Redlands City Council
December 19, 2023

Notes:
1 = SIG = Signalized; AWSC = All-Way Stop-Controlled; TWSC = Two-Way Stop-Controlled; OWSC = One-Way Stop-Controlled. 2 = Overall intersection LOS provided for signalized and AWSC intersections. Worst-approach LOS provided for TWSC and OWSC intersections.
3 = City Intersections – LOS C or better is the preferred acceptable operation at City intersections. Bold text with yellow highlight indicates LOS D, E, or F.
4 = Caltrans Intersections – LOS D or better is the acceptable operation at Caltrans intersections. No intersections operate at LOS E or F. 5 = Delay shown in average seconds per vehicle.

TRANSIT FACILITIES
The study area is currently served by Omnitrans, a public transit agency serving the City and County, with bus service in the study area along San Bernardino Avenue and Lugonia Avenue via Bus Route 15. The closest bus stop is located approximately 0.5-mile away at the intersection of San Bernardino Avenue and Texas Street.

The project would not induce significant population growth and is consistent with the anticipated land use for the project site; refer to Section 4.14, Population and Housing. As a result, it is anticipated that existing transit service in the project area would be able to adequately accommodate the increase in project-generated transit trips. Thus, project impacts on existing and future transit services in the project area are expected to be less than significant.

BICYCLE AND PEDESTRIAN FACILITIES
No bicycle lanes currently exist within the project area; however, future bike lanes are planned along San Bernardino Avenue. No sidewalk currently exists within the project area with the exception of the sidewalk that runs along the north side of San Bernardino Avenue adjacent to Citrus Valley High School.

The project would not induce significant population growth and is consistent with the anticipated land use for the project site; refer to Section 4.14. As a result, it is anticipated that existing bicycle and pedestrian facilities in the project area Redlands Regular meeting of 12-19-23 843 of 1429
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would be able to adequately accommodate the increase in project-generated trips. Thus, project impacts on existing and future bicycle and pedestrian facilities in the project area are expected to be less than significant.

CONCLUSION
While the LOS analysis indicates that off-site roadway operational improvements are not required, the proposed project would construct roadway adjacent network improvements associated with the development operations including:
• Half-width construction along Pioneer Avenue project frontage. • Half-width construction along Domestic Avenue project frontage. • Construct a one-way-stop-controlled driveway to create a new T-intersection along Pioneer Avenue, west of the intersection of Pioneer Avenue and Tennessee Street. At the exiting driveway, allow right and left turns movements which are stop-controlled.
• Construct a driveway along Domestic Avenue, west of the intersection of Domestic Avenue and Texas Street.

The project would widen Pioneer Avenue along the project frontage to a total width of approximately 44 feet from centerline to right-of-way. On the north side of the street, this width would provide a 5-foot sidewalk and approximate 6-foot landscape strip. On Domestic Avenue, along the project frontage, a total width of approximately 30 feet from centerline to right-of-way would be provided. On the south side of the street, this width would provide a 6-foot sidewalk and 4-foot landscape strip. North of the project frontage, on Domestic Avenue, a surface parking lot would be provided for guests. Domestic Avenue would be constructed from the project limits to the intersection of Domestic Avenue and Texas Street (#6), by a development to the north of the project site.

For the purposes of the project’s Traffic Study, the Pioneer Avenue and Street A (#3) intersection was analyzed without turn lanes into the site (eastbound left turn lane and a westbound right turn lane) which is consistent with the proposed site plan. These improvements were assumed in the Existing With Project scenario traffic operations analysis.

As there are no adverse effects at any of the study intersections with the addition of project related traffic, no other improvements are needed or proposed. A less than significant impact would occur.

Mitigation Measures: No mitigation measures are required. b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? Less Than Significant Impact. As discussed, SB 743 eliminates LOS as a basis for determining significant transportation impacts under CEQA and provides a new performance metric, VMT. As a result, the State has shifted from measuring a project’s impact to drivers (LOS) to measuring the impact of driving (VMT) as it relates to achieving State goals of reducing greenhouse gas (GHG) emissions, encouraging infill development, and improving public health through active transportation.

The City utilizes the San Bernardino County Transportation Authority VMT Screening Tool (Screening Tool). The Screening Tool allows users to input an assessor’s parcel number to determine if a project’s location meets one (1) or more of the screening thresholds for land use projects identified in the Governor’s Office of Planning and Research Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory).

Each of the applicable screening thresholds were evaluated to determine if the proposed project would be expected to cause a less than significant impact to VMT without requiring a more detailed VMT analysis. If the screening thresholds are not met, then project-generated VMT are calculated and compared to the applicable VMT threshold as identified in the City of Redlands CEQA Assessment VMT Analysis Guidelines (City Guidelines). The City Guidelines provides details on appropriate “screening thresholds” that can be used to identify when a proposed land use project is Redlands Regular meeting of 12-19-23 844 of 1429
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anticipated to result in a less than significant impact without conducting a more detailed analysis. Screening thresholds are broken into the following types described below. A land use project need only meet one (1) of these screening thresholds to result in a less than significant impact. Based on the VMT Analysis, the project does not meet any of the VMT screening criteria; therefore, a VMT Assessment is required.

Project Trip Generation
In order to calculate vehicle trips to be generated by the proposed projects, trip generation rates were taken from the Institute of Transportation Engineers (ITE) Trip Generation Manual (11th Edition). The proposed project is estimated to generate approximately 1,166 daily trips with 86 AM peak hour trips (21 in / 65 out) and 115 PM peak hour trips (73 in / 42 out).

VMT Screening Criteria
The primary resource for this assessment is the City of Redlands CEQA Assessment VMT Analysis Guidelines (June 2020) (City Guidelines), and the San Bernardino County Transportation Impact Study Guidelines (July 2019) (County Guidelines). Based on the City Guidelines, land use projects that meet any of the screening thresholds based on size, location, project type, proximity to transit or trip-making potential identified in Appendix I2 Table 4 are presumed to result in a less than significant transportation impact under CEQA and do not require a detailed quantitative VMT assessment. The project meets the VMT Screening Criteria for “Project Type,” which ask the following:
“Does the project generate less than 3,000 MT CO2e per year? Including projects such as:
• Single Family Res. – 167 DU’s or fewer
• Multifamily Res. (1-2 stories) – 232 DU’s or fewer
• Multifamily Res. (3+ stories) – 299 DU’s or fewer
• Office – 59,100 square feet or less
• Local Serving Retail Center – 112,400 SF or less
• Warehousing – 463,600 SF or less
• Light Industrial – 74,600 SF or less”
As the project proposes the construction of 117 single family dwelling units, which is less than the screening threshold of 167 dwelling units, a detailed project specific VMT calculation is not required.

Based on the above information, the VMT evaluation shows that the project meets the screening criteria for Project Type, and therefore, a project specific VMT assessment is not required. The project would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). Impacts would be less than significant.

Mitigation Measures: No mitigation measures are required. c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less Than Significant Impact. Final project site plans would be subject to City review and approval, which would ensure that project driveway intersections and internal circulation are safe, with adequate sight distance, driveway widths and stop signs where necessary for entering and exiting the site. This would prevent any impacts due to a design feature. The project site would not create hazards due to incompatible uses because the project would introduce additional residential uses to the project area. Therefore, impacts related to hazardous geometric design features or incompatible uses would be less than significant.

Mitigation Measures: No mitigation measures are required.

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d) Result in inadequate emergency access?
Less Than Significant Impact with Mitigation Incorporated. As stated, two entry points to the site are proposed:
one from West Pioneer Avenue and one from West Domestic Avenue. The Redlands Fire Department would review the proposed vehicular circulation network against the Department’s requirements related to fire access and turning radius requirements to ensure that proper emergency access and maneuvering of emergency vehicles can be accommodated.

Further, should partial or full lane closures be required as part of project construction activities, implementation of a TMP would minimize congestion and ensure safe travel, including emergency access in the project vicinity; refer to Mitigation Measure TRA-1. As such, project implementation would not interfere with the implementation of an emergency response plan or emergency evacuation plan. With implementation of Mitigation Measure TRA-1, impacts would be less than significant.

Mitigation Measures:

TRA-1 Traffic Management Plan. Prior to issuance of grading permits, the project applicant shall prepare a Traffic Management Plan (TMP) for approval by the City of Redlands Traffic Engineer. The TMP shall include measures to minimize potential safety impacts during the short-term construction process if partial or full lane closures are required. The TMP shall specify that one direction of travel in each direction on adjacent roadways (West Pioneer Avenue and West Domestic Avenue) must always be maintained during project construction activities. If full lane closures are required and one direction of travel in each direction cannot be maintained, the TMP shall identify planned detours. The TMP shall include measures such as construction signage, limitations on timing for lane closures to avoid peak hours, temporary striping plans, and use of construction flagperson(s) to direct traffic during heavy equipment use. The TMP shall be incorporated into project specifications for verification prior to final plan approval.

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4.18 Tribal Cultural Resources
Would the project:

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section
5020.1(k), or

2) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying
the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native
American tribe.

As of July 1, 2015, California AB 52 was enacted and expanded CEQA by establishing a formal consultation process for California tribes within the CEQA process. The bill specifies that any project that may affect or cause a substantial adverse change in the significance of a tribal cultural resource would require a lead agency to “begin consultation with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.” Section 21074 of AB 52 also defines a new category of resources under CEQA called “tribal cultural resources.” Tribal cultural resources are defined as “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe” and is either listed on or eligible for the California Register of Historical Resources (CRHR) or a local historic register, or if the lead agency chooses to treat the resource as a tribal cultural resource.

On February 19, 2016, the California Natural Resources Agency proposed to adopt and amend regulations as part of AB 52 implementing Title 14, Division 6, Chapter 3 of the California Code of Regulations, CEQA Guidelines, to include consideration of impacts to tribal cultural resources pursuant to Government Code Section 11346.6. On September 27, 2016, the California Office of Administrative Law approved the amendments to Appendix G of the CEQA Guidelines, and these amendments are addressed within this Initial Study. a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape Redlands Regular meeting of 12-19-23 847 of 1429
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that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? Less Than Significant Impact with Mitigation Incorporated. As detailed in Response 4.5(a), no historic resources were identified within the project site boundaries during the field survey conducted as part of the Cultural Resources Assessment. Although findings were negative for cultural resources on the surface of the project site, ground disturbing activities could reveal historic-period artifacts or structural or building elements. As such, potential significant impacts to buried historic-period resources could result in this regard. To minimize potential impacts resulting from inadvertent discoveries, the project proposes to implement Mitigation Measures CUL-1 through CUL-8. Mitigation Measures CUL1 through CUL-8 mandate that the project applicant engage a qualified archaeologist and tribal monitor who will inspect the site following grubbing/ground-clearing and prior to any grading or ground disturbance. This step is taken to ensure that any potential historical resources that may be uncovered during ground-disturbing activities are properly documented and assessed. Notably, Mitigation Measure CUL-6 outlines a procedure in the event of an inadvertent discovery of a cultural resource during construction. If such a discovery occurs, construction activities would halt immediately. The project Archaeologist and tribal monitor would be promptly contacted, and this expert would determine the appropriate measures to mitigate impacts to the significance of the resource. These measures could include capping, avoidance, or other suitable actions.

With the implementation of Mitigation Measures CUL-1 through CUL-8, impacts related to historic tribal cultural resources defined in Public Resources Code Section 5020.1(k) would be less than significant.

Mitigation Measures: Refer to Mitigation Measures CUL-1 through CUL-8 in Section 4.5, Cultural Resources. 2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less Than Significant Impact with Mitigation Incorporated. In compliance with AB 52, on November 22, 2023 the City distributed letters notifying Native American Tribes that requested to be on the City’s list for the purposes of AB 52 of the opportunity to consult with the City regarding the proposed project. Per AB 52, tribal governments have 30 days to respond to the City’s request for consultation.

As part of the AB 52 consultation process, tribal representatives from the Agua Caliente Band of Cahuilla Indians and Morongo Band of Mission Indians requested copies of cultural resource documents for their review. Representatives from the Gabrieleno Band of Mission Indians – Kizh Nation, Morongo Band of Mission Indians, and San Manuel Band of Mission Indians requested standard mitigation measures for the protection tribal cultural resources. In addition, the Morongo Band of Mission Indians requested active monitoring of ground disturbing activities with the potential to impact tribal cultural resources.

To avoid impacting or destroying tribal cultural resources that may be inadvertently unearthed during the project's ground disturbing activities, the project proposes to implement Mitigation Measures CUL-1 through CUL-8. Mitigation Measures CUL-1 through CUL-8 were developed in consultation with the Morongo Band of Mission Indians and would protect tribal cultural resources. With implementation of Mitigation Measures CUL-1 through CUL-8, impacts would be less than significant.

Mitigation Measures: Refer to Mitigation Measures CUL-1 through CUL-8 in Section 4.5, Cultural Resources.

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4.19 Utilities and Service Systems
Would the project:

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Require or result in the relocation or construction of new or expanded water, or wastewater treatment or storm water
drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?

b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during
normal, dry, and multiple dry years?

c. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

d. Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

e. Comply with Federal, State, and local management and reduction statutes and regulations related to solid waste?  a) Require or result in the relocation or construction of new or expanded water, or wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Less Than Significant Impact.

Water
The proposed development would be served by the Redlands Municipal Utilities and Engineering (MUED) for domestic (drinking) water supply services. Private residential, irrigation, and fire lines would be constructed on-site to connect to existing water facilities in Pioneer Avenue.

Payment of standard water connection fees and ongoing user fees would ensure that the project’s impacts on existing water facilities are adequately offset. The proposed project would not induce substantial unplanned population growth; refer to Section 4.11, Land Use and Planning, and Section 4.14, Population and Housing. Thus, it is not anticipated that project implementation would require construction of new or expanded water facilities. A less than significant impact would occur in this regard.

Wastewater
Sewer service for the proposed project would be provided by Redlands MUED. The Redlands Wastewater Treatment Facility is located on approximately 50 acres and has a rated treatment capacity of 9.5 million gallons per day annual Redlands Regular meeting of 12-19-23 849 of 1429
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dry weather flow. Approximately 6 million gallons of that capacity is in a membrane bioreactor system, with the remaining 3.5 million gallons is in a conventional activated sludge process.39 On-site sewer laterals would connect to existing sewer facilities in Domestic Avenue. Compliance with the required sewer connections and wastewater discharge rate would be verified prior to issuance of building permits by the City of Redlands Public Works Department.

The project would be required to pay standard connection fees, ongoing user fees, as well as a Sewer Facility Charge (i.e., a one-time charge imposed on all new construction or expanded structures within the MUED service area).

Payment of these fees would fund improvements and upgrades to surrounding sewer lines as needed, and would offset the project’s increase in demand for wastewater collection services. Following compliance with relevant laws, ordinances, and regulations, it is not anticipated that project implementation would require construction of new or expanded wastewater facilities that would result in a significant environmental effect. Impacts would be less than significant in this regard.

Stormwater
The project would construct an on-site detention basin with a planned drainage system which would collect on-site runoff and convey the flows to the south. Storm drains and the proposed underground detention basin would be operated and maintained by the City of Redlands. All on-site stormwater would be captured in accordance with MS4 permit requirements; refer to Section 4.10, Hydrology and Water Quality.

It is anticipated the proposed drainage system would adequately provide drainage treatments, detention, and conveyance in accordance with City of San Rafael and regional water board requirements. Construction of any improvements relative to stormwater would be subject to compliance with all applicable local, State, and Federal laws, ordinances, and regulations. Impacts in this regard would be less than significant.

Dry Utilities
The project site would be served by Southern California Edison (SCE) for electricity services and Southern California Gas (SoCalGas) for natural gas services. The project would involve constructing new private on-site dry utility lines associated with such services and would connect to existing off-site service lines, with the final configuration of such service lines to be approved by SCE and SoCalGas. Payment of standard utility connection fees and ongoing user fees would ensure impacts to these utility services are adequately offset. In addition, the project would comply with Energy Building Regulations adopted by the California Energy Commission (CCR Title 24) and any adopted City of Redlands energy conservation requirements.

The project’s potential environmental impacts for construction in this regard are analyzed throughout this Initial Study.

Construction of the project’s dry utilities would also be subject to compliance with all applicable local, State, and Federal laws, ordinances, and regulations. As such, project impacts would be less than significant in this regard.

Mitigation Measures: No mitigation measures are required. b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? Less Than Significant Impact. As stated, water supplies for the project site would be provided by City of Redlands MUED.
39 City of Redlands. Wastewater Treatment. https://www.cityofredlands.org/post/wastewater-treatment. Accessed July 30, 2023.

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According to the 2020 Urban Water Management Plan (UWMP), the City has four (4) sources of water to provide to its service area: purchased imported water from the State Water Project; groundwater from the Bunker Hill Subbasin and the Yucaipa Subbasin; surface water from the Mill Creek and Santa Ana River watersheds; and recycled water.40 The 2020 UWMP indicates adequate water supply are anticipated to be available under a single dry-year supply and demand scenario, and multiple dry-year supply and demand scenarios through 2045. The UWMP water supply predictions is based on existing General Plan designations and accounts for increased demand as growth within the City occurs. The project site has a General Plan land use designation of Commercial/Industrial, and a zoning designation of Industrial (EV-SRP). The project would require a General Plan Amendment to change the site’s designation to Medium Density Residential, which allows for densities of 8 to 15 dwelling units per acre (du/ac). The project would also require a Zone Change to Specific Plan No. 64 (Bergamot Specific Plan), and a Specific Plan Amendment to incorporate the project site in the Bergamot Specific Plan boundary. Although the project involves a land use change, the proposed project would not induce substantial unplanned population growth; refer to Section

4.11, Land Use and Planning, and Section 4.14, Population and Housing. Further, payment of standard water connection fees and ongoing user fees would ensure that the project’s impacts on existing water facilities are adequately offset.

The Water Supply Reliability Assessment in the UWMP concludes that the City has adequate supplies to meet projected demands under multiple dry year scenarios, taking into account the recent prolonged drought.51 The proposed project would have sufficient water supplies available to serve the project from existing entitlements and resources. Therefore, impacts associated with water supplies would be less than significant.

Mitigation Measures: No mitigation measures are required. c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Less Than Significant Impact. According to the City’s 2035 General Plan Livable Community Element, most wastewater generated by sewered development within the project site is treated at the City’s wastewater treatment plant located on the south side of the Santa Ana River wash at Nevada Street. The treatment plant has a rated treatment capacity of 9.5 million gallons per day annual dry weather flow.41 The treatment facility has adequate capacity to allow for anticipated growth of the City over the next 20 years.

Although the project involves a land use change, the proposed project would not induce substantial unplanned population growth; refer to Section 4.11, Land Use and Planning, and Section 4.14, Population and Housing. Further, payment of standard wastewater connection fees and ongoing user fees would ensure that the project’s impacts on existing wastewater facilities are adequately offset.. Impacts would be less than significant.

Mitigation Measures: No mitigation measures are required. d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Less Than Significant Impact. Waste collection services within the City are provided by the Facilities and Community Services Department (FCSD). Solid waste originating from Redlands is primarily disposed of by the FCSD at the California Street Landfill and by the County of San Bernardino at the San Timoteo Sanitary Landfill. Both landfills are within City limits. The San Timoteo Sanitary Landfill is located approximately 4.8 miles to the southwest of the site. The California Street Landfill, located approximately 1.0 mile northwest, is the closest landfill to the site. The California 40 Water Systems Consulting, Inc., 2020 IRUWMP, Part 2 Chapter 4, Redlands Urban Water Management Plan, June 30, 2021. 41 City of Redlands, Wastewater Treatment. https://www.cityofredlands.org/post/wastewater-treatment. Accessed July 26, 2023.

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Street Landfill has a maximum capacity of 11,400,000 cubic yards, with a remaining capacity of approximately 5,168,000 cubic yards. The California Street Landfill accepts a maximum of 829 tons per day, or 302,858 tons per year.

The estimated closure year for the California Street Landfill is 2042.42 Construction
The proposed project would result in development of 117 two-story motor court homes along with associated infrastructure, recreational amenities, and landscaping. Due to the limited scale of the project, construction activities are not anticipated to generate significant quantities of solid waste with the potential to affect the capacity of regional landfills.

Further, construction activities would be subject to conformance with relevant Federal, State, and local requirements related to solid waste disposal. The project would be required to demonstrate compliance with the 2022 Green Building Code, which includes design and construction measures that act to reduce construction-related waste through material conservation and other construction-related efficiency measures. The project would also be required to comply with City adopted Ordinance 2544, which requires all construction development to adhere to construction waste diversion and recycling requirements and also facilitates the City’s compliance with State recycling mandates (Assembly Bill 939) for ensuring the recycling of construction and demolition debris. Compliance with the California Integrated Waste Management Act of 1989 (AB 939) requires all California cities to reduce, recycle, and re-use solid waste generated in the State to the maximum extent feasible and requires that at least 50 percent of waste produced is recycled, reduced, or composted.

The project, as a condition of approval with the City, would also be required to submit a Site and Building Recycling Plan outlining the following:
 The location and design of all existing and proposed recycling and trash enclosures;  Site access points for solid waste and recycling;
 Collection vehicles and a design of the grading of the site;  Operational criteria for the proposed use of the property; and,  Capacity requirements for the waste generation of buildings.

Construction waste generated that cannot be recycled would likely be disposed at the California Street Landfill due to its proximity to the project site. The California Street Landfill is not expected to reach its total maximum permitted disposal capacity during the project’s construction period, and construction waste generated by the project is not anticipated to cause this landfill to exceed its maximum permitted daily disposal volume. Because the project would generate a relatively small amount of solid waste per day, the California Street Landfill would have sufficient daily capacity to accept solid waste generated by the project. Construction impacts relative to solid waste generation would be less than significant.

Operation
Based on CalRecycle’s waste generation rates for residential development (12.23 pounds of waste per household per day), project operations are expected to generate approximately 0.72 tons per day, or approximately 262.8 tons per year.43 This represents less than one percent of the maximum daily permitted throughput capacity identified for the California Street Landfill. As such, the project is not anticipated to generate solid waste in excess of State or local 42 CalRecycle. SWIS Facility/Site Activity Details – California Street Landfill (36-AA-0017). Accessed July 26, 2023. Available at https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1855?siteID=2637. 43 California Department of Resources Recycling and Recovery, Estimated Solid Waste Generation Rates, https://www2.calrecycle.ca.gov/wastecharacterization/general/rates, accessed July 26, 2023.

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standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts in this regard would be less than significant.

Mitigation Measures: No mitigation measures are required. e) Comply with Federal, State, and local management and reduction statutes and regulations related to solid waste?
Less Than Significant Impact. Refer to Response 4.19(d) above. The proposed project would be required to comply with all applicable Federal, State, and local statutes and regulations related to solid waste, including AB 939 and the City’s solid waste reduction programs. Specifically, the project would be subject to AB 939, which requires that at least 50 percent of waste produced be recycled, reduced, or composted. Further, considering the availability of landfill capacity as described above, the proposed project’s solid waste disposal needs can be adequately met without a significant impact on the capacity of area landfills. A less than significant impact would occur in this regard.

Mitigation Measures: No mitigation measures are required.

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4.20 Wildfire
If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Substantially impair an adopted emergency response plan or emergency evacuation plan? 
b. Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

c. Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

d. Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? 
a) Substantially impair an adopted emergency response plan or emergency evacuation plan? No Impact. According to the California Department of Forestry and Fire Protection’s Fire Hazard Severity Zone Map Viewer, the project site is not located in or near a State Responsibility Area (SRA) or a fire hazard severity zone (FHSZ); however, the site is designated as a Local Responsibility Area.44 The closest SRA is located approximately 3.4 miles to the east of the project site; the closest FHSZ is located approximately 2.6 miles to the northeast of the project site.

Therefore, the site is not considered to have a high potential for the risk of wildfire occurrence.

The proposed project would be required to comply with the City’s Emergency Plan and Hazard Mitigation Plan and the emergency access requirements of the California Fire Code which include, but are not limited to, providing access with adjoining uses and providing suitable access for emergency vehicles. The project site is serviced by Redlands Fire Station No. 263 located approximately 1 mile southeast of the site at 10 W. Pennsylvania Avenue. No off-site improvements are proposed that would impair an adopted emergency evacuation or response plan or emergency evacuation plan. No impact would occur in this regard.

Mitigation Measures: No mitigation measures are required. b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? No Impact. Refer to Response 4.20(a) above. The project site is not located in or near an SRA or FHSZ nor does it support lands classified as very high fire hazard severity zones. The site is not adjacent to wildlands subject to wildfires.

The project site has a relatively flat topography and slopes gently to the north; no steep slopes are present on or adjacent to the property that would potentially contribute to the rapid spread of wildfire.

Urban levels of fire protection would be provided to the project area upon project completion. In addition, the project would adhere to building codes and any conditions included through review by the fire department. For such reasons, combined with conditions on-site and on adjacent lands, the project, due to slope, prevailing winds, and other factors, 44 California Department of Forestry and Fire Protection, FHSZ Viewer, https://egis.fire.ca.gov/FHSZ/, accessed July 26, 2023.

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would not exacerbate wildfire risks or expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire within such areas. No impact would occur in this regard.

Mitigation Measures: No mitigation measures are required. c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? No Impact. Refer to Response 4.20(a) above. The project site is not located in or near an SRA and does not contain lands classified as very high fire hazard severity zones. The proposed project includes construction of 117 two-story motor court homes distributed along two new public streets (“Street A” and “Street B”), open space lots, stormwater improvements, parking, recreational amenities, landscaping, and associated utilities. Access would be provided from West Pioneer Avenue and West Domestic Avenue, and all circulation improvements would be designed and constructed consistent with City design and engineering standards. Installation and future maintenance of the proposed facilities would not increase the risk of fire because the proposed residential uses on-site would not include any features that would have the potential to exacerbate fire risk or result in temporary or ongoing impacts to the environment. No new fuel breaks, roads, power lines, or other utilities are proposed with the project. No impact would occur in this regard.

Mitigation Measures: No mitigation measures are required. d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? No Impact. Refer to Response 4.20(a) above. The project site is not located in or near an SRA or FHSZ. The project site is generally flat; no steep slopes are located adjacent to the property. Further, the site is not located in an area susceptible to the risk of landslides (refer to Section 4.7, Geology and Soils). All grading and construction would occur in conformance with City engineering requirements and State and local regulations to ensure that the risk of downstream flooding is minimized.

Therefore, the project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes within such areas. No impact would occur in this regard.

Mitigation Measures: No mitigation measures are required.

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4.21 Mandatory Findings of Significance
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major
periods of California history or prehistory?
b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are
considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?

a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Less Than Significant Impact with Mitigation Incorporated. As concluded in Section 4.4, Biological Resources, to reduce impacts to special status wildlife, the project would implement Mitigation Measures BIO-1 through BIO-3. With implementation of these mitigation measures, biological impacts would be reduced to a less than significant level.

As indicated in Section 4.5, Cultural Resources and Section 4.18, Tribal Cultural Resources, no archaeological or tribal cultural resources occur on-site. Should previously undiscovered cultural or tribal cultural resources be uncovered during project ground-disturbing activities, implementation of Mitigation Measures CUL-1 through CUL-8 would reduce the project’s potential effects to less than significant levels.

As analyzed, the project would not degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California prehistory. b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?
Less Than Significant Impact with Mitigation Incorporated. A significant impact may occur if a proposed project, in conjunction with related projects, would result in impacts that are less than significant when viewed separately, but Redlands Regular meeting of 12-19-23 857 of 1429
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would be significant when viewed together. As concluded in Section 4.1 through Section 4.20, the proposed project would not result in any significant impacts in any environmental categories with implementation of the City’s Standard Conditions of Approval as well as project mitigation measures. Implementation of Standard Conditions of Approval and mitigation measures at the project-level would reduce the potential for the incremental effects of the proposed project to be considerable when viewed in connection with the effects of past projects, current projects, or probable future projects. Impacts would be less than significant with mitigation incorporated in this regard. c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Less Than Significant Impact With Mitigation Incorporated. Previous sections of this Initial Study reviewed the proposed project’s potential impacts related to aesthetics, air quality, noise, hazards and hazardous materials, transportation, and other issues. As concluded in these previous discussions, the proposed project would not have environmental effects which would cause substantial adverse effects on human beings, either directly or indirectly, following conformance with the existing regulatory framework and implementation of Standard Conditions of Approval and project mitigation measures. Impacts would be less than significant with mitigation incorporated in this regard.

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October 2023 5-1

5.0 References
CalEEMod version 2022.1.1.6.

California Air Resources Board, Air Quality and Meteorological Information, https://www.arb.ca.gov/aqmis2/aqdselect.php?tab=specialrpt, accessed July 3, 2023.

California Department of Finance Demographic Research Unit, Report E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2023, Sacramento, California, May 2023.

California Department of Forestry and Fire Protection, FHSZ Viewer, https://egis.fire.ca.gov/FHSZ/, accessed June 3, 2023.

California Department of Resources Recycling and Recovery, Estimated Solid Waste Generation Rates, https://www2.calrecycle.ca.gov/wastecharacterization/general/rates, accessed July 26, 2023. _______, Green Building Materials, https://www.calrecycle.ca.gov/greenbuilding/materials#Material, accessed July 5, 2023.
_______, SWIS Facility/Site Search, https://www2.calrecycle.ca.gov/SolidWaste/Site/Search, accessed July 26, 2023.

California Department of Transportation, List of Eligible and Officially Designated State Scenic Highways, https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa, accessed May 16, 2023.

California Department of Water Resources, SGMA Basin Prioritization Dashboard, https://gis.water.ca.gov/app/bpdashboard/final/, accessed June 3, 2023.

California Energy Commission, Final 2021 Integrated Energy Policy Report Volume IV California Energy Demand Forecast, February 2022.
_______, 2021 Integrated Energy Policy Report, https://www.energy.ca.gov/data-reports/reports/integrated-energypolicy-report/2021-integrated-energy-policy-report, accessed July 14, 2023. _______, Final 2021 Integrated Energy Policy Report Volume I Building Decarbonization, February 2022.

City of Redlands, Bergamot Specific Plan, https://www.cityofredlands.org/sites/main/files/file-attachments/bergamotspecific_plan.pdf?1646188068, adopted October 5, 2021.

City of Redlands, City of Redlands Municipal Code, current through Ordinance 2953, passed January 17, 2023. _______, General Plan 2035, adopted December 2017.
_______, General Plan Environmental Impact Report, July 2017.

City of San Bernardino, City of San Bernardino 2005 General Plan Figure LU-4, San Bernardino International Airport Planning Boundaries.

Coffman Associates, Inc., 2015 Redlands Municipal Airport Land Use Compatibility Plan Review Exhibit 6, Updated ALUCP Safety Zones, November 10, 2015.

Department of Conservation Division of Mines and Geology, A General Location Guide for Ultramafic Rocks in California – Areas More Likely to Contain Naturally Occurring Asbestos Report, August 2000, https://ww3.arb.ca.gov/toxics/asbestos/ofr_2000-019.pdf, accessed July 10, 2023.

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Federal Highway Administration, Roadway Construction Noise Model (FHWA-HEP-05-054), January 2006.

Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, Table 7-4 Vibration Source Levels for Construction Equipment, September 2018.

FirstCarbon Solutions, Tentative Biological Resources Assessment and San Bernardino Kangaroo Rat Habitat Assessment, Song and Emm Properties Project, City of Redlands, San Bernardino County, California, March 23, 2023.
_______, Land Evaluation and Site Assessment Model Letter Report for the Song and Emm Properties, City of Redlands, San Bernardino County, California, April 20, 2022. _______, Phase I Cultural Resources Assessment, Song and Emm Properties Project, City of Redlands, San Bernardino County, California, December 12, 2022.

Huitt-Zollars, Inc., Preliminary Drainage Report for Pioneer Avenue Tentative Tract No. 20528, November 10, 2022. _______, Preliminary Water Quality Management Plan for Pioneer Avenue Redlands, Tentative Tract No. 20528, November 10, 2022.

Michael Baker International, Air Quality/Greenhouse Gas/Energy Modeling Results, July 2023. _______, Traffic Study Tentative Tract Map No. 20528 Residential Development City of Redlands, September 26, 2023.
_______, TTM No. 20528 Vehicle Miles Traveled (VMT) Assessment Technical Memorandum, July 21, 2023.

Petra Geosciences, Inc., Due-Diligence/Feasibility Geotechnical Assessment, Approximately 10-Acre Property at 1160 W. Pioneer Avenue, East of 210 Freeway and North of Domestic Avenue, City of Redlands San Bernardino County, California, September 10, 2021.
_______, Due-Diligence/Feasibility Geotechnical Assessment, 5-Acre Parcel of Agricultural Land, Assessor Parcel Number (APN) 0167-061-03, Site East of 1160 W. Pioneer Avenue, City of Redlands, San Bernardino County, California, April 6, 2022.
_______, Phase I Environmental Site Assessment and Limited Phase II Site Assessment, 10±-Acre Parcel of Agricultural Land, Assessor Parcel Number (APN) 0167-061-01, 1160 W. Pioneer Avenue East of 210 Freeway and North of Domestic Avenue, City of Redlands, San Bernardino County, California, September 10, 2021.
_______, Phase I Environmental Site Assessment and Limited Phase II Site Assessment, 5±-Acre Parcel of Agricultural Land, Assessor Parcel Number (APN) 0167-061-03, Site East of 1160 W. Pioneer Avenue, City of Redlands, San Bernardino County, California, May 11, 2022.

South Coast Air Quality Management District, Rule 1113 Architectural Coatings, http://www.aqmd.gov/docs/defaultsource/rule-book/reg-xi/r1113.pdf, accessed July 10, 2023.

Southern California Association of Governments, 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy, September 3, 2020.
_______, Current Context: Demographics and Growth Forecast Technical Report, September 3, 2020.

State of California Governor’s Office of Planning and Research, General Plan Guidelines, July 2017.

U.S. Environmental Protection Agency, Carbon Monoxide Emissions, https://cfpub.epa.gov/roe/indicator_pdf.cfm?i=10, accessed July 3, 2023.

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U.S. Green Building Council, Green Building Costs and Savings, https://www.usgbc.org/articles/green-building-costsand-savings, accessed July 14, 2023.

Vista Environmental, Noise Impact Analysis Tentative Tract Map No. 20528 Residential Project, City of Redlands, August 2, 2023.

Water Systems Consulting, Inc., 2020 Integrated Regional Urban Water Management Plan, May 27, 2021.

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6.0 Report Preparation Personnel

LEAD AGENCY

CITY OF REDLANDS
35 Cajon Street, Suite 20
Redlands, CA 92373
909-798-7555 ext. 7308
Ryan Murphy, Senior Planner

CEQA CONSULTANT

MICHAEL BAKER INTERNATIONAL
40810 County Center Drive, Suite 200
Temecula, CA 92591
951-506-3523
Alicia Gonzalez, Project Manager
Emily Elliott, AICP, Project Director
Elizabeth Meyerhoff, QA/QC
Renee Gleason, Senior Environmental Associate
Nicole Marotz, Senior Environmental Associate
Krista Perine, Environmental Associate
David Christie, AICP, Environmental Associate
Carla Dietrich, P.E. (PA), PTOE, Transportation/VMT
Alejandro Tapia, P.E., Transportation/VMT
Eddie Torres, Senior AQ/GHG/Energy/Noise Specialist
Zhe Chen, Senior AQ/GHG/Energy/Noise Specialist
Yiting Yuan, AQ/GHG/Energy/Noise Specialist
Winnie Woo, AQ/GHG/Energy/Noise Specialist
Kevin Oliver, GIS Technician

AGRICULTURAL, BIOLOGICAL, CULTURAL AND PALEONTOLOGICAL

RESOURCES SUPPORT
FIRSTCARBON SOLUTIONS, INC.
967 Kendall Drive, #A-537
San Bernardino, CA 92407

GEOTECHNICAL AND PHASE I AND PHASE II ESA SUPPORT
PETRA GEOSCIENCES, INC.
40880 County Center Drive, Suite M
Temecula, CA 92591
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HYDROLOGY AND WQMP SUPPORT
HUITT-ZOLLARS, INC.
2603 Main Street, Suite 400
Irvine, CA 92614

NOISE SUPPORT

VISTA ENVIRONMENTAL
1021 Didrickson Way
Laguna Beach, California 92651
Redlands Regular meeting of 12-19-23 864 of 1429
FINAL

INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
TTM 20528 Pioneer Tract Project
State Clearinghouse No. 2023100144
Lead Agency:

CITY OF REDLANDS

DEVELOPMENT SERVICES
35 Cajon Street, Suite 20
Redlands, CA 92373
Contact: Ryan Murphy, Senior Planner
909-798-7555 ext. 7308
Prepared by:

MICHAEL BAKER INTERNATIONAL
40810 County Center Drive, Suite 200
Temecula, California 92591
Contact: Alicia Gonzalez
909-974-4933
November 2023
JN 195426
Redlands Regular meeting of 12-19-23 865 of 1429
This document is designed for double-sided printing to conserve natural resources.

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November 2023 i Table of Contents

TABLE OF CONTENTS

1.0 Introduction................................................................................................................................................. 1-1

2.0 Response to Comments............................................................................................................................. 2-1

3.0 Mitigation Monitoring and Reporting Program ........................................................................................ 3-1

4.0 Errata…………………………………………………………………………………………………………………..4-1

ATTACHMENTS
Attachment A, Revised Biological Resources Assessment
Attachment B, Revised Cultural Resources Report
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1.0 INTRODUCTION
The Tentative Tract Map (TTM) 20528 Pioneer Tract Project (project) would allow for the development of 117 two-story motor court homes distributed along two new public streets (“Street A” and “Street B”) on a 14.62- acre site. Individual lot sizes would range from 1,837 square feet to 3,337 square feet. The project would include nine lettered lots including a 0.5-acre stormwater detention basin (Lot I), a 1.57-acre public open space lot (Lot F), and 40,720 square feet of landscaping and private open space (Lots A, B ,C, D, E, G and H). Access to the site would be provided via two entry points: one from West Pioneer Avenue and one from West Domestic Avenue. Project entitlements include approval of a Specific Plan Amendment, General Plan Amendment, Commission Review and Approval and Tentative Tract Map.

The Initial Study/Mitigated Negative Declaration (IS/MND) (State Clearinghouse No. 2023100144) was made available for public review and comment pursuant to CEQA Guidelines Section 15073. The public review commenced on October 4, 2023 and concluded on November 2, 2023. The IS/MND and supporting attachments were available for review by the general public at:
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2.0 RESPONSE TO COMMENTS
The TTM 20528 Pioneer Tract Project Initial Study/Mitigated Negative Declaration (IS/MND) (State Clearinghouse No. 2023100144) was made available for public review and comment pursuant to CEQA Guidelines Section 15073. The public review commenced on October 4, 2023 and concluded on November 2, 2023. No comment letters were received on the IS/MND during the project’s public review period.

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3.0 MITIGATION MONITORING

AND REPORTING PROGRAM
The California Environmental Quality Act (CEQA) requires that when a public agency completes an environmental document which includes measures to mitigate or avoid significant environmental effects, the public agency must adopt a reporting or monitoring plan. This requirement ensures that environmental impacts found to be significant will be mitigated. The reporting or monitoring plan must be designed to ensure compliance during project implementation (Public Resources Code Section 21081.6).

In compliance with Public Resources Code Section 21081.6, Table 1, Mitigation Monitoring and Reporting Checklist, has been prepared for the TTM 20528 Pioneer Tract Project (the “project”). This Checklist is intended to provide verification that all applicable Conditions of Approval relative to significant environmental impacts are monitored and reported. Monitoring will include: 1) verification that each mitigation measure has been implemented; 2) recordation of the actions taken to implement each mitigation; and 3) retention of records in the City of Redlands TTM 20528 Pioneer Tract Project file.

This Mitigation Monitoring and Reporting Program (MMRP) delineates responsibilities for monitoring the project, but also allows the City flexibility and discretion in determining how best to monitor implementation.

Monitoring procedures will vary according to the type of mitigation measure. Adequate monitoring consists of demonstrating that monitoring procedures took place and that mitigation measures were implemented.

This includes the review of all monitoring reports, enforcement actions, and document disposition, unless otherwise noted in the Mitigation Monitoring and Reporting Checklist (Table 1). If an adopted mitigation measure or standard condition is not being properly implemented, the designated monitoring personnel shall require corrective actions to ensure adequate implementation.

Reporting consists of establishing a record that a mitigation measure is being implemented, and generally involves the following steps:
• The City distributes reporting forms to the appropriate entities for verification of compliance. • Departments/agencies with reporting responsibilities will review the Initial Study/Mitigated Negative Declaration, which provides general background information on the reasons for including specified mitigation measures.
• Problems or exceptions to compliance will be addressed to the City as appropriate. • Periodic meetings may be held during project implementation to report on compliance of mitigation measures.
• Responsible parties provide the City with verification that monitoring has been conducted and ensure, as applicable, that mitigation measures have been implemented. Monitoring compliance may be documented through existing review and approval programs such as field inspection reports and plan review.
• The City prepares a reporting form periodically during the construction phase and an annual report summarizing all project mitigation monitoring efforts.

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Minor changes to the MMRP, if required, would be made in accordance with CEQA and would be permitted after further review and approval by the City. Such changes could include reassignment of monitoring and reporting responsibilities, plan redesign to make any appropriate improvements, and/or modification, substitution or deletion of mitigation measures subject to conditions described in CEQA Guidelines Section 15162. No change will be permitted unless the MMRP continues to satisfy the requirements of Public Resources Code Section 21081.6.

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Mitigation Monitoring and Reporting Checklist
Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks

BIOLOGICAL RESOURCES
BIO-1
Pre-Construction Survey for Nesting Birds.

Ground-disturbing activities shall be conducted
during the non-breeding season for birds
(approximately September 1 through January 31)
to avoid violations of the Migratory Bird Treaty Act
(MBTA) and California Fish and Game Code § §
3503, 3503.5 and 3513.

If grading or construction activities are scheduled
to occur during the bird breeding season (February
1 through August 31), a pre-construction survey
for nesting birds shall be conducted by a qualified
Designated Biologist who is experienced in the
identification of avian species and conduction
nesting bird surveys using appropriate survey
methodology. The nest survey shall include the
project site and any adjacent areas (i.e.,
construction site entrances and/or staging areas)
where the project activities have the potential to
cause nest failure. The pre-construction survey
shall be conducted no more than three days prior
to the start of ground-disturbing activities within the bird breeding season at the appropriate time of
day/night, and during appropriate weather
conditions. If no nesting birds are observed during
the survey, site preparation and construction
activities may begin. If nesting birds are found to
be present, avoidance or minimization measures
Project Applicant/ Qualified
Designated Biologist
Qualified Designated
Biologist/ Redlands
Planning Division
Within Three
Days Prior to
the Start of
GroundDisturbing
Activities/
During
Construction
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shall be undertaken to avoid potential projectrelated impacts. If a nest is suspected, but not confirmed, the Designated Biologist shall establish
a disturbance-free buffer until additional surveys
can be completed, or until the location can be
inferred based on observations confirm that a nest
does not exist or is inactive. If a nest is observed,
but thought to be inactive, the Designated Biologist
shall monitor the nest for one hour (four hours for
raptors during the non-breeding season) prior to
approaching the nest to determine status. The
Designated Biologist shall use their best
professional judgement regarding the monitoring
period and whether approaching the nest is
appropriate.

If an active avian nest confirmed, the Designated
Biologist shall immediately establish a
conservative avoidance buffer surrounding the
nest based on their best professional judgement
and experience. The Designated Biologist shall
monitor the nest at the onset of project activities,
and at the onset of any changes in such project
activities (e.g., increase in number or type of
equipment, change in equipment usage, etc.) to
determine the efficacy of the buffer. If the
Designated Biologist determines that such project
activities may be causing an adverse reaction, the
Designated Biologist shall adjust the buffer
accordingly or implement alternative avoidance
and minimization measures, such as redirecting or
rescheduling construction or erecting sound
barriers. All work within these buffers will be halted
until the nesting effort is finished (i.e., the juveniles Redlands Regular meeting of 12-19-23 876 of 1429
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Responsibility Timing Verification of Compliance
Initials Date Remarks
are surviving independent from the nest). The onsite qualified biologist will review and verify compliance with these nesting avoidance buffers
and will verify the nesting effort has finished. Work
can resume within these avoidance areas when no
other active nests are found. Upon completion of
the survey and nesting bird monitoring, a report
shall be prepared and submitted to the City for
mitigation monitoring compliance record keeping.

BIO-2
Pre-Construction Surveys for Burrowing Owl.

The project applicant shall retain a qualified
Biologist to perform a pre-construction burrowing
owl survey to determine whether burrowing owls
are present within 30 days prior to construction
activities, according to the California Department
of Fish and Wildlife (CDFW) 2012 guidelines. If
construction is delayed or suspended for more
than 30 days after the survey, the area shall be
resurveyed. Survey for occupied burrows shall be
completed within all construction areas and within
300 feet from the proposed project impact area
(where possible and appropriate based on
locations of barren or ruderal habitats).

If burrowing owls are detected during the preconstruction survey, the City shall consult with the CDFW and United States Fish and Wildlife Service
(USFWS) to develop and implement a Burrowing
Owl Mitigation Plan that includes mitigation
measures outlined in CDFW (2012) guidelines and
a Worker Environmental Awareness Program
(WEAP).

Project Applicant/
Qualified Biologist
Qualified Biologist/
Redlands Planning
Division
Within 30 Days
Prior to the
Start of
Construction
Activities
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BIO-3
Pre-Construction Surveys for Special-Status
Reptiles. Prior to the issuance of a grading permit,
the project applicant shall provide evidence that a
qualified designated biologist has been retained to
perform a pre-construction survey of the entire
project impact area, including any staging/laydown
areas, for Southern California legless lizard and
San Diegan tiger whiptail.
• If special-status reptiles are observed
during construction activities, all work
within 50 feet of the animal(s) will be
stopped. At no time shall work occur
within 50 feet of the animal without the
Biological Monitor present. Any specialstatus wildlife species detected within the project impact area, including any
staging/laydown areas, shall be allowed
to move away on their own and shall not
be captured or handled without
authorization from the California
Department of Fish and Wildlife (CDFW)
or United States Fish and Wildlife Service
(USFWS).
• Avoidance of Entrapment: To prevent
inadvertent entrapment of special-status
reptiles during construction, all
excavated, steep-walled holes or
trenches may need to be covered at the
close of each working day with plywood
or other suitable material or provided with
Project Applicant/ Qualified
Biologist
Qualified Biologist/
Redlands Planning
Division
Prior to
Issuance of
Grading
Permit/ During
Construction
Activities
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one or more escape ramps constructed
of earth fill or wooden planks. The project
applicant shall retain a qualified biologist
to regularly inspect open trenches during
the construction phase.
• Environmentally Sensitive Area Fencing:

Areas that support sensitive habitats or
reptile species shall be temporarily
fenced to protect them from construction
activities and traffic. The project applicant
may need to retain a qualified designated
biologist to monitor Environmentally
Sensitive Areas during the construction
phase.
• Worker Environmental Awareness
Program: A Worker Environmental
Awareness Program (WEAP) training
shall be implemented by a qualified
designated biologist to educate
construction workers about the presence
of special-status plant and reptile species
on and near the project site and shall be
administered to construction personnel
prior to the initiation of ground-disturbing
or vegetation/habitat altering activities.

CULTURAL RESOURCES
CUL-1
Native American Treatment Agreement. Prior to
the issuance of grading permits, the applicant shall
enter into a Tribal Monitoring Agreement with the
Consulting Tribe(s) Morongo Band of Mission
Project Applicant/
Consulting Tribe(s) Tribal
Monitor
Consulting Tribe(s)Tribal
Monitor/ Redlands
Planning Division
Prior to the
Issuance of
Grading
Permits/
Redlands Regular meeting of 12-19-23 879 of 1429
TTM 20528 PIONEER TRACT PROJECT
Final Initial Study/Mitigated Negative Declaration
November 2023 3-8 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
Indians for the project. The Tribal Monitor shall be
on-site during all ground-disturbing activities
(including, but not limited to, clearing, grubbing,
tree and bush removal, grading, trenching, fence
post placement and removal, construction
excavation, excavation for all utility and irrigation
lines, and landscaping phases of any kind). The
Tribal Monitor shall have the authority to
temporarily divert, redirect, or halt the grounddisturbing activities to allow identification, evaluation, and potential recovery of cultural
resources.

During Ground
Disturbing
Activities
CUL-2
Retention of Archaeologist. Prior to any grounddisturbing activities (including, but not limited to, clearing, grubbing, tree and bush removal,
grading, trenching, fence post replacement and
removal, construction excavation, excavation for
all utility and irrigation lines, and landscaping
phases of any kind), and prior to the issuance of
grading permits, the Applicant shall retain a
qualified archaeologist who meets the U.S.

Secretary of the Interior Standards (SOI). The
archaeologist shall be present during all grounddisturbing activities to identify any known or suspected archaeological and/or cultural
resources. The archaeologist will conduct a
Cultural Resource Sensitivity Training, in
conjunction with the Tribe[s] Tribal Historic
Preservation Officer (THPO), and/or designated
Tribal Representative. The training session will
focus on the archaeological and tribal cultural
resources that may be encountered during
ground-disturbing activities as well as the
procedures to be followed in such an event.

Project Applicant/ Qualified
Archaeologist
Qualified Archaeologist/
Redlands Planning
Division
Prior to
Ground
Disturbing
Activities/
During Ground
Disturbing
Activities
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Final Initial Study/Mitigated Negative Declaration
November 2023 3-9 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
CUL-3
Cultural Resource Management Plan. Prior to
any ground-disturbing activities the project
archaeologist shall develop a Cultural Resource
Management Plan (CRMP) and/or Archaeological
Monitoring and Treatment Plan (AMTP) to address
the details, timing, and responsibilities of all
archaeological and cultural resource activities that
occur on the project site. This Plan shall be written
in consultation with the consulting Tribe[s] and
shall include the following: approved Mitigation
Measures (MM)/Conditions of Approval (COA),
contact information for all pertinent parties, parties’ responsibilities, procedures for each MM or COA,
and an overview of the project schedule.

Project Applicant/ Qualified
Archaeologist
Qualified Archaeologist/
Redlands Planning
Division
Prior to
Ground
Disturbing
Activities
CUL-4
Pre-Grade Meeting. The retained qualified
archeologist and Consulting Tribe[s]
representative shall attend the pre-grade meeting
with the grading contractors to explain and
coordinate the requirements of the monitoring
plan.

Project Applicant/ Qualified
Archaeologist/ Consulting
Tribe(s) Representative
Qualified Archaeologist/
Consulting Tribe(s)
Representative/ Redlands
Planning Division
Prior to
Ground
Disturbing
Activities
CUL-5
On-site Monitoring. During all ground-disturbing
activities the qualified archaeologist and the Native
American monitor shall be on-site full-time. The
frequency of inspections shall depend on the rate
of excavation, the materials excavated, and any
discoveries of Tribal Cultural Resources as
defined in California Public Resources Code
Section 21074. Archaeological and Native
American monitoring will be discontinued when the
depth of grading and the soil conditions no longer
retain the potential to contain cultural deposits.

The qualified archaeologist, in consultation with
the Native American monitor, shall be responsible
Project Applicant/ Qualified
Archaeologist/ Native
American Monitor
Qualified Archaeologist/
Native American Monitor/
Redlands Planning
Division
During Ground
Disturbing
Activities
Redlands Regular meeting of 12-19-23 881 of 1429
TTM 20528 PIONEER TRACT PROJECT
Final Initial Study/Mitigated Negative Declaration
November 2023 3-10 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
for determining the duration and frequency of
monitoring.

CUL-6
Inadvertent Discovery of Cultural Resources.

In the event that previously unidentified cultural
resources are unearthed during construction, the
qualified archaeologist and the Native American
monitor shall have the authority to temporarily
divert and/or temporarily halt ground disturbance
operations in the area of discovery to allow for the
evaluation of potentially significant cultural
resources. Isolates and clearly non-significant
deposits shall be minimally documented in the field
and collected so the monitored grading can
proceed.

If a potentially significant cultural resource(s) is
discovered, work shall stop within a 60-foot
perimeter of the discovery and an Environmentally
Sensitive Area (ESA) physical demarcation/barrier
constructed. All work shall be diverted away from
the vicinity of the find, so that the find can be
evaluated by the qualified archaeologist and Tribal
Monitor[s]. The archaeologist shall notify the Lead
Agency and consulting Tribe[s] of said discovery.

The qualified archaeologist, in consultation with
the Lead Agency, the consulting Tribe[s], and the
Native American monitor, shall determine the
significance of the discovered resource. A
recommendation for the treatment and disposition
of the Tribal Cultural Resource shall be made by
the qualified archaeologist in consultation with the
Tribe[s] and the Native American monitor[s] and
be submitted to the Lead Agency for review and
approval. Below are the possible treatments and
Contractor/ Qualified
Archaeologist/ Native
American Monitor
Qualified Archaeologist/
Native American Monitor/
Redlands Planning
Division
During
Construction
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Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
dispositions of significant cultural resources in
order of CEQA preference:

A. Full avoidance.

B. If avoidance is not feasible, Preservation
in place.

C. If Preservation in place is not feasible, all
items shall be reburied in an area away
from any future impacts and reside in a
permanent conservation easement or
Deed Restriction.

D. If all other options are proven to be
infeasible, data recovery through
excavation and then curation in a
Curation Facility that meets the Federal
Curation Standards (CFR 79.1)
CUL-7
Inadvertent Discovery of Human Remains. The
Consulting Tribe(s) Morongo Band of Mission
Indians requests the following specific conditions
to be imposed in order to protect Native American
human remains and/or cremations. No
photographs are to be taken except by the
coroner, with written approval by the consulting
Tribe[s].

A. Should human remains and/or
cremations be encountered on the
surface or during any and all grounddisturbing activities (i.e., clearing, grubbing, tree and bush removal,
grading, trenching, fence post placement
and removal, construction excavation,
excavation for all water supply, electrical,
Construction Contractor Redlands Planning
Division
During Ground
Disturbing
Activities
Redlands Regular meeting of 12-19-23 883 of 1429
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Final Initial Study/Mitigated Negative Declaration
November 2023 3-12 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
and irrigation lines, and landscaping
phases of any kind), work in the
immediate vicinity of the discovery shall
immediately stop within a 100-foot
perimeter of the discovery. The area shall
be protected; project
personnel/observers will be restricted.

The County Coroner is to be contacted
within 24 hours of discovery. The County
Coroner has 48 hours to make his/her
determination pursuant to State and
Safety Code §7050.5. and Public
Resources Code (PRC) § 5097.98.

B. In the event that the human remains
and/or cremations are identified as
Native American, the Coroner shall notify
the Native American Heritage
Commission within 24 hours of
determination pursuant to subdivision (c)
of HSC §7050.5.

C. The Native American Heritage
Commission shall immediately notify the
person or persons it believes to be the
Most Likely Descendant (MLD). The
MLD has 48 hours, upon being granted
access to the Project site, to inspect the
site of discovery and make his/her
recommendation for final treatment and
disposition, with appropriate dignity, of
Redlands Regular meeting of 12-19-23 884 of 1429
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November 2023 3-13 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
the remains and all associated grave
goods pursuant to PRC §5097.98.

D. If the Consulting Tribe(s) have Morongo
Band of Mission Indians has been named
the Most Likely Descendant (MLD), the
Tribe may wish to rebury the human
remains and/or cremation and sacred
items in their place of discovery with no
further disturbance where they will reside
in perpetuity. The place(s) of reburial will
not be disclosed by any party and is
exempt from the California Public
Records Act (California Government
Code § 6254[r]). Reburial location of
human remains and/or cremations will be
determined by the Tribe’s Most Likely
Descendant (MLD), the landowner, and
the City Planning Department.

HAZARDS AND HAZARDOUS MATERIALS
HAZ-1
Soil Management Plan. Prior to issuance of a
grading permit, a Soil Management Plan (SMP)
shall be prepared by a qualified environmental
professional with Phase II/Site Characterization
experience. The SMP shall be approved by the
City and made available by the project Applicant
to the contractor and the City Engineer for use
during grading activities. The SMP shall include
guidelines for safety measures and soil
management in the event that soils are to be
disturbed, and for handling soil during any planned
earthwork activities. The SMP shall also include a
Project Applicant/ Qualified
Environmental Professional
with Phase II/Site
Characterization Experience
City of Redlands Engineer Prior to
Issuance of
Grading
Permits
Redlands Regular meeting of 12-19-23 885 of 1429
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Final Initial Study/Mitigated Negative Declaration
November 2023 3-14 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
decision framework and specific risk management
measures for managing soil, including any soil
import/export activities, in a manner protective of
human health and consistent with applicable
regulatory requirements.

As part of this SMP, all excavation activities shall
be documented daily using digital photography. In
addition, the sides and the bottom of the
excavation areas of concern shall be appropriately
logged on scaled paper. Observed materials,
including an estimate of the quantity observed,
and PID and dust monitor readings shall be
recorded on the Daily Field Record and/or the
Direct Reading Log.

If the results of the stockpile samples show no
contamination, or detected concentrations of
chemicals within acceptable regulatory limits for
residential uses, then the soil may be redistributed
within the excavation. If soil is deemed
contaminated, then it shall be disposed of off-site
at an approved landfill facility. Should any soils be
imported or exported at an off-site location, a
Phase II/Site Characterization Specialist shall
verify that all imported/exported soils are not
contaminated with hazardous materials above
regulatory thresholds. If import/export soils are
determined to be contaminated above regulatory
thresholds, the Phase II/Site Characterization
Specialist would recommend proper handling,
use, and/or disposal of these soils.

Redlands Regular meeting of 12-19-23 886 of 1429
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Final Initial Study/Mitigated Negative Declaration
November 2023 3-15 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
HAZ-2
Removal of Organochloride Pesticides (OCP)
Contaminated Soils. Prior to site grading
activities, the project Applicant shall submit
documentation as proof, to the City Engineer, that
the OCP-impacted soils at the project site have
been excavated and disposed of at a licensed
facility with confirmation sampling to show that all
remaining soil OCP concentrations are below
applicable regulatory screening thresholds for
residential uses. The excavation, transport, and
disposal of all OCP-impacted soils from the project
site shall occur in accordance with applicable
Federal, State, and/or local regulations. In no
event shall the project Applicant proceed with site
grading activities at any location on the site where
OCP contamination is found to be present above
regulatory thresholds for residential use.

Project Applicant City of Redlands Engineer Prior to Site Grading
Activities

TRANSPORTATION
TRA-1
Traffic Management Plan. Prior to issuance of
grading permits, the project applicant shall prepare
a Traffic Management Plan (TMP) for approval by
the City of Redlands Traffic Engineer. The TMP
shall include measures to minimize potential
safety impacts during the short-term construction
process if partial or full lane closures are required.

The TMP shall specify that one direction of travel
in each direction on adjacent roadways (West
Pioneer Avenue and West Domestic Avenue)
must always be maintained during project
construction activities. If full lane closures are
required and one direction of travel in each
direction cannot be maintained, the TMP shall
identify planned detours. The TMP shall include
measures such as construction signage,
Project Applicant City of Redlands Traffic
Engineer
Prior to
Issuance of
Grading
Permits
Redlands Regular meeting of 12-19-23 887 of 1429
TTM 20528 PIONEER TRACT PROJECT
Final Initial Study/Mitigated Negative Declaration
November 2023 3-16 Mitigation Monitoring and Reporting Program Mitigation
Number Mitigation Measure Implementation
Responsibility
Monitoring
Responsibility Timing Verification of Compliance
Initials Date Remarks
limitations on timing for lane closures to avoid
peak hours, temporary striping plans, and use of
construction flagperson(s) to direct traffic during
heavy equipment use. The TMP shall be
incorporated into project specifications for
verification prior to final plan approval.

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Final Initial Study/Mitigated Negative Declaration
November 2023 4-1 Errata

4.0 ERRATA
Changes to the Draft Initial Study/Mitigated Negative Declaration (IS/MND) are noted below. A doubleunderline indicates additions to the text; strikethrough indicates deletions to the text. Changes are listed by page and, where appropriate, by paragraph.

These errata address minor revisions to the Draft IS/MND, which circulated from October 4, 2023 through November 2, 2023. The changes to the Draft IS/MND do not affect the overall conclusions of the environmental document. These clarifications and modifications are not considered to result in any new or substantially greater significant impacts as compared to those identified in the Draft IS/MND.

SECTION 2.0, PROJECT DESCRIPTION

The project site has a land use designation of Commercial/Industrial in the City of Redlands General Plan, and a zoning designation of Science Research Park within the East Valley Corridor Specific Plan (EV-SRP). The project would require a General Plan Amendment to change the site’s designation to Medium Density Residential, which allows for densities of 8 to 15 dwelling units per acre (du/ac). The project would also require a Zone Change to Specific Plan No. 64 (Bergamot Specific Plan), and a Specific Plan Amendment to incorporate the project site in the Bergamot Specific Plan boundary. The Bergamot Specific Plan was adopted by the City on October 5, 2021. It was developed to produce a cohesive, unified development sensitive to the project site and surrounding area through the integration of special buffer treatments, architectural theming, placement of structures, and the integration of passive and active open space and recreational uses.1

The City, as Lead Agency, has discretionary authority over the proposed project, which requires the following discretionary approvals:
• CEQA Clearance;
• Zone Change;
• Specific Plan Amendment;
• General Plan Amendment;
• Tentative Tract Map;
• Water Quality Management Plan; and
• National Pollutant Discharge Elimination System (NPDES) Permit under the Santa Ana Regional Water Quality Control Board (Santa Ana RWQCB).

SECTION 4.3, AIR QUALITY

The project site has a General Plan land use designation of Commercial/Industrial, and a zoning designation of Industrial (EV-SRP). The project would require a General Plan Amendment to change the site’s designation to Medium 1 City of Redlands, Bergamot Specific Plan, adopted October 5, 2021.

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Final Initial Study/Mitigated Negative Declaration
November 2023 4-2 Errata
Density Residential, which allows for densities of 8 to 15 dwelling units per acre (du/ac). The project would also require a Zone Change to Specific Plan No. 64 (Bergamot Specific Plan); and a Specific Plan Amendment to incorporate the project site in the Bergamot Specific Plan boundary. Additionally, the East Valley Corridor Specific Plan would also be amended to remove the project site from its Plan Boundary. The project would allow for the development of 117-unit two-story motor court home units on approximately 14.62 gross acres (11.45 net acres), representing a density of approximately 8 du/ac.2
Although the project would require a General Plan Amendment, Zone Change, and Specific Plan Amendments, the project as analyzed aligns with the City of Redlands General Plan by fostering urban development and land use patterns that are consistent with the City's long-term vision for sustainable growth and efficient land utilization. By integrating the project site into the Bergamot Specific Plan, the project embraces the City's established planning framework and promotes a balanced blend of land uses that adhere to the overarching goals and policies of the City of Redlands General Plan. The proposed development type is also complementary to proposed residential uses to the north. Therefore, as the density of the project would be within the allowable density range of 8 to 15 du/ac within the Medium Density Residential zoning designation with the General Plan Amendment, the project would not conflict with the General Plan in this regard. Therefore, the project is consistent with the site’s General Plan land use designation and zoning with the approval of the General Plan Amendment and Zone Change.

SECTION 4.11, LAND USE AND PLANNING

Less Than Significant Impact. The project site has a General Plan land use designation of Commercial/Industrial, and a zoning designation of Industrial (EV-SRP). The project would require a General Plan Amendment to change the site’s designation to Medium Density Residential, which allows for densities of 8 to 15 dwelling units per acre (du/ac).

The project would also require a Zone Change to Specific Plan No. 64 (Bergamot Specific Plan), and a Specific Plan Amendment to incorporate the project site in the Bergamot Specific Plan boundary. The Bergamot Specific Plan was adopted by the City on October 5, 2021. It was developed to produce a cohesive, unified development sensitive to the project site and surrounding area through the integration of special buffer treatments, architectural theming, placement of structure, and the integration of passive and active open space and recreational uses.3 The proposed project, involving a Zone Change to Specific Plan No. 64 (Bergamot Specific Plan) and a Specific Plan Amendment to include the project site within the Bergamot Specific Plan boundary, aligns with the City of Redlands General Plan. This alignment is achieved by fostering urban development and land use patterns that are consistent with the City's long-term vision for sustainable growth and efficient land utilization, as outlined in the General Plan. By integrating the project site into the Bergamot Specific Plan, the project embraces the City's established planning framework and promotes a balanced blend of land uses that adhere to the overarching goals and policies of the City of Redlands General Plan.

The project as proposed would allow for development of 117 two-story motor court homes distributed along two new public streets (“Street A” and “Street B”) on the 14.62-acre site; refer to Exhibit 3, Conceptual Site Plan. Proposed density would be approximately 8 du/ac.

With City approval of the GPA and rezone, the proposed use of the subject site to support motor court homes would be consistent with the General Plan, Bergamot Specific Plan, and Municipal Code. Further, as noted, the project would require a Specific Plan Amendment to add the project site into the Bergamot Specific Plan area. The proposed use of 2 Density is calculated by dividing gross acreage (14.62 acres) from proposed number of units (117). 3 City of Redlands, Bergamot Specific Plan, https://www.cityofredlands.org/sites/main/files/file-attachments/bergamotspecific_plan.pdf?1646188068, adopted October 5, 2021.

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Final Initial Study/Mitigated Negative Declaration
November 2023 4-3 Errata
motor homes would be consistent with intended development for the Specific Plan area, which includes development of an estimated 120 single-family motor court homes within Neighborhood Three. Design measures identified as part of the Specific Plan (i.e., buffer treatments, architectural theming, placement of structure, and the integration of passive and active open space and recreational uses) would further ensure that the proposed motor home uses are compatible with applicable land use plans and policies.4
SECTION 4.5, CULTURAL RESOURCES

CUL-1 Native American Treatment Agreement. Prior to the issuance of grading permits, the applicant shall enter into a Tribal Monitoring Agreement with the Consulting Tribe(s) Morongo Band of Mission Indians for the project. The Tribal Monitor shall be on-site during all ground-disturbing activities (including, but not limited to, clearing, grubbing, tree and bush removal, grading, trenching, fence post placement and removal, construction excavation, excavation for all utility and irrigation lines, and landscaping phases of any kind). The Tribal Monitor shall have the authority to temporarily divert, redirect, or halt the ground-disturbing activities to allow identification, evaluation, and potential recovery of cultural resources.

CUL-7 Inadvertent Discovery of Human Remains. The Consulting Tribe(s) Morongo Band of Mission Indians requests the following specific conditions to be imposed in order to protect Native American human remains and/or cremations. No photographs are to be taken except by the coroner, with written approval by the consulting Tribe[s].

A. Should human remains and/or cremations be encountered on the surface or during any and all grounddisturbing activities (i.e., clearing, grubbing, tree and bush removal, grading, trenching, fence post placement and removal, construction excavation, excavation for all water supply, electrical, and irrigation lines, and landscaping phases of any kind), work in the immediate vicinity of the discovery shall immediately stop within a 100-foot perimeter of the discovery. The area shall be protected; project personnel/observers will be restricted. The County Coroner is to be contacted within 24 hours of discovery. The County Coroner has 48 hours to make his/her determination pursuant to State and Safety Code §7050.5. and Public Resources Code (PRC) § 5097.98.

B. In the event that the human remains and/or cremations are identified as Native American, the Coroner shall notify the Native American Heritage Commission within 24 hours of determination pursuant to subdivision (c) of HSC §7050.5.

C. The Native American Heritage Commission shall immediately notify the person or persons it believes to be the Most Likely Descendant (MLD). The MLD has 48 hours, upon being granted access to the Project site, to inspect the site of discovery and make his/her recommendation for final treatment and disposition, with appropriate dignity, of the remains and all associated grave goods pursuant to PRC §5097.98.

D. If the Consulting Tribe(s) have Morongo Band of Mission Indians has been named the Most Likely Descendant (MLD), the Tribe may wish to rebury the human remains and/or cremation and sacred items in their place of discovery with no further disturbance where they will reside in perpetuity. The place(s) of reburial will not be disclosed by any party and is exempt from the California Public Records Act (California 4 City of Redlands, Bergamot Specific Plan, https://www.cityofredlands.org/sites/main/files/file-attachments/bergamotspecific_plan.pdf?1646188068, adopted October 5, 2021.

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November 2023 4-4 Errata
Government Code § 6254[r]). Reburial location of human remains and/or cremations will be determined by the Tribe’s Most Likely Descendant (MLD), the landowner, and the City Planning Department.

SECTION 4.19, UTILITIES AND SERVICE SYSTEMS

According to the 2020 Urban Water Management Plan (UWMP), the City has four (4) sources of water to provide to its service area: purchased imported water from the State Water Project; groundwater from the Bunker Hill Subbasin and the Yucaipa Subbasin; surface water from the Mill Creek and Santa Ana River watersheds; and recycled water.5 The 2020 UWMP indicates adequate water supply are anticipated to be available under a single dry-year supply and demand scenario, and multiple dry-year supply and demand scenarios through 2045. The UWMP water supply predictions is based on existing General Plan designations and accounts for increased demand as growth within the City occurs. The project site has a General Plan land use designation of Commercial/Industrial, and a zoning designation of Industrial (EV-SRP). The project would require a General Plan Amendment to change the site’s designation to Medium Density Residential, which allows for densities of 8 to 15 dwelling units per acre (du/ac). The project would also require a Zone Change to Specific Plan No. 64 (Bergamot Specific Plan), and a Specific Plan Amendment to incorporate the project site in the Bergamot Specific Plan boundary. Although the project involves a land use change, the proposed project would not induce substantial unplanned population growth; refer to Section

4.11, Land Use and Planning, and Section 4.14, Population and Housing. Further, payment of standard water connection fees and ongoing user fees would ensure that the project’s impacts on existing water facilities are adequately offset.

APPENDICES
Appendix C, Biological Resources Assessment, Cover Page The Biological Resources Assessment has been revised to remove the following text from the front cover:

THIS REPORT CONTAINS SENSITIVE INFORMATION RELATING TO BIOLOGICAL RESOURCES AND IS NOT INTENDED FOR PUBLIC DISTRIBUTION PURSUANT TO PUB. RESOURCES CODE, SECTION 21082.3(C)(2).

No other revisions were made to the report; refer to Final IS/MND Attachment A, Revised Biological Resources Assessment.

Appendix D, Cultural Resources Report, Cover Page
The Cultural Resources Report has been revised to remove the following text from the front cover:

THIS REPORT CONTAINS SENSITIVE INFORMATION RELATING TO CULTURAL RESOURCES AND IS

NOT INTENDED FOR PUBLIC DISTRIBUTION PURSUANT TO PUBLIC RESOURCES CODE, SECTION 21082.3(C)(2)..

No other revisions were made to the report; refer to Final IS/MND Attachment B, Revised Cultural Resources Report. 5 Water Systems Consulting, Inc., 2020 IRUWMP, Part 2 Chapter 4, Redlands Urban Water Management Plan, June 30, 2021.

Redlands Regular meeting of 12-19-23 892 of 1429
Attachment A
Revised Biological Resources Assessment
Redlands Regular meeting of 12-19-23 893 of 1429
NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
Biological Resources Assessment
and San Bernardino Merriam’s Kangaroo Rat Habitat Assessment Song and Emm Properties Project
City of Redlands, San Bernardino County, California
Project Applicant:

MLC Holdings, Inc.
5 Peters Canyon Road, Suite 310
Irvine, CA 92606
Contact: Johanna Crooker, Director of Entitlements
Prepared by:

FirstCarbon Solutions
967 Kendall Drive, #A-537
San Bernardino, CA 92407
Contact: Jason Brandman, Vice President/Director
Date: June 21, 2023
Redlands Regular meeting of 12-19-23 894 of 1429

THIS PAGE INTENTIONALLY LEFT BLANK
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MLC Holdings, Inc.—Song and Emm Properties Project
Biological Resources Assessment Table of Contents
FirstCarbon Solutions iii Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx Table of Contents
Section 1: Introduction................................................................................................................. 1

1.1 - Project Location and Setting ............................................................................................. 1

1.2 - Project Description............................................................................................................ 1 Section 2: Regulatory Setting........................................................................................................ 9

2.1 - Federal............................................................................................................................... 9

2.2 - State................................................................................................................................. 10

2.3 - Regional and Local........................................................................................................... 13 Section 3: Methods....................................................................................................................17

3.1 - Literature and Database Reviews.................................................................................... 17

3.2 - Field Surveys.................................................................................................................... 18 Section 4: Results.......................................................................................................................21

4.1 - Literature Review............................................................................................................. 21

4.2 - Biological Surveys............................................................................................................ 21 Section 5: Sensitive Biological Resources Database Reviews........................................................31

5.1 - Sensitive Natural Communities....................................................................................... 31

5.2 - Special-status Plant Species ............................................................................................ 31

5.3 - Special-status Wildlife Species ........................................................................................ 32

5.4 - Potentially Jurisdictional Waters and Wetlands.............................................................. 35

5.5 - Protected Trees................................................................................................................ 36 Section 6: Impact Analysis and Recommendations......................................................................39

6.1 - Special-status Wildlife Species ........................................................................................ 39 Appendix A: Professional Qualifications
Appendix B: Site Photographs
Appendix C: Special-status Species Tables
List of Exhibits
Exhibit 1: Regional Location Map ........................................................................................................... 3 Exhibit 2: Local Vicinity Map................................................................................................................... 5 Exhibit 3: Site Plan.................................................................................................................................. 7 Exhibit 4: Soils Map .............................................................................................................................. 27 Exhibit 5: Vegetation Community/Land Cover Map............................................................................. 29 Exhibit 6: Special-status Species Occurrences in the Project Vicinity .................................................. 37 Redlands Regular meeting of 12-19-23 896 of 1429

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Biological Resources Assessment Introduction
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This Biological Resources Assessment (BRA) and San Bernardino Merriam’s kangaroo rat (Dipodomys merriami parvus) Habitat Assessment was prepared by FirstCarbon Solutions (FCS) for a proposed residential development located on West Pioneer Avenue in Redlands, California (proposed project).

The purpose of the BRA is to (1) document existing and potentially occurring biological resources on the project site and adjacent areas; (2) analyze potential project-related impacts on regulated biological resources; (3) summarize relevant local, State, and federal regulations; and (4) recommend appropriate measures to mitigate potential impacts on biological resources to less than significant levels.

1.1 - Project Location and Setting
The 14.6 gross acre project site is located at 1160 West Pioneer Avenue in the City of Redlands, in San Bernardino County, California (Exhibit 1). The project site consists of two adjacent properties, the Song Property (Assessor’s Parcel Number [APN] 016-706-101) and the Emm Property (APN 016- 706-103), which are currently vacant and bounded by West Pioneer Avenue to the south, Citrus Valley High School to the east, undeveloped lands to the north, and State Route (SR) 210 to the west (Exhibit 2). The project site is located within the Redlands, California United States Geological Survey (USGS) 7.5-minute Topographic Quadrangle Map, Township 1 South, Range 3 West, Section 16 (Latitude 34° 4’ 48” North; Longitude 117° 11’ 55” West). The project site is situated on an alluvial terrace that drains into the Santa Ana River, which is located approximately 0.5 mile to the north.

1.2 - Project Description
The proposed project would include development of approximately 117 motor court homes on the

14.6-acre project site at a density of 8.1 units per acre (Exhibit 3).

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60 60
Riverside County
San Bernardino County
74 79
10 38
San Bernardino
15 210
173
215
10 91
15 210
Silverwood
Lake
Lake
Arrowhead
Perris
Reservoir
Mystic Lake
Lake Mathews
Big Bear Lake
San Bernardino
National Forest
Cleveland
National
Forest
Rialto
Fontana
Colton Redlands
Yucaipa
Riverside
Moreno Valley
Perris San Jacinto
Nuevo
Beaumont
Woodcrest
Calimesa
Cherry Valley
Highland
Loma Linda
Exhibit 1
Regional Location Map
5 2.5 0 5
Miles
Text
Project Site
Source: Census 2000 Data, The California Spatial Information Library (CaSIL).

MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT

BIOLOGICAL RESOURCES ASSESSMENT
49400030 • 08/2022 | 1_regional.mxd
Project Site
Legend
City of Redlands
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Exhibit 2
Local Vicinity Map
Source: Bing Aerial Imagery. Huitt-Zollars, 08/2022.

MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT

BIOLOGICAL RESOURCES ASSESSMENT
1,000 500 0 1,000
Feet
Legend
Project Site
Off-site Roadway and Frontage Improvements
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49400030 • 03/2023 | 3_Site_Plan.cdr
Exhibit 3
Site Plan
MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT

BIOLOGICAL RESOURCES ASSESSMENT
Source: MLC Holdings, Inc., May 2022.I
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2.1 - Federal

2.1.1 - Endangered Species Act
The United States Fish and Wildlife Service (USFWS) has jurisdiction over species listed as threatened or endangered under the Endangered Species Act. Section 9 of the Endangered Species Act protects listed species from “take,” which is broadly defined as actions taken to “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct.” The Endangered Species Act protects threatened and endangered plants and animals and their critical habitat. Candidate species are those proposed for listing; during the environmental review process, these species are usually treated by resource agencies as if they were actually listed.

2.1.2 - Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) implements international treaties between the United States and other nations devised to protect migratory birds, their parts, eggs, and nests from activities such as hunting, pursuing, capturing, killing, selling, and shipping, unless expressly authorized in the regulations or by permit. All migratory birds and their nests are protected from take and other impacts under the MBTA (16 United States Code [USC] § 703, et seq.).

2.1.3 - Bald and Golden Eagle Protection Act
The golden eagle (Aquila chrysaetos) and bald eagle (Haliaeetus leucocephalus) are afforded additional protection under the Eagle Protection Act, amended in 1973 (16 USC § 669, et seq.) and the Bald and Golden Eagle Protection Act (16 USC §§ 668–668d).

2.1.4 - Clean Water Act
Section 404
The United States Army Corps of Engineers (USACE) administers Section 404 of the federal Clean Water Act (CWA), which regulates the discharge of dredge and fill material into waters of the United States.

The USACE has established a series of nationwide permits that authorize certain activities in waters of the United States if a proposed activity can demonstrate compliance with standard conditions.

Normally, USACE requires an individual permit for an activity that will affect an area equal to or greater than 0.5 acre of waters of the United States. A project that results in impacts to less than 0.5 acre of waters of the United States can normally be conducted pursuant to one of the nationwide permits if it is consistent with the standard permit conditions. The USACE also has discretionary authority to require an Environmental Impact Statement for projects that result in impacts to between 0.1 and 0.5 acre. Use of any nationwide permit is contingent on the activities having no impacts on endangered species.

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As stated in Section 401 of the CWA, “any applicant for a federal permit for activities that involve a discharge to waters of the State, shall provide the federal permitting agency a certification from the State in which the discharge is proposed that states that the discharge will comply with the applicable provisions under the federal Clean Water Act.” Therefore, before the USACE will issue a Section 404 permit, applicants must apply for and receive a Section 401 Water Quality Certification from the Regional Water Quality Control Board (RWQCB).

2.2 - State

2.2.1 - CEQA Guidelines
The following California Environmental Quality Act (CEQA) Guidelines Appendix G checklist questions serve as thresholds of significance when evaluating the potential impacts of a proposed project on biological resources. Impacts are considered significant if a project would:
• Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as being a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife (CDFW) or USFWS. • 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 CDFW or USFWS. • Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. • 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.
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
• Conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or State habitat conservation plan.

2.2.2 - California Endangered Species Act
The State of California enacted the California Endangered Species Act (CESA) in 1984. CESA pertains to State listed endangered and threatened species. CESA requires State agencies to consult with the CDFW when preparing CEQA documents to ensure that the State lead agency actions do not jeopardize the continued existence of a listed species or result in the destruction or adverse modification of habitat essential to the continued existence of those species, if there are reasonable and prudent alternatives available (Fish and Game Code [FGC] § 2080). CESA directs agencies to consult with the CDFW on projects or actions that could affect listed species, directs the CDFW to determine whether jeopardy would occur, and allows the CDFW to identify “reasonable and prudent alternatives” to the project consistent with conserving the species. CESA allows the CDFW to Redlands Regular meeting of 12-19-23 907 of 1429
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2.2.3 - California Fish and Game Code
Under CESA, the CDFW has the responsibility for maintaining a list of endangered and threatened species (FGC § 2070). Fish and Game Code Sections 2050 through 2098 outline the protection provided to California’s rare, endangered, and threatened species. Fish and Game Code Section 2080 prohibits the taking of plants and animals listed under the CESA, and Fish and Game Code Section 2081 established an incidental take permit program for State listed species. The CDFW maintains a list of “candidate species,” which it formally notices as being under review for addition to the list of endangered or threatened species.

In addition, the Native Plant Protection Act of 1977 (NPPA) (FGC § 1900, et seq.) prohibits the taking, possessing, or sale within the State of any plants with a State designation of rare, threatened, or endangered (as defined by the CDFW). An exception to this prohibition in the NPPA allows landowners to take listed plant species under specified circumstances, provided that the owners first notify CDFW and give the agency at least 10 days to come and retrieve (and presumably replant) the plants before they are plowed under or otherwise destroyed. Fish and Game Code Section 1913 exempts from “take” prohibition “the removal of endangered or rare native plants from a canal, lateral ditch, building site, or road, or other right-of-way.” Project impacts to these species are not considered significant unless the species are known to have a high potential to occur within the area of disturbance associated with construction of the proposed project.

In addition to formal listing under the Endangered Species Act and CESA, some species receive additional consideration by the CDFW and local lead agencies during the CEQA process. Species that may be considered for review are those listed as a “Species of Special Concern.” The CDFW maintains lists of “Species of Special Concern” that serve as species “watch lists.” Species with this status may have limited distributions or limited populations and/or the extent of their habitats has been reduced substantially, such that their populations may be threatened. Thus, their populations are monitored, and they may receive special attention during environmental review. While they do not have statutory protection, they may be considered rare under CEQA and specific protection measures may be warranted. In addition to Species of Special Concern, the CDFW Special Animals List identifies animals that are tracked by the California Natural Diversity Database (CNDDB) and may be potentially vulnerable but warrant no federal interest and no legal protection.

Sensitive species that would qualify for listing but are not currently listed are afforded protection under CEQA. CEQA Guidelines Section 15065 (Mandatory Findings of Significance) requires that a substantial reduction in numbers of a rare or endangered species be considered a significant effect.

CEQA Guidelines Section 15380 (Rare or Endangered Species) provides for the assessment of unlisted species as rare or endangered under CEQA if the species can be shown to meet the criteria for listing. Unlisted plant species on the California Native Plant Society (CNPS) List ranked 1A, 1B, and 2 would typically require evaluation under CEQA.

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Under Fish and Game Code Section 3503.5, it is unlawful to take, possess, or destroy any birds in the orders of Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant thereto. To comply with the requirements of CESA, an agency reviewing a proposed project within its jurisdiction must determine whether any State listed endangered or threatened species may be present in the project site and determine whether the proposed project will have a potentially significant impact on such species. In addition, the CDFW encourages informal consultation on any proposed project that may impact a candidate species.

Project-related impacts to species on the CESA endangered or threatened list would be considered significant. State listed species are fully protected under the mandates of CESA. “Take” of protected species incidental to otherwise lawful management activities may be authorized under Fish and Game Code Section 206.591. Authorization from the CDFW would be in the form of an Incidental Take Permit.

Fish and Game Code Section 1602 requires any entity to notify the CDFW before beginning any activity that “may substantially divert or obstruct the natural flow of, or substantially change or use any material from the bed, channel, or bank of any river, stream, or lake” or “deposit debris, waste, or other materials that could pass into any river, stream, or lake.” “River, stream, or lake” includes waters that are episodic and perennial and ephemeral streams, desert washes, and watercourses with a subsurface flow. A Lake or Streambed Alteration Agreement will be required if the CDFW determines that project activities may substantially adversely affect fish or wildlife resources through alterations to a covered body of water.

2.2.4 - California Porter-Cologne Water Quality Control Act The RWQCB regulates actions that would involve “discharging waste, or proposing to discharge waste, within any region that could affect the waters of the State” (Water Code § 13260(a)), pursuant to provisions of the Porter-Cologne Water Quality Act. “Waters of the State” are defined as “any surface water or groundwater, including saline waters, within the boundaries of the State” (Water Code § 13050(e)).

2.2.5 - California Native Plant Society Rare Plant Rankings The CNPS maintains a rank of plant species that are native to California and that have low population numbers, limited distribution, or are otherwise threatened with extinction. This information is published in the Inventory of Rare and Endangered Vascular Plants of California. Following are the definitions of the CNPS ranks:

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Potential impacts to populations of CNPS-ranked plants receive consideration under CEQA review. All plants appearing on the CNPS List ranked 1 or 2 are considered to meet the CEQA Guidelines Section 15380 criteria. Rank 3 and 4 plants do not automatically meet this definition. Rank 4 plants do not clearly meet CEQA standards and thresholds for impact considerations. 1 2.3 - Regional and Local
The proposed project does not lie within the boundaries of any adopted Habitat Conservation Plan (HCP) Natural Community Conservation Plan (NCCP), or other approved local, regional, or State habitat conservation plan.1

2.3.1 - City of Redlands
The City of Redlands General Plan 2035 (City of Redlands 2017) establishes long-range development policies to guide City departments, the Planning Commission, and City Council in their decisionmaking. The General Plan outlines principles and actions pertaining to natural resources and guidance for location, design, and quality of development to protect important wildlife, plants, and their associated habitats:

Principle 6-P.1 Develop a balanced and integrated open space system that reflects a variety of considerations, including resource conservation, production of agriculture, recreation, aesthetics, and community identity.

Principle 6-P.5 Encourage the preservation of natural habitat areas as open space.

Principle 6-P.6 Promote access to and views of conservation areas in a manner consistent with good land resource stewardship.

Action 6-A.1 Preserve as open space those areas that contain unique habitats, natural resources, and visual amenities such as citrus groves, hillsides, canyons, and waterways. These areas provide natural contrast with the urban cityscape.

Action 6-A.7 Work with San Bernardino County, neighboring cities, conservation organizations, and landowners to maintain and enhance the trails, roadways, and lands within the Emerald Necklace, and to ensure that sensitive resources in these areas are not disturbed or degraded.
1 California Native Plant Society (CNPS). 2020. Considerations for Including CRPR 4 Plant Taxa in CEQA Biological Resource Impact Analysis. Sacramento, CA. January.

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Principle 6-P.7 Protect environmentally sensitive lands, wildlife habitats, and rare, threatened, or endangered plant and animal communities.

Principle 6-P.8 Minimize disruption of wildlife and valued habitat throughout the Planning Area and emphasize that open space is for more than just human use, but also serves as habitat for biological resources.

Principle 6-P.9 Preserve, protect, and enhance wildlife corridors, including natural watercourses, 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.

Action 6-A.11 Require a biological assessment of any proposed project site within the Planning Area where species that are State or federally listed as rare, threatened, or endangered are identified as potentially present.

Action 6-A.12 Require that proposed projects adjacent to, surrounding, or containing wetlands, riparian corridors, or wildlife corridors be subject to a site-specific analysis that will determine the appropriate size and configuration of a buffer zone.

Action 6-A.13 Utilize conservation easements and preserves as means to conserve natural habitats.

Action 6-A.14 Construct freeway and arterial street undercrossings or overpasses where necessary to establish and preserve identified wildlife corridors.

Action 6-A.20 Work with State and County agencies in developing recovery and restoration plans after natural or man-made disasters to restore natural landscapes, habitats, and functioning ecosystems. As part of the recovery and restoration plans, include evaluation processes and implementation actions. Where appropriate, incorporate the use of native species.

Action 6-A.21 Ensure that future activities in the Santa Ana River Wash are consistent with the habitat conservation policies of the Upper Santa Ana River Land Management Habitat Conservation Plan (Wash Plan).

Redlands City Code
Chapter 12.52 of the Redlands City Code outlines the City’s Tree Protection Guidelines. These guidelines are applicable to the following categories of trees as defined by this chapter of the City Code:

Public Tree A tree located in a public place or area under ownership or control of the City, including, but without limitation, City streets, parkways, open space, and park lands.

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Landmark Tree A public tree designated as a historic resource under Chapter 2.62 of this code as a tree of historic or cultural significance and of importance to the community due to any of the following factors: it is one of the largest or oldest public trees of the species located in the City, it has historical significance due to an association with a historic building, site, street, person or event, or it is a significant outstanding feature of a neighborhood.

Native Tree Any tree, identified by a certified arborist as native to the local area, with a trunk more than eight inches (8”) in diameter at a height of four and one-half feet (4 ½’) above natural grade that is identified on a list of native trees approved by the City Council.

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Biological Resources Assessment Methods
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3.1 - Literature and Database Reviews
This literature review provides a baseline from which to evaluate potential project impacts on biological resources on the project site and in the surrounding area.

3.1.1 - Existing Documentation
As part of the literature review, an FCS Biologist examined existing environmental documentation for the project site and vicinity. This documentation included literature pertaining to the habitat requirements of special-status species with the potential to occur in the project vicinity; and federal register listings, protocols, and species data provided by the USFWS and CDFW.

3.1.2 - Topographic Maps and Aerial Photographs
An FCS Biologist reviewed current USGS 7.5-minute topographic quadrangle map(s)and aerial photographs as a preliminary analysis of the existing conditions within the project site and immediate vicinity.2 Information obtained from the topographic maps included elevation, general watershed information, and potential drainage feature locations using Google Earth in conjunction with the United States Environmental Protection Agency (EPA) Watershed Assessment, Tracking, and Environmental Results System (WATERS).3 Aerial photographs provided a perspective of the current site conditions relative to on-site and off-site land use, plant community locations, and potential locations of wildlife movement corridors.

3.1.3 - Soil Surveys
The United States Department of Agriculture (USDA) has published soil surveys that describe the soil series (i.e., group of soils with similar profiles) occurring within a particular area. 4 These profiles
include major horizons with similar thickness, arrangement, and other important characteristics.

These series are further subdivided into soil mapping units that provide specific information regarding soil characteristics. Many special-status plant species have a limited distribution based exclusively on soil type. Therefore, pertinent USDA soil survey maps were reviewed to determine the existing soil mapping units within the project site and to establish whether the soil conditions on-site are suitable for any special-status plant species.

3.1.4 - Special-status Species Database Search
An FCS Biologist compiled a list of threatened, endangered, and otherwise special-status species previously recorded within the project vicinity based on a search of the USFWS Information for 2 United States Geological Survey (USGS). 2021. National Geospatial Program. Website: https://www.usgs.gov/core-sciencesystems/national-geospatial-program/us-topo-maps-america?qt-science_support_page_related_con=4#qtscience_support_page_related_con. Accessed March 2023. 3 United States Environmental Protection Agency (EPA). 2021. Watershed Assessment, Tracking and Environmental Results System (WATERS). Website: https://www.epa.gov/waterdata/waters-watershed-assessment-tracking-environmental-results-system.

Accessed March 2023. 4 Natural Resources Conservation Service (NRCS). 2021. Web Soil Survey (WSS). United States Department of Agriculture (USDA).

Website: https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx. Accessed March 2023.

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5 the California Natural Diversity Database (CNDDB), and the CNPS Electronic Inventory (CNPSEI) of Rare and Endangered Vascular Plants of California. 6,7 The
CNDDB search focused on species records within 10 miles of the project site. The CNPSEI search focused on records from the Redlands, California, USGS 7.5-minute Topographic Quadrangle Map and the eight surrounding quadrangles. The CNDDB Biogeographic Information and Observation System (BIOS 5) was used to determine distances between species occurrences and the project site.8 The potential for occurrence on the project site was assessed for each of the special-status species identified in the database searches. The potential for occurrence was assessed based on conditions on the project site, habitat requirements of special-status species, and number of recent (< 20 years old) occurrences in the project vicinity.

3.1.5 - Jurisdictional Waters and Wetlands
Prior to conducting the reconnaissance-level survey, an FCS Biologist reviewed EPA WATERS and aerial photography to identify potential natural drainage features and water bodies.9 In general, all surface drainage features identified as blue-line streams on USGS maps and linear patches of vegetation are expected to exhibit evidence of flows and are considered potentially subject to State and federal regulatory authority as waters of the United States and/or State. A preliminary assessment was conducted to determine the location of any existing drainages and limits of projectrelated grading activities to aid in determining whether a formal delineation of waters of the United States or State is necessary.

3.2 - Field Surveys

3.2.1 - General Biological Survey
Senior Biologist Matthew South and Biologist Lucas South conducted a survey on March 9, 2023. The objective of the general survey was to ascertain general site conditions and identify whether existing vegetation communities provide suitable habitat for special-status plant or wildlife species. During this survey, the Biologist walked and drove the project site and characterized and mapped vegetation communities, identified and recorded plants and wildlife observed on-site, and recorded evidence of wildlife habitats, including wildlife corridors, nests, dens, or burrows. Special-status or unusual biological resources identified during the literature review were ground-truthed during the field survey for mapping accuracy. Special attention was paid to sensitive habitats and areas potentially supporting special-status floral and faunal species.
5 United States Fish and Wildlife Service (USFWS). 2021. Information for Planning and Consultation (IPaC). Website:
https://ecos.fws.gov/ipac/. Accessed March 2023. 6 California Department of Fish and Wildlife (CDFW). 2021. CNDDB RareFind 5 California Natural Diversity Database Query for SpecialStatus Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed March 2023. 7 California Native Plant Society (CNPS). 2021. California Native Plant Society Rare and Endangered Plant Inventory. Website:
http://www.rareplants.cnps.org/. Accessed March 2023. 8 California Department of Fish and Wildlife (CDFW). 2021. Biogeographic Information and Observation System (BIOS 5). Website:
https://map.dfg.ca.gov/bios/. Accessed March 2023. 9 United States Environmental Protection Agency (EPA). 2021. Watershed Assessment, Tracking and Environmental Results System (WATERS). Website: https://www.epa.gov/waterdata/waters-watershed-assessment-tracking-environmental-results-system.

Accessed March 2023.

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Common plant species observed during the general biological survey were identified by visual characteristics and morphology in the field and recorded in a field notebook and on field maps.

Uncommon and fewer familiar plants were identified with the use of taxonomical guides, including Jepson eFlora and Calflora.10,11 Taxonomic nomenclature used in this study follows The Jepson Manual: Vascular Plants of California.
12 Common plant names, when not available from The Jepson Manual, were taken from other regionally specific references. Vegetation community types and boundaries were noted on aerial photos, verified through field observation, and digitized using ESRI ArcGIS software® ArcMap 10.0. By incorporating collected field data and interpreting aerial photography, a map of habitat types, land cover types, and other biological resources within the project site was prepared. Vegetation community and land cover types used to help classify habitat types are based on the Manual of California Vegetation (MCV) and cross-referenced with the CDFW Natural Communities List.
13,14
Wildlife
Wildlife species detected during the general biological survey by sight, calls, tracks, scat, or other signs were recorded. Notations were made regarding suitable habitat for those special-status species determined to have the potential to occur within the project site. 15 Appropriate field guides were
used to assist in species identification during surveys, such as Peterson, Reid, and Stebbins. 16,17,18
Online resources such as eBird and California Herps were also consulted, as necessary. 19,20 Wildlife Movement Corridors
Wildlife movement corridors link areas of suitable wildlife habitat that are otherwise separated by rugged terrain, changes in vegetation, or human disturbance. Urbanization and the resulting fragmentation of open space areas create isolated “islands” of wildlife habitat, forming separated populations. Corridors act as an effective link between populations.

The project site was evaluated for evidence of a wildlife movement corridor during the general biological survey. The scope of the biological resource assessment did not include a formal wildlife movement corridor study utilizing track plates, camera stations, scent stations, or snares. Rather, the 10 Jepson Flora Project (eds.) 2021. Jepson eFlora, https://ucjeps.berkeley.edu/eflora/. Accessed on March 22, 2022. 11 Calflora. 2020. Calflora: Information on California plants for education, research, and conservation. Website:
http://www.calflora.org/. Accessed on March 2023. 12 Baldwin, B., et al. 2012. The Jepson Manual: Vascular Plants of California. Berkeley: University of California Press. County of San Bernardino (Bernardino)(amended 2015). 13 Sawyer, J.O., T. Keeler-Wolf, and J.M. Evens. 2009. A Manual of California Vegetation, Second Edition. California Native Plant Society, Sacramento. 1300 pp. 14 California Department of Fish and Wildlife (CDFW). 2021. Natural Communities List, Sacramento: California Department of Fish and Wildlife. Website: https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities#sensitive%20natural%20communities. Accessed March 2023. 15 California Department of Fish and Wildlife (CDFW). 2021. CNDDB RareFind 5 California Natural Diversity Database Query for SpecialStatus Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed March 2023. 16 Peterson, T.R. 2010. A Field Guide to Birds of Western North America, 4th Edition. Boston: Houghton Mifflin Harcourt. 17 Reid, F. 2006. A Field Guide to Mammals of North America, Fourth Edition. Boston: Houghton Mifflin Harcourt. 18 Stebbins, R.C. 2003. A Field Guide to Western Reptiles and Amphibians. Third Edition. Boston: Houghton Mifflin Harcourt. 19 eBird. 2021. Online bird occurrence database. Website: http://ebird.org/content/ebird/. Accessed March 2023. 20 California Herps. 2021. A Guide to the Amphibians and Reptiles of California. Website: http://www.californiaherps.com/Accessed March 2023.

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Methods Biological Resources Assessment
20 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx focus of this study was to determine whether a change in land use at the project site could have significant impacts on the regional movement of wildlife. Conclusions are based on the information compiled during the literature review, including aerial photographs, USGS topographic maps, and resource maps for the vicinity; the field survey; and professional experience with the desired topography, habitat, and resource requirements of the special-status species potentially utilizing the project site and vicinity.

3.2.2 - San Bernardino Merriam’s Kangaroo Rat Field Habitat Assessment During the general biological survey of the project site, the FCS Biologist searched the project site and 500-foot buffer area for the presence of vegetation communities that could breeding and/or foraging habitat for San Bernardino Merriam’s kangaroo rat, including Riversidian alluvial fan sage scrub, and ruderal and annual grassland habitats with open vegetation and bare areas. The Biologist also evaluated the condition and suitability of existing wildlife habitats and searched the project site for evidence of kangaroo rats, including burrows, tracks, and scat.

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Biological Resources Assessment Results
FirstCarbon Solutions 21 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx SECTION 4: RESULTS
This section summarizes the results of the literature search and general biological reconnaissance survey. The results of the sensitive biological resources database reviews and an analysis for the potential for occurrence of these resources on the project site are presented in Section 5. An analysis of project requirements for CEQA consistency is presented in Section 6.

4.1 - Literature Review

4.1.1 - Environmental Setting
The Song Property and the Emm Property to the east are currently vacant. Both parcels show signs of previous human use including recent disking and dumping. Former home foundations were also present on the Song Property. The project site is surrounded by urban development and SR-210 to the west, active construction (fully graded) and the Santa Ana River to the north, vacant land to the south and southeast and Citrus Valley High School to the east.

Soils
The Natural Resource Conservation Service (NRCS) Web Soil Survey (WSS) mapped one soil type (Ramona sandy loam, 0 to 2 percent slopes) on the project site and two soil types (Ramona sandy loam, 0 to 2 percent slopes and Pachappa fine sandy loam, 0 to 2 percent slopes) within the off-site road improvements area (Exhibit 4). The Ramona series soils are brown, slightly and medium acid, sandy loams and fine sandy loams. The Pachappa series soils consist of well drained (minimal) Noncalcic Brown soils developed from moderately coarse textured alluvium.

4.2 - Biological Surveys
FCS Biologists conducted the general biological survey of the project site on August 5, 2022, between approximately 9:00 a.m. to 10:30 a.m. Weather conditions during the field surveys were sunny and clear, with temperatures ranging from 79 to 80°F (degrees Fahrenheit), and wind speeds between 0 and 3 miles per hour (mph). Vegetation Communities and Land Use The project site consists of undeveloped lands that were recently disked and vegetated in ruderal species at the time of the survey. Adjacent lands within 500 feet of the project site included ruderal habitat and urban/developed lands (Exhibit 5). Photographs of the vegetation communities on-site are presented in Appendix B. Detailed descriptions of vegetation communities and land cover types are provided below.

Ruderal/Disturbed
Ruderal/disturbed habitat is classified as areas that have been physically disturbed (by previous legal human activity) and are no longer recognizable as a native or naturalized vegetation association but continue to retain a soil substrate. Typically, if any vegetation is present, it is nearly exclusively composed of non-native plant species such as ornamentals or ruderal exotic species that take advantage of disturbance or show signs of past or present animal usage that precludes them from Redlands Regular meeting of 12-19-23 918 of 1429
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22 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx providing viable natural habitat for uses other than dispersal. Examples of disturbed land include areas that have been graded, land that is repeatedly cleared for fuel management purposes and/or experienced repeated use that prevents natural revegetation (i.e., dirt parking lots, trails that have been present for several decades), recently graded firebreaks, graded construction pads, construction staging areas, off-road vehicle (OHV) trails, and old home-sites.

Ruderal/disturbed habitat occurs over the entire project site and on adjacent, undeveloped lands.

Most areas exhibiting ruderal habitat were recently disked for weed abatement activities. The soil surface is predominantly bare in the recently disked areas, but the southwestern portion of the Song Property and areas bordering Pioneer Avenue were not disked and exhibited relatively dense ruderal vegetation. Plant species observed in ruderal areas included prickly Russian thistle (Kali tragus), common fiddleneck (Amsinckia intermedia), puncturevine (Tribulus terrestris), London rocket (Sisymbrium irio), shortpod mustard (Hirschfedlia incana), telegraph weed (Heterotheca grandiflora), and Canada horseweed (Erigeron canadensis), red brome (Bromus rubens), and ripgut brome (Bromus diandrus).

Urban/Developed
Urban developments are characterized by a combination of developed and hardscaped areas and manicured vegetation, including street/shade trees, lawns, and shrubs, and little or no exposed soil substrates. Irrigation and fertilization allow for tropical and other non-native and ornamental species to flourish in urban areas. Trees are often grown in a spaced pattern with an open understory, and lawns are typically one species maintained at a continuous, uniform height. Shrubs are grown as spaced individuals or in tight rows that are hedged. These conditions provide habitat to a low diversity of wildlife that are tolerant of human-modified environments.

Urban/developed lands in the 500-foot buffer around the project site include Citrus Valley High School to the east and SR-210 and industrial warehouses to the west of the project.

Trees
Scattered trees and shrubs were observed in ruderal areas on-site, including black elderberry (Sambucus nigra), tree tobacco (Nicotiana glauca), tree of heaven (Ailanthus altissima), and lemonscented gum (Corymbia citriodora). On the Emm Property, a small group of black elderberry trees is present on the eastern side of the parcel. Several scattered elderberry trees were also observed on the Song Property, including some that had been disked over but survived the disturbance. Several of the black elderberry trees, which grow as multi-trunked trees, appeared to have combined trunk measurements exceeding 8 inches diameter at breast height (DBH; approximately 4.5 feet above the ground surface). A row of lemon-scented gum trees is located along Pioneer Avenue on the southern border of the Song Property.

4.2.1 - Wildlife
Despite the highly modified environment on and adjacent to the project site, the vegetation community and land cover types there provide habitat for numerous wildlife species capable of tolerating those conditions. Even the anthropogenic features on the project site (buildings, shipping containers, stored equipment, and concrete foundations) could provide habitat for numerous Redlands Regular meeting of 12-19-23 919 of 1429
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Biological Resources Assessment Results
FirstCarbon Solutions 23 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx wildlife species. Wildlife activity during the general biological reconnaissance survey was moderate and consisted primarily of avian and mammalian species. Evidence of other species was evident in tracks, scat, and other signs, as well as information provided by the current site occupant. The following discussions regarding the wildlife species observed within the project site are organized by taxonomic group. Each discussion contains representative examples of a particular taxonomic group either observed or expected to occur on-site. No special-status wildlife species were observed during the survey.

Amphibians and Fish
No amphibian or fish species were observed on-site during the general biological reconnaissance survey. Because of arid climate in the region, amphibians are uncommon and typically limited to areas where sufficient sources of water are present. A channelized drainage feature paralleling SR210 conveys water runoff to the Santa Ana River, but it does not likely hold water for sufficient periods that would allow for occurrence of fish or amphibians. A basin associated with the Citrus Valley High School grounds may hold water during storm events but would likely not support breeding habitat for amphibians. With no apparent open water sources on-site or in the vicinity, amphibians and fish are not expected to occur on-site or within a 500-foot buffer.

Birds
Avian activity was moderate during the field survey. FCS Biologists identified common native and non-native species, including mourning dove (Zenaida macroura), Eurasian collared dove (Streptopelia decaocto), rock pigeon (Columba livia), Anna’s hummingbird (Calypte anna), red-tailed hawk (Buteo jamaicensis), American kestrel (Falco sparverius), American crow (Corvus brachyrhynchos), common raven (Corvus corax), horned lark (Eremophila alpestris), bushtit (Psaltriparus minimus), black phoebe (Sayornis nigricans), European starling (Sturnus vulgaris), northern mockingbird (Mimus polyglottos), California towhee (Melozone crissalis), house sparrow (Passer domesticus), house finch (Haemorhous mexicanus), and western meadowlark (Sternella neglecta). Birds may find nesting platforms throughout the project site on bare ground, in grasses, shrubs, and trees, and in similar habitats and on buildings within 500 feet of the project.

Invertebrates
Three butterflies, painted lady (Vanessa cardui), common buckeye (Junonia coenia), and cabbage white (Pieris rapae), were observed on-site, as were European honeybees (Apis mellifera), houseflies (Musca domestica), oblique streaktail (Allograpta obliqua), California harvester ant (Pogonomyrmex californicus), and blue dasher (Pachydiplax longipennis). Other invertebrates that likely occur at the site year-round or during seasonal pulses include several species of beetles, flies, ants, bees, wasps, moths and butterflies, and spiders and tarantulas, among others.

Mammals
Two mammalian species were observed on-site during the general biological field survey, including California ground squirrel (Otospermophilus beecheyi) and desert cottontail (Sylvilagus audubonii).

Burrows, scat, and tracks of other mammals were evident on-site, including coyote (Canis latrans), and valley pocket gophers (Thomomys bottae). Other mammalian species that may be present on the project site include Virginia opossum (Didelphis virginiana), California myotis (Myotis Redlands Regular meeting of 12-19-23 920 of 1429
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24 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx californicus), raccoon (Procyon lotor), striped skunk (Mephitis mephitis), western harvest mouse (Reithrodontomys megalotis), black rat (Rattus rattus), and house mouse (Mus musculus).

Reptiles
Two reptiles, western side-blotched lizard (Uta stansburiana elegans) and Great Basin fence lizard (Sceloporus occidentalis longipes), were observed on the project site. Other common reptiles that may occur on-site include San Diego gophersnake (Pituophis catenifer annectens) and California kingsnake (Lampropeltis californiae). Wildlife Movement Corridors A channelized drainage located west of the project site but within its 500-foot buffer likely provides a movement corridor for a number of terrestrial wildlife species, including Virginia opossum, coyote, raccoon, striped skunk, several rodent species, and several lizard species, including San Diegan tiger whiptail. The channelized drainage provides a connection and movement corridor between the Santa Ana River Wash to the north and the parcel supporting ruderal vegetation located directly southwest of the project site. The channelized drainage supports native riparian woodland species and eucalyptus trees that provide cover for dispersing wildlife species. The bank of the channelized drainage and portions of the terrace area adjacent to and up to approximately 30 feet of the edge of the bank likely also function as a part of the wildlife movement corridor. The channelized drainage bank and the adjoining terrace may be particularly useful for wildlife movements in areas where homeless encampments within the channelized drainage may limit the movement of some wildlife species. The project site itself does not serve as a wildlife movement corridor.

4.2.2 - San Bernardino Merriam’s Kangaroo Rat Habitat Assessment San Bernardino Merriam’s kangaroo rat occurs on alluvial floodplains of the Santa Ana River and its tributaries and adjacent upland habitats in the San Bernardino, Menifee, and San Jacinto Valleys in San Bernardino and Riverside Counties. The Santa Ana River supports suitable habitat and one of the largest extant populations of the species.21 Critical habitat for the species was designated in the Santa Ana River Wash by the USFWS. San Bernardino Merriam’s kangaroo rat prefers early (pioneer) and intermediate successional stages of Riversidian alluvial fan sage scrub, a plant community with coastal sage scrub and chaparral elements on alluvial terraces and braided river channels in Southern California.
22 The species excavates burrows in loose, sandy soils, usually near or beneath shrubs. The species may also occur in abandoned agricultural fields and orchards, but usually only when such habitats are adjacent to suitable natural habitats. San Bernardino Merriam’s kangaroo rat abundance is greatest in areas of sandy soils with low-to-moderate perennial vegetative cover (less than 30 percent to 50 percent) and minimal density of non-native annual grass cover. 23,24 Presence
of San Bernardino Merriam’s kangaroo rat is negatively correlated with dense stands of non-native 21 McKernan, R.L. 1997. The status and known distribution of the San Bernardino kangaroo rat (Dipodomys merriami parvus): field surveys conducted between 1987 and 1996. Prepared for the United States Fish and Wildlife Service, Carlsbad, California. 22 McKernan, R.L. 1997. The status and known distribution of the San Bernardino kangaroo rat (Dipodomys merriami parvus): field surveys conducted between 1987 and 1996. Prepared for the United States Fish and Wildlife Service, Carlsbad, California. 23 Ibid. 24 MEC Analytical Systems, Inc. 2000. Final report of findings for the San Bernardino kangaroo rat and Habitat relationships 1999 field study for the Santa Ana River alluvial fan, San Bernardino County, California. Report prepared for the United States Army Corps of Engineers, Los Angeles District.

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FirstCarbon Solutions 25 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx grasses and areas dominated by surface boulders and rocks, and positively correlated with sandy soils, sparse vegetation cover, and presence of scalebroom (Lepidospartum squamatum).25,26 Habitat conditions on the project site, including the open, ruderal, grassland-like habitat appear to be marginally suitable for San Bernardino Merriam’s kangaroo rat occupancy. Portions of the Song Property may have been used for planting of citrus orchards during historical times, and building ruins located on the Emm Property indicates it was previously occupied and used by humans. In recent years regular disking of the project site has maintained an open habitat that is preferred by San Bernardino Merriam’s kangaroo rats, allowing them to recolonize the site after the removal of orchards and abandonment of residential/agricultural use of the site. The channelized drainage west of the project site provides a potential wildlife movement corridor that could allow access of the site by San Bernardino Merriam’s kangaroo rats from the Santa Ana River, where a large population of the species is known to occur north of the project site.27 25 Root, B. 2008. 2005-2007 San Bernardino Kangaroo Rat Mark-Recapture Survey Analyses from the Woolly Star Preserve Area, San Bernardino County, California. Report prepared for the United States Army Corps of Engineers, Los Angeles District. 87 pp. 26 Root, B. 2008. 2006-2007 San Bernardino Kangaroo Rat Occupancy Survey Analyses from the Woolly Star Preserve Area, San Bernardino County, California. Prepared for the United States Army Corps of Engineers. United States Fish and Wildlife Service.

December. 153 pp. 27 McKernan, R.L. 1997. The status and known distribution of the San Bernardino kangaroo rat (Dipodomys merriami parvus): field surveys conducted between 1987 and 1996. Prepared for the United States Fish and Wildlife Service, Carlsbad, California.

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49400030 • 08/2022 | 4_soils.mxd
Exhibit 4
Soils Map
Source: Google Earth Aerial Imagery. Huitt-Zollars, 08/2022. USDA Soils Data Mart, Southwest San Bernardino.

MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT

BIOLOGICAL RESOURCES ASSESSMENT
Tennessee St
Pioneer Ave
Domestic Ave
210
HbA
TuB
HbA
HbA
250 125 0 250
Feet
Legend
Project Site 14.62 acres
Off-site Roadway and Frontage Improvements 0.56 acre
Soil Classification Project Site Off-site Improvements
HbA - Hanford Sandy Loam, 0 To 2 Percent Slopes 14.49 acres 0.56 acre TuB - Tujunga Loamy Sand, 0 To 5 Percent Slopes 0.13 acre 0.00 acre Redlands Regular meeting of 12-19-23 924 of 1429

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Exhibit 5
Vegetation Community/Land Cover
Source: Google Earth Aerial Imagery. Huitt-Zollars, 08/2022.

MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT

BIOLOGICAL RESOURCES ASSESSMENT
Tennessee St
Pioneer Ave
Domestic Ave
210
400 200 0 400
Feet
Legend
Project Site 14.62 acres
Off-site Roadway and Frontage Improvements 0.56 acre
500-foot Study Area
Vegetation Community/Land Cover Study Area Project Site Off-site Improvements Ruderal/Disturbed 42.40 acres 14.45 acres 0.39 acre
Urban/Developed 36.02 acres 0.17 acre 0.17 acre
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Biological Resources Assessment Sensitive Biological Resources Database Reviews FirstCarbon Solutions 31 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx SECTION 5: SENSITIVE BIOLOGICAL RESOURCES DATABASE REVIEWS The following section discusses the results of the database reviews for sensitive biological resources and an analysis of the potential for these resources to occur within the project site based on existing biological conditions on and adjacent to the site.

5.1 - Sensitive Natural Communities
Sensitive natural communities are vegetation communities or special wildlife habitats that are rare or occur in limited distributions or provide specific habitat requirements for special-status plant or wildlife species. The CDFW maintains a list of natural communities which attempts to classify vegetation types found within the State of California and rank them based on rarity. Communities ranked S1-S3 are considered sensitive natural communities. 28 The CNDDB identified three sensitive
natural communities that are known to occur within 5 miles of the project site: Southern Mixed Riparian Forest, Southern Sycamore Alder Riparian Woodland, and Riversidian Alluvial Fan Sage Scrub. Seven sensitive natural communities, including Canyon Live Oak Ravine Forest, Southern Coast Live Oak Riparian Forest, Southern Cottonwood Willow Riparian Forest, Southern Riparian Forest, Southern Riparian Scrub, Southern Sycamore Alder Riparian Woodland, and Southern Willow Scrub have been recorded in the CNDDB between 5 and 10 miles from the project site. 29 These
communities are not present on or adjacent to the project site.

5.2 - Special-status Plant Species
According to the CNDDB, 19 special-status plant species have been recorded within 5 miles of the project site and an additional 14 species have been recorded between 5 and 10 miles from the project site.
30,31 An additional 50 species were identified on the 9-quadrangle CNPSEI search, and one additional species was identified in the USFWS IPaC review (Appendix C, Table 1). Table 1 in Appendix C includes the species’ status, required habitat, and a summary analysis of the potential for each of these species to occur on the project site. Special-status plant species that were determined to have low or no potential to occur on-site appear in the table with justification for their exclusion from further discussion. The potential for occurrence of a species was based on presence of suitable habitats, soil types, and occurrences recorded by the CNPSEI and CNDDB. 32,33
Previous and significant surface disturbances evident throughout the project site and the presence and abundance of several non-native, invasive, annual plant species there have likely lowered the potential for persistence and occurrence of populations of many special-status plant species. 28 California Department of Fish and Wildlife (CDFW). 2021. Natural Communities List, Sacramento: California Department of Fish and Wildlife. Website: https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities#sensitive%20natural%20communities. Accessed March 2023. 29 California Department of Fish and Wildlife (CDFW). 2021. Biogeographic Information and Observation System (BIOS 5). Website:
https://map.dfg.ca.gov/bios/. Accessed March 2023. 30 Ibid. 31 California Department of Fish and Wildlife (CDFW). 2021. CNDDB RareFind 5 California Natural Diversity Database Query for SpecialStatus Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed March 2023. 32 California Native Plant Society (CNPS). 2021. California Native Plant Society Rare and Endangered Plant Inventory. Website:
http://www.rareplants.cnps.org/. Accessed March 2023. 33 California Department of Fish and Wildlife (CDFW). 2021. Biogeographic Information and Observation System (BIOS 5). Website:
https://map.dfg.ca.gov/bios/. Accessed March 2023.

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5.2.1 - Potential for Occurrence of Special-status Plants The project site is significantly disturbed and is surrounded by urbanized development and undeveloped lands that have been repeatedly disturbed (disked). Because of the conditions on and adjacent to the project site, all special-status plants that occur in the region were assessed as having no potential for occurrence (Appendix C, Table 1). Thus, special-status plants are not expected to occur on the project site and are not discussed further.

5.3 - Special-status Wildlife Species
Forty-two special-status wildlife species were identified as occurring within 5 miles of the project site as recorded in the CNDDB and an additional 14 species were identified in the USFWS IPaC review (Appendix C, Table 2).34,35,36 Table 2 in Appendix C includes the species’ status, required habitat types and features, and potential to occur within the project site. The table also includes special-status wildlife species that have been determined to have low or no potential to occur on-site, primarily based on the absence of suitable habitat and the lack of recorded occurrence in the project vicinity, along with other justification(s) for their exclusion from further discussion. Special-status wildlife species with moderate to high potential to occur on-site are analyzed further below. The potential for wildlife to occur on the project site was based on presence of suitable habitats and occurrences recorded in the CNDDB.

5.3.1 - Potential for Occurrence of Special-status Wildlife The project site contains suitable habitat conditions that provide at least a moderate potential for the following special-status wildlife species to occur on-site:

Species evaluated with a moderate potential to occur include:
• San Diegan tiger whiptail
• Southern California legless lizard (Anniella stebbinsi) • Cooper’s hawk (Accipiter cooperii)
• burrowing owl (Athene cunicularia)
• California horned lark
• San Bernardino Merriam’s kangaroo rat
All other species were assessed as having no or low potential to occur because the project site is outside of the known distributional range of the species or did not support suitable habitat (Appendix C, Table 2). Those species with moderate or high potential to occur on-site are discussed below.
34 California Department of Fish and Wildlife (CDFW). 2021. CNDDB RareFind 5 California Natural Diversity Database Query for SpecialStatus Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed March 2023. 35 California Department of Fish and Wildlife (CDFW). 2021. Biogeographic Information and Observation System (BIOS 5). Website:
https://map.dfg.ca.gov/bios/. Accessed March 2023. 36 United States Fish and Wildlife Service (USFWS). 2021. Information for Planning and Consultation (IPaC). Website:
https://ecos.fws.gov/ipac/. Accessed March 2023.

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San Diegan tiger whiptail
The San Diegan tiger whiptail typically occurs in arid scrublands with sparse vegetation. This whiptail can also be found within forests, woodlands, chaparral and riparian areas. It feeds on small invertebrates, especially spiders, scorpions, centipedes, termites, and other small lizards. This species was observed on a parcel adjacent to the project site during a biological survey by FCS in 2020. There are three recent records (from 2014, 2015, and 2016) within 5 miles of the project site.

One observation was in an area that supported remnant Riversidean fan sage scrub and annual grassland habitat near the channelized drainage. The channelized drainage feature is located just west of the current project site, therefore, there is moderate potential for this species to occur onsite.

Southern California legless lizard
The Southern California legless lizard is found in coastal sand dunes and a variety of interior habitats, including sandy washes and alluvial fans. Much of the coastal dune habitat it lives in has been destroyed by coastal development. Suitable habitat for this species may be present in ruderal habitats on and adjacent to the project site. There are six recent and two historical records within 5 miles of the project site, and 11 recent and six historical records between 5 and 10 miles from the project site. The regular and recent disking of the project site likely make the area less suitable for occurrence of this species.

Cooper’s hawk
The Cooper's hawk is a California Species of Special Concern that inhabits forested or wooded riparian areas throughout California. The species capture prey (typically mid-sized birds) from cover or while flying quickly through dense vegetation, relying on surprise. There is suitable foraging and nesting habitat for this species in the ornamental trees on and adjacent to the project site. There is one historical record within 5 miles of the project site. There is moderate potential for this species to occur on-site as a forager or nester.

Burrowing owl
The burrowing owl is an owl in the family Strigidae. Burrowing owls occur in open, dry, annual or perennial grasslands, deserts, and scrublands characterized by low-growing vegetation. This species utilizes, modifies, and nests in burrows created by other species, most notably those of the California ground squirrel, but also those excavated by coyotes, desert kit foxes, desert tortoises, American badgers, and other burrowing mammals. Burrowing owl populations are threatened by habitat loss, pesticide use, and ground squirrel eradication programs, which limit suitable burrowing habitat. This species is considered a Special Species of Concern (SSC) by the CDFW and a Bird of Conservation Concern (BCC) by the USFWS. Nesting burrows of this species are protected by the MBTA and Fish and Game Codes pertaining to native nesting avian species.

The project site contains suitable open habitat with low-growing vegetation. There were numerous California ground squirrel burrows observed on the project site and adjacent properties. There are 11 recent records within 5 miles of the project site and 40 recent records between 5 and 10 miles Redlands Regular meeting of 12-19-23 930 of 1429
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California Horned Lark
California horned lark is designated as a California Species of Special Concern. This species is a common to abundant year-round resident that inhabits a variety of open habitats, such as grasslands and other open habitats with low, sparse vegetation, and typically where trees and large shrubs are absent.

California horned lark nest on the ground, building grass-lined nests in a cup-shaped depression on open ground. This species is very gregarious and often forms large flocks that forage and roost together after the breeding season. California horned lark eats insects, snails, and spiders during breeding season and grass and forb seeds and other plant matter outside of the breeding season. There is one historical record within 5 miles of the project site. (Exhibit 6).38 The open areas on and adjacent to the project site may provide suitable foraging and nesting habitat for this species, and there is moderate potential for this species to occur there.

Loggerhead Shrike
The loggerhead shrike is a passerine bird in the family Laniidae. This species inhabits open country with short vegetation and well-spaced shrubs or low trees, particularly those with spines or thorns.

They frequent agricultural fields, pastures, old orchards, riparian areas, desert scrublands, savannas, prairies, golf courses, and cemeteries. Loggerhead shrikes were once widely distributed across southern Canada, the contiguous United States and Mexico; however, their populations have declined significantly since the 1960s. They are considered a SSC by the CDFW and a BCC by the USFWS. Their nests are protected by the MBTA and Fish and Game Codes pertaining to native nesting avian species. There is one historical record within 5 miles of the project site. There is moderate potential for this species to forage and nest on the project site.

San Bernardino Merriam’s Kangaroo Rat
The San Bernardino kangaroo rat (SBKR) is one of three subspecies of the Merriam’s kangaroo rat.

The Merriam’s kangaroo rat is a widespread species that can be found from the inland valleys to the deserts of Southern California. The subspecies known as the San Bernardino kangaroo rat, however, is confined to inland valley scrub communities, and more particularly, to scrub communities occurring along rivers, streams and drainages. Most of these systems have been historically altered as a result of flood control efforts and the increased use of river resources, including mining, off-road vehicle use and road and housing development. This increased use of river resources has resulted in a reduction in both the amount and quality of habitat available for the San Bernardino Merriam’s kangaroo rat. Marginally suitable habitat for this species is present on-site. There are 11 recent records (between 2004 and 2017) and two historical records (1989 and 1997) of San Bernardino Merriam’s kangaroo rat within 5 miles of the project site and seven recent records (between 2003 and 2017) and one historical record (1990) between 5 and 10 miles from the project site. Most 37 California Department of Fish and Wildlife (CDFW). 2021. Biogeographic Information and Observation System (BIOS 5). Website:
https://map.dfg.ca.gov/bios/. Accessed March 2023. 38 Ibid.

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MLC Holdings, Inc.—Song and Emm Properties Project
Biological Resources Assessment Sensitive Biological Resources Database Reviews FirstCarbon Solutions 35 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx records were recorded in Riversidean alluvial fan sage scrub habitat, and one record from 2004 was in a recently disked agricultural field.

Our Biologists conducted an SBKR survey and habitat assessment on March 9, 2023, to determine both the quality of habitat for SBKR and to assess the parcels for current SBKR use by conducting a burrow survey.39 Burrows were not observed in most of the site due to the recently tilled soil, which would remove any existing burrows. Burrows were observed on the northeastern edge of the review site in a narrow 10-foot by 100-foot tract of undisturbed ground, half covered with forbs and concrete debris. These burrows were not SBKR burrows because they were either too small or too large and did not have signs of SBKR use. The small burrows were approximately 1.5-2 inches in diameter, and are too small to be used or made by SBKR. The larger burrows were 5.5-6 inches or greater in size and had often an oblong or non-circle entrance. These larger burrows were active with California ground squirrel that were observed frequently along this berm. No burrows were observed in the densely vegetated portions of the berm or in the tilled areas. Each of the burrows were inspected for signs of use by SBKR (tail drags or scat) and showed no signs of SBKR activity.

SBKR habitat has been characterized as areas with a sandy substrate and with a low to moderate perennial vegetative cover absent a dense cover of non-native, annual grasses. SBKR prefers areas with smaller shrubs sparsely spaced and bare sandy ground between the shrubs. The project site lacks the frequent alluvial action that creates SBKRs preferred conditions found in the active floodplain to the north of the review area, and the area lacks the typical plant cover characteristics of SBKR habitat. The tilled areas would not be considered SBKR habitat due to the lack of vegetation and disturbance that altered the soils and plants. The few untilled areas are covered in dense ruderal plants, which do not support SBKR, and in areas where the plant density is sparser, the burrows were not of the size or shape of SBKR. Because of the tilled bare soil, lack of typical plant species and composition, and the position of the site away from any alluvial action of the river, the site lacks habitat for SBKR.

5.3.2 - Nesting Birds
The project site contains numerous surfaces, structures, and vegetation that could provide suitable nesting habitat for bird species protected under the MBTA and the Fish and Game Code. These species include Cooper’s hawk, burrowing owl, California horned lark, loggerhead shrike, and other native avian species. Construction activities could disturb nesting and breeding birds in trees and shrubs within and around the construction site. Potential impacts on special-status and migratory birds that could result from construction and operation of the proposed project include destruction of eggs or occupied nests, mortality of young, and abandonment of nests with eggs or young birds prior to fledging.

5.4 - Potentially Jurisdictional Waters and Wetlands
The project site does not contain any potentially jurisdictional waters or wetlands within its boundaries; therefore, a formal Jurisdictional Delineation is not required. However, it should be 39 South Environmental. 2023. San Bernardino Kangaroo Rat Habitat Assessment and Survey, Song and Emm Properties Project, City of Redlands, San Bernardino County, California, March 9, 2023.

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MLC Holdings, Inc.—Song and Emm Properties Project
Sensitive Biological Resources Database Reviews Biological Resources Assessment 36 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx noted that the concrete drainage channel located immediately to the west of the Song Property may be a jurisdictional water of the United States and water of the State (i.e., a State and federal protected water resource), owing to its connection to the Santa Ana River.

5.5 - Protected Trees
Several trees on-site may meet criteria for protection under Chapter 12.52 of the Redlands City Code. Several of the native black elderberry trees on-site appeared to exhibit combined trunk diameters that exceed 8-inches at 4.5 feet above the ground surface. Additionally, the row of lemonscented gum trees along Pioneer Avenue may be located in a public right-of-way, which would qualify them as public trees. Black elderberry trees with cumulative trunk diameters of 8 inches or greater and any lemon-scented gum trees in a public right-of way may be subject to protection under Redlands City Code Chapter 12.52.

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MLC Holdings, Inc.—Song and Emm Properties Project
Biological Resources Assessment Sensitive Biological Resources Database Reviews FirstCarbon Solutions 37 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx Exhibit 6: Special-status Species Occurrences in the Project Vicinity This exhibit contains sensitive information relating to Biological Resources and is not intended for public distribution pursuant to Public Resources Code Section 21082.3(C)(2). A copy of confidential Exhibit 6 is on file with FirstCarbon Solutions and is available to qualified professionals upon request.

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Biological Resources Assessment Impact Analysis and Recommendations FirstCarbon Solutions 39 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx SECTION 6: IMPACT ANALYSIS AND RECOMMENDATIONS
The following discussion addresses potential project impacts on regulated biological resources, including special-status species, and recommends measures to avoid and/or mitigate impacts to a less than significant level under CEQA. These impacts and others are analyzed and addressed with proposed Mitigation Measures (MMs) that would avoid or lessen them.

6.1 - Special-status Wildlife Species
Burrowing owl, a California Species of Special Concern, was assessed as having a moderate potential to occur on the project site. To prevent potential project impacts on burrowing owl that may utilize the project site, the following mitigation measures are recommended.

Mitigation Measure
MM BIO-1 Pre-Construction Surveys for Burrowing Owl (including avoidance if found) • Burrowing Owl Pre-construction Survey: The project applicant shall retain a qualified Biologist to perform a pre-construction burrowing owl survey to determine whether burrowing owls are present within 30 days prior to construction activities, according to the California Department of Fish and Wildlife (CDFW) 2012 guidelines. If construction is delayed or suspended for more than 30 days after the survey, the area shall be resurveyed. Survey for occupied burrows shall be completed within all construction areas and within 300 feet from the proposed project impact area (where possible and appropriate based on locations of barren or ruderal habitats). At least 15 days prior to the expected start of any project-related ground disturbance activities, or restart of activities, the City shall provide a burrowing owl survey report with mapping exhibits to the CDFW. If no burrowing owls are detected during the pre-construction survey, no further action is necessary.
• Agency Consultation, Mitigation, and Avoidance: If burrowing owls are detected during the pre-construction survey, the City shall consult with the CDFW and United States Fish and Wildlife Service (USFWS) to develop and implement a Burrowing Owl Mitigation Plan that includes mitigation measures outlined in CDFW (2012) guidelines and a Worker Environmental Awareness Program (WEAP).

There is moderate potential for two special-status lizards, San Diegan tiger whiptail and Southern California legless lizard, to occur within the project site.

MM BIO-2 Pre-Construction Surveys for Special-status Reptiles (including avoidance if found) • Pre-construction Survey: Prior to the issuance of a grading permit, the project applicant shall provide evidence that a qualified Biologist has been retained to perform a pre-construction survey of the entire project impact area, including any staging/laydown areas, for Southern California legless lizard and San Diegan tiger Redlands Regular meeting of 12-19-23 936 of 1429
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Impact Analysis and Recommendations Biological Resources Assessment 40 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx whiptail no more than 7 days prior to initiating project activities.

If special-status wildlife species are observed during construction activities, all work within 50 feet of the animal(s) will be stopped. At no time shall work occur within 50 feet of the animal without the Biological Monitor present. Any specialstatus wildlife species detected within the project impact area, including any staging/laydown areas, shall be allowed to move away on their own and shall not be captured or handled without authorization from the California Department of Fish and Wildlife (CDFW) or United States Fish and Wildlife Service (USFWS). • Avoidance of Entrapment: To prevent inadvertent entrapment of animals during construction, all excavated, steep-walled holes or trenches may need to be covered at the close of each working day with plywood or other suitable material or provided with one or more escape ramps constructed of earth fill or wooden planks. The project applicant shall retain a qualified Biologist to regularly inspect open trenches during the construction phase.
• Environmentally Sensitive Area Fencing: Areas that support sensitive habitats or species shall be temporarily fenced to protect them from construction activities and traffic. The project applicant may need to retain a qualified Biologist to monitor Environmentally Sensitive Areas during the construction phase. • Worker Environmental Awareness Program: A Worker Environmental Awareness Program (WEAP) training shall be implemented to educate construction workers about the presence of special-status plant and wildlife species on and near the project site and shall be administered to construction personnel prior to the initiation of ground-disturbing or vegetation/habitat altering activities.

San Bernardino Merriam’s Kangaroo Rat
The project site lacks habitat for SBKR due to the tilled nature, lack of typical plant species and composition, and the position outside of alluvial action of the river. The small mammal burrows at the site were determined to be made by other species and lacked the characteristics of SBKR burrows. Furthermore, no SBKR individuals were observed and there were no signs of SBKR activity in the vicinity of the burrows (e.g., tail drag marks, scat). Therefore, SBKR is considered absent from the site. The exclusionary fencing surrounding the site will ensure that no SBKR will be able to populate the site in the future and it will remain free of SBKR.

Nesting Birds
Birds protected under the MBTA or California Fish and Game Code are considered sensitive during the active nesting period. The project site contains several large and medium sized trees which could provide suitable habitat for nesting birds including special-status species such as Cooper’s hawk and loggerhead shrike. The project site also contains open ruderal habitat that could provide suitable habitat for ground-nesting birds such as California horned lark and burrowing owl. Construction activities that occur during the avian nesting season (generally February 1 to August 31) could disturb nesting sites for bird species protected under the MBTA or the Fish and Game Code. The removal of trees during the nesting season could result in direct harm to nesting birds, while noise, light and other man-made disturbances may cause nesting birds to abandon their nests. The project applicant shall implement the following mitigation measures to ensure that project impacts on nesting birds are less than significant:

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MLC Holdings, Inc.—Song and Emm Properties Project
Biological Resources Assessment Impact Analysis and Recommendations FirstCarbon Solutions 41 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/BRA/49400030 Redlands Song Property Residential Project BRA.docx • Seasonal Avoidance: If feasible, tree removal and vegetation clearing should be limited to the non-nesting season (September 1 through January 31).
• Pre-construction Nesting Bird Surveys: If the project requires trees to be removed during the nesting season (February 1 through August 31), a qualified Biologist shall conduct preconstruction surveys for migratory birds on the project site, including a 300-foot survey buffer, no more than 3 days prior to the start of ground-disturbing activities. If construction is delayed or suspended for more than 3 days after the survey, the area shall be resurveyed to re-confirm the presence/absence of any active nests.
• Monitoring of Active Nests: If an active nest is located during pre-construction surveys, the USFWS and/or the CDFW (as appropriate) will be notified regarding the status of the nest.

Furthermore, construction activities will be restricted as necessary to avoid disturbance of the nest until it is abandoned, or the Biologist deems disturbance potential to be minimal.

Restrictions may include establishment of exclusion zones (no ingress of personnel or equipment at a minimum radius of 300 feet around an active raptor nest and 50-foot radius around an active non-raptor passerine bird nest) or alteration of the construction schedule. • A qualified Biologist will delineate the buffer using nest buffer signs, environmentally sensitive area fencing, pin flags, and or flagging tape. The buffer zone will be maintained around the active nest site(s) until the young have fledged and are foraging independently.

Potentially Jurisdictional Features
Project construction activities on the western side of the Song Property could cause sediment to enter the channelized drainage and result in indirect impacts to the drainage channel and water quality downstream, potentially including through spills and stormwater runoff during construction.

Therefore, implementation of water quality protection Best Management Practices (BMPs) are recommended. These shall include the following:
• Construction General Permit from the RWQCB.
• Stormwater planning documents consistent with the requirements of the RWQCB (e.g., a Storm Water Pollution Prevention Plan [SWPPP] that complies with current National Pollution Discharge Effluent Standards [NPDES]).
• BMPs to control the pollutants in stormwater runoff (e.g., silt fencing, straw wattles, etc.).

Protected Trees
The project site supports several native black elderberry trees with combined trunk diameters that exceed 8 inches, and lemon-scented gum trees in a public right-of-way, which may be regulated by Chapter 12.52 of the City Code of Redlands. If any of these trees would be removed during development of the project, the applicant shall be required to obtain a tree removal permit from the City of Redlands prior to their removal. As part of the application for a removal permit and as mitigation to reduce potential impacts to less than significant, the project applicant shall provide a report prepared by a certified arborist that determines which trees present on-site would be protected under the City Code and provides recommendations for their removal and replacement.

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Appendix A:

Professional Qualifications
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Email: [email protected]
Mobile: 314-805-5566

EDUCATION
B.S., Physics and Astronomy,
University of Rochester, 2022
B.A., Religious Studies, University
of Rochester, 2022
SKILLS
-Scientific collection and
management of field data
-Technical Writing
-Python for data analysis
and data visualization
-Experimental conception
and design
-Grant writing and
coordination of award
usage
Lucas South

BIOLOGIST
Lucas South is a current environmental professional and recent graduate from the University of Rochester, with a Bachelor of Science in Astrophysics. During their degree they gained extensive lab experience in experimental data collection and technical writing (3 years), winning 3 grants for their work in granular physics. More recently they have endeavored to apply their skills to the area of biological monitoring and conservation. They have experience in avian biological monitoring for a major environmental consulting firm during which they conducted field biological research in the Midwestern region. Most recently, Lucas has spent time collecting field data on mortalities of avian and bat species at wind energy farms.

Mr. South’s educational background in physics and planetary science has led to an interest in researching more on environmental impacts on earth, especially in the context of continuing climate change. Their professional experience in biological monitoring has created a specific interest in avian species. They also seek to apply skills of data analytical techniques with Python and technical writing toward facilitating different research projects centered around the conservation of critical natural resources.

EXPERTISE
• Biological Monitoring. Mr. South has experience monitoring utilities and energy farms for living and deceased avian species. • Bird and Bat Identification. Mr. South has experience in identifying migratory and resident bird and bat species throughout the Midwestern region, including identification of endangered species. • Data Acquisition. Mr. South has experience with data acquisition systems that utilize GIS, as well as laboratory data management systems. • Data Management and Analysis. Mr. South has significant expertise in conducting statistical analyses on data through the Python programming language, including the creation and usage of large data structures.
• Scientific Writing. Mr. South has expertise in writing scientific reports, presentations, and grant proposals, having contributed to 3 journal publications, and acquired 3 grants.

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Lucas South Resume, Page 2

SELECT PROJECT EXPERIENCE
MidAmerican Wind Project WEST (2022) - As a Biological Field Technician for Western EcoSystems Technology Inc., Lucas’s responsibilities were to provide quality data collection and to support their technician team. Duties included:
• Conducting biological monitoring and research on avian species and bats, both migratory and resident • Maintaining strict data quality requirements while utilizing specialized field GIS equipment • Conducting searcher efficiency and carcass persistence tests • Coordinating with a team of avian biologists to confirm identifications and manage endangered species find responses
• Effectively communicating and coordinating with field team and wind farm managers to maintain field safety standards
Lead Research Assistant, Asteroid Environments Laboratory (2019-2022) - As a project leader in Dr. Quillen’s astrophysics laboratory at the University of Rochester, Lucas’s responsibilities were to design data taking procedures and strategically implement grant funding. Duties included:
• Creating scientific reports and presentations to communicate results of laboratory experiments • Writing grant proposals and managing acquired funding to complete experimental goals while working with 8-10 collaborators
• Designing physics experiments that utilized an accelerometer array to obtain 150+ data sets • Analyzing physical data using the Python language and creating data visualization tools, as well as creating theoretical models for data comparison
Publications
• Boulder Stranding in Ejecta Launched by an Impact Generated Seismic Pulse, Wright, E., Quillen, A. C., South, L., Nelson, R. C., Sánchez, P., Martini, L., Schwartz, S. R., Nakajima, M., Asphaug, E., 2020, Icarus, 337, 113424.
• Ricochets on Asteroids: Experimental Study of Low Velocity Impacts into Granular Media, Wright, E., Quillen, A. C., South, L., Nelson, R. C., Sánchez, P., Siu, J., Askari, H., Nakajima, M., Schwartz, S. R., 2020, Icarus, 351, 113963.
• Propagation and Attenuation of Pulses Driven by Low Velocity Normal Impacts in Granular Media, Quillen, A. C., Neiderbach, M., Suo, B., South, L., Wright, E., Skerrett, N., Sánchez, P., Cúñez, F. D., Miklavcic, P., Askari, H., 2022, Icarus, 115139.

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Email: [email protected]
Mobile: 303-818-3632

EDUCATION
B.S., Wildlife Ecology, University
of Wisconsin-Madison, 2004

CERTIFICATIONS
Certified Wildlife Biologist, The
Wildlife Society 2014
ISA Certified Arborist (WE12564A) 2019
Certified Technical Service
Provider (TSP) for Fish and
Wildlife Management Plans,
USDA NRCS 2017
Authorized Desert Tortoise
Biologist – Numerous BOs
Unmanned Aircraft System Pilot
Certification, FAA #4177603

TRAINING
Wetland Delineation Training
Course – The Wetland Institute
(2014)
Southwest Willow Flycatcher
Workshop, 2017
USGS Desert Tortoise Health
Assessment and Tissue
Collection Techniques Training,
2009
Matthew South

PRINCIPAL BIOLOGIST
Matthew South founded South Environmental in 2018. He is a certified wildlife biologist and certified arborist with 17 years of professional experience providing natural resources consulting services for a wide variety of clients that include residential, commercial, government, utility, infrastructure, research, and non-profit projects. For the last 13 years, Mr. South has been an environmental consultant in southern California acting as a Wildlife Biologist and Geographic Information System (GIS) Analyst. In early 2018 he started South Environmental and has since been supporting clients in Los Angeles, San Bernardino, and Riverside Counties.

Mr. South’s background in ecology has led to a passion for conservation planning and resources assessments for the purpose of preservation and management. The integration of the latest technologies such as advanced GIS systems, mobile computing, and drone sensing allows him to innovate new data collection, analysis, and collaboration tools for the environmental sciences that produce more accurate data and better-informed resource managers.

EXPERTISE
• Conservation and Management Planning. Mr. South’s has extensive experience preparing mitigation and monitoring plans, habitat conservation plans, and technical biological resources management plans that are compliant with federal, state, and local regulations. Mr.

South is the only active NRCS TSP for Fish and Wildlife Plans Certified in California.
• Biological Resources Assessment. Mr. South has completed dozens of biological resources assessments throughout southern California. • Rare Plants and Arborist Services. Mr. South has surveyed and assessed thousands of native and landscaped trees in southern California. He is a certified arborist with 5-years of tree survey experience working closely with some of the most experienced arborists in California. In addition, he has performed hundreds of hours of rare plant surveys and habitat assessments.
• Wetland & Jurisdictional Delineations. Mr. South has conducted dozens of jurisdictional and wetland delineations per the guidelines and methods from the US Army Corps of Engineers (USACE), California Department of Fish and Wildlife (CDFW), and the state Regional Water Quality Control Boards (RWQCB).
• GIS. Mr. South is an expert at spatial data collection and analysis using ESRI mobile and desktop software products and Trimble hardware.

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Matthew South Resume, Page 2

SELECT PROJECT EXPERIENCE
Southern California Edison (SCE) As-Needed Natural and Cultural Resources Services (2021-ongoing).

As a subconsultant on this contract for multiple Primes (SWCA, EI, Rincon, Cardno, and ERM), South Environmental has focused its biological resources services on wetland delineations and permitting efforts for SCE throughout all its regions. From single pole delineations in roadside ditches to several hundred poles through miles of wet meadows in the Sierras, the projects vary in size and complexity as well as location.

Primarily, delineations have been in the Sierras with the largest and most complex projects in Inyo and Mono Counties and several in Kern and Tulare. A few of the specific projects include • Pickle Meadow: Aquatic Resources Delineation Report and Permitting for 300-poles located in a wet meadow behind Bridgeport Reservoir.
• Kern River: Wetland Delineation and Permitting for 15 pole replacements in Kernville. • June Lake to Tom’s Place: Wetland Delineation and Permitting for 40 poles spread through Inyo and Mono Counties.
• Cajon Wash: Jurisdictional Delineation and SBKR Assessment and Permitting for 10 pole replacements and realignment for a capital project located in SBKR Critical Habitat. • Pipes Wash: Delineation and Permitting for 25-poles that are within Pipes Wash, a large ephemeral wash in the San Bernardino desert.

Southern California Gas (SCG) As-Needed Natural and Cultural Resources Services (2022-ongoing). As a subconsultant on this contract Mr. South has overseen the assessment numerous resources from single point locations to many miles of pipelines. More recently he has begun to conduct biological assessment in the coastal zone in Santa Barbara County as well as endangered species Biological Assessments (BAs) in support of Coastal Development Permits for SCG. Wetland delineation and permitting, biological resources assessments, and resources surveys and monitoring are services that Mr. South both provides personally and oversees a team of specialists that support the environmental impacts analysis and permitting for SCG.

California Department of Water Resources (DWR) As-Needed Environmental Compliance Services (2012-2018). As part of this contract while employed at another firm, Mr. South prepared conservation and biological resources planning documents as well as oversaw the implementation and compliance components of these documents. Most notably, Mr. South was the lead avian biologist for the billion-dollar Perris Dam Remediation Project where he prepared Avian Protection and Avoidance Plan, Feral Hog Management Plan, negotiated environmental mitigation and compensation with both the USFWS and CDFW biologists, conducted protocol surveys for endangered species such as least Bell’s vireo, and oversaw the compliance monitoring efforts for the entire 5-years of project construction.

Los Angeles County Flood Control District and Department of Public Works As-Needed Environmental Compliance Services (2014-2018). As part of this contract while employed at another firm, Mr. South conducted dozens of biological resources assessments, focused surveys for special-status species, and monitored compliance for a wide variety of water infrastructure project. Notably, Mr. South was the lead biologist for the Eaton Dam Maintenance Projects and for a variety of vegetation management programs within sensitive waterways.

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Biological Resources Assessment
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Appendix B:

Site Photographs
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Photograph 1: View of site entrance via the gate on Pioneer Avenue.

Photograph 2: View of recently tilled soil and chain-link fence of site adjacent to Pioneer Avenue.

MLC Holdings, Inc. – Song and Emm Properties Project
Biological Resources Assessment Appendix B
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Photograph 3: View of utility poles and chain-link fence on the site adjacent to Highway 210.

Photograph 4: Untilled strip of land containing ruderal plants and forbs.

MLC Holdings, Inc. – Song and Emm Properties Project
Biological Resources Assessment Appendix B
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Photograph 5: Interior of the parcel featuring tilled soil and elderberry plants.

Photograph 6: Interior of the parcel featuring an out of use asphalt road.

MLC Holdings, Inc. – Song and Emm Properties Project
Biological Resources Assessment Appendix B
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Photograph 7: Small tract of untilled land on the northeast side of the parcel, supporting several burrows.

Photograph 8: An example of a burrow in the parcel, too large for SBKR and active with California ground squirrel activity.

MLC Holdings, Inc. – Song and Emm Properties Project
Biological Resources Assessment Appendix B
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Biological Resources Assessment
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Appendix C:

Special-status Species Tables
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Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Table 1: Special–status Plant Species Evaluated
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Dicots
Abronia villosa var. aurita
chaparral sand–verbena
— — 1B.1 Annual herb found in chaparral, coastal scrub, and desert dunes in sandy habitats.

Elevation: 75–1600 m
Bloom period: March–September
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Acanthoscyphus parishii var. parishii
Parish's oxytheca
— — 4.2 Annual herb found chaparral and lower montane
coniferous forest. Can grow in gravelly or sandy places.

Elevation: 1220–2600 m
Bloom period: June–September
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Ambrosia pumila
San Diego Ambrosia
— — 1B.1 Perennial rhizomatous herb found in chaparral, coastal scrub, valley and foothill grassland, vernal pools.

Elevation: 20–415 m
Bloom period: April–October
None. Suitable habitat for this species is not present
on or adjacent to the project site, and the soils on the project site have been subjected to numerous
disturbances that would prevent its occurrence.

Androsace elongata ssp. acuta
California androsace
— — 4.2 Annual herb that occurs in chaparral, cismontane woodland, coastal scrub, meadows and seeps, pinyon and
juniper woodland, and valley and foothill grassland.

Elevation: 150–1305 m
Bloom period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Arenaria paludicola
marsh sandwort
FE SE 1B.1 Perennial stoloniferous herb found in marshes and swamps (freshwater or brackish).

Elevation: 3–170 m
Bloom period: May–August
None. There is no suitable habitat for this species on
the project site. There is one historical record within 5 miles of the project site.

Artemisia palmeri
San Diego sagewort
— — 4.2 Annual herb found chaparral, cismontane woodland, coastal scrub, meadows and seeps, pinyon and juniper
woodland, and valley and foothill grassland.

Elevation: 150–1305 m
Bloom period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Astragalus hornii var. hornii
Horn’s milk–vetch
— — 1B.1 Occurs on salty flats, alkali sinks, lake shores, and riparian habitats.

Elevation: 60–300 m
Blooming period: May–October
None. Project site is outside of the known elevational
range of the species, and there is no suitable habitat
on the project site. There is one historical record
within 5 miles of the project site.

Redlands Regular meeting of 12-19-23 954 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Astragalus pachypus var. jaegeri
Jaeger's milk–vetch
— — 1B.1 Perennial shrub found in chaparral, cismontane woodland, coastal scrub, and valley and foothill grassland. Can grow in rocky or sandy places.

Elevation: 365–975 m
Bloom period: December–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Atriplex coronata var. notatior
San Jacinto Valley crownscale
FE — 1B.1 Annual herb found in playas, valley and foothill grassland, and vernal pools in alkaline soils.

Elevation: 139–500 m
Bloom period: April–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Atriplex serenana var. davidsonii
Davidson's saltscale
— — 1B.2 Annual herb found in coastal bluff scrub and coastal scrub in alkaline soils.

Elevation: 10–200 m
Bloom period: April–October
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Berberis nevinii
Nevin’s barberry
FE SE 1B.1 Occurs on steep, north–facing slopes or in low grade sandy washes in chaparral, cismontane woodland, coastal sage and Riversidean alluvial fan sage scrub, and riparian scrub habitats.

Elevation: 290–1575 m
Blooming period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site. There are one
recent and two historical records within 5 miles of the project site, and one historical record between 5 and
10 miles from the project site.

Castilleja cinerea
ash–gray paintbrush
FT — 1B.2 Perennial herb found in Mojavean desert scrub, meadows and seeps, pebble plain, pinyon and juniper woodland,
and upper montane coniferous forest.

Elevation: 1800–2960 m
Bloom period: June–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Castilleja lasiorhyncha
San Bernardino Mountains owl's–
clover
— — 1B.2 Annual herb found in chaparral, meadows and seeps, pebble plain, riparian woodland, and upper montane
coniferous forest in mesic soils.

Elevation: 1300–2390 m
Bloom period: May–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Castilleja montigena
Heckard's paintbrush
— — 4.3 Perennial herb found in lower montane coniferous forest, pinyon and juniper woodland, and upper montane
coniferous forest.

Elevation: 1950–2800 m
Bloom period: May–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Redlands Regular meeting of 12-19-23 955 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Caulanthus simulans
Payson's jewelflower
— — 4.2 Annual herb found in chaparral and coastal scrub. Prefers granitic and sandy places.

Elevation: 90–2200 m
Bloom period: March–May
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Centromadia pungens ssp. laevis
Smooth tarplant
— — 1B.1 Occurs in alkali meadow, alkali scrub, and disturbed places in valley and foothill grassland, chenopod scrub,
meadows, playas, and riparian woodland habitats.

Elevation: 0–640 m
Bloom period: April–September
None. Suitable habitat for this species is not present
on or adjacent to the project site. There are three
recent and two historical records within 5 miles of the project site, and two recent and two historical records between 5 and 10 miles from the project site.

Chloropyron maritimum ssp.
maritimum
Salt marsh bird’s–beak
FE SE 1B.2 Occurs in coastal salt marsh.

Elevation: < 10 m
Blooming period: May–October
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record within 5 miles of the project site.

Chorizanthe leptotheca
Peninsular spineflower
— — 4.2 Annual herb found chaparral, coastal scrub, and lower montane coniferous forest. Prefers granitic places.

Elevation: 300–1900 m
Bloom period: May–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Chorizanthe parryi var. parryi
Parry’s spineflower
— — 1B.1 Occurs on sandy soils in chaparral, coastal sage and Riversidean alluvial fan sage scrub habitats.

Elevation: 275–1220 m
Blooming period: April–June
None. Suitable habitat for this species is not present
on or adjacent to the project site, and the soils on the Project site have been subjected to numerous
disturbances that would prevent its occurrence. There
are five recent and six historical records within 5 miles of the project site, and five recent and four historical records between 5 and 10 miles from the project site.

Chorizanthe xanti var. leucotheca
white–bracted spineflower
— — 1B.2 Mojavean desert scrub, pinyon and juniper woodland, coastal scrub. Often grows on sandy or gravelly places
such as alluvial fans.

Elevation: 365–1830 m.

Blooming period: April – June
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one recent record between 5 and 10 miles from the project site.

Convolvulus simulans
small–flowered morning–glory
— — 4.2 Annual herb found in chaparral, coastal scrub, and valley and foothill grassland. Prefers clay, seeps, and
serpentinite.

Elevation: 30–740 m
Bloom period: March–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Redlands Regular meeting of 12-19-23 956 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Cuscuta obtusiflora var. glandulosa
Peruvian dodder
— — 2B.2 Occurs on herbs including Alternanthera, Dalea, Lythrum, Polygonum, Xanthium.

Elevation: +– < 500 m
Blooming period: July–October
None. Suitable habitat and hosts for this species are
not present on or adjacent to the project site. There is one historical record within 5 miles of the project site.

Deinandra paniculata
paniculate tarplant
— — 4.2 Annual herb found in coastal scrub, valley and foothill grassland, and vernal pools. Prefers vernally mesic soil, but can be found in sandy places.

Elevation: 25–940 m
Bloom period: April–November
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Diplacus clevelandii
Cleveland's bush monkeyflower
— — 4.2 Perennial rhizomatous herb found in chaparral,
cismontane woodland, and lower montane coniferous
forest. Tends to grow in disturbed areas, as well as
gabbroic places, openings, and rocky places.

Elevation: 450–2000 m
Bloom period: April–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Dodecahema leptoceras
slender–horned spineflower
FE SE 1B.1 Chaparral, cismontane woodland, coastal scrub (alluvial fan sage scrub). Flood deposited terraces and washes;
associates include Encelia, Dalea, Lepidospartum, etc.

Sandy soils.

Elevation: 200–765 m.

Blooming period: April–May
None. Suitable habitat for this species is not present
on or adjacent to the project site, and the soils on the Project site have been subjected to numerous
disturbances that would prevent its occurrence. There
are one recent (in 2021) and five historical records
within 5 miles of the project site, and three historical records between 5 and 10 miles from the project site.

Eriastrum densifolium ssp.
sanctorum
Santa Ana River woollystar
FE SE 1B.1 Occurs on sandy soils on river floodplains or terraced fluvial deposits in chaparral and coastal sage and
Riversidean alluvial fan sage scrub habitats.

Elevation: 180–700 m
Blooming period: May–September
None. Suitable habitat for this species is not present
on or adjacent to the project site, and the soils on the Project site have been subjected to numerous
disturbances that would prevent its occurrence. There
are five recent (most recently in 2021) and three
historical records within 5 miles of the project site, and eight recent and three historical records between 5
and 10 miles from the project site.

Eriophyllum lanatum var. obovatum
southern Sierra woolly sunflower
— — 4.3 Perennial herb found in lower montane coniferous forest and upper montane coniferous forest. Prefers loam and
sandy places.

Elevation: 1114–2500 m
Bloom period: Jun–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Redlands Regular meeting of 12-19-23 957 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Erythranthe exigua
San Bernardino Mountains
monkeyflower
— — 1B.2 Annual herb found in meadows and seeps, pebble plain, and upper montane coniferous forest. Prefers clay and
mesic soils.

Elevation: 1800–2315 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Frasera neglecta
pine green–gentian
— — 4.3 Perennial herb found in lower montane coniferous forest, pinyon and juniper woodland, and upper montane
coniferous forest.

Elevation: 1400–2500 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Galium californicum ssp. primum
Alvin Meadow bedstraw
— — 1B.2 Perennial herb chaparral lower montane coniferous forest.

Elevation: 1350–1700 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record within 5 miles of the project site.

Galium johnstonii
Johnston's bedstraw
— — 4.3 Perennial herb found in chaparral, lower montane coniferous forest, pinyon and juniper woodland, and
riparian woodland.

Elevation: 1220–2300 m
Bloom period: Jun–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Helianthus nuttallii ssp. parishii
Los Angeles sunflower
— — 1A Dicot perennial (rhizomatous) herb found in marshes and swamps, including coastal salt and freshwater marshes.

Elevation: 10–1,675 m.

Bloom period: August–October
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record between 5 and 10 miles from the
project site.

Heuchera caespitosa
urn–flowered alumroot
— — 4.3 Perennial rhizomatous herb found in cismontane
woodland, lower montane coniferous forest, riparian
forest (montane), and upper montane coniferous forest.

Prefers rocky habitat.

Elevation: 1155–2650 m
Bloom period: May–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Heuchera parishii
Parish's alumroot
— — 1B.3 Perennial rhizomatous herb found in alpine boulder and rock field, lower montane coniferous forest, subalpine
coniferous forest, and upper montane coniferous forest.

Can grow on carbonate, but prefers rocky habitat.

Elevation: 1500–3800 m
Bloom period: June–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Redlands Regular meeting of 12-19-23 958 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Horkelia cuneata var. puberula
mesa horkelia
— — 1B.1 Perennial herb found in chaparral, coastal scrub, and cismontane woodlands.

Elevation: 70–810 m.

Bloom period: February–July
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record between 5 and 10 miles from the
project site.

Hulsea vestita ssp. parryi
Parry's sunflower
— — 4.3 Perennial herb found in lower montane coniferous forest, pinyon and juniper woodland, and upper montane
coniferous forest.

Elevation: 1370–2895 m
Bloom period: April–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Ivesia argyrocoma var. argyrocoma
silver–haired ivesia
— — 1B.2 Perennial herb found in meadows and seeps in alkaline soils, pebble plain, and upper montane coniferous forest.

Elevation: 1463–2960 m
Bloom period: June–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Juglans californica
Southern California black walnut
— — 4.2 Perennial deciduous tree found in chaparral, cismontane woodland, coastal scrub, and riparian woodland.

Elevation: 50–900 m
Bloom period: March–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Lasthenia glabrata ssp. coulteri
Coulter's goldfields
— — 1B.1 Annual herb found in marshes and swamps, playas, and vernal pools.

Elevation: 1–1220 m
Bloom period: February–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Lepidium virginicum var. robinsonii
Robinson’s pepper–grass
— — 4.3 Occurs on dry soils in chaparral and coastal sage and Riversidean alluvial fan sage scrub habitats.

Elevation: 1–855 m
Blooming period: January–July
None. Suitable habitat for this species is not present
on or adjacent to the project site, and the soils on the Project site have been subjected to numerous
disturbances that would prevent its occurrence. There
are two historical records within 5 miles of the project site, and four historical records between 5 and 10
miles from the project site.

Lycium parishii
Parish's desert–thorn
— — 2B.3 Perennial shrub found in coastal scrub and Sonoran Desert scrub.

Elevation: 135–1,000 m.

Blooming period: March–April
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record between 5 and 10 miles from the
project site.

Redlands Regular meeting of 12-19-23 959 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Malacothamnus parishii
Parish’s bush–mallow
— — 1A The one record for this species is in an area that is now developed and urbanized, but it likely supported
Riversidean alluvial fan sage scrub habitat at the time of observation in 1895.

None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record within 5 miles of the project site.

Monardella macrantha ssp. hallii
Hall's monardella
— — 1B.3 Perennial rhizomatous herb found broadleafed upland forest, chaparral, cismontane woodland, lower montane
coniferous forest, and valley and foothill grassland.

Elevation: 730–2195 m
Blooming period: June–October
None. Suitable habitat for this species is not present
on or adjacent to the project site. There are one
recent and two historical records between 5 and 10
miles from the project site.

Monardella pringlei
Pringle's monardella
— — 1A Annual herb found in sandy soils in coastal scrub.

Elevation: 300–400 m.

Bloom period: May–June
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record between 5 and 10 miles from the
project site.

Nama stenocarpa
mud nama
— — 2B.2 Annual/perennial herb found in marshes and swamps.

Elevation: 5–500 m
Bloom period: January–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Nasturtium gambelii
Gambel’s water cress
FE ST 1B.1 Occurs in freshwater and brackish marshes and at the margins of lakes and along streams in or just above the water level.

Elevation: 5–330 m
Blooming period: April–October
None. Project site is outside of the known elevational
range of the species, and there is no suitable habitat
on or adjacent to the project site. There is one
historical record within 5 miles of the project site.

Packera bernardina
San Bernardino ragwort
— — 1B.2 Perennial herb found in meadows and seeps in mesic or alkaline soils, pebble plain, and upper montane coniferous forest.

Elevation: 1800–2300 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Perideridia parishii ssp. parishii
Parish's yampah
— — 2B.2 Perennial herb found in lower montane coniferous forest, meadows and seeps, and upper montane coniferous
forest.

Elevation: 1465–3000 m
Blooming period: June–August
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record between 5 and 10 miles from the
project site.

Redlands Regular meeting of 12-19-23 960 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Phacelia mohavensis
Mojave phacelia
— — 4.3 Annual herb found in cismontane woodland, lower montane coniferous forest, meadows and seeps, and
pinyon and juniper woodland. Can grow in gravelly and
sandy soils.

Elevation: 1400–2500 m
Bloom period: April–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Phacelia stellaris
Brand's star phacelia
— — 1B.1 Annual herb found in coastal dunes and coastal scrub.

Elevation: 1–400 m
Bloom period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Pseudorontium cyathiferum
Deep Canyon snapdragon
— — 2B.3 Annual herb found in Sonoran desert scrub in rocky places.

Elevation: 0–800 m
Bloom period: February–April
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Quercus engelmannii
Engelmann oak
— — 4.2 Perennial deciduous tree found in chaparral, cismontane woodland, riparian woodland, and valley and foothill
grassland.

Elevation: 50–1300 m
Bloom period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Ribes divaricatum var. parishii
Parish’s gooseberry
— — 1A Occurs in moist or riparian woodland habitat.

Elevation: 60–310 m
Blooming period: February–April
None. Project site is outside of the known elevational
range of the species, and there is no suitable habitat
on or adjacent to the project site. There is one
historical record within 5 miles of the project site.

Romneya coulteri
Coulter's matilija poppy
— — 4.2 Perennial rhizomatous herb found in chaparral and coastal scrub, often in burned areas.

Elevation: 20–1200 m
Bloom period: March–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Rupertia rigida
Parish's rupertia
— — 4.3 Perennial herb found in chaparral, cismontane woodland, lower montane coniferous forest, meadows and seeps,
pebble plain, and valley and foothill grassland.

Elevation: 700–2500 m
Bloom period: June–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Redlands Regular meeting of 12-19-23 961 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Senecio aphanactis
chaparral ragwort
— — 2B.2 Annual herb found in drying alkaline flats in chaparral, cismontane woodland, and coastal scrub.

Elevation: 15–800 m.

Bloom period: January–April
None. Suitable habitat for this species is not present
on or adjacent to the project site. There two recent
records between 5 and 10 miles from the project site.

Senecio astephanus
San Gabriel ragwort
— — 4.3 Perennial herb found in coastal bluff scrub and chaparral.

Prefers rocky places and slopes.

Elevation: 400–1500 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Sidalcea hickmanii ssp. parishii
Parish's checkerbloom
— CR 1B.2 Perennial herb found in chaparral, cismontane woodland, and lower montane coniferous forest.

Elevation: 1000–2499 m
Blooming period: June–August
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record between 5 and 10 miles from the
project site.

Sidalcea malviflora ssp. dolosa
Bear Valley checkerbloom
— — 1B.2 Occurs in meadows and seeps in lower montane
coniferous forest, riparian woodland, and upper montane coniferous forest habitats.

Elevation: 1500–2300 m
Blooming period: May–August
None. Project site is outside of the known elevational
range of the species, and there is no suitable habitat
on or adjacent to the project site. There is one
historical record within 5 miles of the project site.

Sidalcea neomexicana
Salt spring checkerbloom
— — 2B.2 Occurs in alkaline springs and marshes.

Elevation: < 1500 m
Blooming period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site. There are two
historical records within 5 miles of the project site.

Sidalcea pedata
bird–foot checkerbloom
FE CE 1B.1 Perennial herb found in meadows and seeps and pebble plains.

Elevation: 1600–2500 m
Blooming period: May–August
None. Suitable habitat for this species is not present
on or adjacent to the project site. There is one
historical record between 5 and 10 miles from the
project site.

Sidotheca caryophylloides
chickweed oxytheca
— — 4.3 Annual herb found in lower montane coniferous forest in sandy places.

Elevation: 1114–2600 m
Bloom period: July–September
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Streptanthus bernardinus
Laguna Mountains jewelflower
— — 4.3 Perennial herb found in chaparral and lower montane coniferous forest.

Elevation: 670–2500 m
Bloom period: May–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Redlands Regular meeting of 12-19-23 962 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Streptanthus campestris
southern jewelflower
— — 1B.3 Perennial herb found in chaparral, lower montane forest, and pinyon and juniper woodland. Prefers rocky places.

Elevation: 900–2300 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Symphyotrichum defoliatum
San Bernardino aster
— — 1B.2 Perennial, rhizomatous herb found in banks of ditches, streams, and springs in cismontane woodlands, coastal
scrub, lower montane coniferous forests, meadows and
seeps, marshes and swamps, and vernally mesic valley and foothill grasslands.

Elevation: 2–2,040 m.

Bloom period: July–November
None. Suitable habitat for this species is not present
on or adjacent to the project site. There are three
historical records between 5 and 10 miles from the
project site.

Trichocoronis wrightii var. wrightii
Wright's trichocoronis
— — 2B.1 Annual herb found meadows and seeps, marshes and swamps, riparian forest, and vernal pools. Prefers alkaline soils.

Elevation: 5–435 m
Bloom period: May–September
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Ferns
Asplenium vespertinum
western spleenwort
— — 4.2 Perennial rhizomatous herb found in chaparral,
cismontane woodland, and coastal scrub in rocky habitats.

Elevation: 180–1000 m.

Bloom period: February–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Pelazoneuron puberulum var.
sonorensis
Sonoran maiden fern
— — 2B.2 Perennial rhizomatous herb found in meadows and seeps.

Elevation: 50–610 m
Bloom period: January–September
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Monocots
Allium howellii var. clokeyi
Mt. Pinos onion
— — 1B.3 Perennial bulbiferous herb found in great basin scrub, meadows and seeps, and pinyon and juniper woodland.

Elevation: 1300–1850 m
Bloom period: April–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Allium marvinii
Yucaipa onion
— — 1B.2 Perennial bulbiferous herb found in chaparral in clay and in openings.

Elevation: 760–1065 m
Bloom period: April–May
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Redlands Regular meeting of 12-19-23 963 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Bouteloua trifida
three–awned grama
— — 2B.3 Perennial herb found in Mojavean desert scrub on carbonate and rocky places.

Elevation: 700–2000 m
Bloom period: May–September
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Brodiaea filifolia
thread–leaved brodiaea
FT SE 1B.1 Perennial herb (bulb) that occurs in openings on clay soils in chaparral, cismontane woodland, coastal scrub, playas, valley and foothill grasslands, and vernal pool habitats.

Elevation: 15–1020 m
Bloom period: March–June
None. Suitable habitat for this species is not present
within the project site. There are two recent records
between 5 and 10 miles from the project site.

Calochortus catalinae
Catalina mariposa lily
— — 4.2 Perennial bulbiferous herb found in chaparral, cismontane woodland, coastal scrub, and valley and foothill grassland.

Elevation: 15–700 m
Bloom period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Calochortus palmeri var. palmeri
Palmer's mariposa–lily
— — 1B.2 Perennial bulbiferous herb found in chaparral, lower montane coniferous forest, and meadows and seeps.

Prefers mesic soils.

Elevation: 710–2390 m
Bloom period: April–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Calochortus plummerae
Plummer’s mariposa–lily
— — 4.2 Occurs on rocky and sandy sites, usually of granitic alluvial material, in coastal sage and Riversidean alluvial fan sage scrub, chaparral, valley and foothill grassland, cismontane woodland, and lower montane coniferous forest habitats.

Can be very common after fire.

Elevation: 100–1700 m
Bloom period: May–July
None. Suitable habitat for this species is not present
within the project site, and the soils on the project site have been subjected to numerous disturbances that
would prevent its occurrence. There are two historical
records within 5 miles of the project site, and eight
recent and four historical records between 5 and 10
miles from the project site.

Calochortus simulans
La Panza mariposa–lily
— — 1B.3 Perennial bulbiferous herb found in chaparral, cismontane woodland, lower montane coniferous forest, and valley
and foothill grassland. Prefers granitic and sandy soils but can grow on serpentinite.

Elevation: 325–1150 m
Bloom period: April–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

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FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Carex comosa
bristly sedge
— — 2B.1 Perennial, rhizomatous herb found in coastal prairie, lake margins of marshes and swamps, and valley and foothill
grasslands.

Elevation: 0–625 m.

Bloom period: May–September
None. Suitable habitat for this species is not present
within the project site. There is one historical record between 5 and 10 miles from the project site.

Fimbristylis thermalis
hot springs fimbristylis
— — 2B.2 Perennial rhizomatous herb found in meadows and seeps.

Elevation: 110–1340 m
Bloom period: July–September
None. Suitable habitat for this species is not present
within the project site. There is one recent record
between 5 and 10 miles from the project site.

Fritillaria pinetorum
pine fritillary
— — 4.3 Perennial bulbiferous herb found in chaparral, lower montane coniferous forest, pinyon and juniper woodland, subalpine coniferous forest, and upper montane
coniferous forest. Can grow in granitic and metamorphic soils.

Elevation: 1735–3300 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Hordeum intercedens
vernal barley
— — 3.2 Annual herb found in coastal dunes, coastal scrub, valley and foothill grassland in depressions and saline flats, and vernal pools.

Elevation: 5–1000 m
Bloom period: March–June
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Imperata brevifolia
California satintail
— — 2B.1 Occurs in wet springs, meadows, streambanks, and floodplains
Elevation: < 500 m
Bloom period: September–May
None. Suitable habitat for this species is not present
within the project site. There are one recent and one
historical record within 5 miles of the project site.

Juncus duranii
Duran's rush
— — 4.3 Perennial rhizomatous herb found in lower montane coniferous forest, meadows and seeps, and upper
montane coniferous forest. Prefers mesic soils.

Elevation: 1768–2804 m
Bloom period: July–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Lilium humboldtii ssp. ocellatum
ocellated Humboldt lily
— — 4.2 Perennial bulbiferous herb found in chaparral, cismontane woodland, coastal scrub, lower montane coniferous
forest, and riparian woodland. Prefers openings.

Elevation: 30–1800 m
Bloom period: March–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

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Biological Constrainst Analysis Appendix C
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Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Lilium parryi
lemon lily
— — 1B.2 Perennial bulbiferous herb found in lower montane coniferous forest, meadows and seeps, riparian forest,
and upper montane coniferous forest. Prefers mesic soils.

Elevation: 1220–2745 m
Bloom period: July–August
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Muhlenbergia californica
California muhly
— — 4.3 Perennial rhizomatous herb found in chaparral, coastal scrub, lower montane coniferous forest, and meadows
and seeps. Prefers mesic soils, seeps, and streambanks.

Elevation: 100–2000 m
Bloom period: June–September
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Muilla coronata
crowned muilla
— — 4.2 Perennial bulbiferous herb found in chenopod scrub, Joshua tree woodland, Mojavean desert scrub, and Pinyon and juniper woodland.

Elevation: 670–1960 m
Bloom period: March–April
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Piperia leptopetala
narrow–petaled rein orchid
— — 4.3 Perennial herb found in cismontane woodland, lower montane coniferous forest, and upper montane
coniferous forest.

Elevation: 380–2225 m
Bloom period: May–July
None. Suitable habitat for this species is not present
on or adjacent to the project site.

Schoenus nigricans
black bog–rush
— — 2B.2 Perennial herb found in marshes and swamps.

Elevation: 150–2000 m
Bloom period: August–September
None. Suitable habitat for this species is not present
within the project site. There is one recent record
between 5 and 10 miles from the project site.

Sphenopholis obtusata
Prairie wedge grass
— — 2B.2 Occurs in wet meadows, streambanks, and ponds.

Elevation: 240–2870 m
Blooming period: April–June
None. Suitable habitat for this species is not present
within the project site. There is one historical record within 5 miles of the project site.

Yucca brevifolia
Joshua tree
— — — Fine, loose, well drained, and/or gravelly soils in Mojavean desert scrub and pinyon and juniper woodland.

Elevation: 400–1800 meters
Blooming period: February–April
None. Suitable habitat for this species is not present
on or adjacent to the project site.

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Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description4 USFWS Potential to Occur and Rationale 1 CDFW2 CNPS3
Code Designations
1 Federal Status: 2020 USFWS Listing 2 State Status: 2020 CDFW Listing 3 CNPS: 2020 CNPS Listing ESU = Evolutionary Significant Unit is a distinctive population.

FE = Listed as endangered under the FESA.

FT = Listed as threatened under the FESA.

FC = Candidate for listing (threatened or endangered) under FESA.

FD = Delisted in accordance with the FESA.

FPD = Federally Proposed to be Delisted.

MBTA = protected by the Migratory Bird Treaty Act
— = Not federally listed
SE = Listed as endangered under the CESA.

ST = Listed as threatened under the CESA.

SSC = Species of Special Concern as identified by the
CDFW.

FP = Listed as fully protected under FGC.

CFG = FGC =protected by FGC 3503.5
CR = Rare in California.
— = Not state listed
Rank 1A = Plants species that presumed extinct in
California.

Rank 1B = Plant species that are rare, threatened, or
endangered in California and elsewhere.

Rank 2 = Plant species that are rare, threatened, or
endangered in California, but more
common elsewhere.

Rank 3 = Plants about which we need more
information—A Review List
Rank 4 = Plants of limited distribution—A Watch
List
Blooming period: Months in parentheses are
uncommon.

Notes:
4 Habitat Description: Habitat description adapted from CNDDB and CNPS online inventory or other specified source. 5 Potential to Occur and Rationale: Location of recorded species occurrences determined by geospatial information from BIOS 5 or other specified source.

Sources:

California Department of Fish and Wildlife (CDFW). 2021. Biogeographic Information and Observation System (BIOS 5). Website: https://map.dfg.ca.gov/bios/. Accessed August 17, 2021.

California Department of Fish and Wildlife (CDFW). 2021. CNDDB RareFind 5 California Natural Diversity Database Query for Special–Status Species. Website:
https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed August 17, 2021, 2021.

California Native Plant Society (CNPS). 2021. California Native Plant Society Rare and Endangered Plant Inventory. Website: http://www.rareplants.cnps.org/. Accessed August 17, 2021.

U.S. Fish and Wildlife Service (USFWS). 2021. Information for Planning and Consultation. Website: https://ecos.fws.gov/ipac/. Accessed August 17, 2021.

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Table 2: Special–status Wildlife Species Evaluated
Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Amphibians
Batrachoseps gabrieli
San Gabriel slender salamander
— — Found under rocks, wood, and fern fronds, and on soil at the base of talus slopes.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site.

Rana draytonii
California red–legged frog
FT —
SSC
Occurs in mesic forests in valleys and foothills near ponds or streams. May also occur in grasslands and coastal sage and Riversidean alluvial fan sage scrub near aquatic habitat. Breeds in permanent or ephemeral water sources, including lakes, ponds, reservoirs, slow streams, marshes, bogs, and swamps.

Near ephemeral wetland habitats, require animal burrows or other moist refuges for estivation when the wetlands are dry.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site.

Rana muscosa
Southern mountain yellow–
legged frog
FE FE
SSC
Occurs in lakes, ponds, meadow streams, isolated pools, and sunny riverbanks in montane habitat at elevations between 370–3,660 m. Prefers clear, deep pools in streams that range from rocky, steep drainages to those with a gentle gradient, marshy margins, and sod banks.

None. Project site is outside of the known elevational range of the species, and there is no suitable habitat on or
adjacent to the project site. There is one historical record within 5 miles of the project site, and two recent and one historical records between 5 and 10 miles from the project site.

Spea hammondii
Western spadefoot
— —
SSC
Occurs in open areas with sandy or gravelly soils in mixed woodlands, grasslands, coastal sage and Riversidean alluvial fan sage scrub, chaparral, sandy washes, lowlands, river floodplains, alluvial fans, playas, alkali flats, foothills, and mountains. Breeds in ephemeral rain pools that do not contain bullfrogs, fish, or crayfish.

Low. Marginally suitable habitat for this species may be present in grassland areas on the project site adjacent to the channelized drainage. There are three recent records within 5 miles of the project site, and nineteen recent and one historical records between 5 and 10 miles from the project site.

Birds
Accipiter cooperii
Cooper’s hawk
—
MBTA
—
WL; FGC
Occurs and nests in deciduous and mixed forests and open woodland habitats. Year–round resident in southern California.

Moderate. There is suitable nesting habitat for this species in the ornamental trees on and adjacent to the project site.

There is one historical record within 5 miles of the project site, and one historical record between 5 and 10 miles from the project site.

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Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Aechmophorus occidentalis
western grebe
—
MBTA
—
FGC
Breeds on freshwater lakes and marshes with extensive open water bordered by emergent vegetation. During winter they move to saltwater or brackish bays, estuaries, or sheltered sea coasts and are less frequently found on freshwater lakes or rivers.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Agelaius tricolor
Tricolored blackbird
—
MTBA
FT
SSC; FGC
Occurs and nests in large freshwater marshes with dense stands of hydrophytic vegetation (cattails, bulrushes, etc.).

Short–distance migrant.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site, and one recent record between 5 and 10 miles from the project site.

Aimophila ruficeps canescens
Southern California rufous–
crowned sparrow
—
MTBA
—
WL; FGC
Occurs and nests on steep, often rocky hillsides with grass and forb patches in coastal sage and Riversidean alluvial fan sage scrub and sparse mixed chaparral habitats. Year–round
resident in southern California.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are five recent records within 5 miles of the project site, and ten recent records between 5 and 10 miles from the project site.

Aquila chrysaetos
golden eagle
BGEPA
MBTA
—
FP; FGC
Forages in areas of rolling foothills, mountainous areas, sage– juniper flats, and desert. Cliff–walled canyons provide nesting habitat in most parts of range; also, large trees in open areas.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site.

Artemisiospiza belli belli
Bell's sage sparrow
—
MBTA
—
WL; FGC
Breeds in coastal sagebrush, chaparral, and other open, scrubby habitats in Southern California mountains, deserts and valleys.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two recent records between 5 and 10 miles from the project site.

Athene cunicularia
Burrowing owl
—
MBTA
—
SSC; FGC
Occurs and nests in open, dry annual or perennial grasslands, deserts, and scrublands characterized by low–growing
vegetation. A subterranean nester, dependent upon burrowing mammals, most notably the California ground squirrel. Short– distance migrant.

Moderate. Suitable nesting habitat for this species is present in the form of California ground squirrel colonies within the project site. There are two known records, from 1983 and 2006, within 5 miles of the project site. Both records are associated with airports. There are two recent records
between 5 and 10 miles from the project site.

Baeolophus inornatus
oak titmouse
—
MBTA
—
FGC
Occurs in warm, open, dry oak or oak–pine woodlands. Many will use scrub oaks or other brush as long as woodlands are nearby. Nests are built in tree cavities.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Buteo regalis
ferruginous hawk
—
MBTA
—
WL; FGC
Grassland and arid shrublands with an abundance of prey species, such as pocket gophers, black–tailed jackrabbits, and desert cottontails. Will winter near cultivated fields that have an abundance of pocket gophers.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one recent record between 5 and 10 miles from the project site.

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Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Buteo swainsoni
Swainson’s hawk
—
MBTA
FT
FGC
Occurs and nests in grasslands with scattered trees, juniper– sage flats, riparian areas, savannahs, and agricultural or ranch lands with groves or lines of trees.

Requires adjacent suitable foraging areas such as grasslands, or alfalfa or grain fields supporting rodent populations. Long– distance migrant.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site. This species is believed to be locally extirpated.

Chamaea fasciata
wrentit
—
MBTA
—
FG
Occurs in chaparral, oak woodlands, and bushland. Nests in 1 m high shrubs.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Coccyzus americanus
occidentalis
Western yellow–billed cuckoo
FT
MTBA
SE
FGC
Occurs and nests in riparian forest along the broad lower flood– bottoms of larger river systems. Found in riparian jungles of willow, often mixed with cottonwoods; understory consists of blackberry, nettles, and wild grape. Long–distance migrant.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site, and one historical record between 5 and 10 miles from the project site.

Contopus cooperi
Olive–sided flycatcher
—
MTBA
—
FGC
Breeds in montane and northern coniferous forests, at forest edges and openings, such as meadows and ponds.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Elanus leucurus
white–tailed kite
—
MTBA
—
FP; FGC
Grasslands and open coastal scrub in coastal and valley lowlands; rarely found away from agricultural areas. Inhabits herbaceous, open stages of most habitats mostly in cismontane California. Year–round resident in southern California.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one recent record between 5 and 10 miles from the project site.

Empidonax traillii extimus
Southwestern willow flycatcher
FE
MTBA
SE
FGC
Occurs and nests in dense riparian woodlands. Long–distance migrant.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site, and one recent record between 5 and 10 miles from the project site.

Eremophila alpestris actia
California horned lark
—
MTBA
—
WL; FGC
Occurs and nests in open areas with sparse vegetation. Year– round resident in southern California.

Moderate. Suitable foraging and nesting habitat for this species in the grassland habitat project site. There is one historical record within 5 miles of the project site.

Falco columbarius
merlin
—
MBTA
—
WL; FGC
Nests in open and semi–open areas such as grasslands, open forests, and coastal areas as well as in towns and cities. Merlins often take over crow nests in conifers planted in residential areas, schoolyards, parks, and cemeteries. Merlins winter across the western and southern United States, along the Pacific Coast up to Alaska, where it typically forages in open habitats supporting natural vegetation communities.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one recent record between 5 and 10 miles from the project site.

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Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Geothlypis trichas sinuosa
common yellowthroat
—
MTBA
—
FGC
Occurs in freshwater and salt marshes with nearby willow thickets. Nests in marshy areas that are usually higher off the ground.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Haliaeetus leucocephalus
bald eagle
FD; BGEPA
MTBA
—
FGC
Breeds and winters in forested areas adjacent to large bodies of water. Nests are usually constructed below the crown of a tree, often the highest point where large branches join the bole of a tree.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Icteria virens
Yellow–breasted chat
—
MTBA
—
SSC; FGC
Occurs and nests in riparian thickets of willow and other bushy tangles near watercourses. Long–distance migrant.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site, and one historical record between 5 and 10 miles from the project site.

Icterus bullockii
Bullock's oriole
—
MTBA
—
FGC
Occurs in riparian corridors, open woodland, and scrub forest.

Nests are usually suspended on the outer branches of a tree.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Lanius ludovicianus
Loggerhead shrike
—
MTBA
—
SSC; FGC
Occurs and nests in broken woodlands, savannah, pinyon– juniper, Joshua tree, and riparian woodlands, desert oases, scrub & washes. Prefers open country for hunting, with
perches for scanning, and fairly dense shrubs and brush for nesting.

Moderate. Suitable foraging and nesting habitat for this species may be present in the form of grasslands and
ornamental trees within project site. There is one historical record within 5 miles of the project site.

Laterallus jamaicensis
coturniculus
California black rail
—
MTBA
ST
FP; FGC
Occurs and nests in freshwater marshes, wet meadows, and shallow margins of saltwater marshes bordering larger bays.

Needs water depths of about 1 inch that do not fluctuate during the year and dense vegetation for nesting habitat.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site.

Passerculus sandwichensis
Belding's savannah sparrow
—
MTBA
—
FGC
Occurs in coastal salt marshes and other wetland edges. Nests in pickleweed salt marsh vegetation.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Picoides nuttallii
Nuttall's woodpecker
—
MTBA
—
FGC
Occurs in oak woodlands, but also found in riparian woodlands. None. Suitable habitat for this species is not present on or adjacent to the project site.

Polioptila californica californica
Coastal California gnatcatcher
FT
MTBA
—
SSC; FGC
Occurs and nests in arid washes, on mesas, and slopes in coastal sage scrub below 2500 ft. Year–round resident in California.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two recent and one historical records within 5 miles of the project site, and eight historical records between 5 and 10 miles from the project site.

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Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Selasphorus sasin
Allen's hummingbird
—
MBTA
—
FGC
Breeds in moist coastal areas, scrub, chaparral, and forests.

Winters in forest edge and scrub clearings with flowers.

Low. Marginal foraging and nesting habitat for this species occurs on and adjacent to the project site in ornamental vegetation.

Setophaga petechia
Yellow warbler
—
MTBA
—
SSC; FGC
Occurs and nests in willow shrubs and thickets, cottonwoods, sycamores, ash, and alders, predominantly in riparian habitats.

Long–distance migrant.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site, and two recent records between 5 and 10 miles from the project site.

Spinus lawrencei
Lawrence's goldfinch
—
MBTA
—
FGC
Inhabits and nests in arid, open woodlands and oak trees in chaparral.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site.

Spizella atrogularis
black–chinned sparrow
—
MBTA
—
FGC
Occurs in arid brushlands on rugged mountain slopes from sea level to almost 2,700 m. Winters in habitat similar to but downslope from breeding areas, with other populations
inhabiting desert grasslands.

None. Suitable habitat for this species is not present on or adjacent to the project site.

Toxostoma redivivum
California thrasher
—
MBTA
—
FGC
Occurs in chaparral and nests in dense shrubs. None. Suitable habitat for this species is not present on or adjacent to the project site.

Vireo bellii pusillus
Least Bell’s vireo
FE
MTBA
SE
FGC
Occurs and nests in low riparian habitat in the vicinity of water or in dry river bottoms. Long–distance migrant.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are four recent and two historical records within 5 miles of the project site, and six recent and two historical records between 5 and 10 miles from the project site.

Fish
Catostomus santaanae
Santa Ana sucker
FT — Endemic to Los Angeles basin south coastal streams. Are habitat generalists, but prefer sand–rubble–boulder bottoms, cool, clear water, and algae.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two recent and one historical records between 5 and 10 miles from the project site.

Gila orcuttii
arroyo chub
— —
SSC
Native to the streams and rivers of the Los Angeles plain in Southern California. Arroyo chub are adapted to survive in streams that fluctuate between large winter storm flows, and low summer flows, and the low dissolved oxygen and wide temperature fluctuations. Feeds on plants such as algae and water fern, as well as insects and mollusks.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two historical records between 5 and 10 miles from the project site.

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Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Oncorhynchus mykiss irideus
pop. 10
Steelhead–southern California
DPS
FE — Occurs in Pacific coast streams, including the Santa Ana River. None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site.

Rhinichthys osculus ssp. 8
Santa Ana speckled dace
— —
SSC
Occurs in small springs, streams, large rivers, and deep lakes, including headwaters of the Santa Ana and San Gabriel Rivers.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two historical records within 5 miles of the project site, and one historical record between 5 and 10 miles from the project site.

Insects
Bombus crotchii
Crotch bumble bee
— CE Occurs in grassland and scrubland habitats. Nests in abandoned rodent burrows.

Low. Marginal habitat for this species is present on and adjacent to the project site. There is one recent (from 2020) and one historical record within 5 miles of the project site, and three recent and two historical records between 5 and 10 miles from the project site.

Danaus plexippus
Monarch Butterfly
— — Occurs in temperate climates, such as eastern and western North America and undergoes long–distance migration. Lays eggs on obligate milkweed host plant (primarily Asclepias spp.) Low: The host plant for this species (milkweed) is absent from the project site, therefore it would only occur there as a transient.

Euchloe hyantis andrewsi
Andrew's marble butterfly
— — Occurs in yellow pine forest. Hostplants are Streptanthus bernardinus and Arabis holboellii var pinetorum.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site.

Eugnosta busckana
Busck's gallmoth
— — Unknown habitat requirements, but probably inhabits a variety of grassland and scrub habitats.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are no known records within 5 miles of the project site. This species is believed to be locally extirpated.

Euphydryas editha quino
Quino checkerspot butterfly
FE — Occurs in grasslands, coastal sage scrub, chamise chaparral, red shank chaparral, juniper woodland, and semi–desert scrub habitats. Larval host plants are native species of plantain.

None. Project site is outside of the known range of the species, and there is no suitable habitat on or adjacent to the project site. There is one historical record within 5 miles of the project site.

Neolarra alba
white cuckoo bee
— — Unknown habitat requirements, but probably inhabits a variety of grassland and scrub habitats. Parasitizes nests of other bees.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site.

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Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Rhaphiomidas terminatus
abdominalis
Delhi Sands flower–loving fly
FE — Occurs on fine sandy soils of the Delhi series (primarily Delhi fine sand), often on wholly or partly sand dunes stabilized by sparse native vegetation.

None. There is no suitable habitat present within the project site due to lack of Delhi series soils and its associated vegetation communities. There are fourteen recent and six historical records within 5 miles of the project site.

Mammals
Antrozous pallidus
Pallid bat
— —
SSC
Occurs in deserts, grasslands, shrublands, woodlands, and forests. Most common in open, dry habitats with rocky areas for roosting. Roosts must protect bats from high temperatures.

Species is very sensitive to disturbance of roosting sites.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site.

Chaetodipus fallax fallax
Northwestern San Diego pocket
mouse
— —
SSC
Occurs in sandy, herbaceous areas, usually in association with rocks or coarse gravel, in coastal sage and Riversidean alluvial fan sage scrub, chaparral, and grasslands.

Low. Marginal habitat for this species is present on and adjacent to the project site. There are five recent and three historical records within 5 miles of the project site, and three recent and five historical records between 5 and 10 miles from the project site.

Dipodomys merriami parvus
San Bernardino kangaroo rat
FE CE
SSC
Occurs on sandy loam substrates on first terraces and
floodplains of washes in Riversidean alluvial fan sage scrub habitat.

Moderate. Marginally suitable habitat for this species is present on–site and potential kangaroo rat burrows and
tracks were observed on the project site. There are ten recent and two historical records within 5 miles of the project site and mostly in Riversidean alluvial fan sage scrub habitat. One record from 2004 was in a recently disked
agricultural field. There are six recent and two historical records between 5 and 10 miles from the project site.

Dipodomys stephensi
Stephens’ kangaroo rat
FE ST Occurs primarily in annual and perennial grasslands, but also occurs in coastal sage scrub with sparse canopy cover. Can burrow into firm soil.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site, and ten historical records between 5 and 10 miles from the project site.

Eumops perotis californicus
Western mastiff bat
— —
SSC
Occurs in many open, semi–arid to arid habitats, including conifer and deciduous woodlands, coastal scrub, grasslands, chaparral. Roosts in crevices in cliff faces, high buildings, trees, and tunnels.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two historical records within 5 miles of the project site, and three historical records between 5 and 10 miles from the project site.

Lasiurus xanthinus
Western yellow bat
— —
SSC
Occurs in valley foothill riparian, desert riparian, desert wash, and palm oasis habitats. Roosts in skirts of dead fronds in both native and non‑native palm trees.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are three historical records within 5 miles of the project site, and four historical records between 5 and 10 miles from the project site.

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Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Leptonycteris yerbabuenae
lesser long–nosed bat
— —
SSC
Occurs in arid regions such as desert grasslands and shrub land.

Roosts in caves, mines, rock crevices, trees and shrubs, and abandoned buildings.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site.

Lepus californicus bennettii
San Diego black–tailed
jackrabbit
— —
SSC
Occurs primarily in arid regions with short grass including open grasslands, agricultural fields, and sparse coastal scrub. Nests under bushes or shrubs that have shallow depressions.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are seven recent and one historical record between 5 and 10 miles from the project site.

Neotoma lepida intermedia
San Diego desert woodrat
— —
SSC
Occurs in rock outcrops, rocky cliffs, and slopes in coastal sage and Riversidean alluvial fan sage scrub with moderate to dense canopies.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two recent and one historical records within 5 miles of the project site in Riversidean alluvial fan sage scrub habitat, and there are one recent and one historical records between 5 and 10 miles from the project site.

Nyctinomops femorosaccus
Pocketed free–tailed bat
— —
SSC
Occurs in pine–juniper woodlands, desert scrub, palm oasis, desert wash, and desert riparian habitats. Roosts in caves, crevices, mines, tunnels, and man–made structures.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site.

Onychomys torridus ramona
southern grasshopper mouse
— —
SSC
Occurs in desert areas, especially scrub habitats with friable soils for digging. Prefers low to moderate shrub cover.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site.

Perognathus alticola alticola
white–eared pocket mouse
— —
SSC
Occurs in pine forests, mixed chaparral, and sagebrush. None. Suitable habitat for this species is not present on or adjacent to the project site. There are three recent and five historical records between 5 and 10 miles from the project site.

Perognathus longimembris
brevinasus
Los Angeles pocket mouse
— —
SSC
Occurs in open areas with fine, sandy soils in lower elevation grasslands and coastal sage and Riversidean alluvial fan sage scrub habitats.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record within 5 miles of the project site in Riversidean alluvial fan sage scrub habitat, and there are six recent and two
historical records between 5 and 10 miles from the project site.

Taxidea taxus
American badger
— —
SSC
Occurs in drier open stages of most shrub, forest, and
herbaceous habitats with friable soils. Requires sufficient food sources (rodents), friable soils, and open, uncultivated ground.

Digs large burrows.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles of the project site. This species is believed to be locally extirpated.

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Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Reptiles
Anniella stebbinsi
Southern California legless lizard
— —
SSC
Occurs in moist, loose soil in coastal sand dunes and a variety of interior habitats, including sandy washes and alluvial fans.

Moderate. Suitable habitat for this species may be present in ruderal habitats on and adjacent to the project site. There are six recent and two historical records within 5 miles of the project site, and eleven recent and six historical records between 5 and 10 miles from the project site. The regular and recent disking of the project site likely make the area less suitable for occurrence of this species.

Arizona elegans occidentalis
California glossy snake
— —
SSC
Occurs in areas of rocky washes and loose, sandy soils and for burrowing in desert scrub grassland, coastal sage and
Riversidean alluvial fan sage scrub, and chaparral habitats.

Prefer open sandy areas with scattered brush, but also found in rocky areas.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are three recent records within 5 miles of the project site in Riversidean alluvial fan sage scrub habitat. There are five historical records between 5 and 10 miles from the project site.

Aspidoscelis hyperythra
Orange–throated whiptail
— —
WL
Occurs primarily on coarse soils in open coastal sage and Riversidean alluvial fan sage scrub habitat.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are six recent and one historical records within 5 miles of the project site, and five recent and five historical records between 5 and 10 miles from the project site.

Aspidoscelis tigris stejnegeri
San Diegan tiger whiptail
— —
SSC
Occurs in dry, open areas with sparse foliage in coastal sage and Riversidean alluvial fan sage scrub, chaparral, woodland, and riparian habitats.

Moderate. Species was observed on a parcel adjacent to the project site during a biological survey by FCS in 2020. There are three recent records (from 2014, 2015, and 2016) within 5 miles of the project site. One observation was in an area that supported remnant Riversidean fan sage scrub and
annual grassland habitat near a storm drainage. There are six recent and one historical records between 5 and 10 miles from the project site.

Charina umbratical
Southern rubber boa
— FT Occurs in rocks and logs or other debris in oak–conifer and mixed–conifer forests at elevations between 5,000 and 8,200 ft.

None. Project site is outside of the known elevational range of the species, and there is no suitable habitat on or
adjacent to the project site. There are four recent and eight historical records within 5 miles of the project site, and five recent and five historical records between 5 and 10 miles from the project site.

Coleonyx variegatus abbotti
San Diego banded gecko
— —
SSC
Prefers rocky areas in coastal sage and chaparral. None. Suitable habitat for this species is not present on or adjacent to the project site. There is one historical record between 5 and 10 miles from the project site.

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Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Crotalus ruber
Red–diamond rattlesnake
— —
SSC
Occurs in arid, rocky areas in creosote scrub, coastal sage and Riversidean alluvial fan sage scrub, chaparral, oak and pine woodlands, grasslands, on cultivated areas.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two recent records within 5 miles of the project site, and one recent and two historical records between 5 and 10 miles from the project site.

Emys marmorata
western pond turtle
— —
SSC
Found in ponds, lakes, rivers, streams, creeks, marshes, and irrigation ditches, with abundant vegetation, and either rocky or muddy bottoms, in woodland, forest, and grassland. In streams, prefers pools to shallower areas. Logs, rocks, cattail mats, and exposed banks are required for basking. May enter brackish water and even seawater.

None. Suitable habitat for this species is not present on or adjacent to the project site. There is one recent record between 5 and 10 miles from the project site.

Phrynosoma blainvillii
Coast horned lizard
— —
SSC
Occurs in open areas with sandy soil and low vegetation in grasslands, coniferous forests, woodlands, and chaparral.

Low. There is marginal habitat for this species on and
adjacent to the project site. There are four historical records within 5 miles of the project site, and six historical records between 5 and 10 miles from the project site.

Salvadora hexalepis virgultea
coast patch–nosed snake
— —
SSC
Occurs in brushy or shrubby vegetation. Dependent on small mammal burrows.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two recent records between 5 and 10 miles from the project site.

Thamnophis hammondii
Two–striped gartersnake
— —
SSC
Occurs in rocky areas near water sources such as pools and streams in oak woodland, willow, coastal sage and Riversidean alluvial fan sage scrub, scrub oak, sparse pine, chaparral, and brushland habitats.

None. Suitable habitat for this species is not present on or adjacent to the project site. There are two recent records within 5 miles of the project site. These observations were in an area supporting Riversidean alluvial fan scrub and
chaparral habitats near a large, rocky wash. There are three recent and three historical records between 5 and 10 miles from the project site.

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Biological Constrainst Analysis Appendix C
FirstCarbon Solutions
Scientific Name
Common Name
Status
Habitat Description3 Potential to Occur and Rationale4 USFWS1 CDFW2 Code Designations
1 Federal Status: 2020 USFWS Listing 2 State Status: 2020 CDFW Listing ESU = Evolutionary Significant Unit is a distinctive population.

FE = Listed as endangered under the FESA.

FT = Listed as threatened under the FESA.

FC = Candidate for listing (threatened or endangered) under FESA.

FD = Delisted in accordance with the FESA.

FPD = Federally Proposed to be Delisted.

MBTA = protected by the Migratory Bird Treaty Act
— = Not federally listed
SE = Listed as endangered under the CESA.

ST = Listed as threatened under the CESA.

SSC = Species of Special Concern as identified by the CDFW.

FP = Listed as fully protected under FGC.

FGC = protected by FGC 3503.5
CE = Candidate endangered under the CESA.
— = Not state listed
Notes:
3 Habitat Description: Habitat description adapted from CNDDBor other specified source 4 Potential to Occur and Rationale: Location of recorded species occurrences determined by geospatial information from BIOS 5 or other specified source.

Sources:

California Department of Fish and Wildlife (CDFW). 2021. Biogeographic Information and Observation System (BIOS 5). Website: https://map.dfg.ca.gov/bios/. Accessed August 17, 2021.

California Department of Fish and Wildlife (CDFW). 2021. CNDDB RareFind 5 California Natural Diversity Database Query for Special–Status Species. Website:
https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed August 17, 2021.

U.S. Fish and Wildlife Service (USFWS). 2021. Information for Planning and Consultation. Website: https://ecos.fws.gov/ipac/. Accessed August 17, 2021.

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Attachment B
Revised Cultural Resources Report
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NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
Phase I Cultural Resources Assessment
Song and Emm Properties Project
City of Redlands, San Bernardino County, California
USGS Redlands 7.5-minute Topographic Quadrangle Map
Township 1 South, Range 3 West, Section 16
Assessor’s Parcel Number (APN): 016-706-101 and 016-706-103 Prepared for:

MLC Holdings, Inc.
5 Peters Canyon Road, Suite 310
Irvine, California 92606
Contact: Johana Crooker, Director of Entitlements
Prepared by:

FirstCarbon Solutions
967 Kendall Drive, #A-537
San Bernardino, CA 92407
714.508.4110
Report Authored by Stefanie Griffin, MA
Fieldwork Conducted by: Kweku A. Williams, MA, RPA, and Natalie Adame Date: August 16, 2022
Revised Date: June 20, 2023
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MLC Holdings, Inc.—Song and Emm Properties Project
Phase I Cultural Resources Assessment Table of Contents FirstCarbon Solutions iii Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/Phase I CRA/edit/49400030 Song and Emm Properties Project PI-CRA.docx Table of Contents
Management Summary ................................................................................................................. 1 Section 1: Introduction .................................................................................................................. 3

1.1 - Project Location................................................................................................................. 3

1.2 - Project Description............................................................................................................ 3

1.3 - Assessment Team .............................................................................................................. 3 Section 2: Cultural Setting............................................................................................................ 11

2.1 - Prehistoric Background ................................................................................................... 11

2.2 - Regional Historic Background.......................................................................................... 15 Section 3: Results......................................................................................................................... 19

3.1 - Records Search ................................................................................................................ 19

3.2 - Pedestrian Survey............................................................................................................ 23 Section 4: Summary and Recommendations ................................................................................ 25

4.1 - Summary ......................................................................................................................... 25

4.2 - Recommendations........................................................................................................... 25

4.3 - Inadvertent Discovery Procedures.................................................................................. 26 Section 5: References................................................................................................................... 29 Appendix A: Professional Qualifications
Appendix B: South Central Coastal Information Center Records Search Results Appendix C: Native American Heritage Commission and Tribal Correspondence Appendix D: Project Area Photographs
Appendix E: Cultural Resources Regulations and Evaluation Criteria List of Tables
Table 1: Cultural Resources within 0.50-mile of the Project Site ......................................................... 19 Table 2: Previous Investigations within 0.5-mile of the Project Site .................................................... 20 List of Exhibits
Exhibit 1: Regional Location Map ........................................................................................................... 5 Exhibit 2: Local Vicinity Map, Topographic Base .................................................................................... 7 Exhibit 3: Local Vicinity Map, Aerial Base............................................................................................... 9 Redlands Regular meeting of 12-19-23 983 of 1429

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Phase I Cultural Resources Assessment Management Summary FirstCarbon Solutions 1 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/Phase I CRA/edit/49400030 Song and Emm Properties Project PI-CRA.docx

MANAGEMENT SUMMARY
At the request of MLC Holdings, Inc., FirstCarbon Solutions (FCS) conducted a Phase I Cultural Resource Assessment (Phase I CRA) for the Song and Emm Properties Project located in Redlands, California. The purpose of this assessment was to identify the presence or absence of potentially significant cultural resources within the project site, and, if impacted by the proposed development, propose recommendations for mitigation. Completion of this investigation fulfills the requirements of the California Environmental Quality Act (CEQA) under Section 15064.5. The City of Redlands has discretionary authority over the proposed project and is the CEQA Lead Agency. This report follows the California Office of Historic Preservation (OHP) procedures for cultural resource surveys and the OHP Archaeological Resource Management Report (ARMR) format for archaeological reports.

On March 5, 2019, a records search was conducted at the South Central Coastal Information Center (SCCIC) located at the California State University, Fullerton, for the project site and a 0.50-mile radius beyond the project boundaries. To identify additional historic properties or resources, the current inventories of the National Register of Historic Places (NRHP), the California Register of Historical Resources (CRHR), the California Historical Landmarks (CHL) list, the California Points of Historical Interest (CPHI) list, and the California Built Environment Resource Directory (BERD) for San Bernardino County were also consulted. The results of the SCCIC records search indicate that there are 22 cultural resources (2 prehistoric resources and 20 historic resources) located within a 0.5-mile radius of the project boundaries, and no recorded cultural resources are located within the project site. In addition, there are 31 area-specific survey reports on file with the SCCIC, none of which address the project site, indicating that the project site has not been previously surveyed for cultural resources.

On August 12, 2021, a records search request was sent to the Native American Heritage Commission (NAHC) in an effort to determine whether any sacred sites are listed on its Sacred Lands File for the project site. On September 15, 2021, a response from the NAHC was received indicating that their Sacred Lands File search came back positive for Tribal Cultural Resources (TCRs) within the project site. The NAHC included a list of 10 tribal representatives available for consultation who may have additional knowledge of the project area. To ensure that all Native American knowledge and concerns over potential TCRs that may be affected by implementation of the proposed project are addressed, a letter containing project information and requesting additional information was sent to each tribal representative on September 16, 2021. A response was received on September 17, 2021 from the Quechan Tribe of the Fort Yuma Reservation providing no comments, but deferring to more local tribes and supporting their decisions regarding the proposed project. On September 28, 2021, a response was received from the San Manuel Band of Mission Indians indicating that the proposed project site is not located near any known SLF Serrano Villages or archaeological sites. On October 29, 2022, a reply was received from Agua Caliente Band of Cahuilla Indians indicating that the proposed project site is not located within the boundaries of the Agua Caliente Band of Cahuilla Indians, however, the tribe requested a copy of the EIC records search results. No additional responses were received.

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MLC Holdings, Inc.—Song and Emm Properties Project
Management Summary Phase I Cultural Resources Assessment 2 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/Phase I CRA/edit/49400030 Song and Emm Properties Project PI-CRA.docx On May 12, 2022, a second set of letters were sent to the 10 tribal representatives, with the updated project description that includes the Emm Property. On June 22, 2022 a response was received from the Yuhaaviatam of San Manuel Nation stating that the project site is not located near any known cultural resources. No additional responses have been received to date.

On August 21, 2021, FCS Archaeologist, Kweku Williams, MA, RPA conducted a pedestrian survey for unrecorded cultural resources at the project site. The survey covered the subject property where possible, beginning in the southern portion of the project site and moving north, using north–south transects spaced at 15-meter intervals. The project site is within an overgrown, semi-desert area with local vegetation scattered throughout the proposed project. Soil visibility was moderate across the site, ranging from 30 to 50 percent. Obstruction of the soil was due to the high volume of modern debris and tall grass. Observed soils were largely composed of dark gray-brown sand with inclusion of gravel-like rocks and quartz. On April 15, 2022, FCS Archaeologist Natalie Adame conducted a pedestrian survey for the adjacent Emm Property. The survey began on the southwest corner of the project site and moved east, using north–west transects spaced at 15-meter intervals whenever possible. The project site was undeveloped and consisted of relatively flat grassy area, with soil visibility of native soils ranging from 10 percent to 5 percent in areas where bioturbation activities had taken place. Soil composition was made up of dark yellowish brown silty sand (10YR 4/4). Because of the proximity to West Pioneer Avenue and Citrus Valley High School, there was scattered modern debris along the edges of the property. To the extent possible, all areas of the project site were inspected for culturally-modified soils or other indicators of potential historic or prehistoric resources. No prehistoric or historic resources or raw materials commonly used in the manufacture of tools (e.g., obsidian, Franciscan chert, etc.) were found within the project site.

Based on the results of the positive Sacred Lands File search from the NAHC, the SCCIC records searches, archival research, and pedestrian survey, FCS considers the potential for the proposed project to have an adverse effect on historic and/or prehistoric cultural resources to be moderate.

While there are no recorded resources within the project site, 20 historic resources and two prehistoric resources have been recorded within the 0.5-mile search radius. In addition, the site has not been previously surveyed for archaeological resources and its topography increases the possibility that subsurface archaeological resources may be encountered during project construction.

For this reason, FCS recommends that a qualified Archaeologist who meets the Secretary of Interior’s Professional Qualification Standards for Archaeology perform an inspection of the site following grubbing, ground clearing, and prior to any grading or project-related ground disturbance.

In the event exposed soils indicate cultural materials may be present, this may be followed by regular or periodic “spot check” archaeological monitoring as determined by the Archaeologist, but full-time archaeological monitoring is not recommended at this time. Additional procedures for the inadvertent discovery of human remains and cultural resources are provided in the report.

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Phase I Cultural Resources Assessment Introduction
FirstCarbon Solutions 3 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/Phase I CRA/edit/49400030 Song and Emm Properties Project PI-CRA.docx SECTION 1: INTRODUCTION

1.1 - Project Location
The project site encompasses approximately 14.6 acres located within the City of Redlands, San Bernardino County, California (Exhibit 1). The project site is located on the Redlands, California United States Geological Survey (USGS) 7.5-minute Topographic Quadrangle Map (Exhibit 2). The project site is located at 1160 West Pioneer Avenue and consists of two Assessor’s Parcel Numbers (APNs): 016-706-101 and 016-706-103. The project site is currently vacant and is bounded by West Pioneer Avenue to the south, Citrus Valley High School to the east, an orchard field in the northeastern border, State Route (SR) 210 to the west, and West Domestic Avenue to the north (Exhibit 3).

1.2 - Project Description
The project applicant is proposing to construct a new residential development on approximately 14.6 acres at 1160 West Pioneer Avenue in the City of Redlands. The proposed project includes the development of a total of approximately 117 motor court homes. The maximum depth of ground disturbance is estimated to be up to 11 feet.

1.3 - Assessment Team
FCS Archaeological Supervisor, Stefanie Griffin, MA, authored this report. FCS Osteologist/Staff Archaeologist, Kweku A. Williams, MA, RPA, and Archaeological Field Manager, Natalie Adame, conducted the pedestrian survey. Ms. Griffin, Mr. Williams, and Ms. Adame exceed the professional standards set for their respective roles by the Secretary of the Interior. Professional qualifications for Ms. Griffin, Mr. Williams, and Ms. Adame can be found in Appendix A.

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Source: Cen sus 2000 Data, Th e Californ ia Sp atial In formation Library (CaSIL).

I
MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT
PHASE 1 CULTURAL RESOURCES ASSESSMENT
49400030 • 08/2022 | 1_ region al.mxd
Project Site
Legend
City of Redlands
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49400030 • 08/2022 | 2_ Local_ Vicinity _ Topo.m xd
Exh ibit 2: Local Vicinity Map I Topograph ic Base
1,000 500 0 1,000
Fe e t
Source : USGS Re dlands 7.5' Q uadrangle / T01S,R03W,se c16.

MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT
PHASE 1 CULTURAL RESOURCES ASSESSMENT
Legend
Project Site
Off-Site Roadway and Frontage Improvements
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49400030 • 08/2022 | 3_lo cal_vicinity_Aerial.m xd
So urce: Bing Aerial Im agery.

I 1,000 500 0 1,000
Feet
Legend
Project Site
Off-site Roadway and Frontage Improvements
MLC HOLDINGS, INC.

SONG AND EMM PROPERTIES PROJECT
PHASE 1 CU LTU RAL RESOU RCES ASSESSMENT
Exhibit 3: Lo cal Vicinity Map
Aerial Base
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MLC Holdings, Inc.—Song and Emm Properties Project
Phase I Cultural Resources Assessment Cultural Setting
FirstCarbon Solutions 11 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/Phase I CRA/edit/49400030 Song and Emm Properties Project PI-CRA.docx SECTION 2: CULTURAL SETTING
Following is a brief overview of the prehistory, ethnography, and historic background, providing context in which to understand the background and relevance of sites found in the general project area. This section is not intended to be a comprehensive review of the current resources available; rather, it serves as a general overview.

Further details can be found in ethnographic studies, mission records, and major published sources, including Beardsley (1948), Bennyhoff (1950), Fredrickson (1973), Kroeber (1925), Chartkoff and Chartkoff (1984), and Moratto (1984).

2.1 - Prehistoric Background
Fagan (2003), Moratto (1984), and Chartkoff and Chartkoff (1984) provide recent overviews of California archaeology and historical reviews of inland Southern California, among other locales. An early and widely used regional chronology for coastal Southern California is Wallace’s four-part Horizon format (1955), which was later updated and revised by Warren (1968) and more recently by Chartkoff and Chartkoff (1984), and King (1990 and 2000). The sequence provides a framework that relates societal change to change in material culture; the advantages and weaknesses of Southern California chronological sequences are reviewed by Warren (in Moratto 1984), Chartkoff and Chartkoff (1984), and Heizer (ed. 1978).

2.1.1 - Paleoamericans
In North America, radiocarbon dates from existing samples of archaeological materials demonstrate human presence as early as 15,000 years Before Present (BP) (Waters et al. 2018). The lithics from the earliest (14,000 to 15,000 BP) documented sites in North America include cores, flakes and flake tools (e.g., 5 blades, 14 bladelets, 12 bifaces, one discoidal flake core, 23 edge-modified tools that includes scrapers and gravers from the Debra L. Friedkin site, Texas) with an absence of projectile points (Waters et al. 2011, 2018). The first known projectile points in North America are from 13,000 years BP, with lanceolate fluted points (Clovis Complex) in sites from central and eastern North America and stemmed projectile points from sites in areas of western North America that were not glaciated (Jenkins et al. 2012; Beck and Jones 2010). Glennan (1972) provides an early study of the hypothesis of Pre-Clovis in Southern California. The oldest California radiocarbon date as of 2007 from archaeological materials confirms a human presence in the northeastern part of the State (from site CA-SIS-218) as early as 13,500 years BP (Jones and Klar 2007). The radiocarbon date corresponds to the period of fluted points and fluted points have been found throughout California (Rondeau et al. 2007; Rondeau 2009) although projectile points and other chronologically and culturally informative materials are absent from the SIS-218 sample.

Pleistocene flora and fauna are regularly uncovered from sediments at the La Brea Tar Pits, deep construction-related excavations in coastal Orange County, and the Santa Ana watershed. Such studies reinforce the idea that much of Southern California exhibited a climate similar to that of Redlands Regular meeting of 12-19-23 995 of 1429
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2.1.2 - Millingstone Complex or Early Period
During the early post glacial period after 8,500 BP the Southern California climate became warmer and drier (Fagan 2003). Groundstone artifacts that include manos and metates correspond to the Early Period. The Early Period in Southern California begins as early or earlier than 8,000 BP and ends by about 2,800 BP (King 1990). The Early Period corresponds to the earliest known sites in Southern California with year-round habitation and cemeteries. Manos and metates consist of a variety of types. Mano and metates of the Early Period in Southern California, correspond to types from studies in the U.S. southwest that efficiently grind small, oily annual and biennial wild seeds (Adams 1999; Ciolek-Torello 1995; Gilman 1988; Lancaster 1984; Whittlesey 1995). Most annual and biennial wild seed plant types in Southern California are best adapted for warm and dry environments (e.g., Hemizonia fasciculata, which is a summer seed source). Annual and biennial seed crops are highly reliable, nutritious, and productive. Annual and biennial seed producers are also, diverse and afford reliable seed production throughout the year. Compared to later periods, utilitarian artifacts are most frequently found with Early Period burials.

Manos and metates are “kitchen tools” and concentrate within residential areas of Early Period habitation sites in Southern California (King and Merrill 2002; Merrill 2015). Other kinds of lithics that correspond to the Early Period include many kinds of core tools (e.g., hammers, choppers, and scraper planes), knives, bifaces, scrapers (many types), gravers, burins, dart points, and compound bone fishhooks. Sedentism apparently increased in areas with abundant resources that were available for longer periods. Arid inland regions and offshore desert islands (e.g., San Nicolas Island) provided less opportunity for long-term residence without trade and possibly for more mobile subsistence. The Early Period ends about 2,800 BP (King 1990).

2.1.3 - Middle Period
The Middle Period lasted from about 2,800 BP to 750 BP (King 1990). Excavated assemblages retain many attributes of the Early Period but with more diverse artifact types. Middle Period sites can contain large-stemmed or notched small projectile points suggestive of bow and arrow use, especially near the end of the Period, and the use of portable grinding tools continued. Intensive use of mortar and pestles signaled processing of acorns as the primary vegetative staple as opposed to a mixed diet of seeds and acorns. Because of a general lack of data, neither the settlement and subsistence systems nor the cultural evolution of this Period are well understood, but it is very likely that the nomadic ways continued. It has been proposed that sedentism increased with the exploitation of storable food resources, such as acorns, but coastal sites from the Period exhibit higher fishing activity than in previous periods. The first permanently occupied villages make their appearance in this Period (Chartkoff and Chartkoff 1984).

2.1.4 - Late Prehistoric
Extending from 750 BP to Spanish Contact in 1769, the Late Prehistoric includes changes in trade networks and political and secular economic subsystems. There was also a differentiation of types of Redlands Regular meeting of 12-19-23 996 of 1429
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Use of personal ornaments such as shell beads were widely distributed east of the coast, suggesting well-organized and codified trade networks. Additional assemblages in this Period included steatite bowls, asphaltum, grave goods, and elaborate shell ornaments. The use of bedrock milling stations was widespread during this horizon. Increased hunting efficiency and widespread exploitation of acorns provided reliable and storable food resources. Village size increased during this time, and some of these villages may have held 1,500 or more residents (Chartkoff and Chartkoff 1984).

Analyses of skeletons showed that the first signs of malnutrition appeared in this Period, signaling greater competition for food resources (Fagan 2003).

The earliest part of this Period may have seen an incursion of Cupan-Takic speakers from the Great Basin (the “Shoshonean wedge” of Kroeber 1925) may have replaced the Hokan speakers in the area. At the time of Spanish conquest, Cupan-Takic speakers were distributed throughout Orange County, western Riverside County, and the Los Angeles Basin (Gabrieliño, Juaneño, and Cahuilla peoples). Serran-Takic speakers are now represented by the Serranos in the San Bernardino Mountains. Recent work (O’Neil 2002) suggests that the “Shoshonean wedge” is misnamed—the original Los Angeles inhabitants replaced by the incoming Takic-speakers may have actually been Yuman speakers (similar to those in the California Delta region of the Colorado River) and not Hokan Salinan-Seri (Chumash) speakers as was suggested by Kroeber.

At the time of Spanish conquest, local indigenous groups were composed of constantly moving and shifting clans and cultures. Early ethnographers applied the concept of territorial boundaries to local indigenous groups purely as a conceptualization device, and the data was based on fragmented information provided to them from second-hand sources. At least three Native American groups, the Cahuilla, Serrano, and Gabrieliño are known to have occupied or utilized resources within the vicinity of the project site at different points in history. A brief overview of these three tribal groups follows.

2.1.5 - Cahuilla
The project site is located in the region known to have been occupied by the Cahuilla Indians.

Cahuilla territory was bounded on the north by the San Bernardino Mountains, on the east by the Orocopia Mountains, on the west by the Santa Ana River, the San Jacinto Plain, and the eastern slope of the Palomar Mountains, and on the south by Borrego Springs and the Chocolate Mountains (Bean 1978). The diversity of the territory provided the Cahuilla with a variety of foods. It has been estimated that the Cahuilla exploited more than 500 native and non-native plants (Bean and Saubel 1972). Acorns, mesquite, screw beans, piñon nuts, and various types of cacti were used. A variety of seeds, wild fruits and berries, tubers, roots, and greens were also a part of the Cahuilla diet. A marginal agricultural existence provided corn, beans, squashes, and melons. Rabbits and small animals were also hunted to supplement the diet. During high stands of Ancient Lake Cahuilla, fish, migratory birds, and marshland vegetation were also taken for sustenance and utilitarian purposes (Bean 1978).

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Some of the Cahuilla who lived in the plains and valleys west of the desert and mountains, however, were missionized through the asistencia located near present day San Bernardino. Cahuilla political, economic, and religious autonomy was maintained until 1877 when the United States government established Indian reservations in the region. Protestant missionaries came into the area to convert and civilize the Native American population. During this era, traditional cultural practices, such as cremation of the dead, were prohibited. Today, the Cahuilla reside on eight separate reservations in Southern California, located from Banning in the north to Warner Springs in the south and from Hemet in the west to Thermal in the east (Bean 1978).

2.1.6 - Serrano
Ethnographic accounts indicate that the Serrano were the dominant group of Native Americans in the region that includes the project site. The Serrano occupied an area in and around the San Bernardino Mountains between approximately 1,500 and 11,000 feet above mean sea level. Their territory extended west into the Cajon Pass, east as far as Twentynine Palms, north to Victorville, and south to the Yucaipa Valley. The Serrano were mainly hunters and gatherers who occasionally fished.

Game that was hunted included mountain sheep, deer, antelope, rabbits, small rodents, and various birds, particularly quail. Vegetable staples consisted of acorns, piñon nuts, bulbs and tubers, shoots and roots, berries, mesquite, barrel cacti, and Joshua tree (Bean and Smith 1978).

A variety of materials were used for hunting, gathering, and processing food, as well as for shelter, clothing, and luxury items. Shells, wood, bone, stone, plant materials, and animal skins and feathers were used for making baskets, pottery, blankets, mats, nets, bags and pouches, cordage, awls, bows, arrows, drills, stone pipes, musical instruments, and clothing (Bean and Smith 1978). Settlement locations were determined by water availability, and most Serrano’s lived in small villages near water sources. Houses and ramadas were round and constructed of poles covered with bark and tule mats (Kroeber 1925). Most Serrano villages also had a ceremonial house used as a religious center. Other structures within the village might include granaries and sweathouses (Bean and Smith 1978).

The Serrano were loosely organized along patrilineal lines and associated themselves with either the Tukum (wildcat) or the Wahilyam (coyote) moiety. Organization of individual bands of Serrano was considered by Kroeber (1925) to be similar to political groups. Tribes, as opposed to bands, were larger in numbers, and were distinguished from each other by having distinct dialects. Unlike bands, tribes often had names that were more than merely a designation for the place where they lived (Kroeber 1925). Partly due to their mountainous inland territory, contact between Serrano and Redlands Regular meeting of 12-19-23 998 of 1429
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2.2 - Regional Historic Background

2.2.1 - Spanish and Mexican Exploration and Settlement
The Spanish Period (1769-1821)
The first Europeans to pass through the region were Spanish military commander Don Pedro Fages and Father Francisco Garces. Fages first passed through the area in 1771, in an attempt to recover several soldiers that had abandoned their garrison in San Diego. Fages is credited with discovering El Cajon Pass and traveled through the Mojave Desert (Lech 2012). Father Francisco Garces first entered present day San Bernardino in 1773 accompanying the Spanish explorer Juan Batista de Anza in expedition to find a safer route via land from Mexico to Alta-California by way of the Colorado River. Father Garces joined de Anza on his first expedition from Sonora to San Gabriel, however, they split during the second trip with Father Garces deciding to stay behind and explore what would eventually become San Bernardino County (Beattie 1923). Father Garces helped further establish the trail that was used by de Anza, which in time proved to be pivotal for transportation of goods from Sonora, Mexico to Mission San Gabriel. The trail grew and several small missions and small towns were erected, one of which was Politana, named after Hipolito, the Native American who was put in charge of the town. The trail remained continuously in use until 1781, when a massacre of 50 people in Yuma, including Father Garces, halted the use of the trail for a few years (Brown and Boyd 1922; Beattie 1923).

As the influence of Mission San Gabriel grew, so did the land that it controlled. At its height, Mission San Gabriel controlled roughly 1,500,000 acres of land, extending from the ocean to the San Bernardino Mountains. In 1810, a party of missionaries, soldiers and Native Americans from Mission San Gabriel entered the region and begun referring to it as San Bernardino (Brown and Boyd 1922).

The mission settlement quickly grew with the addition of adobe buildings, various mission activities and San Bernardino Rancho was officially incorporated into the mission system on May 20, 1819 (Brown and Boyd 1922; Beattie 1923; Lech 2012). The town of Politana was quickly incorporated into the Rancheria. However, a series of earthquakes in 1812 destroyed Politana, with only remnants of the old buildings remaining. In 1822, the area was eventually rebuilt with help from the San Gabriel Mission fathers, and the Guachama Rancheria began to prosper and grow.

The Mexican Period (1821-1848)
In 1821, Mexico overthrew Spanish rule and the monopoly that the missions had in the area began to decline. By 1833, the Mexican government passed The Secularization Act, and the missions reorganized as parish churches and lost their vast land holdings (Beattie and Beattie 1974). Following The Secularization Act, the Mexican government initially planned on redistributing the land to the Native Americans, however, they were instead redistributed to prominent citizens. The first land grant in the area was the Jurupa Land Grant of 1838 given to Juan Bandini (Barrows 1899). In 1842, Redlands Regular meeting of 12-19-23 999 of 1429
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After the Mexican-American War and the cessation of California to the United States, American pioneers, businessmen and members of The Church of Latter-Day Saints eventually settled in the area purchasing land from the Lugo families and the Bandini family. The Lugo family fortune fell into disarray and they sold their land to George and Ellen Cooley, the Hunt Family, and other Mormon pioneers caravanning from Salt Lake City, Utah to California, settling in Rancho San Bernardino before purchasing it. Juan Bandini sold a portion of his land to his son-in-law, who sold a portion of his land to Benjamin Wilson (Sheffield 2004). The land went through several owners before settling with Louis Rubidoux.

2.2.2 - San Bernardino County
San Bernardino County was named after the feast day of San Bernardino of Sienna. The County of San Bernardino was established in April 1953 after dividing from the County of Los Angeles, quickly followed by the creation of three townships including San Bernardino, which would become the county seat the following year. During the Mexican-American War, the Mormon settlers in the area offered their services to the United States, which included the company of Captain Jefferson Hunt, who would be called the father of San Bernardino County and help create the first American settlement in present day San Bernardino before being recalled back to Salt Lake City, Utah (Brown and Boyd 1922; Beattie 1923). The following decade, there was a flourishing agricultural industry, which helped increase trade and commerce in the area. San Bernardino County established the San Bernardino Fire company, the first artesian well, and housed the first commercially-run winery in Cucamonga. The growing population saw the incorporation of a road tax being imposed on every citizen 21-50 and welfare programs being introduced to aid citizens. By the late 1880s, San Bernardino had entered an economic boom ushered by the introduction of Southern Pacific Railroad in 1875, which had a line running from Los Angeles to Colton. The introduction of the railroad caused an influx of settlers with aims at acquiring land, which at the time was rapidly changing ownership and being sold at increased prices, creating a buzz for investment (Brown and Boyd 1922; Beattie 1923; San Bernardino County 2020).

World War II saw the introduction of the San Bernardino Army Air Field (formerly known as the Municipal Airport) and Kaiser Steel operation, both of which opened in 1942, bringing thousands of jobs to the region. The base was later renamed the Norton Air Force Base in honor of Captain Leland Norton (AFCEC 2020). However, by the early 1990s, the closure and/or movement of several industries led to the loss of thousands of jobs and decline in economic growth. The County of San Bernardino is the largest in the State of California, with the fourth largest population. Encompassing over 20,000 square miles of land and 24 cities, the County is currently going through a political and economic reform aimed at fiscal sustainability and further support for housing growth (Pisano 2013).

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2.2.3 - City of Redlands
The City of Redlands was founded in 1881 by two Connecticut Yankees named Frank E. Brown and Edward Judson. It was named after the reddish adobe soil that’s prevalent throughout the city. These men were intrigued by the 1873 book, California for Health, Pleasure, and Residence by Charles Nordhoff, which has a chapter that focuses on the San Bernardino Valley. Brown and Judson arrived in Lugonia, which is now north Redlands, with plans to establish a colony that comprised of emigrants from the East and Midwest. The emigrants planted groves of Washington navel oranges that prospered in the southern California climate. The City was known as the “Washington Navel Orange Growing Capital of the World” making the citrus industry the thriving force of its economy (City of Redlands 2022). From 1885 to 1886, early settlers of the Chicago Colony from the east, named the streets La Salle, Wabash, Dearborn, Lincoln, and State for their hometown. By 1888, the town was incorporated and included the town of Lugonia. In 1889, the famous twin Smiley brothers arrived making Redlands the ideal tourist destination. The Smiley brothers’ Canon Crest Park, known as Smiley Heights, brought in thousands of tourists starting in 1890 through 1930. Redlands was known as “The City of Millionaires” and became a destination hotspot in the 1900s (City of Redlands 2022). The Smiley’s opened up their 200 acres estate to tourists to enjoy magnificent views, eat at local restaurants, and stay at hotels. The vision of Judson and Brown (as part of Brown’s civil engineering skills) came to light when the Big Bear Dam was built and guaranteed a water supply at the Big Bear reservoir for Redlands (Burgess and Gonzales 2004). Additionally, Edward Judson took personal interest in making sure that trees were provided to the early settlers of the area. At the turn of the 20th century, Redlands began to grow exponentially from hundreds to almost 5,000 residents (Burgess and Gonzales 2004). In 1901 President McKinley visited Redlands as part of his “California Welcome” (Burgess and Gonzales 2004). Also in 1903, President Theodore Roosevelt visited California and first stopped in Redlands.

Over the years things have changed with the economy and the great homes of Redlands, however it still provides a community situated in a big town with a small-town feeling. The city still comprises of beautiful historic buildings and locally owned shops and boutiques, and State Street continues to be lined with trees. There are several famous buildings, such as the Albert K. Smiley Public Library, that demonstrates a strong tradition of philanthropy within Redlands. Albert K. Smiley used borrowed money to provide the Moorish style library that was built in 1898, and park to the City. Additionally, the Redlands Bowl was built in 1930 and continues to be the oldest free outdoor concert series in California (). Parks were created and private homes became museums and were given to the public to enjoy. There are also turn of the century bungalows and landmark homes throughout the Smiley Park neighborhood. Redlands is currently home to 73,288 residents and continues to be a great tourist destination (United States Census Bureau 2021).

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3.1 - Records Search

3.1.1 - South Central Coastal Information Center
On March 5, 2019, a records search for the project site and a 0.5-mile radius beyond the project boundaries was conducted at the SCCIC located at California State University, Fullerton. To identify historic properties or resources, the current inventories of the NRHP, CRHR, CHL list, CPHI list, and the BERD for San Bernardino County were reviewed to determine the existence of previouslydocumented local historical resources.

The results of the SCCIC records search indicate that there are 22 cultural resources (2 prehistoric resources and 20 historic resources) located within a 0.5-mile radius of the project boundaries, and no recorded cultural resources are located within the project site (Table 1). In addition, there are 31 area-specific survey reports on file with the SCCIC, none of which address the project site, indicating that the project site has not been previously surveyed for cultural resources (Table 2). The SCCIC records search results can be found in Appendix B.

Table 1: Cultural Resources within 0.50-mile of the Project Site Resource No. Resource Description Date Recorded
P-36-005990 5; AH04 Privies/dumps/trash scatters 1987
P-36-005991 6; AH02 Foundations/structure pads 1987
P-36-005992 7; AH04 Privies/dumps/trash scatters 1987
P-36-006084 B-12; AH04 Privies/dumps/trash scatters 1987 P-36-006095 C-10; AH04 Privies/dumps/trash scatters 1987 P-36-007052 Arth Ranch; AH02 Foundations/structure pads 1991 P-36-007765 CP-1; AH06 Water conveyance system 1993
P-36-007766 CP-2; AH06 Water conveyance system 1993
P-36-007767 CP-4; AH06 Water conveyance system 1993
P-36-007768 CP-6; AH02 Foundations/structure pads, AH05 Wells/cisterns, AH06 Water conveyance system, AH11 Walls/Fences, AH15 Standing Structures, AH16 Other
1993
P-36-008135 CP-1; CP-1; AH06 Water conveyance system 1995 P-36-008137 CP-3; AH03 Landscaping/orchard, AH15 Standing Structures 1995 P-36-012468 CRM Tech 1872-1H; AH06 Water conveyance system 2006 P-36-012531 RUSD New School #3; HP02 Single-family property 2006 P-36-012532 RUSD New School #3; HP02 Single-family property 2006 P-36-012852 RCC-1-001; AH03 Landscaping/orchard 2006
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P-36-013514 1660 W. San Bernardino Ave; HP02 Single-family building 2004 P-36-013622 West San Bernardino Road Curb; AH16 Other 2007 P-36-013783 Redlands CC-Site 001; AH06 Water conveyance system 2007 P-36-032488 AE-3895-01H; AH06 Water conveyance system 2018 P-36-032489 AE-3895-02H; AH06 Water conveyance system 2018 P-36-060203 SBCM-5422; AP16 Other 1983
Source: South Central Coastal Information Center (SCCIC) Records Search. March 5, 2019.

Table 2: Previous Investigations within 0.5-mile of the Project Site Report No. Report Title/Project Focus Author Date
SB-00574 Cultural Resources Survey: Route 30 Between Interstate Route 10 and Arden Avenue, San Bernardino County,
California.

Stephen R. Hammond
and Lois M. Webb
1977
SB-01055 Archaeological Survey Report: Route 30 Between Third Street and Route 10 at Tennessee Street.

Stephen R. Hammond 1980
SB-01105 Archaeological Survey Report: Route 30 Near the City of Redlands.

Stephen R. Hammond 1981
SB-01783 Seven Oaks Dam Project: Water Systems. David Hornbeck and Howard Botts
1988
SB-01808 Cultural Resources Survey, Upper Santa Ana River, California.

Paul R. Hampson,
Jerrel Sorensen, Susa,
K. Goldberg, Mark T.

Swanson, and Jeanne
E. Arnold
1988
SB-01879 A Cultural Resources Investigation for the proposed Redlands Well and Alternative Pipeline, Redlands and San Bernardino County, California.

Jeanette A. McKenna 1989
SB-02062 Archival Research for Cultural Resources: Old Webster Quarry, San Bernardino County.

John M. Foster 1990
SB-02466 Cultural Resources Assessment of Tentative Tract 15304, City of Redlands, San Bernardino County, California.

Michael K. Lerch 1991
SB-02792 Cultural Resources Survey for the Cities Pavilion Project, Redlands, CA.

Roger D. Mason and
Jeanette A. McKenna
1993
SB-03064 An Archaeological Assessment of the 124+/- Acre Concept Plan 5 Citrus Plaza Project, Redlands, CA.

Laurie White and
Robert S. White
1995
SB-03140 Archaeological and Historical Property Survey for the Reconstruction and Widening of All-Weather Crossing at
Orange Street and the Santa Ana River, Redlands, San
Bernardino County, CA.

Bruce Love 1995
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SB-03041 Alabama Street All-Weather Crossing. Bruce Love 1995 SB-03742 An Archaeological Assessment of the Proposed Verizon Buckeye Unmanned Cellular Telecommunication Site to
be Located at 27630 W. Pioneer Ave, Redlands, CA.

Fred Budinger 2001
SB-03750 Westside Landfill Expansion Project. Bruce Love 2000 SB-04044 Identification and Evaluation of Historic Properties:

Orange Street Well Field and Pipeline Project, City of
Redlands, San Bernardino County, CA.

Josh Smallwood 2002
SB-04047 Phase I Cultural Resources Survey Results for Cingular Telecommunications Facility SB-230021 27630 N. Pioneer
Ave, Redlands, San Bernardino County, CA.

Michael Dice 2003
SB-04104 An Architectural Review of Standing Structures Located Within the Proposed Redlands Unified School District’s
Proposed New School Site, Redlands, San Bernardino
County, CA.

Jeanette A. McKenna 2004
SB-04592 Historical/Archaeological Resources Survey Report: ABTHaskell Company Composting Plan Site near the City of Redlands, San Bernardino County, CA.

Bai “Tom” Tang,
Michael Hogan, Casey
Tibbett and John J.

Eddy
2005
SB-04594 HWY 30/CA-8817A. Loma Billat 2005
SB-04597 Cultural Resources Assessment: Tract 16359 City of Redlands, San Bernardino County, California.

Riordan Goodwin 2004
SB-04629 Cultural Resources Assessment of Tentative Tract 16390 Pioneer, City of Redlands, San Bernardino, California.

Michael K. Lerch 2003
SB-04811 Supplemental Research and Documentation of 1042 Pioneer Ave. and 1074 Pioneer Ave., Redlands, San
Bernardino County, CA.

Jeanette A. McKenna 2006
SB-04831 Cultural Resource Assessment: Upper Santa Ana River Wash Land Management and Habitat Conservation Plan,
San Bernardino County, CA.

David Brunzell and
Curt Duke
2005
SB-05166 Historical/Archaeological Resources Survey Report Redlands Common Project Assessor’s parcel No. 0167-
091-02, -04, and -08, City of Redlands, San Bernardino
County, CA.

Bai Tang and Hogan
Michael
2006
SB-05167 Historical/Archaeological Resources Survey: Trojan Groves, Assessor’s Parcel No. 0167-091-09 through -12.

City of Redlands, San Bernardino County, CA.

Hogan Michael 2006
SB-05788 Phase I Cultural Resource Assessment and Paleontological Records Review, Redlands Commerce Center Project, City
of Redlands, San Bernardino County, CA.

Jennifer M. Sanka 2006
SB-05857 Phase I Cultural Resource Assessment and Paleontological Records Review, Holy Name of Jesus Catholic Church
Project, City of Redlands, San Bernardino County, CA.

Jennifer M. Sanka 2008
Redlands Regular meeting of 12-19-23 1005 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Results Phase I Cultural Resources Assessment
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SB-07663 A Phase I Cultural Resource Investigation for the Newland Homes 30.94 Acre Property in the City of Redlands, San
Bernardino County, CA.

Jeanette A. McKenna 2014
SB-07822 Cultural Resource Records Search and Site Visit for TMobile West, LLC. Candidate IE24763A 15500 Orange St.

Redlands, San Bernardino County, CA.

Carrie Willis and
Sarah A. Williams
2014
SB-08097 Archaeological Survey Report State Route 210 Mixed Flow Lane Addition from Highland Avenue to San Bernardino
Avenue, Cities of Highland, San Bernardino, Redlands and Portions of San Bernardino County, CA.

Shelly Logn 2014
SB-08254 Orange Street and Pioneer Avenue Traffic Signal Project in Redlands, San Bernardino County.

Roger D. Mason 2016
Source: South Central Coastal Information Center (SCCIC) Records Search. March 5, 2019.

3.1.2 - Historical Aerials
A review of 16 historical aerial photographs depicting the project site from 1938 until 2018 indicate that from the earliest aerial in 1938 and sometime before 1980, the project site and the general land areas were undeveloped and used for agricultural purposes (Historic Aerials 2020). Sometime between 1980 to 1984 SR-210 was constructed. The images from 1985 to 2018 depict the gradual residential and commercial development surrounding the project site. However, the project site remained vacant from 1938 to the present.

3.1.3 - Native American Heritage Commission
On August 12, 2021, a records search request was sent to the NAHC in an effort to determine whether any sacred sites are listed on its Sacred Lands File for the project site. On September 15, 2021, a response from the NAHC was received indicating that their Sacred Lands File search came back positive for TCRs within the project area. The NAHC included a list of 10 tribal representatives available for consultation who may have additional knowledge of the project area. To ensure that all Native American knowledge and concerns over potential TCRs that may be affected by implementation of the proposed project are addressed, a letter containing project information and requesting additional information was sent to each tribal representative on September 16, 2021. A response was received on September 17, 2021, from the Quechan Tribe of the Fort Yuma Reservation providing no comments, but deferring to more local tribes and supporting their decisions regarding the proposed project. On September 28, 2021, a response was received from the San Manuel Band of Mission Indians indicating that the proposed project site is not located near any known SLFs, Serrano Villages or archaeological sites. On October 29, 2022, a reply was received from Agua Caliente Band of Cahuilla Indians indicating that the proposed project site is not located within the boundaries of the Agua Caliente Band of Cahuilla Indians, however, the tribe requested a copy of the EIC records search results. No additional responses have been received.

On May 12, 2022, a second set of letters were sent to the 10 tribal representatives, with the updated project description that includes Emm Property. On June 22, 2022 a response was received from the Redlands Regular meeting of 12-19-23 1006 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Phase I Cultural Resources Assessment Results
FirstCarbon Solutions 23 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/Phase I CRA/edit/49400030 Song and Emm Properties Project PI-CRA.docx Yuhaaviatam of San Manuel Nation stating that the project site is not located near any known cultural resources. No additional responses have been received to date. Copies of the NAHC correspondence can be found in Appendix C.

3.2 - Pedestrian Survey
Song Property Project: On August 21, 2021, FCS Archaeologist Kweku Williams, MA, RPA conducted a pedestrian survey for unrecorded cultural resources at the project site. The survey covered the subject property where possible, beginning in the southern portion of the project site and moving north, using north–south transects spaced at 15-meter intervals. The project site is within an overgrown, semi-desert area with local vegetation scattered throughout the proposed project. Soil visibility was moderate across the site, ranging from 30 to 50 percent. Obstruction of the soil was due to the high volume of modern debris and tall grass. Observed soils were largely composed of dark gray-brown sand with inclusion of gravel-like rocks and quartz.

Survey conditions were documented using digital photographs and field notes. During the survey, Mr. Williams examined all areas of the exposed ground surface for prehistoric artifacts (e.g., fireaffected rock, milling tools, flaked stone tools, tool-making debris, ceramics), soil discoloration and depressions that might indicate the presence of a cultural midden, faunal and human osteological remains, and features indicative of the former presence of structures or buildings (e.g., postholes, standing exterior walls, foundations) or historic debris (e.g., glass, metal, ceramics). All areas of the project site were closely inspected for culturally-modified soils or other indicators of potential historic or prehistoric resources. No historic or prehistoric cultural resources or raw materials commonly used in the manufacture of tools (e.g., obsidian, Franciscan chert) were observed. The surface was littered with modern debris and garbage.

Emm Property Project: On April 15, 2022, FCS Archaeologist Natalie Adame conducted a pedestrian survey for the adjacent Emm Property. The survey began on the southwest corner of the project site and moved east, using north–west transects spaced at 15-meter intervals whenever possible. The project site was undeveloped and consisted of relatively flat grassy area, with soil visibility of native soils ranging from 10 percent to 5 percent in areas where bioturbation activities had taken place. Soil composition was made up of dark yellowish brown silty sand (10YR 4/4). Because of the proximity to West Pioneer Avenue and Citrus Valley High School, there was scattered modern debris along the edges of the property. To the extent possible, all areas of the project site were inspected for culturally-modified soils or other indicators of potential historic or prehistoric resources. No prehistoric or historic resources or raw materials commonly used in the manufacture of tools (e.g., obsidian, Franciscan chert, etc.) were found within the project site.

Survey conditions were documented using digital photographs and field notes. During the survey, Ms. Adame examined all areas of the exposed ground surface for prehistoric artifacts (e.g., fireaffected rock, milling tools, flaked stone tools, tool-making debris, ceramics), soil discoloration and depressions that might indicate the presence of a cultural midden, faunal and human osteological remains, and features indicative of the former presence of structures or buildings (e.g., postholes, standing exterior walls, foundations) or historic debris (e.g., glass, metal, ceramics. No cultural resources were encountered. Pedestrian survey photos can be found in Appendix D.

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MLC Holdings, Inc.—Song and Emm Properties Project
Results Phase I Cultural Resources Assessment
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3.2.1 - Buried Site Potential
In addition to the pedestrian survey, the potential for yet-identified cultural resources in the vicinity was reviewed against geologic and topographic geographic information system data for the general area and information from other nearby projects. The proposed project was evaluated against a set of criteria identified by a geoarchaeological overview of the Central Valley that was prepared for the California Department of Transportation (Caltrans) Districts 6 and 9 (Meyer et al. 2010). This study mapped the “archaeological sensitivity,” or potential to support the presence of buried prehistoric archaeological deposits, throughout the Central Valley based on geology and environmental parameters including distance to water and landform slope. The methodology used in the study is applicable to other parts of California and concluded that sites consisting of flat, Holocene-era deposits in close proximity to water resources had a moderate to high probability of containing subsurface archaeological deposits when compared to earlier Pleistocene deposits situated on slopes or further away from drainages, lakes, and rivers.

The project site is situated on undeveloped land. According to the geological map of Matti et al. (2003), the project site is entirely situated upon Holocene axial-valley deposits. Applying the criteria set forth above, all Holocene-era deposits have the potential to contain archaeological deposits, which increases with the ease of the slope and proximity to a water resource (Santa Ana River). This, coupled with the presence of known prehistoric resources near the project site, as well as positive SLF results indicates moderate to high potential for unanticipated buried cultural resources to be impacted by project construction.

Redlands Regular meeting of 12-19-23 1008 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Phase I Cultural Resources Assessment Summary and Recommendations FirstCarbon Solutions 25 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/4940/49400030/Phase I CRA/edit/49400030 Song and Emm Properties Project PI-CRA.docx SECTION 4: SUMMARY AND RECOMMENDATIONS

4.1 - Summary
In accordance with CEQA regulations, FCS assessed the effects of development on the proposed project site. Results from the SCCIC indicate that 22 cultural resources (two prehistoric resources and 20 historic resources) are located within the 0.5-mile search radius; none are located within the project site. There are 31 area-specific survey reports on file with the SCCIC, none of which address the project site, indicating that the project site has not been previously surveyed for cultural resources.

The results of the pedestrian field survey failed to identify additional unrecorded cultural resources within the project site.

The NAHC Sacred Lands File search regarding potential TCRs that may be adversely affected by the proposed project contained positive results. Subsequent correspondence with Native American representatives resulted in three responses from the Quechan Tribe of the Fort Yuma Reservation, San Manuel Band of Mission Indians, and Agua Caliente Band of Cahuilla Indians. No additional responses have been received to date.

4.2 - Recommendations

4.2.1 - Cultural Resources Recommendations
Based on the results of the positive Sacred Lands File search from the NAHC, the SCCIC records searches, archival research, and pedestrian survey, FCS considers the potential for the proposed project to have an adverse effect on historic and/or prehistoric cultural resources to be moderate.

While there are no recorded resources within the project site, 20 historic resources and two prehistoric resources have been recorded within the 0.5-mile search radius. In addition, the site has not been previously surveyed for archaeological resources and its topography increases the possibility that subsurface archaeological resources may be encountered during project construction.

For this reason, FCS recommends that a qualified Archaeologist who meets the Secretary of Interior’s Professional Qualification Standards for Archaeology perform an inspection of the site following grubbing, ground clearing, and prior to any grading or project-related ground disturbance.

In the event exposed soils indicate cultural materials may be present, this may be followed by regular or periodic “spot check” archaeological monitoring as determined by the Archaeologist, but full-time archaeological monitoring is not recommended at this time. Additional procedures for the inadvertent discovery of human remains and cultural resources are provided below.

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4.3 - Inadvertent Discovery Procedures

4.3.1 - Accidental Discovery of Human Remains
There is always the possibility that ground-disturbing activities during construction may uncover previously unknown buried human remains. Should this occur, Section 7050.5 of the California Health and Safety Code applies, and the following procedures shall be followed.

In the event of an accidental discovery or recognition of any human remains, Public Resources Code Section 5097.98 must be followed. In this instance, once project-related earthmoving begins and if there is accidental discovery or recognition of any human remains, the following steps shall be taken:

1. There shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until the County Coroner is contacted to determine whether the remains are Native American and if an investigation of the cause of death is required. If the coroner determines the remains to be Native American, the coroner shall contact the NAHC within 24 hours, and the NAHC shall identify the person or persons it believes to be the “most likely descendant” of the deceased Native American. The most likely descendant may make recommendations to the landowner or the person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in Public Resources Section 5097.98, or

2. Where the following conditions occur, the landowner or his/her authorized representative shall rebury the Native American human remains and associated grave goods with appropriate dignity either in accordance with the recommendations of the most likely descendant or on the project site in a location not subject to further subsurface disturbance:
• The NAHC is unable to identify a most likely descendant or the most likely descendant failed to make a recommendation within 48 hours after being notified by the NAHC; • The descendant identified fails to make a recommendation; or • The landowner or his authorized representative rejects the recommendation of the descendant, and the mediation by the NAHC fails to provide measures acceptable to the landowner.

Additionally, California Public Resources Code Section 15064.5 requires the following relative to Native American Remains:
• When an initial study identifies the existence of, or the probable likelihood of, Native American Remains within a project site, a lead agency shall work with the appropriate Native Americans as identified by the Native American Heritage Commission as provided in Public Resources Code Section 5097.98. The applicant may develop a plan for treating or disposing of, with appropriate dignity, the human remains, and any items associated with Native American Burials with the appropriate Native Americans as identified by the Native American Heritage Commission.

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MLC Holdings, Inc.—Song and Emm Properties Project
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4.3.2 - Accidental Discovery of Cultural Resources
It is always possible that ground-disturbing activities during construction may uncover previously unknown, buried cultural resources. In the event that buried cultural resources are discovered during construction, operations shall stop in the immediate vicinity of the find and a qualified Archaeologist shall be consulted to determine whether the resource requires further study. The qualified Archaeologist shall make recommendations to the Lead Agency on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines.

Potentially significant cultural resources consist of but are not limited to stone, bone, fossils, wood, or shell artifacts or features, including hearths, structural remains, or historic dumpsites. Any previously undiscovered resources found during construction within the project area should be recorded on appropriate California Department of Parks and Recreation (DPR) forms and evaluated for significance in terms of CEQA criteria.

If the resources are determined to be unique historic resources as defined under Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by the Archaeological Monitor and recommended to the Lead Agency. Appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds.

No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any archaeological artifacts recovered as a result of mitigation shall be donated to a qualified scientific institution approved by the Lead Agency where they would be afforded long-term preservation to allow future scientific study.

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Bean, L.J. and C.R. Smith. 1978. Serrano. In R.F. Heizer, (ed.), Handbook of North American Indians, Vol. 8: California. Washington, D.C.: Smithsonian Institution.

Bean, Lowell John and Katherine Siva Saubel. 1972. Temalpakh: Cahuilla Indian Knowledge and Use of Plants. Malki Museum, Banning, California.

Bean, Lowell John. 1972. Mukat’s People: The Cahuilla Indians of Southern California. University of California Press, Berkeley.

Bean, Lowell John. 1978. Cahuilla. In Handbook of North American Indians, Volume 8, California.

Edited by Robert F. Heizer, pp. 575-587. W.C. Sturtevant, general editor. Smithsonian Institution, Washington, DC.

Beardsley, R.K. 1948. “Cultural Sequences in Central California Archaeology.” American Antiquity 14:1-28.

Beattie, G.W., 1923. San Bernardino valley in the Spanish period. Annual Publication of the Historical Society of Southern California, 12(3), pp. 10-28.

Beattie, George W. and Helen P. Beattie. 1974. Heritage of the Valley: San Bernardino’s First Century. Biobooks: Oakland.

Beck, C. and G. T. Jones. 2010. Clovis and Western Stemmed: Population migration and the meeting of two technologies in the Intermountain West. American Antiquity 75:81–116.

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Burgess, Larry E., and Gonzales, Nathan D. 2004. Images of America: Redlands. A.K. Smiley Public Library. Arcadia Publishing.

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Redlands Regular meeting of 12-19-23 1013 of 1429
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References Phase I Cultural Resources Assessment
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Glennan, William S. 1972. The Hypothesis of an Ancient, Pre‐Projectile Point Stage in American Prehistory: Its Application and Validity in Southern California. Unpublished Anthropology doctoral dissertation, University of California, Los Angeles.

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Appendix A:

Professional Qualifications
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www.FirstCarbonSolutions.com CORPORATE RESUME
STEFANIE E. GRIFFIN, MA—STAFF ARCHAEOLOGIST

OVERVIEW
• More than 13 years of experience
Education
• Master of Arts, Interdisciplinary Studies in Prehistoric Archaeology, California State University, Stanislaus, CA
• Bachelor of Arts, Anthropology, Concentration in Prehistoric Archaeology, California State University, Stanislaus, CA
Programs
• ESRI Arc View and Arc Map
Professional Affiliations
• President, National Board of Directors, Upsilon Kappa Delta Multicultural Sorority, Inc., 2009–2015 Stefanie E. Griffin, MA, has more than 13 years of experience in anthropology and archaeology, which she gained from laboratory and field experience. She has worked with private companies and public agencies throughout California and this strengthened her knowledge of CEQA and NEPA policies. She has excellent writing, research, and organizational skills which have aided her when assigning primary and trinomial numbers for archaeological projects for counties in Central California and the development and application of cataloging systems.

RELATED EXPERIENCE AND CLIENT SUMMARY
Ritz-Carlton Napa Valley Resort Hotel Napa Data Recovery of CA-NAP-928, Napa, CA FCS is currently assisting the US Army Corps of Engineers (USACE) with the data recovery of CA-NAP-928.

FCS’s Dana DePietro, PhD, RPA, as Principal Investigator, is implementing the Memorandum of Agreement (MOA) and Historic Properties Treatment Plan (HPTP) for the Ritz-Carlton Napa Valley Resort Project, which was determined to have an adverse effect on the prehistoric site CA-NAP-928. The project proponent is a private developer whose application for the hotel site (which included a wetland) prompted Section 106 review by the USACE, San Francisco District. The project would result in the complete displacement of CA-NAP-928, which was determined eligible for listing in the National Register of Historic Places under criterion D for its data potential. To address this adverse effect, the USACE and the California State Historic Preservation Office executed a MOA calling for the implementation of the HPTP. Treatment includes data recovery of the large, complex, multi-period site, involving the analysis of macrobotanical remains, lithics, fire-affected rock, obsidian hydration analysis, C-14 dating, and the treatment and recovery of faunal and human osteological remains. FCS is also working closely with Scott Gabaldon, the Chairperson of the Mishewal Wappo Tribe of Alexander Valley, who has been designated Most Likely Descendant by the Native American Heritage Commission. Mr. Gabaldon has assigned one Native American monitor to be present at the site during all ground-disturbing activities. Ms. Griffin serves as Laboratory Director and Coordinator, developing and applying a cataloging system for all Redlands Regular meeting of 12-19-23 1019 of 1429
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STEFANIE E. GRIFFIN, MA—STAFF ARCHAEOLOGIST
features, artifacts, and ecofacts associated with field and laboratory processing. She also facilitates data sets for the initial write-ups for phases two to five of excavation and budgeting.

Basin “EN” Construction Project Cultural Resources for the Fresno Metropolitan Flood Control District, City of Fresno, CA
The Fresno Metropolitan Flood Control District is proposing to acquire and construct a stormwater basin adjacent to Garfield and Gettysburg Avenues in Fresno, California. The project site is 16.80 acres and involves phased excavation to 25 feet below ground surface for the purposes of capturing and recharging stormwater. FCS is providing biological and cultural resource services to evaluate the potential biological effects of the project, and whether any cultural resources are present at the site for the purposes of complying with CEQA. Ms. Griffin will assist the District by providing assessments for cultural resources.
7190 Trenton/Healdsburg Road Project Biological and Cultural Resources Assessments for Green Qi, Sonoma County, CA
Ms. Griffin supported cultural resource assessment efforts for the 7190 Trenton/Healdsburg Road Project. The proposed project includes the renovation and expansion of an existing barn and cultivation of approximately 1 acre. The exact locations of these facilities have not yet been determined. As such, a comprehensive study was conducted.

Elk Grove Mixed-Use Development Air Quality and Cultural Studies for The Planning Associates Group, City of Sacramento, CA
Ms. Griffin provided cultural resource assessment services for a 2.57-acre site consisting of undeveloped land located in Sacramento, California. The site is bounded by a commercial development to the north, multifamily residential development to the south, and West Stockton Boulevard to the east. The project applicant is proposing to develop a four-story, 92-unit building with 5,200 square feet of commercial space, an 800-square-foot leasing office, and a 3,560-square-foot clubhouse.

Field Technician III, Stockton East Water District Project, InContext, City of Stockton, CA Ms. Griffin performed Phase I initial shovel testing for municipal infrastructure development.

Field Technician, Borello Excavation Project, LSA Associates, Inc., City of Morgan Hill, CA Ms. Griffin assisted with the rapid recovery excavation of human remains in compliance with Section 106.

Field Technician/Monitor, Southern California Edison 16-1002 Hazardous Tree Removal Program and Drought-Related Hazardous Tree Program, Environmental Intelligence, LLC, Sequoia National Forest and Sierra National Forest, CA
Ms. Griffin was first credential selection for the archaeological division of the company to lead the tree removal program in Sequoia and Sierra National Forests.

Redlands Regular meeting of 12-19-23 1020 of 1429
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STEFANIE E. GRIFFIN, MA—STAFF ARCHAEOLOGIST
Field Technician, #2159 Sunpower SCL-68, Far Western Anthropological Research Group, Inc., City of San Jose, CA
Ms. Griffin assisted with the excavation project for a previously recorded prehistoric site.

Field Technician, Crowder Canyon Data Recovery, Cogstone Resource Management, Inc. and Applied EarthWorks, Inc., Phelan, CA
Ms. Griffin performed excavation and data recovery of previously recorded prehistoric sites that were to be demolished for the California Department of Transportation expansion highway project.

Field Technician A, BUT 1123 Feather River West Levee Project, Far Western Anthropological Research Group, Inc., Biggs, CA
Ms. Griffin performed excavation, data recovery, laboratory analysis, and artifact processing for the USACE and Enterprise Tribal Group.

Field Technician, Forebay Dam Project 21250.01, ASM Affiliates, Inc., Pollock Pines, CA Ms. Griffin tested and evaluated a 20th century work camp site in El Dorado County, located within the area of potential effects of the El Dorado Forebay Dam Modification Project.

Field Technician A, Feather River West Levee Project, Far Western Anthropological Research Group, Inc., Gridley, CA
Ms. Griffin reviewed residual materials, sent from the field to the laboratory, to identify all cultural artifacts; inventoried field unit artifacts in preparation for entry into the access database; performed records management; and organized and prepared artifacts to be transported and analyzed.

Field Technician B, #1944 Moke 3700-Acre Survey, Far Western Anthropological Research Group, Inc., Pioneer, CA
For Bear River Lake Resorts, Inc.’s project, Ms. Griffin conducted an archaeological survey for the US Forest Service.

Field Technician, Middle Creek Stewardship Project 23190, ASM Affiliates, Inc., Susanville, CA Ms. Griffin assisted with Class II and Class III pedestrian surveys of 6,491 acres for the Bureau of Land Management project.

Field Technician, #1868 Mendocino Headlands Project, Far Western Anthropological Research Group, Inc., Mendocino, CA
Ms. Griffin performed exploratory excavation of shovel test units of prehistoric and historic sites.

Field Technician, #1873 Pacific Gas & Electric L107 Fremont Test Project, Far Western Anthropological Research Group, Inc., Fremont, CA
Ms. Griffin assisted in the excavation of a prehistoric site.

Redlands Regular meeting of 12-19-23 1021 of 1429
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STEFANIE E. GRIFFIN, MA—STAFF ARCHAEOLOGIST
Field Technician A, Feather River West Levee Project, Far Western Anthropological Research Group, Inc., Live Oak, CA
Ms. Griffin participated in monitoring backhoe excavation for construction purposes, unit excavation of prehistoric and historic artifacts, review of residual materials sent from the field to the laboratory to identify all cultural artifacts, preparation of inventory of field unit artifacts for entry into the access database, records management, and organization and preparation of artifacts to be transported for analysis.

Field Technician, Sand Pass Project, Enviroscientists, Inc., Winnemucca, NV Ms. Griffin performed a 650-acre survey of previously recorded historic sites outside Winnemucca, Nevada, particularly on a private land in Silver State Valley.

Field Technician, NAS Base Fallon Project, ASM Affiliates, Inc., Fallon, NV Ms. Griffin performed testing and data recovery on training ranges in 37 sites, which ranged from the Paleoindian to Late Archaic eras and included historic materials.

Field Technician, Summit Exploration Survey, ASM Affiliates, Inc., Wells, NV Ms. Griffin participated in a notice-level clearance survey of five drill pads and associated access roads of a Class III inventory of 750 acres.

Jordan Archaeological Project of La Sierra University, Riverside, Jordan Ms. Griffin participated in the excavation field school’s program, which involves one of three archaeological sites currently being excavated by the Madaba Plains Project in Jordan.

Proyecto Arqueológico Regional El Paraiso, Honduras
Ms. Griffin participated in this Honduras archaeological project, which entailed excavations at several Late Classic Period (425–825 AD) sites. She also conducted raw mineral surveys of El Paraiso Valley.

Anthropological Studies Center, Sonoma State University, City of Rohnert Park, CA As Laboratory Assistant II, Ms. Griffin processed artifacts through cleaning, sorting and inventory. She also performed historic artifact reconstruction and collection management.

Central California Information Center, California Historical Resources Information System, California State University, Stanislaus, City of Turlock, CA
As Student Intern and Student Assistant, Ms. Griffin participated in the operations of the Central California Information Center by overseeing seven counties in Central Valley. This role entailed data processing of reports, records, and hard-copy and electronic database entries. She also directed Geographic Information System data input, such as mapping and scanning of documents, and performed quality control. Ms. Griffin conducted archaeological investigations, specifically field surveys, excavations, and laboratory analysis, for California Department of Forestry and Fire Protection (CAL FIRE) projects.

Redlands Regular meeting of 12-19-23 1022 of 1429
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STEFANIE E. GRIFFIN, MA—STAFF ARCHAEOLOGIST
California Department of Transportation District 10, City of Stockton, CA As Student Intern for the Environmental Planner-Archaeologist, Ms. Griffin assisted in the completion of projects and, to ensure efficiency of day-to-day tasks, filed and maintained the inventory of tracking systems of project materials. She assisted the Archaeologist with writing letters to Native American tribe consultants/monitors and participated in archaeological field surveys.

Previous Administrative Experience
Central California Information Center, City of Turlock, CA Ms. Griffin served as Assistant Administrator where she managed the processing of archaeological reports for cultural resource management firms and corresponded with the California State Historic Preservation Office to comply with Section 106 of the Historical Preservation Act (HPA). In her previous role as Assistant Lab Administrator, she processed archaeological material for CAL FIRE to comply with Section 106 of the HPA.

California Department of Transportation District 10
Ms. Griffin was an Office Assistant to the Environmental Planner for Archaeology where she wrote correspondences to the Tribal Historical Preservation Office.

Publications
E Griffin, Stefanie (2013) “Building the Maya World: Raw Materials, Trade Routes, and Procurement Strategies in the El Paraiso Valley, Copan, Honduras”, California State University Stanislaus Press.

Redlands Regular meeting of 12-19-23 1023 of 1429
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KWEKU WILLIAMS, MA, RPA—ARCHAEOLOGICAL MONITOR

OVERVIEW
• More than 12 years of experience
Education
• Master of Arts, Archaeology and Physical Anthropology, Northern Illinois University, DeKalb, IL, 2014
• Bachelor of Arts, Anthropology and World History, Cum Laude, State University of New York, Albany, NY, 2010
License
• Registered Professional Archaeologist, License No. 17953, 2019 Affiliations
• Phi Beta Delta Honor Society for International Scholars, 2012 to present • Lambda Alpha National Anthropology Honor Society, 2009 to present Awards and Fellowships
• Superior Exhibit Award for Trowels and Fair Trade: Revealing the Underground Railroad and Contemporary Slavery exhibit, Anthropology Museum, Northern Illinois University, Illinois Association of Museums, IL, 2013
• Rhoten A. Smith Fellowship, Northern Illinois University, DeKalb, IL, 2012–2014 • Anthropology Foundation Fund Award, Northern Illinois University, DeKalb, IL, 2012 Kweku Williams, MA, RPA, is a Registered Professional Archaeologist (License No. 17953) with more than 12 years of experience specializing in archaeology and physical anthropology. He possesses knowledge on excavation practices, artifact analysis, and osteology. Mr. Williams has worked on the field in sites around the US and parts of Europe, as well as in the academe where he served as Adjunct Professor in Anthropology at Berkeley City College, Berkeley, California, and Las Positas College, Livermore, California.

RELATED EXPERIENCE AND CLIENT SUMMARY
FirstCarbon Solutions
Tulocay Cemetery Project for Holman Teague Roche Anglin, LLP Archaeological Monitoring, City of Napa, CA
FCS provided archaeological monitoring for excavations during boundary determination testing at Tulocay Cemetery. Mr. Williams served as Archaeological Monitor.

Redlands Regular meeting of 12-19-23 1024 of 1429
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KWEKU WILLIAMS, MA, RPA—ARCHAEOLOGICAL MONITOR
Ritz-Carlton Napa Valley Resort Hotel Project Data Recovery of CA-NAP-928, City of Napa, CA FCS is currently assisting the US Army Corps of Engineers (USACE) with the data recovery of CA-NAP-928.

FCS is implementing the Memorandum of Agreement (MOA) and Historic Properties Treatment Plan (HPTP) for the Ritz-Carlton Napa Valley Resort Project, which was determined to have an adverse effect on the prehistoric site CA-NAP-928. The project proponent is a private developer whose application for the hotel site (which included a wetland) prompted Section 106 review by the USACE, San Francisco District. The project would result in the complete displacement of CA-NAP-928, which was determined eligible for listing in the National Register of Historic Places under criterion D for its data potential. To address this adverse effect, the USACE and the California State Historic Preservation Officer executed an MOA calling for the implementation of the HPTP. Treatment includes data recovery of the large, complex, multi-period site, involving the analysis of macrobotanical remains, lithics, fire-affected rock, obsidian hydration analysis, C-14 dating, and the treatment and recovery of faunal and human osteological remains. FCS is also working closely with Scott Gabaldon, the Chairperson of the Mishewal Wappo Tribe of Alexander Valley, who has assigned one Native American monitor to be present at the site during all ground-disturbing activities. Mr. Williams is providing archaeological testing and monitoring services for the project.

Previous Field Experience
Applied EarthWorks, Inc. and Cogstone Resource Management, Inc., Crowder Canyon, San Bernardino County, CA
Mr. Williams worked with Applied EarthWorks, Inc. and Cogstone Resource Management as a Field Technician on the Project State Route Realignment—Crowder Canyon Data Recovery Project for California Department of Transportation (Caltrans).

Schoharie Valley Field School, State University of New York, Albany, NY Mr. Williams received training in archaeological techniques in surveying, excavation, and artifact analysis and preservation from Dr. Christina Rieth.

Cultural Resources Survey Program, New York State Museum, New York, NY Under the supervision of Dr. Christina Rieth, Mr. Williams served as Archaeological Field Technician and conducted archaeological surveys and excavation for the New York State Museum.

Far Western Anthropological Research Group, Multiple Locations As Field Technician, Mr. Williams’ work included excavation and osteological recovery in compliance with the Native American Graves Protection and Repatriation Act with the Enterprise people; excavation testing for infrastructure development in Camp Pendleton for the Department of Defense; excavation and teaching demonstration in archaeological practices at Camp Tawonga, California; excavation and boundary site testing for a known archaeological site in Aliso Creek for the USACE; test excavation at Mariposa Leach Field for the US Forest Service (USFS); artifact processing for the Feather River West Levy project of the USACE and the Enterprise Tribal Group; the Moke 3700-Acre Survey in Pioneer, California for the USFS; the Onyx Ranch Survey in Mojave, California, for the Bureau of Land Management; Goleta Data Recovery for the Caltrans; archaeological field surveys, monitoring, and Redlands Regular meeting of 12-19-23 1025 of 1429
www.FirstCarbonSolutions.com CORPORATE RESUME
KWEKU WILLIAMS, MA, RPA—ARCHAEOLOGICAL MONITOR
excavation/burial recovery for the Feather River West Levee Project in Live Oak, California; and archaeological field surveys and excavation in Mariposa Grove at the Yosemite National Park.

Ka’Kabish Field School, Orange Walk, Belize
Through Trent University, Canada, Mr. Williams worked with Dr. Helen Haines as Crew Chief and Field Manager at the Ka’Kabish Field School in the province of Orange Walk, Belize.

Archaeological Field School in Salemi, Sicily, Italy
Through Northern Illinois University’s Archaeological Field School, Mr. Williams collected data for his Master’s thesis and received further training in archaeological techniques in surveying, excavation, and artifact analysis and preservation from Dr. Michael Kolb.

Hydro-archaeology Project, Universidad de Granada, Andalusia, Spain Mr. Williams assisted Dr. José Maria Cervantes in mapping waterways in Andalusia, Spain.

Academic Positions
Berkeley City College, Berkeley, CA
Mr. Williams served as Adjunct Professor in Anthropology, teaching Introduction to Physical Anthropology, Introduction to Cultural Anthropology, and Introduction to Archaeology.

Las Positas College, Livermore, CA
Mr. Williams served as Adjunct Professor in Anthropology teaching Introduction to Physical Anthropology, Introduction to Cultural Anthropology, Introduction to Forensic Anthropology, and Introduction to Archaeology.

Archaeology Camp, College of Liberal Arts and Science, Northern Illinois University, DeKalb, IL Mr. Williams served as Co-coordinator and Counselor for the Archaeology Camp of the College of Liberal Arts and Science in Northern Illinois University, DeKalb.

Anthropology Museum, Northern Illinois University, DeKalb, IL Mr. Williams served as Graduate Assistant in Northern Illinois University, DeKalb’s Anthropology Museum, where he coordinated the exhibit development team, provided tours and lectures on the content of exhibits, and fostered appreciation for education and cultural diversity. He also assisted in the development and installation of the Fast Food Nation: 10,000 B.C. and Trowels and Fair Trade:

Revealing the Underground Railroad and Contemporary Slavery exhibits.

Department of Anthropology, Northern Illinois University, DeKalb, IL As Teaching Assistant, Mr. Williams taught Introduction to Physical Anthropology, where he discussed The Life History and Social Behavior of the Mountain Gorilla, and Exploratory Archaeology, where he discussed The Rise of the City States of Mesopotamia, The Bronze Age in the Western Mediterranean, and Classic Period of the Maya Lowlands.

Redlands Regular meeting of 12-19-23 1026 of 1429
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KWEKU WILLIAMS, MA, RPA—ARCHAEOLOGICAL MONITOR
Ka’Kabish Field School, Orange Walk, Belize
Through Trent University, Canada, Mr. Williams served as Field School Instructor where he provided students with the essentials for archaeological studies, such as laying out units, mapping (plan view and profile), calculating elevations and stadia metric distances, the essentials of logistical management of unit forms, proper notetaking in field journals, and the collection and labeling of artifact bags.

Academic Events and Speaking Engagements
• Learning Community Revolutionary Scholars First Year Experience, Berkeley City College, Berkeley, CA, Fall 2017
• Panelist on the Islamophobia Open Talk, Muslim Student Association and Peace and Social Justice Student Association, Las Positas College, Livermore, CA, Fall 2016 • Panelist on the African-American Science, Technology, Engineering, and Math Panel, Black Student Union, Las Positas College, Livermore, CA, Spring 2016
• Midwestern Mesoamerican Archaeological Conference, Northern Illinois University, DeKalb, IL, Spring 2014
Community Service
Mr. Williams participated in Northern Illinois University Cares Day where he participated in the beautification of DeKalb historical landmarks and public parks.

Publications
Williams, K.A. (2014). Space and Specialization: Understanding the Medieval Economic Behavior through Ceramics in Salemi, Sicily (master’s thesis). Northern Illinois University, Illinois, United States.

Redlands Regular meeting of 12-19-23 1027 of 1429
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NATALIE ADAME—ARCHAEOLOGICAL MONITOR

OVERVIEW
• More than 2 years of experience
Education
• Bachelor of Arts, Biological Anthropology, Minor in Geology, California State University, East Bay, Hayward, CA, 2016
• Associate of Arts, Geology, Mt. San Antonio College, Walnut, CA, 2011 Skill
• Esri Aeronautical Reconnaissance Coverage Geographic Information System (ArcGIS) Natalie Adame has more than 2 years of experience in archaeology, which she gained from extensive fieldwork and museum experience. Ms. Adame has established excellent research skills exemplified by her ability to prepare comprehensive reports and presentations. Her experience includes performing land use analyses and preparing Initial Studies and EIRs for various development projects. As an Archaeological Monitor/Field Technician, Ms. Adame implements Worker Environmental Awareness Programs (WEAP) ‘tailgate’ training sessions and coordinates with construction staff and Native American Monitors, construction monitoring, and the salvage and recordation of archaeological resources.

RELATED EXPERIENCE AND CLIENT SUMMARY
Biological, Archaeological, and Paleontological Monitoring and Reporting Services, Los Angeles Regional Interoperable Communications System, Los Angeles County, CA FCS is providing monitoring and reporting services during the construction of more than 150 land mobile radio (LMR) facilities at sites located primarily in Los Angeles County. The LMR sites contain the infrastructure and equipment necessary to provide voice communications coverage throughout the County for emergency responders. These locations are widely dispersed across the County in both urban (intensively developed) and rural (less developed) settings and include coastal locations, sites in downtown Los Angeles, remote mountain peaks across the County, and the northern high desert. FCS is conducting the biological, archaeological, and paleontological pre-construction and construction monitoring and reporting services in accordance with the Construction Management Requirements outlined in the NEPA Environmental Assessment that FCS prepared for the project. Ms. Adame is a Field Archaeological Monitor on the project.

Barton Road Logistics Facility Project EIR, Technical Studies, and Peer Review, City of Colton, CA FCS is providing CEQA documentation and peer review services for the Barton Road Logistics Facility Project in the City of Colton, in San Bernardino County. The proposed project includes the demolition of four industrial buildings, an office building, and parking lot. The proposed project would construct two state-of-the-art speculative concrete tilt-up industrial warehouse logistics facilities with a total square footage of 960,040 square feet. The project will develop Best-in-Class industrial facilities in the City of Colton that are designed to meet contemporary industry standards, can easily accommodate a wide Redlands Regular meeting of 12-19-23 1028 of 1429
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NATALIE ADAME—ARCHAEOLOGICAL MONITOR
variety of warehouse and distribution uses, and are economically competitive with similar warehouse facilities in the local Inland Empire marketplace. FCS is preparing an EIR with supporting stand-alone Air Quality and Greenhouse Gas (GHG) Emissions Analysis with Health Risk Assessment, Biological Resources Assessment, Phase I Cultural Resources Assessment (CRA), Noise Impact Analysis, and Traffic Impact Analysis. Our team will also peer review the Geotechnical Report. The Phase I Cultural Resources Assessment will provide an evaluation and recommendations regarding potential construction related impacts to cultural resources. Ms. Adame is a Field Archaeological Monitor on the project.

Library/Learning Resource Center Building Project Biological and Cultural Construction Monitoring Services for the Solano Community College District, Fairfield, CA FCS prepared the IS/MND and provided the subsequent biological and cultural construction monitoring services for the construction of a new 59,252-gross-square-foot, 2-story Library/Learning Resources Center building on the Fairfield Campus of the Solano Community College Campus. The building would be constructed on an open quad in the center of campus, replacing an open lawn. FCS conducted AB 52 consultation in coordination with the District and tribal representatives from the Yocha Dehe Wintun Nation to address concerns about tribal cultural resources in the immediate vicinity of the site. In additional to preparing a full PI-CRA, FCS drafted mitigation measures in coordination with the Tribe and District to effectively allow the project to proceed while protecting the Tribal Cultural resources in question. The District approved the project in May 2016, with the approval of the tribe and all parties involved. FCS will provide coordination with Tribal representatives from the Yocha Dehe Wintun Nation, as well as a “tailgate” sensitivity training session for construction personnel. Ms. Adame is a Field Archaeological Monitor on the project.

Prior Work Experience
Archaeologist, Material Culture Consulting, City of Pomona, CA As an archaeologist, Ms. Adame performed excavations, recorded prehistoric and historic artifacts, and catalogued data using ArcGIS. She conducted Phase I, II, and III Environmental Site Assessments (ESAs) and drafted EIRs. Ms. Adame also prepared Department of Parks and Recreation (DPR) forms, searched records, and monitored projects in the State and county.

Field Archaeologist, ICF International, City of Los Angeles, CA As a field archaeologist, Ms. Adame conducted environment surveys, performed excavations, and catalogued prehistoric and historic artifacts using ArcGIS. She prepared Federal Environment Management environmental reviews, DPR forms, and ESAs. Ms. Adame also worked with different transportation agencies, including the Orange County Transportation Authority, OC 405 Partners, LA Metro, and the California Department of Transportation.

Field Archaeologist, Dudek , City of Pasadena, CA
As a field archaeologist, Ms. Adame performed architectural and cultural historical assessments and conducted surveys for various projects to evaluate conflicts during construction period. Her responsibilities also include evaluating historic resource significance, cataloguing exhibit pieces, and gathering daily records of environmental compliances.

Redlands Regular meeting of 12-19-23 1029 of 1429
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NATALIE ADAME—ARCHAEOLOGICAL MONITOR
Grants and Proposal Writer – Applied Anthropology Coursework, California State University, East Bay, City of Hayward, CA
As a Grants and Proposal Writer, Ms. Adame analyzed organizational cultures, conducted needs assessment, and prepared social impact reports. Part of her task was to identify the appropriate research disciplines necessary for specific jobs.

Student Museum Docent, California State University, East Bay, City of Hayward, CA Ms. Adame served as a docent at the university’s C.E. Smith Museum of Anthropology. Her responsibilities include preparing materials for exhibits, researching and writing about artifacts, and mounting display materials in the museum.

Redlands Regular meeting of 12-19-23 1030 of 1429
MLC Holdings, Inc.—Song and Emm Properties Project
Phase I Cultural Resources Assessment
FirstCarbon Solutions
Appendix B:

South Central Coastal Information Center Records Search Results Appendix B contains sensitive information pertaining to cultural resources and has been withheld from public distribution pursuant to Public Resources Code, Sections 5097.9 and 5097.993.

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MLC Holdings, Inc.—Song and Emm Properties Project
Phase I Cultural Resources Assessment
FirstCarbon Solutions
Appendix C:

Native American Heritage Commission and Tribal Correspondence Redlands Regular meeting of 12-19-23 1033 of 1429

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Local Government Tribal Consultation List Request
Native American Heritage Commission
1550 Harbor Blvd, Suite 100
West Sacramento, CA 95691
916-373-3710
916-373-5471 – Fax
[email protected]
Type of List Requested
☐ CEQA Tribal Consultation List (AB 52) – Per Public Resources Code § 21080.3.1, subs. (b), (d), (e) and 21080.3.2 ☐ General Plan (SB 18) - Per Government Code § 65352.3.

Local Action Type:
___ General Plan ___ General Plan Element ___ General Plan Amendment ___ Specific Plan ___ Specific Plan Amendment ___ Pre-planning Outreach Activity Required Information
Project Title:____________________________________________________________________________ Local Government/Lead Agency: ___________________________________________________________ Contact Person: __________________________________________________________________________ Street Address: ___________________________________________________________________________ City:_____________________________________________________ Zip:__________________________ Phone:____________________________________ Fax:_________________________________________ Email:_____________________________________________
Specific Area Subject to Proposed Action
County:________________________________ City/Community: ___________________________ Project Description:

Additional Request
☐ Sacred Lands File Search - Required Information:

USGS Quadrangle Name(s):____________________________________________________________ ____________________________________________________________ Township:___________________ Range:___________________ Section(s):___________________ Redlands Regular meeting of 12-19-23 1035 of 1429
49400030 • 08/2021 | 49400030_re cord_se arch _m ap.m xd Re cord Se arch Map
Source : USGS Re dlands 7.5' Quadrangle / T01S,R03W ,se c16 & 21; Land Grant: San Be rnardino.

CITY OF REDLANDS

REDLANDS SONG P ROP ERTY P ROJECT
I 2,000 1,000 0 2,000Fe e t
Project Area
Half-Mile Radius
Redlands Regular meeting of 12-19-23 1036 of 1429
STATE OF CALIFORNIA Gavin Newsom, Governor

NATIVE AMERICAN HERITAGE COMMISSION