Redlands City Council
October 18, 2022

As discussed on page 5.1-14 of the Draft EIR, future cumulative development would result in changes to the existing development intensities through conversion of vacant land to developed uses, as well as through the conversion of existing land uses to higher development intensities. However, because the General Plan, Redlands Regular Meeting of 10-18-22 1078 of 1815
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Municipal Code, and TVSP set forth policies to protect the character of existing development (as previously listed), it is anticipated that cumulative projects adopted in a manner consistent with those General Plan, Municipal Code, and TVSP policies would not cumulatively degrade the existing character of area land uses. In addition, cumulative projects would be required to adhere to setback requirements as set forth by the TVSP and Redlands Municipal Code, which would prevent structures from blocking public views of the mountains from existing rights-of-way. As a result, there would be no significant cumulative impact to which implementation of the proposed Project could contribute.

Comment I6.5: This comment states that the EIR does not discuss issues related to freeway access and the Orange Street and Redlands Boulevard intersection, which would be congested with the increased development.

Response I6.5: 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.

Comment I6.6: This comment includes quotes from the EIR’s noise analysis included in Section 5.10 of the Draft EIR and states that once the Project is developed, there would be noise from the Arrow Line train whistle. The comment questions if all the noise impacts could be mitigated.

Response I6.6: San Bernardino County Transportation Authority (SBCTA) conducted its own independent environmental analysis for impacts related to the development and operation of the Arrow Line. The Environmental Impact Statement/Environmental Impact Report (EIS/EIR) for the Arrow Line project can be found on the SBCTA website (https://www.gosbcta.com/wp-content/uploads/2019/09/Final_EIS-EIRRedlandsPassengerRailProject.pdf). The EIS/EIR for the Arrow Line Project concluded that operational noise impact would be significant and unavoidable. These impacts would occur independent of the proposed Project, as the Arrow Line project has already been approved and is under construction.

As discussed in Section 5.10, Noise, on pages 5.10-19 through 5.10-21 of the Draft EIR, 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 from construction and operation of implementing projects within the TVSP would be less than significant.

Comment I6.7: This comment contains multiple questions related to the Water Supply Analysis conducted for the Project, including what would happen in 25 years and what defines adequate supply. The comment questions if there will be enough water with all of the new development going in. The comment asks whether the EIR considered water usage of the new apartments being built to the west side of Redlands and the residential development on the north side of Redlands.

Response I6.7: A Water Supply Assessment was conducted to determine the water demand associated with the proposed Project and whether there is adequate supply, pursuant to CEQA Guidelines Section 15155, and is included as Appendix F to the Draft EIR. As shown in Table 5.16-3 of the Draft EIR, buildout of the TVSP would result in a total demand of 1,996 AFY by the year 2040, which would be a 639 AFY Redlands Regular Meeting of 10-18-22 1079 of 1815
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increase in comparison to the current TVSP area water demands from existing development within the TVSP area. The Redlands Municipal Utilities and Engineering Department (MUED) 2020 Urban Water Management Plan (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. 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. Therefore, it is anticipated that existing and future water entitlements from groundwater, surface water, purchased or imported water sources, recycled water would be sufficient to meet the Project’s demand at buildout, in addition to forecast demand for MUED’s entire service area.

Comment I6.8: This comment states that parking concerns are not addressed in the EIR.

Response I6.8: Parking or a lack of parking is not considered an environmental impact under CEQA except insofar as the lack of parking may have secondary environmental effects. Here, proposed developments within the TVSP would be required to meet the parking standards as set forth in Chapter 6 of the TVSP and those set forth in the City of Redlands Municipal Code. Thus, the project would not result in a parking deficiency. The comment does not raise any specific concerns with the adequacy of the Draft EIR or provide substantial evidence to support the claim that the project will lack necessary parking and thus result in significant environmental impacts. This comment will be forwarded to City decisionmakers are part of the Final EIR. Therefore, no further response is required or provided.

Comment I6.9: This comment states that the EIR addresses many problems and concludes that most of them can be mitigated. However, the document does not address the need for taxpayers to pay for the mitigation or the cost of all of the infrastructure. The comment states that the EIR mentions that developers would be required to pay fair-share for improvements and questions what fair-share means.

Response I6.9: 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). 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 taxpayer contribution to infrastructure improvements.

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 taxpayer contribution to infrastructure improvements is not provided.

As mentioned by the commenter, the majority of the financial burden associated with development pursuant to the TVSP would be placed on future developers that would be required to pay fair-share development impact fees toward improvements, funding for public services, etc. Fair-share is defined as an equitable or reasonable portion or share of something; (more generally) a good number, a large amount, sometimes implying the amount is excessive or inordinate. Essentially, future developers would be required to pay for improvements based on their portion of impacts or requirement for improvements. The comment Redlands Regular Meeting of 10-18-22 1080 of 1815
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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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LETTER I7: Richard O’Donnell (1 page)
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Response to Letter I7: Richard O’Donnell, Received August 21, 2022 Comment I7.1: This comment states that the TVSP would result in substantial, negative impacts and discusses that the EIR states that impacts related to air quality and transportation would be significant and unavoidable. The comment states that in order to avoid that problem, the TVSP should not be approved.

Response I7.1: As detailed in Draft EIR 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.

As detailed in Draft EIR 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.

Pursuant to Public Resources Code Section 21081(a)(3), the City of Redlands would be required to make findings that specific economic, legal, social, technological, or other considerations make infeasible the alternatives identified in the Draft EIR related to significant environmental effects. As such, the City shall prepare a Findings of Fact, which would be included as part of the administrative record. The comment does not raise any specific concerns with the adequacy of the Draft EIR. Therefore, no further response is required or provided.

Comment I7.2: This comment states that water supply and use is an important issue for residents and that the Draft EIR contains confusing language regarding water supply and use. The comment states that supply volumes provided in the Draft EIR are unrealistic as they show an increase in supply despite a multi-year drought.

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The comment states that the City just requested an emergency delivery of State Water Project water, which shows issues related to anticipated needs of thousands of new residents and businesses. In addition, rail lines cross the Bunker Hill basin daily with hazardous waste, which could lead to problems.

Response I7.2: As discussed in Draft EIR Section 5.16, Utilities and Service Systems, starting on page 5.16- 3, the City of Redlands Municipal Utilities and Engineering Department (MUED) provides water service to the TVSP area. 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 in Table 5.16-2 of the Draft EIR, the 2020 Urban Water Management Plan (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. In addition, the UWMP contained a drought risk assessment which concluded that the City would be able to meet growing demands through 2045, plus a 15% surplus, even in a five-year drought condition.4 In addition, the City of Redlands has a Water Shortage Contingency Plan (WSCP) that the City uses to prepare for and respond to foreseeable and unforeseeable water shortages. Since the TVSP water demand is within the forecasted demand projected by the UWMP, implementation would not result in significant environmental effects related to water use.

Furthermore, impacts related to hazardous materials spills effecting the Bunker Hill basin are speculative and any potential spills would be required to comply with existing regulations, reporting, and remediation procedures in order to ensure that hazardous materials would not impact groundwater quality within the Bunker Hill basin. The comment does not raise any specific concerns with the adequacy of the Draft EIR.

Therefore, no further response is required or provided.

Comment I7.3: This comment states that financing should be considered as the Draft EIR is not specific on infrastructure needed to build in a 100-year floodplain. The comment also questions where apartmentdwellers would go when a large earthquake hits and their multi-story complex is without water or power.

Response I7.3: The majority of the financial burden associated with development pursuant to the TVSP would be placed on future developers that would be required to pay fair-share development impact fees toward improvements, funding for public services, etc. Future developers would be required to pay for improvements based on their portion of impacts or requirement for improvements associated with development the future project.

Future developments proposed within the 100-year floodplain must comply with City of Redlands Municipal Code Chapter 15.32, Flood Damage Prevention. Compliance with Municipal Code Chapter

15.32 would residential structures to have the lowest floor elevated at least 4-feet above existing grade in Flood Zone AO and 2-feet above base flood elevation in Flood Zones AE, AH, or A1-30. In addition, all developments would be required to comply with existing regulations, which would be reviewed through the permitting process, in order to ensure that impacts would not occur related to flooding.

Impacts related to a large earthquake occurring and multi-story complexes being without water or power are speculative. However, all future developments would be required to comply with the provisions set forth in the most current version of the California Building Code (CBC). Compliance with the CBC would ensure that buildings are designed to endure ground shaking related to earthquakes and compliance would be reviewed and assured through the permitting process. The comment does not raise any specific concerns with the adequacy of the Draft EIR. Therefore, no further response is required or provided. 4 City of Redlands. 2020 IRUWMP. https://www.cityofredlands.org/sites/main/files/fileattachments/part_2_chapter_4_redlands_2020_uwmp.pdf?1622145365 Redlands Regular Meeting of 10-18-22 1084 of 1815
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Comment I7.4: This comment states that community sentiment toward the TVSP was not evaluated in the EIR despite voters expressing consistent resistance to large-scale development. The comment states that it is obvious that the City Council, Planning Commission, and Development Services Department have been pushing development in spite of rejection by voters and are trying to delay the latest initiative to limit growth. The comment concludes by stating the TVSP should not be approved.

Response I7.4: 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 voter or community sentiment. 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 community or voter sentiment is not provided (however, the draft Transit Villages Specific Plan was created following an extensive public participation and community outreach program. 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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LETTER I8: Joanne Lessard (1 page)
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Response to Letter I8: Joanne Lessard, Received September 3, 2022 Comment I8.1: This comment states that a City should only change zoning when absolutely necessary, that universities have had to diversify locations in the past and it has not been detrimental. In addition, the comment states that the commenter can see some trade-off between preservation of the canyons and densification of urban areas. The comment states that the commenter does not like the changes in zoning and believes that Redlands has ambiance and character, and that the City should not remove the reasons for Redlands’ success.

Response I8.1: 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 character and ambiance. 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 character and ambiance 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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LETTER I9: Renae Reiswig (1 page)
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Response to Letter I9: Renae Reiswig, Received September 6, 2022 Comment I9.1: This comment states that the TVSP Regulating Plan shows the boundary of the TVSP extending south into the Smiley Park Historic District with a zoning called Village Corridor. The comment states that the neighborhood worked hard to become designated and that the Project could result in demolition of historic resource. The comment requests that the City remove the Smiley Park Historic District from the boundaries of the TVSP and that the City notifies other property owners in older neighborhoods of their inclusion in the TVSP.

Response I9.1: 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. 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.

Comment I9.2: This comment states that the public has let the City Council know that the public prefers to keep the small-town charm and protect historic resources by not increasing height and density in the City.

Response I9.2: In regard to historical resources, the commenter is referred to Response I9.1. As discussed on page 5.1-12 of the Draft EIR, TVSP Chapter 4, Development Code, provides detailed regulations for development and new land uses within the TVSP area, and describes how these regulations would be used as part of the City’s development review process. These provisions supersede and replace regulations under the City of Redlands Zoning Code (Title 18 of the Municipal Code). Where specific provisions are not set forth for development standards within the TVSP, or where otherwise applicable requirements of the Zoning Code are not covered by the TVSP Development Code, implementing projects within the TVSP area would be subject to current or future Municipal Code regulations. However, while regulations within the TVSP supersede regulations set forth by the current Municipal Code, the majority of regulations align with the development standards set forth throughout the Municipal Code. For example, the R-3 Multiple Family Residential District set forth in Chapter 18.60 of the Municipal Code allows for development of buildings and structure with a height of no greater than four stories. As discussed in Section 3, Project Description, of this Draft EIR, buildings within the Village Center (VC) district would have a maximum height of four stories and buildings within the Village General (VG) district would be required to have an average height of three stories. Therefore, the new building standards, such as those for building height, provided for by the TVSP would largely remain consistent with existing Municipal Code development standards. 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 I10: Julia Lenhardt (1 page)
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Response to Letter I10: Julia Lenhardt, Received September 6, 2022 Comment I10.1: This comment states that the commenter supports the TVSP and the Draft EIR, but has two concerns. The comment states that the City should study the impact of the Project on the coyote population.

The comment states that the riparian corridor that will be converted to open space is likely a coyote corridor, so it will benefit the community to know where the coyotes will go when they can no longer use the riparian corridor.

Response I10.1: As discussed on pages 54 to 55 of the Initial Study (included as Appendix A) to the Draft EIR, riparian habitats are those occurring along the banks of rivers and streams. Sensitive natural communities are natural communities that are considered rare in the region by regulatory agencies, known to provide habitat for sensitive animal or plant species, or known to be important wildlife corridors. Such areas, especially those with native vegetation adjacent to or immediately upstream of the Santa Ana River, Mill Creek, and San Timoteo Creek, are not within the Project area (GP2035 EIR, Figure 3.4-1). The GP2035 identifies potential wildlife corridors through the Live Oak Canyon and San Timoteo Canyon areas, and for the City to protect wildlife corridors connecting the San Bernardino National Forest, Santa Ana River Wash, Crafton Hills, San Timoteo and Live Oak canyons, the Badlands, and other open space areas (GP2035 EIR, p. 3.4-29). These areas are not located within or adjacent to the Project area. The proposed Project would not result in impacts to riparian habitats or wildlife corridors. Further, while the Project would designate the Zanja Greenway corridor as civic space, with the purpose of maintaining it as open space, the corridor would remain largely the same as in existing conditions. Additionally, the Project would also include planting of riparian landscaping along the Zanja Greenway, which would only serve to enhance its use for wild animals such as coyotes, birds, and squirrels. Therefore, the Project would not result in the displacement of any coyotes from the Zanja corridor.

Comment I10.2: This comment states that there is no mention of how the Project will impact housing prices and questions if families living in lower-income housing will still be able to afford living in the area.

Response I10.2: 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 affordability of housing. 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 affordable housing is not provided. 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.

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LETTER I11: Steve Rogers (3 pages)
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Response to Letter I11: Steve Rogers, Received September 6, 2022 Comment I11.1: This comment states that the commenter provides multiple comments on the Draft EIR and the Transit Villages Specific Plan.

Response I11.1: 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 I11.2: This comment states that the draft Transit Villages Specific Plan (TVSP) was completed a while ago and posted to the City’s website, but was not properly distributed for comment in conjunction with the Draft EIR. The comment states that this results in a piecemeal approval in violation of CEQA. The comment states that the Draft EIR should be recirculated and accompanied by the TVSP document.

Response I11.2: As the commenter stated the draft TVSP document is available on the City’s website for public review. Pursuant to CEQA Guidelines Section 15087, the Draft EIR was provided for public review from July 21, 2022 through September 6, 2022. Pursuant to CEQA, there is no requirement for a public review period for the Draft TVSP document. Furthermore, this document has been provided on the City’s webpage (https://www.cityofredlands.org/pod/transit-villages-plan) and the project website (https://redlandstransitvillages.org/) since May 2020, for review and comment, independent of CEQA.

In addition, CEQA piecemealing is defined as improperly splitting a project into separate segments to avoid consideration of the cumulative impacts of the project. Not including the TVSP document as an appendix to the Draft EIR does not constitute piecemealing. The Draft EIR, in fact, analyzes the TVSP document as the project. 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.

Comment I11.3: This comment states that a scope for a Traffic Impact Analysis (TIA) was included in the scope of work from EPD Solutions, the City’s environmental consultant for the Project. However, a TIA was not included as an appendix to the Draft EIR.

Response I11.3: 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. As such, pursuant to Public Resources Code Section 21099(b)(2), a vehicle miles traveled analysis was prepared for the proposed Project instead of a TIA.

The vehicle miles traveled analysis is included as Appendix I to the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. No further response is required.

Comment I11.4: This comment states that false assumptions have been made by the environmental consultant and/or City staff in scoping the work effort for the Draft EIR document to include the Transit Villages Overlay Zones and the citywide Traffic Impact Analysis to support the General Plan Update.

Response I11.4: The comment provides the commenter’s opinion on the scope of work for 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. No further response is required.

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Comment I11.5: This comment states that the Draft EIR is deficient and does not properly analyze impacts related to the Master Plan of Streets, Master Plan of Drainage, Master Plan of Sanitary Sewer, Master Plan of Water, and Master Plan of Recycled Water as these facilities master plans still need to be developed.

Response I11.5: As discussed in Draft EIR Section 3.0, Project Description, infrastructure plans contained in the TVSP are conceptual and identify a vision of future improvements based on an assumed buildout of the proposed Specific Plan. The identified infrastructure improvements will likely occur incrementally depending on the location(s), type(s), and extent of future private development projects that would need to utilize the public and private infrastructure. The precise timing of infrastructure and other public improvements are not known with certainty, as improvements would likely depend on the extent and timing of future development projects, buildout of private development projects, future availability and amounts of public grant funding, and other factors. Adoption of the TVSP would provide the policy framework and specific types of improvements (i.e., sufficient specificity to articulate the community’s goals for the future) with which the City can then pursue Federal, State, or regional grant funding that may be available in the future for such public improvements. City updates to the Master Plan of Streets, Master Plan of Drainage, Master Plan of Sanitary Sewer, Master Plan of Water, and Master Plan of Recycled Water are independent projects under CEQA and analysis of impacts related to implementation of these plans would be conducted independently of the Draft EIR prepared for this Project.

Furthermore, cumulative impacts related to infrastructure improvements were analyzed throughout the Draft EIR. This comment will be forwarded to City decisionmakers are part of the Final EIR. No further response is required.

Comment I11.6: This comment refers to a previous item on the City Council meeting agenda for Tuesday, June 7, 2022, which was an approval to continue the agreement with EPD Solutions for preparation of the TVSP EIR for another year. The comment states that the commenter is concerned about the City identifying a proper scope of services for the preparation of the TVSP Draft EIR. The comment states that the commenter has met with the City and the California Department of Transportation regarding the TVSP Project and the lack of progress on preparation of the Draft EIR to analyze impacts related to traffic circulation, drainage, water utilities, wastewater utilities, and solid waste facilities.

Response I11.6: Pursuant to CEQA Guidelines Section 15087, the Draft EIR was provided for public review from July 21, 2022 through September 6, 2022. As discussed in Draft EIR Section 5.14, Transportation, impacts to the circulation system, such as transit, bicycle infrastructure, and pedestrian infrastructure, were determined to be less than significant. As discussed in Draft EIR Section 5.16, Utilities and Service Systems, impacts related to capacity of existing drainage, water, wastewater, and solid waste infrastructure and facilities was analyzed and determined to be less than significant with the incorporation of mitigation measures related to construction, included throughout the Draft EIR.

Comment I11.7: This comment states that the commenter is confused why the City is moving forward with the Redlands Mall Project without the benefit of the TVSP and the Draft EIR, which is a piecemeal approval in violation of CEQA and the California Subdivision Map Act.

Response I11.7: As discussed in Response I11.2, CEQA piecemealing is defined as improperly splitting a project into separate segments to avoid consideration of the cumulative impacts of the project. The Redlands Mall redevelopment project (known as the “State Street Village” mixed use project) was a set of requested entitlements approved by the Redlands City Council on May 11, 2022. The State Street Village project was approved under the existing zoning regulations (RMC Title 18) and in accordance with Redlands Regular Meeting of 10-18-22 1096 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-64
Final EIR
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all applicable development standards and design regulations in effect at that time. That project previously underwent separate environmental review in accordance with the requirements of CEQA for individual development projects. The State Street Village project was independently functional and does not require the approval of the TVSP project in order to be developed. As such, having distinct CEQA documents and approvals for the Redlands Mall project and the proposed Project do not constitute CEQA piecemealing.

Comment I11.8: This comment states that the commenter does not believe that the City can use grant funds to pay for the environmental review services and that the scope of work and estimated fee of services are inadequate for the level of analysis necessary for the Project. The comment therefore requests that the City pulling the item from the June 7, 2022 agenda.

Response I11.8: The comment provides the commenter’s opinion on the scope of work for the Draft EIR and does not raise any specific concerns with the adequacy of the Draft EIR. Funding of the EIR (i.e., reimbursement from the State) is a matter of separate and independent agreements between the City of Redlands and the State of California (SB 2 Planning Grant and a LEAP Grant awarded by the Department of Housing & Community Development). This comment will be forwarded to City decisionmakers are part of the Final EIR. No further response is required.

Redlands Regular Meeting of 10-18-22 1097 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-65
Final EIR
September 2022
LETTER I12: Chris E. Sedmack (3 pages)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-66
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-67
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-68
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Response to Letter I12: Chris E. Sedmack, Received September 6, 2022 Comment I12.1: This comment states that the commenter tried to read the TVSP document, but the document came out for public review when a lot of people are away for Labor Day weekend. The comment states that the citizens of Redlands need to have the opportunity to review the document and requests the City extend the public review period.

Response I12.1: 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 (a total of 48 calendar days). 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 I12.2: This comment states that the City Council should create an advisory committee of concerned citizens to offer new ideas and review/critique future projects as they come forward.

Response I12.2: The City currently has a Planning Commission, which is comprised of local residents (appointed by the City Council), who review development projects as they are proposed. The City also provides a Development Review Committee (composed of City staff) to conduct the technical review of project plans to ensure conformance with City regulations, design standards, California Building and Fire Codes, and other applicable regulations. 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 I12.3: This comment states that according to the Draft EIR, there are over 200 historical properties located in the TVSP area and states that these buildings show the city’s unique history and character. The comment further states that the increases in maximum height and density, plus the zone changes within the Project area, would incentivize the demolition of Redlands’ physical character and unique history. The comment states that single-story houses will get replaced with the highest and best use and that historical buildings should be protected and adaptively reused.

Response I12.3: 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. No historically significant buildings are planned for alteration or demolition and the proposed TVSP aims to ensure preservation of historic resources. As such, the Draft EIR concluded that impacts to historical resources would be less than significant from buildout pursuant to the TVSP.

Further, in regard to height and density, as discussed on page 5.1-12 of the Draft EIR, TVSP Chapter 4, Development Code, provides detailed regulations for development and new land uses within the TVSP area, and describes how these regulations would be used as part of the City’s development review process. These provisions supersede and replace regulations under the City of Redlands Zoning Code (Title 18 of the Municipal Code). Where specific provisions are not set forth for development standards within Redlands Regular Meeting of 10-18-22 1101 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-69
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September 2022
the TVSP, or where otherwise applicable requirements of the Zoning Code are not covered by the TVSP Development Code, implementing projects within the TVSP area would be subject to current or future Municipal Code regulations. However, while regulations within the TVSP supersede regulations set forth by the current Municipal Code, the majority of regulations align with the development standards set forth throughout the Municipal Code. For example, the R-3 Multiple Family Residential District set forth in Chapter 18.60 of the Municipal Code allows for development of buildings and structure with a height of no greater than four stories. As discussed in Section 3, Project Description, of this Draft EIR, buildings within the Village Center (VC) district would have a maximum height of four stories and buildings within the Village General (VG) district would be required to have an average height of three stories. Therefore, the new building standards, such as those for building height, provided for by the TVSP would largely remain consistent with existing Municipal Code development standards. 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.

Comment I12.4: This comment states that the TVSP area includes historic neighborhoods like Kendall Street, East High Avenue, East Central Avenue, and parts of the Smiley Park Historic District and owners should be contacted to see if they object to development pressures being placed on their neighborhoods, which could result in demolitions and nonresidential uses. The comment states that the Smiley Park Historic District should be removed from the TVSP area and the Santa Fe Historic District should be removed or protected from the TVSP Project.

Response I12.4: As discussed in Response I12.3, 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. In addition, all implementing projects within the TVSP area are subject to the Redlands Historic Architectural Design Guidelines and any project altering a historic resource would be subject to a Certificate of Appropriateness application reviewed by the Historic and Scenic Preservation Commission, and a demolition permit application for a structure over 50 years of age is subject to review by the Redlands Historic and Scenic Preservation Commission. As such, the Draft EIR concluded that impacts to historical resources would be less than significant from buildout pursuant to the TVSP and the TVSP would not result in substantial adverse impacts to the Smiley Park Historic District or the Santa Fe Historic District.

Comment I12.5: This comment states that the Draft EIR has contradictory statements about where residential dwelling units can go. The comment summarizes a statement from Draft EIR Section 5.11, Population and Housing, that discusses where housing is currently allowed in the Downtown Transit Village.

The comment includes a summary of the Project Description stating Project including development of multifamily residential uses between Eureka Street, Texas Street, Stuart Avenue, and State Street and states that this area is already developed with commercial uses. The comment states that the Zanja should be landscaped with outdoor eating along it and not residential. The comment further states that areas right next to train stations could be all residential while the public was told that there would be ground floor retail in the Village Center District and states that residential units are also allowed in the Downtown District. The comment states that the document cannot be trusted because it contradicts itself about where residential units will be built.

Response I12.5: The commenter erroneously refers to the Environmental Setting Discussion in Draft EIR Section 5.11, which actually states that multi-family residential uses are currently allowed in the Downtown Transit Village area under the current General Plan and zoning designations. As discussed in Draft EIR Section 3, Project Description, the Project provides a 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. It is anticipated that individual development projects on privately-owned parcels would occur incrementally and over an extended period Redlands Regular Meeting of 10-18-22 1102 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-70
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September 2022
of time (i.e., infill development) such as the 20-year or longer lifespan of the TVSP. Multi-family and single-family residential uses would be allowed in the Village Center, Downtown, Village General, Village Corridor, Village Neighborhood 1, and Village Neighborhood 2 districts throughout the New York Street/Esri Village, Downtown Transit Village, and University Village. The Draft EIR provides a programmatic analysis of buildout of the TVSP with 2,400 residential units, but does not assign units to specific sites, as future development is unknown. 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.

Comment I12.6: This comment states that former Mayor Paul Foster told other City Council members that the citizens of Redlands have repeatedly voiced their opinion that they do not want tall buildings that change the small town charm of Downtown Redlands. The comment states that the former mayor advised the City Council not to approve projects with taller buildings until after the November vote, but the City Council has approved the Redlands Mall project and will soon approve the City Center project and the Grand project, which are all four stories tall and within three adjacent blocks. The comment asks why if the TVSP buildout goal for dwelling units is 2,400 units, close to half of them will be built on three blocks instead of spreading them out all over the TVSP area.

Response I12.6: As discussed on page 5.1-12 of the Draft EIR, TVSP Chapter 4, Development Code, provides detailed regulations for development and new land uses within the TVSP area, and describes how these regulations would be used as part of the City’s development review process. These provisions supersede and replace regulations under the City of Redlands Zoning Code (Title 18 of the Municipal Code). Where specific provisions are not set forth for development standards within the TVSP, or where otherwise applicable requirements of the Zoning Code are not covered by the TVSP Development Code, implementing projects within the TVSP area would be subject to current or future Municipal Code regulations. However, while regulations within the TVSP supersede regulations set forth by the current Municipal Code, the majority of regulations align with the development standards set forth throughout the Municipal Code. For example, the R-3 Multiple Family Residential District set forth in Chapter 18.60 of the Municipal Code allows for development of buildings and structure with a height of no greater than four stories. As discussed in Section 3, Project Description, of this Draft EIR, buildings within the Village Center (VC) district would have a maximum height of four stories and buildings within the Village General (VG) district would be required to have an average height of three stories. Therefore, the new building standards, such as those for building height, provided for by the TVSP would largely remain consistent with existing Municipal Code development standards.

In addition, the Redlands Mall redevelopment project (State Street Village), City Center Project, and The Grand project are distinct projects with their own sets of requested entitlements under the current General Plan and current zoning designations in place. 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.

Comment I12.7: This comment states that the City should consider the concerns of past City Council members, citizens who have spoken at previous City Council meetings, citizens who were out of town due to Labor Day, and past votes by citizens who have made their concerns clear regarding high density and high rise buildings in the City. The comment states that people moved to Redlands because of its history, small town feel, old trees, and a safe community.

Response I12.7: The draft Transit Villages Specific Plan was prepared after an extensive public participation and community outreach effort, including nine community workshops open to the public (over a period of nine months) plus several meetings of the City Council and Planning Commission (over a period exceeding two years). 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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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-71
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September 2022
LETTER I13: Norm and Laurie Cosme (1 page)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-72
Final EIR
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Response to Letter I13: Norm and Laurie Cosme, Received September 6, 2022 Comment I13.1: This comment states that the TVSP Regulating Plan shows the boundary of the TVSP extending south into the Smiley Park Historic District with a zoning called Village Corridor, which allows for commercial uses. The comment states that the neighborhood worked hard to become designated and that residents do not want commercial uses in the Smiley Park Historic District. The comment requests that the City remove the Smiley Park Historic District from the boundaries of the TVSP and that the City notifies other property owners in older neighborhoods of their inclusion in the TVSP.

Response I13.1: 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 I13.2: This comment states that there are already 977 units planned on the three adjacent blocks on Eureka, which are a lot for the Downtown. The comment states that more residential units will be allowed in the Downtown Transit Village despite the Draft EIR stating in Section 5.11.3 that the Downtown Transit Village area is primarily non-residential.

Response I13.2: The Redlands Mall redevelopment project (State Street Village), City Center Project, and The Grand project, which the commenter is referring to, are distinct projects with their own sets of requested entitlements under the current General Plan and current zoning designations in place. Those projects were able to move forward utilizing the existing zoning regulations (RMC Title 18), applicable development standards, and other design regulations that are in effect at the present time.

The commenter erroneously refers to the Environmental Setting Discussion in Draft EIR Section 5.11, which actually states that multi-family residential uses are currently allowed in the Downtown Transit Village area under the current General Plan and zoning designations (for example, the existing C-3 General Commercial zoning for a large portion of the downtown area currently permits mixed uses including multifamily residential uses). 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.

Comment I13.3: This comment states that the Draft EIR mentions that there are 182 historic properties within the TVSP area and these historic resources need to be protected from being demolished to make way for new taller and denser buildings. The comment states that these historic buildings are a visual reminder of the City’s history and old houses should be adaptively reused for restaurants and shops to make Downtown more inviting.

Response I13.3: 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. Many properties exceed 50 years of age and could potentially be eligible for historic designation, but they have not been individually assessed or evaluated for historical significance (a necessary step prior to designation). Furthermore, designation requires the consent and authorization of the property owner for the City Council to formally designate and list a property as historically significant on the City’s local list of Historic Resources. 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. The comment provides the commenter’s opinion on Redlands Regular Meeting of 10-18-22 1105 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-73
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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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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-74
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September 2022
LETTER I14: Ruth Cook (3 pages)
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-75
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 2-76
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-77
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Response to Letter I14: Ruth Cook, Received September 6, 2022 Comment I14.1: This comment provides an introduction to the comment letter and states that the commenter supports the concept of Transit Villages and thinks that community input is critical. The comment states that the commenter is concerned about three aspects of the Draft EIR.

Response I14.1: 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 I14.2: The comment states that historic homes and structures are located throughout the TVSP area and should be identified to be preserved or else there will be too many incentives to remove and demolish them. The comment states that the process cannot wait for each individual demolition project and should be overarching and comprehensive for preservation. The comment states that multiple historic areas are designated for Village Corridor so it is not clear how they will be preserved and the community should be aware of potential changes.

Response I14.2: Section 5.3.3 of the Draft EIR includes a comprehensive discussion of historical resources within the TVSP area and Table 5.3-2 contains a list of historical properties in the TVSP area. There are 182 historic properties located within the TVSP area, with most of the eligible historic properties located in Downtown Redlands. The California Office of Historic Preservation’s (OHP) Built Environment Resources Directory (BERD) for San Bernardino County, the City of Redlands’ General Plan EIR (2017a), the City of Redlands’ Downtown Specific Plan (2017b), the City of Redlands’ List of Historic Resources (2019), the National Register (NR), the California Register of Historic Places (CR), California Historic Landmarks, and California Point of Historical Interest identify 114 historic properties within the TVSP area. Of these historic resources, 25 historic properties are listed in the National Register (NR) and/or the California Register (CR), three properties appear eligible for NR or CR, and 63 properties are designated as local historic resources. Eleven properties have been determined ineligible for listing or designation and 13 properties have not been evaluated for NR or NR or need evaluation. Additional research provided by the Redlands Area Historical Society identified over 100 additional properties which are of historic era but have not yet been evaluated as to their significance for local, state, or federal registers. In addition, there are two historic districts located within the TVSP area, the Smiley Park Historic District and Santa Fe Depot Historic District.

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. With implementation of the historic design standards that would be implemented as part of the proposed TVSP, Mitigation Measure CUL-1, and Redlands Municipal Code Section 2.62.200, impacts related to a substantial adverse change in the significance of a historic resource would be less than significant.

Comment I14.3: This comment states that there should be a clear explanation of the relationship between the 2035 General Plan and the TVSP as it is very difficult to read the Specific Plan and see which is the actual deciding factor for projects. The comment questions how the two will work together to inform development decisions and projects.

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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-78
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September 2022
Response I14.3: As discussed in Draft EIR Section 3, Project Description, the TVSP is a means of implementing the Transit Village Concept included in the City of Redlands General Plan 2035. The Project would include amendments to the GP2035 to change land use designations of parcels from various GP2035 land use designations to a “Transit Village” (TV) District (or similar) land use classification. The proposed TVSP would provide a form-based code to achieve preferred building forms and design, promote compact and walkable urban form in the vicinity of the train stations, introduce a greater variety of transportation options (and reduce vehicle trips and vehicle miles traveled), and provide more public open space and amenities that provides aesthetic and community benefits.

As discussed in Section 5.9, Land Use and Planning, California law (Government Code §65450-§65453) allows cities to develop and administer Specific Plans as an implementation tool for their General Plan. As a requirement of state law, Specific Plans must demonstrate consistency in regulations, guidelines and programs with the goals, objectives, policies, standards, programs and uses that are established in the General Plan. The proposed Specific Plan would implement General Plan policies related to infill development, providing a supply of non-residential development area within the City, provision of housing for employees, and increasing use of alternative methods of circulation. The proposed TVSP provides for infill development that would make use of the existing circulation and utility infrastructure and provide mixed-use and higher density housing opportunities that provide affordability. The TVSP addresses the consistency of the TVSP with the relevant City’s General Plan and said analysis is incorporated by reference into this EIR. The TVSP would become the main land use implementation tool for the project area.

Comment I14.4: This comment states that if half of the 2,400 units are already proposed for the mall and the two adjacent projects, then the rest of the residential units should be encouraged near ESRI and the University of Redlands stations. The comment states that the mall has a huge impact on the Downtown neighborhood and the other two add up, but the commenter is not saying that they oppose either.

Response I14.4: The Redlands Mall redevelopment project (State Street Village), City Center Project, and The Grand project, which the commenter is referring to, are distinct projects with their own sets of requested entitlements under the current General Plan and zoning designations in place. Those projects were able to move forward utilizing the existing zoning regulations (RMC Title 18), applicable development standards, and other design regulations that are in effect at the present time. 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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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-79
Final EIR
September 2022

LATE COMMENTS
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-80
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LETTER O3: Mitchell M. Tsai, on behalf of the Southwest Regional Council of Carpenters (271 pages) Redlands Regular Meeting of 10-18-22 1113 of 1815
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Redlands Regular Meeting of 10-18-22 1134 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-102
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1135 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-103
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1136 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-104
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1137 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-105
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1138 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-106
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1139 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-107
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1140 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-108
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1141 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-109
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1142 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-110
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1143 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-111
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1144 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-112
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1145 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-113
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1146 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-114
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1147 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-115
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1148 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-116
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1149 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-117
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1150 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-118
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1151 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-119
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1152 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-120
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1153 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-121
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1154 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-122
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1155 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-123
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1156 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-124
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1157 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-125
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1158 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-126
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1159 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-127
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1160 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-128
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1161 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-129
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1162 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-130
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1163 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-131
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1164 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-132
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1165 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-133
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1166 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-134
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1167 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-135
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1168 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-136
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1169 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-137
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1170 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-138
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1171 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-139
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1172 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-140
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1173 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-141
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1174 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-142
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1175 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-143
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1176 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-144
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1177 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-145
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1178 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-146
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1179 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-147
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1180 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-148
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1181 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-149
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1182 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-150
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1183 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-151
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1184 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-152
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1185 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-153
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1186 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-154
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1187 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-155
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1188 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-156
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1189 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-157
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1190 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-158
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1191 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-159
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1192 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-160
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1193 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-161
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1194 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-162
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1195 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-163
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1196 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-164
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1197 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-165
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1198 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-166
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1199 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-167
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1200 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-168
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1201 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-169
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1202 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-170
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1203 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-171
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1204 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-172
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1205 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-173
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1206 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-174
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1207 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-175
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1208 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-176
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1209 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-177
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1210 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-178
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1211 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-179
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1212 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-180
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1213 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-181
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1214 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-182
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1215 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-183
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1216 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-184
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1217 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-185
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1218 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-186
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1219 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-187
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1220 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-188
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1221 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-189
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1222 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-190
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1223 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-191
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1224 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-192
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1225 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-193
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1226 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-194
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1227 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-195
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1228 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-196
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1229 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-197
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1230 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-198
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1231 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-199
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1232 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-200
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1233 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-201
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1234 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-202
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1235 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-203
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1236 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-204
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1237 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-205
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1238 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-206
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1239 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-207
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1240 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-208
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1241 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-209
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1242 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-210
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1243 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-211
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1244 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-212
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1245 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-213
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1246 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-214
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1247 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-215
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1248 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-216
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1249 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-217
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1250 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-218
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1251 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-219
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1252 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-220
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1253 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-221
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1254 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-222
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1255 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-223
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1256 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-224
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1257 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-225
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1258 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-226
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1259 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-227
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1260 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-228
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1261 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-229
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1262 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-230
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1263 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-231
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1264 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-232
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1265 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-233
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1266 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-234
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1267 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-235
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1268 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-236
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1269 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-237
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1270 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-238
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1271 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-239
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1272 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-240
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1273 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-241
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1274 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-242
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1275 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-243
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1276 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-244
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1277 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-245
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1278 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-246
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1279 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-247
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1280 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-248
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1281 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-249
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1282 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-250
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1283 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-251
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1284 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-252
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1285 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-253
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1286 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-254
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1287 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-255
Final EIR
September 2022
Redlands Regular Meeting of 10-18-22 1288 of 1815
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September 2022
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September 2022
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September 2022
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-260
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September 2022
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September 2022
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September 2022
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September 2022
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September 2022
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-266
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-267
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-268
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-269
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-270
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-271
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-272
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-273
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September 2022
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-275
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September 2022
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-277
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-278
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-279
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-280
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-281
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-282
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-283
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September 2022
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-286
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-287
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-288
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-289
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-290
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-291
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-292
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-293
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-294
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-295
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-296
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-297
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 2-298
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-299
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-300
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-301
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 2-302
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 2-303
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 2-304
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 2-305
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 2-306
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 2-307
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 2-308
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-309
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 2-310
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 2-311
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 2-312
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 2-313
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 2-314
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 2-315
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 2-316
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 2-317
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 2-318
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 2-319
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 2-320
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 2-321
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 2-322
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 2-323
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 2-324
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 2-325
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 2-326
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 2-327
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 2-328
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 2-329
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 2-330
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 2-331
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-332
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-333
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-334
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 2-335
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 2-336
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-337
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-338
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-339
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-340
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-341
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 2-342
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 2-343
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 2-344
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 2-345
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 2-346
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-347
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September 2022
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-349
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-350
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September 2022
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Redlands General Plan Transit Villages District and Specific Plan Project 2. Response to Comments City of Redlands 2-351
Final EIR
September 2022
Response to Letter O3: Mitchell M. Tsai, on behalf of the Southwest Regional Council of Carpenters, Received September 6, 2022
Comment O3.1: This comment introduces the comment letter, and that the commenter is writing on behalf of the Southwest Regional Council of Carpenters (“SWRCC”). This comment provides background on the SWRCC and Project and introduces the comment letter. Additionally, the comment requests the City notify the firm of any and all notices related to the proposed Project.

Response O3.1: The City will add Mitchell M. Tsai and SWRCC to the notification list for future updates regarding the Redlands General Plan Transit Villages District and Specific Plan Project. 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 O3.2: This comment states that the City should require the applicant to provide additional community benefits such as requiring local hire to build the Project. The comment further states that the use of local hire serves to reduce length of trips, decrease greenhouse gas (GHG) emissions, decrease air pollutants, decrease vehicle miles travelled (VMT), and provides localized economic benefits.

Response O3.2: 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. The requirements for local hire for all future development projects within the TVSP is not economically or realistically feasible as there is no data supporting the conclusion that there would be enough local construction workers to hire for all future construction projects within the TVSP. Therefore, pursuant to CEQA Guidelines Section 15041, mitigation requiring local hire provisions is not required for the Project.

However, implementation of the Project does not prohibit the use of local construction workers for future development projects within the TVSP. This comment does not provide substantial evidence of environmental impacts related to the Project that would require revision of the Draft EIR. As provided in the responses throughout this Final EIR, potential impacts have been adequately addressed and an updated EIR is not required.

Comment O3.3: This comment states that the City should require the Project to be built to standards exceeding the current 2019 California Green Building Code.

Response O3.3: 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. As such, the City is already requiring mitigation for implementing projects to be built to standards exceeding the current building code. This comment does not provide substantial evidence of environmental impacts related to the Project that would require revision of the Draft EIR.

Comment O3.4: This comment provides a background summary on the purpose of the CEQA and the function of an EIR.

Response O3.4: 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 O3.5: This comment provides a summary of when CEQA requires revision and recirculation of an EIR pursuant to Section 21092 of the California Public Resources Code. Additionally, the comment provides a description of what constitutes significant new information.

Response O3.5: As described throughout this Final EIR, no significant information has arisen that would require substantial changes to the Draft EIR requiring revision and recirculation pursuant to Section 21092 Redlands Regular Meeting of 10-18-22 1384 of 1815
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of the California Public Resources Code or Section 15088.5 of the CEQA Guidelines. Therefore, no further response is required or provided.

Comment O3.6: This comment states that the City must adopt a mandatory finding of significance that the Project may cause a substantial adverse effect on human beings and must mitigate COVID-19 impacts. The comment provides multiple measures to mitigate COVID-19 impacts.

Response O3.6: The COVID-19 pandemic is an existing condition of temporary significance and not a Project-specific impact. Effects of the environment on a project are not subject to CEQA review (Public Resources Code Sections 21065 and 21068). CEQA is generally not concerned with the effect the existing environment might have on proposed projects, and such effects are not treated as changes in the physical environment. See, e.g., California Bldg. Indus. Assn. v. Bay Area Air Quality Mgmt. Dist., 62 Cal. 4th 369, 378 (2015) (CEQA does not require analysis of impact that existing environmental conditions might have on project, its residents, or its users, except when required by specific statutory exception). Therefore, the City is not required to analyze the impact of COVID-19, an existing condition, on the Project. Moreover, in the absence of any applicable methodology, such an analysis would be speculative. Therefore, none of the proposed measures proffered by the commenter are warranted.

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 EIR includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include a discussion of COVID-19. 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 COVID-19 is not provided. The comment does not raise any CEQA issues, and no further response is required.

Comment O3.7: This comment requests that the City revise and recirculate the Project’s EIR to address the previous comments.

Response O3.7: As described throughout this Response to Comments, no significant information has arisen that would require substantial changes to the Draft EIR requiring revision and recirculation pursuant to Section 21092 of the Public Resources Code or CEQA Guidelines, section 15088.5. The letter does not provide any evidence of potential significant impacts from implementation of the Project. Therefore, no further response is required or provided.

Comment O3.8: This comment provides an introduction to the attached comment letter from SWAPE and states that the attachment provides a draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of GHG emissions.

This comment states the report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Response O3.8: 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 O3.9: This comment provides background information on the use and purpose of California Emissions Estimator Model (CalEEMod). The comment further provides information on how emissions, trip length, and VMT relate.

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Response O3.9: 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 O3.10: This comment provides technical information on default trip lengths within CalEEMod and how to calculate and justify trip lengths.

Response O3.10: The comment is informational in nature and does not raise concerns regarding 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 O3.11: This comment provides a summary of an example on the potential impact of local hire provisions on construction related GHG emissions utilizing the Village South Specific Plan in the City of Claremont. The comment states that for the example, the Project reduced the default trip length of 14.7 miles to 10 miles, which resulted in a decrease of GHG emissions by approximately 17%.

Response O3.11: As shown on page 10 of the CalEEMod Emissions Model Outputs attachment to Appendix E, Greenhouse Gas Analysis, to the Draft EIR, the trip length utilized for the proposed Project’s GHG analysis was 14.7 miles. As such, the construction modeling for GHG emissions contained in the Draft EIR provides a conservative and accurate estimate of potential GHG emissions resulting from buildout of the TVSP. Using this trip length, GHG emissions resulting from construction and operation of the proposed Project would be less than significant, as stated on page 5.6-12 of the Draft EIR. As such, not only does the Draft EIR provide a conservative analysis of potential GHG emissions resulting from construction of the proposed Project, that conservative analysis would result in emissions below the threshold set by the City of Redlands Climate Action Plan. Additionally, since GHG impacts would be less than significant from Project construction, pursuant to CEQA Guidelines Section 15126.4, subd. (a)(4)(A)–(B), there is no nexus between requiring local hire provisions and impacts from the proposed Project. Further, the analysis conducted by SWAPE does not present any substantial evidence of impacts not previously discussed in the Draft EIR.

Comment O3.11 and this response will be forwarded to all decision-making bodies to inform their decision on the Project. No further response is warranted.

Comment O3.12: This comment provides a conclusion to the SWAPE letter attachment and states that SWAPE retains the right to revise or amend this report when additional information becomes available.

Response O3.12: The comment is general in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. None of the analysis or modeling presented by SWAPE provides any substantial evidence of impacts not previously discussed in the Draft EIR. The comment letter presents information about how local hire has been utilized by other development projects but does not raise any specific issues about the adequacy of the Draft EIR. As described throughout this Response to Comments, no significant information has arisen that would require substantial changes to the Draft EIR requiring revision and recirculation pursuant to Section 21092 of the Public Resources Code or CEQA Guidelines, section 15088.5. The letter does not provide any evidence of potential significant impacts from implementation of the Project. Therefore, no further response is required or provided.

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LETTER I15: Hazel Fuller (1 page)
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Response to Letter I15: Hazel Fuller, received September 6, 2022 Comment I15.1: This comment states that the commenter needs more time to respond as they just heard about the Project today and requests that the comment date be extended.

Response I15.1: 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 (a total of 48 calendar days). 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.

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LETTER I16: Lisa Pierce (1 page)
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Response to Letter I16: Lisa Pierce, Received September 6, 2022 Comment I16.1: This comment states that the public review time was not long enough for residents to comment on the Draft EIR and the commenter was not aware of any public review events during evening hours.

Response I16.1: 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 (a total of 48 calendar days). 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 I16.2: This comment states that the Draft EIR has multiple inconsistencies and lacks a professional interpretation of what “no impacts” means. The comment states that the public review period should be extended to allow more public input as the document is unfinished.

Response I16.2: As discussed on page 5-2 of the Draft EIR, the below classifications are used throughout the impact analysis in this Draft EIR to describe the level of significance of environmental impacts. Although the criteria for determining significance are different for each topic area, the environmental analysis applies a uniform classification of the impacts based on definitions consistent with CEQA and the CEQA Guidelines.
• No Impact. The Project would not change the environment. • Less Than Significant. The Project would not cause any substantial, adverse change in the environment.
• Less Than Significant with Mitigation Incorporated. The Draft EIR includes mitigation measures that avoid substantial adverse impacts on the environment. • Significant and Unavoidable. The Project would cause a substantial adverse effect on the environment, and no feasible mitigation measures are available to reduce the impact to a less than significant level.

The commenter does not refer to specific inconsistencies in the Draft EIR document or areas where impact determinations are unclear. In regard to the public review period, the commenter is referred to Response I16.1, and a total of 48 calendar days were provided for public review and comment (exceeding the CEQA requirement for 45 days). The comment provides the commenter’s opinion 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 I16.3: This comment states that the Project requires community participation for a fair vision of what the city should look like in the future. The comment states that if the City is concerned about development being consistent with community vision, an advisory committee of citizens should be formed.

Response I16.3: The City currently has a Planning Commission, which is comprised of local residents (appointed by the City Council), who review development projects as they are proposed to ensure that future projects are consistent with City design regulations and requirements. The draft Transit Villages Specific Plan was prepared after an extensive public participation and community outreach effort, including nine community workshops open to the public (over a period of nine months) plus several meetings of the City Council and Planning Commission (over a period exceeding two years). 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.

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LETTER I17: Bettina McLeod (4 pages)
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Response to Letter I17: Bettina McLeod, Received September 7, 2022 Comment I17.1: This comment states that the commenter previously sent a message that did not go through so the commenter resent the comments and hopes they will be accepted.

Response I17.1: 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 I17.2: This comment states that there are aspects of the plan that the commenter supports, such as the maximum height being reduced from 5 stories to 4 stories, the plans for a tree canopy, walkability, bike paths, mixed-use, and plantings along the Zanja, among others. The comment states that the attempt to get more aesthetically pleasing architecture by requiring offsets for new buildings is appreciated, but the commenter is not sure it will work.

Response I17.2: The comment provides the commenter’s opinion 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 I17.3: This comment states that the TVSP recognizes Redlands unique history, historical architecture, and community input, but there are no teeth behind its statements and the increase in height, increase in building densities, and changes in zoning are all incentives to demolish old buildings. The comment states that more protection is needed for historic buildings and there should be incentives for old homes to be adaptively reused. The comment states that older homes can be adaptively reused for restaurants or small shops. In addition, the comment states that old homes are built with old growth trees that should be preserved.

Response I17.3: 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 addition, as described in the proposed TVSP, development within the TVSP area shall be based on the historic architectural styles found throughout the proposed villages. Furthermore, buildings adjacent to historic structures shall be designed in a manner that safeguards the prominence and integrity of the historic structure, as detailed in the Secretary of the Interior’s Standards and the City’s design guidelines for historic resources. Additionally, the proposed TVSP sets forth restrictions for historic residential structures, as listed below to support the preservation of historic resources. Historic residential structures are subject to the following provisions:

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

2. Buildings on project sites located immediately adjacent to lots (i.e., that share side or rear property lines) that have designated or eligible historic structures on them shall be designed per the requirements of this Specific Plan and per the recommendations of the Secretary of the Redlands Regular Meeting of 10-18-22 1395 of 1815
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Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings s and/or the Redlands Historic Architectural Design Guidelines.

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.

Comment I17.4: This comment states that former Mayor Paul Foster told other City Council members that the citizens of Redlands have repeatedly voiced their opinion that they do not want tall buildings that change the small town charm of Downtown Redlands. The comment states that the former mayor advised the City Council not to approve projects with taller buildings until after the November vote.

Response I17.4: As discussed on page 5.1-12 of the Draft EIR, TVSP Chapter 4, Development Code, provides detailed regulations for development and new land uses within the TVSP area, and describes how these regulations would be used as part of the City’s development review process. These provisions supersede and replace regulations under the City of Redlands Zoning Code (Title 18 of the Municipal Code). Where specific provisions are not set forth for development standards within the TVSP, or where otherwise applicable requirements of the Zoning Code are not covered by the TVSP Development Code, implementing projects within the TVSP area would be subject to current or future Municipal Code regulations. However, while regulations within the TVSP supersede regulations set forth by the current Municipal Code, the majority of regulations align with the development standards set forth throughout the Municipal Code. For example, the R-3 Multiple Family Residential District set forth in Chapter 18.60 of the Municipal Code allows for development of buildings and structure with a height of no greater than four stories. As discussed in Section 3, Project Description, of this Draft EIR, buildings within the Village Center (VC) district would have a maximum height of four stories and buildings within the Village General (VG) district would be required to have an average height of three stories. The draft Transit Villages Specific Plan was prepared after an extensive public participation and community outreach effort, including nine community workshops open to the public (over a period of nine months) plus several meetings of the City Council and Planning Commission (over a period exceeding two years). The general public offered significant input on the desired building height standards, which was incorporated into the Draft TVSP, and is reflected in the proposed TVSP development standards.

Therefore, the new building standards, such as those for building height, provided for by the TVSP would largely remain consistent with existing Municipal Code development standards. 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.

Comment I17.5: This comment states that the City Council should create an advisory committee of concerned citizens to offer new ideas and review/critique future projects as they come forward.

Response I17.5: The City currently has a Planning Commission, which is comprised of local residents (appointed by the City Council), who review development projects as they are proposed. 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 I17.6: This comment states that Downtown has potential to generate more tax revenue so the commenter is surprised that new buildings could be all retail, all office, or all residential near the train station and there is no requirement for the first floor to be retail. The comment states that there should be retail on the bottom floors with interesting store fronts.

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Response I17.6: The comment provides the commenter’s opinion 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 I17.7: This comment states that the commenter is pleased with how the City of Claremont’s new Village West blends with the feeling of the older downtown and that they hope that something similar can be achieved for Redlands. The comment also suggests that the Zanja should be landscaped on the south side and there should be cafes and restaurants with outdoor dining, but now the area is shown for residential.

Response I17.7: As shown on Draft EIR Figure 3-8, Regulating Plan, areas along the Zanja would be designated as Village Center, Village General, and Neighborhood General 2. As further described in Draft EIR Section 3, all three of these districts would allow for commercial uses, such as restaurants, to be developed. The comment provides the commenter’s opinion 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 I17.8: This comment states that it is unfortunate that people who live in areas whose properties will be impacted were not notified of this plan. The comment states that the City did not let property owners know about this plan and gave a small window of opportunity for people to make comments. The comment states that the TVSP boundary should exclude all of Smiley Park Historic District and Sacred Heart, as the TVSP should not allow commercial uses in these primarily residential areas.

Response I17.8: 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. A Notice of Availability for the Draft EIR was posted on the City’s website and published in the July 21, 2022 edition of the Redlands Daily Facts. Therefore, residents within the City were adequately notified of the Project pursuant to CEQA requirements. 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 I17.9: This comment states that the Draft EIR has contradictory statements about where residential dwelling units can go. The comment summarizes a statement from Draft EIR Section 5.11, Population and Housing, that discusses where housing is currently allowed in the Downtown Transit Village.

The comment includes a summary of the Project Description stating Project including development of multifamily residential uses between Eureka Street, Texas Street, Stuart Avenue, and State Street and states that this area is already developed with commercial uses. The comment further states that areas right next to train stations could be all residential while they should have ground floor commercial.

Response I17.9: The commenter erroneously refers to the Environmental Setting Discussion in Draft EIR Section 5.11, which actually states that multi-family residential uses are currently allowed in the Downtown Transit Village area under the current General Plan and zoning designations. As discussed in Draft EIR Section 3, Project Description, the Project provides a 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. It is anticipated that individual development projects on privately-owned parcels would occur incrementally and over an extended period of time (i.e., infill development) such as the 20-year or longer lifespan of the TVSP. Multi-family and single-family residential uses would be allowed in the Village Center, Downtown, Village General, Village Corridor, Village Neighborhood 1, and Village Neighborhood 2 districts throughout the New York Street/Esri Village, Downtown Transit Village, and University Village. The Draft EIR provides a Redlands Regular Meeting of 10-18-22 1397 of 1815
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programmatic analysis of buildout of the TVSP with 2,400 residential units, but does not assign units to specific sites, as future development is unknown. 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.

Comment I17.10: This comment states that the TVSP document contradicts itself in regard to where residential uses will be placed. The comment also states that the Mall Project, City Center project, and The Grand Project are moving forward for a total of 977 dwelling units, which is nearly half of the units projected by the TVSP. The comment questions why all units are being crammed in Downtown and states that the TVSP is not ready to be approved in its current form.

Response I17.10: The Redlands Mall redevelopment project (State Street Village), City Center Project, and The Grand project, which the commenter is referring to, are distinct projects with their own sets of requested entitlements under the current General Plan and zoning designations in place.

The commenter erroneously refers to the Environmental Setting Discussion in Draft EIR Section 5.11, which actually states that multi-family residential uses are currently allowed in the Downtown Transit Village area under the current General Plan and zoning designations. 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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Chapter 3. Revisions to the Draft EIR
This section contains revisions to the Draft EIR based upon: (1) clarifications required to prepare a response to a specific comment; and/or (2) typographical errors. The provision of these revisions does not alter any impact significance conclusions as disclosed in the Draft EIR. Changes made to the Draft EIR are identified here in strikeout text to indicate deletions and in underlined text to signify additions.

3.1 Revisions in Response to Written Comments and City Changes to Text The following text has been revised in response to comments received on the Draft EIR and corrections identified by the City.

Section 1, Executive Summary
Table 1-1, Summary of Impacts, Mitigation Measures, and Level of Significance, on Page 1-42 is revised as follows:

5.8 Hydrology and Water Quality
Impact WQ-2: The Project would not
substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin.

None Less than significant None required Less than significant Impact WQ-3i: The Project would not
substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition
of impervious surfaces, in a manner
which would result in a substantial
erosion or siltation on- or off-site.

PPP HYD-1 National Pollutant
Discharge Elimination System
(NPDES). Projects will be
constructed in accordance with the
NPDES General Permit for Storm
Water Discharges Associated with
Construction and Land Disturbance
Activities, NPDES No. CAS000002.

Compliance requires a risk
assessment, a SWPPP, and
associated BMPs.

PPP HYD-23 Santa Ana RWQCB
MS4 Permit. Projects will be
constructed and operated in
accordance with the Santa Ana
RWQCB Municipal Stormwater
(MS4) Permit for the part of the
Santa Ana Basin in San Bernardino
County in 2010 (Order No. R8-
2010-0036). The MS4 Permit
requires new development and
redevelopment projects to adopt a
WQMP to:
• Control contaminants into storm
drain systems
• Educate the public about
stormwater impacts
• Detect and eliminate illicit
discharges
• Control runoff from construction
sites
Less than significant None required Less than significant Impact WQ-3ii: The Project would not
substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition
of impervious surfaces, in a manner
which would substantially increase the
rate or amount of surface runoff in a
manner which would result in flooding
on- or off-site.

Less than significant None required Less than significant Impact WQ-3iii: The Project would not
substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition
of impervious surfaces, in a manner
which would create or contribute runoff
water which would exceed the capacity
of existing or planned stormwater
drainage systems or provide substantial
additional sources of polluted runoff.

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• Implement BMPs and sitespecific runoff controls and
treatments
Section 5.2, Air Quality
Paragraph 2, under Threshold AQ-2, on Page 5.2-20 is revised as follows:

As shown in Table 5.2-7, emissions resulting from construction would exceed criteria pollutant thresholds for VOC and NOx. Development projects would be required, through City review and construction permitting, to implement SCAQMD rules, including: Rule 401, Rule 402, Rule 403, Rule 481, Rule 1108, Rule 1113, and Rule 1143 (described previously) that would reduce construction related emissions. Also, Mitigation Measures AQ-1 through AQ-67 are included to require the construction activities to utilize “Super-Compliant” low VOC paints that have no more than 10g/L of VOC, which exceeds the regulatory VOC limits put forth by SCAQMD’s Rule 1113, require all construction equipment greater than 150 horsepower (>150 HP) to be CARB certified tier 3 or higher, use of electrical and alternative fueled equipment, and other similar measures. With implementation of Mitigation Measures AQ-1 through AQ-6, emissions of VOC and NOx from construction activities would be reduced and emissions from most TVSP developments would be reduced to below the SCAQMD significance thresholds. However, due to the potential overlap of development projects and construction activities, it cannot be assured that the mitigation measures would reduce emissions below the SCAQMD significance thresholds. As shown in Table 5.2-7, VOC emissions have the potential to be 7.9 times higher than the threshold, and NOX emissions have the potential to be over 3.8 times higher than the threshold, with this level of potential emissions exceedances during overlapping construction projects, construction emissions could continue to exceed thresholds with implementation of Mitigation Measures AQ1 through AQ-6. Therefore, based on the very conservative scenario of construction timing and construction equipment use, impacts related to construction emissions would remain significant and unavoidable.

Section 5.3, Cultural Resources
Section 5.3.3, Environmental Setting, on Page 5.3-8 is revised as follows:

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

Eleven properties have been determined ineligible for listing or designation and 13 properties have not been evaluated for NR or NR or need evaluation. Additional research provided by the Redlands Area Historical Society identified over 100 additional properties which are of historic era but have not yet been evaluated as to their significance for local, state, or federal registers. In addition, there are two historic districts located within the TVSP area, the Smiley Park Historic District and Santa Fe Depot Historic District, as outlined on Table 5.3-2.

Table 5.3-2, List of Historical Properties within TVSP Area, on Pages 5.3-8 through 5.3-11 is revised as follows:

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Name Address APNs NR/CR Eligibility City List of
Historic
Resources
Smiley Park Historic District
Michigan, Buena Vista,
Parkwood, Alvarado,
Grant, Eureka, Fourth,
and Cajon Streets
between Palm, Cypress,
Home Place, Fern, Clark,
Olive, Vine, and
Brookside Streets Multiple 1S
n/a 251 S Fourth St 017-132-422 SPHD, HD8
n/a 255 S Fourth St 017-132-401 SPHD, HD8
S.F. Home 529 Bonita 017-013-121 Unevaluated
n/a U.S. Post Office 201 Brookside Ave 017-125-107 5S2
n/a 302 Brookside 017-120-313 Unevaluated HR81
Theron’s Marketplace n/a 122 Cajon St 017-129-204 5S2
Fox Theater n/a 123 Cajon St 017-130-103 5S2
Masonic Temple Charles G. Rohrer
House 131 Cajon St 017-130-102 5S2
Avery/Mock Home n/a 215 Cajon St 017-133-109 1D, 5S2
J.W. Barrow’s Home n/a 243 Cajon St 017-133-104 1D, 5S2 n/a 248 Cajon St 017-132-417 6X
n/a 256 Cajon St 017-132-418 1D
n/a 261 Cajon St 017-133-101 1D, 5S2
A Harvey Collins House, Trolley Car
Barn 746 E Citrus Ave 017-134-217 7N, NR, HL27 HL27
Cope Commercial Building 19 E Citrus 017-121-103 Unevaluated Provident Bank Building 125 E. Citrus 017-112-218 Unevaluated n/a 415 W Citrus 017-121-110 Unevaluated
n/a 423 W Citrus 017-121-108 Unevaluated
n/a 527 W Citrus 017-120-302 Unevaluated
n/a 509 Division 017-013-214 Unevaluated
n/a 615 Division 017-007-222 Unevaluated
Chamber of Commerce 47 N. First 017-103-401 Unevaluated HR129 First Methodist Church Gold Banner
Packing, Packing House Antiques 1 E Olive Ave
017-130-111
7N
Star Grocery
1 E State St Redlands
Blvd
017-106-121
5S2
Redlands Photographers 109 E State St 017-106-206 5S2
n/a 112 E State St 033-123-204 5S2
Frame N Lens 101 E Olive Ave 017-128-125 5S2
Underpinnings 219 E Olive Ave 017-132-212 5S2
n/a 255 E Olive Ave 017-128-129 5S2
McMahan's 37 E Olive Ave 017-130-109 5S2
Rose of Sharon Salon 21 E Redlands Blvd 016-930-110 5S2 Redlands Regular Meeting of 10-18-22 1402 of 1815
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Name Address APNs NR/CR Eligibility City List of
Historic
Resources
Goodie Shop 214 E Redlands Blvd 017-107-109 5S2
Children’s Carousel
215 E Redlands Blvd
State St
017-106-102
7N
n/a 1 E State St 017-106-121 5S2
Citrograph house 10 E State St 017-112-106 5S2
J.C. Penney 104 E Olive Ave State St 017-112-216 5S2
Sligers Music
1089 E Olive Ave State
St
017-106-206
5S2
n/a 124 E Olive Ave 017-133-230 5S2
L And T Hobby 204 E Olive Ave 017-133-312 5S2
Pizza Chalet
208 E Olive Ave 120 E
State St
017-112-213
5S2
Armory Building 617 Texas Street 016-912-110 Unevaluated Greg Wolfin Co. Grocery 213 E Olive Ave 017-128-128 5S2 Branch-Cooch Real Estate, Wilmouth
House 214 E Olive Ave
017-133-314
5S2, SPHD, HR26
Patio Shop 215 E Olive Ave 017-128-115 5S2, SPHD, HD8
Norris House 110 E State St 017-112-217 5S2
Medical Arts Building, Courtyard
137 E Vine St 113 E
State St
017-127-211
5S2
Redlands Motorcycle Club, Redlands
Copies And Card
150 E Vine St 114 E
State St
017-130-108
5S2
J.W. Hollett House 122 E State St 017-112-214 7N
Frank Meyer House 27 E State St 017-106-101 7N
Mission Gables Apartments
168 Eureka St 117 E
State St
017-124-430
1D, 7N
E.D. Donham 120 E State St 017-112-213 7R
n/a 12 E State St 017-112-106 Unevaluated
Old Burrough’s Building 103 E State S 033-123-335 Unevaluated W.P. Griffitts House 14 E State St 017-112-115 7N
Walter Lynn House 15 E State St 017-107-103 7N
Daniel Cotcher House 17 E State St 017-106-103 7N
Dr. M. M. Horton House 18 E State St 017-112-114 7N
n/a 2 E State St 035-602-103 5S2
n/a 200 E State St 017-113-117 Unevaluated HR91
n/a 204 E State St 017-113-133 5S2
n/a 22 E State St 017-112-109 5S2
n/a Buster Building 24 E State St 017-112-110 5S2, HR33 HR33 Roc N Fondue n/a 25 E State St 017-106-102 5S2
Baster Building n/a 28 E State St 017-112-110 5S2
Sunset Funeral Care 305 W State St 017-110-116 Unevaluated Cousin House 430 E State St 017-108-713 5S2
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Name Address APNs NR/CR Eligibility City List of
Historic
Resources
n/a 508 W State St 017-103-116 Unevaluated
n/a 6 E State St 017-112-113 5S2
n/a 609 E State St 017-108-515 5S2
n/a 150 E Vine St 017-130-108 5S2
n/a 804 E High Ave 017-013-111 Unevaluated
n/a 805 E High Ave 017-007-235 Unevaluated
n/a 807 E High Ave 017-007-234 Unevaluated
n/a 809 E High Ave 017-007-233 Unevaluated HR92
n/a 813 E High Ave 017-007-231 Unevaluated
n/a 814 E High Ave 017-013-205 Unevaluated
n/a 817 E High Ave 017-007-230 Unevaluated
n/a 819 E High Ave 017-007-229 Unevaluated
n/a 831 E High Ave 017-007-228 Unevaluated
n/a 839 E High Ave 017-007-226 Unevaluated
n/a 842 E High Ave 017-013-233 Unevaluated
n/a 845 E High Ave 017-007-225 Unevaluated
n/a 851 E High Ave 017-007-224 Unevaluated
n/a 856 E High Ave 017-013-212 Unevaluated
n/a 857 E High Ave 017-007-223 Unevaluated
n/a 861 E High Ave 017-007-222 Unevaluated
n/a 866 E High Ave 017-013-213 Unevaluated
n/a 915 E High Ave 017-008-213 Unevaluated
n/a 919 E High Ave 017-008-212 Unevaluated
n/a 931 E High Ave 017-008-211 Unevaluated
n/a 935 E High Ave 017-008-210 Unevaluated
n/a 15 Kendall St 017-120-312 Unevaluated
n/a 18 Kendall St 017-121-101 Unevaluated
n/a 20 Kendall St 017-121-102 Unevaluated
n/a 21 Kendall St 017-120-311 Unevaluated
n/a 23 Kendall St 017-120-310 Unevaluated
n/a 24 Kendall St 017-121-103 Unevaluated
n/a 25 Kendall St 017-120-309 Unevaluated
n/a 26 Kendall St 017-121-104 Unevaluated
n/a 29 Kendall St 017-120-308 Unevaluated
n/a 33 Kendall St 017-120-342 Unevaluated
n/a 34 Kendall St 017-121-105 Unevaluated
n/a 40 Kendall St 017-121-106 Unevaluated
n/a 41 Kendall St 017-120-305 Unevaluated
n/a 45 Kendall St 017-120-304 Unevaluated
I.N. Hoag House 816 E High Ave 017-013-206 Unevaluated HR13 HR13 Redlands Regular Meeting of 10-18-22 1404 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 3. Revisions to the Draft EIR City of Redlands 3-6
Final EIR
September 2022
Name Address APNs NR/CR Eligibility City List of
Historic
Resources
n/a 611 Lawton St 016-913-125 Unevaluated
Charles Midgley House 612 Lawton St 016-914-126 7N
n/a 615 Lawton St 016-913-135 Unevaluated
Ferndinand Montiegel House 214 Myrtle St 017-133-317 7N C.J. Crafts House 14 N 5th St 017-112-209 7N
Charles A. Nicholas House 345 N 5th St 016-930-101 7N
n/a 220 Nordina St 017-133-113 7N
Redlands Santa Fe Depot Historic
District Orange St Multiple 1S
Pioneer Transfer 348 (1001) Orange St 016-930-128 1D, 3D, SFDD Atchison, Topeka, and Santa Fe
Railway Redlands Station 108 Orange St 017-106-129 1D,3B,7P C.C. McCarty House 1101 Orange St 016-729-424 1D, 3D, HR82 HR82 Packard Motor Company Sales Office,
Coast Federal 415 (1157) Orange St 016-729-413 1D, SFDD Home Oil Company 118 Orange St 017-106-113 5S2
E F Edwards Photography Shop 120 Orange St 017-106-113 5S Lombard Building, Hamilton Block 206 Orange St 016-930-115 5S2, SFDD Levine’s 208 Orange St 016-930-116 SFDD, 6Y
Gregg Block 216 Orange St 016-930-131 SFDD, 5S2
Phinney Block 220 Orange St 016-930-119 SFDD, HL34, 5S HL37 E.J. Martin Home and Nursery 328 Orange St 016-930-121 SFDD, 6X1 Gregory Packing House, Hamilton Block 330 Orange St 016-930-122 SFDD, 3D, 6X 203 Oriental Ave, Beacon Printery 336 Orange St 016-930-123 SFDD, 6X Redland Fruit Association Warehouse,
Worley Bldg 338 Orange St
016-930-124
SFDD, 1D
Poundstone & Hamilton Building,
Oriental Street 342 Orange St
016-930-125
SFDD, HL37, 7R
Palace Livery Stable 346 Orange St 016-930-127 SFDD, 5S2 Santa Fe Railroad Station 347 351 Orange St 016-928-139 SFDD, 5S2 Pioneer Transfer, Nordoff Home 348 Orange St 016-930-128 SFDD, 3S, 7P Redlands City Transfer, Lite House,
Wade House 360 Orange St 016-930-129 SFDD, 1D, 7N
Kohlman House, Packard Motor Co.

Sales Office 415 Orange St 016-928-143 SFDD. 6X
n/a 418 Orange St 016-921-221 1D, 7N
Willard And Alice Cannady House 501 Orange St 016-920-135 1D n/a Kimberly Crest 921 Orange St 016-906-512 1C, 1D, 3S Pergola, Major David Shaw House 928 Orange St 016-907-206 HR75, 6X HR75 Semi-Circular Pergola 930 Orange St 016-907-207 1CL, 1D n/a La Casada, Edward C Sterling
Mansion 812 Stillman Ave 017-007-209 3S
n/a 903 Stillman Ave 017-008-116 Unevaluated
Redlands Regular Meeting of 10-18-22 1405 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 3. Revisions to the Draft EIR City of Redlands 3-7
Final EIR
September 2022
Name Address APNs NR/CR Eligibility City List of
Historic
Resources
n/a 904 Stillman Ave 017-008-201 Unevaluated
n/a 908 Stillman Ave 017-008-202 Unevaluated
n/a 909 Stillman Ave 017-008-115 Unevaluated
n/a 915 Stillman Ave 017-008-114 Unevaluated
n/a 919 Stillman Ave 017-008-113 Unevaluated
n/a 921 Stillman Ave 017-008-112 Unevaluated
n/a 923 Stillman Ave 017-008-111 Unevaluated
n/a 931 Stillman Ave 017-008-110 Unevaluated
n/a 819 E. Sylvan Blvd 017-013-228 Unevaluated
n/a 831 E. Sylvan Blvd 017-013-217 Unevaluated
n/a 835 E. Sylvan Blvd 017-013-230 Unevaluated
n/a 837 E. Sylvan Blvd 017-013-225 Unevaluated
n/a 839 E. Sylvan Blvd 017-013-227 Unevaluated
n/a 841 E. Sylvan Blvd 017-013-232 Unevaluated
n/a 845 E. Sylvan Blvd 017-013-215 Unevaluated
Ben Cave Home 322 E The Terrace 016-918-209 Unevaluated n/a 610 E The Terrace 016-919-209 Unevaluated
n/a 616 E The Terrace 016-919-210 Unevaluated
WD Clark Home 702 E The Terrace 016-919-211 Unevaluated Harry Gregory Home 710 E The Terrace 016-919-212 Unevaluated n/a 107 W Colton Ave 016-920-202 1D
n/a 806 E Colton Ave 017-007-107 Unevaluated
n/a 808 E Colton Ave 017-007-108 Unevaluated
n/a 810 E Colton Ave 017-007-109 Unevaluated
n/a 812 E Colton Ave 017-007-110 Unevaluated
n/a 814 E Colton Ave 017-007-111 Unevaluated
n/a 816 E Colton Ave 017-007-112 Unevaluated
n/a 818 E Colton Ave 017-007-113 Unevaluated HR54
n/a 1000 E Colton Ave 017-008-104 Unevaluated
n/a 1006 E Colton Ave 017-008-105 Unevaluated
n/a 1012 E Colton Ave 017-008-106 Unevaluated
n/a 1016 E Colton Ave 017-008-107 Unevaluated
n/a 603 W Colton Ave 016-914-210 Unevaluated
n/a 402 W Colton Ave 016-904-610 Unevaluated
n/a 320 W Colton Ave 016-905-315 Unevaluated
n/a 314 W Colton Ave 016-905-314 Unevaluated HR110
n/a 310 W Colton Ave 016-905-313 Unevaluated
n/a 306 W Colton Ave 016-905-312 Unevaluated
n/a 224 W Colton Ave 016-905-611 Unevaluated
n/a 222 W Colton Ave 016-905-610 Unevaluated
Redlands Regular Meeting of 10-18-22 1406 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 3. Revisions to the Draft EIR City of Redlands 3-8
Final EIR
September 2022
Name Address APNs NR/CR Eligibility City List of
Historic
Resources
n/a 214 W Colton Ave 016-905-609 Unevaluated
n/a 201 W Colton Ave 016-915-403 Unevaluated
n/a 127 W Colton Ave 016-915-406 Unevaluated
n/a 126 W Colton Ave 016-906-314 Unevaluated
n/a 120 W Colton Ave 016-906-313 Unevaluated
n/a 115 W Colton Ave 016-920-201 Unevaluated
n/a 114 W Colton Ave 016-906-316 Unevaluated
n/a 108 W Colton Ave 016-906-317 Unevaluated
n/a 39 W Colton Ave 016-920-204 Unevaluated
Gold Banner Packing House
(Honda/Yamaha) 215 E Redlands Blvd
016-931-204
Unevaluated
ESRI Learning Center 757 W Redlands Blvd 017-103-106 Unevaluated J.H. Logie House 206 W Colton Ave 016-905-607
1D, 5S2, SPHD,
HD8 HD8
n/a 208 W Colton Ave 016-905-608 1D, 5S2
W.F. Holt House 450 2 W Olive Ave 017-123-324 1D, 3S
C.C. Ames House 24 W Olive Ave 017-129-207 1D, 5S2
n/a 329 W State St 017-110-106 5S2
Cope Commercial Co. Warehouse 21 W Stuart Ave 016-928-120 1D, SFDD Rettig Machine Shop (demolished) 205 W Stuart Ave 016-928-167 2B Property Acquisition And Rehabilitation 816 Clay St 016-906-315 6Y, 5S2 n/a 411 N University St
017-014-207,
-208, -209, -
210 HR124
Second Baptist Church 4280 E Stuart Ave 016-923-514 Significant Historic Properties (City of
Redlands 2017b)
First Presbyterian Church 100 Cajon St 017-129-218 2S2
n/a 816 Clay St 5S2
n/a 1131 Columbia St 016-728-317 6Y
n/a 812 Stillman Ave 017-007-209 6Y
Old Chamber of Commerce 347 Orange St 016-928-139 HL 40 Deming Building 526-528 Orange St 016-921-218 Local Listing Joseph E. Brown House 124 Eleventh St 017-108-606 HR63
n/a 314 W Colton Ave 016-905-314 HR110
Reasoner Residence 620 W Colton Ave 016-903-612 HR83
Boettger House 809 E High Ave 017-007-233 HR92
William Risch House 47 First St 017-103-401 HR129
n/a 30 Cajon St 017-129-204 HR109
YMCA Building 201 Cajon St 017-133-110 HD8 HR91
n/a 237 S Fourth St 017-132-406 HD8
n/a 254 S Fourth St 017-132-321 HD8
Redlands Regular Meeting of 10-18-22 1407 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 3. Revisions to the Draft EIR City of Redlands 3-9
Final EIR
September 2022
Source: MCC, 2022, Appendix C.

Section 5.12, Public Services
Section 5.12.3, Environmental Setting, on Page 5.12-4 is revised as follows:

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, 9180 sworn officers and 58 full and part-time civilians, resulting in a service level of 1.2312 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.

Threshold PS-2, on Page 5.12-7 is revised as follows:

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, 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. 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.

Whether the City chooses to construct new police 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, Therefore, impacts to police protection facilities would be less than significant.

Section 5.13, Recreation
Section 5.13.8, Existing Regulations, Standard Conditions, and Plans, Programs, or Policies, on Page

5.13-5 is revised as follows:

PPP PS-21: 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.

Section 5.16, Utilities and Service Systems
Section 5.16.2.2, Water Environmental Setting, on Page 5.16-3 is revised as follows:

Redlands Regular Meeting of 10-18-22 1408 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 3. Revisions to the Draft EIR City of Redlands 3-10
Final EIR
September 2022
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.

MUED 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.

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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-1
Final EIR
September 2022
Chapter 4. Mitigation Monitoring and Reporting
Program

4.1 Introduction
The California Environmental Quality Act (CEQA) requires a lead or public agency that approves or carries out a project for which an Environmental Impact Report has been certified which identifies one or more significant adverse environmental effects and where findings with respect to changes or alterations in the project have been made, to adopt a “…reporting or monitoring program for the changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment” (CEQA, Public Resources Code Sections 21081, 21081.6).

A Mitigation Monitoring and Reporting Program (MMRP) is required to ensure that adopted mitigation measures are successfully implemented for the Redlands General Plan Transit Villages District and Specific Plan Project (Project). The City of Redlands is the Lead Agency for the Project and is responsible for implementation of the MMRP. This report describes the MMRP for the Project and identifies the parties that will be responsible for monitoring implementation of the individual mitigation measures in the MMRP.

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

The MMRP also includes a column that will be used by the compliance monitor (individual responsible for monitoring compliance) to document when implementation of the measure is completed. As individual Plans, Programs, Policies; and mitigation measures are completed, the compliance monitor will sign and date the MMRP, indicating that the required actions have been completed.

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Final EIR
September 2022
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Final EIR
September 2022
TABLE 4-1: MITIGATION MONITORING AND REPORTING PROGRAM

THE REDLANDS GENERAL PLAN TRANSIT VILLAGES DISTRICT AND SPECIFIC PLAN PROJECT EIR Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials

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

In Construction Plans and
Specifications. Prior to
Building Permits.

City of Redlands Building
and Safety Division

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

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

In Construction Plans and
Specifications. Prior to
Building Permits.

City of Redlands Building
and Safety Division
MM AQ-3: Electric Construction Equipment. Construction plans and specifications and construction permitting for developments within the TVSP area shall include the requirement that contract specifications for construction activities rely on the electricity infrastructure surrounding the construction site, In Construction Plans and
Specifications. Prior to
Demolition Permits
City of Redlands Building
and Safety Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-4
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
if available rather than electrical generators powered by internal combustion engines.

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

In Construction Plans and
Specifications. Prior to
Demolition Permits
City of Redlands Building
and Safety Division
MM AQ-5: Construction Equipment Maintenance. Construction plans and specifications and construction permitting for developments within the TVSP area shall include the requirement that construction equipment be maintained in good operating condition pursuant to manufacturer specifications to reduce emissions. The Construction Contractor shall ensure that all construction equipment is being properly serviced and maintained as per the manufacturer’s specification. Maintenance records shall be available at the construction site for City verification.

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

In Construction Plans and
Specifications. Prior to
Demolition Permits
City of Redlands Building
and Safety Division
MM AQ-7: Enhanced Energy Efficiency. Prior to the issuance of building permits, the Project applicant shall submit energy usage calculations to the Planning Division showing that the Project is designed to achieve 5 percent (%) efficiency beyond the incumbent California Building Code Title 24 requirements. Example of measures that reduce energy consumption include, In Construction Plans and
Specifications. Prior to
Building Permits
City of Redlands Building
and Safety Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-5
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
but are not limited to, the following (it being understood that the items listed below are not all required and merely present examples; the list is not allinclusive and other features that reduce energy consumption also are acceptable):
• Increase in insulation such that heat transfer and thermal bridging is minimized;
• Limit air leakage through the structure and/or within the heating and cooling distribution system;
• Use of energy-efficient space heating and cooling equipment; • Installation of electrical hook-ups at loading dock areas; • Installation of dual-paned or other energy efficient windows; • Use of interior and exterior energy efficient lighting that exceeds then incumbent California Title 24 Energy Efficiency performance standards;
• Installation of automatic devices to turn off lights where they are not needed;
• Application of a paint and surface color palette that emphasizes light and off-white colors that reflect heat away from buildings; • Design of buildings with “cool roofs” using products certified by the Cool Roof Rating Council, and/or exposed roof surfaces using light and off-white colors;
• Design of buildings to accommodate photo-voltaic solar electricity systems or the installation of photo-voltaic solar electricity systems; Installation of ENERGY STAR-qualified energy-efficient appliances, heating and cooling systems, office equipment, and/or lighting products.

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Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
MM AQ-8: Enhanced Water Conservation. To reduce water demands and associated energy use, subsequent development proposals within the TVSP area shall incorporate a Water Conservation Strategy and demonstrate a minimum 30% reduction in outdoor water usage when compared to baseline water demand (total expected water demand without implementation of the Water Conservation Strategy). Development proposals within the TVSP area shall also implement the following:
• Landscaping palette emphasizing drought tolerant plants; • Use of water-efficient irrigation techniques;
• U.S. EPA Certified WaterSense labeled or equivalent faucets, highefficiency toilets (HETs), and water-conserving shower heads; • Use of recycled water, when available.

In Construction Plans and
Specifications. Prior to
Building Permits
City of Redlands Building
and Safety Division
MM AQ-9: Localized Emissions. For implementing projects within the TVSP area, the applicant shall be responsible for submitting a focused project-level air quality assessment that includes the modeling of localized on-site emissions associated with daily grading activities anticipated for the proposed development. During the City’s review process of development applications in the TVSP area, the applicant shall conduct or shall have conducted modeling of the regional and the localized emissions (nitrogen oxides [NOX], carbon monoxide [CO], Particulate Matter 10 microns in diameter or less [PM10], and Particulate Matter 2.5 microns in diameter or less [PM2.5]) associated with the maximum daily grading activities estimated for the proposed individual developments. If the modeling shows that emissions would exceed the 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.

Prior to Discretionary
Project Approval
City of Redlands Planning
Division
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Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
MM AQ-10: Toxic Air Contaminants. Applicants for residential and other sensitive land use projects (e.g., hospitals, nursing homes, day care centers) in the TVSP area within 1,000 feet of a major sources of TACs (e.g., warehouses, industrial areas, freeways, roadways, and rail lines with traffic volumes over 10,000 vehicle per day), as measured from the property line of the project to the property line of the source/edge of the nearest travel lane, shall submit a health risk assessment (HRA) to the City of Redlands prior to future discretionary project approval. The HRA shall be prepared in accordance with policies and procedures of CEQA and the SCAQMD. If the HRA shows that the incremental cancer risk exceeds ten in one million (10E-06), PM10 concentrations exceed 2.5 microgram per cubic meter (µg/m3), PM2.5 concentrations exceed 2.5 µg/m3, or the appropriate noncancer hazard index exceeds 1.0, the applicant will be required to identify and demonstrate that mitigation measures are capable of reducing potential cancer and noncancer risks to an acceptable level (i.e., below ten in one million or a hazard index of 1.0), including appropriate enforcement mechanisms. Measures to reduce risk may include but are not limited to:
• Air intakes located away from high volume roadways and/or truck loading zones.
• Heating, ventilation, and air conditioning systems of the buildings provided with appropriately sized maximum efficiency rating value (MERV) filters (e.g., MERV 13 or better).

Prior to Discretionary
Project Approval
City of Redlands Planning
Division

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

Prior to Discretionary
Project Approval
City of Redlands Planning
Division
MM CUL-1: Historical Properties. Prior to issuance of a permit for a development project within the TVSP area that could directly or indirectly impact a building/structure in excess of 50 years of age, the City shall determine whether the affected building/structure is historically significant.

In Construction Plans and
Specifications. Prior to
Demolition Permits
City of Redlands Planning
Division
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Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
The evaluation of historic architectural resources shall be based on criteria such as age, location, context, association with an important person or event, uniqueness, or structural integrity. Preferred mitigation for historic buildings or structures shall be to avoid significant impacts to the resource through project redesign. If the resource cannot be entirely avoided, all prudent and feasible measures to minimize harm to the resource shall be taken. An historical resource assessment report shall be prepared by a qualified architectural historian meeting the U.S. Secretary of the Interior standards for each project to document the methods used to determine the presence or absence of historical resources, to identify potential impacts from a project, and to evaluate the significance of any historical resources identified. If potentially significant impacts to a historical resource are identified, the report will also recommend appropriate mitigation to reduce the impacts to below a significant degree, where possible. If mitigation is required, mitigation programs can also be included in the report. Depending upon project impacts, measures shall include, but are not limited to:
• Preparing a historic resource management plan;
• Adding new construction that is compatible in size, scale, materials, color, and workmanship to the historical resource (such additions, whether portions of existing buildings or additions to historic districts, shall be clearly distinguishable from historic fabric); • Repairing damage according to the Secretary of the Interior's Standards for Rehabilitation;
• Screening incompatible new construction from view through the use of berms, walls, and landscaping in keeping with the historic period and character of the resource; and
• Shielding historic properties from noise generators through the use of sound walls, double glazing, and air conditioning.

MM CUL-2: Desktop Review. During environmental review for future projects located within the TVSP area, a qualified archaeologist will prepare a brief letter report to determine the likelihood for the project site to contain archaeological resources. This letter report will contain the results of Prior to Discretionary
Project Approval
City of Redlands Planning
Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-9
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
background research and will tier off the research conducted in the Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments prepared by Material Culture Consulting, Inc. Additional reference material will be reviewed, including project area specific historic photographs, topographic maps and existing historic information. The background information provided in the Redlands Transit Villages Specific Plan Project Cultural and Paleontological Assessments will be valid for five (5) years, after which time an updated search of the CHRIS will be required and submitted as an addendum to the original document. If there is any evidence that the project site has an increased sensitivity for archaeological or tribal cultural resources, based on existing onsite historic-age buildings or structures, or if previously identified resources are present within the project area or vicinity, then Mitigation Measure CUL-4 through Mitigation Measure CUL-6 shall be implemented.

MM CUL-3: Native American Coordination. Where a recorded Native American archaeological site is identified, the City shall initiate coordination with identified California Indian tribes. It should be noted that during the coordination process, tribal representative(s) will be directly involved in making recommendations regarding the significance of a prehistoric archaeological site, which could be considered a historic tribal cultural resource listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k).

Prior to Discretionary
Project Approval
City of Redlands Planning
Division
MM CUL-4: Phase 2 Archaeological Site Testing. If previously identified archaeological resources are present within the project area, a Phase 2 Archaeological Site Testing program shall be recommended, which would include evaluating the horizontal and vertical dimensions of a site, the chronological placement, site function, artifact/ecofact density and variability, presence/absence of subsurface features, and research potential.

Results of the testing program, in tandem with the Native American coordination process required by Mitigation Measure CUL-3 will determine the historic significance of the resource.

When appropriate, the final testing report must be submitted to the City for eligibility determination and possible designation. An agreement on the In Construction Plans and
Specifications. Prior to
Demolition Permits
City of Redlands Planning
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appropriate form of mitigation is required prior to distribution of a draft environmental document, should one be required. If no significant resources are found, and site conditions are such that there is no potential for further discoveries, then no further action is required. Resources found to be nonsignificant as a result of a survey and/or assessment will require no further work beyond documentation of the resources on the appropriate Department of Parks and Recreation site forms and inclusion of results in the survey and/or assessment report. If no significant resources are found but results of the initial evaluation and testing phase indicate there is still a potential for resources to be present in portions of the property that could not be tested, then development of a mitigation and monitoring program is required.

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

In Construction Plans and
Specifications.

City of Redlands Planning
Division
MM CUL-6: Archaeological Resources Management Plan (ARMP). If resources are discovered within a given Project Area, or if there is a high potential for encountering resources, an Archaeological Resources Management Plan (ARMP) will be required. In this case, the ARMP should include the following, at a minimum:

At least 90 days prior to issuance of grading permits, the project permittee/owner shall retain a qualified archaeological monitor to prepare the ARMP and to monitor all ground-disturbing activities in an effort to identify any unknown archaeological resources. Qualified archaeological monitor(s) will have a minimum of a bachelor’s degree, verifiable training and one year of monitoring experience in Southern California on similar projects.

Prior to grading, the project permittee/owner shall provide to the City Development Services Department verification that a qualified monitor has In Construction Plans and
Specifications. Prior to
Grading Permit
City of Redlands Planning
Division
Redlands Regular Meeting of 10-18-22 1419 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-11
Final EIR
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been retained. Monitors will report to the Project Archaeologist for the Project and may work in collaboration with Native American monitors for tribal cultural resources that may be a historical resource as defined in Public Resources Code section 5020.1(k).
• The Project Archaeologist shall meet the U.S. Secretary of the Interior Standards.
• Any newly discovered archaeological resource deposits shall be subject to a formal significance evaluation.
• The Project Archaeologist will work in coordination with consulting tribes, the permittee/owner, and the City on the ARMP to address the details, timing, and responsibility of all archaeological activities that will occur on the project site. Details in the plan shall include, at a minimum:
a. Project grading and development scheduling;
b. The development of a schedule in coordination with the permittee/owner/consulting Native American tribes
and the Project Archaeologist during grading,
excavation and ground-disturbing activities on the site:
including the scheduling, safety requirements, duties,
scope of work, and Native American tribal monitors’
authority to stop and redirect grading activities in
coordination with all project archaeologists; and,
c. The protocols and stipulations that the
permittee/owner, City, tribes, and Project
Archaeologist will follow in the event of inadvertent
archaeological resource discoveries, including any
newly discovered archaeological resource deposits
that shall be subject to a archaeological resources
evaluation.
• A final report documenting the monitoring activity and disposition of any recovered archaeological resources shall be submitted to the City of Redlands, South Central Coast Information Center (SCCIC), and consulting tribes within 60 days of completion of monitoring.

A. Pregrading Conference
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The Project Archaeologist and/or designee shall participate in a pre-grading conference with development staff and construction operations, to ensure an understanding of the monitoring requirements and implementation procedures to be utilized during construction. This meeting shall take place before the initiation of major ground-disturbing activities. Training at this meeting shall inform all construction personnel of the procedures to be followed upon the discovery of archaeological resources, general archaeological items, including the archaeology and culture history of the area, as well as pictures of typical artifacts, sites, and resources that can be found during construction.

This training should stress applicable state, federal, and local laws, and include information on what to do in case an unanticipated discovery is made by a worker. All construction personnel should be instructed to stop work within a 50-foot radius of the find and immediately inform their field supervisor upon any discovery in the Project Area. The Project Archaeologist and Native American monitors shall be called to assess the find to determine if additional monitors should be mobilized to the Project Area to examine and evaluate the resources.

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

Archaeological monitoring will include inspection of exposed cut surfaces and spoils piles. Monitors maintain close communication with the on-site construction personnel to maintain a safe working environment and to be fully appraised of the upcoming Project activity areas and any schedule changes. All monitors shall complete daily documentation of all construction activities requiring monitoring, including the location of monitoring activities throughout the day, observations of sediment type and distribution, observations regarding resources, collection of resources and other information. This documentation will be prepared by each monitor on each shift, in a Daily Field Monitoring Redlands Regular Meeting of 10-18-22 1421 of 1815
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Summary and Daily Artifact Collection log, as relevant to the discoveries each day. The monitor shall photograph ground disturbing activities, sediment, and resources for documentation purposes and will fill out a Photograph Log each day. The Daily Field Monitoring Summary, Daily Artifact Collection Log and/or Photograph Log comprise the field notes. These notes shall be filed weekly with the Project Archaeologist and be made available to the Proponent and City upon request.

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

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

E. Data Recovery Plan for Archaeological Resources
The following plan identifies protocol for assessing newly discovered resources. This section follows state guidelines for management of archaeological resources, as well as current best practices and industry standards for cultural resource management professional. Please note that when inadvertent discoveries of Native American archaeological resources occur, coordination with consulting Native American tribes/affiliations should Redlands Regular Meeting of 10-18-22 1422 of 1815
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be completed prior to removal or treatment of these resources, to ensure proper treatment and disposition, as outlined in Mitigation Measures TCR-3.

The Project Archaeologist shall be contacted to flag the area in the field and determine if the archaeological deposits meet the CEQA definition of historical (State CEQA Guidelines 15064.5(a)) and/or unique archaeological resource (Public Resources Code 21083.2(g)). If the find is considered a “resource” the archaeologist shall pursue either protection in place or recovery, salvage and treatment of the deposits.

F. Isolates
Less than three artifacts in one location are defined as isolates. These may consist of, for example, a single projectile point, a culturally modified animal bone, or a glass bottle. When isolates are discovered, the monitor carefully examines the surrounding area to ensure that other artifacts are not present.

Subsequently, the monitor photographs the isolate with a scale bar, obtains GPS coordinates of the location and records the isolate using standard California Department of Parks and Recreation (DPR) series 523 forms.

I. Archaeological Sites
Archaeological sites consist of more than three artifacts in one location. In addition, sites may have features such as rock ovens, burials, and other humancreated alterations of the natural environment - with or without the presence of artifacts. Sites and features require evaluation to determine if they meet significance criteria as per CEQA. An archaeological site is considered significant if it is eligible or potentially eligible for listing in the CRHR. When an archaeological site is discovered during any Project activity, the archaeological monitor will divert construction away from the area at a minimum distance of 50 ft from the find and establish an exclusionary zone (flagging pins/tape) around the resource. The archaeological monitor(s) will then notify the Project Archaeologist for direction on how to proceed.

Regardless of the outcome of the significance and CRHR eligibility assessment, every feature and site require a standard set of data collection for analysis and recordation on standard DPR forms. Features or sites older than 50 years must be delineated and photographed, GPS coordinates must be taken, and features and site records are completed including production of field maps and sketch map drawings. Thorough mapping is required for all features or Redlands Regular Meeting of 10-18-22 1423 of 1815
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sites, and include an accurate elevation measurement, the depth the deposit extends below surface and true north reading.

Recovery, salvage and treatment protocols shall be developed in accordance with applicable provisions of Public Resource Code Section 21083.2 and State CEQA Guidelines 15064.5 and 15126.4. If unique archaeological resources cannot be preserved in place or left in an undisturbed state, recovery, salvage and treatment shall be required at the applicant’s expense.

All recovered and salvaged resources shall be prepared to the point of identification and permanent preservation by the archaeologist. Resources shall be identified and curated into an established accredited professional repository, at the Western Science Center in Hemet. Excavation as a treatment option will be restricted to those parts of the unique archaeological resource that would be damaged or destroyed by the project. All items found in association with Native American human remains shall be considered grave goods and sacred in origin and subject to special handling pursuant to Mitigation Measure TCR-4.

MM CUL-7: Human Remains. Procedures taken upon discovery of human remains will be consistent with State Law (California Health and Safety Code Section 7050.5; California PRC Section 5907.98) and CR-3. If human remains are encountered during project grading, no further disturbance shall occur until the San Bernardino County Coroner has made the necessary findings as to origin. Further, pursuant to California Public Resources Code Section 5097.98(b) remains shall be left in place and free from disturbance until a final decision as to the treatment and disposition has been made. The monitor(s) will immediately divert work a minimum of 100 feet and place an exclusion zone (flagging pins) around the burial. In-place preservation and protection from further disturbance shall always be the preferred approach.

If the San Bernardino County Coroner determines the remains to be Native American, the NAHC shall be contacted within a twenty-four (24) hour timeframe. Subsequently, the NAHC shall identify the “most likely descendant.” The most likely descendant (MLD) shall then make recommendations and engage in consultations concerning the treatment of the remains as provided in Public Resources Code 5097.98. According to the California Health and Safety Code, six or more human burials at one location In Construction Plans and
Specifications.

City of Redlands Planning
Division
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constitute a cemetery (Section 8100), and willful disturbance of human remains is a felony (Section 7052).

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

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

In Construction Plans and
Specifications.

City of Redlands Planning
Division
MM CUL-9: Curation of Archaeological Resources. All archaeological materials, including original maps, field notes, non-burial related artifacts, catalog information, and final reports recovered during public and/or private development projects must be permanently curated with an appropriate institution, one that has the proper facilities and staffing for ensuring research access to the collections consistent with state and federal standards. In the In Construction Plans and
Specifications.

City of Redlands Planning
Division
Redlands Regular Meeting of 10-18-22 1425 of 1815
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event that a prehistoric and/or historic deposit is encountered during construction monitoring, a collections management plan would be required in accordance with the project Mitigation and Monitoring Program.

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

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

GEOLOGY AND SOILS
MM GEO-1: Paleontological Resources Management Program (PRMP). If a project proposes subsurface disturbance within an area mapped as a high sensitivity geologic unit (i.e., older alluvial deposits), or subsurface disturbance greater than 5 feet deep within an area mapped at the surface as a low sensitivity geologic unit (i.e., younger alluvial deposits), a paleontological resource management program (PRMP) is required unless a qualified paleontologist retained by a Project Proponent provides a letter to the City In Construction Plans and
Specifications. Prior to
Grading Permits
City of Redlands Planning
Division
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verifying that a PRMP is not warranted based on the results of a projectspecific assessment. The PRMP will be reviewed and approved by the City prior to the issuance of a grading permit. The PRMP will be designed and implemented prior to any ground disturbance activities to monitor, salvage, and curate any recovered fossils associated with the project area, should these be unearthed. It is recommended that, if necessary, a project’s PRMP implement the following standard procedures:

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

2. The project paleontologist retained shall review the approved development plan and grading plan and conduct any preconstruction work necessary to render appropriate monitoring requirements as appropriate. These requirements shall be documented by the project paleontologist in a paleontological resource management program (PRMP). This PRMP shall be
submitted to the City for approval prior to issuance of a grading permit. Information to be contained in the PRMP, at a minimum and in addition to other industry standards and Society of Vertebrate Paleontology standards, are as follows:
a. The Project Paleontologist shall participate in a preconstruction project meeting with development staff Redlands Regular Meeting of 10-18-22 1427 of 1815
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and construction operations to ensure an understanding
of any monitoring measures required during
construction, as applicable.
b. Paleontological monitoring of earthmoving activities will be conducted on an as-needed basis by the project
paleontologist during all earthmoving activities that
may expose sensitive strata. Earthmoving activities in
areas of the project area where previously
undisturbed strata will be buried but not otherwise
disturbed will not be monitored. The project
paleontologist or his/her assign will have the authority to reduce monitoring once he/she determines the
probability of encountering fossils has dropped below
an acceptable level.
c. If the Project Paleontologist finds fossil remains,
earthmoving activities will be diverted temporarily
around the fossil site until the remains have been
evaluated, documented, and recovered. Earthmoving
will be allowed to proceed through the site when the
Project Paleontologist determines the fossils have been recovered and/or the site mitigated to the extent
necessary.
d. If fossil remains are encountered by earthmoving
activities when the Project Paleontologist is not onsite, these activities will be diverted around the fossil site and the Project Paleontologist called to the site
immediately to evaluate, document, and recover the
remains.
e. If fossil remains are encountered, fossiliferous rock and soil will be recovered from the fossil site and processed to allow for the recovery of smaller fossil remains. Test samples may be recovered from other sampling sites
in the geologic unit if appropriate.

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f. Any recovered fossil remains will be prepared to the point of identification and identified to the lowest
taxonomic level possible by knowledgeable
paleontologists. The remains then will be curated
(assigned and labeled with museum* repository fossil
specimen numbers and corresponding fossil site
numbers, as appropriate; placed in specimen trays
and, if necessary, vials with completed specimen data
cards) and catalogued, an associated specimen data
and corresponding geologic and geographic site data
will be archived (specimen and site numbers and
corresponding data entered into appropriate museum
repository catalogs and computerized data bases) at
the museum repository by a laboratory technician. The
remains will then be accessioned into the museum*
repository fossil collection, where they will be
permanently stored, maintained, and, along with
associated specimen and site data, made available
for future study by qualified scientific investigators. g. A qualified paleontologist shall prepare a report of findings made during all site grading activity with an
appended itemized list of fossil specimens recovered
during grading (if any). This report shall be submitted to the Development Services Department for review
and approval prior to building final inspection as
described elsewhere in these conditions.

A. Pregrading Conference
The Project Paleontologist and/or designee shall participate in a pre-grading conference with development staff and construction operations, to ensure an understanding of the monitoring requirements and implementation procedures to be utilized during construction. This meeting shall take place before the Redlands Regular Meeting of 10-18-22 1429 of 1815
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initiation of major ground-disturbing activities. Training at this meeting shall inform all construction personnel of the procedures to be followed upon the discovery of paleontological resources, general paleontological items, including the paleontology and geology of the area, as well as pictures of typical fossils that can be found during construction. This training should stress applicable state, federal, and local laws, and include information on what to do in case an unanticipated discovery is made by a worker. All construction personnel should be instructed to stop work within a 50-foot radius of the find and immediately inform their field supervisor upon any discovery in the project area. The Project Paleontologist shall be called to assess the find to determine if monitors should be mobilized to the project area to examine and evaluate the fossils.

B. Paleontological Monitoring
Paleontological monitoring of earthmoving activities within older Quaternary alluvial deposits will be initially conducted on a full-time basis, and earthmoving activities below five feet within younger Quaternary alluvial deposits will be conducted on a part-time (spot-checking) basis by the paleontological monitor. The Project Paleontologist may re-evaluate the necessity for paleontological monitoring after initial examination of the affected sediments during excavation, which may result in part-time or spotchecking the remainder of excavations, or cessation of monitoring.

Paleontological monitoring of construction excavations involves field inspection of trenches, spoils piles, scraped or graded surfaces. Monitors shall maintain close communication with the on-site construction personnel to maintain a safe working environment and to be fully appraised of the upcoming Project activity areas and any schedule changes. All monitors shall complete daily documentation of all construction activities requiring monitoring, including the location of monitoring activities throughout the day, observations of sediment type and distribution, observations regarding paleontological resources, collection of resources and other information. This documentation will be prepared by each monitor on each shift, in a Daily Redlands Regular Meeting of 10-18-22 1430 of 1815
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Field Monitoring Summary and Daily Paleontological Locality Collection log, as relevant to the discoveries each day. The monitor shall photograph ground disturbing activities, sediment, and resources for documentation purposes and will fill out a Photograph Log each day. The Daily Field Monitoring Summary, Daily Paleontological Locality Collection Log and/or Photograph Log shall comprise the field notes. These notes shall be filed weekly with the Project Paleontologist and be made available to the Proponent and City upon request.

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

D. Data Recovery Plan for Paleontological Resources
If fossils are discovered, the qualified paleontological monitor shall recover them. In the instance of an extended salvage period, the Project Paleontologist shall work with the construction manager to temporarily direct, divert, or halt earthwork to allow recovery of fossil remains in a timely manner. If the find is too large to be managed by one monitor, additional assistance will be called upon to expedite the process. Because of the potential for the recovery of small fossil remains, it may be necessary to collect bulk samples (up to 6,000 pounds) of sedimentary rock matrix. Screenwashing will only occur in the event of a significant discovery. The Project Redlands Regular Meeting of 10-18-22 1431 of 1815
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Paleontologist will consult with the Project Applicant/Proponent prior to collecting any bulk samples. Scientifically significant fossils of microscopic size consisting of vertebrates, invertebrates, plants, or trace fossils, may be in sediments that produce significant finds. The locations of any significant discoveries should be sampled and later screen-washed and picked in the paleontological laboratory to fully document the microfaunal or microfloral diversity of the locality.

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

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

G. Curation of Paleontological Resources
Fossil remains collected during monitoring and salvage shall be cleaned, repaired, sorted, and catalogued as part of the monitoring program. When potentially scientifically significant fossil discoveries are made by Redlands Regular Meeting of 10-18-22 1432 of 1815
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paleontological monitors, they should be quickly and professionally explored, assessed, and evaluated to minimize construction delays; the City Development Services Department and Project Paleontologist will be notified immediately. Additional paleontologists will be brought in to assist with the salvage as needed. Salvages may consist of the relatively rapid removal of small isolated fossils from an active cut, to hand-quarrying of larger fossils over several hours, to excavations of large fossils or large numbers of smaller fossils from a bone bed over several days or weeks.

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

HYDROLOGY AND WATER QUALITY
PPP HYD-1 National Pollutant Discharge Elimination System (NPDES).

Projects will be constructed in accordance with the NPDES General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities, NPDES No. CAS000002. Compliance requires a risk assessment, a SWPPP, and associated BMPs.

In Construction Plans and
Specifications. Prior to
Demolition and Grading
Permits
City of Redlands Building
and Safety Division
Redlands Regular Meeting of 10-18-22 1433 of 1815
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PPP HYD-2 Santa Ana RWQCB MS4 Permit. Projects will be constructed and operated in accordance with the Santa Ana RWQCB Municipal Stormwater (MS4) Permit for the part of the Santa Ana Basin in San Bernardino County in 2010 (Order No. R8-2010-0036). The MS4 Permit requires new development and redevelopment projects to adopt a WQMP to:
• Control contaminants into storm drain systems
• Educate the public about stormwater impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement BMPs and site-specific runoff controls and treatments In Construction Plans and
Specifications. Prior to
Grading Permits
City of Redlands Building
and Safety Division
NOISE
MM 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.

In Construction Plans and
Specifications. Prior to
Demolition, Grading
Permits
City of Redlands Building
and Safety Division
MM 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.

In Construction Plans and
Specifications. Prior to
Demolition, Grading, and
Building Permits
City of Redlands Building
and Safety Division
MM 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).

In Construction Plans and
Specifications. Prior to
Demolition, Grading, and
Building Permits
City of Redlands Building
and Safety Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-26
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
MM 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.

In Construction Plans and
Specifications. Prior to
Demolition, Grading, and
Building Permits
City of Redlands Building
and Safety Division
MM 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.

In Construction Plans and
Specifications. Prior to
Demolition, Grading, and
Building Permits
City of Redlands Building
and Safety Division
MM 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.

In Construction Plans and
Specifications. Prior to
Building Permits
City of Redlands Building
and Safety Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-27
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
MM 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).

In Construction Plans and
Specifications. Prior to
Building Permits.

City of Redlands Building
and Safety Division
MM 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 noisesensitive uses, 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.

In Construction Plans and
Specifications. Prior to
Demolition, Grading, and
Building Permits
City of Redlands Building
and Safety Division
MM 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.

In Construction Plans and
Specifications. Prior to
Demolition, Grading, and
Building Permits
City of Redlands Building
and Safety Division

PUBLIC SERVICES
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-28
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
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.

Prior to Building Permit. City of Redlands Planning
Division
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.

Prior to Building Permit. City of Redlands Planning
Division

TRANSPORTATION
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 the 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 Prior to Discretionary
Project Approval.

City of Redlands Planning
Division
Redlands Regular Meeting of 10-18-22 1437 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-29
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
• Implementing pedestrian and sidewalk improvements consistent with the TVSP (i.e., wider than typical 5-foot-wide sidewalks for highpedestrian traffic areas) • Constructing bicycle network improvements along the project’s frontage consistent with the TVSP
City of Redlands Planning
Division

TRIBAL CULTURAL RESOURCES
MM 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 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:

In Construction Plans and
Specifications. Prior to
Grading Permits
City of Redlands Planning
Division
Redlands Regular Meeting of 10-18-22 1438 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-30
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
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 grounddisturbing 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 In Construction Plans and
Specifications. Prior to
Grading Permits
City of Redlands Planning
Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-31
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
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 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 pregrading meeting; and, in a confidential appendix, include the daily/weekly monitoring notes from the archaeologist. All reports Redlands Regular Meeting of 10-18-22 1440 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-32
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
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, In Construction Plans and
Specifications. Prior to
Grading Permits
City of Redlands Planning
Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-33
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
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 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).

MM 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 immediate notify the San Bernardino County Coroner, the City of Redlands Police Department, and the City of Redlands Development Services In Construction Plans and
Specifications. Prior to
Grading Permits
City of Redlands Planning
Division
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Redlands General Plan Transit Villages District and Specific Plan Project 4. Mitigation Monitoring and Reporting Program City of Redlands 4-34
Final EIR
September 2022
Plans, Programs, and Policies /Project Design Feature/ Mitigation Measure Timing Responsible for
Ensuring Compliance /
Verification
Date Completed and
Initials
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)).

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Redlands General Plan Transit Villages District and Specific Plan Project CEQA Findings of Fact City of Redlands 1
September 2022

CEQA FINDINGS OF FACT

FOR THE

REDLANDS GENERAL PLAN TRANSIT VILLAGES DISTRICT AND SPECIFIC PLAN PROJECT

REDLANDS, CALIFORNIA
STATE CLEARINGHOUSE NO. 2021080622
Public Resources Code section 21002 states that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” Section 21002 further states that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which would avoid or substantially lessen such significant effects.”
Agencies demonstrate compliance with section 21002’s mandate by adopting findings before approving projects for which EIRs are required. (See Pub. Resources Code, § 21081, subd. (a); State CEQA Guidelines § 15091, subd. (a).) The approving agency must make written findings for each significant environmental effect identified in an EIR for a proposed project and must reach at least one of three permissible conclusions. • The first possible finding is that “[c]hanges or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the final EIR.” (State CEQA Guidelines § 15091, subd. (a)(1).) • The second permissible finding is that “[s]uch changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding” and that “[s]uch changes have been adopted by such other agency or can and should be adopted by such other agency.” (State CEQA Guidelines § 15091, subd. (a)(2).) • The third potential conclusion is that “[s]pecific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.” (State CEQA Guidelines § 15091, subd. (a)(3).)
Agencies must not approve a project with significant environmental impacts if feasible alternatives or mitigation measures would substantially lessen the significant impacts. Public Resources Code section 21061.1 defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social and technological factors.” State CEQA Guidelines section 15364 adds “legal” considerations as another indicium of feasibility (See also Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565). Project objectives also inform the determination of “feasibility.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417.) Further, “‘feasibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environ mental, social, and technological factors.” (Id.; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) An agency need not, however, adopt infeasible mitigation measures or alternatives (State CEQA Guidelines § 15091, subds. (a), (b)). Further, environmental impacts that are less than significant do not require the imposition of mitigation measures (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347).

Notably, section 21002 requires an agency to “substantially lessen or avoid” significant adverse environmental impacts. Thus, mitigation measures that “substantially lessen” significant environmental impacts, even if not completely avoid them, satisfy section 21002’s mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 (“CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level”); Las Virgenes Homeowners Federation, Inc. v. County of Los Angeles (1986) 177 Cal.App.3d 300, 309 (“[t]here is no Redlands Regular Meeting of 10-18-22 1444 of 1815
Redlands General Plan Transit Villages District and Specific Plan Project CEQA Findings of Fact City of Redlands 2
September 2022
requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance . . . if such would render the project unfeasible”).

CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to substantially lessen or avoid significant environmental impacts that would otherwise occur. Project modification or alternatives are not required, however, where such changes are infeasible or where the responsibility for modifying the project lies with some other agency. (State CEQA Guidelines § 15091, subds. (a), (b). The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced.” (Citizens of Goleta Valley v. Board of Supervisors, supra, 52 Cal.3d at p. 576).

The City of Redlands has determined that based on all the evidence presented, including, but not limited to, the Final EIR, written and oral testimony given at meetings and hearings on the Project, and submission of testimony from the public, organizations and regulatory agencies, the following environmental impacts associated with the Project are either:
(1) less than significant and do not require mitigation; (2) potentially significant and each of these impacts would be avoided or reduced to a level of insignificance through the identified mitigation measures; or (3) significant and cannot be fully mitigated to a level of less than significant but will be substantially lessened to the extent feasible by the identified mitigation measures.

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Redlands General Plan Transit Villages District and Specific Plan Project CEQA Findings of Fact City of Redlands 3
September 2022

SECTION I

ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION
The Final EIR includes the Draft Environmental Impact Report (EIR) dated July 2022, written comments on the Draft EIR that were received during the public review period, written responses to those comments and changes to the Draft EIR, and the Final EIR Errata making minor corrections and revisions to the Final EIR. In conformance with CEQA and the State CEQA Guidelines, the City of Redlands conducted an extensive environmental review of the Redlands General Plan Transit Villages District and Specific Plan Project that includes the following:
• Completion of an Initial Study (IS) by the City of Redlands, which concluded that an EIR should be prepared, and the Notice of Preparation (NOP), were released for a 30-day public review period from September 1, 2021, through September 30, 2021. The NOP was posted at the San Bernardino County Clerk of the Board’s office on September 1, 2021. The notice was published in the August 31, 2021 issue of the Redlands Daily Facts, a newspaper of general circulation. The NOP was posted to the State Clearinghouse’s ceqanet.opr.ca.gov for public review from September 1, 2021 to September 30, 2021. Copies of the IS were made available for public review at Redlands City Hall and the A.K. Smiley Public Library and it was available for download via the City’s website at:
https://www.cityofredlands.org/post/environmental-documents • Completion of a scoping process, in which agencies the public was invited by the City of Redlands to participate. The agency scoping meeting for the EIR was held on September 15, 2021 at 4:00 p.m. via Zoom. The notice of an agency scoping meeting was included in the NOP distributed on September 1, 2021. The public scoping meeting for the EIR was held on September 15, 2021 at 5:00 p.m. via Zoom. The notice of the public scoping meeting was included in the NOP distributed on September 1, 2021.
• Preparation of a Draft EIR by the City of Redlands, which was made available for a 47-day public review period (July 21, 2022 through September 6, 2022). The Notice of Availability (NOA) for the Draft EIR was sent to all persons, agencies and organizations on the interested persons list and published in the July 21, 2022 edition of the Redlands Daily Facts. The NOA of the Draft EIR was posted to the State Clearinghouse’s ceqanet.opr.ca.gov for public review from July 21, 2022 to September 6, 2022. The NOA was posted at the San Bernardino County Clerk of the Board’s office on July 21, 2022. Copies of the Draft EIR were made available for public review at the Redlands City Hall and the A.K. Smiley Public Library and it was available for download via the City’s website at: https://www.cityofredlands.org/post/environmental-documents • The Final EIR contains comments on the Draft EIR, responses to those comments, revisions to the Draft EIR, if any, and appended documents. The Final EIR was released for a 10-day agency review period prior to certification of the Final EIR.
• After considering the EIR and in conjunction with making these findings, the City of Redlands hereby finds that pursuant to Section 15092 of the CEQA Guidelines that approval of the Project will result in significant effects on the environment, however, the significant effects will be eliminated or substantially lessened where feasible and has determined that remaining significant effects are found to be acceptable under Section 15093.
• The Mitigation Monitoring and Reporting Program is hereby adopted to ensure implementation of feasible mitigation measures identified in the EIR. The City of Redlands finds that these mitigation measures are fully enforceable and shall be binding upon the City and affected parties. • The City of Redlands finds that the Project is in the public interest and is necessary for the public health, safety, and welfare.

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• The City of Redlands hereby certifies the Final EIR in accordance with the requirements of CEQA. • Pursuant to CEQA Guidelines Section 15095, staff is directed as follows: a) copy of the Final EIR and CEQA Findings of Fact shall be retained in the Project files; b) copy of the Final EIR and CEQA Findings of Fact shall be provided to all CEQA "responsible" agencies.

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Redlands General Plan Transit Villages District and Specific Plan Project CEQA Findings of Fact City of Redlands 5
September 2022

SECTION II

ENVIRONMENTAL IMPACTS NOT REQUIRING MITIGATION
The City prepared an Initial Study that determined that potentially significant environmental effects could occur and that an EIR should be prepared for the Project. The scope of the EIR was determined based upon the Initial Study which is included as Appendix A to the Draft EIR. Based upon the Initial Study, the City determined that the Project would have no impact or a less than significant impact on the following environmental topic areas and that no further analysis of these topics was required in the EIR:
• Agriculture & Forest Resources
• Biological Resources
• Mineral Resources
• Wildfire
Section 15091 of the State CEQA Guidelines does not require specific findings to address environmental effects that an EIR identifies as “less than significant” where no mitigation is required. These findings will nevertheless fully account for all such effects identified in the Initial Study and Draft EIR in this Section II. Thus, the City hereby finds that the following potential environmental impacts of the Project are less than significant and do not require the imposition of mitigation measures:

A. Aesthetics
Impact AE-1 Finding: The Project would not have a substantial adverse effect on a scenic vista (Initial Study at p. 45). Impacts would be less than significant.

Facts in Support of Findings: The terrain of the Project area slopes gently to the west at about two percent and does not include hilly topography. 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 developing in open space and agricultural areas, while filling visual gaps in existing neighborhoods.

Toward this end, the Project incorporates a TOD approach that is guided by 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. 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.

Thus, implementation of the Project would not directly diminish the scenic quality of an existing scenic vista, block a view corridor, or vista of a scenic resource and impacts would be less than significant.

Impact AE-3 Finding: The Project is located in an urban area and would not conflict with applicable zoning and other regulations governing scenic quality. (Draft EIR at p. 5.1-11). Impacts would be less than significant.

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

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

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

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

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

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

The Project would advance the Redlands General Plan’s present Transit Village Strategy and Concept by amending the Redlands General Plan to establish the new Transit Village (TV) land use designation to encourage development in the center of town by providing a plan for introducing new residential and commercial uses located within 0.5 mile of each of these three new train stations. The proposed adoption of the Transit Village (TV) district, along with the implementing TVSP, will set regulations for the community’s long-term vision for compact, efficient, responsible, and environmentally sustainable development. As a formbased code, the TVSP will emphasize building form, a mix and density of different uses, strong pedestrian orientation and transit-oriented development, and public realm improvements and amenities. Therefore, Redlands Regular Meeting of 10-18-22 1449 of 1815
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implementation of the Project would not result in conflict with the City’s General Plan, and impacts would not occur.

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

TVSP Chapter 4, Development Code, provides detailed regulations for development and new land uses within the TVSP area, and describes how these regulations would be used as part of the City’s development review process. These provisions supersede and replace regulations under the City of Redlands Zoning Code (Title 18 of the Municipal Code). Where specific provisions are not set forth for development standards within the TVSP, or where otherwise applicable requirements of the Zoning Code are not covered by the TVSP Development Code, implementing projects within the TVSP area would be subject to current or future Municipal Code regulations. However, while regulations within the TVSP supersede regulations set forth by the current Municipal Code, the majority of regulations align with the development standards set forth throughout the Municipal Code. Therefore, the new building standards, such as those for building height, provided for by the TVSP would largely remain consistent with existing Municipal Code development standards.

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

Overall, the TVSP area is located within an urbanized area and would not conflict with applicable zoning and other regulations governing scenic quality. Hence, the proposed Project would not degrade the visual character of the TVSP area and surrounding area; and impacts would be less than significant.

B. Agricultural & Forestry Resources
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Impact AG-1 Finding: The Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use (Initial Study at p. 49). No impacts would occur.

Facts in Support of Findings: 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. Therefore, implementation of the Project would not convert existing designated farmland and no related impact would occur.

Impact AG-2 Finding: The Project would not conflict with existing zoning for agricultural use, or a Williamson Act contract (Initial Study at p. 49). No impacts would occur.

Facts in Support of Findings: None of the parcels within the Project area are currently zoned for agricultural use, nor is there any land under a Williamson Act contract within the Project area. Therefore, no impact would occur.

Impact AG-3 Finding: The Project would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)) (Initial Study at p. 49). No impacts would occur.

Facts in Support of Findings: The Project area is an urbanized environment. None of the parcels within the Project are currently zoned as forest land, timberland, or Timberland Production. Therefore, no impact would occur.

Impact AG-4 Finding: The Project would not result in the loss of forest land or conversion of forest land to non-forest use (Initial Study at p. 49). No impacts would occur.

Facts in Support of Findings: The Project area is an urbanized environment. No forest land exists in the Project area, and implementation will not result in the loss of forest land or the conversion of forest land to non-forest use. Therefore, no impact would occur.

Impact AG-5 Finding: The Project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use (Initial Study at p. 49). No impacts would occur.

Facts in Support of Findings: The Project area is an urbanized environment. Implementation of the Project focuses on infill redevelopment pursuant to TOD planning principles, within an area where no farmland, agricultural land, or forest land exists. The Project would not result in the conversion of farmland to nonagricultural or forest land to non-forest land, either directly or indirectly. Therefore, no impact would occur.

Agricultural and Forestry Resources Cumulative Findings: The Project would not result in cumulatively considerable impacts to agricultural or forestry resources.

Facts in Support of Findings: The Project area is an urbanized environment. Implementation of the Project focuses on infill redevelopment within an area where no farmland, agricultural land, or forest land exists.

Therefore, the Project would not result in any cumulative impacts to agricultural or forestry resources.

C. Air Quality
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Impact AQ-4 Finding: The Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people (Initial Study at pp. 51-52). Impacts would be less than significant.

Facts in Support of Findings: The Project would implement residential, commercial, retail, civic, and institutional development within the Project area. These types of land uses do not include activities that would emit objectionable odors affecting a substantial number of people. In addition, odors generated by new and existing non-residential land uses are required to follow SCAQMD Rule 402 to prevent odor nuisances on sensitive land uses. During construction, emissions from diesel equipment, use of VOCs from architectural coatings, and paving activities may generate some nuisance odors. However, these odors would be temporary and are not expected to affect a substantial number of people. Therefore, impacts relating to both operational and construction activity odors would be less than significant.

D. Biological Resources
Impact BIO-1 Finding: The Project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service (Initial Study at pp. 53-54). No impacts would occur.

Facts in Support of Findings: As described by the City’s GP2035 EIR, there are 19 species that are state or federally listed as rare, threatened, or endangered species that have been or were identified as potentially present within the City and its Sphere of Influence. Only eight species are known to either be present or have a moderate to high probability of occurring due to the presence of suitable habitat, mainly along the Santa Ana River, Mill Creek, or San Timoteo Creek. These areas are not within the Project (GP2035 EIR, Figure 3.4-12). 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. By focusing more future development in the future transit villages in the core area of the city (a primary strategy of the GP2035), it will result in preserving and protecting the open space and any potentially sensitive habitat areas around the periphery of the city.

Impact BIO-2 Finding: The Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or US Fish and Wildlife Service (Initial Study at p. 54). No impacts would occur.

Facts in Support of Findings: Riparian habitats are those occurring along the banks of rivers and streams.

Sensitive natural communities are natural communities that are considered rare in the region by regulatory agencies, known to provide habitat for sensitive animal or plant species, or known to be important wildlife corridors. Such areas, especially those with native vegetation adjacent to or immediately upstream of the Santa Ana River, Mill Creek, and San Timoteo Creek, are not within the Project area (GP2035 EIR, Figure

3.4-1).

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. Therefore, the Project would not result in impacts on riparian habitats.

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Impact BIO-3 Finding: The Project would not have a substantial adverse effect on state or federally protected wetlands (including but not limited to, marsh, vernal, pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means (Initial Study at p. 54). No impacts would occur.

Facts in Support of Findings: 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. Therefore, no impact would occur.

Impact BIO-4 Finding: The Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites (Initial Study at pp. 54-55). Impacts are less than significant.

Facts in Support of Findings: The GP2035 identifies potential wildlife corridors through the Live Oak Canyon and San Timoteo Canyon areas, and for the City to protect wildlife corridors connecting the San Bernardino National Forest, Santa Ana River Wash, Crafton Hills, San Timoteo and Live Oak canyons, the Badlands, and other open space areas (GP2035 EIR, p. 3.4-29). These areas are not located within or adjacent to the Project area.

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) 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 to any nesting birds if found. With adherence to the MBTA requirements, less than significant impacts would occur.

Impact BIO-5 Finding: The Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance (Initial Study at p. 55). Impacts are less than significant.

Facts in Support of Findings: The City has a Street Tree Policy and Protection Guidelines Manual (adopted January 2013) and a tree protection ordinance codified as RMC Chapter 12.52 for street trees and trees in public places. The GP2035 also includes tree protection policies consistent with said guidelines manual.

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 and impacts would be less than significant.

Impact BIO-6 Finding: The Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan (Initial Study at pp. 55-56). No impacts would occur.

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Facts in Support of Findings: The Project is within an urbanized area, and there are no adopted regional conservation plans in the City (CDFW 2019). There is, however, the Upper Santa Ana Wash Land Management and Habitat Conservation Plan, known also as the Wash Plan. The City, among other agencies, is a signatory to the Wash Plan and would participate in the implementation of the plan through a Certificate of Inclusion to receive coverage for planned projects. Implementation of the Wash Plan would result in permanent conservation and management of approximately 1,659.9 acres of native habitats that support slender-horned spine-flower, Santa Ana River woolly-star, cactus wren, California gnatcatcher, and San Bernardino kangaroo rat. The Wash Plan was adopted in 2020. The Project area is not within 6,000 feet (i.e., more than one mile) of the nearest Wash Plan boundaries, and implementation of the Project would not conflict or otherwise impact the Wash Plan policies or objectives. Therefore, the Project would not conflict with the provisions of an adopted habitat conservation plan or natural community conservation plan and no impacts would occur.

Biological Resources Cumulative Findings: The Project would not result in cumulatively considerable impacts to biological resources.

Facts in Support of Findings: The Project area is an urbanized environment. The proposed Project would not have potentially significant impacts related to special-status species, jurisdictional waters, wildlife movement, local ordinances or regulations protecting biological resources, habitat conservation plans, plant communities, and habitat fragmentation. Since the Project would result in no impacts or less than significant impacts to biological resources, the Project could not combine with other projects within the City in a manner that would result in cumulative impacts. Cumulative projects would be required to comply with applicable survey requirements and mitigation for biological resources. Since all projects would be required to implement their respective mitigation measures, their contribution would not be cumulatively considerable.

There are no projects that would, in combination with the Project, produce a significant impact to biological resources.

E. Cultural Resources
Impact CUL-3 Finding: The Project would not disturb any human remains, including those interred outside of formal cemeteries (Initial Study at p. 58). Impacts are less than significant.

Facts in Support of Findings: There are no known human remains on or near the Project area, including formal cemeteries. Additionally, the Project area is within an urbanized environment. Because the area has already been previously disturbed and developed, it has been subject to construction and ground-disturbing activities. The likelihood that human remains may be discovered during further site clearing and grading activities is considered extremely low. However, ground-disturbing activities have the potential to disturb previously undiscovered subsurface human remains.

In the unlikely event that human remains are uncovered during ground-disturbing activities, California Health and Safety Code Section 7050.5 states that if human remains are discovered, no further disturbance shall occur until the County Coroner has made a determination of origin and disposition. If the Coroner determines that the remains are not subject to his or her authority and if the Coroner recognizes the human remains to be those of a Native American, or has reason to believe that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission (NAHC). This regulation is applicable to any project where ground disturbance would occur. Section 7052 of the California Health and Safety Code makes the willful mutilation, disinterment, or removal of human remains a felony. Therefore, compliance with existing law regarding the discovery of human remains would reduce potential impacts to human remains to less than significant levels.

F. Energy
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Impact E-1 Finding: The Project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation (Draft EIR at p. 5.4-4). Impacts are less than significant.

Facts in Support of Findings:

Construction
During construction of the proposed Project, energy would be consumed in three general forms, petroleumbased fuels, electricity, and energy used in the production of construction materials. Construction activities related to the proposed mixed-use Project would not be expected to result in demand for fuel greater on a per-unit-of-development basis than other development projects in Southern California. Construction would occur over the 18 year buildout period and the demand for construction-related electricity and fuels would be limited to those time frames.

Also, CCR Title 13, Motor Vehicles, section 2449(d)(3) Idling, limits idling times of construction vehicles to no more than 5 minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. Additionally, construction contractors are required to demonstrate compliance with applicable California Air Resources Board (CARB) regulations governing the accelerated retrofitting, repowering, or replacement of heavy duty diesel on- and off-road equipment during the City’s construction permitting process. Compliance with existing CARB idling restrictions and the use of newer engines and equipment would reduce fuel combustion and energy consumption. Draft EIR pages 5.4-4 through 5.4-10 detail that construction of the proposed Project is estimated to result in the need for 2,282,064 kWh of electricity and approximately 661,217gallons of diesel fuel. Construction workers would use approximately 864,212 gallons of fuel to travel to and from the Project area. Approximately 291,668gallons of fuel would be used by vendor trucks during construction of the proposed Project.

Construction contractors are required to demonstrate compliance with applicable CARB regulations and compliance with existing CARB idling restrictions and the use of newer engines and equipment would reduce fuel combustion and energy consumption on the Project site. Overall, construction activities would require limited energy consumption and would comply with all existing regulations. Thus, impacts related to construction energy usage would be less than significant.

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

Draft EIR pages 5.4-10 and 5.4-11 detail that the TVSP at full buildout is estimated to result in the annual use of 1,535,977 gallons of fuel. In addition, the proposed Project would use approximately 47,182,575 thousand British thermal units (kBTU) per year of natural gas, and approximately 20,065,361 kilowatt-hour (kWh) per year of electricity.

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

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

Impact E-2 Finding: The Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency (Draft EIR at p. 5.4-11) Impacts are less than significant.

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Facts in Support of Findings: The development that would occur pursuant to the proposed TVSP would be required to meet the CCR Title 24 energy efficiency standards in effect during permitting of future development projects. The City’s administration of the CCR Title 24 requirements includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. In addition, as described in Draft EIR Section 5.2 Air Quality, the TVSP would be implemented to require development projects in the TVSP area to surpass state and local plans for energy efficiency and achieve 5 percent efficiency beyond the incumbent California Building Code Title 24 requirements, and enhanced water conservation (per Mitigation Measures AQ-7 and AQ-8). These mitigation measures would further ensure adherence to energy efficiency and renewable energy regulations.

Furthermore, the TVSP would not conflict with or obstruct opportunities to use renewable energy, such as solar energy. The non-residential buildings would be solar ready and residences would have solar infrastructure as required by CCR Title 24 requirements. Thus, the TVSP would not obstruct use of renewable energy or energy efficiency. Overall, the TVSP would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Energy Cumulative Findings: The Project would not result in cumulative energy consumption which would occur in a cumulatively wasteful, inefficient, or unnecessary (Draft EIR at pp. 5.4-11 through 5.4-11).

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

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

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

G. Geology and Soils
Impact GEO-1i Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault (Initial Study at p. 61). No impacts would occur.

Facts in Support of Findings: No known fault lines or Alquist-Priolo Fault Zones traverse the Project area or are within 50 feet of the Project area (GP2035 EIR, Figure 3.6-2). The nearest fault line to the Project area is the Redlands Fault of the Crafton Hills Fault Zone, located south of Highland Avenue/Fifth Avenue (i.e., approximately 3,300 feet to the south of the nearest boundary of the Project along East Citrus Ave.).

Therefore, individual projects constructed within the Project area would not expose people or structures to potential substantial adverse effects from rupture of a known earthquake fault that is delineated on an Alquist-Priolo Earthquake Fault Zoning Map. No impact would occur.

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Impact GEO-1ii Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking (Initial Study at p. 61). Impacts are less than significant.

Facts in Support of Findings: The Project is located within a seismically active region of Southern California.

The nearest fault line to the Project area is the Redlands Fault of the Crafton Hills Fault Zone, located south of Highland Avenue and Fifth Avenue (GP2035 EIR, Figure 3.6-2). New structures built in the City are required to be built in compliance with the California Building Code (CBC), as codified in RMC Chapter

15.04. CBC Section 1613 requires all structures be designed and constructed to resist the effects of earthquake motions in accordance with the Minimum Design Loads for Buildings and Other Structures established by the American Society of Civil Engineers. Compliance with the CBC would include the incorporation of: 1) seismic safety features to minimize the potential for significant effects as a result of earthquakes; 2) proper building footings and foundations; and 3) construction of the building structures so that it would withstand the effects of strong ground shaking. Regulatory compliance with the CBC would minimize the potential for structures, including individual development projects under the TVSP, to sustain substantial damage during an earthquake as modern buildings are designed to resist ground shaking through the use of shear panels, moment frames, and reinforcement. Development within the Project area would not directly or indirectly exacerbate seismic conditions in the Project area or elsewhere in the region. Therefore, impacts would be less than significant with respect to risk of loss, injury, or death involving strong seismic ground shaking.

Impact GEO-1iii Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction (Initial Study at p. 62). Impacts are less than significant.

Facts in Support of Findings: The Project area and immediate surroundings are in an area that is susceptible to liquefaction (GP2035 EIR, Figure 3.6-4). However, as described previously, the impacts from seismic ground failure, including liquefaction, from development under the Project would be addressed through sitespecific geotechnical studies prepared in accordance with CBC requirements. Individual development projects within the Project area would also be required to adhere to local policies in the RMC that contain seismic safety requirements and help strengthen existing code requirements such as limiting the disturbance of natural terrain and vegetation to the minimum necessary to accommodate reasonable use of property.

Therefore, the potential impact related to seismically related ground failure including liquefaction is less than significant.

Impact GEO-1iv Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides (Initial Study at p. 62). No impacts would occur.

Facts in Support of Findings: The Project area and surrounding area consists of relatively flat terrain that gently slopes to the west at about two percent. There are no existing hillsides within or adjacent to the Project area. Also, the Project area is not located in an area known to be susceptible to landslides (GP2035 EIR, Figure 3.6-3) and not in the path of any known or potential landslides. Thus, as the Project does not propose substantial alteration to the existing topography and would not directly or indirectly exacerbate existing environmental conditions related to landslides, no impacts would occur.

Impact GEO-2 Finding: The Project would not result in soil erosion or the loss of topsoil (Initial Study at pp. 62-63). Impacts are less than significant.

Facts in Support of Findings: The Project area is in an urbanized environment and in an area that is relatively level, with minimal rises or changes in elevation. No major slopes or bluffs are on or adjacent to the Project area. Generally, earthwork and ground-disturbing activities, unless below minimum requirements, require a grading permit, compliance with which minimizes erosion, and the City’s grading permit Redlands Regular Meeting of 10-18-22 1457 of 1815
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requirements ensure that construction practices include measures to protect exposed soils such as limiting work to dry seasons, covering stockpiled soils and use of straw bales and silt fences to minimize offsite sedimentation.

In addition, individual development projects that disturb more than one acre would be subject to compliance with a National Pollutant Discharge Elimination System (NPDES) permit, including the implementation of best management practices (BMPs), some of which are specifically implemented to reduce soil erosion or loss of topsoil, and the implementation of a stormwater pollution prevention plan (SWPPP). BMPs that are required under a SWPPP include erosion prevention measures that have proven effective in limiting soil erosion and loss of topsoil. Generally, once construction is complete and exposed areas are revegetated or covered by buildings, asphalt, or concrete, the erosion hazard is substantially eliminated or reduced. Therefore, the potential for adverse soil erosion and topsoil loss would be less than significant.

Impact GEO-3 Finding: The Project would not c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or offsite landslide, lateral spreading, subsidence, liquefaction or collapse (Initial Study at p. 63). Impacts are less than significant.

Facts in Support of Findings: The Project area is within a generally flat area that is not subject to landslides, and due to the flat topography, the potential for lateral spreading is also considered very low. The Project area is not identified as being located on a geologic unit or soil that is unstable, or that would become unstable because of development activities.

As described previously, future individual development projects proposed within the Project area would be required to implement CBC requirements and site-specific geotechnical investigations that are typically required for all new development. Therefore, compliance with the requirements of the California Building Code requires adherence to any and all geotechnical design recommendations that may be applicable to a particular project, which would be reviewed by the City for appropriate inclusion as part of the development review process and subsequent building plan check process, and would reduce potential impacts related to any unstable geologic unit or soil to a less than significant level.

Impact GEO-4 Finding: The Project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property (Initial Study at pp. 63-64). Impacts are less than significant.

Facts in Support of Findings: Various soil types within the TVSP area include Ramona Sandy Loam (RmC), Hanford Sandy Loam (HaC), Tujunga Loamy Sand (TuB), and Greenfield Sandy Loam (GtC) (GP2035 EIR, Figure 3.6-1), which are not clay based soils, and not prone to expansion. Also, any potential hazards related to unstable soils would be addressed through the integration of geotechnical information and design recommendations in the design and construction process for future individual development projects in accordance with the CBC requirements which minimize the risk associated with soils hazards. Therefore, compliance with the requirements of the CBC, which would be verified as part of the development review process as well as the subsequent building plan check and permitting process, would reduce potential impacts related to expansive soil to a less than significant level.

Impact GEO-5 Finding: The Project would not e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater (Initial Study at p. 64). No impacts would occur.

Facts in Support of Findings: The Project area is currently served by a sewer and wastewater treatment system. Future development projects would include connection to existing sewers mainlines and service lines.

Future development under the Project would not include the use of septic systems. Therefore, no impact would occur.

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Geology and Soils Cumulative Finding: The Project would not result in cumulatively considerable impacts to geology and soils.

Facts in Support of Findings: Geotechnical impacts are site-specific rather than cumulative in nature. Direct and indirect impacts related to geology and soils would be mitigated through mandatory conformance with the California Building Code, Redlands Municipal Code, and site-specific geotechnical recommendations, which will be incorporated as part of future projects’ design and construction efforts. With the exception of erosion hazards, potential hazardous effects related to geologic and soil conditions are unique to each project site, and inherently restricted to the developments proposed. That is, issues including fault rupture, seismic ground shaking, liquefaction, landslides, and expansive soils would involve effects to (and not from) the development, are specific to conditions on the property, and are not influenced by or additive with the geologic and/or soils hazards that may occur on other, off-site properties. Because of the site-specific nature of these potential hazards and the measures to address them, there would be no direct or indirect connection to similar potential issues or cumulative effects from the TVSP.

Impacts related to erosion and loss of topsoil could be cumulatively considerable. However, as discussed in Impact GEO-2, mandates related to the NPDES permit, preparation of a WQMP, Erosion Control Plan, and SWPPP, as well as compliance with SCAQMD Rule 403 (Fugitive Dust) incorporate measures during construction activities to ensure that significant erosion impacts do not occur. Other development projects in the vicinity of the TVSP would be required to comply with the same regulatory requirements as the Project to preclude substantial adverse water and wind erosion impacts. Because the Project and related projects within the cumulative study area would be subject to similar mandatory regulatory requirements to control erosion hazards during construction and long-term operation, cumulative impacts associated with wind and water erosion hazards would be less than significant.

H. Greenhouse Gas Emissions
Impact GHG-2 Finding: The Project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs (Draft EIR at p. 5.6-12) Impacts are less than significant.

Facts in Support of Findings: The City of Redlands CAP was designed to reinforce the City’s commitment to reducing GHG emissions and demonstrate compliance with the State’s GHG emissions reduction standards.

The CAP used the 2017 Scoping Plan recommended Plan Level emissions target of 6.0 MTCO2e per capita per year for 2030. The TVSP would result in GHG emissions per service population that would be less than

4.0 MTCO2e, and therefore would be consistent with the CAP emission goals. Also, the Project would implement CalGreen building standards, as verified through the City’s permitting process, that include requirements such as solar photovoltaic systems, increased energy and water efficiency.

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

The development resulting from the TVSP would include sustainable design features related to reduction of GHG emissions that would be consistent with CARB’s Scoping Plans (the 2007 and 2017) that provide measures to reduce GHG emissions, which the Project is consistent with as discussed below and detailed in Redlands Regular Meeting of 10-18-22 1459 of 1815
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Draft EIR Tables 5.6-4 and 5.6-5 and the requirements listed and described below. Thus, the TVSP would not conflict with the CARB Scoping Plans and related regulations.

Overall, implementation of the proposed Project would not result in conflict with any applicable plan, policy, or regulation that was adopted for the purpose of reducing GHGs. Thus, impacts would be less than significant.

I. Hazards and Hazardous Materials
Impact HAZ-1 Finding: The Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials (Initial Study at pp. 66-67). Impacts are less than significant.

Facts in Support of Findings: Implementation of the Project would provide for the development of land uses, including residential, mixed-use, recreational, commercial retail, office, institutional, and hotel uses that may require the routine use, transport, and disposal of hazardous material and waste. Additionally, construction activities associated with individual development projects under the Project may generate hazardous materials and waste, such as fuels and oils from construction equipment and vehicles.

Federal and state regulations require adherence to specific guidelines regarding the use, transportation, disposal, and accidental release of hazardous materials. Regulations associated with using, transporting, or disposing of hazardous materials include Resource Conservation and Recovery Act (RCRA), Emergency Planning and Community Right-to-Know Act (EPCRA), Hazardous Materials Transportation Act (HMTA), California Health and Safety Code, CCR Title 22, CCR Title 27, Senate Bill 1889, and the Consolidated Fire Code. Locally, facilities requiring a hazardous materials permit would be subject to routing inspection by the San Bernardino County Fire Department (SBFD), acting as the state-designated Certified Unified Program Agency (CUPA) for the City of Redlands, which would also minimize foreseeable risks of an accident that could create a hazard to the public or environment.

Transportation of hazardous waste from construction and operations of development projects under the Project would be subject to U.S. Department of Transportation’s (USDOT) requirements for hazardous materials transport and would require carriers to register with the California Department of Toxic Substances Control (DTSC). In addition, compliance with existing regulations require businesses handling or storing certain amounts of hazardous materials to prepare a hazardous materials business plan to inventory hazardous materials onsite and emergency response regarding potential release of materials. Additionally, existing regulations specify storage areas for hazardous materials to be designed to prevent accidental release and to protect against explosion hazard, high fire or physical hazard, or health hazards.

Implementation of the applicable federal, state, and local regulations would lessen the risk of death, injury, and/or property loss associated with the transport, use, or disposal of hazardous materials by promoting safe handling and storage, documentation and information sharing, and appropriate emergency planning and response. Therefore, compliance with the existing federal and state regulations would ensure the impact of routine use, transport, and disposal of hazardous materials associated with implementation of the Project would be less than significant.

Impact HAZ-2 Finding: The Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment (Initial Study at p. 68). Impacts are less than significant.

Facts in Support of Findings: Implementation of the Project would result in development of land uses that would involve the use, transportation, disposal, and storage of hazardous materials in the City. The Project does not propose industrial land uses. Depending on the age of the structure that would be demolished, asbestos-containing materials (ACMs) and lead-based paints (LBPs) may be present in the existing buildings.

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Although the risk of upset and accident conditions involving the release of hazardous materials into the environment cannot be completely eliminated, it can be reduced to a manageable level. Existing regulations at the federal, state, and local levels serve to minimize the potential for upset during routine transportation, use, and disposal as discussed in the response above. Given existing regulations and programs that reduce the potential for hazardous materials upsets and promote the ability of emergency services to respond to incidents, impacts from Project implementation associated with the release of hazardous materials into the environment would be less than significant.

Impact HAZ-3 Finding: The Project would not emit hazardous emissions or handle hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school (Impact at pp. 68-69). Impacts are less than significant.

Facts in Support of Findings: The following schools are located within the TVSP area boundaries:
• University of Redlands (southern portion of the campus) • Redlands Adventist Academy (private school)
• Orangewood High School (public continuation school)
The following schools are not within the Project area, but are located within a quarter mile:
• Arrowhead Christian Academy Upper School (private school) • Crafton Elementary
• Franklin Elementary
• Grove School (private school)
• Lugonia Elementary
• McKinley Elementary School
• Moore Middle School
• Redlands Christian Lower School and Preschool (private school) • Redlands Christian Middle (private school)
• Redlands High School
• Sacred Heart Academy (private school)
Implementation of the Project would allow land uses that would be reasonably expected to handle hazardous materials or generate hazardous emissions commensurate to residential, mixed-use, recreational, commercial retail and office, institutional, and hotel uses that are proposed. The Project does not propose industrial land uses. Operation of individual development projects under the Project would not produce hazardous emissions or handle acutely hazardous materials, substances, or wastes. However, construction phase for individual development projects would involve the temporary use of potentially hazardous materials, including vehicle fuels, paints, oils, and transmission fluids. All potentially hazardous materials would be used, stored, and disposed of in accordance with manufacturers’ specifications and in compliance for applicable federal, state, and local regulations. As such, given that the use of such materials would not create a significant hazard to any nearby schools and the land uses proposed by the Project would not create a hazardous incompatibility with existing school sites. Therefore, impacts from Project implementation would be less than significant.

Impact HAZ-4 Finding: The Project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment. (Draft EIR at p. 5.7-11). Impacts are less than significant.

Facts in Support of Findings: There are numerous sites in the TVSP area that are included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 or that need further Redlands Regular Meeting of 10-18-22 1461 of 1815
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investigation (See Table 5.7-1). Several of the sites have reported releases to the ground resulting in soil and groundwater contamination and which are subject to various State and federal laws and regulators, including the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Environmental Protection Agency (EPA), DTSC, and the Regional Water Quality Control Board (RWQCB), and are in various stages of the cleanup process as stipulated by the relevant agencies. Redevelopment of sites with existing soil or groundwater contamination in accordance with the TVSP could potentially pose a significant hazard to the public or the environment through releases of hazardous materials into the environment. However, these sites are being regulated by existing federal and state policies and have been or in the process of being investigated and remediated pursuant to existing regulation. Existing regulations (such as CFR, Title 49, Chapter I; CCR, Title 8; CCR, Title 22; CFR, Title 40, Part 263 that are enforced by the USEPA, USDOT, CalEPA, CalOSHA, DTSC, and the City of Redlands) and CUPA programs would also help by ensuring the reporting and documentation of any hazardous materials incidents in the TVSP area such that property owners could be aware of potential hazards. For future projects, CEQA requires developers to reference the Cortese List and discuss if the project would be located on a listed site.

Additionally, the City’s development review process would require preparation of Phase I Environmental Site Assessments (ESAs) for future projects that would identify potential hazardous materials onsite. If future redevelopment is proposed on listed sites, potential contamination at these sites, if not already remediated, would be addressed through the City’s development review requirements and in compliance with applicable state and federal regulations. Compliance with these policies, regulations, and programs would reduce the impact to less than significant.

Impact HAZ-5 Finding: The Project would not result in a safety hazard or excessive noise for people residing or working in the project area (Initial Study at p. 69). Impacts are less than significant.

Facts in Support of Findings: The nearest airports to the Project area are Redlands Municipal Airport (approximately 1.5 miles to the northeast of the University Transit Village) and San Bernardino International Airport (approximately three miles northwest of the New York Street/Esri Transit Village). The Project area is not within the airport compatibility zones or airport influence areas for either the Redlands Municipal Airport or San Bernardino International Airport (GP2035 EIR, p. 3.7-2), nor is the TVSP area within the modeled noise contours for the Redlands Municipal Airport (GP2035 EIR, Figure 3.12-3) or San Bernardino International Airport (GP2035 EIR, Figure 3.12-4). Additionally, implementation of the Project would not result in structures that would pose a hazard to airport operations, flight patterns, or otherwise result in substantial aviation-related safety risks. Therefore, impacts would be less than significant.

Impact HAZ-6 Finding: The Project would not impair implementation of an adopted emergency response plan or emergency evacuation plan (Initial Study at pp. 69-70). Impacts are less than significant.

Facts in Support of Findings: Relevant emergency response or emergency evacuation plans include the San Bernardino County Emergency Operations Plan and, to the extent that they mitigate potential disasters in the City and TVSP area, the City’s Hazard Mitigation Plan (HMP), and the San Bernardino County MultiJurisdictional Hazard Mitigation Plan (MJHMP). Physical development under the Project, including new roadways and new intersections to break up superblocks and increased densities (e.g., to multi-story mixeduse buildings such as near the future train stations), is not expected to create obstacles to the implementation of emergency response or evacuation plans adopted for the City. Emergency access and circulation during construction and operation of individual development projects under the Project would be part of each project’s review and approval by the City. Therefore, as existing City development standards would require new development within the TVSP to be designed so as to not interfere with an adopted emergency response plan or emergency evacuation plan, impacts from Project implementation would be less than significant.

Impact HAZ-7 Finding: The Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires (Initial Study at p. 70). Impacts are less than significant.

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Facts in Support of Findings: The Project area, as with most of the City, is characterized as having a moderate fire threat level (GP2035 EIR, Figure 3.7-3). Areas with high, very high, and extreme fire threat levels are located on the periphery of the City. Areas of high to extreme fire threat levels are characterized by natural vegetation that can serve as fuel for wildland fires, and steeper topographies that can impede emergency access and facilitate the rapid spread of potential fire.

The Project area is an urbanized environment that does not contain wildlands. City policies require all development to adhere to safety standards provided in the CBC and California Fire Code, including construction and design methods that effectively reduce the risk of structure fires. The City’s close coordination of the Redlands Fire Department with the fire services of neighboring jurisdictions ensures the safety of new development. Therefore, impacts would be less than significant.

Hazards and Hazardous Materials Cumulative Findings: The Project would not result in cumulative impacts related to hazards or hazardous materials (Draft EIR at p. 5.7-12).

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

J. Hydrology and Water Quality
Impact WQ-1 Finding: The Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality (Initial Study at pp 71- 72). Impacts are less than significant.

Facts in Support of Findings: Project implementation would have a significant environmental impact if it would violate water quality standards and waste discharge requirements set out in current NPDES and municipal permits issued by the Santa Ana RWQCB. Violation of these permits could occur if the individual development projects under the Project would substantially increase pollutant loading levels in the sanitary sewer system or in groundwater underlying the City, either directly through the introduction of pollutants, or indirectly through stormwater pollution. The NPDES permit is based on the federal Clean Water Act, compliance with the Porter-Cologne Water Quality Control Act (Division 7 of the Water Code, commencing with Section 13000), applicable state and federal regulations, all applicable provisions of statewide water quality control plans and policies adopted by the State Water Resources Control Board (SWRCB), the Santa Ana River Basin Plan adopted by the Santa Ana RWQCB, the California Toxics Rule, and the California Toxics Rule Implementation Plan. Regulatory compliance of development under the Project with the NPDES permit would, by extension, ensure compliance with these other applicable plans and regulations pertaining to water quality.

Implementation of the Project would implement additional development and redevelopment within the Project area that would increase impervious surfaces, and could therefore increase the amount of runoff and associated pollutants during both construction and operation of development. However, construction activities are required to comply with the NPDES Stormwater Discharge Permit. The City’s Pretreatment and Regulation of Wastes Ordinance and its Storm Drains Ordinance further protect water quality in the City and would be Redlands Regular Meeting of 10-18-22 1463 of 1815
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applicable to development projects under the Project. As a standard requirement in the City, individual development projects are required to demonstrate compliance with the applicable regulations prior to issuance of building or engineering permits.

Implementation of practices required by the NPDES permit would reduce the volume of runoff from impervious surfaces and increase the amount of natural filtration of pollutants from stormwater occurring onsite for the development projects, which would improve the quality of stormwater before it enters the City’s stormwater system.

The Project includes stormwater management guidelines that require a Water Quality Management Plan (WQMP) that incorporates Low Impact Development (LID) design principles and provide water quality improvements. Moreover, the Project also includes street and streetscape design standards that require runoff from public right-of-way to be treated per water quality standards of the San Bernardino County Stormwater Program Water Quality Management Plan and as approved by the City. Compliance with federal, state, and local water quality regulations will ensure that water quality is protected to the maximum extent practicable. Therefore, impacts from Project implementation would be less than significant.

Impact WQ-2 Finding: The Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin (Draft EIR at p. 5.8-9). Impacts are less than significant.

Facts in Support of Findings: A Water Supply Assessment (WSA) was prepared for the Project in order to coordinate local water supply and land use decisions per Senate Bill 610 (SB 610). Future land uses within the TVSP will utilize water from the local groundwater from the San Bernardino Basin (SBB) (also known as Bunker Hill Basin) and surface water supplies from Mill Creek and the Santa Ana River. Supplemental water is purchased from the State Water Project for direct deliveries only when the local sources cannot provide it or is needed for water quality.

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

Even with the additional demand of 639 AFY from the proposed TVSP land uses (639 AFY in addition to existing 13,916 AFY is approximately 14,555 AFY), the City will have surplus groundwater supplies available over the next 25 years. The WSA, included as Appendix F to the Draft EIR, includes an analysis of reliability of the City’s water supplies and concludes with a sufficiency analysis of water supply during normal, single-dry, and multiple dry years. The WSA identifies programs and activities that the City is managing to enforce lowering water demand and assist with sustainable water supply for the future. The City, inclusive of the proposed TVSP Project, will have an adequate supply of water now and 25 years into the future. The Western Judgment would continue to monitor and ensure the basins, as adjudicated, are pumped and replenished in accordance with imposed allocations and rights.

Additionally, the proposed Specific Plan would allow for additional development and redevelopment within the city that would increase the area of impervious surfaces. However, projects proposed within the Specific Plan area would be required to comply with City policies, such as Policy 6-A.40 and Policy 6-A.43, that require post-development stormwater runoff of projects to not exceed pre-development rates and to maximize the amount of pervious surfaces for the percolation of urban runoff. Depending on the type or size of the project, each project would be required to provide a WQMP, or if no WQMP is required, comply Redlands Regular Meeting of 10-18-22 1464 of 1815
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with other requirements which would include measures to collect and infiltrate stormwater in compliance with the requirements of the NPDES stormwater permit (NPDES Permit No. CAS618036 and RWCB Order R8- 2010-0036 for San Bernardino County) and support the recharge of the underlying groundwater basins.

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

Impact WQ-3i Finding: The Project would not substantially alter the existing drainage pattern of the area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in a substantial erosion or siltation on- or off-site (Draft EIR at p.

5.8-11). Impacts are less than significant.

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

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

The existing NPDES Construction General Permit requires preparation and implementation of a SWPPP by a QSD for the proposed construction activities (included as PPP HYD-1). The SWPPP is required to address site-specific conditions related to potential sources of sedimentation and erosion and would list the required BMPs that are necessary to reduce or eliminate the potential of erosion or alteration of a drainage pattern during construction activities.

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

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

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

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

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

While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area including:
• Preparing and processing a Letter of Map Revision based on hydrologic modeling, included as Appendix A to the TVSP, in order to remove approximately 155 properties from being subject to the City’s Floodplain Regulations;
• Implement the 2014 Master Plan of Drainage Alternative 1 for the Downtown Village; • Explore opportunities to implement a diversion drainage system that intercepts Zanja channel flows near or east of North Grove Street, where it would be conveyed parallel to the Zanja and be discharged into the Zanja upstream of the I-10 underpass; and • Increase the size of the Zanja at the Kansas Street, New York Street, and Tennessee Street crossings to increase flow capacity.

Projects built pursuant to the Specific Plan would be required to comply with requirements included under Chapter 3.56 of the City’s Municipal Code, Storm Drain Facilities Fees. Additionally, development applicants are required to pay development storm drain impact fees per Section 3.56.040, Storm Drain Fees, established for the purpose of constructing the storm facilities provided in the City's Master Storm Drain Plan.

Development proposed through the Specific Plan would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash. The Project could implement development that could result in substantial changes to existing drainage patterns within the Project area, through direct modification of existing storm drains or indirectly through the anticipated development of 2,400 dwelling units, 265,000 square feet of retail commercial, 238,000 square feet of office, 220 hotel rooms, and 280,000 square feet of open space and park area. However, drainage proposed as part of future development projects would comply with the City’s Master Storm Drain Plan, which would facilitate improvements to the City’s storm drain system.

Additionally, the MS4 permit requires any new development project to prepare a WQMP (included as PPP HYD-2) that includes post-construction BMPs to reduce the potential of erosion and/or sedimentation through site design and structural treatment control BMPs. As part of the permitting approval process for each project, proposed drainage and water quality design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the site-specific design limits the potential for erosion and siltation.

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Overall, the proposed drainage system and adherence to the existing regulations would ensure that Project impacts related to alteration of a drainage pattern and erosion/siltation from operational activities would be less than significant.

Plans, Program and Policies
PPP HYD-1 National Pollutant Discharge Elimination System (NPDES). Projects will be constructed in accordance with the NPDES General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities, NPDES No. CAS000002. Compliance requires a risk assessment, a SWPPP, and associated BMPs.

PPP HYD-2 Santa Ana RWQCB MS4 Permit. Projects will be constructed and operated in accordance with the Santa Ana RWQCB Municipal Stormwater (MS4) Permit for the part of the Santa Ana Basin in San Bernardino County in 2010 (Order No. R8-2010-0036). The MS4 Permit requires new development and redevelopment projects to adopt a WQMP to:
• Control contaminants into storm drain systems
• Educate the public about stormwater impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement BMPs and site-specific runoff controls and treatments Impact WQ-3ii Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site (Draft EIR at p. 5.8-13). Impacts are less than significant.

Facts in Support of Findings: The Specific Plan Area would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash.

Construction
Construction of the proposed Project could require demolition of the existing building structures, including foundations, floor slabs, and utilities systems. These activities could temporarily alter the existing drainage pattern of the site and could result in flooding on- or off-site if drainage is not properly controlled. However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site specific drainage issues related to construction and include BMPs to eliminate the potential of flooding or alteration of a drainage pattern during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to potential alteration of a drainage pattern or flooding on or off-site from development activities. Therefore, impacts would be less than significant.

Operation
As discussed previously, the Project area contains areas of flood risk. Per the Redlands Floodplain Regulations, in a FEMA Flood zone any new “occupiable” finished floor must be at least two feet above the one percent (100-year) base flood elevation. Any floodplain cross-section modifications (earthen platforms) may not cause more than one-foot water surface elevation increase upstream. These floodplain conditions create significant challenges to existing and new development, especially in commercial zones where zerostep entries are required.

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The buildout of the Project is anticipated to increase impervious surfaces, which would result in an increase of stormwater runoff volume and peak flow rates. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Improvements would be implemented by the City as regional drainage improvements.

However, projects proposed in implementation of the Specific Plan would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, the proposed drainage system and adherence to the existing NPDES permit regulations would ensure that Project impacts related to alteration of a drainage pattern or flooding from operational activities would be less than significant.

Plans, Program and Policies
PPP HYD-1: National Pollutant Discharge Elimination System (NPDES). As listed previously.

PPP HYD-2: Santa Ana RWQCB MS4 Permit. As listed previously.

Impact WQ-3iii Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff (Draft EIR at p. 5.8-14). Impacts are less than significant.

Facts in Support of Findings: The Specific Plan Area would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash.

Construction
As described in the previous response, construction of the proposed Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff and polluted runoff if drainage is not properly controlled. However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to increases in runoff and pollution from development activities. Therefore, impacts would be less than significant.

Operation
The existing topography of the Specific Plan area is relatively flat and generally drains from the east to the west. The Project area drains to an existing storm drain network that is discharged to five drainage areas within the City, including Mission Zanja, Reservoir Canyon, Downtown, North City, and South City. The TVSP area has historically experienced flooding during moderate storm events. Development of the Project could increase impervious surface area within the TVSP area, which could result in additional stormwater runoff Redlands Regular Meeting of 10-18-22 1468 of 1815
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that could further exceed the existing drainage system and contribute to additional sources of stormwater pollutants. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Additionally, the City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues through incorporation of new stormwater infrastructure and BMPs, such as construction of a large culvert adjacent to Redlands Boulevard and implementation of a bypass structure for the Zanja drainage system. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans.

Additionally, projects would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Proposed project design would be reviewed for consistency during design check by the City.

Additionally, the MS4 permit requires any new development project to prepare a WQMP (included as PPP HYD-2), or if a WQMP is not required, comply with other measures that includes post-construction BMPs to reduce the potential of stormwater runoff pollution through site design and structural treatment control BMPs.

As part of the permitting approval process for each project, proposed drainage and water quality design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the site-specific design would adequately treat and capture onsite stormwater runoff. Overall, with compliance to the existing regulations as verified by the City’s permitting process, Project impacts related to the capacity of the drainage system and polluted runoff would be less than significant.

Plans, Program and Policies
PPP HYD-1: National Pollutant Discharge Elimination System (NPDES). As listed previously.

PPP HYD-2: Santa Ana RWQCB MS4 Permit. As listed previously.

Impact WQ-3iv Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows (Draft EIR at p. 5.8-16). Impacts are less than significant.

Facts in Support of Findings:

Construction
Construction of the proposed Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff. However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of increased runoff during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to increases in runoff from development activities. Therefore, impacts would be less than significant.

Operation
As discussed previously, the Project area contains areas of flood risk. Per the Redlands Floodplain Regulations, in a FEMA zone any new “occupiable” finished floor must be at least two feet above the one Redlands Regular Meeting of 10-18-22 1469 of 1815
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percent (100-year) base flood elevation. Any floodplain cross-section modifications (earthen platforms) may not cause more than one-foot water surface elevation increase upstream. These floodplain conditions create significant challenges to existing and new development, especially in commercial zones where zero-step entries are required.

The buildout of the Project is anticipated to increase impervious surfaces, which would result in an increase of stormwater runoff volume and peak flow rates. The City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues through incorporation of new stormwater infrastructure and BMPs, such as construction of a large culvert adjacent to Redlands Boulevard and implementation of a bypass structure for the Zanja drainage system. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Improvements would be implemented by the City as regional drainage improvements. However, projects proposed in implementation of the Specific Plan would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to address the City’s flooding issues. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, the proposed drainage system and adherence to the existing NPDES permit regulations would ensure that Project impacts related to alteration of a drainage pattern or flooding from operational activities would be less than significant.

Plans, Program and Policies
PPP HYD-1: National Pollutant Discharge Elimination System (NPDES). As listed previously.

PPP HYD-2: Santa Ana RWQCB MS4 Permit. As listed previously.

Impact WQ-4 Finding: The Project would not risk release of pollutants due to Project inundation within a flood hazard zone (Draft EIR at p. 5.8-17). Impacts are less than significant.

Facts in Support of Findings: The Specific Plan Area would consist of infill development of new residential and commercial uses within 0.5 mile of each of the three new Arrow stations, which is not anticipated to result in direct modifications to existing drainage channels, Mill Creek Zanja and the Morey Wash.

Construction
Construction of the proposed Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased polluted runoff.

However, as described previously, implementation of the Project requires a SWPPP (included as PPP HYD1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities.

This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD1) as verified by the City through the construction permitting process would prevent construction-related impacts related to increases in runoff and pollution from development activities. Therefore, impacts would be less than significant.

Operation
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The Project would facilitate the development of new residential uses within the TVSP area. Development of the Project could increase impervious surface areas and introduce additional residential uses within the TVSP area, which could result in additional sources of stormwater pollutants. The TVSP has historically experienced flooding and parts of the TVSP area are within a designated floodplain. While the TVSP does not include specific drainage system improvements, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Additionally, the City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues through incorporation of new stormwater infrastructure and BMPs, such as construction of a large culvert adjacent to Redlands Boulevard and implementation of a bypass structure for the Zanja drainage system. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans. Additionally, projects would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Proposed project design would be reviewed for consistency during design check by the City.

Additionally, the MS4 permit requires any new development project to prepare a WQMP (included as PPP HYD-2) that includes post-construction BMPs to reduce the potential of stormwater runoff pollution through site design and structural treatment control BMPs. As part of the permitting approval process for each project, proposed drainage and water quality design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the site-specific design would adequately treat and capture onsite stormwater runoff. Overall, with compliance to the existing regulations as verified by the City’s permitting process, Project impacts related to the release of pollutants due to project inundation would be less than significant.

Plans, Program and Policies
PPP HYD-1: National Pollutant Discharge Elimination System (NPDES). As listed previously.

PPP HYD-2: Santa Ana RWQCB MS4 Permit. As listed previously.

Impact WQ-5 Finding: The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan (Initial Study at pp. 74-75). Impacts are less than significant.

Facts in Support of Findings: The City is within the Santa Ana RWQCB jurisdiction. The Santa Ana RWQCB adopted the Santa Ana Region Basin Plan which designates beneficial uses for all surface and groundwater within their jurisdiction and establishes the water quality objectives and standards necessary to protect those beneficial uses. As summarized below, the Project would comply with the applicable NPDES permits, and implement construction and operational BMPs to reduce pollutants of concern in stormwater runoff.

Construction activity within the City is required to comply with the NPDES Stormwater Discharge Permit. The City’s Pretreatment and Regulation of Wastes Ordinance and its Storm Drains Ordinance further protect water quality in the City and would be applicable to development projects under the Project. Implementation of practices required by the NPDES permit and verified through City construction and operational permitting would reduce the volume of runoff from impervious surfaces and increase the amount of natural filtration of pollutants from stormwater occurring onsite for the development projects, generally improving the quality of stormwater before it infiltrates into the groundwater basin.

The Project includes stormwater management guidelines that requires a WQMP, and street and streetscape standards that require runoff from public right-of-way to be treated per water quality standards of the San Redlands Regular Meeting of 10-18-22 1471 of 1815
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Bernardino County Stormwater Program Water Quality Management Plan and as approved by the City.

The Project in conjunction with City policies promote the protection of the City’s natural water bodies, prevent water pollution, ensure preparation and implementation of applicable water quality plans, require incorporation of BMPs, and otherwise ensure compliance with the City’s NPDES permit. As such, Project implementation would not result in water quality impacts that would conflict with the RWQCB’s Santa Ana Region Basin Plan.

The Bunker Hill Basin, which underlies the City, stores approximately five million acre-feet of water and is recharged by rain, runoff from the surrounding mountains, and imported water. The Bunker Hill Basin provides water to the cities of Redlands, Highland, San Bernardino, Loma Linda, Colton, Rialto, Fontana, Grand Terrace, Riverside, and portions of unincorporated San Bernardino County. Regarding a sustainable groundwater management plan, in September, 2014, the California Legislature enacted the Sustainable Groundwater Management Act of 2014 (SGMA), which established a statewide framework, and granted new authorities and responsibilities to local agencies, for the sustainable management of groundwater resources. While adjudicated basins, such as the Bunker Hill Basin in the San Bernardino Basin Area (SBBA), are not subject to most provisions of the SGMA, local agencies, such as the City, are expected to responsibly manage the SBBA in accordance with common sustainability principles. Using SGMA as a model to achieve water supply reliability and long-term groundwater sustainability, in 2015, the City and other local water agencies began meeting to identify and develop a Groundwater Sustainability Council for the SBBA, which is presently known as the Groundwater Council (GC). The City is the second largest user of groundwater within the SBBA, and as a voting member of the GC, is a participant as critical SBBA sustainability decisions are made, and GC membership fees are used, to purchase water during "wet" years when supplies are less expensive and more readily available.

Early efforts in the development of the GC identified water resources to ensure a sustainable water supply into the future and to equitably share the cost of those resources among SBBA pumpers. Ultimately, the GC developed two (2) primary tools to sustain the SBBA: (i) method to allocate the costs of sustainable basin management, and (ii) a five-year agreement that establishes an organizational structure to administer the process, known as the San Bernardino Basin Groundwater Council Framework Agreement. The agreement is for a five-year initial term, and is currently in its third year. The fourth year budget was recently approved by the GC in January, 2021.

The GC provides the funding, integration, and agency coordination necessary to manage imported water, and associated groundwater replenishment facilities, within the SBBA. The GC partners collaborate to manage the SBBA, including accessing and applying imported water supplies to augment and complement native water supplies. The goal of the GC is to maintain the long-term yield of the SBBA by ensuring overdraft, or other negative impacts, are prevented in the future, and to take advantage of imported water replenishment opportunities as they arise.

Participation in the GC is open to groundwater producers in the SBBA. Current members include Redlands, the cities of Colton, Loma Linda, Rialto, and San Bernardino the East Valley Water District, West Valley Water District, San Bernardino Valley Municipal Water District, San Bernardino Valley Water Conservation District, West valley Water District and the Yucaipa Valley Water District, the Bear Valley Mutual Water Company and the Fontana water, and Loma Linda University.

The 2015 San Bernardino Valley Regional Urban Water Quality Control Management Plan (UWMP), amended in June 2017, also provides management strategies to meet targets for future water use, including groundwater supply from the Bunker Hill Basin. The WQMP for the Project addresses quality and quantity of stormwater runoff and provides BMPs for construction and operation to ensure compliance with the current General Stormwater Permit. The Project would also be consistent with the management strategy outlined by the UWMP for local surface water and groundwater in the San Bernardino Valley. Therefore, as Project implementation would not conflict with a water quality control plan or sustainable groundwater management plan, impacts would be less than significant.

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Hydrology and Water Quality Cumulative Findings: The Project would not result in cumulative impacts related to hydrology and water quality (Draft EIR at p. 5.7-12).

Facts in Support of Findings:

Water Quality: The geographic scope for cumulative impacts related to hydrology and water quality includes the Santa Ana Watershed because cumulative projects and developments pursuant to the proposed Project could incrementally exacerbate the existing impaired condition and could result in new pollutant related impairments. Related developments within the watershed would be required to implement water quality control measures pursuant to the same NPDES General Construction Permit that requires implementation of a SWPPP (for construction), a WQMP (for operation) and BMPs to eliminate or reduce the discharge of pollutants in stormwater discharges, reduce runoff, reduce erosion and sedimentation, and increase filtration and infiltration, in areas permitted. The NPDES permit requirements have been set by the SWRCB and implemented by the RWQCB to reduce incremental effects of individual projects so that they would not become cumulatively considerable. Therefore, overall potential impacts to water quality associated with present and future development in the watershed would not be cumulatively considerable with compliance with all applicable laws, permits, ordinances and plans. As detailed previously, the proposed Project would be implemented in compliance with all regulations, as would be verified during the permitting process. Therefore, cumulative impacts related to water quality would be less than significant.

Drainage: The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area served by the existing stormwater infrastructure for the City’s Master Drainage Plan area, from capture of runoff through final discharge points. As described above, TVSP does not include specific drainage system improvements; however, the TVSP includes multiple recommendations related to drainage improvements within the Project Area. Additionally, the City’s Master Drainage Plan outlines several alternatives that would reduce the City’s flooding issues. Projects proposed in implementation of the TVSP would be required to be consistent with the City’s drainage plans. Additionally, projects would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. As a result, the proposed Project would not generate runoff that could combine with additional runoff from cumulative Projects that could cumulatively combine to impact drainage. Thus, cumulative impacts related to drainage would be less than significant.

Groundwater Basin: The geographic scope for cumulative impacts related to the groundwater basin is the Bunker Hill Subbasin of the Upper Santa Ana Groundwater Basin. As described previously, the volume of water that would be needed by the Project is within the anticipated groundwater pumping volumes.

Therefore, the Project would not result in changes to the projected groundwater pumping that would decrease groundwater supplies. As a result, the proposed Project would not generate impacts related to the groundwater basin that have the potential to combine with effects from other projects to become cumulatively considerable. Therefore, cumulative impacts related to the groundwater basin would be less than significant.

K. Land Use and Planning
Impact LU-1 Finding: The Project would not physically divide an established community (Initial Study at p. 77). No impacts would occur.

Facts in Support of Findings: The Project is anticipated to facilitate the development of a more cohesive community, and connectivity through focusing on improvements to roadways as corridors for multiple modes of travel (including pedestrians, bicycles, transit options, and motor vehicles). The Project would provide for infill and redevelopment of parcels within and around the Esri campus, Downtown, and southern portion of the University of Redlands (portions of which are currently bisected by the Interstate 10 freeway), which Redlands Regular Meeting of 10-18-22 1473 of 1815
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would not physically divide an established existing community. The Project would also “break up” superblocks with the introduction of new streets, restoring a more pedestrian- and circulation-friendly grid pattern to the area, which would improve community connectivity and not physically divide the community. The Project public realm and landscaping plan would interconnect the three transit villages as well by providing connected open space and parks. The Project does not include any components that would physically divide the community. Therefore, no impacts would occur.

Impact LU-2 Finding: The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect (Draft EIR at p. 5.9-4). Impacts are less than significant.

Facts in Support of Findings:
2020 RTP/SCS. The 2020 RTP/SCS Goals that are relevant to the proposed Project focus largely on maximizing mobility, encouraging development patterns and densities that reduce infrastructure costs, and provide for efficiency. The proposed Project would be consistent with the applicable SCAG’s 2020 RTP/SCS goals, as detailed in Draft EIR Table 5.9-1 on pages 5.9-4 through 5.9-5. Therefore, implementation of the proposed Project would not result in conflict with RTP/SCS goals, and impacts would not occur.

Land Use Consistency. 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. Areas south of the Project have a General Plan Land Use Designation of low density residential, medium density residential, high density residential, public institutional, commercial, and office. Areas to the north have a General Plan Land Use Designation of low density residential, medium density residential, low medium density residential, and commercial. Areas to the west have a land use designation of commercial/industrial and commercial. Areas to the east have a low density residential General Plan Land Use Designation.

California law (Government Code §65450-§65453) allows cities to develop and administer Specific Plans as an implementation tool for their General Plan. As a requirement of state law, Specific Plans must demonstrate consistency in regulations, guidelines and programs with the goals, objectives, policies, standards, programs and uses that are established in the General Plan. The proposed Specific Plan would implement General Plan policies related to infill development, providing a supply of non-residential development area within the City, provision of housing for employees, and increasing use of alternative methods of circulation. The proposed TVSP provides for infill development that would make use of the existing circulation and utility infrastructure and provide mixed-use and higher density housing opportunities that provide affordability. The TVSP addresses the consistency of the TVSP with the relevant City’s General Plan and said analysis is incorporated by reference into the Draft EIR. Therefore, impacts related to land use inconsistency would be less than significant.

General Plan Goals, Policies, and Objectives. A detailed analysis of the proposed Project’s consistency with the applicable goals, policies, and objectives of the City’s General Plan that serve to avoid or mitigate environmental impacts is provided in Draft EIR Table 5.9-2. As described in the Table, the proposed Project would be consistent with the relevant goals, policies, and objectives of the City’s General Plan that avoid or mitigate environmental impacts, and impacts related to conflict with a General Plan policy related to an environmental effect would be less than significant.

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, Redlands Regular Meeting of 10-18-22 1474 of 1815
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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.

Land Use and Planning Cumulative Findings: The Project would not result in cumulative impacts related to land use and planning (Draft EIR at p. 5.9-23).

Facts in Support of Findings: 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 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.

L. Mineral Resources
Impact MIN-1 Finding: The Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state (Initial Study at p. 78). Impacts are less than significant.

Facts in Support of Findings: Large areas in the northern portion of the City around the Santa Ana River wash are classified as MRZ-2, which contains high quality construction aggregates (e.g., sand, gravel, and crushed stone) that have been mined since the 1920s. Active mining in the Santa Ana River wash is located on both sides of the boundary between the cities of Redlands and Highland, and new areas are currently being proposed for mining along the northern boundary of the City. This mining operations in the Santa Ana River wash are not within or adjacent to the Project http://usrpt.com/area.

The northwestern portion of the New York Street/Esri Transit Village area is within MRZ-2 (GP2035 EIR, Figure 3.11-1). 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. Therefore, impacts would be less than significant from implementation of the Project.

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Impact MIN-2 Finding: The Project would not result in the loss of availability of a locally-important mineral resource recovery site delineated on the general plan, specific plan or other land use plan (Initial Study at p. 79). Impacts are less than significant.

Facts in Support of Findings: The Project area does not include areas designated for mining in any land use plan. Also, as described previously, implementation of the Project would not result in the loss of availability of a known mineral resource recovery site. Therefore, impacts would be less than significant from implementation of the Project.

Mineral Resources Cumulative Findings: The Project would not result in cumulative impacts related to mineral resources.

Facts in Support of Findings: 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 significant impacts to mineral resources and impacts would not be cumulatively considerable.

M. Noise
Impact N-3 Finding: The Project would not expose people residing or working in the project area to excessive noise levels, 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 (Initial Study at p. 81). Impacts are less than significant.

Facts in Support of Findings: The nearest airports to the Project area are Redlands Municipal Airport, approximately 1.5 miles to the northeast of the University Transit Village, and San Bernardino International Airport, approximately three miles northwest of the New York Street/Esri Transit Village. The Project area is not within the airport compatibility zones for either the Redlands Municipal Airport or San Bernardino International Airport (GP2035 EIR, p. 3.7-2), nor is the Project area within the modeled noise contours for the Redlands Municipal Airport (GP2035 EIR, Figure 3.12-3) or San Bernardino International Airport (GP2035 EIR, Figure 3.12-4). There are no private airstrips in the vicinity of the Project area (AirNav 2020).

Thus, individual development projects under the Project would not expose people residing or working in the Project area to excessive noise levels from airport operations. Therefore, impacts would be less than significant.

N. Population and Housing
Impact POP-1 Finding: The Project would not induce substantial unplanned population growth in an area, either directly or indirectly (Draft EIR at p. 5.11-6). Impacts are less than significant.

Facts in Support of Findings: The amount of new development proposed under the TVSP 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 form-based code to achieve preferred building forms and design, promote compact and walkable urban form in the vicinity of the train stations, introduce a greater variety of transportation options (and reduce vehicle trips and vehicle miles traveled), and provide more public open space and amenities that provides aesthetic and community benefits. Therefore, the Project would not induce population growth, it would just provide for the form and function of future development.

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

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Residential Development. 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. 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, 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 feet of non-residential uses, the Project is estimated to result in approximately 1,226 job opportunities.

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, Draft EIR 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.

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• 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 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.

Impact POP-2 Finding: The Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere (Initial Study at pp. 82-83). No impacts would occur.

Facts in Support of Findings: The Project would not result in the displacement of substantial number of existing housing, nor would it result in the displacement of substantial numbers of people within the Project area. The Project provides for infill development and redevelopment and would include a mix of residential, commercial (retail and office), hotel, and civic uses. Individual development projects pursuant to the Project may result in temporary displacement of residents during construction activities. However, development projects would occur at a parcel-by-parcel project level. The potential displacement of persons residing on an infill or redevelopment parcel (if any) would be short-term, and the Project would result in a greater number of residential units to house residents of the area. Therefore, impacts related to displacement of housing or persons that would require replacement housing elsewhere would not occur.

Population and Housing Cumulative Findings: The Project would not result in cumulative impacts related to population and housing (Draft EIR at p. 5.9-23).

Facts in Support of Findings: 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 Redlands Regular Meeting of 10-18-22 1478 of 1815
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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.

O. Public Services
Fire Protection
Impact PS-1 Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire service facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for fire protection services (Draft EIR at p. 5.12-6). Impacts are less than significant.

Facts in Support of Findings: 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 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.

Plans, Programs, or Policies:

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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.

Police Services
Impact PS-2 Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police service facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for police services (Draft EIR at p. 5.12-7). Impacts are less than significant.

Facts in Support of Findings: 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, 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. Therefore, impacts to police protection facilities would be less than significant.

Plans, Programs, or Policies:

PPP PS-1: Development Impact Fees. Listed previously.

School Facilities
Impact PS-3 Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, the construction fo which could cause significant environmental impacts (Initial Study at pp. 85-86). Impacts are less than significant.

Facts in Support of Findings: The City, including the Project area, is within the Redlands Unified School District (RUSD). RUSD has 16 elementary schools (grades K-5), four middle schools (grades 6-8), and three comprehensive high schools (grades 9-12), an alternative high school, an independent study program, home education learning program, and a grades K-12 online academy. Current enrollment at RUSD is approximately 21,233 students (RUSD 2020). As new residential units would be included in the Project, the school-aged population is expected to increase and increase enrollment at Redlands schools.

The Leroy F. Greene School Facilities Act of 1998 (SB 50) sets a maximum level of fees a developer may be required to pay to mitigate a project’s impacts on school facilities. The maximum fees authorized under SB 50 apply to zone changes, general plan amendments, zoning permits and subdivisions. Development fees are required to be paid pursuant to development conditions of approval. Pursuant to SB 50, the payment of these school fee amounts provided for in Government Code Sections 65995, 65995.5, and 65995.7 would constitute full and complete mitigation for school facilities. That is to say, SB 50 states that the exclusive method of mitigating the impact of school facilities according to CEQA is to pay the maximum school fees and that such fees are “deemed to provide full and complete school facilities mitigation” related to the adequacy of school facilities when considering approval or the establishment of conditions for the approval of a development project (Government Code 65996(a) and (b)).

Pursuant to California Government Code Section 65995.5-7, RUSD has instituted school facility fees that would apply to Project implementation, specifically fees for new residential construction and commercial construction based on square footage. Accordingly, project applicant(s) are required to pay school fees to RUSD to offset the impact of additional student enrollment at schools serving the individual development project site.

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Pursuant to state law, payment of the school fees established by RUSD in accordance with existing rules and regulations regarding the calculation and payment of such fees, would, by law, mitigate the Project’s impacts on schools’ facilities. Thus, impacts on school facilities would be less than significant Park Facilities
Impact PS-4 Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities, the construction of which could cause significant environmental impacts (Draft EIR at p. 5.12-7). Impacts are less than significant.

Facts in Support of Findings: 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. 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 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.

Plans, Programs, or Policies:

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.

Other Services:

Impact PS-5 Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered other public facilities, the construction of which could cause significant environmental impacts (Draft EIR at p. 5.12-8). Impacts are less than significant.

Facts in Support of Findings: 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 Redlands Regular Meeting of 10-18-22 1481 of 1815
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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.

Public Services Cumulative Findings: The Project would not result in cumulative impacts related to public services (Draft EIR at p. 5.12-8).

Facts in Support of Findings: 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.

P. Recreation
Impact REC-1 Finding: The Project would not result in increased use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated (Draft EIR at p. 5.13-3). Impacts are less than significant.

Facts in Support of Findings: 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.

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 Redlands Regular Meeting of 10-18-22 1482 of 1815
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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.

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.

Plans, Programs, or Policies:

PPP PS-2: Park Fees. As listed previously.

Impact REC-2 Finding: The Project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment (Draft EIR at p. 5.13-4). Impacts are less than significant.

Facts in Support of Findings: 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.

Recreation Cumulative Findings: The Project would not result in cumulative impacts related to public services (Draft EIR at p. 5.13-5).

Facts in Support of Findings: 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, Redlands Regular Meeting of 10-18-22 1483 of 1815
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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.

Q. Transportation
Impact TR-1 Finding: The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities (Draft EIR at p. 5.14-7).

Impacts are less than significant.

Facts in Support of Findings:

Roadway Network: The TVSP area includes a variety of roadway types. 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.

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.

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 Redlands Regular Meeting of 10-18-22 1484 of 1815
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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.

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-3 Finding: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) (Initial Study at p. 90). Impacts are less than significant.

Facts in Support of Findings: The Project would introduce roadway and streetscape designs that would facilitate multi-modal streets that conveniently and safely accommodate a variety of users, including pedestrians, bicyclists, transit riders, and motorists. The Project roadway network would include, among other considerations, roadways designed according to the adjacent building intensities and uses, traffic calming offsets, and narrow lane widths and tight curb radii. These design considerations would not constitute a design hazard but would serve to slow automobile travel speeds and require heightened driver awareness of the surroundings to enhance the safety of bicyclists and pedestrians as well as safety of other motorists.

The Project land uses represent urban TOD and would not create hazards from incompatible uses in the Project area or with the surrounding area. Future individual development projects under the Project 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 hazardous design conditions.

Therefore, impacts from Project implementation would be less than significant.

Impact TR-4 Finding: The Project would not result in inadequate emergency access (Initial Study at p. 90).

Impacts are less than significant.

Facts in Support of Findings: The Project would introduce roadway and streetscape designs that would facilitate multi-modal streets that conveniently and safely accommodate a variety of users, including pedestrians, bicyclists, transit riders, and motorists. The transportation network design in the Project also considers emergency access and accommodates emergency vehicles. As the Project would break up the superblocks in the Project area by introducing new roadways in a more traditional grid pattern, the improved connectivity would benefit emergency vehicles by increasing turning movement options and routes. Moreover, construction of development projects under the Project would require the presence of construction equipment and materials adjacent to roadways. Construction activities would be required to ensure emergency access in accordance with California Fire Code Section 503 (CCR Title 24, Part 9), which would be confirmed and approved through the City’s standard development review and permitting process. Therefore, impacts from Project implementation would be less than significant.

R. Utilities and Service Systems
Wastewater
Impact UT-4 Finding: 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. (Draft EIR at p. 5.16-11). Impacts are less than significant.

Facts in Support of Findings: 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.

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Wastewater demand associated with the buildout of the TVSP would be typical of residential and commercial wastewater usage in the City of Redlands. The proposed Project would generate a demand for approximately 551,134 gallons per day (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.

Solid Waste
Impact UT-6 Finding: 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 (Draft EIR at p. 5.16-17). Impacts are less than significant.

Facts in Support of Findings:

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 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
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. 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.

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.

Impact UT-7 Finding: The Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste (Initial Study at pp. 94-95). Impacts are less than significant.

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Facts in Support of Findings: The California Integrated Waste Management Act (AB 939) changed the focus of solid waste management from landfill to diversion strategies (e.g., source reduction, recycling, and composting). The purpose of the diversion strategies is to reduce dependence on landfills for solid waste disposal. AB 939 established mandatory diversion goals of 25 percent by 1995 and 50 percent by 2000.

AB 341 (2011) amended AB 939 to include a provision declaring that it is the policy goal of the state that not less than 75 percent of solid waste generated be source-reduced, recycled, or composted by the year 2020 and annually thereafter. In addition, AB 341 requires California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal.

According to the City’s General Plan Sustainable Community Element, future solid waste reduction strategies include improved commercial recycling diversion rates, enhanced food waste diversion, and exploring the potential to generate energy using biomethane from the City’s landfill and wastewater treatment plant, among other strategies.

Individual development projects proposed under the Project would be required comply with RMC Section

13.66.040, Construction and Demolition Recycling Requirements, which requires that no demolition permit or building permit shall be issued for any development activity unless the construction and demolition recycling plan has been approved by the municipal utilities director. In addition, individual development projects under the Project would be required to comply with all federal, state, and local regulations related to solid waste, and toward that end, the Project would comply with all applicable standards related to solid waste diversion, reduction, and recycling during construction and operation. Therefore, implementation of the Project would result in less than significant impacts related to potential conflicts with federal, state, and local management and reduction statutes and regulations pertaining to solid waste.

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SECTION III

IMPACTS MITIGATED TO A LEVEL OF LESS THAN SIGNIFICANT
The City hereby finds that mitigation measures have been identified in the EIR that would avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level.

The potentially significant impacts and the mitigation measures that would reduce them to a less than significant level are detailed in the EIR and summarized below.

A. Aesthetics
Impact AE-2 Finding: The Project would not substantially damage scenic resources, including trees, rock outcroppings, and historic buildings within a state scenic highway. (Draft EIR at p. 5.1-9). Impacts are less than significant with mitigation.

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

Upon implementation of the TVSP parcels along Orange Street north of the I-10 to Lugonia Avenue would be designated as Village General (VG), Village Corridor (COR), and Special District 1 (SD1). Individual development projects proposed under the Project could be built along State Route 38 per the design guidelines and standards set forth in the TVSP. The TVSP would guide infill development, which would alter the existing visual character of the State Route 38 corridor over the plan implementation period (through 2040) by introducing additional commercial, residential, and/or mixed-use development to the Orange Street area. However, as previously discussed, the majority of the State Route 38 corridor along Orange Street is already developed with commercial, residential, and institutional uses, and all of the parcels along the corridor area already designated for Commercial or Public/Institutional development by the City of Redlands General Plan. As discussed above, parcels along the eligible portion of Orange Street are zoned Highway Commercial (C-4), which does not prescribe a building height limit, and Educational (E), which does not prescribe a building height limit and requires a Conditional Use Permit for structures over 35 feet. The TVSP would designate these parcels as Village General (VG), which prescribes an average building height of three stories, Village Corridor (COR), which prescribes a building height of two stories maximum, and Special District 1 (SD1). The majority of parcels along the eligible portion of Orange Street, besides those adjacent to the freeway, would be designated as Village Corridor (COR), which would limit height of new development to two stories, consistent with existing building heights. Therefore, structures resulting from the TVSP would be generally within the heights of the existing developed parcels, as allowed by the Redlands General Plan and Municipal Code, along State Route 38 and would not block views of scenic resources, such as the San Bernardino foothills, as implementing project structures would be consistent with views presently found in the area. As shown on Figure 2-1 of the City of Redlands General Plan, three properties along the State Route 38 corridor within the TVSP Area are Local Historic Landmarks/Resources. Any future development projects that might affect or alter historic or scenic resources must first be reviewed and approved by the City’s Historic and Scenic Preservation Commission.

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

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

Therefore, with implementation of the historic design standards that would be implemented as part of the TVSP (provided as PPP CUL-1) and Mitigation Measure CUL-1, impacts related to damaging historic resources within a state scenic highway would be less than significant.

Plans, Program and Policies:

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

Mitigation Measures:

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

Impact AE-4 Finding: The Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. (Draft EIR at p. 5.1-13). Impacts are less than significant with mitigation.

Facts in Support of Findings: Light and glare sensitive uses include the existing residences, motorists, and pedestrians and the proposed residences, motorists, and pedestrians that are located within the TVSP area.

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

Operation
Lighting
The proposed TVSP area is urbanized and includes a mix of residential, commercial, industrial, and office land uses. The majority of the TVSP area is developed with few vacant parcels. Sources of light include interior and exterior building lighting, parking lot lighting, vehicular lighting, street lighting, and landscape lighting. Implementation of the proposed Project would increase overall nighttime lighting because it would result in greater intensity and density of land uses than currently exists. New lighting would accompany all new development, including exterior lighting for streetlights, parking lots, signs, walkways, and interior lighting, which could be visible through windows to the outside. In addition, existing and proposed residential uses, considered light-sensitive receptors, would be located throughout the TVSP area.

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

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

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

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

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

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

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

Mitigation Measures:

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

Aesthetics Cumulative Findings: The Project would not result in cumulative impacts related to aesthetics (Draft EIR at pp 5.1-14 through 5.1-15).

Facts in Support of Findings:

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

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

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

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

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

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

B. Air Quality
Impact AQ-3 Finding: The Project would not result in exposure of sensitive receptors to substantial pollutant concentrations (Draft EIR p. 5.2-22). Impacts are less than significant with mitigation.

Facts in Support of Finding:

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

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

CO Hotspots
An adverse CO concentration, known as a “hot spot”, would occur if an exceedance of the state one-hour standard of 20 ppm or the eight-hour standard of 9 ppm were to occur. In 2003, the SCAQMD estimated that a project would have to increase traffic volumes at a single intersection by more than 44,000 vehicles per hour—or 24,000 vehicles per hour where vertical and/or horizontal air does not mix—in order to generate a CO hot spot.

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

Mitigation Measures:

Mitigation Measure AQ-9: Localized Emissions. For implementing projects within the TVSP area, the applicant shall be responsible for submitting a focused project-level air quality assessment that includes the modeling of localized on-site emissions associated with daily grading activities anticipated for the proposed development. During the City’s review process of development applications in the TVSP area, the applicant shall conduct or shall have conducted modeling of the regional and the localized emissions (nitrogen oxides [NOX], carbon monoxide [CO], Particulate Matter 10 microns in diameter or less [PM10], and Particulate Matter 2.5 microns in diameter or less [PM2.5]) associated with the maximum daily grading activities estimated for the proposed individual developments. If the modeling shows that emissions would exceed the SCAQMD’s significance thresholds for those emissions, the maximum daily grading activities of the proposed development shall be limited to the extent that could occur without resulting in emissions in excess of SCAQMD’s significance thresholds for those emissions.

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

C. Cultural Resources
Impact CUL-1 Finding: The Project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5. (Draft EIR at p. 5.3-12) Impacts are less than significant with mitigation.

Facts in Support of Findings: The TVSP area contains 25 historic properties are listed in the California Register of Historical Resources and the National Register of Historic Places. In addition, other structures are eligible or potentially eligible for a historic designation (however, application for local designation would require the property owner’s authorization). Also, the Specific Plan would be built out through 2040, and over that time additional buildings and/or structures in the city could become 50 years of age or more, and therefore potentially historic resources if certain criteria are met.

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

Historic residential structures are subject to the following provisions:

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

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

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

Plans, Program and Policies:

PPP CUL-1, as listed previously.

Mitigation Measures:

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Mitigation Measure CUL-1, as listed previously.

Impact CUL-2 Finding: The Project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Draft EIR at p. 5.3-14) Impacts are less than significant with mitigation.

Facts in Support of Findings: The records search conducted for the Project identified that 53 cultural resources investigations have been previously completed within a 0.5-mile radius of the TVSP area. Of these, 33 of the previously conducted investigations are directly within the TVSP area (MCC 2022). The records search conducted for the Project identified one previously recorded prehistoric archaeological resource, one historic archaeological resource with a prehistoric component, and twenty-four historic archeological resources within TVSP area (MCC 2022).

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

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

Mitigation Measures:

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

Mitigation Measure CUL-3: Native American Coordination. Where a recorded Native American archaeological site is identified, the City shall initiate coordination with identified California Indian tribes. It should be noted that during the coordination process, tribal representative(s) will be directly involved in making recommendations regarding the significance of a prehistoric archaeological site, which could be considered a historic tribal cultural resource listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k).

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

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

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

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

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

At least 90 days prior to issuance of grading permits, the project permittee/owner shall retain a qualified archaeological monitor to prepare the ARMP and to monitor all ground-disturbing activities in an effort to identify any unknown archaeological resources. Qualified archaeological monitor(s) will have a minimum of a bachelor’s degree, verifiable training and one year of monitoring experience in Southern California on similar projects. Prior to grading, the project permittee/owner shall provide to the City Development Services Department verification that a qualified monitor has been retained. Monitors will report to the Project Archaeologist for the Project and may work in collaboration with Native American monitors for tribal cultural resources that may be a historical resource as defined in Public Resources Code section 5020.1(k). • The Project Archaeologist shall meet the U.S. Secretary of the Interior Standards. • Any newly discovered archaeological resource deposits shall be subject to a formal significance evaluation.

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• The Project Archaeologist will work in coordination with consulting tribes, the permittee/owner, and the City on the ARMP to address the details, timing, and responsibility of all archaeological activities that will occur on the project site. Details in the plan shall include, at a minimum:
a. Project grading and development scheduling;
b. The development of a schedule in coordination with the permittee/owner/consulting Native American tribes and the Project Archaeologist during grading, excavation and ground-disturbing activities on the site: including the scheduling, safety requirements, duties, scope of work, and Native American tribal monitors’ authority to stop and redirect grading activities in coordination with all project archaeologists; and, c. The protocols and stipulations that the permittee/owner, City, tribes, and Project Archaeologist will follow in the event of inadvertent archaeological resource discoveries, including any newly discovered archaeological resource deposits that shall be subject to a archaeological resources evaluation.
• A final report documenting the monitoring activity and disposition of any recovered archaeological resources shall be submitted to the City of Redlands, South Central Coast Information Center (SCCIC), and consulting tribes within 60 days of completion of monitoring.

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

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

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

Archaeological monitoring will include inspection of exposed cut surfaces and spoils piles. Monitors maintain close communication with the on-site construction personnel to maintain a safe working environment and to be fully appraised of the upcoming Project activity areas and any schedule changes. All monitors shall complete daily documentation of all construction activities requiring monitoring, including the location of monitoring activities throughout the day, observations of sediment type and distribution, observations regarding resources, collection of resources and other information. This documentation will be prepared by each monitor on each shift, in a Daily Field Monitoring Summary and Daily Artifact Collection log, as relevant Redlands Regular Meeting of 10-18-22 1497 of 1815
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to the discoveries each day. The monitor shall photograph ground disturbing activities, sediment, and resources for documentation purposes and will fill out a Photograph Log each day. The Daily Field Monitoring Summary, Daily Artifact Collection Log and/or Photograph Log comprise the field notes. These notes shall be filed weekly with the Project Archaeologist and be made available to the Proponent and City upon request.

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

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

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

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

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

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

I. Archaeological Sites
Archaeological sites consist of more than three artifacts in one location. In addition, sites may have features such as rock ovens, burials, and other human-created alterations of the natural environment - with or without the presence of artifacts. Sites and features require evaluation to determine if they meet significance criteria as per CEQA. An archaeological site is considered significant if it is eligible or potentially eligible for listing in the CRHR. When an archaeological site is discovered during any Project activity, the archaeological monitor will divert construction away from the area at a minimum distance of 50 ft from the find and establish Redlands Regular Meeting of 10-18-22 1498 of 1815
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an exclusionary zone (flagging pins/tape) around the resource. The archaeological monitor(s) will then notify the Project Archaeologist for direction on how to proceed. Regardless of the outcome of the significance and CRHR eligibility assessment, every feature and site require a standard set of data collection for analysis and recordation on standard DPR forms. Features or sites older than 50 years must be delineated and photographed, GPS coordinates must be taken, and features and site records are completed including production of field maps and sketch map drawings. Thorough mapping is required for all features or sites, and include an accurate elevation measurement, the depth the deposit extends below surface and true north reading.

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

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

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

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

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

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

Mitigation Measure CUL-8: Monitoring Compliance Report. The Project Archaeologist shall prepare a final archaeological report prior to issuance of final building inspection, or other City milestone, to verify compliance with project conditions and mitigation measures. The report shall follow industry standard Redlands Regular Meeting of 10-18-22 1499 of 1815
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guidelines and City of Redlands requirements and shall include at a minimum: a discussion of monitoring methods and techniques uses, the results of the monitoring program including any artifacts recovered, an inventory of any resources recovered, updated DPR forms, if any, and any other site(s) identified, final disposition of the resources, and any additional recommendations. A final copy shall be submitted to the City of Redlands Development Services Department and the South Central Coast Information Center (SCCIC).

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

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

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

Cultural Resources Cumulative Findings: The Project would not result in cumulative impacts related to cultural resources (Draft EIR at pp 5.3-14 through 5.3-15).

Facts in Support of Findings:

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

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

Furthermore, implementation of PPP CUL-1 would avoid demolition of historically significant structures and would ensure that adaptive reuse of historically significant structures comply with Secretary of the Interior Standards and thereby protect the historic integrity of the structure’s façade. Furthermore, Mitigation Measure CUL-1 requires preparation of historical resource analyses for future developments that have the Redlands Regular Meeting of 10-18-22 1500 of 1815
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potential of impacting a building over 50 years in age. Thus, with the application of PPP CUL-1 and Mitigation Measure CUL-1, and the applicable Specific Plan design criteria, the proposed Project’s contribution to the cumulative effect to historic resources in the region would be less than cumulatively considerable.

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

D. Geology & Soils
Impact GEO-6 Finding: The Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. (Draft EIR at p. 5.5-3). Impacts are less than significant with mitigation.

Facts in Support of Findings:

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

Paleontological Resources
The paleontological record search did not yield any fossil localities within the Specific Plan Area and no fossil localities within one mile of the Specific Plan Area. However, nine fossil localities from similar sedimentary deposits have been recorded within a 70-mile radius of the Specific Plan Area. The closest fossil locality from the LACM Records Search is LACM IP 437, located approximately 20-miles east of the Specific Plan Area. The locality came from an unknown Pleistocene formation and consisted of invertebrates at an unknown depth. Additional literature was consulted, including the University of California Museum of Paleontology (UCMP)’s Miocene Mammal Mapping Project (MioMap), resulting in eight fossil localities from the San Timoteo Formation located approximately five miles south-southeast of the Specific Plan. These eight localities are the closest fossils to the Specific Plan Area. Additionally, 11 localities from the San Timoteo Formation and 13 localities from the Mount Eden Formation are located approximately 13 to 18 miles southeast of the Specific Plan Area, near the city of Beaumont (MCC 2022).

Additionally, Older Quaternary alluvium, similar to the old alluvial-fan and very old axial-valley deposits mapped within the Specific Plan Area, have produced significant Pleistocene fossils throughout Southern California. While the younger deposits typically do not contain significant fossils within the uppermost layers, it is likely they are underlain by older Quaternary deposits and, potentially, Plio-Pleistocene San Timoteo Formation. Therefore, excavations have the potential to impact paleontologically sensitive sediments throughout the Specific Plan Area (both at the surface and in the subsurface) and potentially destroy the fossil resources contained within. Therefore, Mitigation Measure GEO-1 is included to require preparation Redlands Regular Meeting of 10-18-22 1501 of 1815
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of paleontological resources management program (PRMP) for future projects that propose subsurface disturbance greater than five feet deep within areas mapped as low sensitivity or any subsurface disturbance within an area mapped as a high sensitivity geologic unit. With implementation of Mitigation Measure GEO-1, impacts related to paleontological resources would be less than significant.

Mitigation Measures:

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

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

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

2. The project paleontologist retained shall review the approved development plan and grading plan and conduct any pre-construction work necessary to render appropriate monitoring requirements as appropriate. These requirements shall be documented by the project paleontologist in a paleontological resource management program (PRMP). This PRMP shall be submitted to the City for approval prior to issuance of a grading permit. Information to be contained in the PRMP, at a minimum and in addition to other industry standards and Society of Vertebrate Paleontology standards, are as follows:
a. The Project Paleontologist shall participate in a pre-construction project meeting with development staff and construction operations to ensure an understanding of any monitoring measures required during construction, as applicable. b. Paleontological monitoring of earthmoving activities will be conducted on an as-needed basis by the project paleontologist during all earthmoving activities that may expose sensitive strata. Earthmoving activities in areas of the project area where previously undisturbed strata will be buried but not otherwise disturbed will not be monitored. The project paleontologist or his/her assign will have the authority to reduce monitoring once he/she determines the probability of encountering fossils has dropped below an acceptable level.

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

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

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

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

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

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

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

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

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

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

Paleontological Resources Cumulative Findings: The Project would not result in cumulative impacts related to paleontological resources (Draft EIR at p. 5.5-4).

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

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E. Greenhouse Gas Emissions
Impact GHG-2 Finding: The Project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. (Draft EIR at p. 5.6-10). Impacts are less than significant with mitigation measures.

Facts in Support of Findings:

Construction
Construction activities would occur at different sites throughout the TVSP area through the Plan’s estimated 18-year build out. The site-specific development projects that would occur pursuant to the TVSP would be temporary at any one location, but numerous site-specific development projects are anticipated to occur pursuant to buildout of the proposed TVSP. Construction of site-specific development projects would create new sources of GHG and could contribute to global climate change. Construction activities would result in the emission of GHGs from equipment exhaust, construction-related vehicular activity, and construction worker automobile trips. Emission levels for construction activities would vary depending on the number and type of equipment, duration of use, operation schedules, and the number of construction workers. Total estimated construction related GHG emissions from build out of the proposed TVSP were amortized over 30 years per SCAQMD methodology and would equal approximately 554.66 MT/yr CO2E per year.

Operation
Long-term operations of uses included in the TVSP would generate GHG emissions from the following primary sources:

Area Source Emissions. Landscape maintenance equipment would generate emissions from fuel combustion and evaporation of unburned fuel. Equipment in this category would include lawnmowers, shedders/grinders, blowers, trimmers, chain saws, and hedge trimmers used to maintain the landscaping.

Energy Source Emissions. GHGs are emitted from buildings as a result of activities for which electricity and natural gas are typically used as energy sources. Combustion of any type of fuel emits CO2 and other GHGs directly into the atmosphere; these emissions are considered direct emissions associated with a building. GHGs are also emitted during the generation of electricity from fossil fuels; these emissions are considered to be indirect emissions.

Mobile Source Emissions. The Project related GHG emissions are derived primarily from vehicle trips generated by the Project, including employee trips to and from the TVSP area, truck trips associated with the proposed uses, and trips related to residential uses. Trip characteristics from the Trip Generation (Appendix H) were utilized to quantify the GHGs from operation of the TVSP at buildout.

Water Supply, Treatment, and Distribution. Indirect GHG emissions result from the production of electricity used to convey, treat, and distribute water and wastewater. The amount of electricity required depends on the volume of water as well as the sources of the water. For purposes of analysis, CalEEMod default parameters were used in modeling GHGs from Project water demand.

Solid Waste. The proposed land uses would result in the generation and disposal of solid waste. A percentage of this waste would be diverted from landfills by a variety of means, such as reducing the amount of waste generated, recycling, and/or composting. The remainder of the waste not diverted would be disposed of at a landfill. GHG emissions from landfills are associated with the anaerobic breakdown of material. For purposes of analysis, CalEEMod default parameters were used in modeling GHGs from Project generation of solid waste.

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Service Population. Based on the 2035 General Plan estimates of 2.65 persons per household, buildout of the TVSP would generate approximately 6,421 people; and the estimate of 1 employee per 500 square feet would generate 1,039 employees, which would result in a total service population of 7,460. Construction and operation of the Project would generate a CO2e per service population of 2.84, which would not exceed the threshold of 4.0. Thus, operational impacts would be significant. Additionally, Mitigation Measure AQ-7 would be implemented to require development projects in the TVSP area to achieve 5 percent efficiency beyond the incumbent California Building Code Title 24 requirements; and Mitigation Measure AQ-8 would require enhanced water conservation for TVSP development projects. These measures are designed to reduce Project operational-source emissions of GHGs. However, it should be noted that there is no way to quantify these reductions in the CalEEMod. Therefore, to provide a conservative disclosure of Project emissions, no reductions in emissions are assumed to occur even with implementation of the below measures. As the Project total GHG emissions per service population would not exceed the screening threshold of 4.0 MTCO2e per service population per year, Project related GHG emissions would be less than significant.

Mitigation Measures:

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

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

Mitigation Measure AQ-8: Enhanced Water Conservation. To reduce water demands and associated energy use, subsequent development proposals within the TVSP area shall incorporate a Water Conservation Strategy and demonstrate a minimum 30% reduction in outdoor water usage when compared to baseline Redlands Regular Meeting of 10-18-22 1507 of 1815
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water demand (total expected water demand without implementation of the Water Conservation Strategy)1.

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

Greenhouse Gas Emissions Cumulative Findings: The Project would not result in cumulative impacts related to greenhouse gas emissions (Draft EIR at p. 5.6-20).

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

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

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

F. Noise
Impact NOI-1 Finding: 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 (Draft EIR at p. 5.10-19). Impacts are less than significant with mitigation.

Facts in Support of Findings:

Construction
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 1 The analysis includes a reduction of 20% indoor water usage consistent with the current CALGreen Code (11) for residential and non-residential land uses. Per CALGreen, the reduction shall be based on the maximum allowable water use per plumbing fixture and fittings as required by the California Building Standards Code.

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buildout of the proposed TVSP would likely occur sporadically over an 18-year period or longer and include different project specific construction activities.

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).

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 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. 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. 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 NOI-5 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. 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 Redlands Regular Meeting of 10-18-22 1509 of 1815
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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, 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.

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 non-residential 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.

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.

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;
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• 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).

Impact NOI-2 Finding: The Project would not generate excessive groundborne vibration or groundborne noise levels (Draft EIR at p. 5.10-21). Impacts are less than significant with mitigation.

Facts in Support of Findings:

Construction
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.

Draft EIR 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 vibration impacts to below the vibration threshold of 0.01 in/sec RMS, which would reduce impacts to a less than significant level.

Operation
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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.

Mitigation Measures:

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, 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 vibrationgenerating 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.

Noise Cumulative Findings: The Project would not result in cumulative impacts related to noise (Draft EIR at pp. 5.10-22 through 5.10-23).

Facts in Support of Findings: Buildout of the TVSP in combination with the related projects would result in an increase in construction-related 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.

G. Tribal Cultural Resources
Impact TCR-1 Finding: 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 register of historical resources as defined in Public Resources Code Section 5020.1(k) (Draft EIR at p. 5.15-5). Impacts are less than significant with mitigation.

Facts in Support of Findings: 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. 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). 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.

Mitigation Measures:

Mitigation Measures CUL-2 through CUL-9, as 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 1513 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 1514 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 1515 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)).

Impact TCR-2 Finding: 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 Public Resources Code Section 5024.1, that considers the significance of the resource to a California Native American tribe (Draft EIR at p. 5.15-6).

Impacts are less than significant with mitigation.

Facts in Support of Findings: 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 Redlands Regular Meeting of 10-18-22 1516 of 1815
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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.

Mitigation Measures:

Mitigation Measures CUL-2 through CUL-9, as listed previously.

Mitigation Measures TCR-1 through TCR-4, as listed previously.

Tribal Cultural Resources Cumulative Findings: The Project would not result in cumulative impacts related to tribal cultural resources (Draft EIR at p. 5.15-7).

Facts in Support of Findings: 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.

H. Utilities and Service Systems
Water
Impact UT-1 Finding: 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 (Draft EIR at p. 5.16-5). Impacts are less than significant with mitigation.

Facts in Support of Findings: 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 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:
• 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 Redlands Regular Meeting of 10-18-22 1517 of 1815
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• 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
• 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.

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.

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 water infrastructure and new connections to the water system that could include improvements to aged water pipelines and other connecting infrastructure. Such improvements would be required to be sized to accommodate the water demand of such new development.

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 Redlands Regular Meeting of 10-18-22 1518 of 1815
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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.

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, as listed previously.

Impact UT-2 Finding: The Project would have sufficient water supplies available to serve the Project and reasonably foreseeable development during normal, dry, and multiple dry years (Draft EIR at p. 5.16-6).

Impacts are less than significant with mitigation.

Facts in Support of Findings: 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 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.

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. 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, the projected MUED normal year water demand would increase from 26,866 AF in 2020 to 30,908 AF in 2045.

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 Draft EIR 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 MUED’s entire service area. Thus, impacts related to the need for new or expanded water supplies and entitlements would be less than significant.

Mitigation Measures:

Mitigation Measure AQ-8, as listed previously.

Wastewater
Impact UT-3 Finding: 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. (Draft EIR at p. 5.16-10). Impacts are less than significant with mitigation.

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Facts in Support of Findings: The TVSP area contains a network of sewer lines that range from 6-inches to 48-inches in diameter and operate well within capacity. 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:
• 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.

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, as listed previously.

Stormwater
Impact UT-5 Finding: 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. (Draft EIR at p. 5.16-14). Impacts are less than significant with mitigation.

Facts in Support of Findings: 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 Redlands Regular Meeting of 10-18-22 1520 of 1815
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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. 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.