the City chooses to construct new fire stations in the future is too speculative to be considered as a Project-related impact. Any potential improvements would be subject to City policies that are designed to protect environmental resources as well as environmental review under CEQA, separate from this Project.

Therefore, with the payment of development fees included as PPP PS-1, Project impacts to fire services would be less than significant.

IMPACT PS-2 THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS

ASSOCIATED WITH THE CONSTRUCTION OR EXPANSION OF NEW OR PHYSICALLY ALTERED POLICE FACILITIES.

Less than Significant Impact. The service ratio for the City of Redlands is 1.1 officers per 1,000 residents.

Based on the new resident population of 6,360, the City would need to hire approximately 7 new officers to maintain the service ratio in the City. The increased residential population and increased commercial uses from buildout of the TVPS could increase the frequency of emergency and non-emergency calls to the Redlands Police Department, as compared to existing conditions. Buildout of the TVSP is not expected to increase demand for police protection to the extent that new facilities would be required. However, payment of development impact fees included as PPP PS-1 would serve to ensure the maintenance of existing facilities.

In addition, property tax revenue generated by development of the Project would provide funding for police services and would help to offset the Project’s increase in the demand for services. Therefore, impacts to police protection facilities would be less than significant.

IMPACT PS-4 THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS

ASSOCIATED WITH THE CONSTRUCTION OR EXPANSION OF NEW OR PHYSICALLY ALTERED PARK FACILITIES.

Less than Significant Impact. As discussed in Section 5.13, Population and Housing, full buildout of the TVSP would result in the generation of up to 6,360 residents. Without the development of new parks, this population increase would place additional physical demands on existing parks and recreational facilities, which could result in deterioration of existing facilities. The City of Redlands has a ratio of 5.9 acres of parkland per 1,000 residents which exceeds the state law requirement of 5.0 acres per 1,000 residents. As such, buildout of the TVSP would result in a demand for 31.8 acres of parkland. According to the City’s General Plan Parks and Recreational Open Space Element (Section 7.2), there are several different kinds of parks in Redlands, including community parks, neighborhood parks, and pocket parks. As discussed in Table 5.12-3, there are 4 existing parks totaling 40.8 acres within the TVSP area. The TVSP area at full buildout would provide an additional 280,000 SF (6.4 acres) of open space and park area which would bring the City’s total parkland acreage to 430.6 acres (not including any additional parkland that may be added in the future by the City outside the Project area).

Furthermore, the City’s mechanism for addressing parkland needs are its development impact fees as set forth in RMC Chapter 3.32 included as PPP PS-2. The funds would be used to maintain and operate the existing park facilities and construct additional facilities, as deemed warranted by the City. Development impact fees are charged by local governments to defray all or a portion of the cost of public facilities Redlands Regular Meeting of 10-18-22 926 of 1815
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related to development projects. Any potential new facilities would be subject to the City’s policies designed to protect environmental resources and environmental review under CEQA, which would be separate from this Project. Based on the TVSP’s provisions for additional parkland and the existing parkland within the TVSP area and the incremental population increase resulting from buildout of the TVSP, the Project would not result in overuse of existing parks and facilities that would result in substantial deterioration of existing facilities. Additional City policies requiring maintenance and funding of existing and future recreational facilities would ensure that parks within the TVSP are in good physical condition. The development of future recreational facilities would be subject to existing building and construction regulations that would ensure that construction activities have a minimal effect on the surrounding environment. These, along with Redlands General Plan policies established to protect environmental resources, air quality, and water quality, would ensure that future park construction within the TVSP would have a less than significant impact.

IMPACT PS-5 THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS

ASSOCIATED WITH THE CONSTRUCTION OR EXPANSION OF NEW OR PHYSICALLY ALTERED PUBLIC FACILITIES.

Less than Significant Impact. Other public facilities and services provided by the City include library services and City administrative services. As with all developments, the Project would contribute to the incremental demand for expanded government services and facilities, including libraries, community recreation centers, public health facilities, and/or animal shelters. The policies set forth by the Redlands General Plan ensure that within the city these public services are improved and expanded to meet demand as development occurs within the TVSP area. Future development of new public facilities would require project-level environmental review and site-specific mitigation measures as appropriate, ensuring that adverse environmental effects are avoided or mitigated. Additionally, the Project would generate new tax revenues that would contribute to and supplement existing revenue sources for the maintenance and enhancement of these facilities. Therefore, Project implementation would not adversely affect public facilities or require the construction of new or modified public facilities that are not already addressed in this document. Impacts would be less than significant.

5.12.7 CUMULATIVE IMPACTS
The Project would not significantly increase the need for public services in Redlands, cities surrounding Redlands, or the region. As discussed above, the Project applicant would pay the required City Development Impact Fees and Park Fees included as PPP PS-1 and PPP PS-2. Additionally, as discussed above, the Project would not impact acceptable service ratios, staffing levels, adequate equipment, response times, and other performance objectives or if the result in the need for new or the expansion of existing government services and facilities. Related projects in the region would be required to demonstrate their level of impact on public services and also pay their proportionate development fees. Therefore, the past, present, and future projects would not result in a cumulative impact related to the provision of public services.

5.12.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND PLANS,

PROGRAMS, OR POLICIES
Regulations
None.

Standard Conditions
None.

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Plans, Programs, or Policies
PPP PS-1: Development Impact Fees. As a standard requirement for implementing projects within the TVSP area, and prior to issuance of any building permits for the implementing project, the project applicants/developers shall pay all applicable City of Redlands Development Impact Fees (DIF) pursuant to the Redlands Municipal Code and/or adopted fee schedules.

PPP PS-2: Park Fees. As a Condition of Approval for implementing projects within the TVSP area, the project applicants/developers shall pay applicable park related fees pursuant to Redlands Municipal Code Chapter 3.32.

5.12.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements Impacts PS-1, PS-2, PS-4, and PS-5 would be less than significant.

5.12.10 MITIGATION MEASURES
No mitigation measures are required.

5.12.11 LEVELS OF SIGNIFICANCE AFTER MITIGATION
Compliance with regulatory programs would reduce potential impacts related to public services to less than significant. Therefore, no significant unavoidable adverse impacts would occur.

REFERENCES
City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/post/planning-divisiongeneral-plan City of Redlands General Plan EIR. 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/0-0-0-1977 Citygate Associates, LLC. Fire Department Assessment and Deployment Study. 25 June 2020. https://destinyhosted.com/redladocs/2020/CC/20200901_218/2879_Vol_1_- _Final_Redlands_FD_Assessment_and_Deployment_Study_Technical_Report_%2806-25-20%29.pdf Redlands Regular Meeting of 10-18-22 928 of 1815
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5.13 Recreation

5.13.1 INTRODUCTION
This section describes the recreational conditions in the TVSP area and potential impacts from Project implementation. 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 Municipal Code

5.13.2 REGULATORY SETTING

5.13.2.1 Federal Regulations
There are no federal regulations related to recreation that are applicable to the Project.

5.13.2.2 State Regulations
There are no federal regulations related to recreation that are applicable to the Project.

5.13.2.3 Local Regulations
City of Redlands General Plan
The City of Redlands Active Lifestyle Element contains the following policies related to recreation that is applicable to the Project:

Policy 7-P.1 Promote active lifestyles and community health by furthering access to trails, parks, public open space, and other recreational opportunities.

Policy 7-P.11 Maximize the availability of recreational facilities and activities throughout the city Policy 7-P.12 Create and maintain a system of trails serving both recreational and emergency access needs.

Action 7-A.3 Provide 5 acres of park area for each 1,000 Planning Area residents, and additional parkland for specialized, and low-use park acreage
Action 7-A.21 Require that the recreational needs of children and adults, including seniors and dependent adults, be addressed in development plans.

Action 7-A.29 Review new development proposals for compliance with the Trails Plan and provide for right-of-way dedication and improvement/development of trails.

City of Redlands Municipal Code
Chapter 3.32 Open Space and Park Fees: It is the purpose and intent of this chapter to implement the Redlands general plan to ensure that open space lands and active and passive parks are made available to the public concurrent with the need for such lands and parks caused by new development within the city.

The fees established pursuant to this chapter shall be imposed as a condition of approval of new residential, commercial, office, and industrial development to pay for the costs incurred by the city for acquiring, developing, improving and expanding open space areas, scenic drives, parks, playgrounds and recreational facilities to meet the increased needs for those facilities resulting from the effects of new development.

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5.13.3 Environmental Setting
Regional Parks
The San Bernardino County Regional Parks Department manages and maintains nine Regional Parks throughout San Bernardino County totaling approximately 9,200 acres. Each park offers diverse outdoor recreation opportunities in settings that range from metro, mountain, and desert scenery. Regional County recreational facilities near the TVSP area include the Santa Ana River Trail and Parkway which is approximately 6.9 miles from the Project site and the Yucaipa regional park which is approximately 10 miles from the Project site.

Local Parks
Existing parks within the City include four pocket parks (1.8 acres), eight neighborhood parks (76.8 acres), six community parks (143.2 acres), and three other parks (202.4 acres) for a total of approximately 424.2 acres (GP2035 EIR, Table 3.13-1). At the estimated 2019 population of 71,513 residents, the ratio of existing parkland acres per 1,000 residents is 5.9, which exceeds the GP2035’s parkland/recreational space standard of 5.0 acres per 1,000 residents consistent with state law (Quimby Act). There are several parks within the TVSP area that provide open space and recreational opportunities to surrounding residents, workers, and visitors. Table 5.13-1, Existing Parks within the Project Area, shows the existing parks within the TVSP area as well as additional park information.

Table 5.13-1: Existing Parks within the TVSP Area
Park Type Park Name Location (in Redlands) Park Size Park Details Pocket Park Ed Hales Park 101 E. State St. 0.7 acre Picnic facilities in the downtown central business district
Neighborhood Park
Smiley Park
(Portion) 126 E. Eureka St.

23.3 acres
Open grassy areas, rose garden, picnic
areas, a playground, a
stage/bandstand area, a skate park, a
baseball/softball field, horseshoe pits,
bag toss, lawn bowling, and trails.

Other Park Terrace Park
Between N. Sixth St.
and Church St. on
Colton Ave.

2.4 acres
Linear park featuring landscaped treelined walkway with benches and drinking fountain
Source: City of Redlands, Facilities & Community Services Department Recreational Facilities
Recreational facilities in Redlands include the Redlands Community Center, the Community Senior Center, the Joslyn Senior Center, neighborhood community gardens, and the Carriage House. Large open spaces, including the San Timoteo Canyon, Live Oak Canyon, and the Crafton Hills also provide recreational space.

The City of Redlands currently has joint use agreements with the Redlands Unified School District and the Grove School allowing public access to school recreational facilities. The agreement with the school district allows the City and the District to use facilities, parks, sports fields and classrooms as needed for community activities, such as the community gardens, adult and youth sports, and after school programs.

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Trails
The City of Redlands provides public trails for walking, jogging, bicycling, and equestrian use. Some trails are located within City parks and open space, while others act as linkages between the parks or to other regional trails. The Orange Blossom Trail runs the entire length of the TVSP area and the Sylvan Park Trail, the Church Street to Panorama Trail, and the Terrace Trail are located within the University Village.

5.13.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the State CEQA Guidelines indicates that a project could have a significant effect if the project would:

REC-1 Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

REC-2 Include recreational facilities or requires the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

5.13.5 METHODOLOGY
This analysis is based on a review of public information about San Bernardino County and City of Redlands parks and recreational facilities. The analysis considers the increase in use of parks and recreation facilities that would result from the increased development intensity from the proposed project, along with the ability of existing park and recreation facilities to accommodate the increased use. The analysis considers whether an increase in use would result in the substantial physical deterioration of existing recreational facilities, such as accelerated wear on sports facilities and fields, or in the need for new or expanded facilities.

5.13.6 ENVIRONMENTAL IMPACTS
IMPACT REC-1 THE PROJECT WOULD NOT INCREASE THE USE OF EXISTING NEIGHBORHOOD AND

REGIONAL PARKS OR OTHER RECREATIONAL FACILITIES SUCH THAT SUBSTANTIAL PHYSICAL DETERIORATION OF THE FACILITY WOULD OCCUR OR BE ACCELERATED.

Less than Significant Impact. As discussed previously in Table 5.13-1, there are 40.8 acres of existing parks within the TVSP area and 424.2 acres of parks within the City of Redlands. In addition, the Project area at full buildout would provide an additional 280,000 SF (6.4 acres) of open space and park area which would bring the City’s total parkland acreage to 430.6 acres. (not including any additional parkland that may be added in the future by the City outside the Project area).

In addition to parks, the City operates numerous recreational community centers and facilities, and has a joint use agreement with RUSD allowing public access to school recreational facilities. Other recreational opportunities include open spaces such as San Timoteo Canyon, Live Oak Canyon, Crafton Hills, and approximately 27.58 acres of recreational trails. At the estimated 2019 population of 71,513 residents, the ratio of existing parkland acres per 1,000 residents is 5.9, which exceeds the GP2035’s parkland/recreational space standard of 5.0 acres per 1,000 residents.

Without the development of new parks and recreational facilities, future increases would place additional physical demands on existing parks and facilities. The GP2035 provides for new parkland, recreational facilities, and trails to serve the City’s population as it grows. The City’s mechanism for addressing parkland and recreational facility needs are its development impact fees as set forth in RMC Chapter 3.32.

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Development impact fees are charged by local governments to defray all or a portion of the cost of public facilities related to development projects. The development impact fee program is set forth in Government Code Sections 66000-66025. In the City, development impact fees are collected at the time a building permit is issued for the purpose of further alleviating the impacts caused by new development on the City’s infrastructure. Fees are used to finance the acquisition, construction, and improvement of public facilities needed because of new development. A separate funding structure has been established to account for the impact of new development on each of the following types of public facilities: open space, parks and recreational facilities, public facilities (including public safety, library and general government facilities), transportation, water, solid waste, and sewer.

Individual development projects under the Project would be subject to the payment of these development impact fees to the City, which includes fees specific to TOD, as currently set forth in City Resolution No. 7951.

As noted, the addition of approximately 6,360 residents would place additional physical demands on existing parks and facilities.

The addition of 6,360 new residents as a result of the Project would increase the use of recreational facilities and would require approximately 31.8 acres of new parkland based on the parkland/recreational space standard of 5.0 acres per 1000 residents. Here, the proposed Project would provide 6.4 acres of parkland at full buildout which would result in a total of 430.6 acres of parkland and 77,873 residents. The Project would therefore result in a ratio of parkland acres per 1000 residents of 5.5 acres per 1,000 residents, which exceeds the GP2035’s parkland/recreational space standard of 5.0 acres per 1,000 residents. Thus, the Project would not significantly increase the use of existing parks or recreational facilities such that substantial physical deterioration would occur or be accelerated. Impacts would be less than significant.

IMPACT REC-2 THE PROJECT WOULD NOT INCLUDE RECREATIONAL FACILITIES OR REQUIRES THE

CONSTRUCTION OR EXPANSION OF RECREATIONAL FACILITIES WHICH MIGHT HAVE AN ADVERSE PHYSICAL EFFECT ON THE ENVIRONMENT.

Less than Significant Impact. The recreational trail and open space network, which is conceptually planned as part of the TVSP, would provide a contiguous green space connecting the TVSP villages. The proposed Zanja Greenway is located along a historic existing irrigation feature that traverses the TVSP area from Sylvan Boulevard in the University Transit Village southwest past the New York Street/Esri Transit Village.

The TVSP would install riparian landscaping along the Zanja Greenway, which also runs parallel to the Orange Blossom Trail. The TVSP also includes an open space plaza at State Street/Third Street, a midtown greenbelt in the Downtown Transit Village, a central park in the University Transit Village, and a neighborhood park in the New York Street/Esri Transit Village. The precise timing of open space or other public improvements are not known with certainty, as improvements would likely depend on the timing of future developments, buildout of private development projects, future availability and amounts of public grant funding or other public funds, and other factors. The development of future parkland and recreational facilities would be subject to existing building and construction regulations that would ensure that future construction activities have a minimal effect on the surrounding environment. Furthermore, individual recreational projects within the TVSP would be subject to the mitigation measures included throughout this EIR and the Redlands General Plan policies established to protect cultural resources, paleontological resources, air quality, and water quality. Adherence to existing regulations and mitigation measures included in this EIR would ensure that the Project would not result in construction or expansion of recreational facilities which might have an adverse impact on the environment, and impacts would be less than significant.

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5.13.7 CUMULATIVE IMPACTS
The geographic area in which cumulative impacts to recreation could occur is the nearby locations within portions of City of Redlands and San Bernardino County that the residents from the project would recreate a majority of the time. Recreational needs of the future residents within the proposed project and other cumulative development within the City of Redlands would add to local and regional demand for parks and recreational facilities. However, each project within the City is required to comply with the City’s open space and park fees as contained in the Chapter 3.32.040 of the City’s Municipal Code included as PPP PS-1. As individual developments within the TVSP would pay open space and park fees, the proposed Project would not contribute to a cumulatively considerable impact related to recreation. Furthermore, individual recreational facility and park projects would be required to undergo CEQA review, which would ensure that no significant impacts would occur from development of future parkland or recreational facilities. Cumulative impacts related to recreation would be less than significant.

5.13.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Regulations
None.

Standard Conditions
None.

Plans, Programs, or Policies
PPP PS-1: Park Fees. As a Condition of Approval for implementing projects within the TVSP area, the project applicants/developers shall pay applicable park related fees pursuant to Redlands Municipal Code Chapter 3.32.

5.13.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impacts REC-1 and REC-2 would be significant.

5.13.10 MITIGATION MEASURES
No mitigation measures are required.

5.13.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts associated with recreation are less than significant.

REFERENCES
City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/post/planning-divisiongeneral-plan Redlands Regular Meeting of 10-18-22 934 of 1815
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City of Redlands Municipal Code. Accessed:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1977 Redlands Regular Meeting of 10-18-22 935 of 1815
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5.14 Transportation

5.14.1 INTRODUCTION
This section addresses potential transportation impacts that may result from implementation of the Specific Plan. The following discussion addresses the existing transportation conditions in the Project area, identifies applicable regulations, evaluates the Project’s consistency with applicable goals and policies, identifies and analyzes environmental impacts, and recommends measures to reduce or avoid adverse impacts anticipated from implementation of the Project. The analysis in this section is based on the following resources:
• City of Redlands General Plan 2035, December 2017
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report, Dyett & Bhatia, July 2017
• City of Redlands Municipal Code
• City of Redlands CEQA Assessment VMT Analysis Guidelines, • Vehicle Miles Traveled (VMT) Screening Analysis, EPD Solutions, 17 January 2022. Included as Appendix I.

Transportation Terminology
• Traffic Analysis Zone (TAZ). Traffic Analysis Zone (TAZ) refers to the geographic unit used for traffic analysis within transportation planning models, such as the San Bernardino County Transportation Authority’s VMT Screening Tool model. A TAZ is a special area delineated by state and/or local transportation officials for tabulating traffic-related data especially journey-to-work and place-of-work statistics. A TAZ usually consists of one or more census blocks, block groups, or census tracts.
• Transit Priority Area (TPA). As defined by SB 743, a Transit Priority Area (TPA) is an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in the applicable regional transportation plan. • Low VMT Area. Low VMT areas are defined as TAZs with a total daily VMT/Service Population (employment plus population) that is 15% less than the baseline level for the County.

5.14.2 REGULATORY SETTING

5.14.2.1 State Regulations
Senate Bill 743 (Steinberg, 2013)
On September 27, 2013, Senate Bill (SB) 743 was signed into state law. The California legislature found that with the adoption of the Sustainable Communities and Climate Protection Act of 2008 (SB 375), the state had signaled its commitment to encourage land use and transportation planning decisions and investments that reduce vehicle miles traveled (VMT) and thereby contribute to the reduction of greenhouse gas (GHG) emissions, as required by the California Global Warming Solutions Act of 2006 (AB 32).

SB 743 requires the California Governor’s Office of Planning and Research to amend the State CEQA Guidelines to provide an alternative to LOS as the metric for evaluating transportation impacts under CEQA.

Particularly within areas served by transit, SB 743 requires the alternative criteria to promote the reduction of greenhouse gas emissions, development of multimodal transportation networks, and diversity of land uses.

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5.14.2.2 Regional Regulations
Regional Transportation Plan/Sustainable Communities Strategy The Southern California Association of Governments (SCAG) is the designated metropolitan planning organization for six Southern California counties (Ventura, Los Angeles, San Bernardino, Riverside, Orange, and Imperial). As the designated metropolitan planning organization, SCAG is mandated by the federal and state governments to prepare plans for regional transportation and air quality conformity. The most recent plan adopted by SCAG is the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also known as Connect SoCal, which was adopted in September 2020. The RTP/SCS integrates transportation planning with economic development and sustainability planning and aims to comply with state GHG emissions reduction goals, such as SB 375. With respect to transportation infrastructure, SCAG anticipates, in the RTP/SCS, that the six-county region will have to accommodate 22.5 million residents by 2045 while also meeting the GHG emissions reduction targets set by the California Air Resources Board. SCAG is empowered by state law to assess regional housing needs and provide a specific allocation of housing needs for all economic segments of the community for each of the region’s counties and cities. In addition, SCAG has taken on the role of planning for regional growth management.

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

Principle 5-P.2 Use the layered network approach to identify, schedule, and implement roadway improvements as development occurs in the future, and as a standard against which to evaluate future development and roadway improvement plans.

Principle 5-P.4 Support transportation infrastructure improvements such as safer street crossings and attractive streetscapes to encourage bicyclists, walkers, and users of mobility devices.

Principle 5-P.5 Manage the city’s transportation system to minimize traffic congestion, improve flow, and improve air quality.

Principle 5-P.7 Minimize emergency vehicle response time and improve emergency access.

Principle 5-P.8 Ensure the safety of the transportation network by preventing excessive speeding of vehicular traffic and promoting safe sharing of the network by all transportation modes.

Principle 5-P.10 Require developers to construct or pay their fair share toward improvements for all travel modes consistent with the layered network.

Principle 5-P.11 Implement standards for pavement design and roadway and intersection striping so streets are accessible by all users and all modes, and safety is improved.

Principle 5-P.13 Ensure streets are designed to accommodate bicyclists per the Bicycle Master Plan.

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Principle 5-P.14 Design streets to accommodate various modes according to roadway classification and reduce conflicts and safety risks between modes per Figure 5-4.

Principle 5-P.16 Strengthen active transportation circulation routes within Downtown and the Transit Villages, and to/ from adjacent neighborhoods.

Action 5-A.1 Maintain and update design standards for each functional roadway classification per Figure 5-4. These standards are for a typical midblock application. Additional turn lanes may be needed at some intersection approaches. Different standards may govern in specific plan areas and variations are permitted given site conditions and right-of-way availability.

Action 5-A.6 Add bike and pedestrian facilities on roads with excess capacity where such facilities do not exist, using supporting transportation plans as guidance. Excess capacity includes street right-of-ways or pavement widths beyond the standards, or excess capacity in roadways based on actual vehicular travel versus design capacity.

Action 5-A.7 Add new streets to create a finer grained, pedestrian-scaled road network where the roadway network is characterized by particularly long blocks, connecting residential areas to parks and Transit Village cores. Ensure the street systems in Transit Villages support development of connected and accessible communities.

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

Action 5-A.20 Provide pedestrian routes between offices, neighborhoods, Downtown, and Transit Villages. Plan for direct connections from the interiors of residential tracts to neighboring parks, schools, retail, and other services using sidewalks, trails, and paseos.

Principle 5-P.21 Develop bike routes that provide access to rail stations, Downtown, schools, parks, the University, employment, and shopping destinations.

Action 5-A.25 Implement bicycle and trail improvements that provide strong east-west connections between Transit Villages and in the city’s wider bicycle network. Routes would include the Orange Blossom Trail, the Mission Creek Zanja Trail routes on Colton Redlands Regular Meeting of 10-18-22 938 of 1815
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Avenue and Citrus Avenue, Santa Ana River Trail, and the San Timoteo Canyon Trail.

Action 5-A.26 Implement bicycle and trail improvements that provide strong north-south connections, especially with major east-west trails, including routes on Mountain View Avenue, California Street, Nevada Street, Alabama Street, Texas Street, New York Street, Orange Street, Church Street, Dearborn Street, and Wabash Avenue.

Action 5-A.27 Implement safety improvements in mid-block areas that allow for bicycles to safely cross heavily traveled roads. Improvements can include stop signs for cyclists, warning beacons, and illuminated signs initiated by pedestrians and cyclists.

Action 5-A.61 Support investments in passenger rail by providing effective on-site circulation and multi-modal connections to transit stations.

Action 5-A.68 Provide for direct pedestrian paths and access from new developments to the nearest public transportation stop.

Action 5-A.70 Locate Downtown public parking to encourage a park once approach. Provide pedestrian directional signage to direct persons from peripheral parking to downtown destinations.

Action 5-A.75 Consider techniques to reduce the amount of area in the Transit Villages occupied by parking, especially for developments located within easy walking distance of the Passenger Rail stations.

5.14.3 ENVIRONMENTAL SETTING
Table 5.14-1, Existing Major Roadway Characteristics within TVSP Area, shows the roadway characteristics that are observed within the TVSP area.

Table 5.14-1: Existing Major Roadway Characteristics within TVSP Area Roadway Classification Number of Lanes Bike Lane?
Redlands Boulevard
(E/W)
Boulevard (between
Alabama Street and
E Citrus Avenue),
Major Arterial
elsewhere
4-Lane Divided w/Concrete median,
except between Center Street and
1st Street
No
Orange Street
(N/S)
Boulevard (between
Redlands Boulevard
and Union Avenue),
Minor Arterial
elsewhere
4-Lane Divided w/Painted median No
Cajon Street (N/S) Minor Arterial 2-Lane Divided w/Painted median Class II Colton Avenue
(E/W)
Boulevard (between
Redlands Boulevard
and 6th Street)
2-Lane Divided w/Painted median Class III between Orange Street and Church Street
Brookside Avenue
(E/W) Major Arterial 2-Lane Divided w/Concrete median Class II Citrus Avenue
(E/W)
Major Arterial west
of Orange Street,
Minor Arterial East of
Orange Street
4-Lane Divided w/Concrete median
between Eureka Street and Orange
Street, 2-Lane Divided w/Painted
median elsewhere
Class III west of Redlands
Boulevard, Class II east of
Redlands Boulevard
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Roadway Classification Number of Lanes Bike Lane?
University Street
(N/S)
Boulevard between I10 and Colton
Avenue, Minor
Arterial south of I-10
and between Colton
Avenue and Lugonia
Avenue, Collector
north of Lugonia
Avenue
4-Lane Divided w/Painted median None
Tennessee Street
(N/S) Minor Arterial 4-Lane Divided w/Painted median Class III south of State Street Olive Avenue
(E/W) Collector 2-Lane Divided w/Painted median Class II Existing Transit Service
The TVSP area is served by bus service via Omnitrans, which serves the San Bernardino Valley. Omnitrans Route 8 connects San Bernardino and Yucaipa via Loma Linda, Redlands, and Mentone, including the TVSP area, with buses running every 60 minutes Monday through Sunday, and has stops along Redlands Boulevard and Lugonia Avenue. Omnitrans Route 15 serves the cities of Fontana and Redlands (including the TVSP area) via San Bernardino and Rialto, with buses running every 60 minutes Monday through Sunday, and has stops along Orange Street, Redlands Boulevard, and Eureka Street. Omnitrans Route 19 provides service between Fontana, the San Bernardino Transit Center, and Yucaipa. Route 19 has stops at the Redlands Mall and has buses running every 60 minutes, Monday through Sunday.

Furthermore, the San Bernardino County Transportation Authority’s newly built Arrow line connects the City of Redlands to the City of San Bernardino and provides further direct rail trips once a day to the City of Los Angeles. The Arrow line has three stops located at the center of each proposed Transit Village:
• New York/Esri Station: located north of the intersection of Redlands Boulevard and New York Street across from the Esri campus
• Downtown Station: located at the historic Redlands Santa Fe Depo, between Eureka Street and Orange Street
• University Station: located at the University of Redlands at the south end of campus near North University Street
Starting in 2022, during morning and afternoon peak commute hours, trains operate every 30 minutes.

During non-commute or off-peak hours, trains operate every 60 minutes. Weekday and weekend service is planned to start at 5 a.m. and run until 10 p.m. In addition to standard passenger rail service, the Metrolink Express train will be extended to serve the Redlands – Downtown Station with limited stop service to and from Los Angeles during peak commute hours.

Existing Bicycle and Pedestrian Facilities
As shown on Table 5.14-1, above, in the TVSP area, Brookside Avenue, Citrus Avenue, Cajon Street, Olive Street, and Colton Avenue, contain bicycle lanes. Furthermore, a Class I bicycle lane currently exists west of Center Street and east of Grove Street within the TVSP area.

Generally, throughout the TVSP area, sidewalks are provided on both sides of the street. University Street currently lacks sidewalks on some segments near the I-10 and Redlands Boulevard currently lacks sidewalks on some segments. Additionally, a multi-use trail, the Orange Blossom Trail, transverses the TVSP area east Redlands Regular Meeting of 10-18-22 940 of 1815
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of Center Street and west of Grove Street. Other multi-use trails exist on Church Street and a portion of Colton Avenue between 6th Street and Church Street.

5.14.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:
• TR-1 Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; • TR-2 Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b); • TR-3 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or • TR-4 Result in inadequate emergency access.

The Initial Study established that the proposed Project would result in less than significant impacts related to Thresholds TR-3 and TR-4. No further assessment of these impacts is required in this Draft EIR.

Vehicle Miles Traveled Significance Criteria
State CEQA Guidelines Section 15064.3(b)(1) provides that for land use projects:

VMT traveled exceeding an applicable threshold of significance may indicate a significant impact.

Generally, projects within 0.5 mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.

The City of Redlands’ VMT Guidelines provides VMT screening thresholds to identify projects that would be considered to have a less than significant impact on VMT and therefore could be screened out from further analysis. If a project meets one of the following criteria, then the VMT impact of the project would be considered less than significant and no further analysis of VMT would be required:

1. The project is in a Transit Priority Area (TPA).

2. The project is in a low VMT area.

3. The project is one of the following land uses:
o Local serving K-12 school
o Local park
o Daycare center
o Local-serving gas station
o Local-serving bank
o Local-serving hotel (e.g., non-destination hotel)
o Student housing project on or adjacent to a college campus o Local-serving assembly use (place of worship, community organization) o Community institution (public library, fire station, local government) o Local-serving community college that is consistent with the assumptions noted in the RTP/SCS o Affordable or supportive housing
o Assisted living facility
o Senior housing (as defined by the Federal Department of Housing and Urban Development)

4. The project generates less than 3,000 MT CO2e per year. This includes:
o Single family residential – 167 dwelling units (DU) or fewer o Multifamily residential (low-rise) – 232 DU or fewer
o Multifamily residential (mid-rise) – 299 DU or fewer
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o Office – 59,100 square feet (SF) or less
o Local-serving retail – 112.400 SF or less (no stores larger than 50,000 SF) o Warehousing – 463,600 SF or less
o Light industrial – 74,600 SF or less

5.14.5 METHODOLOGY
On September 27, 2013, Senate Bill (SB) 743 was signed into state law. The California legislature found that with the adoption of the Sustainable Communities and Climate Protection Act of 2008 (SB 375), the state had signaled its commitment to encourage land use and transportation planning decisions and investments that reduce vehicle miles traveled (VMT) and thereby contribute to the reduction of greenhouse gas (GHG) emissions, as required by the California Global Warming Solutions Act of 2006 (AB 32).

The alternative metric for transportation impacts detailed in the State CEQA Guidelines is VMT. Jurisdictions had until July 1, 2020, to adopt and begin implementing VMT thresholds for traffic analysis. As outlined in State CEQA Guidelines Section 15064.3, except as provided for roadway capacity transportation projects, a project’s effect on automobile delay shall not constitute a significant environmental impact. Therefore, in order to comply with CEQA Guidelines Section 15064.3, impacts associated with automobile delay are not analyzed in this Draft EIR.

Vehicle Miles Traveled Analysis Methodology
The applicability of each City of Redlands VMT Guidelines screening criterion was analyzed in relation to the proposed TVSP’s land uses, location, and proximity to transit. If the Project meets one of the screening criteria set forth in the City of Redlands VMT Guidelines, it can be presumed that the Project would result in a less than significant impact.

5.14.6 ENVIRONMENTAL IMPACTS
IMPACT TR-1: THE PROJECT WOULD NOT CONFLICT WITH A PROGRAM, PLAN, ORDINANCE, OR

POLICY ADDRESSING THE CIRCULATION SYSTEM, INCLUDING TRANSIT, ROADWAY, BICYCLE, AND PEDESTRIAN FACILITIES.

Less than Significant Impact.

Roadway, Transit, Bicycle, and Pedestrian Facilities
Roadway Network: As described in 5.14-1, the TVSP area includes a variety of roadway types. As shown on Figure 3-9, Future Street Network Improvements, the TVSP identifies multiple potential circulation network improvements such as transforming New York Street, Orange Street, and University Street into gateway streets; introducing new streets to promote walkability and to reestablish Redlands’ traditional street and block pattern; changing State Street between Orange Street and 7th Street into a two-way street; introducing a traffic signal at the intersection of Orange Street and Shoppers Lane; and upgrading crosswalks along University Street, among others. Implementation of these recommended roadway improvements would improve the circulation network within the TVSP area. Therefore, the proposed Project would not conflict with a plan, ordinance, or policy addressing roadway circulation, and impacts would be less than significant.

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Transit Facilities: As described previously, the TVSP area is served by Omnitrans Routes 8 and 15 and the newly constructed Arrow line. These existing transit services would continue to serve their ridership in the area and would serve residents, employees, and visitors within the TVSP area. The TVSP includes recommendations for transit facility upgrades such as rerouting of certain bus routes through the Downtown Village to provide more effective bus stops and providing bus routes through the University Village. While the TVSP provides certain recommendations for improving existing transit throughout the TVSP area, the proposed Project would not alter or conflict with existing transit stops and schedules, and impacts related to transit services would not occur.

Bicycle Facilities: As detailed previously, Brookside Avenue, Olive Avenue, and Cajon Street have Class II bike lanes. Citrus Avenue, Tennessee Street, and Colton Avenue have Class III bike lanes. Both the Redlands General Plan 2035 and TVSP identify New York Street and Church Street for Class III bike lanes and Tennessee Street, Redlands Boulevard, Colton Avenue, New York Street, Texas Street, Eureka Street, Citrus Avenue, Orange Street, Sixth Street, University Street, State Street, and Grove Street for Class II bike lanes, as shown on Figure 3-11, Future Bicycle Network Improvements. Furthermore, both the Redlands General Plan 2035 and TVSP identify extending the Orange Blossom Trail, a multi-use/Class I bike trail, westward from Grove Street to 9th Street through the TVSP area. Connection to the existing Class I portion of the Orange Blossom Trail in the New York Street Village, west of Texas Street, would be provided by a proposed Class II bike lane along Redlands Boulevard. Implementation of the Specific Plan would not alter or conflict with existing or planned bike lanes or bicycle transportation. Thus, impacts related to bicycle facilities would not occur.

Pedestrian Facilities: As detailed previously, sidewalks currently exist on streets throughout the majority of the TVSP area. However, the TVSP identifies multiple issues with existing pedestrian facilities throughout the TVSP area such as mega blocks, inadequate underpasses and intersections, and missing and deficient sidewalks. To enhance pedestrian facilities within the TVSP area, the TVSP provides recommendations for pedestrian-scaled blocks through the development of new streets that form blocks less than 500 feet by 500 feet; intersection improvements such as bulb-outs and pedestrian priority signal intervals; improvements for mid-block intersection crossings using pedestrian activated caution lights; and new signals at the intersection of Shoppers Lane and Orange Street; improved I-10 underpasses; a pedestrian crossing for the railroad tracks at the Downtown Village; and new sidewalks along University Street and Redlands Street. These proposed pedestrian facility improvements are shown in Figure 3-10, Future Pedestrian Network Improvements.

Implementation of the Specific Plan would include roadway improvements within the TVSP area that would provide for new sidewalks where none exist currently or provide for sidewalk improvements, thereby improving pedestrian facilities and the sidewalk network. Therefore, the proposed Specific Plan would also not conflict with pedestrian facilities, but instead would provide additional facilities. Overall, impacts related to transit, bicycle, and pedestrian facilities would be less than significant.

IMPACT TR-2: THE PROJECT WOULD CONFLICT OR BE INCONSISTENT WITH CEQA GUIDELINES SECTION 15064.3, SUBDIVISION (B) REGARDING VEHICLE MILES TRAVELED.

As described previously, State CEQA Guidelines Section 15064.3(b) focus on determining the significance of VMT-related transportation impacts. The proposed Project was analyzed in comparison to the City of Redlands VMT Guidelines. As discussed in the City of Redlands VMT Guidelines, if a project meets the screening criteria set forth in the guidelines, then it would be considered to have a less than significant impact on VMT. The applicability of each screening criteria, included in Section 5.14.4, in comparison to each TAZ within the proposed Project is discussed below.

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TAZs 53835601, 53827301, 53835602, 53834101, 53834102, 53835302, 53835303, 53835304, 53835702, 53834701, 53835701, 53834702, 53834303, 53835204, 53835501, 53834202, 53834302, 53834501, 53835203, 53835502, 53834201, 53834301, 53839202, 53839301, 53839201, 53840205, 53839101, 53834401, 53834502, 53837201, 53835202, and 53837101
Less than Significant Impact.

Screening Criteria 1 – TPA: According to the City’s guidelines, projects within one-half mile of an existing or planned major transit stop or an existing stop along a high-quality transit corridor are within a transit priority area (TPA). Traffic Analysis Zones (TAZs) within the TVSP area and within a TPA may be presumed to have a less than significant VMT impact so long as developments have a floor area ratio of 0.75 or more, provide less parking than required by the City of Redlands, are consistent with the applicable Sustainable Communities Strategy, and do not replace affordable units with a smaller number of moderate- or highincome residential units. As shown in Figure 5.14-1, Transit Priority Areas & Specific Plan TAZs, a large portion of the TVSP area, and its respective TAZs, is located within a TPA. As shown in Table 5.14-2, 29 of the TAZs within the TVSP area are fully within a TPA, five are partially within a TPA, and three are not within a TPA.

Implementing projects that are within the TVSP area and in TPAs, as shown on Figure 5.14-1, would be presumed to have a less than significant on VMT so long as they have a FAR of greater than 0.75 and provide less parking than required by the City of Redlands Municipal Code. However, at this time, specific development within this TAZ is unknown. Therefore, implementing projects consistent with the TVSP and consistent with the Screening 1 Criteria within TPAs would be presumed to have a less than significant impact on VMT. As TAZs 53835601, 53827301, 53835602, 53834101, 53834102, 53835302, 53835303, 53835304, 53835702, 53834701, 53835701, 53834702, 53834303, 53835204, 53835501, 53834202, 53834302, 53834501, 53835203, 53835502, 53834201, 53834301, 53839202, 53839301, 53839201, 53840205, and 53839101 are located fully within a TPA, implementing projects pursuant to the TVSP within these TAZs would result in less than significant impacts related to VMT.

Additionally, portions of TAZs 53834401, 53834502, 53837201, 53835202, and 53837101 are located within a TPA. Implementing projects within a TPA within those TAZs would result in a less than significant impact related to VMT.

Screening Criteria 2 – Low VMT Area: Low VMT areas are defined as TAZs with a total daily VMT/Service Population (employment plus population) that is 15% less than the baseline level for the County. TAZs within the TVSP area and in a low VMT area according to the San Bernardino Transportation Analysis Model (SBTAM) may be presumed to have a less than significant VMT impact. As shown in Table 5.14-2, all TAZs that are not located within, or are partially within, a TPA are in a low VMT area and would satisfy the low VMT area screening criteria, except for TAZ 53827101 and TAZ 53834601. TAZs 53834401, 53835301, 53835302, 53837201, 53835201, 53835202, 53837101, 53835203, and 53839101 are located within Low VMT areas. Therefore, implementing projects pursuant to the TVSP within these TAZs would have a less than significant impact on VMT.

Screening Criteria 3 – Land Use Type: If any implementing projects within the TVSP area consist of a local serving K-12 school, local park, daycare center, local-serving gas station, local-serving bank, local-serving hotel, student housing project on or adjacent to a college campus, local-serving assembly use, community institution, local-serving community college, affordable housing, assisted living facility, or senior housing, the implementing projects would screen out of further VMT analysis. Implementing projects within the aforementioned TAZs could potentially consist of the type of developments that would screen out via Screening Criteria 3; however, specific implementing developments are unknown at this time.

Screening Criteria 4 – Land Use Quantity: If an implementing project does not screen out of conducting a VMT analysis pursuant to City of Redlands’ screening criterion 1-3, if the project generates less than 3,000 MT CO2e, such as a project that proposes 167 single-family dwelling units or fewer, 232 low-rise multifamily dwelling units or fewer, 299 mid-rise multi-family dwelling units or fewer, 59,100 SF or less of office space, 112,400 SF or less (with no stores larger than 50,000 SF) of local-serving retail uses, 463,600 SF or less of warehousing uses, and 74,600 SF or less of light industrial uses, the project would screen out of further Redlands Regular Meeting of 10-18-22 944 of 1815
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VMT analysis. Implementing projects that generate less than 3,000 MT CO2e per year would be presumed to have a less than significant impact on VMT pursuant to Screening Criteria 4. Implementing projects within the aforementioned TAZs could potentially consist of the type of developments that would screen out via Screening Criteria 4; however, specific implementing developments are unknown at this time.

Overall, TAZs 53835601, 53827301, 53835602, 53834101, 53834102, 53835302, 53835303, 53835304, 53835702, 53834701, 53835701, 53834702, 53834303, 53835204, 53835501, 53834202, 53834302, 53834501, 53835203, 53835502, 53834201, 53834301, 53839202, 53839301, 53839201, 53840205, 53839101, 53834401, 53834502, 53837201, 53835202, and 53837101 would all screen out of further VMT analysis based on the City’s Screening Criteria 1 or 2 and implementing projects within these TAZs pursuant to the TVSP would result in a less than significant VMT impact.

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Transit Priority Areas & Specific Plan TAZs
Figure 5.14-1
Transit Priority Area
■ ■ ■
I ■ ■
=1 ■ ■ .. r ■ ■
.... ■
- "I II: :.. ■
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Table 5.14-2: Specific Plan Traffic Analysis Zones
Source: EPD Solutions, 2022 (Appendix I)
TAZ # TPA? TAZ VMT Jurisdiction VMT Threshold Low VMT Area? Screened 53827101 No 94.8 32.1 28.3 No No
53835601 Yes 119.8 32.1 28.3 No Yes
53827301 Yes 61.7 32.1 28.3 No Yes
53835602 Yes 61.5 32.1 28.3 No Yes
53834101 Yes 34.2 32.1 28.3 No Yes
53834401 Yes/No 20.3 32.1 28.3 Yes Yes
53834601 Yes/No 37.4 32.1 28.3 No Yes
53834102 Yes 173.8 32.1 28.3 No Yes
53835301 No 21.6 32.1 28.3 Yes Yes
53835302 Yes 22.3 32.1 28.3 Yes Yes
53835303 Yes 72.9 32.1 28.3 No Yes
53835304 Yes 79.3 32.1 28.3 No Yes
53835702 Yes 51.5 32.1 28.3 No Yes
53834701 Yes 89.4 32.1 28.3 No Yes
53835701 Yes 67.2 32.1 28.3 No Yes
53834702 Yes 98.0 32.1 28.3 No Yes
53834303 Yes 103.1 32.1 28.3 No Yes
53834502 Yes/No 39.0 32.1 28.3 No Yes
53837201 Yes/No 24.5 32.1 28.3 Yes Yes
53835201 No 17.6 32.1 28.3 Yes Yes
53835202 Yes/No 18.3 32.1 28.3 Yes Yes
53835204 Yes 177.5 32.1 28.3 No Yes
53835501 Yes 71.1 32.1 28.3 No Yes
53834202 Yes 53.2 32.1 28.3 No Yes
53834302 Yes 63.3 32.1 28.3 No Yes
53834501 Yes 46.5 32.1 28.3 No Yes
53837101 Yes/No 24.7 32.1 28.3 Yes Yes
53835203 Yes 22.0 32.1 28.3 Yes Yes
53835502 Yes 44.7 32.1 28.3 No Yes
53834201 Yes 49.4 32.1 28.3 No Yes
53834301 Yes 50.4 32.1 28.3 No Yes
53839202 Yes 33.2 32.1 28.3 No Yes
53839301 Yes 33.6 32.1 28.3 No Yes
53839201 Yes 39.4 32.1 28.3 No Yes
53840205 Yes 232.2 32.1 28.3 No Yes
53839101 Yes 20.8 32.1 28.3 Yes Yes
Note: In TAZ's noted as "Yes/No" unless highlighted, the TAZ is not completely within a TPA, however the portion of the project within the TAZ is completely within the TPA.

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TAZ 53834601
Less than Significant Impact. TAZ 53834601 is located in the southwest portion of the TVSP within the Downtown Village. Most of the implementing projects within this TAZ would fall within a TPA. However, there are five parcels that are not within the TPA (the addresses of the non-screened parcels are 15, 21, 23, 25 and 29 Kendall Street). These parcels are currently fully developed with single-family residences, and, when combined would total 1.06 acres in size.

Screening Criteria 1 – TPA: As shown in Figure 5.14-1, Transit Priority Areas & Specific Plan TAZs, a portion of TAZ 53834601 is located within a TPA. Implementing projects within TAZ 53834601 that are within the TPA, as shown on Draft EIR Figure 5.14-1 would screen out of a VMT analysis and can be presumed to have a less than significant impact on VMT. However, areas outside of the TPA within TAZ 53834601 would not be screened out of a VMT analysis based on Screening Criteria 1.

Screening Criteria 2 – Low VMT Area: As shown in Table 5.14-2, all TAZs that are not located within, or are partially within, a TPA are in a low VMT area and would satisfy the low VMT area screening criteria, except for TAZ 53827101 and TAZ 53834601. TAZ 53834601 is not located within a low VMT area. Therefore, 53834601 would not be screened out of a VMT analysis pursuant to Screening Criteria 2.

Screening Criteria 3 – Land Use Type: If any implementing projects within the TVSP area consist of a local serving K-12 school, local park, daycare center, local-serving gas station, local-serving bank, local-serving hotel, student housing project on or adjacent to a college campus, local-serving assembly use, community institution, local-serving community college, affordable housing, assisted living facility, or senior housing, the implementing projects would screen out of further VMT analysis. Based on the residential nature of the TAZ located outside of the TPA, implementing projects within these portions of the TAZ 53834601are unlikely to consist of the type of developments that would screen out via Screening Criteria 3. As such, TAZ 53834601 would not be screened out of a VMT analysis pursuant to Screening Criteria 3.

In order for projects within TAZ 53834601 to be presumed to have a less than significant VMT impact, developments located within TAZ 53834601 must adhere to the land use quantities presented in Screening Criteria 4 – Land Use Quantities. As discussed above, the parcels that do not screen out within TAZ 53834601 are currently fully developed with single-family residences and are not expected to be redeveloped with a denser use. Furthermore, based on the small size of the portion of TAZ 53834601 that does not screen out via Screening Criteria 1, it can definitively be assumed that based on the design and development guidelines within these parcels, implementing development pursuant to the TVSP would not result in more than 167 single-family dwelling units, 232 low-rise multi-family dwelling units, 299 mid-rise multi-family dwelling units, 59,100 SF of office space, 112,400 SF (with no stores larger than 50,000 SF) of local-serving retail uses, 463,600 SF of warehousing uses, and 74,600 SF of light industrial uses. As such, it can be reasonably presumed that any future development pursuant to the TVSP within the portion of TAZ 53834601 located outside of a TPA would meet the criteria set forth in Screening Criteria 4. Therefore, implementing projects pursuant to the TVSP within TAZ 53834601 would result in less than significant VMT impacts via Screening Criteria 1 or Screening Criteria 4.

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TAZ 53827101
Significant and Unavoidable Impact. As shown in Figure 5.14-1, TAZ 53827101 is located toward the western portion of the TVSP area by the Tri City Center. As shown in Figure 3-17, Vacant and NonConforming Parcels, two parcels within TAZ 53827101 are vacant and the rest are considered nonconforming. As such, it can be reasonably presumed that these parcels will be developed or redeveloped pursuant to the TVSP prior to buildout. However, at this time, specific development within this TAZ is unknown.

Screening Criteria 1 – TPA: As shown in Figure 5.14-1, Transit Priority Areas & Specific Plan TAZs, a portion of TAZ 53827101 is located within a TPA. Implementing projects within TAZ 53827101 that are within the TPA, as shown on Draft EIR Figure 5.14-1 would screen out of a VMT analysis and can be presumed to have a less than significant impact on VMT. However, areas outside of the TPA within TAZ 53827101 would not be screened out of a VMT analysis based on Screening Criteria 1.

Screening Criteria 2 – Low VMT Area: As shown in Table 5.14-2, all TAZs that are not located within, or are partially within, a TPA are in a low VMT area and would satisfy the low VMT area screening criteria, except for TAZ 53827101 and TAZ 53834601. TAZ 53827101 is not located within a Low VMT area. Therefore, TAZ 53827101 would not be screened out of a VMT analysis pursuant to Screening Criteria 2.

Screening Criteria 3 – Land Use Type: If any implementing projects within the TVSP area consist of a local serving K-12 school, local park, daycare center, local-serving gas station, local-serving bank, local-serving hotel, student housing project on or adjacent to a college campus, local-serving assembly use, community institution, local-serving community college, affordable housing, assisted living facility, or senior housing, the implementing projects would screen out of further VMT analysis. Implementing projects within TAZ 53827101 are unlikely to consist of the type of developments that would screen out via Screening Criteria 3. As such, TAZ 53827101 would not be screened out of a VMT analysis pursuant to Screening Criteria 3.

Screening Criteria 4 – Land Use Quantity: If a implementing project does not screen out of conducting a VMT analysis pursuant to City of Redlands’ screening criterion 1-3, if the project generates less than 3,000 MT CO2e, such as a project that proposes 167 single-family dwelling units of fewer, 232 low-rise multi-family dwelling units or fewer, 299 mid-rise multi-family dwelling units or fewer, 59,100 SF or less of office space, 112,400 SF or less (with no stores larger than 50,000 SF) of local-serving retail uses, 463,600 SF or less of warehousing uses, and 74,600 SF or less of light industrial uses, the project would screen out of further VMT analysis. Implementing projects that generate less than 3,000 MT CO2e per year would be presumed to have a less than significant impact on VMT pursuant to Screening Criteria 4.

As discussed above, parcels outside of a TPA within TAZ 53827101 do not meet Screening Criteria 1, 2, or

3. In order for projects within TAZ 53827101 to be presumed to have a less than significant VMT impact, developments located within TAZ 53827101 must adhere to the land use types presented in Screening Criteria 3 – Land Use Types or land use quantities presented in Screening Criteria 4 – Land Use Quantities.

The parcels that are not located within a TPA in TAZ 53827101 are currently developed with commercial uses associated with the Tri City Center and total approximately 40 acres. Therefore, there is potential that a large development, above the land use quantities presented in Screening Criteria 4 could be developed within the area located outside of the TPA and could potentially result in a VMT impact.

However, Mitigation Measure TR-1 is included to require implementing projects within a TPA and within TAZ 53827101 to conduct a VMT Screening Analysis or VMT Analysis prior to approval of any site plans. While it is likely that implementing projects would meet the criteria set forth in Screening Criteria 4, it is also possible that an implementing project would include development beyond the land uses provided for in Screening Criteria 4 and would result in more than 3,000 MT CO2e of GHG emissions per year. Additionally, anticipated VMT reductions from inclusion of Transportation Demand Management (TDM) measures for implementing projects that result in a VMT impact, are not large enough to guarantee that significant impacts from implementing projects could be fully mitigated. As such, despite inclusion of Mitigation Measure TR-1, impacts related to VMT would be significant and unavoidable.

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5.14.7 CUMULATIVE IMPACTS
Roadway, Transit, Bicycle, and Pedestrian Networks
The TVSP provides a comprehensive framework that would improve the street, transit, bicycle, and pedestrian networks throughout the TVSP area through buildout in 2040. This would include implementing roadway and circulation improvements, new bicycle and pedestrian facilities, and improving access to public transit. Overall, recommendations included in the TVSP would serve to improve the existing circulation networks with the TVSP area, and the City of Redlands as a whole, and cumulative impacts would be less than significant.

Vehicle Miles Traveled
The cumulative traffic study area for the proposed Project includes the City of Redlands. As discussed in the City of Redlands CEQA Assessment VMT Analysis Guidelines, projects that are consistent with the Redlands General Plan 2035 would not have a cumulative impact on VMT as General Plan buildout has been found to be consistent with the City’s threshold of VMT per capita that is 15 percent below baseline conditions. As substantiated within Section 5.9, Land Use and Planning, of this Draft EIR, the proposed Project would be consistent with the General Plan and the TVSP would serve as an implementing tool for City of Redlands General Plan 2035. Therefore, implementing projects would be consistent with the Redlands General Plan and would not result in cumulatively considerable VMT impacts. As such, the proposed Project would not result in cumulative impacts related to VMT.

5.14.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• SCAG 2020 - 2045 Regional Transportation Plan/Sustainable Communities Strategy Standard Conditions
None.

Plans, Programs, or Policies
None.

5.14.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impact TR-1 would be less than significant.

Regarding Impact TR-2, implementing projects within TAZs 53835601, 53827301, 53835602, 53834101, 53834102, 53835302, 53835303, 53835304, 53835702, 53834701, 53835701, 53834702, 53834303, 53835204, 53835501, 53834202, 53834302, 53834501, 53835203, 53835502, 53834201, 53834301, 53839202, 53839301, 53839201, 53840205, 53839101, 53834401, 53834502, 53837201, 53835202, and 53837101 would result in a less than significant VMT impact.

Additionally, implementing projects within TAZ 53834601 would result in a less than significant VMT impact.

Without mitigation, implementing projects within TAZ 53827101 would be potentially significant.

5.14.10 MITIGATION MEASURES
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Mitigation Measure TR-1: VMT Screening. Prior to approval of any site plan, any applicant for an implementing project within a TPA or TAZ 53827101 shall prepare a VMT Screening Analysis pursuant to the City of Redlands CEQA Assessment VMT Analysis Guidelines and provide this Analysis to the City of Redlands Planning Division and Engineering Division. The VMT Screening Analysis shall demonstrate that the implementing project meets the screening criteria set forth in in the City of Redlands CEQA Assessment VMT Analysis Guidelines.

If the implementing project does not meet the screening criteria set forth in Screening Criteria 1, 2, 3, or 4, the implementing project applicant shall prepare a VMT analysis pursuant to the City of Redlands CEQA Assessment VMT Analysis Guidelines, and, if necessary, provide mitigation in order to reduce VMT generated by the implementing project such as:
• Modifying the project’s build environment characteristics to reduce VMT generated by the project • Implementing Transportation Demand Management (TDM) measures to reduce VMT generated by the project
• Participating in an available VMT fee program and/or VMT mitigation exchange or banking program, if any exist, to reduce VMT from the project or other land uses to achieve acceptable levels
• Implementing pedestrian and sidewalk improvements consistent with the TVSP (i.e., wider than typical 5-foot-wide sidewalks for high-pedestrian traffic areas) • Constructing bicycle network improvements along the project’s frontage consistent with the TVSP

5.14.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact TR-2: Implementing projects within TAZ 53827101 have the potential to result in significant VMT impacts after implementation of Mitigation Measure TR-1. Implementing projects within the TAZ that do not meet Screening Criterion 1, 2, 3, or 4 could result in VMT levels where potential VMT reductions associated with TDM measures would not be large enough to guarantee that significant impacts could be fully mitigated.

REFERENCES
City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/sites/main/files/fileattachments/05_connected_city_low.pdf?1591207392 City of Redlands CEQA Assessment VMT Analysis Guidelines. Accessed:
https://www.cityofredlands.org/sites/main/files/file-attachments/redlands_vmt_analysis_guidelines.pdf EPD Solutions, Inc. Vehicle Miles Traveled (VMT) Screening Analysis. January 17, 2022. Appendix I.

Transit Villages Specific Plan. Accessed: https://redlandstransitvillages.org/wpcontent/uploads/2020/05/Ch.-5-Transportation-and-Circulation.pdf Redlands Regular Meeting of 10-18-22 952 of 1815
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5.15 Tribal Cultural Resources

5.15.1 INTRODUCTION
This section addresses potential impacts to tribal cultural resources (TCR) associated with implementation of the Project. 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)
Additionally, part of this analysis is based upon Project-specific coordination and consultation with California Native American tribes that are traditionally and culturally affiliated with the TVSP region.

5.15.2 REGULATORY SETTING

5.15.2.1 Federal Regulations
Archaeological Resources Protection Act
The Archaeological Resources Protection Act (ARPA) of 1979 regulates the protection of archaeological resources and sites on federal and Native American 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 (NPS 2018).

Native American Graves Protection and Repatriation Act (NAGPRA) NAGPRA is a federal law passed in 1990 that mandates museums and federal agencies to return certain Native American cultural items—such as human remains, funerary objects, sacred objects, or objects of cultural patrimony—to lineal descendants or culturally affiliated Indian tribes.

5.15.2.2 State Regulations
California Senate Bill 18
Senate Bill 18 (SB 18) (California Government Code Section 65352.3) sets forth requirements for local governments to consult with California Native American tribes identified by the California Native American Heritage Commission (NAHC) to aid in the protection of tribal cultural resources. The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early stage of planning to protect, or mitigate impacts on, tribal cultural resources. The Tribal Consultation Guidelines: Supplement to General Plan Guidelines (OPR, 2005), identifies the following contact and notification responsibilities of local governments:
• Prior to the adoption or any amendment of a general plan or specific plan, a local government must notify the appropriate tribes (on the contact list maintained by the NAHC of the opportunity to conduct consultations for the purpose of preserving, or mitigating impacts to, cultural places located on land within the local government’s jurisdiction that is affected by the proposed plan adoption or Redlands Regular Meeting of 10-18-22 954 of 1815
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amendment. Tribes have 90 days from the date on which they receive notification to request consultation, unless a shorter timeframe has been agreed to by the tribe (Government Code Section 65352.3).
• Prior to the adoption or substantial amendment of a general plan or specific plan, a local government must refer the proposed action to those tribes that are on the NAHC contact list and have traditional lands located within the city or county’s jurisdiction. The referral must allow a 45- day comment period (Government Code Section 65352). Notice must be sent regardless of whether prior consultation has taken place. Such notice does not initiate a new consultation process. • Local government must send a notice of a public hearing, at least 10 days prior to the hearing, to tribes who have filed a written request for such notice (Government Code Section 65092).

Because the proposed Project includes a General Plan Amendment, it is subject to the statutory requirements of SB 18 Tribal Consultation Guidelines.

California Assembly Bill 52
Assembly Bill 52 (AB 52) established a requirement under CEQA to consider “tribal cultural values, as well as scientific and archaeological values when determining impacts and mitigation.” Public Resources Code (PRC) Section 21074(a) defines “tribal cultural resources” (TCRs) as “[s]ites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe” that are either “[i]ncluded or determined to be eligible for inclusion in the California Register of Historical Resources” or “in a local register of historical resources.” Additionally, defined cultural landscapes, historical resources, and archaeological resources may be considered tribal cultural resources. PRC Section 21074(b), (c). The lead agency may also in its discretion treat a resource as a TCR if it is supported with substantial evidence.

Projects for which a notice of preparation for a Draft EIR was filed on or after July 1, 2015 are required to have lead agencies offer California Native American tribes traditionally and culturally affiliated with the project area consultation on CEQA documents prior to submitting an EIR in order to protect TCRs. PRC Section 21080.3.1(b) defines “consultation” as “the meaningful and timely process of seeking, discussing, and considering carefully the views of others, in a manner that is cognizant of all parties’ cultural values and, where feasible, seeking agreement.” Consultation must “be conducted in a way that is mutually respectful of each party’s sovereignty [and] recognize the tribes’ potential needs for confidentiality with respect to places that have traditional tribal cultural significance.” The consultation process is outlined as follows:

1. California Native American tribes traditionally and culturally affiliated with the project area submit written requests to participate in consultations.

2. Lead agencies are required to provide formal notice to the California Native American tribes that requested to participate within 14 days of the lead agency’s determination that an application package is complete or decision to undertake a project.

3. California Native American tribes have 30 days from receipt of notification to request consultation on a project.

4. Lead agencies initiate consultations within 30 days of receiving a California Native American tribe’s request for consultation on a project.

5. Consultations are complete when the lead agencies and California Native tribes participating have agreed on measures to mitigate or avoid a significant impact on a TCR, or after a reasonable effort in good faith has been made and a party concludes that a mutual agreement cannot be reached (PRC Sections 21082.3(a), (b)(1)-(2); 21080.3.1(b)(1)).

AB 52 requires that the CEQA document disclose significant impacts on TCRs and discuss feasible alternatives or mitigation to avoid or lessen an impact.

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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.

California Public Resources Code, Sections 5097.9 to 5097.991 PRC Sections 5097.9 to 5097.991 provide protection to Native American historical and cultural resources and sacred sites and identify the powers and duties of the NAHC. These sections also require notification to descendants of discoveries of Native American human remains and provide for treatment and disposition of human remains and associated grave goods.

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

Action 2-A.74 Proactively coordinate with the area’s native tribes in the review and protection of any tribal cultural resources discovered at development sites.

5.15.3 ENVIRONMENTAL SETTING
Native American Tribes
The TVSP area is within a region where the traditional use territories of the Serrano, Cahuilla, and Gabrielino meet. These three cultural groups spoke languages belonging to the Takic branch of the Shoshonean family, a part of the larger Uto-Aztecan language stock.

Serrano
The Serrano people once occupied the Mountain, North Desert, and East Desert Regions of present-day San Bernardino County. Mainly due to the inland territory that the Serrano occupied beyond Cajon Pass, contact between Serrano and Europeans was minimal. As early as 1790, some Serrano people were drawn into mission life. After a failed attack of the Mission San Gabriel in 1811, some Serrano people relocated to Morongo with the Cahuilla tribe. Others followed the Serrano leader Santos Manuel toward the San Bernardino County valley floors and eventually settled to become the San Manuel Band of Mission Indians Reservation.

Cahuilla
The eastern portion of the Valley Region, the southeastern part of the Mountain Region, and the southern portion of the East Desert Region of San Bernardino County were once home to the Cahuilla people. It is thought that the Cahuilla migrated to southern California approximately 2,000 to 3,000 years ago with related sociolinguistic groups, most likely from the southern Sierra Nevada Mountain ranges. The Cahuilla settled in a territory that extended from the present-day city of Riverside to the central portion of the Salton Sea in the Colorado Desert, and from the San Jacinto Valley to the San Bernardino Mountains.

Gabrielino
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The Gabrielino historically occupied the southwestern portion of San Bernardino County, including the Valley Region. The name Gabrielino denotes the people who were under the control of the Spanish from Mission San Gabriel, which included people from the Gabrielino proper as well as other social groups. Many contemporary Gabrielino identify themselves as descendants of the indigenous people living across the plains of the Los Angeles Basin and use the native term Tongva. Historic-era Tongva settlements in the San Bernardino Valley were primarily located at the base of the foothills and along perennial watercourses.

Tribal Cultural Resources
A search of the NAHC Sacred Lands File yielded positive results within the TVSP area. As discussed in Section

5.3, Cultural Resources, two prehistoric archaeological resource sites are located within the TVSP area, which are listed in Table 5.3-1, Recorded Prehistoric Cultural Resources. Furthermore, the Mill Creek Zanja transverses the proposed TVSP area. The historic feature was designated a California Historical Landmark No. 43 in 1932 and placed on the National Register of Historic Places in 1977. 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 storm runoff. It is the oldest continuously operating irrigation canal in California, and the oldest civil engineering project in Southern California. It runs through University Street and New York Street.

Through a study for the Passenger Rail Project by ICF International in 2014, a segment of the Mill Creek Zanja was found ineligible for the NR. The portion of the Mill Creek Zanja that is located west of Division Street to the southwest and terminates west of the concrete channel at Ninth Street. This portion is no longer eligible for listing in the NR due to its loss of historic integrity (ICF International 2014). The segment mentioned above does not resemble the Mill Creek Zanja segment to the east which was described in the 1976 Nomination Form and appears it was excluded from the 1976 nomination because of its lack of resemblance (ICF International 2014). In August 2014, SHPO concurred with the determination of National Register eligibility and Section 106 finding of effect regarding the evaluated segment of the Mill Creek Zanja (MCC 2022). Based on AB 52 and SB 18 consultation, the Soboba Band of Luiseño Indians described that there is a potential of encountering historic and prehistoric resources near the Zanja.

5.15.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

TCR-1: Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k); or TCR-2: A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

5.15.5 METHODOLOGY
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The analysis within this Draft EIR section is based on the Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments that was prepared by Material Culture Consulting, January 2022, and information compiled through Native American Consultation. The City requested a sacred lands record search from the Native American Heritage Commission (NAHC). The NAHC responded on July 3, 2018 that there are known sacred lands within a half mile of the TVSP boundaries.

In compliance with SB 18 and AB 52, on January 9, 2020, the City sent letters to Native American groups or individuals that may have knowledge regarding tribal cultural places in the TVSP area. • Agua Caliente Band of Cahuilla Indians
• Big Pine Paiute Tribe of Owens Valley
• Cabazon Band of Mission Indians
• Chemehuevi Indian Tribe
• Colorado River Indian Tribes of the Colorado River Indian Reservation • Fort Mojave Indian Tribe
• Kern Valley Indian Community
• Gabrieleno Band of Mission Indians – Kizh Nation
• Gabrieleno/Tongva San Gabriel Band of Mission Indians • Gabrielino/Tongva Nation
• Morongo Band of Mission Indians
• Pechanga Band of Luiseño Indians
• Ramona Band of Cahuilla Tribe
• San Manuel Band of Mission Indians
• Serrano Nation of Mission Indians
• Soboba Band of Luiseno Indians
• Torres-Martinez Desert Cahuilla Indians
• Twenty-Nine Palms Band of Mission Indians
Responses were received from two tribes, the San Manuel Band of Mission Indians and the Soboba Band of Luiseño Indians. A SB 18 consultation was requested by the San Manuel Band of Mission Indians on February 13, 2020 and started via email on May 6, 2020 and August 30, 2021. The San Manuel Band of Mission Indians considers the TVSP area sensitive for tribal cultural resources due to the presence of the Mill Creek Zanja. A SB 18 consultation was requested by the Soboba Band of Luiseño Indians on April 8, 2020 and started via email on May 6, 2020 and August 30, 2021. The Soboba Band of Luiseño Indians consulted with City on September 9, 2021 and considers the area sensitive for cultural resources as several sites are located nearby. Furthermore, due to the presence of portions of the Mill Creek Zanja within the TVSP area, the Soboba Band of Luiseño Indians described that there is a potential of encountering historic and prehistoric resources near the Zanja. As such, the consulting tribes requested inclusion of mitigation due to the potential of the Project to unearth previously undocumented tribal cultural resources during construction.

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

SIGNIFICANCE OF A TRIBAL CULTURAL RESOURCE THAT IS LISTED OR ELIGIBLE FOR

LISTING IN THE CALIFORNIA REGISTER OF HISTORICAL RESOURCES, OR IN A LOCAL

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Less than Significant with Mitigation Incorporated. The Mill Creek Zanja, which is considered a tribal cultural resource by multiple area tribes, is listed on the California Register of Historical Resources and the National Register of Historic Places (MCC 2022).

SB 18 and AB 52 require meaningful consultation between lead agencies and California Native American tribes regarding potential impacts on TCRs. As described above, TCRs are sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either eligible or listed in the California Register of Historical Resources or local register of historical resources (PRC Section 21074). As outlined above, the NAHC’s Sacred Lands File search was positive for sacred lands within 0.5-mile of the TVSP area, and the City sent letters to Native American Tribes notifying them of the proposed project in accordance with SB 18 and AB 52. In response, San Manuel Band of Mission Indians and the Soboba Band of Luiseño Indians, California Native American tribes, requested consultation and the City of Redlands met with representatives of the San Manuel Band of Mission Indians and the Soboba Band of Luiseño Indians. The Mill Creek Zanja was identified as a tribal cultural resource during the consultation.

Due to the presence of portions of the Mill Creek Zanja within the TVSP area, the Soboba Band of Luiseño Indians described that there is a potential of encountering historic and prehistoric resources near the Zanja.

Implementation of the proposed TVSP would not directly result in physical construction that could impact tribal cultural resources. However, development and redevelopment projects pursuant to the TVSP could involve grading and excavation to greater depths than previously undertaken that could disturb unknown buried TCRs. Thus, Mitigation Measures CUL-2 through CUL-9 and TCR-1 through TCR-4 are required for implementing projects and would reduce the potential for tribal cultural resources to be impacted during earthmoving activities and provides for preservation of any identified resources.

With implementation of Mitigation Measures CUL-2 through CUL-9 and TCR-1 through TCR-4, impacts related to a substantial adverse change in the significance of a tribal cultural resource would be less than significant.

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

SIGNIFICANCE OF A RESOURCE DETERMINED BY THE LEAD AGENCY, IN ITS

DISCRETION AND SUPPORTED BY SUBSTANTIAL EVIDENCE, TO BE SIGNIFICANT

PURSUANT TO CRITERIA SET FORTH IN SUBDIVISION (C) OF THE PUBLIC RESOURCES CODE SECTION 5024.1, THAT CONSIDERS THE SIGNIFCANCE OF THE RESOURCES TO A CALIFORNIA NATIVE AMERICAN TRIBE.

Less than Significant with Mitigation Incorporated. As described in Section 5.3, Cultural Resources, the Specific Plan is located in an urbanized area; however, future site-specific development projects pursuant to the Specific Plan could involve grading and excavation to greater depths than previously undertaken that could disturb buried archaeological resources, including tribal cultural resources. Thus, Mitigation Measures CUL-2 through CUL-9 are included to reduce the potential for archaeological resources, which include tribal cultural resources, to be impacted during earthmoving activities and provides for preservation of any identified resources. Furthermore, as a result of SB 18 and AB 52 tribal consultation, Mitigation Measures TCR-1 through TCR-4 are included to require tribal monitoring for sites that are sensitive for tribal cultural resources and provisions for inadvertent discoveries of tribal cultural resources. With implementation of Mitigation Measures CUL-2 through CUL-9 and TCR-1 through TCR-4, impacts related to a substantial adverse change in the significance of a tribal cultural resource would be less than significant.

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5.15.7 CUMULATIVE IMPACTS
The cumulative study area for tribal cultural resources includes the Southern California region, which contains the same general tribal historic setting of the Gabrieleño, Cahuilla, and Serrano, as detailed previously in Section 5.15.3, Environmental Setting. Other projects in the vicinity of the TVSP area would involve ground disturbances that could reveal buried TCRs.

As described above, there is a possibility that ground-disturbing activities in native soils may uncover or disturb unknown tribal cultural resources. However, the Project has included Mitigation Measure CUL-1 and TCR-1 through TCR-4 that would reduce the potential impact to unknown resources, and cumulative development would be required to undergo environmental review, which would establish requirements for avoidance or mitigation of impacts potential resources. Thus, the cumulative effects of development on tribal cultural resources from implementation of the proposed Specific Plan in combination with other projects would be less than significant.

5.15.8 EXISTING REGULATIONS, STANDARD CONDITIONS, AND

PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• California Government Code Sections 5097.9-5097.99
• California Health and Safety Code Section 7050.5
• California Public Resources Code Sections 21073 et seq. (AB 52) Standard Conditions
None.

Plans, Programs, or Policies
None.

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

5.15.10 MITIGATION MEASURES
Mitigation Measure CUL-2 through CUL-9, listed previously.

Mitigation Measure TCR-1: Archaeological Resources Management Plan (ARMP). If resources are discovered within a given Project Area, for any ground disturbing activities within 300 feet of the Mill Creek Zanja, or if there is a high potential for encountering resources, an Archaeological Resources Management Plan (ARMP) and tribal monitoring shall 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 Redlands Regular Meeting of 10-18-22 960 of 1815
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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 and a Native American monitor from the consulting tribe(s) have been retained. Archaeological monitors will report to the project Archaeologist for the project and may work in collaboration with Native American monitors from consulting tribes. 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 an 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.

Mitigation Measure TCR-2: Inadvertent Discovery of Tribal Cultural Resources. In the event that Native American tribal cultural resources are inadvertently discovered during the course of grading for any project being developed under the Transit Villages Specific Plan, the following procedures will be carried out for treatment and disposition of the discoveries:

1. Temporary Curation and Storage: During the course of construction, all discovered resources shall be temporarily curated in a secure location onsite or at the offices of the Project archaeologist. The removal of any artifacts from the Project Site will need to be thoroughly inventoried with tribal monitor oversight of the process. Construction staff should also be provided with cultural sensitivity training, including identification of possible in situ tribal cultural resources.

2. Treatment and Final Disposition: The landowner(s) shall relinquish ownership of all cultural resources, including sacred items, burial goods, and all archaeological artifacts and non-human remains as part of the required mitigation for impacts to cultural resources. The applicant shall relinquish the artifacts through one or more of the following methods and provide the City of Redlands with evidence of same:
a. Accommodate the process for onsite reburial of the discovered items with the interested Native American tribes or bands. This shall include measures and provisions to protect the future reburial area from any future impacts. Reburial shall not occur until all cataloguing and basic recordation have been completed.
b. A curation agreement with an appropriate qualified repository within San Bernardino County or Riverside County that meets federal standards per 36 CFR Part 79 and therefore would be professionally curated and made available to other archaeologists/researchers for further study. The Redlands Regular Meeting of 10-18-22 961 of 1815
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collections and associated records shall be transferred, including title, to an appropriate curation facility within San Bernardino County or Riverside County, to be accompanied by payment of the fees necessary for permanent curation.
c. For purposes of conflict resolution, if more than one Native American tribe or band is involved with the Project and cannot come to an agreement as to the disposition of cultural materials, they shall be curated at the San Bernardino County Museum (or similar appropriate qualified repository able and willing to accept the tribal cultural resources) by default. d. At the completion of grading, excavation and ground disturbing activities on the site a Phase IV Monitoring Report shall be submitted to the City of Redlands documenting monitoring activities conducted by the Project Archaeologist and Native Tribal Monitors within 60 days of completion of grading. This report shall document the impacts to the known resources on the property; describe how each mitigation measure was fulfilled; document the type of cultural resources recovered and the disposition of such resources; provide evidence of the required cultural sensitivity training for the construction staff held during the required pre-grading meeting; and, in a confidential appendix, include the daily/weekly monitoring notes from the archaeologist. All reports produced will be submitted to the City of Redlands, CHRIS, and consulting tribe(s).

Mitigation Measure TCR-3: Treatment and Disposition of Tribal Cultural Resources. In the event that tribal cultural resources, including historic and pre-contact materials, are discovered during the course of ground disturbance for any project being developed under the Transit Villages Specific Plan, the following procedures shall be implemented:

1. All work in the immediate vicinity of the find (within a 50-foot buffer) shall cease and the find shall be assessed by an archaeologist meeting the Secretary of the Interior’s standards. Work on the other portions of the project, outside of the buffered area, may continue during this assessment period.

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

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

4. Treatment and Final Disposition: The Applicant shall relinquish ownership of all cultural resources, including sacred items, burial goods, archaeological artifacts, and non-human remains discovered during construction of the proposed project. The Applicant shall relinquish the cultural resources through one or more of the following methods and provide the City of Redlands with evidence of same:
a. Accommodate the onsite reburial of the discovered cultural resources in consultation with the consulting Native American tribe(s) or band(s). The reburial area shall be protected from any future impacts. All reburials are subject to a reburial agreement that shall be developed between the landowner and the consulting tribes outlining the determined reburial process/location, and shall include measures and provisions to protect the reburial area from any future impacts (vis-a-vis project plans, conservation/preservation easements, etc.). Reburial shall not occur until all cataloguing and recordation have been completed.
b. In the event that reburial is infeasible, and/or if more than one Native American tribe or band is involved with the proposed project and cannot come to a consensus as to the disposition of cultural resources within one hundred and twenty (120) days from the initial recovery of the items, the cultural resources shall be curated. The landowner shall relinquish all ownership and rights to this material and confer with the consulting tribes to identify an American Association of Museums (AAM)-accredited Redlands Regular Meeting of 10-18-22 962 of 1815
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facility within the County that can accession the materials into their permanent collections and provide for the proper care of these objects in accordance with the 1993 CA Curation Guidelines. A curation agreement with an appropriate qualified repository shall be developed between the landowner and museum that legally and physically transfers the collections and associated records to the facility. c. Within 60 days following the completion of ground-disturbing activities, a Monitoring Compliance Report shall be submitted to the City of Redlands. The Monitoring Report shall document monitoring activities conducted by the Project Archaeologist and Native Tribal Monitor(s) including: any impact to cultural resources discovered on the project site; how each mitigation measure was fulfilled; the type of cultural resources recovered and the disposition of such resources; evidence of completion of pre-grading cultural sensitivity training required for the construction staff; and daily/weekly monitoring notes from the archaeologist in a confidential appendix. The Monitoring Compliance Report shall be submitted to the City of Redlands, the South Central Coastal Information Center, and the consulting tribe(s).

Mitigation Measure TCR-4: Discovery of Human Remains. In the event that human remains are encountered on any project site of any project being developed under the Transit Villages Specific Plan, the construction contractors, Project Archaeologist, and designated Native American Tribal Monitor (if any) shall immediately stop all work within 100 feet of the discovery. The Applicant shall immediately notify the San Bernardino County Coroner, the City of Redlands Police Department, and the City of Redlands Development Services Department. The County Coroner shall be permitted to examine the remains consistent with the requirements of California Code of Regulations (CCR) §15064.5(e). State Health & Safety Code §7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code (PRC) §5097.98. If the remains are determined to be Native American, the County Coroner shall notify the Native American Heritage Commission (NAHC), which shall determine and notify a Most Likely Descendant (MLD). The MLD shall complete the inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. The MLD recommendations may include scientific removal and nondestructive analysis of human remains and items associated with Native American burials, preservation of Native American human remains and associated items in place, relinquishment of Native American human remains and associated items to the descendants for treatment, or any other culturally appropriate treatment.

The specific location of Native American burials and reburials will be proprietary and not disclosed to the general public. The locations will be documented by the Project Archaeologist in conjunction with the various stakeholders and a report of findings will be filed with the South Central Coastal Information Center and/or NAHC.

According to the California Health & Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). In the event that the project proponent and the MLD are in disagreement regarding the disposition of the remains, State law will apply and the mediation and decision process will occur with the NAHC (see Public Resources Code Sections 5097.98(e) and 5097.94(k)).

5.15.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
The mitigation measures and existing regulatory programs described previously would reduce potential impacts associated with tribal cultural resources for Impacts TCR-1 and TCR-2 to a level that is less than significant. Therefore, no significant unavoidable adverse impacts related to tribal cultural resources would occur.

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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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5.16 Utilities and Service Systems

5.16.1 INTRODUCTION
This section of the Draft EIR evaluates the potential effects on utilities and service systems from implementation of the TVSP, identifying anticipated demand and existing and planned utility availability. This includes water supply and infrastructure, wastewater, drainage, and solid waste. Electric power, natural gas, telecommunications, and renewable energy resources are described in Section 5.4, Energy Resources. Water supply and infrastructure capacity information in this section is from:
• 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
Because CEQA focuses on physical environmental effects, this section analyzes whether increases in demand for water, wastewater, and solid waste utilities would result from implementation of the TVSP that would result in significant adverse physical environmental effects. For example, an increase in wastewater generation, by itself, would not be considered a physical change in the environment; however, physical changes in the environment resulting from the construction of new facilities or an expansion of existing wastewater facilities could constitute a significant impact under CEQA.

5.16.2 WATER

5.16.2.1 WATER REGULATORY SETTING

5.16.2.1.1 State Water Regulatory Setting
California Urban Water Management Planning Act
Section 10610 of the California Water Code established the California Urban Water Management Planning Act (CUWMPA), requires urban water suppliers to initiate planning strategies to ensure an appropriate level of reliability in its water service. CUWMPA states that every urban water supplier that provides water to 3,000 or more customers, or that annually provides more than 3,000 acre-feet of water service, should make every effort to ensure the appropriate level of reliability in its water service to meet the needs of its various categories of customers during normal, dry, and multiple-dry years. The CUWMPA describes the contents of UWMP’s as well as methods for urban water suppliers to adopt and implement the plans.

Senate Bill 610
Senate Bill (SB) 610 requires public urban water suppliers with 3,000 or more service connections to identify existing and planned sources of water for planned developments of a certain size. It further requires the public water system to prepare a specified water supply assessment (WSA) for projects that meet the following criteria:
a) A proposed residential development of more than 500 dwelling units; b) A proposed shopping center employing more than 1,000 persons or having more than 500,000 square feet of floor space;
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c) A commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space;
d) A hotel or motel, or both, with more than 500 rooms; e) An industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 sf of floor area; and
f) A mixed-use project that includes one or more of the projects above.

The components of a WSA include existing water demand, future water demand by the project, and must ensure that water is available for the project during normal years, a single dry year, and multiple dry years during a 20-year future projection period. The WSA must also describe whether the project’s water demand is accounted for in the water supplier’s UWMP. Supplies of water for future water supply must be documented in the WSA.

CalGreen Building Code
California Code of Regulations Title 24, Part 11, establishes the California Green Building Code or CALGreen. The CALGreen Code is updated every three years. It was recently updated in 2019 and is effective January 1, 2020. CALGreen sets forth water efficiency standards (i.e., maximum flow rates) for all new plumbing and irrigation fittings and fixtures

5.16.2.1.2 Local Water Regulatory Setting
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.20 Pursue creative, innovative, and environmentally sound methods to capture and use stormwater and urban runoff for beneficial purposes.

Policy 6-P.21 Work with regional organizations to manage groundwater resources of the Bunker Hill Basin.

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.

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.

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5.16.2.2 WATER ENVIRONMENTAL SETTING
The TVSP area is located within the water service area of the City of Redlands Municipal Utilities and Engineering Department (MUED), which provides retail water service to the majority of the City of Redlands, a portion of the City of Loma Linda, and unincorporated areas of the Donut Hole (an area in unincorporated San Bernardino County surrounded by Redlands), Mentone, and most of Crafton.

WVWD participates in the Upper Santa Ana River Watershed Integrated Regional Urban Water Management Plan. This Urban Water Management Plan (UWMP) is a tool that provides a summary of anticipated supplies and demands for the years 2020 to 2045 within the Valley Region of San Bernardino County, including various incorporated cities such as the City of Redlands.

Water Supply and Demand- MUED
The MUED utilizes four primary sources for drinking water supply: groundwater, surface water, imported water, and recycled water. The MUED’s water supply is a combination of groundwater from the Bunker Hill Subbasin; groundwater from the Yucaipa Subbasin; surface water from the Santa Ana River; surface water from Mill Creek; imported water from the State Water Project (SWP) Water; and recycled water. As shown on Table 5.16-1, in 2020 the MUED obtained the majority of its water supply from the Bunker Hill Subbasin.

Table 5.16-1: MUED Water Supply 2020
Water Supply Source Water Quality Volume (acrefeet)Percentage Groundwater Bunker Hill Drinking Water 12,088 43%
Groundwater Bunker Hill Non-Potable 1,531 5.4%
Groundwater Yucaipa Non-Potable 297 1.1%
Surface Water Santa Ana River Drinking Water 5,796 20.6% Surface Water Mill Creek Drinking Water 6,045 21.5%
Purchased or
Imported Water
SWP-Direct
Deliveries
Drinking Water 535 1.9%
Recycled Recycled WaterDirectRecycled Water 1,806 6.5% Total 28,098 100%
Source: 2020 UWMP.

As shown in Table 5.16-2, the 2020 UWMP estimates that water supplies in the future are anticipated to be obtained through a similar mix of surface water, groundwater, and purchased or imported water. The 2020 UWMP anticipates that the MUED’s water supply will increase from 31,039 AF in 2025 to 35,544 AF in 2045 (increase of 4,505 AFY) to meet MUED’s anticipated growth in water demands.

Table 5.16-2: MUED Projected Water Supply (AF)
Water Supply Source 2025 2030 2035 2040 2045 2045
Percentage
Groundwater Bunker Hill 12,973 13,922 14,861 15,677 16,484 46.4% Groundwater Bunker Hill 3,766 4,015 4,275 4,513 4,760 13.4% Groundwater Yucaipa 1,000 1,000 1,000 1,000 1,000 2.8%
Surface Water Santa Ana River 5,000 5,000 5,000 5,000 5,000 14.1% Surface Water Mill Creek 5,500 5,500 5,500 5,500 5,500 15.5% Purchased or
Imported Water
SWP-Direct
Deliveries
700 700 700 700 700 1.9%
Recycled Recycled WaterDirect2,100 2,100 2,100 2,100 2,100 5.9% Total 31,039 32,238 33,436 34,490 35,544 100%
Source: 2020 UWMP.

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The 2045 projections anticipate that 62.6 percent of supply would be from the groundwater sources, 29.6 percent from surface water, 1.9 percent from imported/purchased sources, and 5.9 percent from recycled water. The UWMP also describes that there has been a historical trend associated with drier years and an increase in water use among agencies. Conservation efforts have proven to be effective in decreasing water use in dry years. Additionally, according to the UWMP, MUED has adequate supplies to serve 100 percent of its customers during normal, dry year, and multiple dry year demand through 2045 with projected population increases and accompanying increases in water demand (UWMP 2020).

Groundwater: Redlands MUED extracts groundwater from the Bunker Hill Subbasin (also known as San Bernardino Basin or SBB) and Yucaipa Subbasin. Extractions from both basins include potable and nonpotable water. In 2020, Redlands MUED extracted 13,619 AF of groundwater from the Bunker Hill Subbasin and 297 AF from the Yucaipa Subbasin. The City of Redlands uses 15 wells that pump directly into the system or into reservoirs (UWMP 2020).

Purchased or Imported Water: Imported water from the SWP is available for the MUED to purchase from Valley District when needed. The MUED has purchased supplemental SWP water only in years when surface water flows have not been able to meet demands and on occasion when surface water supplies are turbid and require blending or for other operational purposes. The MUED contributes to regional efforts to recharge the Bunker Hill groundwater basin with SWP water and local surface water in wet years when available so that storage is available for use in dry years when other supplies may be limited (UWMP 2020).

Surface Water: The MUED receives water from the Mill Creek watershed and the Santa Ana River watershed.

Water from the Mill Creek watershed is treated at Henry Tate Surface Water Treatment Plant. Water from the Santa Ana River watershed is treated at the Horace P. Hinckley Surface Water Treatment Plant. The MUED has ownership in a variety of private and mutual water companies to supply water to the City’s Tate and Hinckley Surface Water Treatment Plants (UWMP 2020).

Recycled Water: The City’s Wastewater Treatment Plant has the capability of treating 7.2 million gallons per day (mgd) of wastewater to a Title 22 Recycled Water level. The City’s recycled water customers include Southern California Edison, a landfill, and recycled/non-potable water customers in the 1350 pressure zone.

Southern California Edison uses recycled water for its Mountain View Power Plant and recycled water customers use recycled water for irrigation.

Water Infrastructure
The City’s water treatment plants include the Henry Tate Water Treatment Plant and the Horace Hinckley Surface Water Treatment Plant. The Henry Tate Water Treatment Plant is a conventional water treatment plant built in 1967. The design capacity of the Tate plant is 20 million gallons per day (mgd). The City added enhancements to the Tate WTP to provide more water supply reliability by allowing State Water Project water to be mixed with Mill Creek water for treatment. The Horace Hinckley Surface Water Treatment Plant started operation in 1987 and has a permitted capacity of 14.5 mgd. The 10-year average flow (up to and including 2016) is 6,363 AF at the Henry Tate Plant, and 6,697 AF at the Horace Hinckley Plant. The TVSP area contains a network of water lines from 1 to 36-inches in diameter, which operate within capacity for existing development within the TVSP area. The City of Redlands maintains approximately 400 miles of pipeline with over 21,500 metered connections that serve potable water (MUED 2022).

Water Demand in TVSP Area
Within the TVSP area, there are currently 2,318 multi-family dwelling units, approximately 6.5 million square feet of commercial (or non-residential) uses, and 5.7 million square feet of landscaped areas. Currently, residential uses comprise approximately 40 percent of the water demand in the TVSP area, commercial/nonresidential uses comprise approximately 27 percent of the water demand, and landscaping irrigation Redlands Regular Meeting of 10-18-22 969 of 1815
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comprises approximately 33 percent of the water demand. The TVSP area currently has an annual water usage of approximately 1,357 AF (WSA 2022).

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

UT-1 Require or result in the relocation or construction of new water facilities, or expansion of existing facilities, the construction of which could cause significant environmental effects; or UT-2 Not have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

5.16.2.4 WATER SERVICE METHODOLOGY
The evaluation of water supply quantifies the amount of water that would be required to support operation of the proposed Project and compares the demand to the Redlands MUED’s available water supply to identify if sufficient water supplies available to serve the Project and reasonably foreseeable development during normal, dry, and multiple dry years. Additionally, the existing water supply infrastructure that serves the TVSP area was identified and evaluated to ensure design capacity would be adequate to supply the TVSP area upon buildout of the TVSP, or to identify if expansions would be required to serve the proposed development.

5.16.2.5 WATER ENVIRONMENTAL IMPACTS
IMPACT UT-1: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR

CONSTRUCTION OF NEW WATER FACILITIES, OR EXPANSION OF EXISTING FACILITIES,

THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT ENVIRONMENTAL EFFECTS.

Less than Significant with Mitigation Incorporated. The Specific Plan would redevelop the 947-acre TVSP area with residential, commercial, office, and hotel uses, which is currently served by the MUED’s water infrastructure. As discussed above, the Specific Plan contains multiple water pipelines ranging in size from 1- inch to 36-inches in diameter. These water pipelines currently provide water supplies to the Specific Plan and surrounding adjacent areas.

However, the Specific Plan’s projected water demand increase of 639 AFY, as calculated in Impact UT-2, would require upgrades to some of the existing water mains in the TVSP area due to insufficient transmission capacity for the water demands or required fire flow at buildout of the TVSP. To accommodate the increase in capacity, buildout of the TVSP would include construction of the following potable water main upgrades, as shown on Figure 3-13, Existing and Proposed Domestic Water Distribution:
• Upgrading the existing water main in Colton Avenue to a 12-inch main between Texas Street and Orange Street
• Upgrading the existing water main in Stuart Avenue to a 12-inch main west of Texas Street • Upgrading the existing water main in Eureka Street to a 12-inch water main between Oriental Avenue and Redlands Boulevard
• Upgrading the existing water main in Redlands Boulevard to a 12-inch water main between Orange Street and Sixth Street
• Upgrading the existing water main on Ninth Street to an 8-inch water main between E. Central Avenue and State Street
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• Upgrading the existing water main on Church Street to a 12-inch water main between Colton Avenue and Citrus Avenue
• Upgrading the existing water main on University Street to a 12-inch water main between Colton Avenue and E. Central Avenue
• Upgrading the existing water main on E. Central Avenue to a 12-inch water main between University Street and Judson Street
These improvements are consistent with MUED’s 1981 Water Master Plan and would be evaluated on a project-by-project basis as development occurs pursuant to the TVSP. Additionally, buildout of the TVSP would include the installation of new 12-inch non-potable waterlines in New York between Colton Avenue and State Street that would connect to future non-potable pipelines, ultimately connecting to the existing non-potable pipeline in Lugonia Avenue. The Project proposes to install a new 8-inch non-potable waterline in Orange Street and Redlands Boulevard that would connect to a proposed non-potable pipeline in State Street, ultimately connecting to the proposed non-potable pipeline in New York Street, and the Project would include a new 8-inch non-potable line in University Street and Colton Avenue that would connect to the existing non-potable line in Colton Avenue. The Project also proposes the construction of various other new non-potable waterlines as shown in Figure 3-14, Existing and Proposed Non-Potable Water Distribution.

The new onsite water systems would convey potable and non-potable water supplies to the proposed residential, commercial, office, and hotel uses, and landscaping through plumbing/landscaping fixtures that are compliant with the CalGreen Plumbing Code for efficient use of water.

Under the City’s development review procedures for site-specific development projects, the City determines water system design requirements and the needs for any improvements to existing infrastructure that would be required by the TVSP and Water Master Plans. Needed improvements would be referenced directly in the design plans for the proposed development to assure adequate capacity. The water design specifications for each site-specific development project would be required to comply with City standards (per the California Building Code) regarding requirements for design and operation of water distribution facilities.

The construction of any needed water system improvements as part of future site-specific development projects under the proposed Specific Plan would generally occur from project sites to existing connection points in roadway rights-of-way and would be required to comply with all Redlands Municipal Code standards and Draft EIR Mitigation Measures AQ-1 through AQ-10, CUL-1 through CUL-9, GEO-1, NOI-1 through NOI-4, NOI-8 through NOI-9, and TCR-1 through TCR-4.. These requirements would ensure that construction related impacts remain less than significant. As a result, potential impacts related to build out of the proposed TVSP would not result in construction of new or expanded wastewater facilities that could result in a significant environmental effect, and impacts would be less than significant.

IMPACT UT-2: THE PROJECT WOULD HAVE SUFFICIENT WATER SUPPLIES AVAILABLE TO SERVE THE

PROJECT AND REASONABLY FORESEEABLE DEVELOPMENT DURING NORMAL, DRY, AND MULTIPLE DRY YEARS.

Less than Significant with Mitigation Incorporated. The Project would redevelop the 947-acre TVSP area with an additional 2,400 residential dwelling units, 265,000 SF of commercial retail uses, 238,000 SF of Redlands Regular Meeting of 10-18-22 971 of 1815
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office uses, 220 hotel rooms, and approximately 280,000 SF of open space. The Water Supply Assessment (WSA) prepared for the Specific Plan estimated the Proposed Project’s water demands using the developed acreage attributed to each use type (including landscape irrigation and parking area requirements). The total developed area was prorated based on the building square footage for each use type. Water demands were then estimated for the Project using land use-based water demand factors from the City of Redlands’ “Water and Sewer Demands Spreadsheet”. The land use demand factors are applied to gross estimated acreage for each land use.

As shown in Table 5.16-3, the proposed Specific Plan would result in a total demand of 1,996 AFY by the year 2040, which would be a 639 AFY increase in comparison to the current TVSP area water demands from existing development within the TVSP area.

Table 5.16-3: Water Demands from Buildout of the TVSP
Land Use Type DU/Acreage Unit Water
Demand Factor
Annual Water
Usage (AFY)
Residential MultiFamily 2,400 DU 210 gpd/DU 564.55
Retail Commercial 6.08 acres 2,178 gpd/acre 14.83
Office 5.46 acres 2,178 gpd/acre 13.32
Hotel 220 DU 100 gpd/DU 24.64
Open Space &
Parks 6.43 acres 3,050 gpd/acre 21.97
Additional Project Water Demand 639
Existing Site Water Demand 1,357
Total Water Demand 1,996 AFY
Source: WSA, Appendix F.

The MUED’s 2020 UWMP assumed that the MUED’s total water supply would increase from 28,098 AF in 2020 to 35,544 AF in 2045, which constitutes an increase of 7,446 AF. Additionally, as shown in Table 5.16- 4, the projected MUED normal year water demand would increase from 26,866 AF in 2020 to 30,908 AF in 2045.

Table 5.16-4: Projected MUED Water Demand
2020 2025 2030 2035 2040 2045
Potable and Raw Water 25,892 25,818 26,860 27,902 28,818 29,735 Recycled Water 994 1,173 1,173 1,173 1,173 1,173
Total Water Demand 26,866 26,991 28,033 29,075 29,991 30,908 Source: 2020 UWMP
The UWMP assessed the projected water demand and supply in the service area and concluded that MUED has an adequate water supply to meet all demands within its service area to 2045. As shown in Table 5.16- 4, the Project’s additional demands of 639 AFY is less than the assumed increase in demands in the UWMP; therefore, the Project’s relatively small increase in water demand would not cause demand to exceed the 2045 projected demands for the MUED. Additionally, implementing projects in the TVSP area would be required to implement Mitigation Measure AQ-8, which requires projects to incorporate a Water Conservation Strategy and demonstrate a minimum 30% reduction in outdoor water usage when compared to baseline water demand.

Based on the above, it is anticipated that existing and future water entitlements from groundwater, surface water, purchased or imported water sources, recycled water, and implementation of Mitigation Measure AQ-8, would be sufficient to meet the Project’s demand at buildout, in addition to forecast demand for Redlands Regular Meeting of 10-18-22 972 of 1815
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MUED’s entire service area. Thus, impacts related to the need for new or expanded water supplies and entitlements would be less than significant.

5.16.2.6 WATER CUMULATIVE IMPACTS
Cumulative water supply impacts are considered on a water purveyor basis and are associated with the capacity of the infrastructure system and the adequacy of the water purveyor’s infrastructure and primary sources of water that include groundwater, surface water, purchased or imported water, and recycled water.

As described previously, during buildout of the Specific Plan, water lines would be installed as needed to serve implementing projects. The continued regular assessment, maintenance, and upgrades of the water system by the Redlands MUED pursuant to the City’s Water Master Plans would reduce the potential of development projects to result in a cumulatively substantial increase in water such that new or expanded facilities would be required.

As discussed above, the Specific Plan would result in an increase in water demand of 639 AFY. It is anticipated that existing and future water entitlements from groundwater, surface water, purchased or imported water sources, and recycled water, plus water conservation methods included in Mitigation Measure AQ-8, would be sufficient to meet the Specific Plan’s demand at buildout, in addition to forecast demand for MUED’s entire service area. As a result, the Project would not result in a cumulatively considerable increase in water supply demands that would require new or expanded entitlements, and cumulative impacts would be less than significant.

5.16.2.7 EXISTING REGULATIONS, STANDARD CONDITIONS, AND PLANS, PROGRAMS, OR

POLICIES
Existing Regulations
The following standard regulations would reduce potential impacts related to water supplies:
• California Code of Regulations Title 24, Part 11; the California Green Building Code • Chapter 15.54 of the Redlands Municipal Code
Standard Conditions
None.

Plans, Programs, or Policies
None.

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

5.16.2.9 WATER MITIGATION MEASURES
Mitigation Measures AQ-1 through AQ-10, CUL-1 through CUL-9, GEO-1, NOI-1 through NOI-4, NOI-8 through NOI-9, and TCR-1 through TCR-4.

5.16.2.10 WATER LEVEL OF SIGNIFICANCE AFTER MITIGATION
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With implementation of mitigation, no significant unavoidable adverse impacts related to water supplies or water infrastructure would occur.

5.16.3 WASTEWATER

5.16.3.1 WASTEWATER REGULATORY SETTING

5.16.3.1.1 Local Wastewater Regulatory Setting
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:

Principle 4-P.56 Ensure that public facilities and services are provided in a timely manner to adequately serve new and existing development.

Action 4-A.145 Coordinate future development with the City’s Capital Improvement Program to ensure adequate funding and planning for needed public services and facilities.

Action 4-A.146 Encourage the development of programs that enable concurrent provision of necessary public services and facilities prior to the approval of development projects that would require those services.

Action 4-A.148 Ensure that all utilities and public facilities are designed and constructed to preserve and enhance the perceived natural and historic character of the area, particularly on hillsides and in the canyon areas.

5.16.3.2 WASTEWATER ENVIRONMENTAL SETTING
Sewer service in the TVSP area is provided by the City of Redlands. The City’s Wastewater Treatment Plant is located on the south side of the Santa Ana River Wash at Nevada Street. The City’s Wastewater Treatment Plant has a secondary treatment capacity of 9.5 mgd and a tertiary treatment capacity of 7.2 mgd. As of 2021, average flow to the City’s Wastewater Treatment Plant was approximately 5.8 mgd (MUED 2021).

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.

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

UT-3 Require or result in the construction of new wastewater facilities, or expansion of existing facilities, the construction of which could cause significant environmental effects; or UT-4 Result in a determination by the wastewater treatment provider that would serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

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5.16.3.4 WASTEWATER SERVICE METHODOLOGY
The evaluation of wastewater infrastructure quantifies the amount of wastewater that would be generated from buildout of the TVSP and compares the demand to the existing and planned sewer infrastructure and wastewater treatment plants. The evaluation identifies if expansions would be required to serve full buildout of the TVSP, and if those expansions have the potential to result in an environmental impact.

5.16.3.5 WASTEWATER ENVIRONMENTAL IMPACTS
IMPACT UT-3: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR

CONSTRUCTION OF NEW WASTEWATER FACILITIES, OR EXPANSION OF EXISTING

FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT ENVIRONMENTAL EFFECTS.

Less than Significant with Mitigation Incorporated. As described previously, the TVSP area contains a network of sewer lines that range from 6-inches to 48-inches in diameter and operate well within capacity.

As shown on Table 5.16-5, in the Impact UT-4 discussion below, buildout pursuant to the TVSP would result in an increase of wastewater flows within the TVSP area. To accommodate the increase in wastewater flows, buildout of the TVSP would include construction of the following wastewater upgrades, as shown on 3-15, Existing Sewer System and Proposed Upgrades:
• Replacing the 8-inch sewer in University Street from Park Avenue to the I-10 Freeway with a new 12-inch sewer (or adding an additional 8-inch sewer line) • Replacing the 15-inch sewer in Citrus Avenue from Central Avenue to Church Street with a new 18- inch sewer (or adding an additional 8-inch sewer line)
• Adding a new 12-inch sewer line in State Street from Eureka Street to First Street, then north on First Street to Redland Boulevard, then west on Redlands Boulevard to Texas Street.

These improvements would be evaluated on an as needed, project-by-project basis as development occurs pursuant to the TVSP. Implementation of development projects pursuant to the TVSP would increase the intensity of land uses within the TVSP area, and future site-specific development projects would install onsite sewer infrastructure and new connections to the sewer system that could include improvements to aged sewer pipelines and other connecting infrastructure. Such improvements would be required to be sized to accommodate the wastewater generation of such new development.

Under the City’s development review procedures for site-specific development projects, the City determines sewer system design requirements and the needs for any improvements to existing infrastructure that would be required by the City’s construction permit and referenced directly in the design plans for the proposed development to assure adequate capacity. The sewer design specifications for each site-specific development project would be required to comply with City standards (per the California Building Code) regarding requirements for design and operation of sewer collection facilities.

The construction of any needed wastewater system improvements as part of future site-specific development projects under the proposed Specific Plan would generally occur from project sites to existing connection points in roadway rights-of-way and would be required to comply with all Redlands Municipal Code standards and Draft EIR Mitigation Measures AQ-1 through AQ-10, CUL-1 through CUL-9, GEO-1, NOI-1 through NOI-4, NOI-8 through NOI-9, and TCR-1 through TCR-4. These requirements would ensure that construction related impacts remain less than significant. As a result, potential impacts related to build out of the proposed Specific Plan would not result in construction of new or expanded wastewater facilities that could result in a significant environmental effect, and impacts would be less than significant.

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IMPACT UT-4: THE PROJECT WOULD NOT RESULT IN A DETERMINATION BY THE WASTEWATER

TREATMENT PROVIDER THAT WOULD SERVE THE PROJECT THAT IT HAS INADEQUATE

CAPACITY TO SERVE THE PROJECTS PROJECTED DEMAND IN ADDITION TO THE PROVIDERS EXISTING COMMITMENTS.

Less than Significant Impact. Buildout of the proposed Specific Plan would result in an increase of 2,400 residential units, 265,000 SF of commercial retail, 238,000 SF of office uses, and 220 hotel rooms.

Wastewater demand associated with the buildout of the TVSP would be typical of residential and commercial wastewater usage in the City of Redlands. As shown in Table 5.16-5, TVSP Estimated Wastewater Generation, the proposed Project would generate a demand for approximately 551,134 gallons per day (gpd).

Table 5.16-5: TVSP Estimated Wastewater Generation
Land Use Type DU/Acreage Wastewater Generation Rate
(gpd/unit)
Total Wastewater
Generation
(gpd)
Residential Multi-Family 2,400 DU 210 gpd/du 504,000
Retail Commercial 6.08 acres 2,178 gpd/acre 13,242
Office 5.46 acres 2,178 gpd/acre 11,892
Hotel 220 rooms 100 gpd/room 22,000
Total Project Wastewater Generation: 551,134 gpd
The operational buildout of the proposed TVSP would generate approximately 551,134 gallons per day (0.55 mgd) of wastewater that would be conveyed to the City’s Wastewater Treatment Plant for disposal.

The treatment plant currently treats approximately 5.8 mgd and has the capacity to treat 9.5 mgd. Thus, the addition of 551,134 gallons per day (0.55 mgd) from buildout of the TVSP would be accommodated by the existing facilities and would not result in a capacity constraint related to serving the proposed Specific Plan in addition to the existing commitments. Thus, impacts related to wastewater treatment plant capacity would be less than significant.

5.16.3.6 WASTEWATER CUMULATIVE IMPACTS
Cumulative wastewater infrastructure impacts are considered on a systemwide basis and are associated with the overall capacity of existing and planned infrastructure. The cumulative system evaluated includes the sewer system and the conveyance system through wastewater disposal at the City of Redlands Wastewater Treatment Plant.

As described previously, during buildout of the Specific Plan, sewer lines would be installed as needed to serve implementing projects. The continued regular assessment, maintenance, and upgrades of the sewer system by the City MUED would reduce the potential of development projects to result in a cumulatively substantial increase in wastewater such that new or expanded facilities would be required. Thus, increases in wastewater in the sewer system would result in a less than significant cumulative impact.

Additionally, the City of Redlands Wastewater Treatment Plant have an average flow of 5.8 mgd and a treatment capacity of 9.5 mgd (MUED 2021). Due to this volume of excess capacity that is designed by MUED to accommodate future regional growth, the increase in wastewater flow from cumulative projects would not significantly impact the Wastewater Treatment Plant facilities. As a result, impacts related to cumulative projects wastewater treatment and conveyance capacity would be less than significant.

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5.16.3.7 EXISTING REGULATIONS, STANDARD CONDITIONS, AND PLANS, PROGRAMS, OR

POLICIES
Existing Regulations
• California Code of Regulations Title 24, Part 11; the California Green Building Code Standard Conditions
None.

Plans, Programs, or Policies
None.

5.16.3.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact UT-3 would be potentially significant.

Impact UT-4 would be less than significant.

5.16.3.9 WASTEWATER MITIGATION MEASURES
Mitigation Measures AQ-1 through AQ-10, CUL-1 through CUL-9, GEO-1, NOI-1 through NOI-4, NOI-8 through NOI-9, and TCR-1 through TCR-4.

5.16.3.10 WASTEWATER LEVEL OF SIGNIFICANCE AFTER MITIGATION With implementation of mitigation, no significant unavoidable adverse impacts related to wastewater infrastructure would occur.

5.16.4 STORM WATER DRAINAGE

5.16.4.1 STORMWATER REGULATORY SETTING

5.16.4.1.1 Local Stormwater Regulatory Setting
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.

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.

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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 predevelopment baseline flow rate to receiving waterbodies.

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).

5.16.4.2 STORM WATER DRAINAGE ENVIRONMENTAL SETTING
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 2014, the City adopted the 2014 Master Plan of Drainage.

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

UT-5 Require or result in the construction of new stormwater drainage facilities, or expansion of existing facilities, the construction of which could cause significant environmental effects.

5.16.4.4 STORM WATER DRAINAGE METHODOLOGY
The evaluation of stormwater drainage infrastructure quantifies the amount of impervious surfaces and stormwater runoff that would be generated from buildout of the TVSP and identifies if runoff from buildout of the TVSP would be accommodated by the existing stormwater drainage infrastructure. The evaluation Redlands Regular Meeting of 10-18-22 978 of 1815
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identifies if expansions would be required to serve the proposed development, and if those expansions have the potential to result in an environmental impact.

5.16.4.5 DRAINAGE ENVIRONMENTAL IMPACTS
IMPACT UT-5: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR

CONSTRUCTION OF NEW DRAINAGE FACILITIES, OR EXPANSION OF EXISTING

FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT ENVIRONMENTAL EFFECTS.

Less than Significant with Mitigation Incorporated. As shown on Figure 3-3, the majority of the TVSP area is fully developed. However, there are multiple vacant parcels within the TVSP area. As such, buildout pursuant to the TVSP could result in a greater amount of impermeable surfaces within the TVSP area. The TVSP Infrastructure Plan includes improvements to divert flows away from undersized segments of the existing drainage system, such as the undersized Zanja channel through the University Transit Village, and the undersized Mission Creek channel through the New York Street/Esri Transit Village, among other floodrelated strategies, in line with the strategies set forth by the 2014 Redlands Master Plan of Drainage. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the TVSP area including:
• 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 (MPD) 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 • Increase the size of the Zanja at the Kansas Street, New York Street, and Tennessee Street crossings to increase flow capacity.

Development under the TVSP would allow for redevelopment of the TVSP area that could result in the generation of increased stormwater volumes in areas that are currently largely pervious. Increased flows could in turn create a need for new infrastructure in order to accommodate infiltration of stormwater or to convey stormwater to detention basins to prevent flooding, particularly where there are already stormwater capacity problems, such as the Downtown Village. Development under the TVSP would largely focus on infill development, allowing future projects to take advantage of the existing stormwater drainage infrastructure.

In most cases, parcels that may be developed or redeveloped within the TVSP area are already disturbed or developed with impervious surfaces, and future development would be unlikely to significantly increase runoff.

Stormwater drainage improvements would be evaluated on a project-by-project basis as development occurs pursuant to the TVSP and the 2014 Master Plan of Drainage. Implementation of development projects pursuant to the TVSP would increase the intensity of land uses within the TVSP area, and future site-specific development projects would install onsite stormwater drainage infrastructure and new connections to the existing stormwater drainage system. Such improvements would be required to be sized to accommodate the stormwater generation of such new development.

Under the City’s development review procedures for site-specific development projects, the City determines stormwater system design requirements and the needs for any improvements to existing infrastructure that would be required by the City’s construction permit and referenced directly in the design plans for the Redlands Regular Meeting of 10-18-22 979 of 1815
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proposed development to assure adequate capacity. The stormwater system design specifications for each site-specific development project would be required to comply with City standards and implementing projects would be required to prepare a Water Quality Management Plan (WQMP).

The construction of any needed drainage system improvements as part of future site-specific development projects under the proposed Specific Plan would generally occur from project sites to existing connection points in roadway rights-of-way. Additional, large-scale stormwater drainage improvements pursuant to the 2014 Redlands Master Plan of Drainage and implementing project site-specific stormwater drainage improvements would be required to comply with all Redlands Municipal Code standards and Draft EIR Mitigation Measures AQ-1 through AQ-10, CUL-1 through CUL-9, GEO-1, NOI-1 through NOI-4, NOI-8 through NOI-9, and TCR-1 through TCR-4. Additionally, policies within the TVSP seek to minimize the volume of stormwater entering the drainage system, reduce the need for system expansions, and limit potential impacts from system expansion on the environment. Policies within the TVSP require that new development provide landscaping, maximize pervious surfaces, promote onsite stormwater management solutions such as low-impact development utilizing best management practices, promote stormwater capture and reuse onsite, and ensure that post-development peak stormwater runoff discharge rates do not exceed the estimated pre-development rate. As a result, potential impacts related to build out of the proposed Specific Plan would not result in construction of new or expanded stormwater drainage facilities that could result in a significant environmental effect, and impacts would be less than significant.

5.16.4.6 STORM WATER DRAINAGE CUMULATIVE IMPACTS
The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area served by the existing stormwater infrastructure for the TVSP area, from capture of runoff through final discharge points. Pursuant to state and regional regulations that require development projects to maintain pre-project hydrology, no net increase of offsite stormwater flows would occur from implementing projects.

Regional Water Quality Control Board (RWQCB) Permit conditions and the Redlands Municipal Code Municipal Code require a hydrology/drainage study to demonstrate that all runoff would be appropriately conveyed and not leave the project sites at rates exceeding pre-project conditions, prior to receipt of necessary permits. As a result, increases of runoff from cumulative projects that could cumulatively combine to impact stormwater drainage capacity would not occur, and cumulative impacts related to drainage infrastructure would be less than significant.

5.16.4.7 EXISTING REGULATIONS, STANDARD CONDITIONS, AND PLANS, PROGRAMS, OR

POLICIES
Existing Regulations
None.

Standard Conditions
None.

Plans, Programs, or Policies
None.

5.16.4.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact UT-5 would be potentially significant.

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5.16.4.9 STORM WATER DRAINAGE MITIGATION MEASURES
Mitigation Measures AQ-1 through AQ-10, CUL-1 through CUL-9, GEO-1, NOI-1 through NOI-4, NOI-8 through NOI-9, and TCR-1 through TCR-4

5.16.4.10 STORM WATER DRAINAGE LEVEL OF SIGNIFICANCE AFTER MITIGATION With implementation of mitigation, no significant unavoidable adverse impacts related to drainage would occur.

5.16.5 SOLID WASTE

5.16.5.1 SOLID WASTE REGULATORY SETTING

5.16.5.1.1 SOLID WASTE STATE REGULATORY SETTING
California Assembly Bill 341
On October 6, 2011, Governor Brown signed AB 341 establishing a state policy goal that no less than 75 percent of solid waste generated be source reduced, recycled, or composted by 2020, and requiring CalRecycle to provide a report to the Legislature that recommends strategies to achieve the policy goal.

California Green Building Standards
Section 5.408.1 Construction waste diversion. Recycle and/or salvage for reuse a minimum of 65 percent of the nonhazardous construction and demolition waste.

Section 5.410.1 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, or meet a lawfully enacted local recycling ordinance, if more restrictive.

5.16.5.1.2 SOLID WASTE LOCAL REGULATORY SETTING
City of Redlands Recycling Ordinance
Chapter 13.66 of the Redlands Municipal Code establishes requirements for recycling by specified development activities to facilitate the City’s compliance with State recycling mandates, remove architectural barriers to recycling, and ensure the recycling of construction and demolition debris. The ordinance applies to applicants for the demolition of any structure; construction, additions, or improvements to any building other than a single-family residential building; and reroofing activities. Applicants are required, as a condition of approval, to submit for review and approval a completed Site and Building Recycling Plan to the City. The ordinance also specifies requirements for Construction and Demolition Recycling Plans.

5.16.5.2 SOLID WASTE ENVIRONMENTAL SETTING
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.

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, Redlands Regular Meeting of 10-18-22 981 of 1815
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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.

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

UT-6 Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

UT-7 Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

The Initial Study established that the proposed Project would result in less than significant impacts related to Threshold UT-7; and no further assessment of these impacts is required in this Draft EIR.

5.16.5.4 SOLID WASTE METHODOLOGY
The analysis for this section addresses potential impacts on solid waste generation and infrastructure due to projected growth arising from the proposed Project. Solid waste generation from operation of the maximum projected buildout of the TVSP area was estimated using solid waste generation factors derived for multifamily residential, commercial, and office uses from CalRecycle. Solid waste volumes were then compared with recent estimates of remaining disposal capacity of the landfill serving the City.

5.16.5.5 SOLID WASTE ENVIRONMENTAL IMPACTS
IMPACT UT-6: THE PROJECT WOULD NOT GENERATE SOLID WASTE IN EXCESS OF STATE OR LOCAL

STANDARDS, OR IN EXCESS OF THE CAPACITY OF LOCAL INFRASTRUCTURE, OR

OTHERWISE IMPAIR THE ATTAINMENT OF SOLID WASTE REDUCTION GOALS Less than Significant Impact.

Construction
Construction for implementing projects within the TVSP area would require demolition of various buildings located through the TVSP area. The majority of waste generated during demolition and construction activities by implementing projects would be building materials (e.g., concrete, dirt, and waste generated by construction workers). Nonhazardous waste from construction activities would be recycled to the extent feasible. As stated in the City’s Municipal Code Section 13.66.040, Construction and Demolition Recycling Requirements, no demolition permit or building permit shall be issued for any development activity subject to this chapter unless the construction and demolition recycling plan has been approved by the municipal utilities director. Thus, implementing projects pursuant to the TVSP would be required to meet the City’s waste Redlands Regular Meeting of 10-18-22 982 of 1815
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diversion requirements as they pertain to project construction. Furthermore, construction waste is anticipated to be minimal compared to waste generated from peak operations at full buildout of the TVSP area as construction waste would only be generated during occasional construction activities for future implementing projects and operational waste would be generated continuously.

Operation
As described previously in Section 3 of this document, full buildout pursuant to the TVSP would include development and operation of an additional 2,400 residential dwelling units, 265,000 SF of commercial retail, 238,000 SF of office space, and 220 hotel rooms. As shown on Table 5.16-6, it is anticipated that operations at full buildout of the TVSP would generate a total of approximately 3.49 tons of solid waste per day (94 tons per year) during operation with adherence to AB 341, which requires a diversion of 75% of waste from landfills.

Table 5.16-6: Solid Waste Generation during Project Operation Land Use Quantity Generation Rate1 Solid Waste
Demand (Tons)
Residential Units 2,400 units 10 lbs/unit/day 12 tons/day Commercial Retail1 265,000 SF 0.006 lb/SF/day 0.795 tons/day Office 238,000 SF 0.006 lb/SF/day 0.714 tons/day
Hotel 220 rooms 4 lbs/room/day 0.44 tons/day
Total Solid Waste 13.949 tons/day
Daily Landfill Disposal with AB 341 (75% Reduction) 3.49 tons/day Annual Landfill Disposal with AB 341 (75% Reduction) 1,274 tons per year Weekly Landfill Disposal with AB 341 (75% Reduction) 24.5 tons per week 1 CalRecycle Generation Rates As the California Street Landfill has the capacity to process an additional 683 tons of solid waste per day and the San Timoteo Sanitary Landfill has the capacity to process an additional 1,228 tons per day, the solid waste generated by the Project would be within the capacity of the landfill. The solid waste generated by full buildout of the TVSP would represent approximately 0.5 percent of the excess capacity of the California Street Landfill and 0.3 percent of the excess capacity of the excess capacity at the San Timoteo Sanitary Landfill each day. Furthermore, the California Street Landfill is permitted to operate through buildout of the TVSP. Thus, the proposed Project would be served by a landfill with sufficient permitted capacity to accommodate the Project’s solid waste disposal needs and the Project would not impair the attainment of solid waste reduction goals. Impacts related to landfill capacity would be less than significant.

5.16.5.6 SOLID WASTE CUMULATIVE IMPACTS
The geographic scope of cumulative analysis for landfill capacity is the service area for the California Street Landfill and San Timoteo Sanitary Landfill, which serve the TVSP Area. Both landfills serve the Valley portion of San Bernardino County. The projections of future landfill capacity based on the entire projected waste stream going to these landfills is used for cumulative impact analysis. As described previously, 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.

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extra capacity of 1,228 tons per day. The 3.49 tons per day from operation of the TVSP area at full buildout would be approximately 0.5 percent of the excess capacity of the California Street Landfill and

0.3 percent of the excess capacity of the excess capacity at the San Timoteo Sanitary Landfill each day.

Furthermore, combined, the landfills have a total remaining capacity of 17,528,587 cubic yards. Therefore, the landfills would have sufficient capacity to serve the Project and the increase is solid waste from full buildout of the TVSP area would be less than cumulatively considerable and less than significant.

5.16.5.7 EXISTING REGULATIONS, STANDARD CONDITIONS AND PLANS, PROGRAMS, OR

POLICIES
Existing Regulations
• Assembly Bill 341 (Chapter 476, Statutes of 2011)
• California Green Building Standards Code
Standard Conditions
None.

Plans, Programs, or Policies
None.

5.16.5.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts UT-6 and UT-7 would be less than significant.

5.16.5.9 SOLID WASTE MITIGATION MEASURES
No mitigation measures are required.

5.16.5.10 SOLID WASTE LEVEL OF SIGNIFICANCE AFTER MITIGATION No significant unavoidable adverse impacts related to solid waste would occur.

REFERENCES
2020 Upper Santa Ana River Watershed Integrated Regional Urban Water Management Plan. Accessed:
https://www.cityofredlands.org/sites/main/files/fileattachments/part_2_chapter_4_redlands_2020_uwmp.pdf?1622145365 City of Redlands General Plan 2035. Accessed: https://www.cityofredlands.org/post/planning-divisiongeneral-plan City of Redlands General Plan 2035 Draft EIR. 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 Redlands Regular Meeting of 10-18-22 984 of 1815
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City of Redlands Utilities. Accessed: https://www.cityofredlands.org/utilities-0 Fuscoe Engineering. Redlands Transit Village Water Supply Assessment (WSA 2022). January 26, 2022. (Appendix F)
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/ San Bernardino Countywide Plan. http://countywideplan.com/ Redlands Regular Meeting of 10-18-22 985 of 1815
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5.17 Mandatory Findings of Significance

5.17.1 SIGNIFICANT UNAVOIDABLE IMPACTS
Section 15126.2(b) of the CEQA Guidelines requires an EIR to describe “any significant impacts, including those which can be mitigated but not reduced to a level of insignificance.” Potential environmental effects of the proposed Project and mitigation measures are discussed in detail throughout in Chapter 5 of this Draft EIR. As summarized below and detailed in Section 5.2, Air Quality, and Section 5.14, Transportation, impacts in the following areas would remain significant and unavoidable, even with the incorporation of standard conditions; plans, programs, policies; and feasible mitigation measures.

Air Quality
As detailed in Section 5.2, Air Quality, due to the uncertainty of the timing and methods of construction activities related to TVSP development projects, a significant impact could occur related to construction emissions of VOC and NOx, with implementation of South Coast Air Quality Management District (SCAQMD) Rules and mitigation measures. In addition, operation of the proposed TVSP at buildout would result in exceedance of the applicable SCAQMD thresholds for VOC, NOx, and CO after implementation of mitigation. The large majority of operational-source 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, emissions generated from implementation of the proposed TVSP would be significant and unavoidable. Also, because the emissions would exceed thresholds, the Project would result in a conflict with implementation of the AQMP and impacts related to the AQMP would also be significant and unavoidable.

In addition, 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. Due to the Project exceedance of CO, VOC, and NOx thresholds, impacts would be cumulatively considerable and significant and unavoidable.

Transportation
As detailed in Section 5.14, Transportation, all TAZs within the TVSP area satisfy screening criteria 1, 2, 3, or 4 and are less than significant, except for TAZ 53827101 on the western boundary of the TVSP area. In order for projects within TAZ 53827101 to have a less than significant VMT impact, developments must adhere to the land use types in Screening Criteria 3 or land use quantities in Screening Criteria 4 – Land Use Quantities. Specific development within this TAZ is currently unknown. As such, Mitigation Measure TR-1 is included to require implementing projects within TAZ 53827101 to conduct a VMT Screening Analysis or VMT Analysis prior to approval of any site plans. While it is likely that implementing projects would meet the screening criteria, it is also possible that an implementing project would include development beyond the land uses provided for in Screening Criteria 4 and would result in more than 3,000 MT CO2e of GHG emissions per year. Therefore, individual implementing projects within TAZ 53827101 would potentially need to conduct their own CEQA analysis. Additionally, anticipated VMT reductions from inclusion of Transportation Demand Management (TDM) measures for implementing projects that result in a VMT impact, are not large enough to guarantee that significant impacts from implementing projects could be fully mitigated. As such, despite inclusion of Mitigation Measure TR-1, impacts related to VMT within TAZ 53827101 are considered be significant and unavoidable.

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5.17.2 GROWTH INDUCEMENT
This section analyzes the growth inducement potential of the proposed Project and the associated secondary effects of growth the Project might permit. As required by CEQA Guidelines Section 15126.2(d), an EIR must:
“Discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth (a major expansion of a recycled water plant might, for example, allow for more construction in service areas). Increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. Also discuss the characteristic of some projects which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.” Thus, based on CEQA, a project could have a direct effect on population growth, for example, if it would involve construction of substantial new housing. A project could also have indirect growth-inducement potential if it would:
• Establish substantial new permanent employment opportunities (e.g., commercial, industrial, governmental, or other employment-generating enterprises) or otherwise stimulate economic activity such that it would result in the need for additional housing, businesses, and services to support increased economic activities;
• Remove obstacles to growth, e.g., through the construction or extension of major infrastructure facilities that do not presently exist in the project area, or would add substantial capacity that could accommodate additional unplanned growth;
• Remove obstacles to growth through changes in existing regulations pertaining to land development; • Result in the need to expand one or more public service facilities to maintain desired levels of service; or
• Involve some other action that could encourage and facilitate other activities that could significantly affect the environment.

As CEQA Guidelines Section 15126.2(d) states that growth-inducing effects are not to be construed as necessarily beneficial, detrimental or of little significance to the environment; the following information is provided as additional information on ways in which the proposed Project could contribute to significant changes in the environment beyond the direct consequences of developing the land use concepts examined in the preceding sections of this Draft EIR.

Establish substantial new permanent employment opportunities or otherwise stimulate economic activity such that it would result in the need for additional housing, businesses, and services to support increased economic activities
The proposed TVSP would result in development of up to 613,000 square feet of retail commercial, hotel, and office space by 2045. SCAG estimates that employment in the City will increase from 42,600 jobs in 2016 to 56,300 in 2045, which is an increase of 13,700 jobs or a 32.2 percent increase (SCAG 2020 growth forecast). The employment anticipated by the proposed TVSP would generate approximately 1,226 new employees (see Section 5.11, Population and Housing), which represents 8.9 percent of the estimated Redlands Regular Meeting of 10-18-22 987 of 1815
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job growth by 2045. The 1,226 jobs expected in the TVSP area are included in SCAG projections because the employment land in the TVSP area is included in the General Plan and is not changing with implementation of the TVSP. Thus, the employment that would occur within the TVSP area would be less than significant.

The new Project would accommodate the forecasted employment in an environmentally sustainable manner by providing for housing to maintain the jobs to housing balance, that would reduce vehicle miles traveled.

Also, as listed below, the City of Redlands has had recent unemployment rates ranging between 3.0 and

7.5 percent (EDD, 2021).
• December 2021: 3.6 percent unemployment rate
• 2020 Annual Average: 7.5 percent unemployment rate
• 2019 Annual Average: 3.0 percent unemployment rate
• 2018 Annual Average: 3.3 percent unemployment rate
• 2017 Annual Average: 3.8 percent unemployment rate
• 2016 Annual Average: 4.5 percent unemployment rate
The jobs would provide new employment opportunities for people living in Redlands and the surrounding cities. Most of the new commercial and office jobs that would be created by the proposed TVSP would be positions that are anticipated to be filled by people who would already be living within Redlands and surrounding communities and would not induce an unanticipated influx of new labor into the region. As described in Section 5.11, Population and Housing, buildout of the TVSP would result in maintenance and future improvement of the projected jobs-household ratio, which is a benefit of the proposed TVSP because a more balanced jobs-to-housing ratio could improve the environment by reducing vehicle miles traveled and emissions from motor vehicles. Overall, the proposed TVSP would accommodate forecasted employment growth consistent with SCAG’s regional forecasts. Thus, impacts related to increased growth through the provision of employment opportunities would be less than significant.

Remove Obstacles to Growth, e.g., Through the Construction Or Extension of Major Infrastructure Facilities that do not Presently Exist in the Project Area or Would Add Substantial Capacity that Could Accommodate Additional Unplanned Growth.

The elimination of a physical obstacle to growth is considered to be a growth inducing impact. A physical obstacle to growth typically involves the lack of public service infrastructure. The proposed Project would induce growth if it would provide public services or infrastructure with excess capacity to serve lands that would otherwise not be developable.

The TVSP area is a developed urban area that is connected to the City’s existing infrastructure system.

Water, sewer, drainage, and roadways provide service to all of the areas within the TVSP. As described in Section 5.16, Utilities and Service Systems, development projects pursuant to the TVSP would include installation of onsite infrastructure and new connections to the existing infrastructure systems, which include improvements to existing aged infrastructure such as increasing the size of water and sewer lines. However, these improvements are sized to accommodate the TVSP buildout and not provide excess capacity. As described above, the TVSP area is urban and developed and the projects implemented by the TVSP would consist of infill and redevelopment of existing uses or development of vacant parcels that are in between developed parcels in the urban area. The TVSP related infrastructure and utility improvements do not involve extension of utilities into undeveloped areas. Therefore, the infrastructure improvements implemented by the Project would not result in unplanned growth.

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The TVSP would also implement circulation improvements to street, pedestrian, and bicycle facilities, which would enhance local circulation and the use of transit. The circulation improvements provided by the TVSP would not extend circulation into a new area or provide excess circulation capacity that could induce growth.

The improvements proposed by the TVSP would enhance circulation to provide for multi-modal transportation and implement use of transit. As a result, the circulation improvements would result in less than significant growth inducing impacts.

Remove Obstacles to Growth Through Changes in Existing Regulations Pertaining to Land Development A project could directly induce growth if it would remove barriers to population growth such as change to a jurisdictions general plan and zoning code, which allows new development to occur in underutilized areas.

The proposed TVSP includes amending the GP2035 to establish a new Transit Village District (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 proposed TVSP provides detailed standards for building placement, height, massing, articulation, frontage, landscape, and parking based through a form-based code. The formbased code incorporates a gradual transitioning of the height and mass of buildings from larger to smaller to avoid incompatible buildings heights next to each other. The amount of square-footage and dwelling units listed at buildout of the proposed TVSP could be constructed at the present time under the current GP2035 land use designations and current zoning designations within the TVSP area. The difference is that with implementation of the Project, the new development 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 reduce vehicle trips and vehicle miles traveled), and provide more public open space and amenities that provides aesthetic and community benefits. Therefore, the proposed TVSP related changes to land use and zoning designations would not result in removing an obstacle to growth.

Also, SCAG household growth projections estimate that between 2021 and 2045 the number of households within the City will grow by 21.2 percent (5,395 households). Assuming that the maximum number of residential units in the proposed TVSP are developed and occupied (no vacancy), the 2,400 additional households in the TVSP area would consist of a 9.4 percent increase of households citywide, which is within the SCAG anticipated growth of both the City and the County. Likewise, as described previously, the employment anticipated by the TVSP would generate approximately 1,226 new employees (see Section

5.11, Population and Housing), which represents 8.9 percent of the estimated job growth by 2045. These jobs are included in SCAG projections because the employment land in the TVSP area is included in the General Plan and is not changing with implementation of the TVSP. Therefore, impacts related to growth from changes in existing regulations pertaining to land development would not occur.

Result in the Need to Expand One or More Public Service Facilities to Maintain Desired Levels of Service The proposed Project is expected to incrementally increase the demand for fire protection and emergency response, police protection, and school services. However, as detailed in Section 5.12, Public Services, the proposed Project would not require development of additional facilities or expansion of existing facilities to maintain existing levels of service. Based on service ratios and buildout projections, the proposed Project would not create a demand for services beyond the capacity of existing facilities. Therefore, an indirect growth inducing impact as a result of expanded or new public facilities that could support other development in addition to the proposed Project would not occur. The proposed Project would not result in significant growth inducing consequences that would require the need to expand public services to maintain desired levels of service.

Involve Some Other Action that Could Encourage and Facilitate Other Activities that Could Significantly Affect the Environment
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The proposed Project does not propose changes to any of the City’s building safety standards (i.e., building, grading, plumbing, mechanical, electrical, or fire codes). The development implemented pursuant to the TVSP would comply with all applicable City plans, policies, and ordinances. In addition, mitigation measures have been identified within this Draft EIR to ensure that the Project minimizes environmental impacts. The Project would not involve any precedent-setting action that could encourage and facilitate other activities that significantly affect the environment.

Environmental Impacts of Induced Growth
All physical environmental effects from construction of development of the proposed TVSP have been analyzed in all technical sections of this Draft EIR and Initial Study prepared for this Project. For example, activities such as excavation, grading, and construction as required for the buildout of the TVSP have been evaluated herein. Also, all operational aspects of the TVSP have been analyzed in this Draft EIR and through implementation of existing regulations, including the General Plan and zoning ordinance, would not create an environmental impact of induced growth.

5.17.3 SIGNIFICANT IRREVERSIBLE EFFECTS
State CEQA Guidelines require the EIR to consider whether “uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely…. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.” (CEQA Guidelines Section 15126.2(c)). “Nonrenewable resource” refers to the physical features of the natural environment, such as land, waterways, mineral resources, etc. These irreversible environmental changes may include current or future uses of non-renewable resources, and secondary or growth-inducing impacts that commit future generations to similar uses.

Generally, a project would result in significant irreversible environmental changes if:
• The primary and secondary impacts would generally commit future generations to similar uses; • The project would involve a large commitment of nonrenewable resources; • The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project; or • The proposed irretrievable commitments of nonrenewable resources is not justified (e.g., the project involves the wasteful use of energy).

Energy Resources
While not implementing development under the TVSP would not involve the wasteful use of energy, new development under the TVSP would result in an increase of energy use. Residential, commercial, office, and mixed-use developments would use electricity, natural gas, and petroleum products for lighting, heating, and power. Additionally, vehicles traveling within and to and from the TVSP area would utilize both oil and gas.

Use of these types of energy for development within the TVSP would result in an increase of use of nonrenewable energy resources, which represents an irreversible environmental change.

Construction Impacts
Construction of implementing development projects under the TVSP would result in the consumption of building materials, including lumber, sand, and gravel for construction. Depletion of non-renewable resources that supply building materials would represent an irreversible environmental change.

5.17.4 EFFECTS FOUND NOT TO BE SIGNIFICANT
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CEQA Guidelines Section 15126.2(a) states that “[a]n EIR shall identify and focus on the significant effects on the environment”. However, CEQA Guidelines Section 15128 requires that an EIR contain a statement briefly indicating the reasons that various possible effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR. The following environmental issue areas would not be potentially impacted by the proposed Project, as detailed below.

Agricultural Resources
The Project area is urbanized and largely developed. There is no designated Prime Farmland, Unique Farmland, or Farmland of Local Importance within the Project area (GP2035 EIR, Figure 3.2-1). Therefore, implementation of the Project would not convert existing designated farmland and no related impact would occur. Also, none of the parcels within the Project area are zoned for agricultural use, nor is there any land under a Williamson Act contract within the Project area (City Zoning 2020), and GP2035 EIR, Figure 3.2-1).

None of the parcels within the Project are currently zoned as forest land, timberland, or Timberland Production, and the Project would not result in the conversion of farmland to non-agricultural or forest land to non-forest land, either directly or indirectly. As such, the Project would not involve other changes in the existing environment that could result in conversion of farmland to non-agricultural use or forest land to nonforest land.

Biological Resources
The Project area is urbanized and developed. Implementation of the Project would implement infill development within an already highly disturbed urban environment and would not result in any direct impacts to special status species, nor involve or result in any existing habitat modifications that could indirectly result in a substantial adverse effect on any special status species. Therefore, the Project would not result in impacts on species identified as candidate, sensitive, or special status.

The Project area is located in an area that contains a considerable amount of impervious surfaces (i.e., asphalt, cemented streets, parking lots, buildings, etc.) and non-native ornamental trees, shrubs, and ground cover; therefore, riparian habitat is not present nor another sensitive natural community present in the Project area. The Project would involve infill and redevelopment within an already highly disturbed urban environment and would not involve any changes or alterations to any riparian habitat or other sensitive natural community. Likewise, the Project area does not contain protected wetlands (USFWS 2020). The Project area is a highly disturbed urban environment. Implementation of the TVSP would not have a substantial adverse effect on wetlands as defined by Section 404 of the Clean Water Act.

No wildlife corridors, native wildlife nursery sites, or bodies of water in which fish are present are located within the Project area or in the surrounding area. However, mature trees are scattered throughout the area.

Although the trees are mainly ornamental and nonnative, they may provide suitable habitat, including nesting habitat, for migratory birds. The Migratory Bird Treaty Act of 1918 (MBTA) implements the United States’ commitment to four treaties with Canada, Japan, Mexico, and Russia for the protection of shared migratory bird resources. The MBTA governs the taking, killing, possession, transportation, and importation of migratory birds, their eggs, parts, and nests. The U.S. Fish and Wildlife Service (USFWS) administers permits to take migratory birds in accordance with the MBTA. The City requires that all projects comply with the MBTA by either avoiding grading activities during the nesting season (February 15 to August 15) or conducting a site survey for nesting birds prior to commencing grading activities. Projects implemented under the Project would be required to comply with the provisions of the MBTA. Adherence to the MBTA regulations would ensure that if construction occurs during the breeding season, appropriate measures would be taken to avoid impacts Redlands Regular Meeting of 10-18-22 991 of 1815
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to any nesting birds if found. With adherence to the MBTA requirements, less than significant impacts would occur and no further analysis is required in the EIR.

Implementation of the Project is not anticipated to conflict with the provisions of these existing tree policies and guidelines. Future development, revitalization, and/or redevelopment activities that would be permitted under the Project would be required to be reviewed by the City for consistency with the exiting tree policies and guidelines. Additionally, the Project outlines standards and guidelines to ensure the proper management (e.g., planting, health, maintenance) of trees occurs. Therefore, implementation of the Project would not conflict with any local policies or ordinances protecting biological resources. Impacts would be less than significant. Furthermore, the Project would not conflict with the provisions of an adopted habitat conservation plan or natural community conservation plan.

Mineral Resources
The Project area consists of the City’s urban core, residential neighborhoods, civic uses, and parks. The Project area has not historically included mineral extraction, nor does the Project area currently support mineral extraction or have identified mineral resources. Thus, implementation of the Project would not result in the loss of availability of a known mineral resource of value to the region and state or delineated on the general plan, specific plan or other land use plan, and no impact would occur.

Wildfire
The Project area is an urbanized environment with moderate fire threat level and does not include, nor is it around, wildlands or areas of high fire hazard terrain or vegetation. Implementation of the Project would not exacerbate wildfire risks nor expose occupants to risk of pollutant concentrations from a wildfire or uncontrolled spread of a wildfire. The Project area is also not located in or near a state responsibility area, and the Project would not impair the implementation of an adopted emergency response plan or emergency evacuation plan. The project would not require installation of infrastructure that could exacerbate fire risks and would not expose people to downstream flooding related to post fire slope instability. Therefore, implementation of the Project would not result in any impacts related to wildfire.

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REFERENCES
California Department of Fish and Wildlife (CDFW 2019), https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=68626&inline City of Redlands (GP2035 EIR), General Plan 2035 Environmental Impact Report, https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands (GP2035), General Plan 2035, https://www.cityofredlands.org/post/planning-divisiongeneral-plan City of Redlands (City Zoning 2020), Zoning Map, https://www.cityofredlands.org/sites/main/files/fileattachments/zoning.pdf California Department of Conservation Important Farmland mapping (CDC 2022). Accessed:
https://www.conservation.ca.gov/dlrp/fmmp
California Geological Survey Mineral Resource mapping (CGS 2022). Accessed:
https://maps.conservation.ca.gov/mineralresources/#webmaps Cal Fire. Website: https://www.fire.ca.gov/
Southern California Association of Governments (SCAG). Website:
https://scag.ca.gov/sites/main/files/fileattachments/dpeir_connectsocal_3_14_populationhousing.pdf?1606003672 United States Fish and Wildlife Service (USFWS 2020),
https://www.fws.gov/wetlands/Data/Mapper.html
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6.0 Alternatives
This section addresses alternatives to the proposed Project and describes the rationale for including them in the Draft EIR. The section also discusses the environmental impacts associated with each alternative and compares the relative impacts of each alternative to those of the proposed Project. In addition, this section describes the extent to which each alternative meets the Project objectives.

6.1 INTRODUCTION
The identification and analysis of alternatives to a project is a fundamental part of the environmental review process pursuant to CEQA. Public Resources Code (PRC) Section 21002.1(a) establishes the need to address alternatives in an EIR by stating that in addition to determining a project’s significant environmental impacts and indicating potential means of mitigating or avoiding those impacts, “the purpose of an environmental impact report is . . . to identify alternatives to the project.” Pursuant to CEQA Guidelines Section 15126.6(a), an EIR must describe a reasonable range of alternatives to the proposed Project or to the Project’s location that would feasibly avoid or lessen its significant environmental impacts while attaining most of the proposed Project’s objectives. CEQA Guidelines Section 15126.6(b) emphasizes that the selection of project alternatives be based primarily on the ability to reduce impacts relative to the proposed project. In addition, CEQA Guidelines Section 15126.6(e)(2) requires the identification and evaluation of an “Environmentally Superior Alternative.” Pursuant to CEQA Guidelines Section 15126.6(d), discussion of each alternative presented in this Draft EIR Section is intended “to allow meaningful evaluation, analysis, and comparison with the proposed project.” As permitted by CEQA, the significant effects of each alternative are discussed in less detail than those of the proposed Project, but in enough detail to provide perspective and allow for a reasoned choice among alternatives to the proposed Project.

In addition, the “range of alternatives” to be evaluated is governed by the “rule of reason” and feasibility, which requires the Draft EIR to set forth only those alternatives that are feasible and necessary to permit an informed and reasoned choice by the lead agency and to foster meaningful public participation (CEQA Guidelines Section 15126.6(f)). CEQA generally defines “feasible” to mean an alternative that is capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, technological, and legal factors and other considerations (CEQA Guidelines Sections 15091(a)(3), 15364).

Based on the CEQA requirements described above, the alternatives addressed in this Draft EIR were selected in consideration of one or more of the following factors:
• The extent to which the alternative could avoid or substantially lessen any of the identified significant environmental effects of the proposed Project;
• The extent to which the alternative could accomplish the objectives of the proposed Project; • The potential feasibility of the alternative;
• The appropriateness of the alternative in contributing to a “reasonable range” of alternatives that would allow an informed comparison of relative advantages and disadvantages of the proposed Project and potential alternatives to it; and
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• The requirement of the CEQA Guidelines to consider a “no project” alternative; and to identify an “environmentally superior” alternative in addition to the no project alternative (CEQA Guidelines Section 15126.6(e)).

Neither the CEQA statute, the CEQA Guidelines, nor recent court cases specify a specific number of alternatives to be evaluated in an EIR. Rather, “the range of alternatives required in an EIR is governed by the rule of reason that sets forth only those alternatives necessary to permit a reasoned choice” (CEQA Guidelines 15126(f)).

6.2 ENVIRONMENTAL IMPACTS
CEQA requires the alternatives selected for comparison in an EIR to avoid or substantially lessen one or more significant effects of the project being evaluated. In order to identify alternatives that would avoid or substantially lessen any of the identified significant environmental effects of implementation of the proposed Project, the significant impacts must be considered, although it is recognized that alternatives aimed at reducing the significant and unavoidable impacts would also avoid or reduce impacts that were found to be less than significant or reduced to below a level of significance with implementation of mitigation measures.

The analysis in Chapter 5 of this EIR determined that buildout of the proposed Specific Plan would result in the following significant and unavoidable impacts.

Air Quality
 As detailed in Section 5.2, Air Quality, due to the uncertainty of the timing and methods of construction activities related to Specific Plan development projects, a significant impact could occur related to construction emissions of ROGs and NOx, even with implementation of South Coast Air Quality Management District (SCAQMD) Rules and mitigation measures. In addition, operation of the proposed Specific Plan would result in exceedance of the applicable SCAQMD thresholds for ROGs, NOx, and CO even after implementation of mitigation. Therefore, emissions generated from implementation of the proposed Specific Plan would be significant and unavoidable. Also, because the emissions would exceed thresholds, the Project would result in a conflict with implementation of the AQMP and impacts related to the AQMP would also be significant and unavoidable.  Cumulative Air Quality Impacts: As described in Section 5.2, Air Quality, per SCAQMD’s methodology, if an individual project results in air emissions of criteria pollutants (including ROG, CO, NOx, SOx, PM10, and PM2.5) that exceed the SCAQMD’s thresholds for project-specific impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants for which the region is in non-attainment under an applicable federal or state ambient air quality standard.

As described previously, emissions from construction of projects pursuant to the proposed Specific Plan would exceed SCAQMD’s threshold for ROGs and NOx after implementation of SCAQMD Rules and mitigation measures. In addition, emissions from buildout of the proposed Specific Plan would exceed the applicable SCAQMD thresholds for ROGs, NOx, and CO even with implementation of mitigation. Therefore, operational-source emissions from implementation of the proposed Specific Plan would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable.

Transportation and Circulation
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 As detailed in Section 5.9, Transportation and Circulation, all TAZs within the Specific Plan Area are within a TPA or a low-VMT area or would meet Criteria 3 or 4 based on limited buildout area, except for TAZ 53827101. As such, implementing development pursuant to the TVSP in all TAZs except 53827101 would be less than significant. In order for implementing projects within a TPA to be presumed to have a less than significant VMT impact, developments must meet the criteria set forth in the City of Redlands VMT Guidelines Screening Criteria. In order for projects within TAZ 53827101 to be presumed to have a less than significant VMT impact, developments located within TAZ 53827101 must adhere to the land use types presented in Screening Criteria 3 – Land Use Types or land use quantities presented in Screening Criteria 4 – Land Use Quantities. As shown in Figure 3-17, Vacant and Non-Conforming Parcels, two parcels within TAZ 53827101 are vacant and the rest are considered non-conforming. As such, it can be reasonably presumed that these parcels will be developed or redeveloped pursuant to the TVSP prior to buildout. However, at this time, specific development within the TVSP area is unknown. As such, Mitigation Measure TR-1 is included to require implementing projects within a TPA or TAZ 53827101 to conduct a VMT Screening Analysis or VMT Analysis prior to approval of any site plans. While it is likely that implementing projects would meet the criteria set forth in Screening Criteria 1, 2, 3, or 4, it is also possible that an implementing project would not meet the criteria set forth in Screening Criteria 1 or include development beyond the land uses provided for in Screening Criteria 4 and would result in more than 3,000 MT CO2e of GHG emissions per year. Additionally, anticipated VMT reductions from inclusion of Transportation Demand Management (TDM) measures for implementing projects that result in a VMT impact, are not large enough to guarantee that significant impacts from implementing projects could be fully mitigated. As such, despite inclusion of Mitigation Measure TR1, impacts related to VMT within TAZ 53827101would be significant and unavoidable.

6.3 PROJECT OBJECTIVES
The following objectives have been identified in order to aid decision makers in their review of the proposed Project and its associated environmental impacts.

1. A vision for the future of the three station areas that recognizes the importance of Redlands’ unique history and tradition while embracing opportunities for continued reinvestment, growth, and beneficial change.

2. Application of the General Plan’s goals, policies, and actions to achieve the revitalization of the Plan Area.

3. New form-based zoning standards for the Plan Area that will replace current zoning regulations.

These new standards are calibrated to deliver new development that is consistent with Redlands’ physical character, history, and culture, as well as the community’s vision for its future growth.

4. An implementation strategy for transforming the Plan Area’s streets, infrastructure, parks, and other public spaces in line with the City of Redland’s unique culture and history.

5. Transform streets and create neighborhood connectivity through pedestrian-oriented improvements.

6. Provide a variety of housing options to accommodate and attract a range of household types in order to meet the City’s housing needs.

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7. Provide for transit-oriented development around the three new Arrow Line stations in line with the City’s General Plan.

6.4 ALTERNATIVES CONSIDERED BUT REJECTED
Pursuant to CEQA Guidelines Section 15126.6(c), an EIR must briefly describe the rationale for selection and rejection of alternatives. The lead agency may make an initial determination as to which alternatives are potentially feasible and, therefore, merit in-depth consideration, and which are infeasible and need not be considered further. Alternatives that are remote or speculative, or the effects of which cannot be reasonably predicted, need not be considered (CEQA Guidelines Section 15126.6(f), (f)(3)). This section identifies alternatives considered by the lead agency but rejected as infeasible and provides a brief explanation of the reasons for their exclusion. Alternatives may be eliminated from detailed consideration in the Draft EIR if they fail to meet most of the Project objectives, are infeasible, or do not avoid any significant environmental effects.
• Alternate Site Alternative: An alternate site for the proposed Project was eliminated from further consideration. The primary purpose of the proposed TVSP is to guide redevelopment of areas surrounding the three new Arrow Line stations by introducing additional residential and mixed use, and proposing circulation improvements for vehicles, pedestrians, bicyclists, and transit users. Since all of the Project objectives are related to the areas surrounding the three Arrow Line Stations in the New York Street Village, Downtown Village, and University Village, none of these objectives could be met in another location in the city. Therefore, the Alternative Site Alternative was rejected from further consideration.
• No Project/No Build Alternative. No development within the TVSP area was eliminated from further consideration as an alternative. Under the No Project/No Build Alternative, the current uses within the TVSP area would remain the same, and vacant or underutilized parcels would remain as such.

The No Build Alternative would not allow developments to be constructed that are consistent with the existing General Plan land use designations and zoning. Since all of the Project objectives are related to redevelopment of the areas surrounding the three new Arrow Line Stations, none of these objectives could be met through no development within the TVSP area. Therefore, the No Project/No Build Alternative was rejected from further consideration.

6.5 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
Three alternatives to the proposed Project have been identified for further analysis as representing a reasonable range of alternatives that attain most of the objectives of the Project, may avoid or substantially lessen any of the significant effects of the proposed Project, and are feasible from a development perspective. These alternatives have been developed based on the criteria identified in Section 6.1, and are described below:

Alternative 1: No Project/Buildout of the Existing Zoning. Under this alternative, the proposed Specific Plan would not be developed. In accordance with the CEQA Guidelines, the No Project/ Buildout of Existing Zoning Alternative will be the continuation of the existing plan, policy or operation into the future when the project is the revision of an existing land use or regulatory plan, policy or ongoing operation. Section 15126.6(e)(3)(A) of the CEQA Guidelines states that, “typically this is a situation where other projects initiated under the existing plan will continue while the new plan is developed. Thus, the projected impacts of the proposed plan or alternative plans would be compared to the impacts that would occur under the existing plan.”
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This alternative evaluates the environmental effects of buildout of the Specific Plan area according to the existing General Plan and zoning designations. Because the Specific Plan area is an urban area that is generally built out, most new development would occur as adaptive reuse of existing buildings, development on existing vacant sites, and infill or redevelopment of existing uses at the intensity allowed by the existing zoning. The majority of development under this alternative would similarly occur on vacant and nonconforming parcels as shown on Figure 3-17, Vacant and Non-Conforming Parcels. The addition of residential uses and mixed residential uses within the TVSP area would not occur, as proposed by the project. However, as described in Chapter 3.0, Project Description, the amount of square-footage and dwelling units listed in Table 3-1 could be constructed at the present time under the current General Plan land use designations and current zoning designations within the Project area. Because the land use and zoning designations of the non-residential parcels would not change as a result of the proposed Specific Plan, the No Project/ Buildout of Existing Zoning Alternative assumes development of 2,400 dwelling units, 220 hotel rooms, 265,000 SF of retail commercial, 238,000 SF of office space, and 280,000 SF of open space and parks as allowed by existing General Plan and Zoning. However, development would occur in line with the existing zoning and General Plan land use designations in the area, and an increase in density in areas immediately surrounding the new Arrow Line Stations in the proposed Village Center district would not occur. In addition, areas within the proposed TVSP area would remain largely commercial within the New York Street Village and Downtown Village, and an increase in multi-family development in these areas would not be realized.

The Alternative 1: No Project/Buildout of Existing Zoning Alternative evaluation provides a comparison between the environmental impacts of the proposed Specific Plan in contrast to the result from not approving, or denying, the proposed Specific Plan. Thus, this alternative is intended to meet the requirements of CEQA Guidelines Section 15126.6(e) for evaluation of a no project alternative.

Alternative 2: Reduced Specific Plan Area Alternative. Under this alternative, the parcels located within Traffic Analysis Zone (TAZ) 53827101 outside of the Transit Priority Area (TPA), which include parcels north of Colton Avenue on the northwestern tip of the TVSP area, as demonstrated by Figure 5.14-1, Transit Priority Areas & Specific Plan TAZs, would not be included in the TVSP area. Under this alternative, implementing developments in TPAs would meet the criteria under the City’s Screening Criteria. Under this alternative, a 25 percent reduction in the number of proposed dwelling units, commercial retail, and office space would be developed in the New York Street Village. Based on the reduction in land included in the TVSP area within the New York Street Village, only 150 dwelling units, 26,250 SF of retail commercial, and 131,250 SF of office uses would be developed in the New York Street Village. Under this alternative a total of 2,350 dwelling units, 256,250 SF of retail commercial, and 194,250 SF of office uses could be developed under buildout of the TVSP. This alternative includes all of the circulation and streetscape improvements, open space improvements, and infrastructure improvements that are proposed under the TVSP, with exception to those only applicable to areas outside of TPAs within TAZ 53827101.

Alternative 3: Reduced Intensity Alternative. Under this alternative, a 60 percent reduction in the number of dwelling units, retail commercial uses, and office uses would be developed throughout all of the proposed Transit Villages. The proposed TVSP would allow for development of up to 960 dwelling units, 88 hotel rooms, 106,000 SF of retail commercial, and 95,200 SF of office uses through the year 2040. Overall, 60 percent less development would occur within each Transit Village. Under this alternative, redevelopment would still be concentrated on vacant and non-conforming parcels within the TVSP area, as shown on Figure 3-17, Vacant and Non-Conforming Parcels. This alternative includes all of the circulation and streetscape improvements, open space improvements, and infrastructure improvements that are proposed under the TVSP.

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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-6
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6.6 ALTERNATIVE 1: NO PROJECT/NO BUILDOUT OF THE EXISTING ZONING
Section 15126.6(e) of the CEQA Guidelines requires analysis of the No Project Alternative. The no project alternative analysis must discuss the existing conditions at the time the Notice of Preparation/Initial Study was published and considers conditions that would be reasonably expected to occur in the foreseeable future if the project were not approved. The No Project Alternative applies to the following scenarios:
(1) When the project is a revision of an existing land use or regulatory plan, policy, or ongoing operation, the "no project" alternative is the continuation of the existing plan, policy, or operation into the future; or
(2) If the project is other than a land use or regulatory plan, for example a development project on identifiable property, the "no project" alternative is the circumstance under which the project does not proceed.

Therefore, under Alternative 1: No Project/Buildout of Existing Zoning Alternative, the proposed TVSP would not be implemented, and the TVSP area would be developed pursuant to the existing land use and zoning regulations. Limited new development would occur on vacant parcels and redevelopment of sites would occur pursuant to the existing zoning. However, as discussed in Section 3, Project Description, the same amount of square-footage and dwelling units listed in Table 3-1 as proposed by TVSP could be constructed at the present time under the current General Plan land use designations and current zoning designations within the Project area. Because the land use and zoning designations of the non-residential parcels would not change as a result of the proposed Specific Plan, the No Project/ Buildout of Existing Zoning Alternative assumes development of 2,400 dwelling units, 220 hotel rooms, 265,000 SF of retail commercial, 238,000 SF of office space, and 280,000 SF of open space and parks as allowed by existing General Plan and Zoning.

However, development would occur in line with the existing zoning and General Plan land use designations in the area, and an increase in density in areas immediately surrounding the new Arrow Line Stations in the proposed Village Center district would not occur. In addition, areas within the proposed TVSP area would remain largely commercial within the New York Street Village and Downtown Village, and an increase in multi-family development in these areas would not be realized. Accordingly, Alternative 1: No Project/Buildout of Existing Zoning Alternative provides a comparison between the environmental impacts of the proposed Specific Plan and the result of not approving, or denying, the proposed Specific Plan.

6.6.1 ENVIRONMENTAL IMPACTS
Aesthetics
Under the No Project/Buildout of Existing Zoning Alternative, infill development on remaining vacant parcels, redevelopment per the existing zoning on non-conforming parcels, and adaptive reuse of existing buildings would occur within the TVSP area to add residential and commercial uses. Development under this alternative would occur in the absence of unifying design guidelines, architectural guidelines, streetscape improvements, open space improvements, and other aesthetic enhancements proposed in the TVSP that are intended to create distinctive areas that are compatible with the history and culture of Redlands while enhancing connectivity for alternative transportation. Although visual impacts would be less than significant under this alternative, as development would occur consistent with the existing zoning and compatible with the surrounding developments, the overall visual quality of the TVSP area would not be improved when compared to the proposed Project, which would result in an overall improvement in aesthetics and enhancement of character within the area. Furthermore, the No Project/Buildout of Existing Zoning Alternative would not promote compact and walkable urban form in the vicinity of the train stations, introduce a greater Redlands Regular Meeting of 10-18-22 999 of 1815
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variety of transportation options (and reduce vehicle trips and vehicle miles traveled), or provide more public open space and amenities that provides aesthetic and community benefits.

Development under this alternative would result in the same amount of new sources of light and glare from infill development. However, both this alternative and the proposed Project would result in similar impacts with implementation of the City’s existing lighting regulations and the City’s design review process. Overall, the aesthetic impacts from this alternative would be similar to those associated with the proposed Project, and result in less than significant impacts.

Air Quality
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. However, an increase in density, as allowed by the proposed Village Center District within the TVSP, for parcels immediately surrounding the new Arrow Line Stations would not occur. The alternative would not result in changes to zoning or the General Plan land uses. Therefore, it would be consistent with the Air Quality Management Plan (AQMP) under the AQMP Consistency Criterion No. 1.

However, as the No Project/Buildout of Existing Zoning Alternative would result in the same development as the proposed Project, air quality pollutant emissions from both construction and operations of the alternative would exceed criteria pollutant thresholds set by the South Coast Air Quality Management District (SCAQMD). Therefore, buildout pursuant to the existing zoning would continue to result in a significant and unavoidable impact after implementation of mitigation. Thus, impacts under the No Project/Buildout of Existing Zoning Alternative would be the same as the proposed Project.

Cultural Resources
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in a similar potential to adversely affect any historic or undiscovered archeological resources as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to the same intensity. This alternative would have a similar impact on historic structures within the TVSP area. However, like the proposed Project, similar mitigation to the Project’s mitigation measures and compliance with applicable City of Redlands Municipal Code provisions, including Redlands Historic Architectural Design Guidelines, would be required to reduce potential impacts to a less than significant level. Therefore, impacts to cultural resources from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

Energy
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. This would result in the same demand for energy in comparison to the proposed Project, which was determined to be less than significant.

Implementing projects under this alternative would be compliant with Title 24 requirements. Therefore, impacts to energy from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

Geology and Soils
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Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in a similar potential to adversely affect any undiscovered paleontological resources as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to the same intensity. However, like the proposed Project, similar mitigation to the Project’s mitigation measure would be required to reduce potential impacts to a less than significant level. Therefore, impacts to paleontological resources from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

Greenhouse Gas Emissions
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. Therefore, this alternative would generate the same amount of construction and operational greenhouse gas emissions when compared to the proposed Project. Therefore, buildout pursuant to the existing zoning would continue to result in less than significant impacts. Thus, impacts under the No Project/Buildout of Existing Zoning Alternative would be the same as the proposed Project.

Hazards and Hazardous Materials
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in redevelopment of vacant and underutilized parcels within the TVSP area, including parcels that are included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 or that need further investigation. If future redevelopment under this alternative 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. Therefore, impacts related to hazards and hazardous materials from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

Hydrology and Water Quality
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in a similar potential to adversely affect hydrology and water quality as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to the same intensity. However, like the proposed Project, implementation of existing regulatory requirements would reduce potential impacts to a less than significant level. Therefore, impacts to hydrology and water quality from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

Land Use and Planning
The No Project/Buildout of Existing Zoning Alternative would continue the existing land uses and zoning designations within the area. The proposed TVSP has been prepared to provide a cohesive plan that specifically addressees: development standards, building design, parking, architectural treatment, landscaping, open space, and infrastructure and circulation improvements. This alternative would not provide Redlands Regular Meeting of 10-18-22 1001 of 1815
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a cohesive plan for optimal functioning of a transit-oriented environment that is accessible to residents, workers, and visitors via alternative forms of transportation.

With the absence of the TVSP to guide development of the area, development would be considered on a project-by-project basis, which would not provide for a cohesive future land use plan that would maximize land use and circulation opportunities. This alternative would not implement the pedestrian and bicycle circulation patterns identified in the Specific Plan to improve access and reduce local vehicular trips. In addition, this alternative would not implement SCAG policies that encourage greater densities in areas with transit and mixed-use opportunities and less dependence on the automobile. The No Project/Buildout of Existing Zoning Alternative would not implement SCAG policies in a cohesive manner, such as would be done by the proposed TVSP
However, the land uses that would occur by the No Project/Buildout of Existing Zoning Alternative would be consistent with the City’s General Plan and zoning ordinance. Hence, like the proposed TVSP, the No Project/Buildout of Existing Zoning Alternative would result in a less than significant impact and would be similar to those associated with the proposed Project.

Noise
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in a similar potential to result in increases of ambient noise levels from construction and operation and increases in construction vibration as implementing projects of the alternative would occur in the same geographical area to the same intensity. However, like the proposed Project, similar mitigation to the Project’s mitigation measures would be required to reduce potential impacts to a less than significant level. Therefore, impacts related to noise from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

Population and Housing
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in an increase of 6,360 residents and 1,226 employees. The increase in population that would be generated by this alternative would be consistent with SCAG forecasts and would not induce substantial population growth in the Project area. The No Project/Buildout of Existing Zoning Alternative and the proposed TVSP would result in similar impacts related to population and housing.

Hence, like the proposed TVSP, the No Project/Buildout of Existing Zoning Alternative would result in a less than significant impact and would be similar to those associated with the proposed Project.

Public Services
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in the same residential and employee population increases as the proposed Project. Thus, demand for public services, including fire protection, police protection, school services, and library services would be the same as the proposed Project. Hence, like the proposed TVSP, the No Project/Buildout of Existing Zoning Alternative would result in a less than significant impact and would be similar to those associated with the proposed Project.

Recreation
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Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in the same residential and employee population increases as the proposed Project. Thus, demand for recreational facilities would be the same as the proposed Project.

However, unlike the proposed TVSP, this alternative would not include enhancement of the city’s open space network to provide a contiguous green space connecting the TVSP villages. Hence, like the proposed TVSP, the No Project/Buildout of Existing Zoning Alternative would result in a less than significant impact and would be similar to those associated with the proposed Project.

Transportation
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in a similar potential to result in vehicle miles traveled at levels above existing City thresholds, as implementing projects of the alternative would occur in the same geographical area to the same intensity. Therefore, buildout pursuant to the existing zoning would continue to result in a significant and unavoidable impact after implementation of mitigation. Furthermore, the No Project/Buildout of Existing Zoning Alternative would not promote compact and walkable urban form in the vicinity of the train stations, nor would it introduce a greater variety of transportation options (and reduce overall vehicle trips and vehicle miles traveled). Thus, impacts under the No Project/Buildout of Existing Zoning Alternative would be slightly worse than the proposed Project.

Tribal Cultural Resources
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in a similar potential adverse effect on any undiscovered tribal cultural resources as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to the same intensity. However, like the proposed Project, similar mitigation to the Project’s mitigation measures and compliance with AB 52 and SB 18 would be required to reduce potential impacts to a less than significant level. Therefore, impacts to tribal cultural resources from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

Utilities and Service Systems
Under the No Project/Buildout of Existing Zoning Alternative, the same level of development would occur within the TVSP area based on market conditions and the existing zoning. As such, the No Project/Buildout of Existing Zoning Alternative would result in the same residential and employee population increases as the proposed Project. Thus, demand for regional water supplies, wastewater treatment, and solid waste disposal would be the same as the proposed Project. Therefore, impacts to utilities and service systems from the No Project/Buildout of the Existing Zoning Alternative would be similar to those associated with the proposed Project.

6.6.2 CONCLUSION
Ability to Reduce Impacts
The No Project/Buildout of Existing Zoning Alternative would not eliminate the significant and unavoidable impacts related to air quality and vehicle miles traveled that would occur from implementation of the Redlands Regular Meeting of 10-18-22 1003 of 1815
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proposed TVSP, as buildout under this alternative would be consistent with that allowed under the TVSP. In fact, the No Project/Buildout of Existing Zoning Alternative would have more severe impacts related to vehicle miles traveled. In addition, this alternative would require the same mitigation to ensure less than significant impacts related to historical resources, cultural resources, paleontological resources, and noise.

Ability to Achieve Project Objectives
The analysis of the No Project/Buildout of Existing Zoning Alternative compares the impacts of the proposed Specific Plan to the impacts that would occur if the existing General Plan and zoning continue to be implemented. Regarding the ability to achieve Project objectives, the No Project/Buildout of Existing Zoning Alternative would not achieve most of the Project objectives, including Objectives 1, 3, 4, 5, 6, and 7, as it would not provide for new mixed-use, transit-oriented development within the vicinity of the new Arrow stations and would not provide a new form-based code. Development of the Specific Plan area under this alternative would partially achieve Objective 2, (Application of the General Plan’s goals, policies, and actions to achieve the revitalization of the Plan Area) if the Transit Village Overlay Zone within the City’s General Plan is realized through another means in order to revitalize the TVSP area pursuant to the General Plan.

6.7 ALTERNATIVE 2: REDUCED SPECIFIC PLAN AREA ALTERNATIVE Under this alternative, the parcels located within TAZ 53827101 outside of the Transit Priority Area (TPA), which include parcels north of Colton Avenue on the northwestern tip of the TVSP area, as demonstrated by Figure 5.14-1, Transit Priority Areas & Specific Plan TAZs, would not be included in the TVSP area. Under this alternative, implementing developments pursuant to the TVSP would either occur in TPAs and would meet the criteria under Screening Criteria 1 or would occur in Low VMT areas and would meet the criteria under Screening Criteria 2. Therefore, VMT impacts under Alternative 2 would be less than significant. Under this alternative, a 25 percent reduction in the number of proposed dwelling units, commercial retail, and office space would be developed in the New York Street Village. Based on the reduction in land included in the TVSP area within the New York Street Village, only 150 dwelling units, 26,250 SF of retail commercial, and 131,250 SF of office uses would be developed in the New York Street Village. Under this alternative a total of 2,350 dwelling units, 256,250 SF of retail commercial, and 194,250 SF of office uses could be developed under buildout of the TVSP, which would represent an approximately 2 percent smaller residential, 3 percent smaller retail commercial, and 18 percent smaller office buildout when compared to the proposed Project.

The area that would be developed pursuant to the TVSP under the Reduced Specific Plan Area Alternative is shown in Figure 6-1, Alternative Two Area.

This alternative includes all of the circulation and streetscape improvements, open space improvements, and infrastructure improvements that are proposed under the TVSP, with exception to those only applicable to areas outside of TPAs within TAZ 53827101.

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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-12
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Alternative Two Area
Figure 6-1
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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-15
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6.7.1 ENVIRONMENTAL IMPACTS
Aesthetics
Under the Reduced Specific Plan Area Alternative, the same type of mixed-use development would occur within the TVSP area; however, existing parcels outside of the TPA in TAZ 53827101 and TAZ 53834601 would not be redeveloped. These parcels currently make up the Tri City Shopping Center and other various commercial uses that are currently largely vacant or underutilized. The overall visual character and quality of the TVSP area would be the same as the proposed condition under development with the exception of the excluded parcels in TAZ 53827101. While slightly fewer new sources of light and glare would occur from this alternative due to the decreased buildout in the New York Street Village, overall impacts related to light and glare would be consistent with those under the proposed Project.

Implementation of the Reduced Specific Plan Area Alternative would result in the same less than significant impacts related to aesthetics as the proposed Specific Plan. The Reduced Specific Plan Area Alternative would implement the same type of visual improvements that would be introduced throughout the TVSP area by the proposed Project (e.g., new and improved open space, providing a consistent design theme within the villages, and increased streetscaping). Thus, improvements to the existing views, character, and quality of the TVSP area would also occur under the Reduced Specific Plan Area Alternative, with the exception of parcels excluded at the northwestern tip of the TVSP area. Overall, the aesthetic impacts from this alternative would be less than significant, and would be similar to those associated with the proposed Project.

Air Quality
The Reduced Specific Plan Area Alternative would develop approximately 2 percent fewer dwelling units, 3 percent less square footage of commercial retail, and 18 percent less square footage of office space than the proposed Project. Therefore, a slightly reduced overall volume of construction activities and the related emissions would occur. However, the volume of ROG and NOx emissions from construction activities would remain significant and unavoidable. As described in Section 5.2, Air Quality, construction of simultaneous implementing projects under the TVSP could result in worst-case emissions of up to 590.61 lbs/day of VOC, which is above the threshold of 75 lbs/day, and 385.10 lbs/day of NOx, which is above the threshold of 100 lbs/day. Under the Reduced Specific Plan Area Alternative, it is possible that a combination of developments could occur, such that daily construction emissions would still exceed this threshold. Thus, construction air quality impacts would remain significant and unavoidable.

In addition, the slightly reduced amount of development by this alternative would result in less stationary source emissions from equipment and less traffic associated air emissions than the proposed TVSP. Therefore, overall air quality impacts would be reduced in comparison to the proposed TVSP. However, the volume of VOC, NOx, and CO emissions from operational vehicular emissions generated by the Reduced Specific Plan Area Alternative would remain significant and unavoidable due to the volume of vehicular trips that would occur from operation of the alternative. As described in Section 5.2, Air Quality, operations from implementing projects under the TVSP would generate up to 117.49 lbs/day of VOC emissions, which is substantially above the threshold of 55 lbs/day; 79.95 lbs/day of NOx, which is above the threshold of 55 lbs/day; and 615.20 lbs/day of CO, which is above the threshold of 550 lbs/day during peak summer operations. Under the Reduced Specific Plan Area Alternative, the daily VOC, NOx, and CO emissions related to residential, commercial, and office operations would be slightly less, but would still exceed the SCAQMD thresholds. Therefore, although less emissions would occur, significant and unavoidable impacts would still occur from the Reduced Specific Plan Area Alternative. Thus, impacts under this alternative would be the same as the proposed TVSP.

Redlands Regular Meeting of 10-18-22 1008 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-16
Draft EIR
July 2022
Cultural Resources
Under the Reduced Specific Plan Area Alternative, a slightly reduced level of development would occur within a reduced TVSP area based on market conditions. As such, the Reduced Specific Plan Area Alternative would result in a generally similar potential to adversely affect any historic or undiscovered archeological resources as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to a slightly lesser intensity. This alternative would have a similar impact on historic structures within the TVSP area. However, like the proposed Project, similar mitigation to the Project’s mitigation measures and compliance with applicable City of Redlands Municipal Code provisions, including Redlands Historic Architectural Design Guidelines, would be required to reduce potential impacts to a less than significant level. Therefore, impacts to cultural resources from the Reduced Specific Plan Area Alternative would be similar to those associated with the proposed Project.

Energy
Under the Reduced Specific Plan Area Alternative, a slightly reduced level of development would occur within the reduced TVSP area based on market conditions. This would result in a slight decrease in the demand for energy in comparison to the proposed Project, which was determined to be less than significant.

Implementing projects under this alternative would be compliant with Title 24 requirements. Therefore, impacts to energy from the Reduced Specific Plan Area Alternative would be slightly less than those associated with the proposed Project, but still less than significant.

Geology and Soils
Under the Reduced Specific Plan Area Alternative, a slightly decreased level of development would occur within the reduced TVSP area based on market conditions. As such, the Reduced Specific Plan Area Alternative would generally result in a similar potential to adversely affect any undiscovered paleontological resources as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to a slightly lesser intensity. However, like the proposed Project, similar mitigation to the Project’s mitigation measure would be required to reduce potential impacts to a less than significant level.

Therefore, impacts to paleontological resources from the Reduced Specific Plan Area Alternative would be similar to those associated with the proposed Project.

Greenhouse Gas Emissions
The Reduced Specific Plan Area Alternative would develop approximately 2 percent (50) fewer dwelling units, 3 percent (8,750 SF) less retail commercial, and 18 percent (43,750 SF) less office space than the proposed TVSP. Therefore, a slightly reduced volume of construction activities and related production of GHG emissions would occur. In addition, the slightly reduced amount of development by this alternative would result in less stationary source emissions from equipment onsite, and less traffic-associated GHG emissions than the proposed TVSP. Therefore, the overall volume of GHG emissions would be reduced in comparison to the proposed Specific Plan. However, the development and operation of 2,350 dwelling units, 256,250 SF of retail commercial, and 194,250 SF of office uses would result in significant GHG emissions and would require implementation of the same mitigation measures that are required for the proposed TVSP.

Therefore, although fewer GHG emissions would occur, impacts would still be less than significant. Thus, impacts under this alternative would be the same as the proposed Specific Plan.

Redlands Regular Meeting of 10-18-22 1009 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-17
Draft EIR
July 2022
Hazards and Hazardous Materials
Under the Reduced Specific Plan Area Alternative, a slightly reduced level of development would occur within the reduced TVSP area based on market conditions. As such, the Reduced Specific Plan Area Alternative would result in redevelopment of vacant and underutilized parcels within the TVSP area, including parcels that are included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 or that need further investigation. If future redevelopment under this alternative 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.

Therefore, impacts related to hazards and hazardous materials from the Reduced Specific Plan Area Alternative would be similar to those associated with the proposed Project.

Hydrology and Water Quality
Under the Reduced Specific Plan Area Alternative, a slightly reduced level of development would occur within the reduced TVSP area based on market conditions. As such, the Reduced Specific Plan Area Alternative would result in a similar potential to adversely affect hydrology and water quality as the proposed Project, as implementing projects of the alternative would occur in the same general geographical area to a slightly smaller intensity. However, like the proposed Project, implementation of existing regulatory requirements would reduce potential impacts to a less than significant level. Therefore, impacts to hydrology and water quality from the Reduced Specific Plan Area Alternative would be similar to those associated with the proposed Project.

Land Use and Planning
Like the proposed Project, the Reduced Specific Plan Area Alternative would involve General Plan and Zoning designation changes for the reduced TVSP area and would have the same type of consistency with the SCAG RTP/SCS policies and the City’s General Plan policies. Hence, like the proposed Specific Plan, the Reduced Specific Plan Area Alternative would result in a less than significant impact related to land use and would be similar to those associated with the proposed Project.

Noise
Construction and operation noise impacts would be slightly reduced under the Reduced Specific Plan Area Alternative because this alternative would decrease the maximum development within the New York Street Transit Village by 25 percent. Construction of this alternative would generate the same type and volume of construction noise as the proposed Specific Plan, and impacts would continue to be potentially located next to sensitive receptors. Therefore, mitigation measures would be required to reduce construction noise and construction noise impacts would be similar to the proposed Project under the Reduced Specific Plan Area Alternative.

Operational noise would be reduced under this alternative as traffic-generated and stationary noise sources would decrease in relation to the reduction in dwelling units, commercial space, and office space in the New York Street Transit Village. Additionally, the Reduced Specific Plan Area Alternative would result in fewer residents in the New York Street Village that could be exposed to noise from surrounding development and roadways. Overall, operational noise impacts from the Reduced Specific Plan Area Alternative would be less than impacts associated with the proposed Project but would likely require the same mitigation.

Redlands Regular Meeting of 10-18-22 1010 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-18
Draft EIR
July 2022
Population and Housing
Under the Reduced Specific Plan Area Alternative, a 25 percent reduction in the number of proposed dwelling units, commercial retail, and office space would be developed in the New York Street Village.

Under this alternative a total of 2,350 dwelling units, 256,250 SF of retail commercial, and 194,250 SF of office uses could be developed under buildout of the TVSP. This would reduce the number of residents at buildout from 6,360 to 6,228 and reduce the number of employment opportunities from 1,226 to 1,122.

The increase in population that would be generated by this alternative would be consistent with SCAG forecasts and would not induce substantial population growth in the Project area. The Reduced Specific Plan Area Alternative and the proposed Specific Plan would result in similar less than significant impacts related to population and housing.

Public Services
The Reduced Specific Plan Area Alternative would result in a slight decrease of development within the TVSP over a slightly reduced area. As such, the Reduced Specific Plan Area Alternative would result in 132 fewer residents and 104 fewer employees at full buildout of the TVSP. Thus, demand for public services, including fire protection, police protection, school services, and library services would be slightly reduced compared to the proposed Project. However, like the proposed TVSP, the Reduced Specific Plan Area Alternative would result in a less than significant impact and would be similar to those associated with the proposed Project.

Recreation
Under the Reduced Specific Plan Area Alternative only 150 dwelling units, 26,250 SF of retail commercial, and 131,250 SF of office uses would be developed in the New York Street Village. The Reduced Specific Plan Area Alternative would result in the same square footage of open space as originally proposed in the TVSP. Since fewer residential dwelling units would be built, impacts on existing recreational facilities would be decreased under the Reduced Specific Plan Area Alternative in comparison to the proposed Project .

Transportation
Under the Reduced Specific Plan Area Alternative, parcels located within TAZ 53827101 and TAZ 53834601 outside of the TPA would be removed from the TVSP area. As discussed in Section 5.14, Transportation, all TAZs within the Specific Plan Area satisfy screening criteria 1 or 2, except for TAZ 53827101. As such, under the Reduced Specific Plan Area Alternative, all of the TAZs within the reduced area would satisfy the City’s screening criteria, as the TAZs would either be within a TPA (Criteria 1) or within a Low VMT area (Criteria 2) and would or would not be able to support dense development (Criteria 4), and VMT impacts from implementation of the Reduced Specific Plan Area Alternative would be less than significant. Because the proposed development in the TAZs would be screened from further VMT analysis and assumed to have less than significant impacts, the mitigation included for the proposed Project would not be required. As such, impacts would be decreased in comparison to the proposed project under the Reduced Specific Plan Area Alternative, and impacts would be less than significant.

Tribal Cultural Resources
Under the Reduced Specific Plan Area Alternative, a slightly reduced level of development would occur within a reduced TVSP area based on market conditions. As such, the Reduced Specific Plan Area Alternative would result in a generally similar potential to adversely affect any tribal cultural resources as the proposed Redlands Regular Meeting of 10-18-22 1011 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-19
Draft EIR
July 2022
Project, as implementing projects of the alternative would occur in the same geographical area to a slightly lesser intensity. However, like the proposed Project, similar mitigation to the Project’s mitigation measures would be required to reduce potential impacts to a less than significant level. Therefore, impacts to tribal cultural resources from the Reduced Specific Plan Area Alternative would be similar to those associated with the proposed Project.

Utilities and Service Systems
Under the Reduced Specific Plan Area Alternative only 150 dwelling units, 26,250 SF of retail commercial, and 131,250 SF of office uses would be developed in the New York Street Village. Thus, the demand for regional water supplies, wastewater treatment, and solid waste generation from dwelling units and commercial/office space would be less than the proposed Specific Plan. Therefore, impacts to utilities and service system would be slightly less under this alternative than the less than significant impacts that would occur from implementation of the proposed Specific Plan.

6.7.2 CONCLUSION
Ability to Reduce Impacts
The Reduced Specific Plan Area Alternative would not eliminate the significant and unavoidable impacts related to air quality that would occur from implementation of the proposed TVSP, as buildout under this alternative would be only slightly reduced in comparison to that allowed under the TVSP. In addition, this alternative would require the same mitigation to ensure less than significant impacts related to historical resources, cultural resources, paleontological resources, and noise. However, this alternative would eliminate the Project’s significant and unavoidable impact related to vehicle miles traveled.

Overall, although the volume of impacts would be less under the Reduced Specific Plan Area Alternative and the significant and unavoidable vehicle miles traveled impact would not occur in comparison to the proposed Specific Plan, the Reduced Specific Plan Area Alternative would not eliminate all of the significant and unavoidable impacts that would result from buildout of the proposed Specific Plan.

Ability to Achieve Project Objectives
Implementation of the Reduced Specific Plan Area Alternative would achieve Objectives 1, 3, 4, 5, and 6, but at a much lesser extent than would be achieved by the proposed Specific Plan, as the alternative would provide for transit-oriented development and a form-code but would provide this to a smaller acreage. The Reduced Specific Plan Area Alternative would not meet Objectives 2 and 7, to apply the General Plan’s goals, policies, and actions to achieve the revitalization of the Plan Area and to create transit oriented development around the three stations, as the portion of the TVSP area that would be excluded from the development area is currently underutilized. Additionally, the 25 percent reduction in development in the New York Street Village, compared to the proposed Specific Plan, would not fully achieve the vision of the Specific Plan pursuant to Objective 1.

6.8 ALTERNATIVE 3: REDUCED INTENSITY ALTERNATIVE
Under this alternative, a 60 percent reduction in the number of dwelling units, retail commercial uses, and office uses would be developed throughout all of the proposed Transit Villages. The proposed TVSP would allow for development of up to 960 dwelling units, 88 hotel rooms, 106,000 SF of retail commercial, and 95,200 SF of office uses through the year 2040. Overall, 60 percent less development would occur within each Transit Village, which would result in 60 percent less overall development than what is proposed under the TVSP. Under this alternative, redevelopment would still be concentrated on vacant and non-conforming parcels within the TVSP area, as shown on Figure 3-17, Vacant and Non-Conforming Parcels. This alternative Redlands Regular Meeting of 10-18-22 1012 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-20
Draft EIR
July 2022
includes all of the circulation and streetscape improvements, open space improvements, and infrastructure improvements that are proposed under the TVSP.

6.8.1 ENVIRONMENTAL IMPACTS
Aesthetics
The Reduced Intensity Alternative would provide for the same type of land uses, and would provide design guidelines, such that the visual character of new development within the planning area would be the same, as what would occur from implementation of the proposed Specific Plan Project. However, because 60 percent fewer dwelling units and hotel rooms, and 60 percent less commercial and office square footage would be developed by this alternative, in comparison to the proposed Specific Plan, the visual density would be less. It is anticipated that building heights would be lower and massing of non-residential structures would be less than the proposed Specific Plan because 60 percent fewer mixed-use buildings would exist upon buildout. In addition, 60 percent fewer residences and less commercial and office square footage would generate sources of new light and glare from this alternative.

However, implementation of the Reduced Intensity Alternative would result in similar less than significant impacts related to aesthetics as the proposed Specific Plan. The Reduced Intensity Alternative would implement the same type of visual improvements that would be introduced throughout the Specific Plan area by the proposed Project (e.g., new and improved landscaping, providing a consistent design theme within the villages, and streetscaping). Thus, improvements to the existing views, character, and quality of the Specific Plan area would also occur under the Reduced Intensity Alternative. Overall, the aesthetic impacts from this alternative would be less than significant, and would be similar to those associated with the proposed Project.

Air Quality
The Reduced Intensity Alternative would develop 60 percent fewer dwelling units and hotel rooms and 60 percent less commercial and office square footage than the proposed Project. Therefore, forty percent of the volume of construction activities and the related emissions from mixed-use development analyzed under the proposed Project would occur. However, the volume of VOC and NOx emissions from construction activities would remain significant and unavoidable. As described in Section 5.2, Air Quality, the construction of the proposed Project could generate up to 590.61 lbs/day of VOC emissions, which is above the threshold of 75 lbs/day; and up to 385.10 lbs/day of NOx emissions, which is above the SCAQMD threshold of 100 lbs/day. Under the Reduced Intensity Alternative, it is possible that a combination of developments could occur, such that daily construction emissions would still exceed this threshold, as a reduction in development by 60 percent would only reduce construction emissions by 60 percent. This 60 percent reduction in emissions would continue to result in VOC emissions and NOx emissions above SCAQMD thresholds. Thus, construction air quality impacts would remain significant and unavoidable.

In addition, the reduced number of dwelling units and commercial square footage that would be developed by this alternative would result in forty percent of the stationary source emissions from residential equipment and less residential traffic associated with air emissions analyzed under the proposed Specific Plan.

Therefore, air quality impacts would be less than the proposed Specific Plan. As described in Section 5.2, Air Quality, operation of the proposed project would generate up to 117.59 lbs/day of VOC emissions, which is substantially above the 55 lb/day SCAQMD threshold; 82.78 lbs/day of NOx emissions, which is above the SCAQMD threshold of 55 lbs/day; and the Project would generate approximately 615.20 lbs/day of CO, which is above the SCAQMD threshold of 550 lbs/day. Under the Reduced Intensity Alternative, the daily VOC, NOx, and CO emissions related to various operations would be sixty percent Redlands Regular Meeting of 10-18-22 1013 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-21
Draft EIR
July 2022
less. As such, emissions of VOC, NOx, and CO would not meet the respective thresholds. Thus, operational air quality emissions would result in less than significant impacts and would eliminate the need for mitigation.

Cultural Resources
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. As such, the Reduced Intensity Alternative would result in a generally similar potential to adversely affect any historic or undiscovered archeological resources as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to a lesser intensity. This alternative would have a similar impact on historic structures within the TVSP area. However, like the proposed Project, similar mitigation to the Project’s mitigation measures and compliance with applicable City of Redlands Municipal Code provisions, including Redlands Historic Architectural Design Guidelines, would be required to reduce potential impacts to a less than significant level. Therefore, impacts to cultural resources from the Reduced Intensity Alternative would be similar to those associated with the proposed Project.

Energy
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. This would result in an approximately 60 percent decrease in the demand for energy in comparison to the proposed Project, which was determined to be less than significant.

Implementing projects under this alternative would be compliant with Title 24 requirements. Therefore, impacts to energy from the Reduced Intensity Alternative would be less than those associated with the proposed Project, and remain less than significant.

Geology and Soils
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. As such, the Reduced Intensity Alternative would generally result in a similar potential to adversely affect any undiscovered paleontological resources as the proposed Project, as implementing projects of the alternative would occur in the same geographical area to a slightly lesser intensity. However, like the proposed Project, similar mitigation to the Project’s mitigation measure would be required to reduce potential impacts to a less than significant level. Therefore, impacts to paleontological resources from the Reduced Intensity Alternative would be similar to those associated with the proposed Project.

Greenhouse Gas Emissions
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. Therefore, a reduced volume of construction activities and related production of GHG emissions would occur. In addition, the reduced amount of development by this alternative would result in less stationary source emissions from residential equipment, and less residential trafficassociated GHG emissions than the proposed Specific Plan. Therefore, the overall volume of GHG emissions would be reduced in comparison to the proposed Specific Plan. Therefore, although less GHG emissions would occur, the Reduced Intensity Alternative would continue to result in less than significant GHG impacts.

Thus, impacts under this alternative would be similar to the proposed Specific Plan.

Redlands Regular Meeting of 10-18-22 1014 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-22
Draft EIR
July 2022
Hazards and Hazardous Materials
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. As such, the Reduced Intensity Alternative would result in redevelopment of vacant and underutilized parcels within the TVSP area, including parcels that are included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 or that need further investigation. If future redevelopment under this alternative 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. Therefore, impacts related to hazards and hazardous materials from the Reduced Intensity Alternative would be similar to those associated with the proposed Project.

Hydrology and Water Quality
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. As such, the Reduced Intensity Alternative would result in a similar potential to adversely affect hydrology and water quality as the proposed Project, as implementing projects of the alternative would occur in the same general geographical area, albeit to a lesser intensity. However, like the proposed Project, implementation of existing regulatory requirements would reduce potential impacts to a less than significant level. Therefore, impacts to hydrology and water quality from the Reduced Intensity Alternative would be similar to those associated with the proposed Project.

Land Use and Planning
Like the proposed Project, the Reduced Intensity Alternative would involve General Plan and Zoning designation changes for the reduced TVSP area and would have the same type of consistency with the SCAG RTP/SCS policies and the City’s General Plan policies. Hence, like the proposed Specific Plan, the Reduced Intensity Alternative would result in a less than significant impact related to land use and would be similar to those associated with the proposed Project.

Noise
Construction and operation noise impacts would be slightly reduced under the Reduced Intensity Alternative because this alternative would decrease the maximum development within each transit village by 60 percent.

Construction of this alternative would generate the same type of construction noise as the proposed Specific Plan to a lesser volume, and impacts would continue to be potentially located next to sensitive receptors.

Therefore, mitigation measures would be required to reduce construction noise and construction noise impacts would be similar to the proposed Project under the Reduced Intensity Alternative.

Operational noise would be reduced under this alternative as traffic-generated and stationary noise sources would decrease in relation to the reduction in dwelling units, commercial space, and office space in each transit village. Additionally, the Reduced Intensity Alternative would result in fewer residents in the Specific Plan Area that could be exposed to noise from surrounding development and roadways. Overall, operational noise impacts from the Reduced Intensity Alternative would be less than impacts associated with the proposed Project but would likely require the same mitigation.

Redlands Regular Meeting of 10-18-22 1015 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-23
Draft EIR
July 2022
Population and Housing
Under the Reduced Intensity Alternative, a 60 percent reduction in the number of proposed dwelling units, commercial retail, and office space would be developed throughout the TVSP. Under this alternative a total of 960 dwelling units, 88 hotel rooms, 106,000 SF of retail commercial, and 95,200 SF of office uses of office uses could be developed under buildout of the TVSP. This would reduce the number of residents at buildout from 6,360 to 2,544 and reduce the number of employment opportunities from 1,226 to 491. The increase in population that would be generated by this alternative would be consistent with SCAG forecasts and would not induce substantial population growth in the Project area. The Reduced Intensity Alternative and the proposed Specific Plan would result in similar impacts related to population and housing, which is considered less than significant.

Public Services
The Reduced Intensity Alternative would result in a 60 percent decrease in development throughout the Specific Plan Area. As such, the Reduced Intensity Alternative would result in 3,816 fewer residents and 735 fewer employees at full buildout of the TVSP. Thus, demand for public services, including fire protection, police protection, school services, and library services would be reduced compared to the proposed Project.

However, like the proposed TVSP, the Reduced Intensity Alternative would result in a less than significant impact..

Recreation
Under this alternative, potential impacts on recreation facilities would be decreased by approximately 60 percent since there would be only 960 dwelling units, 88 hotel rooms, 106,000 SF of retail commercial, and 95,200 SF of office uses. The Reduced Intensity Alternative would result in the same square footage of open space as originally proposed in the TVSP. Since fewer residential dwelling units would be built, impacts on existing recreational facilities would be decreased in comparison to the proposed project under the Reduced Intensity Alternative, but impacts would still remain less than significant.

Tribal Cultural Resources
The Reduced Intensity Alternative would result in a similar potential to adversely affect any tribal cultural resources as the proposed Specific Plan, despite the reduction in development. However, like the proposed Specific Plan, cultural and tribal cultural resource mitigation measures would reduce potential impacts to less than significant. Therefore, impacts that could occur by the Reduced Intensity Alternative would be similar to those associated with the proposed Project.

Transportation
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. As discussed in Section 5.14, Transportation, all TAZs within the Specific Plan Area satisfy the City’s screening criteria, except for TAZ 53827101. In order for projects within TAZ 53827101 to be presumed to have a less than significant VMT impact, developments located within TAZ 53827101 must adhere to the land use types presented in Screening Criteria 3 – Land Use Types or land use quantities presented in Screening Criteria 4 – Land Use Quantities. Development within the portions of TAZ 5384601 that do not screen out of a VMT analysis based on Criteria 1 or 2 would likely screen out of a VMT analysis based on Criteria 3 or 4 due to the single-family nature of development within these parcels.

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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-24
Draft EIR
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However, as 60 percent less development would occur in each transit village, the maximum development allowed in the New York Street Village would be 80 dwelling units, 14,000 SF of commercial retail, and 70,000 SF of office space. Based on the reduced buildout potential of the New York Street Village, there is the potential for an implementing project in TAZ 53827101 to occur that would surpass the land use quantities presented in Screening Criteria 4. As such, VMT impacts under the Reduced Intensity Alternative would still be significant and unavoidable.

Utilities and Service Systems
Under the Reduced Intensity Alternative, 60 percent less development would occur within the same TVSP area based on market conditions. Thus, the demand for regional water supplies, wastewater treatment, and solid waste generation from dwelling units and commercial/office space would be less than the proposed Specific Plan. Therefore, impacts to utilities and service system would be slightly less under this alternative than the less than significant impacts that would occur from implementation of the proposed Specific Plan.

6.8.2 CONCLUSION
Ability to Reduce Impacts
Although the Reduced Intensity Alternative would result in a 60% reduction in development intensity, it would not eliminate the significant and unavoidable impacts related to construction air quality and vehicle miles traveled that would occur from implementation of the proposed TVSP. In addition, this alternative would require the same mitigation to ensure less than significant impacts related to historical resources, cultural resources, paleontological resources, and noise. However, this alternative would eliminate the Project’s significant and unavoidable impact related to operational air quality emissions.

Overall, although the volume of impacts would be reduced by the Reduced Intensity Alternative and the significant and unavoidable operational air quality impact would not occur in comparison to the proposed Specific Plan, the Reduced Intensity Alternative would not eliminate all of the significant and unavoidable impacts that would result from buildout of the proposed Specific Plan.

Ability to Achieve Project Objectives
As shown in Table 6-2, the Reduced Intensity Alternative would meet Project Objectives 1, 4, and 5 as it would implement new street improvements and allow for transit-oriented development. The Reduced Intensity Alternative would partially meet Objectives 3 and 7 as it would limit the potential for sustainable mixeduse development around the Arrow Stations by limiting the potential buildout. This alternative would not meet Objective 6 to provide a variety of housing options to accommodate and attract a range of household types in order to meet the City’s housing needs or revitalize the TVSP area to the same degree. Additionally, the alternative would not meet Objective 2, as only 40 percent of the allowed growth under the TVSP, which was foreseen by the City’s General Plan, would occur.

6.9 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires a lead agency to identify the “environmentally superior alternative” when significant environmental impacts result from a proposed Project. The Environmentally Superior Alternative for the proposed Project would be the Reduced Intensity Alternative. The Reduced Intensity Alternative would avoid the significant impacts related to operational air quality emissions and would avoid mitigation measures associated with operational air quality emissions. Additionally, the Reduced Intensity Alternative would reduce potential construction air quality emissions. However, the Reduced Intensity Alternative would still be required to implement the mitigation measures that are identified in Chapter 5.0 of this EIR that are related to: construction air quality, cultural resources, geology and soils, noise, and tribal cultural resources.

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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-25
Draft EIR
July 2022
Moreover, this alternative would not meet all of the Project objectives, and the objectives it does meet would not be to the same degree as the proposed Project.

CEQA does not require the Lead Agency (the City of Redlands) to choose the environmentally superior alternative. Instead, CEQA requires the City to consider environmentally superior alternatives, weigh those considerations against the environmental impacts of the proposed Project, and make findings that the benefits of those considerations outweigh the harm. Table 6-1 provides, in summary format, a comparison between the level of impacts for each alternative and the proposed Project. In addition, Table 6-2 provides a comparison of the ability of each of the alternatives to meet the objectives of the proposed Project.

Table 6-1: Impact Comparison of the Proposed Project and Alternatives Proposed Project
Alternative 1: No
Project/Buildout of
Existing Land Use
and Zoning
Alternative 2:

Reduced Specific
Plan Area
Alternative 3:

Reduced Intensity
Alternative
Aesthetics Less than significant
with mitigation
Same as proposed
Project, less than
significant with
mitigation
Same as proposed
Project, less than
significant with
mitigation
Same as proposed
Project, less than
significant with
mitigation
Air Quality Significant and
Unavoidable
Same as proposed
Project, significant
and unavoidable
Same as proposed
Project, significant
and unavoidable
Less than the
proposed Project,
significant and
unavoidable for
construction; less
than significant for
operations
Cultural Resources Less than significant
with mitigation
Same as proposed
Project, less than
significant with
mitigation
Same as proposed
Project, less than
significant with
mitigation
Same as proposed
Project, less than
significant with
mitigation
Energy Less than significant Same as proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Geology and Soils Less than significant
with mitigation
Same as proposed
Project, less than
significant with
mitigation
Same as proposed
Project, less than
significant with
mitigation
Same as proposed
Project, less than
significant with
mitigation
Greenhouse Gas
Emissions
Less than significant Same as proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Hazards and
Hazardous
Materials
Less than significant Same as proposed
Project, less than
significant
Same as proposed
Project; less than
significant
Same as proposed
Project; less than
significant
Hydrology and
Water Quality
Less than significant Same as proposed
Project, less than
significant
Same as proposed
Project, less than
significant
Same as proposed
Project, less than
significant
Land Use and
Planning
Less than significant Same as proposed
Project, less than
significant
Same as proposed
Project; less than
significant
Same as proposed
Project; less than
significant
Noise Less than significant Same as proposed
Project, less than
significant with
mitigation
Less than proposed
Project, less than
significant with
mitigation
Less than proposed
Project, less than
significant with
mitigation
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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-26
Draft EIR
July 2022
Proposed Project
Alternative 1: No
Project/Buildout of
Existing Land Use
and Zoning
Alternative 2:

Reduced Specific
Plan Area
Alternative 3:

Reduced Intensity
Alternative
Population and
Housing
Less than significant Same as proposed
Project, less than
significant
Same as proposed
Project, less than
significant
Same as proposed
Project, less than
significant
Public Services Less than significant Same as proposed
Project, less than
significant
Same as proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Recreation Less than significant Same as proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Transportation Significant and
Unavoidable
Greater than
proposed Project,
significant and
unavoidable
Less than the
proposed Project,
less than significant
Same as proposed
Project, significant
and unavoidable
Tribal Cultural
Resources
Less than significant
with mitigation
Same as proposed
Project, less than
significant with
mitigation
Same as proposed
Project; less than
significant with
mitigation
Same as proposed
Project; less than
significant with
mitigation
Utilities and Service
Systems
Less than significant Same as proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Less than proposed
Project, less than
significant
Reduce Impacts of the Project? No Yes Yes
Areas of Reduced Impacts Compared to
the Project 0 6 7
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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-27
Draft EIR
July 2022
Table 6-2: Comparison of the Proposed Project and Alternatives Ability to Meet Objectives Proposed Project
Alternative 1: No
Project/Buildout of
Existing Land Use
and Zoning
Alternative 2:

Reduced Specific
Plan Area
Alternative 3:

Reduced Intensity
Alternative

1. A vision for the
future of the three
station areas that
recognizes the
importance of
Redlands’ unique
history and tradition
while embracing
opportunities for
continued
reinvestment,
growth, and
beneficial change.

Yes No Partially Yes

2. Application of the
General Plan’s
goals, policies, and
actions to achieve
the revitalization of
the Plan Area.

Yes Partially No No

3. New form-based
zoning standards for
the Plan Area that
will replace current
zoning regulations.

These new standards
are calibrated to
deliver new
development that is
consistent with
Redlands’ physical
character, history,
and culture, as well
as the community’s
vision for its future
growth.

Yes No Partially Partially

4. An implementation
strategy for
transforming the
Plan Area’s streets,
infrastructure, parks,
and other public
spaces in line with
the City of Redland’s
unique culture and
history.

Yes No Partially Yes

5. Transform streets
and create
neighborhood
connectivity through
pedestrian-oriented
improvements.

Yes No Partially Yes
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Redlands General Plan Transit Villages District and Specific Plan Project 6. Alternatives City of Redlands, CA 6-28
Draft EIR
July 2022
Proposed Project
Alternative 1: No
Project/Buildout of
Existing Land Use
and Zoning
Alternative 2:

Reduced Specific
Plan Area
Alternative 3:

Reduced Intensity
Alternative

6. Provide a variety
of housing options to
accommodate and
attract a range of
household types in
order to meet the
City’s housing needs.

Yes No Partially No

7. Provide for
transit-oriented
development around
the three new Arrow
Line stations in line
with the City’s
General Plan.

Yes No No Partially
Redlands Regular Meeting of 10-18-22 1021 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 7.0 Preparers and Persons Contacted City of Redlands, CA 7-1
Draft EIR
July 2022

7.0 EIR Preparers and Persons Contacted

7.1 EIR Preparers
City of Redlands
Brian Foote, AICP, Planning Manager
E|P|D Solutions, Inc.

Jeremy Krout, AICP
Konnie Dobreva, JD
Meghan Macias, TE
Renee Escario
Alex Garber
Brooke Blandino
Danielle Thayer
Meaghan Truman
Fuscoe Engineering, Water Supply Assessment
Ian Adam, QSD/QSP
Stephanie Castle Zinn, CPMSM
Material Culture Consulting, Cultural and Paleontological Resource Assessment Tria Belcourt, MA
Lily Arias
Jennifer Kelly
Urban Crossroads, Air Quality, Energy, and Greenhouse Gas Analyses and Noise Impact Analysis Haseeb Qureshi
Alyssa Barnett
Bill Lawson

7.2 Persons Contacted
City of Redlands Fire Department
City of Redlands Police Department
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Redlands General Plan Transit Villages District and Specific Plan Project 7.0 Preparers and Persons Contacted City of Redlands, CA 7-2
Draft EIR
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Redlands Regular Meeting of 10-18-22 1023 of 1815
September 2022
Final Environmental
Impact Report

REDLANDS GENERAL PLAN TRANSIT VILLAGES

DISTRICT AND SPECIFIC PLAN PROJECT
SCH NO. 2021080622
prepared for
City of Redlands
35 Cajon Street
Redlands, CA 92373
prepared with the assistance of
EPD, Solutions Inc.

Irvine, CA 92614
(949) 794-1180
www.epdsolutions.com
Redlands Regular Meeting of 10-18-22 1024 of 1815
2355 Main Street, Suite 100
Irvine, CA 92614
(949) 794-1180
www.epdsolutions.com
Redlands Regular Meeting of 10-18-22 1025 of 1815
FINAL

ENVIRONMENTAL IMPACT REPORT

REDLANDS GENERAL PLAN TRANSIT VILLAGES

DISTRICT AND SPECIFIC PLAN PROJECT

CITY OF REDLANDS, CALIFORNIA
STATE CLEARINGHOUSE NO. 2021080622
PREPARED FOR:

CITY OF REDLANDS
35 CAJON STREET
REDLANDS, CA 92373
CONTACT: BRIAN FOOTE, AICP, PLANNING MANAGER
PREPARED BY:

EPD SOLUTIONS
2355 MAIN STREET, SUITE 100
IRVINE, CA 92614
CONTACT: KONNIE DOBREVA, JD, V.P. of Environmental Planning SEPTEMBER 2022
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Redlands General Plan Transit Villages District and Specific Plan Project Table of Contents City of Redlands i
Final EIR
September 2022

TABLE OF CONTENTS
Section Page

1.0 INTRODUCTION............................................................................................................................................ 1-1 SECTION 1.1, FORMAT OF THE FINAL EIR............................................................................................................................................ 1-1 SECTION 1.2, CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES .............................................................................. 1-2

2.0 RESPONSE TO COMMENTS........................................................................................................................... 2-1

3.0 REVISIONS TO THE DRAFT EIR ..................................................................................................................... 3-1

4.0 MITIGATION AND MONITORING PROGRAM............................................................................................... 4-1 SECTION 4.1, INTRODUCTION ............................................................................................................................................................. 4-1 SECTION 4.2, MITIGATION MONITORING AND REPORTING PROGRAM ............................................................................................. 4-1 Redlands Regular Meeting of 10-18-22 1027 of 1815
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ACRONYMS AND ABBREVIATIONS

°C degrees celsius
µg/m3 micrograms per cubic meter
AB 52 California Assembly Bill 52
ACM asbestos-containing material
AF acre-feet
ALUC Airport Land Use Commission
ALUCP Airport Land Use Compatibility Plan
amsl above mean sea level
AQIA Air Quality Impact Analyses
AQMP Air Quality Management Plan
APN Assessor’s Parcel Number
ATCM airborne toxic control measure
BAAQMD Bay Area Air Quality Management District
BACM best available control measure
BACT best available control technology
Basin South Coast Air Quality Basin
BAU business as usual
BFE base flood elevation
bgs below ground surface
BMPs Best Management Practices
CAA Clean Air Act of 1970
CAAA CAA Amendments of 1990
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards Code
CAP Climate Action Plan of 2013
CARB California Air Resources Board
CBC California Building Code
CCAA California Clean Air Act of 1988
CDA Chino Desalter Authority
CDFW California Department of Fish and Wildlife
CC&Rs Covenants, Conditions, and Restrictions
CEC California Energy Commission
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CGEU California Gas and Electric Utilities 2016 California Gas Report CGS California Geological Survey
CH4 methane
CHAPIS Community Health Air Pollution Information System (CARB) CHRIS California Historical Resources Inventory System
CNDDB California Natural Diversity Database
CNEL community noise equivalent level
CNPS California Native Plant Society
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CRHR California Register of Historical Resources
CTP Clean Truck Program
CUP Conditional Use Permit
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September 2022
dB decibel
dBA A-weighted decibels
DPM diesel particulate matter
DTSC Department of Toxic Substances Control
EIR Environmental Impact Report
EMS Emergency Medical Services
ESA Environmental Site Assessment
FAR floor area ratio
FEMA Federal Emergency Management Agency
FESA Federal Endangered Species Act of 1973
FMMP Farmland Mapping and Monitoring Program
gal/day gallons per day
GHG greenhouse gas
GWP global warming potential
Handbook Air Quality and Land Use Handbook: A Community Health Perspective (CARB 2005)
HAPs hazardous air pollutants
HCM Highway Capacity Manual
HCP Habitat Conservation Plan
HDT Heavy Duty Trucks
HFCs hydroflourocarbons
Hot Spots Act Air Toxics Hot Spots Information and Assessment Act of 1987 HP horsepower
HPLV High Pressure Low Volume
HVAC heating, ventilating, and air conditioning
ICU intersection capacity utilization
I Interstate
IEUA Inland Empire Utilities Agency
LBP lead-based paint
LCFS Low Carbon Fuel Standard
LEED Leadership in Energy and Environmental Design
LEV Low Emission Vehicle
LID low impact development
LOS level of service
LSTs localized significance thresholds
MACT maximum available control technology
MBTA Migratory Bird Treaty Act of 1918
MCC Material Culture Consulting
mgd million gallons per day
MMRP Mitigation Monitoring and Reporting Program
MMT million metric tons
MPO metropolitan planning organization
MT metric tons
MT CO2e metric tons of carbon dioxide equivalent
NAAQS National Ambient Air Quality Standards
N2O nitrous oxide
NAHC Native American Heritage Commission
NALs numeric action levels
NCCP Natural Community Conservation Plan
NESHAP national emissions standards for HAPs
NH3 ammonia
NHPA National Historic Preservation Act of 1966
NHTSA National Highway Traffic and Safety Administration Redlands Regular Meeting of 10-18-22 1029 of 1815
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September 2022
NOP Notice of Preparation
NO2 nitrogen oxide
NOx nitrogen oxide
NOI Notice of Intent
NPDES National Pollutant Discharge Elimination System
NRCS U.A. Department of Agriculture Natural Resources Conservation Service O3 ozone
Pb lead
PDF project design feature
PFCs perflourocarbons
PM2.5 particulate matter less than 2.5 micrometers in aerodynamic diameter PM10 particulate matter less than 10 micrometers in aerodynamic diameter ppb parts per billion
PPP Plans, Programs, and Policies
PRC Public Resources Code
PRIMP Paleontological Resources Impact Mitigation Plan
PWS public water supplier
REC recognized environmental conditions
ROG reactive organic gas
RP-5 IEUA Regional Water Recycling Plant No. 5
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SB Senate Bill
SB 18 California Senate Bill 18, Ch. 905 (2004)
SC Standard Condition
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCCIC South Central Coastal Information Center
SCE Southern California Edison Company
SCS Sustainable Communities Strategy
SF square feet
SF6 sulfur hexaflouride
SIP state implementation plan
SO2 sulfur dioxide
SO3 sulfur trioxide
SO4 sulfates
SoCalGas Southern California Gas Company
SOx sulfur oxides
SP Specific Plan
SR State Route
SRA Source Receptor Area
SWPPP Storm Water Pollution Prevention Plan
SWQMP Storm Water Quality Management Plan
SWRCB Storm Water Resources Control Board
TACs toxic air contaminants
TIA Traffic Impact Analysis
tpy tons per year
TTCP traditional tribal cultural places
TUA traditional use area
USDA United States Department of Agriculture
USEPA United States Environmental Protection Agency
USFWS United States Fish and Wildlife Service
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September 2022
UTRs utility tractors
UWMP Urban Water Management Plan
VdB velocity levels expressed in decibel notation
VMT vehicle miles travelled
VOC volatile organic compounds
WDR Waste Discharge Requirements
WFA Water Facilities Authority
Williamson Act California Land Conservation Act of 1965 WQC Water Quality Certification
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Redlands General Plan Transit Villages District and Specific Plan Project 1. Introduction City of Redlands 1-1
Final EIR
September 2022

1. Introduction
This Final Environmental Impact Report (FEIR; Final EIR) has been prepared in conformance with the State guidelines for the implementation of the California Environmental Quality Act (CEQA) to evaluate the environmental effects that may result from construction and operation of the proposed Redlands General Plan Transit Villages District and Specific Plan Project (proposed Project).

According to CEQA Guidelines Section 15132, the FEIR shall consist of:
(a) The Draft Environmental Impact Report (DEIR; Draft EIR) or a revision of the Draft EIR; (b) Comments and recommendations received on the Draft EIR, either verbatim or in summary; (c) A list of persons, organizations, and public agencies commenting on the Draft EIR; (d) The responses of the lead agency to significant environmental points raised in the review and consultation process;
(e) Any other information added by the lead agency.

This document contains responses to comments received on the Draft EIR during the public review period, which began July 21, 2022 and ended on September 6, 2022. This document also includes revisions to the Draft EIR, which are reflected in the Errata in Chapter 3. This document has been prepared in accordance with CEQA, the State CEQA Guidelines, the City’s Local CEQA Guidelines, and represents the independent judgment of the lead agency, the City of Redlands. This document and the circulated Draft EIR comprise the Final EIR in accordance with CEQA Guidelines, Section 15132.

1.1 Format of the Final EIR
The following chapters are contained within this document:

Chapter 1, Introduction. This chapter describes CEQA requirements and the content of the Final EIR.

Chapter 2, Response to Comments. This chapter provides a list of agencies, organizations, and individuals who commented on the Draft EIR, as well as copies of their comment letters received during and following the public review period, and individual responses to their comments.

Chapter 3, Revisions to the Draft EIR. This chapter contains revisions made to the Draft EIR as a result of the comments received by agencies and organizations as described in Chapter 3, and/or errors and omissions discovered subsequent to release of the Draft EIR for public review.

The City of Redlands has determined that none of this material constitutes significant new information that requires recirculation of the Draft EIR for further public comment under CEQA Guidelines Section 15088.5.

The additional material clarifies existing information prepared in the Draft EIR and does not present any new substantive information. None of this new material indicates that the project would result in a significant new environmental impact not previously disclosed in the Draft EIR. Additionally, none of this material indicates that there would be a substantial increase in the severity of a previously identified environmental impact that would not be mitigated, or that there would be any of the other circumstances requiring recirculation described in Section 15088.5.

Chapter 4, Mitigation, Monitoring, and Reporting Program. This chapter includes the Mitigation Monitoring and Reporting Program (MMRP). CEQA requires lead agencies to “adopt a reporting and mitigation monitoring program for the changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment” (CEQA Section 21081.6, CEQA Redlands Regular Meeting of 10-18-22 1032 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 1. Introduction City of Redlands 1-2
Final EIR
September 2022
Guidelines Section 15097). The MMRP was prepared based on the mitigation measures included in this Final EIR and has been included as Chapter 4.0.

1.2 CEQA Requirements Regarding Comments and Responses
CEQA Guidelines Section 15204(a) outlines parameters for submitting comments and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be “on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible … CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.” CEQA Guidelines Section 15204(c) further advises, “Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence.” Section 15204 (d) also states, “Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility.” Section 15204 (e) states, “This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.”
In accordance with CEQA, Public Resources Code (PRC) Section 21092.5, copies of the written responses to public agencies are being forwarded to those agencies at least 10 days prior to certification of the Final EIR, with copies of this Final EIR document, which conforms to the legal standards established for response to comments on the Draft EIR pursuant to CEQA.

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September 2022
Chapter 2. Response toComments
Section 15088 of the CEQA Guidelines requires the Lead Agency, the City of Redlands, to evaluate comments on environmental issues received from public agencies, organizations, companies, and individuals who reviewed the Draft EIR (DEIR) and prepare written responses. This section includes copies of all written comment letters received on the DEIR and the City of Redlands’s responses to the comment letters.

Comment letters and specific comments are numbered for reference purposes which correspond with the City’s response. A summary of each numbered comment in the commenter’s letter precedes the City’s response.

MASTER RESPONSES
Master Response 1: Project Merits
Some comments to the Draft EIR expressed concerns related to the economic and social effects of the proposed Project. CEQA is an environmental protection statute that is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (CEQA Guidelines Section 15360). Any economic and social effects of the proposed project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Therefore, consistent with CEQA, the Draft EIR includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include a discussion of the Project’s economic or social effects. Further, it is not the purpose of a CEQA document to advocate for or against any specific project. Instead, environmental impact reports are objective and technical documents, completed for the purpose of identifying and disclosing environmental impacts, to inform both the public and the City’s decision makers. It is then up to the City’s decision makers to weigh the environmental impacts identified in the environmental impact report, against the Project merits (which includes its economic and social effects), in deciding whether to approve or disapprove a proposed Project.

CEQA Guidelines Section 15204(a) states that when responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, and provides the following direction related to EIR comments and responses:

In reviewing draft EIRs, persons and public agencies should focus on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible, in light of factors such as the magnitude of the project at issue, the severity of its likely environmental impacts, and the geographic scope of the project. CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commentors.

Thus, this Final EIR does not provide direct responses to comments that do not raise a significant environmental question (Citizens for E. Shore Parks v. State Lands Commission (2011) 202 Cal.App.4th 549). Because comments regarding Project merits do not pertain to the potential for significant physical impacts, or the objective analysis of the same, such comments are not responded to in this Final EIR.

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September 2022
Even though the EIR does not consider and weigh the Project’s economic and social effects, economic and social effects are important and the decision makers in the City of Redlands will consider all comments regarding the Project merits in determining what action to take on the proposed Project. The Planning Commission and City Council will hold publicly‐noticed hearings to consider action on the Project, which will include consideration of the Project merits (including economic and social effects).

PUBLIC COMMENTS
The following is a list of public agencies, organizations, and individuals or interested parties that submitted comments on the DEIR during the public review period. The comment letters received on the DEIR and responses to those comments are provided on the following pages.

Letter Number Agency/Organization/Name Comment Date Received Agencies
A1 San Bernardino County Department of Public Works August 31, 2022 A2 South Coast Air Quality Management District September 6, 2022 Organizations
O1 Redlands Area Historical Society September 4, 2022
O2 Redlands Conservancy September 6, 2022
Individuals
I1 Anne Hernandez July 26, 2022
I2 Ron Running July 27, 2022
I3 Patricia Jolliff July 30, 2022
I4 T. Jolliff July 30, 2022
I5 Marie DeLange July 30, 2022
I6 Larry Leonard July 31, 2022
I7 Richard O’Donnell August 21, 2022
I8 Joanne Lessard September 3, 2022
I9 Renae Reiswig September 6, 2022
I10 Julia Lenhardt September 6, 2022
I11 Steve Rogers September 6, 2022
I12 Chris E. Sedmack September 6, 2022
I13 Norm and Laurie Cosme September 6, 2022
I14 Ruth Cook September 6, 2022
The following is a list of public agencies, organizations, and individuals or interested parties that submitted comments on the DEIR after the public review period. The comment letters received on the DEIR and responses to those comments are provided on the following pages.

Letter Number Agency/Organization/Name Comment Date Received Organizations
O3 Mitchell M. Tsai, on behalf of Southwest Regional Council of Carpenters
After 5:30 pm
September 6, 2022
Individuals
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I15 Hazel Fuller After 5:30 pm
September 6, 2022
I16 Lisa Pierce After 5:30 pm
September 6, 2022
I17 Bettina McLeod September 7, 2022
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September 2022

COMMENTS RECEIVED DURING PUBLIC REVIEW
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LETTER A1: San Bernardino County Department of Public Works (2 pages) Redlands Regular Meeting of 10-18-22 1039 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-7
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Response to Letter A1: San Bernardino County Department of Public Works, received August 31, 2022 Comment A1.1: This comment provides an introduction to the comment letter and thanks the City for allowing the San Bernardino County Department of Public Works the opportunity to comment on the proposed Project.

Response A1.1: The comment is introductory in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment A1.2: This comment states that the Project is within Comprehensive Storm Drain Plan No. 4 from February 2013 and the City of Redlands Master Plan of Drainage (MPD) from May 2014.

Response A1.2: The commenter is referred to Section 5.8, Hydrology and Water Quality, and Section

5.16, Utilities and Service Systems, for a discussion of storm drain plans in the Project area. This comment is informational in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment A1.3: This comment states that there may be storm drains in and around the TVSP area that may be affected by the Project and that when planning for and altering existing or future storm drains, the Project is subject to the City of Redlands MPD. The comment states that future revisions to drainage should be reviewed and approved by the City of Redlands and that if construction of new, or alterations to existing storm drains, is necessary, impacts and any necessary mitigation should be discussed in the Draft EIR.

Response A1.3: As discussed on page 5.16-14 of the Draft EIR, the TVSP Infrastructure Plan includes improvements to divert flows away from undersized segments of the existing drainage system, such as the undersized Zanja channel through the University Transit Village, and the undersized Mission Creek channel through the New York Street/Esri Transit Village, among other flood-related strategies, in line with the strategies set forth by the 2014 Redlands Master Plan of Drainage. Stormwater drainage improvements would be evaluated on a project-by-project basis as development occurs pursuant to the TVSP and the 2014 Master Plan of Drainage. Implementation of development projects pursuant to the TVSP would increase the intensity of land uses within the TVSP area, and future site-specific development projects would install onsite stormwater drainage infrastructure and new connections to the existing stormwater drainage system. Such improvements would be required to be sized to accommodate the stormwater generation of such new development.

Additional, large-scale stormwater drainage improvements pursuant to the 2014 Redlands Master Plan of Drainage and implementing project site-specific stormwater drainage improvements would be required to comply with all Redlands Municipal Code standards and Draft EIR Mitigation Measures AQ-1 through AQ10, CUL-1 through CUL-9, GEO-1, NOI-1 through NOI-4, NOI-8 through NOI-9, and TCR-1 through TCR-4.

Therefore, impacts related to stormwater drainage infrastructure were determined to be less than significant with mitigation.

Comment A1.4: This comment states that the Project partially lies within flood hazard zones, which should be discussed and mitigated, if necessary, in the Draft EIR.

Response A1.4: As discussed on page 5.8-8 of the Draft EIR, 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 Redlands Regular Meeting of 10-18-22 1041 of 1815
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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.

As discussed in Section 5.8, future developments within the TVSP area would be subject to the Redlands Floodplain Regulations, which requires any new occupiable finished floor to be at least two feet above the one percent (100-year) base flood elevation. With compliance with existing requirements and implementation of the stormwater infrastructure included in the Redlands MPD, impacts were determined to be less than significant.

Comment A1.5: This comment states that the benefit of the CSDP/MPD is to identify the alignment of future drainage and flood control facilities and that the County hopes that the City will continue to use this document.

Response A1.5: As discussed within the Draft EIR, the City will continue to utilize the Redlands MPD to evaluate the need for improvements to and the location of stormwater drainage infrastructure within the City and the TVSP area. This comment does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment A1.6: This comment states that the County recommends that the City enforces its most recent FEMA regulations for development within a Special Flood Hazard Area.

Response A1.6: As discussed throughout Section 5.8 of the Draft EIR, the City has continued to and will continue to enforce the City’s Floodplain Regulations, which require any new occupiable finished floor to be at least two feet above the one percent (100-year) base flood elevation. This comment does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment A1.7: This comment states that San Bernardino County Flood Control District right-of-way and facilities are located within the TVSP area and any encroachments on the District’s right-of-way or facilities that is not authorized under Permit P-22017018 to SBCTA for rail line construction will require a permit from the San Bernardino County Flood Control District. The comment states that the necessity for permits should be addressed within the Draft EIR.

Response A1.7: As discussed in Section 3.0, Project Description, of the Draft EIR, no specific developments or improvements are proposed under the Project. The Draft EIR provides program-level information related to development and operation of the TVSP. Improvements proposed within the Transit Villages Specific Plan are conceptual plans that may or may not be implemented during the timeframe of the specific plan, depending on the timing of future developments, availability of public grant funding or other public funds, and other factors. Nevertheless, should future developments or improvements within the City require encroachment into San Bernardino County Flood Control District right-of-way or facilities, the City or developer shall request permits, if needed, at the time of the future development or improvement.

Comment A1.8: This comment requests that the San Bernardino County Department of Public Works be included on the circulation list for all public notices, public review, or public hearings.

Response A1.8: The City will add the San Bernardino County Department of Public Works to the notification list for future updates regarding the Redlands General Plan Transit Villages District and Specific Plan Project. No further response is required.

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Response to Letter A2: South Coast Air Quality Management District, Received September 6, 2022 Comment A2.1: The comment states that the South Coast Air Quality Management District (SCAQMD) appreciates the opportunity to comment on the EIR, and that the following comments include recommended mitigation measures and health risk reduction strategies. The comment also provides a summary of the Project Description.

Response A2.1: The comment is introductory in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment A2.2: This comment states that CEQA requires all feasible mitigation measures be implemented.

The comment states that the Project serves as a programmatic level analysis that can provide guidance to subsequent, project-level analysis and that the SCAQMD therefore recommends multiple project-level mitigation measures be included in the Final EIR to ensure that future development projects that generate heavy-duty diesel fueled truck trips reduce mobile emissions.

Response A2.2: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips. However, Mitigation Measure AQ-10 requires that 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. In addition, future projects under the TVSP would be required to implement Mitigation Measure AQ-9, which requires submittal of 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. If the modeling shows that emissions would exceed the 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. Therefore, the Draft EIR includes measures to limit potential impacts from emissions, including those of toxic air contaminants, from construction and operation to sensitive receivers. The comment is introductory in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment A2.3: This comment states that the City of Redlands should require the use of zero emission or near zero emission heavy-duty trucks, or at a minimum 2010 model year on-road trucks during operation to all trucks accessing the proposed Project, by future development projects during operation as a mitigation measure since the zero emission and near zero emission trucks are becoming more available.

The comment states that the City should require future development projects to include an evaluation of sufficient electricity and supportive infrastructures for these trucks and the City should conduct regular inspections at future development projects to ensure that trucks are being documented.

Response A2.3: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips. However, as discussed in Response A2.2, Mitigation Measures AQ-9 and AQ-10 are included to require further project-specific analysis for future development to reduce impacts from heavy-duty diesel fueled truck trips in the TVSP area. Currently, the use of zero-emissions light- and medium-duty trucks is limited and an infrastructure network to support their use is limited throughout southern California. Thus, commercial use and availability Redlands Regular Meeting of 10-18-22 1047 of 1815
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throughout the State is currently limited. However, CARB passed its updated Advanced Clean Truck Rule on July 1, 2020 that requires medium-and heavy-duty truck manufacturers to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero-emission truck/chassis sales are required to be 55% of Class 2b – 3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales1. The rule begins in 2024, at which point an infrastructure network to support zero-emission trucks throughout southern California is anticipated to begin to become available.

CARB estimates that by 2030, nearly one in three new trucks will be zero-emissions2.

The City, as Lead Agency, determines what measures are feasible, economically, and technologically, and required for future development projects as part of the City’s permitting process. Consistent with the comment and CARB regulations, on-road diesel vehicles with a Gross Vehicle Weight Rating (GVWR) that is 14,001+ lbs. must reduce exhaust emissions by meeting particulate matter (PM) filter requirements and upgrading to newer engines. Vehicles with 2010 engine model year or newer are fully compliant.

However, at this time requiring all trucks accessing future developments to be zero emission or near zero emission vehicles is currently infeasible economically and technologically due to limited commercial availability and lack of necessary charging infrastructure.

Comment A2.4: This comment states that the City should limit the daily number of trucks that would access future development projects to the levels analyzed in the subsequent, project-level environmental analyses and if higher daily truck volumes are necessary, additional CEQA analysis should be conducted.

Response A2.4: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips. Therefore, there would be no nexus requiring mitigation to limit heavy-duty truck trips pursuant to CEQA Guidelines Section 15126.4, subd. (a)(4)(A)-(B). However, as discussed in Response A2.2, Mitigation Measures AQ-9 and AQ-10 are included to require further project-specific analysis for future development to reduce impacts from heavyduty diesel fueled truck trips in the TVSP area.

Comment A2.5: This comment states that the Final EIR should include mitigation requiring future development projects to provide electrical infrastructure and electrical panels for truckers to plug in any onboard auxiliary equipment.

Response A2.5: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips. However, Mitigation Measure AQ-7 requires that 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. Mitigation Measure AQ-7 lists installation of electrical hook-ups at loading dock areas as a possible measure to increase energy efficiency.

Comment A2.6: The comment states that operational project-level mitigation measures should include maximizing the use of solar arrays by installing solar panels.

Response A2.6: Mitigation Measure AQ-7 requires that 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. Mitigation Measure AQ-7 lists the design of buildings to accommodate photo-voltaic solar 1 https://ww2.arb.ca.gov/resources/fact-sheets/advanced-clean-trucks-fact-sheet 2 https://ww2.arb.ca.gov/rulemaking/2019/advancedcleantrucks Redlands Regular Meeting of 10-18-22 1048 of 1815
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electricity systems or the installation of photo-voltaic solar electricity systems as a possible measure to increase energy efficiency.

Comment A2.7: The comment states that operational project-level mitigation measures should include using light colored paving and roofing materials.

Response A2.7: Mitigation Measure AQ-7 requires that 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. Mitigation Measure AQ-7 lists the 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 as a possible measure to increase energy efficiency.

Comment A2.8: The comment states that operational project-level mitigation measures should include using only Energy Star Appliances.

Response A2.8: Mitigation Measure AQ-7 requires that 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. Mitigation Measure AQ-7 lists the Installation of ENERGY STAR-qualified energy-efficient appliances, heating and cooling systems, office equipment, and/or lighting products as a possible measure to increase energy efficiency.

Comment A2.9: This comment states that design considerations that the City should consider for future development projects include clearly marking truck routes so that trucks will not travel near sensitive uses.

Response A2.9: Currently, the truck routes within the City of Redlands are signed and limit truck travel near sensitive uses. Additionally, future trucks accessing the TVSP would be required to utilize existing truck routes.

Comment A2.10: This comment states that design considerations that the City should consider for future development projects include designing truck entrances and exits so that they are not facing sensitive receptors.

Response A2.10: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips where truck entrances and exits would have to be designed to be oriented away from sensitive receptors. However, for future industrial or manufacturing projects within the city, the City will continue to include siting of truck entrances as a design consideration. In addition, as discussed in Response A2.2, Mitigation Measures AQ-9 and AQ-10 are included to require further project-specific analysis for future development to reduce impacts from heavy-duty diesel fueled truck trips in the TVSP area.

Comment A2.11: This comment states that design considerations that the City should consider for future development projects include having truck check in points inside the project site to avoid queuing on offsite streets.

Response A2.11: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips where truck check in points would need to be inside the project site. However, for future industrial or manufacturing projects within the city, the City will continue to include siting of truck check in points and queuing as a design consideration. In addition, as discussed in Response A2.2, Mitigation Measures AQ-9 and AQ-10 Redlands Regular Meeting of 10-18-22 1049 of 1815
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are included to require further project-specific analysis for future development to reduce impacts from heavy-duty diesel fueled truck trips in the TVSP area.

Comment A2.12: This comment states that design considerations that the City should consider for future development projects include designing future projects so that truck traffic inside the project site is as far away as possible from sensitive receptors.

Response A2.12: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips where internal truck circulation would need to be oriented away from sensitive receptors. However, for future industrial or manufacturing projects within the city, the City will continue to include internal truck circulation as a design consideration. In addition, as discussed in Response A2.2, Mitigation Measures AQ-9 and AQ10 are included to require further project-specific analysis for future development to reduce impacts from heavy-duty diesel fueled truck trips in the TVSP area.

Comment A2.13: This comment states that design considerations that the City should consider for future development projects include designing future projects so overnight truck parking would be allowed inside the project site.

Response A2.13: As discussed in Draft EIR Section 3.0, allowed development under the TVSP would include commercial, office, hotel, and residential uses. The Project would not include industrial or manufacturing uses that would result in a high number of heavy-duty diesel fueled truck trips where overnight truck parking would be required. However, for future industrial or manufacturing projects within the city, the City will continue to include overnight truck parking as a design consideration. In addition, as discussed in Response A2.2, Mitigation Measures AQ-9 and AQ-10 are included to require further projectspecific analysis for future development to reduce impacts from heavy-duty diesel fueled truck trips in the TVSP area.

Comment A2.14: This comment states that the City should consider impacts of air pollutants on people who live in a new project and provide mitigation where necessary. The comment states that implementation of the Project could result in new development of sensitive uses within 1,000 feet of train stations, the I-10, and warehouses and SCAQMD recommends that, in order to facilitate implementation of Mitigation Measure AQ-10, the City should include discussion of a mobile HRA analysis in the Final EIR. This comment also states that strategies to reduce exposures to toxic air contaminants include building filtration systems with MERV 13 or higher filters; building orientation and location; vegetation barriers or landscaping screening, among others. The comment states that there are multiple issues with filtration systems such as burden of cost, waste, and effectiveness.

Response A2.14: As discussed on page 5.2-23 of the Draft EIR, it is currently unknown what future development projects including a sensitive receptor would be proposed next to an existing toxic air contaminant source such as warehouses, industrial areas, freeways, roadways, and rail lines with traffic volumes over 10,000 vehicle per day. Therefore, as discussed in Draft EIR Section 5.2, Mitigation Measure AQ-10, if an HRA conducted for a future development 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 non-cancer risks to an acceptable level (i.e., below ten in one million or a hazard index of 1.0), including appropriate enforcement mechanisms. Future project-specific HRAs would be conducted pursuant to SCAQMD guidance using the latest version of EMFAC, as required by the City’s Local CEQA Redlands Regular Meeting of 10-18-22 1050 of 1815
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Guidelines.3 As such, future developments pursuant to the TVSP that are located near a source of toxic air contaminants would be required to conduct project-level HRAs to demonstrate that they do not result in a substantial health risk for project occupants.

Comment A2.15: The comment requests that the Lead Agency provide SCAQMD staff with written responses to all comments contained herein prior to the certification of the Final EIR. In addition, issues raised in the comments should be addressed in detail giving reasons why specific comments and suggestions are not accepted. There should be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice (CEQA Guidelines Section 15088I).

Conclusory statements do not facilitate the purpose and goal of CEQA on public disclosure and are not meaningful, informative, or useful to decision makers and to the public who are interested in the Proposed Project. Further, if the Lead Agency makes the finding that the recommended new mitigation measures are not feasible, the Lead Agency should describe the specific reasons supported by substantial evidence for rejecting them in the Final EIR (CEQA Guidelines Section 15091).

Response A2.15: The City will comply with the requirements imposed by Public Resources Code §21092.5 and CEQA Guidelines §15088(b), which require a Lead Agency to provide a written response to a public agency on comments made on environmental issues by that public agency at least ten days prior to certifying an EIR. The comment does not express any specific concern or question regarding the adequacy of the EIR. No further response is required or provided. 3 http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/mobile-source-toxics-analysis Redlands Regular Meeting of 10-18-22 1051 of 1815
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LETTER O1: Redlands Area Historical Society (1 page)
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Response to Letter O1: Redlands Area Historical Society, received September 4, 2022 Comment O1.1: This comment states that there are multiple issues with the addresses and names of the historic resources included in Table 5 of the Cultural Report (Appendix C to the Draft EIR) and Table 5.3-2 on pages 5.3-8 to 5.3-11 of the Draft EIR. The comment states that the table should be corrected so that the proposed mitigation for these resources be identified correctly. The comment also states that Assessor Parcel Numbers (APNs) should be added to the table for more accuracy.

Response O1.1: As further discussed in Chapter 3, Errata, of the Final EIR, Table 5 of the Cultural Report and Table 5.3-2 of the Draft EIR has been revised to include the correct addresses and names of the historical resources within the TVSP area. Individual Assessor Parcel Numbers (APNs) are not provided within the cultural records search results provided by the South Central Coastal Information Center.

However, as shown in Chapter 3 of the Final EIR, Table 5.3-2 has been revised to include APNs associated with each historical resource. The provision of these revisions does not alter any impact significance conclusions as disclosed in the Draft EIR and merely provide clarification and additional information regarding existing historical resources within the TVSP area. Further, independent of listed addresses, Mitigation Measure CUL-1 would apply to any development project within the TVSP area that could directly or indirectly impact a building/structure in excess of 50 years of age. Therefore, impacts to historical resources would be less than significant with adherence to Mitigation Measure CUL-1. No further response is required.

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LETTER O2: Redlands Conservancy (1 page)
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Response to Letter O2: Redlands Conservancy, Received September 6, 2022 Comment O2.1: This comment states that the Redlands Conservancy appreciates the opportunity to comment on the Draft EIR and requests that the public review period be extended for two reasons.

Response O2.1: The comment is introductory in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment O2.2: This comment states that the document has significant errors, contradictions, and omissions and that there are multiple errors in Section 5.3, especially in Table 5.3-2. The comment states that if Table 5.3-2 has so many errors, the entire document requires revisiting.

Response O2.2: As further discussed in Chapter 3, Errata, of the Final EIR, Table 5 of the Cultural Report and Table 5.3-2 of the Draft EIR has been revised to include the correct addresses and names of the historical resources within the TVSP area. The provision of these revisions does not alter any impact significance conclusions as disclosed in the Draft EIR and merely provide clarification regarding existing historical resources within the TVSP area. Further, independent of listed addresses, Mitigation Measure CUL-1 would apply to any development project within the TVSP area that could directly or indirectly impact a building/structure in excess of 50 years of age. Therefore, impacts to historical resources would be less than significant with adherence to Mitigation Measure CUL-1. No further response is required.

Comment O2.3: This comment states that the document became available for public review at an inopportune time since the months of August and September are when many people who care about these issues are away and do not have time to read or comment on the Draft EIR.

Response O2.3: Pursuant to the requirements set forth in CEQA Guidelines Section 15087, the Draft EIR was provided for a 45-day public review period from July 21, 2022 through September 6, 2022. The comment provides the commenter’s opinion on the Project’s public review period and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment O2.4: This comment states that the Redlands Conservancy is committed to advocating for historic preservation and the Redlands Conservancy believes that the Draft EIR indicates that historic preservation is in peril. The comment requests that the City provide the community with more time to deeply dive into potential impacts.

Response O2.4: As discussed on page 5.3-13 of the Draft EIR, Mitigation Measure CUL-1 would apply to any development project within the TVSP area that could directly or indirectly impact a building/structure in excess of 50 years of age. Therefore, impacts to historical resources would be less than significant with adherence to Mitigation Measure CUL-1and Redlands Municipal Code Section 2.62.200. 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. In regard to the public review period, the commenter is referred to Response O2.3. The comment provides the commenter’s opinion on the Project and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. No further response is required.

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LETTER I1: Anne Hernandez (1 page)
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Response to Letter I1: Anne Hernandez, received July 26, 2022 Comment I1.1: This comment states that the commenter is opposed to the proposed Project and states that the commenter’s main concerns are related to the University Village. The comment states that the highdensity apartments would result in structures above one-story, which will lower the commenter’s quality of life. In addition, the comment states that this increase in apartments would result in an increase in noise, traffic, and decrease property value.

Response I1.1: The comment does not provide substantial evidence of any environmental impact. As discussed in Section 3.0, Project Description, of the Draft EIR, the University Village would be redeveloped with pedestrian-oriented mixed-use buildings and include pedestrian connections directly to the University of Redlands campus. The mixed-use buildings are proposed to be concentrated along the Rambla corridor.

Village Center, located between the Arrow station to the north and Citrus Avenue to the south of west of the Rambla, would include mixed-use blocks with neighborhood-serving ground floor uses, such as a market hall or grocery store. Village South, located between Central Avenue to the north and Citrus Avenue to the south, would include commercial and mixed-use buildings that provide regional retail uses, and residential uses along Cook Street. Also, the Sylvan Neighborhood would be located to the east of Village North and consist of residential uses. As such, approval of the TVSP could result in future developments with heights greater than one-story. However, as discussed in Section 3.0, the TVSP buildout would be consistent with the total dwelling units allowed pursuant to the Redlands General Plan.

As discussed in Section 5.10, Noise, on pages 5.10-19 through 5.10-21, while construction of new developments pursuant to the TVSP that are infill and redevelopment projects could occur adjacent to sensitive receptors, and temporary intermittent construction noise impacts could occur, Mitigation Measures NOI-1 through NOI-4 would be implemented which would reduce impacts to a less than significant level.

After implementation of Mitigation Measures NOI-5 through NOI-7, buildout of the TVSP would not result in a substantial permanent increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance. Thus, impacts related to noise would be less than significant.

Senate Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines “shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses” (Public Resources Code Section 21099[b][1]); and that “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment” (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section 21099(b)(2), the Draft EIR is not required to analyze impacts related to traffic congestion.

CEQA is a disclosure statute that is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (CEQA Guidelines Section 15360). The Project merits, including any economic and social effects of the Project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)) (San Franciscans for Reasonable Growth v City & County of San Francisco (1989) 209 Cal.App.3d 1502). Therefore, consistent with CEQA, the Draft EIR includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include a discussion of quality of life or property values. Furthermore, CEQA Guidelines Section 15204(a) states that when responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers. Thus, information related to quality of life and property values is not provided. The comment provides the commenter’s opinion on the Project and does not raise any specific concerns with the adequacy of the Draft EIR. This Redlands Regular Meeting of 10-18-22 1057 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-25
Final EIR
September 2022
comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I1.2: This comment states that the Arrow Line and other transit do not provide transportation between Redlands and San Bernardino, Ontario Airport, or San Bernardino Airport. The comment states that additional connection points and transfers should be developed before any high-density development.

Otherwise, congestion and parking issues will arise.

Response I1.2: The commenter erroneously states that the Arrow Line does not connect to San Bernardino.

The San Bernardino County Transportation Authority (SBCTA) shows that the Arrow Line will connect to the San Bernardino Downtown Station once train services open on the Arrow Line in fall 2022, which would provide additional connections to Los Angeles and other destinations.

In addition, as discussed above in Response I1.1, congestion is no longer considered an environmental impact pursuant to CEQA. Additionally, parking or a lack of parking is not considered an environmental impact under CEQA. However, proposed developments within the TVSP would be required to meet the parking standards as set forth in Chapter 6 of the TVSP. The comment provides the commenter’s opinion on the Project and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I1.3: This comment states that the commenter’s biggest complaint is the City hiring Orange County firms as their environmental consultants or environmental engineers. The comment states that hiring Orange County firms makes everyone commute and increases vehicle miles travelled.

Response I1.3: The hiring of Orange County firms for preparation of various documents related to the Project is not related to any environmental impact from the Project; therefore, a discussion of increased commuting or vehicle miles traveled due to the hiring of Orange County firms by the City would be irrelevant to the analysis. The comment provides the commenter’s opinion on firms that the City hires and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-26
Final EIR
September 2022
LETTER I2: Ron Running (5 pages)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-27
Final EIR
September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-28
Final EIR
September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-29
Final EIR
September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-30
Final EIR
September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-31
Final EIR
September 2022
Response to Letter I2: Ron Running, Received July 27, 2022 Comment I2.1: This comment states that the commenter found multiple issues with the addresses and names of the historic resources included in Table 5 of the Cultural Report (Appendix C to the Draft EIR) and Table

5.3-2 on pages 5.3-8 to 5.3-11 of the Draft EIR.

Response I2.1: As further discussed in Chapter 3, Errata, of the Final EIR, Table 5 of the Cultural Report and Table 5.3-2 of the Draft EIR has been revised to include the correct addresses and names of the historical resources within the TVSP area. The provision of these revisions does not alter any impact significance conclusions as disclosed in the Draft EIR and merely provide clarification regarding existing historical resources within the TVSP area. No further response is required.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-32
Final EIR
September 2022
LETTER I3: Patricia Jolliff (1 page)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-33
Final EIR
September 2022
Response to Letter I3: Patricia Jolliff, received July 30, 2022 Comment I3.1: This comment requests the City consider the future of Redlands and halt the three housing projects in downtown Redlands.

Response I3.1: The comment provides the commenter’s opinion on the Project and other housing projects in the City and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I3.2: This comment states that there was no analysis of the impact of adding additional people to already congested streets. In addition, the comment states that the analysis in the EIR does not have enough information but has too many words.

Response I3.2: Senate Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines “shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses” (Public Resources Code Section 21099[b][1]); and that “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment” (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section 21099(b)(2), the Draft EIR is not required to analyze impacts related to traffic congestion. The comment provides the commenter’s opinion on the Project and the text of the Draft EIR and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I3.3: The comment asks where bicycles would be securely stored while patrons visit businesses.

Response I3.3: As shown on page 6:9 of the TVSP, bicycle parking would be included for the Downtown Station. In addition, the TVSP has multiple provisions for enhancing bicycle infrastructure, such as provisions for bike storage and bike racks for use by residents, employees, and visitors in the TVSP area. This comment does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I3.4: This comment states that since there are no employment opportunities in downtown Redlands, the Project would result in the need for freeway access and widened streets. The comment questions which businesses will be removed to allow for wider streets and freeway access.

Response I3.4: Senate Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines “shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses” (Public Resources Code Section 21099[b][1]); and that “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment” (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section 21099(b)(2), the Draft EIR is not required to analyze impacts related to traffic congestion or widening roads. As discussed in Section 3.0, Project Description, street improvements proposed within the TVSP may include the following (i.e., conceptual plans that may or may not be implemented during the timeframe of the specific plan, depending on the timing of future developments and buildout):

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-34
Final EIR
September 2022
• Modifying Colton Avenue, Tennessee Street, State Street, Redlands Boulevard, Brookside Avenue, Citrus Avenue, Texas Street, Stuart Avenue, Eureka Street, Sixth Street, University Street, and Grove Street into multi-modal streets.
• Adding multiple new streets north of the New York/Esri station, within the existing Redlands Mall site, and surrounding the University station.
• Transforming New York Street, Orange Street, and University Street into gateway streets. • Creating a roundabout on Cypress Avenue at the southeast corner of the TVSP area.

These street improvements are dependent on future development within the TVSP (e.g., the street frontages along future project sites) as well as availability of future public funding or grant opportunities (i.e., for public improvements that may be implemented by the City and not associated with any individual development projects). Future individual development projects under the TVSP would be subject to the typical development review process, which includes planning and engineering review, and compliance with standard engineering design requirements that will ensure no impacts to roadway design. This comment does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I3.5: This comment states that the argument that the Project and other housing projects in the City address the housing shortage per State demands is ridiculous since there is a large undeveloped property across from Home Depot that could support a development.

Response I3.5: This comment provides the commenter’s opinion that housing could also be developed on another site in the city. The parcel of land that the commenter is referring to is located within the East Valley Corridor Specific Plan and is designated for Special Development, which allows for development of residential uses. The Project would not prohibit the development of the site with residences. Currently, the City is reviewing multiple development applications for new housing projects in several different areas of Redlands (and includes several vacant properties to the north of Home Depot). However, including the parcel of land that the commenter is referring to as part of the TVSP area would not achieve the main objectives of the Project. As discussed on page 6-4 of the Draft EIR, the primary purpose of the proposed TVSP is to guide redevelopment of areas surrounding the three new Arrow Line stations by introducing additional residential and mixed use, and proposing circulation improvements for vehicles, pedestrians, bicyclists, and transit users. Since all of the Project objectives are related to the areas surrounding the three Arrow Line Stations in the New York Street Village, Downtown Village, and University Village, none of these objectives could be met in another location in the city. The comment does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I3.6: This comment states that voters rejected Measure G and the City is not listening to voter desires. The commenter states that they are spending valuable time asking the City to reconsider this Project.

Response I3.6: This comment provides the commenter’s opinion that the City is not listening to voters and does not raise any specific concerns with the adequacy of the Draft EIR. The draft Transit Villages Specific Plan was created following an extensive public participation and community outreach effort (including nine community workshops that were open to the public). This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I3.7: This comment states that the commenter would like transparency as to who in office at the City is benefiting from these Projects that are not voter sanctioned.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-35
Final EIR
September 2022
Response I3.7: This comment provides the commenter’s opinion that the City is not listening to voters and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-36
Final EIR
September 2022
LETTER I4: T. Allen Jolliff (2 pages)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-37
Final EIR
September 2022
Response to Letter I4: T. Allen Jolliff, Received July 30, 2022 Comment I4.1: This comment requests the City consider the future of Redlands and halt the three housing projects in downtown Redlands.

Response I4.1: The comment provides the commenter’s opinion on the Project and other housing projects in the City and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I4.2: This comment states that there was no analysis of the impact of adding additional people to already congested streets. In addition, the comment states that the analysis in the EIR does not have enough information but has too many words.

Response I4.2: Senate Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines “shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses” (Public Resources Code Section 21099[b][1]); and that “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment” (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section 21099(b)(2), the Draft EIR is not required to analyze impacts related to traffic congestion. The comment provides the commenter’s opinion on the Project and the text of the Draft EIR and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I4.3: The comment asks where bicycles would be securely stored while patrons visit businesses.

Response I4.3: As shown on page 6:9 of the TVSP, bicycle parking would be included for the Downtown Station. In addition, the TVSP has multiple provisions for enhancing bicycle infrastructure, such as provisions for bike storage and bike racks for use by residents, employees, and visitors in the TVSP area. This comment does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I4.4: This comment states that since there are no employment opportunities in downtown Redlands, the Project would result in the need for freeway access and widened streets. The comment questions which businesses will be removed to allow for wider streets and freeway access.

Response I4.4: Senate Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines “shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses” (Public Resources Code Section 21099[b][1]); and that “automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment” (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section 21099(b)(2), the Draft EIR is not required to analyze impacts related to traffic congestion or widening roads. As discussed in Section 3.0, Project Description, street improvements proposed within the TVSP may include the following (i.e., conceptual plans that may or may not be implemented during the timeframe of the specific plan, depending on the timing of future developments and buildout):

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-38
Final EIR
September 2022
• Modifying Colton Avenue, Tennessee Street, State Street, Redlands Boulevard, Brookside Avenue, Citrus Avenue, Texas Street, Stuart Avenue, Eureka Street, Sixth Street, University Street, and Grove Street into multi-modal streets.
• Adding multiple new streets north of the New York/Esri station, within the existing Redlands Mall site, and surrounding the University station.
• Transforming New York Street, Orange Street, and University Street into gateway streets. • Creating a roundabout on Cypress Avenue at the southeast corner of the TVSP area.

These street improvements are dependent on future development within the TVSP (e.g., the street frontages along future project sites) as well as availability of future public funding or grant opportunities (i.e., for public improvements that may be implemented by the City and not associated with any individual development projects). Future individual development projects under the TVSP would be subject to the typical development review process, which includes planning and engineering review, and compliance with standard engineering design requirements will ensure no impacts to roadway design. This comment does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I4.5: This comment states that the argument that the Project and other housing projects in the City address the housing shortage per State demands is ridiculous since there is a large undeveloped property across from Home Depot that could support a development.

Response I4.5: This comment provides the commenter’s opinion that housing could also be developed on another site in the city. The parcel of land that the commenter is referring to is located within the East Valley Corridor Specific Plan and is designated for Special Development, which allows for development of residential uses. The Project would not prohibit the development of the site with residences. Currently, the City is reviewing multiple development applications for new housing projects in several different areas of Redlands (and includes several vacant properties to the north of Home Depot). However, including the parcel of land that the commenter is referring to as part of the TVSP area would not achieve the main objectives of the Project. As discussed on page 6-4 of the Draft EIR, the primary purpose of the proposed TVSP is to guide redevelopment of areas surrounding the three new Arrow Line stations by introducing additional residential and mixed use, and proposing circulation improvements for vehicles, pedestrians, bicyclists, and transit users. Since all of the Project objectives are related to the areas surrounding the three Arrow Line Stations in the New York Street Village, Downtown Village, and University Village, none of these objectives could be met in another location in the city. The comment does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I4.6: This comment states that voters rejected Measure G and the City is not listening to voter desires. The commenter states that they are spending valuable time asking the City to reconsider this Project.

Response I4.6: This comment provides the commenter’s opinion that the City is not listening to voters and does not raise any specific concerns with the adequacy of the Draft EIR. The draft Transit Villages Specific Plan was created following an extensive public participation and community outreach effort (including nine community workshops that were open to the public). This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I4.7: This comment states that the commenter would like transparency as to who in office at the City is benefiting from these Projects that are not voter sanctioned.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-39
Final EIR
September 2022
Response I4.7: This comment provides the commenter’s opinion that the City is not listening to voters and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-40
Final EIR
September 2022
LETTER I5: Marie DeLange (1 page)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-41
Final EIR
September 2022
Response to Letter I5: Marie DeLange, Received July 30, 2022 Comment I5.1: This comment refers to comment I3. Additionally, the comment states that planning is changing the character and ambiance of Redlands, which could result in high-density and high crime areas that would be avoided by local residents. The comment states that businesses might be unlikely to move into these new areas.

Response I5.1: CEQA is a disclosure statute that is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (CEQA Guidelines Section 15360). The Project merits, including any economic and social effects of the Project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)) (San Franciscans for Reasonable Growth v City & County of San Francisco (1989) 209 Cal.App.3d 1502). Therefore, consistent with CEQA, the Draft EIR includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include a discussion of ambiance, character, and portrayed crime changes. Furthermore, CEQA Guidelines Section 15204(a) states that when responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers.

Thus, information related to ambiance, character, and portrayed crime changes is not provided. The comment provides the commenter’s opinion on the Project and does not raise any specific concerns with the adequacy of the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-42
Final EIR
September 2022
LETTER I6: Larry Leonard (2 pages)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-43
Final EIR
September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-44
Final EIR
September 2022
Response to Letter I6: Larry Leonard, Received July 31, 2022 Comment I6.1: This comment states that the City has 10 sworn police officers fewer than 2008 levels. The comment states that the Project would result in increased crime, which would make it hard for police officers to serve Redlands. The comment states that the EIR states that current response times are double what is desirable and the EIR should define what policing needs would be in the future in 2045.

Response I6.1: As discussed in Section 5.12, Public Services, of the Draft EIR on page 5.12-4, the Redlands Police Department has 91 sworn officers, 100 volunteers, and 58 full and part-time civilians, resulting in a service level of 1.12 officers per 1,000 residents. As discussed on page 5.12-7 of the Draft EIR, the service ratio for the City of Redlands is 1.1 officers per 1,000 residents. Based on the new resident population of 6,360 resulting from the Project, the City would need to hire approximately 7 new officers to maintain the service ratio in the City. Buildout of the TVSP is not expected to increase demand for police protection to the extent that new facilities would be required. However, payment of development impact fees included as PPP PS-1 would serve to ensure the maintenance of existing facilities, and if new facilities are required in order to decrease response times, these development impacts fees would ensure the timely provision of new facilities as needed. Further, as discussed in Section 3 of the Draft EIR, projected development under the TVSP would currently be allowed based on existing land use and zoning designations; therefore, the Project would not exacerbate any future impacts to police services in the City from future development. Therefore, impacts to police protection facilities would be less than significant.

Therefore, the EIR adequately describes future policing needs based on buildout of the TVSP.

Comment I6.2: This comment states that the EIR discusses that current fire response times are 9 minutes, 90 percent of the time, while desired response times according to the NFPA are 4 minutes, 90 percent of the time. The comment states that apartments result in more demand for emergency medical services than single-family housing. The comment asks if the two planned fire stations are enough to meet the demand for fire services from the increased residential population.

Response I6.2: As discussed in Section 5.12, Public Services, of the Draft EIR on page 5.12-4, the Redlands Fire Department currently has a goal response time of 7 minutes, 90 percent of the time (Citygate, 2020).

The City currently has plans to acquire sites for and to construct two new fire stations (Stations 265 and 266) in different parts of the City and relocate Station 264 based on the annual increase in calls for service and location of service need. Based on studies conducted by Citygate, the majority of calls for service in Redlands in past years were for emergency medical services. As discussed on pages 5.12-6 through 5.12-7 of the Draft EIR, the General Plan EIR stated that the fire services have stated the needs for expansion in order to accommodate continued increase in population. However, development impact fees included as PPP PS-1 would serve to ensure the maintenance of existing facilities and the timely provision of new facilities as needed. The fees collected would ensure the level of fire protection services are maintained and can be applied to the purchase of equipment, maintenance of existing facilities, and the construction of additional facilities, if needed in the future. Furthermore, future developments pursuant to the TVSP would be required to meet fire and life safety standards, including smoke and carbon monoxide detectors, fire alarms, and residential fire sprinklers, among other building requirements. Their development plans would also be reviewed by City planning and fire departments to ensure state and City codes and requirements are implemented.

Therefore, with the payment of development fees included as PPP PS-1, Project impacts to fire services would be less than significant.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-45
Final EIR
September 2022
Comment I6.3: The comment states that the EIR does not analyze potential impacts related to issues with sewer treatment facilities in Redlands. The comment states that the Project, along with other proposed developments in the City, should update the sewer treatment plant.

Response I6.3: As discussed in Section 5.16 of the Draft EIR on page 5.16-9, the City’s Wastewater Treatment Plant is located on the south side of the Santa Ana River Wash at Nevada Street. The City’s Wastewater Treatment Plant has a secondary treatment capacity of 9.5 mgd and a tertiary treatment capacity of 7.2 mgd. As of 2021, average flow to the City’s Wastewater Treatment Plant was approximately 5.8 mgd (MUED 2021).

As discussed on pages 5.16-10 to 5.16-11 of the Draft EIR, to accommodate the increase in wastewater flows, buildout of the TVSP would include construction of the multiple wastewater upgrades.

Implementation of development projects pursuant to the TVSP would increase the intensity of land uses within the TVSP area, and future site-specific development projects would install onsite sewer infrastructure and new connections to the sewer system that could include improvements to aged sewer pipelines and other connecting infrastructure. Such improvements would be required to be sized to accommodate the wastewater generation of such new development. As shown in Table 5.16-5, TVSP Estimated Wastewater Generation, the proposed Project would generate a demand for approximately 551,134 gallons per day (gpd). The treatment plant currently treats approximately 5.8 mgd and has the capacity to treat 9.5 mgd.

Thus, the addition of 551,134 gallons per day (0.55 mgd) from buildout of the TVSP would be accommodated by the existing facilities and would not result in a capacity constraint related to serving the proposed Specific Plan in addition to the existing commitments. Thus, impacts related to wastewater treatment plant capacity would be less than significant.

Comment I6.4: This comment questions how cumulative aesthetic impacts from the Project, in combination with the Stuart Street Parking Structure and the State Street Village Project, could not be significant. The comment states that the 6-story parking structure and 55-foot-high State Street Village would obscure views of the mountains to the north.

Response I6.4: As discussed on page 45 of the Initial Study (included as Appendix A to the Draft EIR), 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. Likewise, the Project advances the GP2035’s intent to focus development within infill areas to relieve pressure on potential future development in open space and agricultural areas in and around Redlands, while infilling vacant parcels in existing neighborhoods. Toward this end, the Project incorporates a transit-oriented development approach that is guided by a proposed form-based code, which means the physical form detailed in the TVSP’s Development Code is the primary urban design principal in each zone followed then by the land use, instead of the land use determining the form of the built environment. As such, changes resulting from the Project would be consistent with an urbanized environment and with the type of development appropriate for the center of the City as envisioned by the GP2035. Additionally, structures resulting from the Project would be generally within the heights of the existing developed areas and would not block views of or from these scenic vistas as the Project structures would be consistent with views presently found in the area.

Redlands City CouncilOctober 18, 2022

Redlands City Council
October 18, 2022