Redlands City Council
December 3, 2024

PROJECT BREACH-TERMINATION
Failure of a Grantee to comply with this MOU or the TGP Regulations shall be treated by DOJ as a breach of contract. If an act of noncompliance occurs, DOJ may take actions described within the TGP Regulations, including termination. DOJ may terminate this MOU and be relieved of any obligation to disburse grant funds to Grantee should Grantee fail to perform the scope of work at the time and in the manner provided in this MOU.

MISCELLANEOUS PROVISIONS
Addendum – No addendum or variation of the terms of this MOU is valid unless made in writing and signed by the duly authorized representatives of the parties.

Assignment – This MOU is not assignable by Grantee in whole or in part.

Indemnification – Grantee agrees to indemnify and hold harmless DOJ, its officers, agents and employees from all claims, liabilities, or losses in connection with the performance of this MOU.

Certifications – Grantee certifies that it does not receive funding from a manufacturer, distributor, or advertiser of Cigarettes or Tobacco Products. Grantee further certifies that grant funds will not supplant existing state or local funds dedicated for the same purpose.

TERMS
Grant Duration: 11/1/2024 – 6/30/2028
Award Amount
Category of Expenditure Budget
FY 2024-2025
Budget
FY 2025-2026
Budget
FY 2026-2027
Budget
FY 2027-2028
Personal Services $21,254 $21,254 $ $
Operating Expenses and
Equipment $320 $320 $ $
Administrative Costs (Not to
Exceed 5%) $0 $0 $ $
TOTAL AWARD AMOUNT $43,148
The time limit for reimbursements against this award ends 6/30/2028. Requests for reimbursement received after 7/15/2028 cannot be considered by DOJ.

GRANTEE CONTACT INFORMATION

JIMMY NGUYEN, MANAGEMENT ANALYST

REDLANDS POLICE DEPARTMENT
PO BOX 1025
909-335-4751
[email protected]
Redlands Regular Meeting of 12-03-24 234 of 875
Redlands Police Department DOJ-PROP56-2024-25-1-055

AUTHORIZATION
DOJ and Grantee, by their duly authorized officials, have executed this MOU on the respective dates indicated below. This MOU and any future addendums shall be e-mailed to [email protected], care of the Division of Operations, Local Assistance Unit, Tobacco Grant Program, and will become fully executed upon completion of signatures from all parties. ___________________________________ ___________________ NAME: Rachel Tolber Date
Title: Chief of Police
Agency: Redlands Police Department
___________________________________ ___________________ NAME: Date
Title:

Agency:
___________________________________ ___________________ NAME: Date
Title:

Agency:
______________________________ ___________________
JENNIFER IVERY JOHNSON, Grant Manager Date
Division of Operations
California Department of Justice
___________________________________ ___________________ NICOLE LEARNED, Administrative Manager Date
Division of Operations
California Department of Justice
__________________________________ ___________________
CHRIS RYAN, Chief Date
Division of Operations
California Department of Justice
Redlands Regular Meeting of 12-03-24 235 of 875
Tobacco Grant Program
GRANT SERVICES BRANCH – LOCAL ASSISTANCE

DIVISION OF OPERATIONS
10/16/2024 Page 1 of 3

TOBACCO GRANT SUMMARY OF AWARD
DOJ-PROP56-2024-25-1-055

REDLANDS POLICE DEPARTMENT
This Summary of Award document will be used by the Tobacco Grant Program when determining whether an activity or expense claimed was approved for funding and is reimbursable. Activities other than those presented here may not be reimbursable. A Grant Modification may be necessary for material deviations. Please consult with your Grant Program Officer before engaging in any activity beyond this scope.

By signing the Memorandum of Understanding, your agency agrees to the commitments outlined below and this document becomes part of the Grant Agreement.

AWARD SUMMARY
Award Amount: $43,148 Requested Amount: $43,148
Removed from Award: N/A Reduced Line Items: N/A
Other Changes or Stipulations: N/A

IMPORTANT PROVISIONS FOR ALL GRANTEES
I. Enforcement Activities
a. Authorized - If enforcement activities were proposed, only activities that target retailers for illegal sales/marketing of tobacco products were approved. It is expected that the flavor ban will be enforced within one or more enforcement activities. b. Unauthorized - Community or school patrols, or other enforcement actions related to tobacco use and possession, are not permitted.

II. Educational Activities
a. Authorized – Retailer and/or officer educational activities on tobacco laws and ordinances, if included, are authorized as noted below. b. Unauthorized – School or community education efforts, including media campaigns, are not permitted as part of this award. All educational efforts should be directed to retailers and/or officers.

III. Removed Personnel or Other Items
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10/16/2024 Page 2 of 3
a. If specific personnel or other items were removed and not funded, they cannot be reinstated during the grant term.

IV. Reduced Line Items
a. If a specific line item was reduced, the intention was to not fully fund it or the activities it represents.

V. Mileage/Fuel
a. Budgets that include mileage or fuel were amended to include both together in one line item for flexibility and the type of backup documentation available. Mileage is limited to the state rate in effect at the time of travel.

VI. Equipment
a. All equipment items must be purchased during the first year of the grant as noted on the Budget Detail. Their awarding is intended to support project goals and be used to support grant activities throughout the grant term.

Please reference the Tobacco Grant Program Grantee Handbook for more information regarding allowable costs.

GOALS AND ACTIVITIES
Per year, 25 retailers will be inspected.

Additional details regarding these inspections:
o There are currently 50 licensed tobacco retail businesses in the City of Redlands and through these operations, all will be inspected within the grant period.

Per year, 4 minor decoy operations will be conducted.

Per year, 50 retailers will be targeted through these operations.

Additional details regarding these operations:
o Redlands Police Department has built a strong relationship with the San Bernardino County District Attorney's Office and have received confirmation these cases will be prosecuted.

Per year, 4 shoulder tap operations will be conducted.

Per year, 50 retailers will be targeted through these operations.

Additional details regarding these operations:
o The San Bernardino County District Attorney's Office has confirmed they are successfully prosecuting these cases.

N/A
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10/16/2024 Page 3 of 3
Per year, 25 retailers will receive educational materials.

Per year, 25 retailers will receive on-site education.

Additional details regarding these retailer education activities:

Per year, 93 enforcement officers will receive education about tobacco laws and ordinances.

Additional details regarding these officer education activities:
o Briefing training for each patrol team and specialized team educating them on current tobacco laws and trends. Officers that assist with the minor decoy, shoulder tap, and retail inspections will also learn tobacco laws through their experience in these operations.

N/A
N/A
N/A

PARTNERING AGENCIES
Based upon the proposal submitted and any subsequent modifications approved by DOJ, the following agencies are expected to partner with and support the activities and fulfillment of goals referenced above:

N/A
Please notify your Grant Program Officer of any proposed changes to partnering agencies, particularly if they are included within your budget.

Redlands Regular Meeting of 12-03-24 238 of 875
Rob Bonta
Attorney General

DIVISION OF OPERATIONS

OFFICE OF THE CHIEF

GRANT SERVICES BRANCH

TOBACCO GRANT PROGRAM
P.O. Box 160187
Sacramento, CA 95816-0187
Telephone: (916) 210-6422
E-Mail Address: [email protected]
October 1 , 2024
Richard Dean McLaughlin, Police Officer
Redlands Police Department
30 Cajon Street
Redlands, CA 92373
Re: Tobacco Grant Award Notification Fiscal Year 2024-25 (RFP: DOJ-PROP56-2024-25-1) Dear: Officer Richard Dean McLaughlin
Congratulations! On behalf of the California Department of Justice (DOJ), Tobacco Grant Program, I am pleased to inform you that your agency’s grant application for the fiscal year 2024-25 grant cycle has been approved for grant funds authorized under the California Healthcare, Research and Prevention Tobacco Tax Act of 2016. The total amount of your agency’s grant award is $43 148.

The Tobacco Grant Program award process is highly competitive, and for the 2024-25 grant cycle, the Department received over $50 million in requests. As noted in the application materials, grant funding prioritized support for local retailer enforcement, including enforcement of flavored tobacco bans. Consequently, some awards were approved with modifications to align with these funding priorities. Attached is a Summary of the Award and Budget Detail outlining the funding provided along with any modifications applied.

To accept the 2024-25 grant award, please complete and return a signed copy of your Letter of Intent (see template and instructions attached) by email within 15 calendar days of the date of this letter. This letter will affirm either:

1. Your agency will seek a resolution from the governing body to accept the award (if your agency has a governing body); OR

2. No governing body exists and no resolution is required.

Please email the signed Letter of Intent as noted above to [email protected] with the subject line including the name of your agency: “FY 24-25_Letter of Intent_Redlands Police Department.” Upon receipt of this information, DOJ will provide your agency with additional documents for execution/use (e.g., Memorandum of Understanding, Governing Body Resolution template, Grantee Handbook, etc.). These documents will contain more information Redlands Regular Meeting of 12-03-24 239 of 875
October 1 , 2024

about the process for reimbursement and other important details. Activities for reimbursement under this grant may commence on or after November 1, 2024 depending upon your selected start date.

Should you have any questions regarding this letter or the required follow up information, please email [email protected].

Sincerely,

JENNIFER IVERY JOHNSON
Manager, Grant Services Branch
For ROB BONTA
Attorney General
Attachments:

Letter of Intent
Summary of Award
Budget Detail
Redlands Regular Meeting of 12-03-24 240 of 875
1 I:\cmo\Resolutions\8640 Authorizing RPD Accept Grant Funds From CA DOJ Tobacco Grant Program.docx-ms RESOLUTION NO. 8640

RESOLUTION AUTHORIZING THE REDLANDS POLICE DEPARTMENT TO ACCEPT GRANT FUNDS IN THE AMOUNT OF $43,148.00 FROM THE STATE OF

CALIFORNIA DEPARTMENT OF JUSTICE, OFFICE OF ATTORNEY GENERAL,

TOBACCO GRANT PROGRAM, AND AUTHORIZING THE AGREEMENT WITH REDLANDS POLICE DEPARTMENT AND AMENDING THE FISCAL YEAR 2025-2026 BUDGET
WHEREAS: The Redlands Police Department (RPD) is interested in participating in the Tobacco Grant Program, which is made available through the California Healthcare, Research and Prevention Tobacco Tax Act of 2016 (Pop. 56) and administered by the California Department of Justice (DOJ) to support local efforts to reduce the illegal sale of tobacco products to minors in the City; and
WHEREAS: Grant funds will be used for RPD overtime costs related to tobacco education and enforcement operations, specifically decoy operations, “shoulder tap” operations, inspections, and educational outreach to tobacco-licensed retailers in the city, and NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Redlands as follows:

Section 1. The Recitals set forth above are true and correct and are incorporated by reference in this Resolution.

Section 2. The Chief of the Redlands Police Department is hereby authorized, on behalf of the City, to accept grant funding in the amount of $43,148.00 from California DOJ; to execute the Memorandum of Understanding (MOU) with the Cal DOJ regarding grant funds; and to execute and submit all other necessary grant documents, including but not limited to agreements, modifications, payment requests, and amendments for the purpose of increasing funding, that may be necessary for the completion of 2025-2026 TGP.

Section 3. This Resolution shall take effect upon adoption.

ADOPTED, SIGNED AND APPROVED this 3rd day of December 2024. ______________________________
Eddie Tejeda, Mayor
ATTEST:
______________________
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 12-03-24 241 of 875
2 I:\cmo\Resolutions\8640 Authorizing RPD Accept Grant Funds From CA DOJ Tobacco Grant Program.docx-ms I, Jeanne Donaldson, City Clerk of the City of Redlands, do hereby certify that the foregoing Resolution was duly adopted by the City Council at a regular meeting thereof held on the 3 rd day
of December, 2024, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
______________________________
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 12-03-24 242 of 875
City Council Meeting I. 13.

DATE: 12/03/2024
TO: Honorable Mayor and City Council Members
SUBJECT: Approve the Memorandum of Understanding with the Inland Regional Narcotics Enforcement Team and authorize the Chief of Police to execute the Memorandum of Understanding (Police Chief Tolber)
MOTION(S):

If the City Council determines that staff’s recommendation is appropriate, the following motions are provided:

I move that City Council approve the Memorandum of Understanding with the Inland Regional Narcotics Enforcement Team; and

1. I further move that City Council authorize the Chief of Police to execute the Memorandum of Understanding.

2. RECOMMENDATION:

Staff recommends that City Council approve the Memorandum of Understanding with the Inland Regional Narcotics Enforcement Team and authorize the Chief of Police to sign the Memorandum of Understanding (MOU).

DISCUSSION:

The Inland Regional Narcotic Enforcement Team (IRNET) is a major narcotic investigation team which is comprised of various San Bernardino County law enforcement officers and is spearheaded by the Sheriff's department. This team is also composed of several Federal and State investigators. By its diversity alone, IRNET has numerous resources that make it a premier investigative unit within the Southern California area. IRNET is the primary means by which the Redlands Police Department addresses the proliferation of dangerous drugs in the community.

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The Redlands Police Department has been a member of IRNET for decades.

Currently, the Department commits one full-time police officer to work with the team. IRNET has stemmed the flow of narcotics to Redlands streets through numerous mid and high- level investigations over the years. The officer assigned to the team gains valuable experience in investigative techniques and develops priceless contacts with local, state and federal partners that have proven useful in all types of investigations. As detailed in the MOU, the assignment of the officer to the team entitles the City to 3.502% of proceeds from assets forfeited during the investigations.

The current IRNET Memorandum of Understanding (MOU) signed by the Redlands Police Department was in December 2022. In October 2024, staff received an updated MOU from IRNET for review by the Department. The updates include guidelines for federal agencies' cooperation with IRNET, the addition of another police department agency to the MOU, and updates to new department heads who have been installed in other agencies. No other changes were made to the MOU, and the distribution of forfeiture actions and seizures of assets remained at 3.502% (per officer) as stated in the previous MOU.

ALTERNATIVES:

Do not approve the IRNET MOU or authorize the Chief of Police to sign.

STRATEGIC PLAN:

N/A
SUBMITTED BY:

Rachel Tolber, Chief of Police
RECOMMENDED BY:

Charles M. Duggan Jr., City Manager
REVIEWED BY:

Yvette M. Abich Garcia, City Attorney
Janice McConnell, Assistant City Manager
Danielle Garcia, Management Services/Finance Director
PREPARED BY:

Sean Flynn, Commander
Redlands Regular Meeting of 12-03-24 244 of 875
Fiscal Impact
Revenue Generating: Yes
Appropriation Required Y/N: N
Budgeted Y/N: N
Discussion:

There will be no impact to the General Fund.

Attachments

IRNET MOU
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MEMORANDUM OF

UNDERSTANDING
Inland Regional Narcotics
Enforcement Team
(IRNET)
Revised 10/23/2024
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MEMORANDUM OF .......................................................................................................................................1 UNDERSTANDING .........................................................................................................................................1 Inland Regional Narcotics..................................................................................................................................1 Enforcement Team.............................................................................................................................................1 (IRNET).............................................................................................................................................................1 Revised 12/13/2021 ...........................................................................................................................................1 ARTICLE I. NAME .........................................................................................................................................1 ARTICLE II. PURPOSE....................................................................................................................................1 ARTICLE III. EXECUTIVE BOARD.....................................................................................................................1 ARTICLE IV. AMENDMENTS TO THE MEMORANDUM OF UNDERSTANDING ...............................................1 ARTICLE V. DISTRIBUTION FROM FORFEITURE ACTIONS AND SEIZURE OF ASSETS.....................................2 ARTICLE VI. FEDERAL LAW ENFORCEMENT……………….……………………………………..……………………………..2 ARTICLE VII. ORGANIZATIONAL OPERATING PROCEDURES ..........................................................................3 A. Site Location ......................................................................................................................................3 B. Structural Command ..........................................................................................................................3 C. Case Initiation ....................................................................................................................................3 D. Enforcement Manpower.....................................................................................................................3 E. Prosecutorial Support.............................................................................................................................3

1. Cross-Designation of Attorneys.........................................................................................................3

2. Special Program Attorney..................................................................................................................3 F. Equipment Pool......................................................................................................................................3 G. Request for Assistance.......................................................................................................................4 H. Reporting Format...............................................................................................................................4 I. Undercover Documents..........................................................................................................................4 J. Operating Standards...............................................................................................................................4 K. Personnel............................................................................................................................................4 L. Life of this Agreement...........................................................................................................................5 ARTICLE VIII. FISCAL PROCEDURE...............................................................................................................5 A. Special Appropriation Fund...............................................................................................................5 B. Asset Sharing .....................................................................................................................................5 ARTICLE IX. ADMINISTRATIVE GUIDELINES .............................................................................................5 A. Case Information................................................................................................................................5 B. Document Security.............................................................................................................................6 C. Undercover Documentation ...............................................................................................................6 D. Firearms.............................................................................................................................................7 E. Qualification ..........................................................................................................................................7 F. Other Defensive Equipment...................................................................................................................7 Redlands

1. Regular
Handcuffs
Meeting ................................ of 12-03-24 ................................................................................................ 247 ........... of 875 7 2. Equipment..........................................................................................................................................7

3. Protective Garments...........................................................................................................................7

4. Operation Jackets...............................................................................................................................7 G. Press Release......................................................................................................................................7 H. Release of Information.......................................................................................................................8

1. General Information for Release........................................................................................................8

2. Information NOT for Release ............................................................................................................8 I. Multi-Agency Administrative Concerns................................................................................................9

1. Civilian Complaints...........................................................................................................................9

2. Employee Evaluation.........................................................................................................................9

3. Injuries Sustained On-Duty................................................................................................................9

4. On-Duty Motor Vehicle Accidents....................................................................................................9 J. Administrative Policy ............................................................................................................................9 ARTICLE X. INVESTIGATIVE GUIDELINES.....................................................................................................10 A. Outside Agencies - Requests For Assistance...................................................................................10 B. Notification ......................................................................................................................................10 C. Undercover Operations...................................................................................................................11

1. Preparation and Planning .................................................................................................................11

2. Determine Logistical Needs.............................................................................................................11 D. Use of Intoxicating Beverages/Drugs..............................................................................................13 E. Investigative Expenses........................................................................................................................14

1. Narcotic Purchases...........................................................................................................................14

2. Program Maintenance ......................................................................................................................14

3. Operational Expenses.......................................................................................................................14 F. Confidential Informant Procedures......................................................................................................14

1. Informant Files.................................................................................................................................15

2. Request Memorandum.....................................................................................................................15

3. Follow-up Memorandum .................................................................................................................16 G. Informant Identification ...................................................................................................................16 H. Planning Operations Involving Informants......................................................................................17 I. Undesirable Informants........................................................................................................................17 J. Shooting Incidents ...............................................................................................................................17 K. Evidence...........................................................................................................................................18

1. Collection, Storage, and Testing......................................................................................................18 ARTICLE XI. FISCAL GUIDELINES....................................................................................................................18 A. Payroll Checks and Balances...........................................................................................................18

1. Payroll..............................................................................................................................................18

2. Sick Time .........................................................................................................................................18

3. Overtime ..........................................................................................................................................18 Redlands Regular Meeting of 12-03-24 248 of 875
B. Fiscal and Voucher Procedure .........................................................................................................19 ARTICLE XII. SIGNATURE PAGES ............................................................................................................20 California Department of Alcoholic Beverage Control ...............................................................................20 Drug Enforcement Administration...............................................................................................................21 Federal Bureau of Investigations .................................................................................................................22 Montclair Police Department.......................................................................................................................23 Ontario Police Department ..........................................................................................................................24 Redlands Police Department........................................................................................................................25 Rialto Police Department.............................................................................................................................26 Riverside County Sheriff’s Department.......................................................................................................27 San Bernardino Police Department..............................................................................................................28 San Bernardino County Sheriff’s Department.............................................................................................29 U.S. Department of Homeland Security ......................................................................................................30 Upland Police Department...........................................................................................................................31 Redlands Regular Meeting of 12-03-24 249 of 875
Page | 1
ARTICLE I. NAME
The name of this organization shall be the Inland Regional Narcotics Enforcement Team (IRNET).

ARTICLE II. PURPOSE
The purposes of this organization are:

The identification and conviction of high-level drug traffickers and the seizure of assets derived through drug trafficking.

The targeting, investigation, and prosecution of individuals who organize, direct, finance, or otherwise engage in high-level drug trafficking enterprises or money laundering with high priority emphasis on those subjects engaged in the importation of drugs for sale into San Bernardino and Riverside Counties.

Members will conduct coordinated drug enforcement efforts throughout the Inland Region, encouraging maximum cooperation between all law enforcement and prosecutorial agencies.

ARTICLE III. EXECUTIVE BOARD
An Executive Board will direct the affairs of this organization. The members of this Board will be the Sheriff of San Bernardino County, the Sheriff of Riverside County, the Chiefs of all participating Police Departments, and the Special Agents in Charge of the participating federal and state law enforcement agencies or their designees.

Starting January 1, 2022, the IRNET Executive Board will attempt to meet bi-annually (two times a year). Due to scheduling conflicts, it is difficult to forecast yearly bi-annual meeting dates; however, the Executive Board must meet annually at a minimum. All meetings are scheduled at the Sheriff’s Department Gangs/Narcotics Division Commander’s request to maintain this requirement.

ARTICLE IV. AMENDMENTS TO THE MEMORANDUM OF UNDERSTANDING The Executive Board may amend any Article of this Memorandum of Understanding by a twothirds (2/3) vote of the quorum.

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ARTICLE V. DISTRIBUTION FROM FORFEITURE ACTIONS AND SEIZURE OF ASSETS IRNET investigators shall conduct thorough investigations, including identifying all assets qualifying for forfeiture proceedings. In every instance, civil and criminal forfeiture statutes will be explored.

Assets seized federally are subject to an administrative cost of 20% for the Department of Justice or 30% for the Department of Treasury. According to equitable sharing guidelines, any forms submitted for equitable sharing by agencies outside of IRNET will reduce IRNET agency percentages. Assets seized under State law are subject to an administrative cost of 35% for the State of California.

It is agreed that each IRNET participating agency may submit a claim for an equitable share of any remaining funds based on the participating agency's respective contribution to the IRNET organization. IRNET participating agencies agree that each agency will be awarded 3.502% per personnel assigned to IRNET. Sworn personnel assigned to IRNET are as follows: ABC – 1, Montclair PD – 1, Redlands PD – 1, Rialto PD – 1, Riverside SO – 1, Ontario PD – 1, San Bernardino PD – 1, Upland PD – 1, and San Bernardino County SO – 12. It is agreed that SBSD will receive an additional 21%, which will be returned to the IRNET program to cover operating costs, and an additional 12.462%, which will be used to pay Confidential Informants. Therefore, the agreed-upon equitable share of the assets seized shall be:

ABC Share –3.502%
San Bernardino PD Share – 3.502%
Montclair PD Share – 3.502%
Ontario PD Share – 3.502%
Redlands PD Share – 3.502%
Rialto PD Share – 3.502%
Riverside Sheriff’s Dept. Share – 3.502%
Upland PD Share – 3.502%
SBSD Share – 71.984%
All IRNET participating members will be responsible for submitting their forms on behalf of their agency for an equitable share of seized assets. All returned assets will be distributed under applicable federal and state law and follow the Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies.

ARTICLE VI. FEDERAL LAW ENFORCEMENT
Consistent with Article II, the Drug Enforcement Administration (DEA), Federal Bureau of Investigation (FBI), and Department of Homeland Security (DHS) are committed to working with IRNET in order to target high-level drug trafficking and money laundering organizations operating in San Bernardino and Riverside Counties. Each federal agency may designate one or more federal agents to be co-located with IRNET team members in order to facilitate coordination and cooperation between IRNET and the federal agency. Each designated federal agent shall operate consistent with his/her home agency policies regardless of whether those policies are consistent with Articles VII-XI. All forfeitures from any joint investigation between IRNET and DEA, FBI, or DHS shall be shared as outlined in Article V.

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ARTICLE VII. ORGANIZATIONAL OPERATING PROCEDURES
A. Site Location
The Executive Board will approve the site location of this project.

B. Structural Command
The Sheriff’s Department, Gangs/Narcotics Division, will assign a designee with the rank of lieutenant or higher. This person will report directly to the Executive Board on all matters of IRNET concern.

C. Case Initiation
All IRNET investigations shall regularly be reviewed by the Sheriff’s Department Gangs/Narcotics Division lieutenant or his designee. The type of enterprise, the impact on the community, the current caseload, the available workforce and equipment, and workable investigative leads will determine the areas of discretion in setting priorities for these cases.

D. Enforcement Manpower
This project will bring together the highest level of expertise from contiguous and, at times, overlapping jurisdictions to focus jointly on major drug trafficking. Personnel will generally be limited to 50 investigative officers.

E. Prosecutorial Support
At the inception of this project, it shall be incumbent upon the Executive Board members to coordinate a firm and positive relationship between the United States Attorney and the State Attorney designees.

1. Cross-Designation of Attorneys
Cross-designating local and federal prosecutors may enhance collaboration between federal prosecutors and their state and local colleagues.

2. Special Program Attorney
As previously recommended, consistency on how to best proceed in certain instances could best be achieved by allowing the program direct access to one (1) attorney assigned for that specific purpose.

F. Equipment Pool
The San Bernardino County Sheriff’s Department will supply IRNET members with specialized items, mobile devices, and office equipment (desks, chairs, typewriters, file cabinets, phones, computers, office supplies, etc.).

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The San Bernardino County Sheriff’s Department will not supply vehicles to personnel assigned to the task force. Member agencies should assign vehicles appropriate for use in covert surveillance operations. All vehicle maintenance shall be the responsibility of the member agency. The participating agency should provide their investigator with a department radio and mobile device to assist with investigations.

G. Request for Assistance
This program's policy is to respond to a request for case development assistance from any law enforcement agency whose situation demands expertise or resources beyond its existing limitations.

H. Reporting Format
The San Bernardino County Sheriff’s Department standard report forms and case report incident numbers shall be utilized for case development and to track program activity. An internal numbering system will also be used to account for all activities.

I. Undercover Documents
Documents used to support or enhance undercover operations will be encouraged. These will include, but will not be limited to, driver's licenses, credit cards, checking accounts, and passports.

Procuring, utilizing, and controlling these documents will ensure that they are properly accounted for and used only for authorized purposes.

J. Operating Standards
All matters governing operating procedures will balance civilians' rights and law enforcement's needs to detect, arrest, and prosecute individuals engaged in major illicit drug activity.

Effective control of major illicit drug traffickers depends to a large degree on the close working relationship among agencies at all levels of law enforcement. Therefore, all IRNET personnel will assist to the fullest extent possible in developing inter-agency cooperation.

K. Personnel
Their respective department head must approve the assignment of federal, state, and local officers to IRNET. With Executive Board approval, the commander or his designee of the Sheriff’s Gangs/Narcotics Division may reject any nominee based on the officer's training, past performance, or other factors bearing on suitability.

Federal, state, and local officers assigned to IRNET will work full-time unless special Executive Board arrangements have been made. Officers will be under the direct daily supervision of the Sheriff’s Department Gangs/Narcotics Division lieutenant and follow all policies, procedures, and guidelines enacted explicitly by IRNET. Upon assignment to IRNET, all members shall read the IRNET policy manual. The member will sign an Inter-Office Memorandum (IOM) indicating they Redlands Regular Meeting of 12-03-24 253 of 875
Page | 5
read the policy. A copy of the IOM will be filed at IRNET and provided to the member. Should any IRNET policies or procedures conflict with their own department rules and regulations, the individual member will immediately bring said conflict to the attention of his/her IRNET supervisor. The supervisor will, in turn, bring the matter to the attention of the IRNET Manager, who will take the necessary action to rectify the situation.

L. Life of this Agreement
This agreement is effective on the date two of the parties of this agreement sign it. Any party may terminate their involvement with this agreement on 30 days advance written notice.

ARTICLE VIII. FISCAL PROCEDURE
A. Special Appropriation Fund
SBSD shall establish a Special Appropriation Fund to which members of IRNET may charge expenditures as necessary to perform the program's duties. In general, such charges shall include extraordinary or special expenses incurred in investigating major narcotics traffickers.

This fund's utilization, responsibility, accountability, and control shall be determined exclusively by the lieutenant overseeing IRNET in the Sheriff’s Department. It shall conform to standards as required by policy and procedure for the San Bernardino County Sheriff’s Department. Federal agencies will adhere to federal law and respective agency policies and procedures for any expenditures and reimbursements of expenses incurred by or through the federal agent.

B. Asset Sharing
IRNET will provide an audit trail showing that the assets seized are following applicable state and federal law. IRNET’s finance specialist will notify partner agencies of a seized asset so the required forms can be submitted.

Each IRNET member agency will receive a monthly activity report, which will include activity and seizures by month and year to date.

ARTICLE IX. ADMINISTRATIVE GUIDELINES
A. Case Information
Large-scale narcotics investigations are sensitive. Protecting sources of information and managing information about areas of narcotics/drug-related activity are essential. Information and reports will be disseminated on a need-to-know basis in compliance with existing state and federal laws and, when appropriate, with the Department of Justice guidelines.

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Written reports are vital to the conduct of operations. They are a formal means of communicating among participating agencies, other agencies, and the court. In composing an investigation report, the officer should remember that it will be read by someone else and will most likely form the basis for action or inaction by the reader. The report may also be read by someone seeking to discredit its contents or IRNET. Investigative reports will be completed promptly and describe activities fully, exactly, and plainly. All case reports will be kept in the IRNET office until the case's conclusion.

Statistical information regarding arrests and narcotics seized will be forwarded to the jurisdictional agency where such activity occurred to maintain proper information reporting procedures to the State Department of Justice.

Questions about the appropriateness of releasing case information will be referred to the lieutenant of IRNET.

B. Document Security
All reports and records will be designated "Confidential" (“Unclassified” for the FBI). When unattended, this material will be secured under lock and key. Access to all files is on a need-toknow basis.

IRNET will not keep intelligence files. Case files actively being worked on will be kept under the direct security of IRNET until the investigation is concluded. Federal agencies will maintain their files in compliance with the Freedom of Information Act.

If IRNET feels certain case information should be considered "intelligence," the entire file will be sent to the appropriate agency and filed under that department's guidelines for intelligence information.

Investigative reports or official records will never be kept or stored outside the designated office of IRNET or the San Bernardino County Sheriff’s Records Bureau.

Reports will always be stored, and information will be disseminated strictly by applicable local, state, and federal laws.

C. Undercover Documentation
Should IRNET require assigned officers to assume a covert identity, arrangements will be made to issue each IRNET officer as required:

1. A California Driver's License; and

2. Documents to support covert identification as they become available.

The IRNET lieutenant will maintain records and photostatic copies of all identities issued to officers. These documents shall only be used while the officers are on duty and working in an official capacity, and the use of the covert identity is required to further the case. The IRNET lieutenant may deem additional documentation, such as credit cards, a credit rating Redlands Regular Meeting of 12-03-24 255 of 875
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with TRW, a passport, or a social security card, to support identity. The need for these items will be evaluated on a case-by-case basis. In every situation requiring assigned officers to obtain undercover documentation, their respective department heads will be advised that the required application forms have been submitted.

D. Firearms
Every officer assigned to IRNET will carry a firearm following their department's policies and procedures. Officers may carry authorized firearms while off duty; however, applicable departmental policies about the use of firearms shall apply.

E. Qualification
The IRNET member’s department must approve any firearm an officer carries and meet minimum departmental qualifications. The San Bernardino County Sheriff’s Department standards will apply if no departmental requirements exist, and officers will qualify on a trimester schedule.

F. Other Defensive Equipment

1. Handcuffs
Officers will carry A set of handcuffs when engaged in any enforcement activity (excluding undercover work).

2. Equipment
The Board may authorize the purchase and use of equipment to assist IRNET in accomplishing its purpose.

3. Protective Garments
All IRNET officers will have a bulletproof (protective) vest available. Officers shall wear their vests in arrest and search situations.

4. Operation Jackets
Members of IRNET shall wear the approved operation jackets/vests during arrests, searches, and similar enforcement situations.

G. Press Release
IRNET will cooperate with the media to obtain information on matters of public interest. However, certain information must remain confidential to protect the accused's Constitutional Rights, avoid interfering with an IRNET investigation, or because it is legally privileged.

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IRNET will function as a unit. All members will refer to themselves as members of IRNET. If asked what agency they are employed by, the member should identify their respective agency and their assignment to the “Inland Regional Narcotics Enforcement Team." The IRNET lieutenant will designate the "Press Information Officer." Members of IRNET will not release information to the press unless otherwise directed to do so by the IRNET lieutenant.

H. Release of Information
The IRNET lieutenant will be available to assist in disseminating or coordinating such information.

The facts of each situation will determine the information to be released and will be distributed at the direction of the Executive Board. Generally, a description of the circumstances which do not prejudice the rights of the suspect(s) or interfere with an investigation will be made.

1. General Information for Release
a. Type of crime (statutes violated, etc.)
b. The extent of injury or damage
c. Value of drugs seized
d. Date and time of crime discovery
e. Length of investigation
f. Suspect name and age, if adult
g. Factual details of the incident

2. Information NOT for Release
a. Prior criminal record, character, or reputation of accused. b. The existence or contents of any confession, admission, or statement given by the accused or failure of the accused to make any statement. c. The identity, testimony, or credibility of any prospective witnesses. d. The possibility of a plea bargain.
e. Any opinion as to the guilt or innocence of the accused.

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I. Multi-Agency Administrative Concerns

1. Civilian Complaints
Any complaint from an individual alleging misconduct by IRNET personnel will be directed to the IRNET lieutenant or, in his absence, a supervisor, and a written report will be submitted to the Sheriff’s Department Gangs/Narcotics Division commander for evaluation.

The IRNET lieutenant will notify the officer's respective agency and facilitate their investigation of the incident.

It will be the policy of IRNET to receive, record, and properly direct all citizen complaints against its members without exception.

2. Employee Evaluation
IRNET recognizes that all agencies have at least annual employee evaluations. When such evaluations are due, the affected employee's supervisor will assist the appropriate law enforcement supervisor in completing a fair and objective evaluation for the rating period.

3. Injuries Sustained On-Duty
When an IRNET officer is injured on duty, it will be necessary to follow the procedures required by the officer's agency, including notification of the specific agency involved. In emergencies, the officer will receive immediate medical attention most expediently. To assist the supervisors in ensuring an officer's injury is treated without unnecessary delay, officers assigned to IRNET will supply their supervisor with a packet containing the forms and application instructions for processing per Sheriff’s Department policies and procedures.

4. On-Duty Motor Vehicle Accidents
If an IRNET Officer is involved in an accident while on duty, a long-form accident report will be completed by the jurisdictional agency. Copies will be forwarded to the officer's agency and the IRNET lieutenant for further review and necessary action. In any on-duty motor vehicle accident, whether injury or non-injury, the IRNET lieutenant or his designee will immediately notify the member agency so they can notify their appropriate Risk Management/Civil Liabilities Division per Sheriff’s Department policies and procedures.

J. Administrative Policy
All members of IRNET will be expected to conform to their department's policy and procedure and any additional policies and procedures set forth by IRNET (such as performance expectations, punctuality, and chain of command).

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ARTICLE X. INVESTIGATIVE GUIDELINES
A. Outside Agencies - Requests For Assistance
IRNET will respond to requests for case development assistance from any law enforcement agency whose situation demands expertise or resources beyond its existing capabilities. The IRNET lieutenant will review all such requests as soon as practicable after receiving them.

The Sheriff’s Department Gangs/Narcotics Division commander will be informed of all requests for assistance made by non-participating agencies.

IRNET recognizes that Southern California's jurisdictional makeup lends itself to investigative overlay during narcotics case development. Therefore, IRNET will strictly adhere to the following notification procedures to minimize any chance of conflicting with the enforcement routine of the affected jurisdiction.

B. Notification
Before opening an active case, IRNET will contact the local agency of jurisdiction and check to see if that department is already actively working on a case on the subject(s) of IRNET's investigation. IRNET will also contact adjacent jurisdictions and LACRCIC/WSIN to see if any agency has information on the subjects.

After opening a case, IRNET will utilize the guidelines of LACRCIC/WSIN to identify the case and subjects being worked on, facilitating communications between investigating agencies and eliminating duplication of effort.

Note: IRNET will communicate closely with the affected jurisdiction throughout its investigation. If the agency in question has an open, active case centered on that target, IRNET will not open a separate case unless requested to do so by the affected agency. (See Requests for Assistance.)
When executing Search or Arrest Warrants, the following procedure will be followed, and, when appropriate, at least one uniformed officer from the jurisdictional agency will be requested and utilized.

Members of IRNET will notify the jurisdictional agency Watch Commander regarding the type of activity, the location, and the approximate operation time.

IRNET will also notify the narcotics detail of the affected agency:

1. To prevent a duplication of effort.

2. To protect undercover officers.

3. A means to gather additional intelligence.

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C. Undercover Operations
IRNET, by its nature, will conduct undercover operations on numerous occasions. Specifically, this will entail introducing undercover officers to narcotics traffickers to purchase drugs or infiltrate their organizations. The following guidelines will be adhered to as to ensure officer safety and proper case development (Federal agencies will additionally observe DOJ guidelines):

1. Preparation and Planning
a. Discuss the purpose and intention of the operation with your supervisor.

Depending on the magnitude of the investigation, prior approval may be required from the IRNET lieutenant to the Executive Board.

2. Determine Logistical Needs
a. Manpower
An IRNET supervisor will assess each case with the IRNET lieutenant to determine if special tactics or the utilization of a special weapons team will be required. Jurisdictional responsibilities will be recognized. b. Equipment

1. Communications

2. Wireless Transmitter/Receiver with Recorder

3. Helicopter
4) "Flash Roll"
c. Plan Formulation

1. Indicate the scenario the Undercover Officer will utilize.

2. Designate a Case Agent.

3. Prepare a case history on the violators involved.
d. Operational Plan

1. The Case Agent will submit a written operational plan on all narcotics investigations, including buy/busts, arrest and search warrant service, and undercover surveillance cases. The IRNET lieutenant will approve all operational plans. In cases involving narcotics deliveries out of state or reverse operations more than 10 kilos in weight, the captain of the Redlands Regular Meeting of 12-03-24 260 of 875
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Sheriff’s Department Gangs/Narcotics Division (SBCSD) will be notified before beginning the operation.

2. Plan Format
a. The written plan will include suspect information, criminal history, pictures, vehicles, and associates.
b. The suspect's method of operation and other criminal tendencies. c. Maps, diagrams, and addresses.

1. Clothing description

2. Undercover vehicle

3. Money flash vehicle.

4. Provide a description of the clothing of undercover officers and confidential informants, if involved.

5. Arrest and trouble signal (visual and audio)

6. List all officers involved, including their assignment and vehicle and equipment responsibilities.

7. Copies of the plan will be distributed to all involved officers. d. Notification of the law enforcement agency where the operation will take place will be noted on the plan, including who was notified.
e. Communication channel frequency for the operation and necessary clearances from Central Dispatch. (An alternative frequency should be included in case of communication
problems on the primary channel).
f. Before starting, a complete briefing will be conducted utilizing the written plan.
g. The sergeant assigned to the IRNET team will approve all operation plans before their implementation.
e. Undercover Operation (U/C)

1. The U/C will not deviate from the written plan unless he/she can obtain supervisory approval during the operation.

2. When the arrest signal is given, the U/C will not be involved in the actual arrest unless the situation dictates his/her intervention.

3. If the U/C is robbed by the suspects during the operation for the flash money, he/she will immediately give the trouble signal and rely on the cover/surveillance units to take appropriate action.

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4. The U/C officer will never "front" any portion of the flash roll.

Additionally, he/she will not "front" any special funds for narcotics purchases without prior supervisory approval.

5. The U/C officer will never meet with suspects in a narcotics investigation without proper surveillance and cover units. An IRNET sergeant must notify and approve any meeting between a suspect and CI.

6. Section 11367 of the Health and Safety Code provides immunity from prosecution to authorized peace officers or other agents while investigating violations of the Health and Safety Code.

D. Use of Intoxicating Beverages/Drugs

1. IRNET Personnel will not use or possess any intoxicating beverage before reporting for duty to the extent that they are impaired, nor will they use intoxicating beverages while on duty.

Members will adhere to their respective department policies for the use of intoxicating beverages. IRNET personnel, with the consent of their superior officer, may drink alcoholic beverages while on duty when necessary to accomplish a police purpose. a. IRNET personnel who have approval from a superior to drink while involved in a covert operation must:

1. Not drink to such a degree that their judgment may be impaired.

2. Not drive a vehicle after such assignment, until reaching an appropriate state of sobriety.
b. IRNET personnel will ensure that all persons under their control and who have used alcoholic beverages can perform their tasks without becoming a danger to themselves or others.

2. IRNET officers shall not maintain drugs or paraphernalia for use or provide them for use.

3. IRNET personnel shall not use any narcotics or drugs. The only exception would be in a lifethreatening situation. If in the best judgment of the employee, failure to use a drug or narcotic could result in death or serious injury, that employee may participate in the use. IRNET personnel will notify their supervisor if they are taking prescribed medication that may interfere with the performance of their job duties.

During some covert investigations, it may become necessary to simulate the use of narcotics, for example, simulating the smoking of marijuana or the inhalation of stimulant drugs.

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a. As soon as possible after use or simulation, a supervisor will examine the officer and, if necessary, medical personnel to determine the extent of intoxication or effect. A complete report by the officer and his supervisor will be submitted regarding the circumstances of the use of simulation and the effects thereof. Based on this examination and report, the IRNET lieutenant will take appropriate action, if necessary.

4. The investigative staff will ensure that informants under their direction have read and understood the provisions of the Confidential Agreement Form regarding the use of alcohol, drugs, and narcotics.

E. Investigative Expenses
IRNET officers will expend program funds during narcotic investigations in the performance of their duties. This area includes narcotic purchases, program maintenance, and operational expenses. (Federal agents will adhere to their respective agencies' policies.)

1. Narcotic Purchases
With prior supervisory approval, IRNET officers will be available to expend funds for narcotics.

2. Program Maintenance
This will include meals, gasoline, lodging, and money for confidential informants and/or witnesses. Another officer will be present while disbursing these funds or obtaining a signed receipt from the recipient. This is to protect the credibility of IRNET officers. On rare occasions, it is conceivable that an officer will not be able to adhere to the above policy. In those instances, the officer can disburse funds and later advise a supervisor of the circumstances.

3. Operational Expenses
This will include officer expenses in an undercover capacity for food, gasoline, lodging, vehicle rental, special equipment, and any other item deemed necessary by the supervisor to enhance the successful completion of an operation.

F. Confidential Informant Procedures
IRNET sergeants will be responsible for ensuring that investigative personnel follow the following procedures while utilizing informant operatives. While assigned to IRNET, federal agents responsible for managing IRNET informants will follow their respective agency's policies while complying with the below-listed IRNET policies.

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1. Informant Files
An IRNET-coded file will be maintained on each informant operative, which will minimally consist of the following:
a. Background Information Sheet and Photograph
b. CII and/or FBI Rap Sheet
c. A report of the prospective investigations in which officers anticipate engaging the informant.
d. A list of investigations in which the informant has participated. e. De-briefing of current criminal activity that the informant knows. f. Copies of authorization and follow-up memorandums (if applicable). g. Informant files shall be kept pursuant to member agency policies and procedures.
h. The IRNET lieutenant shall maintain a copy of informant files in compliance with the San Bernardino County Sheriff’s Department policy.

2. Request Memorandum
The investigator wishing to use an informant who is currently charged or is going to be charged will initiate a memorandum requesting authorization:
a. Memorandum addressed to the IRNET lieutenant and District Attorney or United States Attorney from an IRNET supervisor.
b. Contain a summary of charges.
c. Authorization from the arresting officer or agency.
d. A general overview of proposed investigations (do not list the suspect's name).
e. The type of investigative assistance the informant is expected to provide (information, obtain evidence, a covert operative, testify, etc.). f. A paragraph outlining the informant's understanding of the District Attorney's and IRNET's involvement specifically states that no promises of leniency or specific types of sentencing can be made, and the defendant must enter a guilty plea on the charges. The Court will ultimately handle the disposition and sentencing of the case with which he/she is presently Redlands Regular Meeting of 12-03-24 264 of 875
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charged. The District Attorney and IRNET can only make
recommendations based on their evaluation of the informant's participation in the investigations.
g. Attachments:
i. Informant's current CII and/or FBI Rap Sheet
ii. Confidential Agreement Form
iii. Consent Form
iv. Copy of Crime Reports (if possible)

3. Follow-up Memorandum
After the investigations are completed, a follow-up memorandum shall be written to the District Attorney or United States Attorney outlining the informant's assistance. It will contain the following:
a. Present status of the case pending against the informant. b. Investigations.
c. A general appraisal of aid rendered by the informant (very successful, did not meet the commitment, seemed insincere, etc.).
d. If an informant fails to meet his/her commitments and make himself/herself available to and participate with the investigating officers, the IRNET lieutenant and District Attorney or United States Attorney will be advised immediately by inter-office memorandum. The IRNET lieutenant shall review all follow-up and status memorandums written to the District Attorney or United States Attorney concerning the Confidential Informants and then hand-carry to the District Attorney or the United States Attorney.

G. Informant Identification
The informant's identity must always be known to the supervisor and IRNET lieutenant.

1. Officers are reluctant to divulge the names of their informants, so access to informant files must be limited to a "need-to-know basis" only.

2. Knowing the name of the informant is not enough. A complete identification package will be maintained.

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H. Planning Operations Involving Informants
Planning includes proper time, workforce, and logistical support.

1. The case agent must control the direction of the operations and the informant. They must never have to act when there are not enough team members or equipment.

2. The entire relationship and direction must come from the officer. a. It is not uncommon for the informant to attempt to become involved in planning.
b. The informant should not be present at briefings.

I. Undesirable Informants
When a case agent is aware an informant is undesirable, all contact with that informant should cease, and the reasons should be noted in his/her informant package. This information will be disseminated throughout the narcotic enforcement community.

When a case agent determines it necessary, informants will be checked through LACRCIC/WSIN to see if they have been "blackballed" before utilizing them.

J. Shooting Incidents
Any member of IRNET who discharges his weapon during the performance of duty will immediately notify the:

1. Jurisdictional agency of the area in which the discharge took place.

2. IRNET lieutenant or on-call Sheriff’s Duty Captain.
a. San Bernardino Sheriff’s Duty Matrix and current officer-involved policies and procedures shall be complied with.

3. The respective department's Watch Commander from which the officer is employed.

In those cases where death or serious injury is related to an officer-involved shooting or the operation of a motor vehicle, the jurisdictional agency will handle the full investigation according to departmental policy and procedure.

4. IRNET MOU does not supersede the policy of any member agency.

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K. Evidence

1. Collection, Storage, and Testing
IRNET will utilize the facilities of the San Bernardino County Sheriff’s Department to maintain a proper evidence chain on all items collected in pursuit of case preparation. All evidence obtained during an investigation will be tagged and placed in an appropriate evidence locker without delay.

In addition, when handling seized narcotics or money, no less than two (2) officers will be detailed to move or count such contraband. Further, no less than two (2) officers will be allowed to maintain security on such items at any time after seizure and before placement in secure storage.

As a matter of routine, the seized currency will be placed in a plastic bag designed for that purpose. The case agents will seal, date, and initial this receptacle, which will only be opened by the appropriate federal or state agency.

Under normal circumstances, currency seized because of IRNET investigations will be forfeited through a state or federal government agency. Because of this, the money will be turned over as soon as possible after the seizure, and they will conduct an exact count of the cash. Any deviation from these procedures will require the prior approval of the IRNET lieutenant.

ARTICLE XI. FISCAL GUIDELINES
A. Payroll Checks and Balances

1. Payroll
Their respective agency will pay all personnel assigned to IRNET.

2. Sick Time
All personnel will utilize sick time following their agency's policies and procedures.

Sick time will be reported to the IRNET supervisor. IRNET will notify the officer's agency to ensure proper notification and timekeeping.

3. Overtime
All personnel will attempt to contact/notify the supervisor for approval before working overtime.

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All personnel will, as required, work beyond their normal workday or respond on callouts as deemed necessary by the IRNET lieutenant or supervisor.

Each local agency will have any overtime worked by their respective personnel assigned to IRNET reimbursed by the HIDTA grant up to the federal cap on overtime reimbursement. All overtime worked after HIDTA funds are expended will be the sole responsibility of each respective agency.

B. Fiscal and Voucher Procedure
Investigative funds are authorized expenditures incurred by officers while working undercover or on surveillance. They must directly relate to the continuing development of an investigation or informant. The Sheriff of San Bernardino County will provide the initial funding for this item, and funds will be distributed from the Sheriff’s Department Special Appropriation Fund.

A voucher will include a statement explaining why the money was spent. By signing the voucher, the officer attests to the validity and necessity of the expenditure. a. Date
b. Amount
c. Reason(s)
d. Signature of requester
It shall be submitted to a Sergeant for review and authorization signature of the IRNET lieutenant.

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ARTICLE XII. SIGNATURE PAGES
California Department of Alcoholic Beverage Control
The signatures affixed below signify the California Department of Alcoholic Beverage Control agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Armando Gonzales, Division Chief Date
California Department of Alcoholic Beverage Control
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Drug Enforcement Administration
The signatures affixed below signify the Drug Enforcement Administration agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Matthew W. Allen, Special Agent in Charge Date
Drug Enforcement Administration
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Federal Bureau of Investigations
The signatures affixed below signify the Federal Bureau of Investigations agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Ted Docks, Special Agent in Charge Date
Federal Bureau of Investigations
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Montclair Police Department
The signatures affixed below signify the Montclair Police Department agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Jason Reed, Chief of Police Date
Montclair Police Department
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Ontario Police Department
The signatures affixed below signify the Ontario Police Department agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Mike Lorenz, Chief of Police Date
Ontario Police Department
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Redlands Police Department
The signatures affixed below signify the Redlands Police Department agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Rachel Tolber, Chief of Police Date
Redlands Police Department
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Rialto Police Department
The signatures affixed below signify the Rialto Police Department agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Mark Kling, Chief of Police Date
Rialto Police Department
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Riverside County Sheriff’s Department
The signatures affixed below signify the Riverside County Sheriff’s Department agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Chad Bianco, Sheriff-Coroner Date
Riverside County Sheriff’s Department
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San Bernardino Police Department
The signatures affixed below signify the San Bernardino Police Department agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Darren Goodman, Chief of Police Date
San Bernardino Police Department
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San Bernardino County Sheriff’s Department
The signatures affixed below signify the agencies agreed to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Shannon D. Dicus, Sheriff-Coroner Date
San Bernardino County Sheriff’s Department
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U.S. Department of Homeland Security
The signatures affixed below signify the U.S. Department of Homeland Security agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Eddy Wang, Special Agent in Charge Date
U.S. Department of Homeland Security
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Upland Police Department
The signatures affixed below signify the Upland Police Department agrees to the contents of this Memorandum.

This Memorandum of Understanding outlines the organizational operating policies and procedures for the Inland Regional Narcotics Enforcement Team (IRNET).

As Officers of the Executive Board and representatives of the IRNET member agencies, the signatures affixed below signify our agreement to the contents of this Memorandum:
____________________________________ ___________
Marcelo M. Blanco, Chief of Police Date
Upland Police Department
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City Council Meeting I. 14.

DATE: 12/03/2024
TO: Honorable Mayor and City Council Members
SUBJECT: Approve the submission of a Facility Request Form to the University of Redlands for use of its facilities from January 1, 2025 through December 31, 2026 for the purpose of Redlands Police Department training, presentations, and testing and authorize the Chief of Police or her designee to execute the request form and related facility use documents (Police Chief Tolber)
MOTION(S):

If the City Council determines that staff’s recommendation is appropriate, the following motion is provided:

I move that City Council approve the submission of a Facility Request Form to the University of Redlands for use of its facilities January 1, 2025 through December 31, 2026 for the Redlands Police Department to conduct training, testing, and presentations; and

1. I further move that City Council authorize the Chief of Police, or her designee, to execute the facility use request form and other related facility use documents for Redlands Police Department to conduct training, presentations, and testing from January 1, 2025 through December 31, 2026 at the University of Redlands.

2. RECOMMENDATION:

Staff recommends that Council authorize the Chief of Police, or her designee, to execute the facility request form and other related facility use documents between the City of Redlands and the University of Redlands for the use of its facilities to conduct training, presentations, and testing from January 1, 2025, through December 31, 2026.

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DISCUSSION:

The Redlands Police Department may find the need to periodically use facilities at the University of Redlands to conduct training, testing, and/or presentations. Currently, the Redlands Police Department lacks adequate facilities and the proper equipment to carry out training, presentations, and/or administer testing. At times, the Department needs to be able to utilize facilities at short notice. The University of Redlands has offered the use of their facilities to the Redlands Police Department for training, presentations, and testing free of charge. All events conducted by the Department will have city employees present. The University of Redlands has prepared a Facility Use Request Form for the time period between January 1, 2025, through December 31, 2026, for consideration. The agreement will allow Redlands Police Department members to use the facilities at the University of Redlands from January 1, 2025, through December 31, 2026, without having to complete a separate agreement on each occasion. The current Facility Use Request and agreement with the University of Redlands is set to expire on December 31, 2024.

ALTERNATIVES:

Attempt to locate another suitable location for instruction which may incur additional costs.

STRATEGIC PLAN:

Not applicable
SUBMITTED BY:

Rachel Tolber, Chief of Police
RECOMMENDED BY:

Charles M. Duggan Jr., City Manager
REVIEWED BY:

Yvette M. Abich Garcia, City Attorney
Janice McConnell, Assistant City Manager
Danielle Garcia, Management Services/Finance Director
PREPARED BY:

Stephen Crane, Deputy Chief
Redlands Regular Meeting of 12-03-24 282 of 875
Fiscal Impact
Fiscal Year: 2025/2026
Revenue Generating: N
Appropriation Required Y/N: N
Budgeted Y/N: Y
Discussion:

The University of Redlands has offered the use of their facilities to the Redlands Police Department for training, presentations, and testing free of charge.

Attachments
Facility Request Form
Redlands Regular Meeting of 12-03-24 283 of 875
4/18/23
University of Redlands

DEPARTMENT OF PHYSICAL EDUCATION AND ATHLETICS

FACILITY REQUEST FORM
City of Redlands Stephen Crane 11/05/2024
Sponsoring Organization Representative in Charge Date of Application 1270 W. Park Avenue (909)557-6200 [email protected] Address Phone # Email
Facility Requested: Ashel Cunningham Track Attendance: TBD Participation: PT Test Name of Event: Police Training
01/01/2025-12/31/2026 TBD to TBD
Day of Week Month/Day/Year Event Times
OTHER:

Is there any charge associated with your contest/activity? (membership dues, entry or admission fees) X Yes No Amount
THE SPONSORING AGENT/ORGANIZATION AND REPRESENTATIVE IN CHARGE AGREE AS FOLLOWS:

A. INDEMNITY: Each party shall defend, indemnify and hold, its officers, agents, and employees harmless from and against any and all liability, loss, expense (including reasonable attorney's fees), or claims for injury or damages arising out of the performance of this Agreement but only in proportion to and to the extent such liability, loss, expense, attorney's fees, or claims for injury or damages are caused by or result from the negligent or intentional acts or omissions of the indemnifying party, its agents, or employees.

B. INSURANCE: Sponsoring Organization shall procure at its own expense, and maintain during the term of this Agreement, the following policies of insurance in connection with the use of University facilities, as outlined in this Agreement:
a. Comprehensive General Liability insurance must list “The University of Redlands, its trustees, officers, employees, and representatives are named as an additional insured. Coverage is primary and noncontributory. Waiver of Subrogation applies.” b. A certificate of insurance should be issued by the carrier in the amount of $1,000,000 for each occurrence and $2,000,000 for general aggregate.
c. If the guests include persons under the age of eighteen (18), then the General Liability insurance policy must provide coverage for sexual misconduct (including by definition sexual molestation, abuse, and harassment) with limits of no less than $1,000,000 per occurrence/$2,000,000 aggerate. Note: If the General Liability coverage has any sub-limits or exclusions inconsistent with the above that apply to coverage for sexual misconduct the Certificate of Insurance must define those limits and exclusions. d. If the event includes the use of an automobile for the purposes of the activity, automobile insurance is required by the carrier in the amount of $1,000,000 for each occurrence and $2,000,000 for general aggregate. e. If the client is bringing workers on campus for the event, workers compensation coverage is required at the state-mandated limits. f. Each insurance policy shall be issued by an insurance company authorized to do business in the state of California or eligible surplus lines insurer acceptable to the State and having agents in California to whom service of process may be made, and currently rated by A.M. best as “(A-) IX” or better.
g. The policy start and end date must encompass the event date(s). h. Subcontractors are also required to provide these insurance requirements.

Upon execution of this Agreement, Sponsoring Organizations shall obtain and deliver certificates evidencing such insurance from its insurers.

Said policies shall name the “University of Redlands” as an additional insured and loss payee, but only with respect to liability arising out of the use of university facilities, as outlined in this Agreement, and shall contain covenants requiring thirty (30) days written notice to the University before cancellation of such coverage. These policies shall be primary and noncontributory with any insurance carried by the University. A waiver of subrogation in favor of the University must be provided with respect to Worker’s Compensation, Auto Liability and General Liability.

It is preferable that the Certificate of Insurance cover an entire year and not name specific contests to avoid having to secure a Certificate for each appearance on the University campus. All Certificates must be submitted to the University at least 14 days prior to the facility use.

C. Sponsoring Organization officials are responsible for the conduct of their members and guests using the facility and will be financially responsible to reimburse the University of Redlands for all damage to the fields, buildings, furniture, fixtures, or equipment which Redlands Regular Meeting of 12-03-24 284 of 875
4/18/23
occur during any scheduled activity of the Sponsoring Organization. Sponsoring Organization is responsible for leaving the facility in appropriate condition and will be billed for the cost of any clean-up performed by the University.

D. Sponsoring Organization/representative agrees to abide by all rules and regulations of the University of Redlands and the laws for the State of California and the United States of America, and to obey all rules and regulations promulgated by University officials for the use of the property.

E. The University of Redlands bears no expense for any publicity, advertising, or other expenses. The University may be listed as the event site in all promotional materials and advertising, but shall not be represented as a sponsor, co-sponsor, or agent for the event.

F. The University of Redlands shall not be responsible for any loss of or damage to Sponsoring Organization’s property, or the property of its employees, contractors or agents, located on the University of Redlands premise unless such loss or damage is directly caused by the negligence or willful misconduct of the University of Redlands or its employees.

G. The University of Redlands may terminate this Agreement at any time and for any reason with written notice to the Sponsoring Organization. . The Sponsoring Organization may terminate this Agreement at any time and for any reason with written notice to the University.

H. This Agreement constitutes the entire agreement between the parties with respect to its subject matter and supersedes all prior agreements, written or oral. This Agreement may only be amended by a written instrument signed by the authorized representatives from both parties.

RENTAL FEE: A fee will be assessed to groups who are not directly associated with the University of Redlands. Facility rental fees are based on hours of use and services requested. Fees are determined by the Director of Athletics.

Upon approval of the request, a copy of this form will be emailed to the representative in charge and will serve as confirmation of rental request and as a statement of fees charged.

AMOUNT DUE $ PAYMENT DUE DATE is no later than the first date of facility rental.

REQUIRED SIGNATURES:

Sponsoring Representative Date U of R Director of Athletics Date Please send completed FACILITY REQUEST FORM and CERTIFICATE OF INSURANCE to:

Jill Muratet, Athletics [email protected] University of Redlands P.O. Box 3080 909-748-8012
Redlands, CA 92373-0999 FAX 909-335-4088
Redlands Regular Meeting of 12-03-24 285 of 875
City Council Meeting K. 1.

DATE: 12/03/2024
TO: Honorable Mayor and City Council Members
SUBJECT: PUBLIC HEARING to consider Resolution No. 8641 related to the development applications for the proposed “Tennessee Village” project located on a 13.48-acre site located on the east side of Tennessee Street approximately 600 feet north of West Lugonia Avenue within the Special Development (EV/SD) District of the East Valley Corridor Specific Plan (APN: 0167-171-15-0000):
(Mayor to declare the meeting open as a public hearing) Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program prepared for the project in
accordance with Section 15074 of the California
Environmental Quality Act (CEQA) Guidelines.

A.

Socio-Economic Cost/Benefit Study prepared for the
proposed project as required by Measure U.

B.

Amendment No. 50 to Specific Plan 40 – A request to
amend the East Valley Corridor Specific Plan (Specific Plan No. 40) to remove the project site consisting of 13.48 acres (gross) from the boundaries of Specific Plan 40 area.

C.

Zone Change No. 477 – A request to change the zoning
designation of the 13.48 (gross) acre project site from Special Development (EV/SD) District to General Commercial (C-3) District.

D.

Tentative Parcel Map No. 20688 – A request to subdivide the entire project site into four parcels consisting of 1.37 net acres,

1.49 net acres, 5.02 net acres, and 4.88 net acres in size for development purposes.

E.

Conditional Use Permit No. 1173 – A request to construct a mixed-use project consisting of 460 apartments and
approximately 18,000 square feet of commercial space on a vacant 13.48-acre site as allowed in the C-3, General
Commercial District.

F.

Commission Review and Approval No. 956 – A request for
site plan approval and architectural design review to construct a mixed used development composed of 460 apartment units within ten buildings and approximately 18,000 square feet of G.

Redlands Regular Meeting of 12-03-24 286 of 875
within ten buildings and approximately 18,000 square feet of commercial space. The residential units include one-bedroom, two-bedroom, and three-bedroom floor plans ranging from 755 to 1,599 square feet each.

Density Bonus Agreement with Declaration of Affordable
Housing Covenants and Restrictions – A request to approve a Density Bonus Agreement which sets forth the terms and conditions to allow the Density Bonus Units and increased density for the project, the concessions and waivers that the developer is entitled to pursuant to State law, and affordability covenants to ensure the affordability of twenty (20) apartment units for Very Low Income households.
(Development Services Director Desatnik)
H.

PROCEDURE FOR PUBLIC HEARING:

1. Mayor declares the meeting open as a public hearing.

2. Mayor calls upon Department Director for report.

Mayor calls for questions/comments from members of the City Council.

3. Mayor calls upon applicant, or his/her representative, for comments and testimony.

4. Mayor calls for comments/questions/testimony from members of the public
(3 minutes per speaker).

5. Mayor calls upon City Clerk to note any written comments received.

6. Mayor calls upon the applicant, or representative, for rebuttal comments (5 minutes).

7. 8. Mayor closes the public hearing.

9. City Council considers the motion and votes.

MOTION(S):

If the City Council determines the recommendation is appropriate, the following motion is provided:

I move that the City Council adopt Resolution No. 8641 and approve the Tennessee Village Mixed Use Project.

RECOMMENDATION:

The Planning Commission voted 6-0 (Commission Chair Karah Shaw absent) to adopt Resolution No. 1688 recommending approval of the project entitlements and the Density Bonus Agreement to the City Council.

Redlands Regular Meeting of 12-03-24 287 of 875
During the meeting, the Commission discussed site design, the density bonus, requirements for the project to provide electic vehicle charging and the timing of project phasing. The Commission was supportive of the project and its design, and suggested possible improvements related to service for electric vehicles and electric appliance service for residential units. Following the Planning Commission meeting, the applicant agreed to a condition of approval requiring all garage parking spaces to be EV charger ready. This change exceeds the typical building code standards. The current building code requires 169 EV ready spaces which could be placed anywhere on the residential portion of the site, including unenclosed outdoor spaces. This condition of approval includes nine additional spaces (a total of 178) that are all located within garage spaces where they are the most beneficial to the residents.

BACKGROUND:

The project site currently consists of vacant and unimproved land. Historic aerial surveys indicate that the site previously supported agricultural uses (citrus groves); however, agricultural use of the property ceased between 1980 and 1984 based upon historic aerials of the project area.

Recent residential developments in the vicinity have been driven in large part by the construction of Citrus Valley High School founded in 2009 (located one-half mile to the north of the proposed project site), and further residential and commercial construction in the area can be expected.

In 2020, the Heritage Specific Plan (Specific Plan No. 62) located on the northwest corner of San Bernardino Avenue and Texas Street was approved (and now fully constructed). This project allowed the construction of 207 homes on the 37-acre site.

In 2021, the Bergamot Specific Plan (Specific Plan No. 64) located north of Domestic Avenue and west of Texas Street, was approved for the construction of 317 homes on 38 acres within three neighborhoods with lot sizes ranging from 1,900 sf to over 7,200 square feet. This project is currently under construction.

In 2024, the Bergamot Specific Plan was amended to include an additional 14.6 acres located west of Citrus Valley High School and north of Pioneer Avenue, for the construction of an additional 117 single-family homes. This project is currently in the process of obtaining building permits.

In 2024, the Lugonia Village multifamily residential project was approved by the City Council. This project is located north of Lugonia Avenue, South of Pennsylvania Avenue and west of Karon Street (directly to the east of the proposed project). The Lugonia Village project includes a total of 541 residential units in three distinct neighborhoods and includes single-family homes, townhomes, and apartments.

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2021-2029 Housing Element: The City’s new 2021-2029 Housing Element was certified by the California Department of Housing & Community Development (HCD) on September 26, 2022. State Law requires it to include housing programs that identify adequate sites to accommodate the jurisdiction's share of the Regional Housing Needs Allocation (RHNA); assist in the approval of housing for Very Low- and Low-income households; and remove or mitigate governmental constraints that inhibit building more affordable housing.

Project Description:

The applicant proposes to develop a vacant property 13.48 acres in size (12.79 acres net) with ten buildings, which include a mix of residential and commercial uses. The site is located on the east side of Tennessee Street and approximately 600 feet north of West Lugonia Avenue (see Attachment A – Location Map and Aerial Photo).

The proposal includes 460 residential units and approximately 18,000 square feet of commercial space. The mixed-use buildings are placed adjacent to Tennessee St. and include commercial space on the first floor, with the residential units above, and six live/work lofts (consisting of retail/office space on the first floor and the residential unit on the second floor). Commercial uses within the project are located near the southwestern corner of the project site in Building 8 and Building 10. The remainder of the buildings within the project are residential apartments only (see Attachment B – Site Plan).

As currently proposed, there are two primary points of entry into the project, one located off Tennessee Street and one from a proposed future extension of Pennsylvania Avenue. A third access point is located on the southern boundary of the site (to the property to the south that is currently vacant), which may provide entry and exit into any future development that may occur on the vacant parcel located to the south (possibly a shopping center).

There are approximately 190,000 square feet of common/private open space proposed. Proposed outdoor amenities include a walk-through linear park leading to a pool area in the Proposed outdoor amenities include a walk-through linear park leading to a pool area in the center of the project, as well as other open space areas. Additionally, Building 9 will hold leasing offices, a foyer, a mail room and other amenities that may include office/meeting spaces, a kitchen, and movie theater.

The apartment units include 1-bedroom, 2-bedroom, and 3-bedroom units in varying floor plans and sizes. The average sizes of the apartments are: 935sq. ft. for the 1-bedroom units; 1,230sq. ft. for the 2-bedroom units; and 1470sq. ft. for the 3-bedroom units. Attachment C: Project Data includes unit square-footage, unit mix per building, and other project data.

The project will be developed in two phases (See Attachment D). Phase 1 is Redlands Regular Meeting of 12-03-24 289 of 875
made up of the central, western and southwestern portions of the site, which includes the commercial buildings and apartments within buildings 8 through 11 (225 units). Phase 1 would also include construction of all project access points.

Phase 2 consists of the remaining apartments (235 units) located on the northern and eastern portions of the site (Buildings 1 through 6). The required inclusionary units will be split evenly between the two project phases with ten in each phase. The Inclusionary Housing Agreement and the project's Conditions of Approval require that all inclusionary units within the first phase are constructed prior to issuance of a Certificate of Occupancy for any unit within the second phase.

To construct the proposed project, the applicant proposes legislative applications including a Specific Plan Amendment, Zone Change, Density Bonus Agreement, and Inclusionary Housing Agreement.

Specific Plan Amendment: A request to amend the East Valley Corridor Specific Plan (Specific Plan 40) land use map to remove the entire 13.48-acre project site from the Special Development (EV/SD) District.

Zone Change: A request to amend the Zoning Map to designate the project site as “Multiple Family Residential (R-3) District” in accordance with RMC Title 18 (Zoning Regulations).

Density Bonus: A total of 20 residences within the apartment community would be restricted for rental only to Very Low-income households. Therefore, the project is eligible for a Density Bonus and concessions/waivers pursuant to State Density Bonus Law (Gov. Code § 65915 et seq.).

ANALYSIS:

The proposal and project plans were fully evaluated in the staff report prepared for the September 24, 2024, Planning Commission meeting (see Attachment E).

Analysis from the previous report is summarized below.

A) General Plan
The General Plan designation of the property is ‘Commercial’ (see Attachment F). The Commercial land use category designates areas for the development of a wide range of commercial uses, including neighborhood-serving stores and convenience centers, regional commercial centers, and commercial recreation.

Sites with this designation may be developed with a stand-alone commercial use, two or more commercial uses, or mixed uses. The Commercial land use category may permit residential and mixed uses consistent with the underlying zoning district. The proposed mixed-use project is consistent with the existing General Plan Designation.

B) Specific Plan Amendment and Proposed Zoning
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The project is located in the Special Development District (EV/SD) District of the East Valley Corridor Specific Plan, which allows for a wide range of commercial, industrial, and office uses (See Attachment G-1: Existing Zoning Map).

Residential uses are not permitted in this district of the Specific Plan. The applicant is proposing a Specific Plan Amendment to remove the subject parcel from the East Valley Corridor Specific Plan, in conjunction with a Zone Change to General Commercial (C-3) in accordance with Title 18 of the Redlands Municipal Code (See Attachment G-2: Proposed Zoning Map).

The C-3, General Commercial District allows a wide variety of commercial retail and service uses. It also allows residential uses subject to approval of a conditional use permit either as a mixed-use development, or as a multifamily-attached residential project. To establish a mixed-use within the General Commercial District, a Conditional Use Permit is required. Under C-3 zoning (which allows multifamily residential uses based on R-3 density), the base density for this project site would be a maximum of 384 units.

C) Density Bonus
Pursuant to State law, as well as Section 18.228.030(A) of the Redlands Municipal Code, a density bonus granted to a residential development project shall consist of an increase over the otherwise maximum allowable residential density under the applicable zoning ordinance and of the City's General Plan as of the date of application. Projects that deed restrict 5% of the project’s base units for rent to very low-income residents are eligible for a density bonus. The allowable density bonus by State law is up to a 20% increase above the base unit count.

A total of 20 units (or 5%) within the project would be restricted for rental only to Very Low-income households and would be distributed throughout the project site. Therefore, the project is eligible for a Density Bonus pursuant to State Density Bonus Law (Gov. Code Section 65915 et seq.). Through a Density Bonus Agreement, as specified by State law, the applicant may request and be entitled to reductions to on-site parking requirements, incentives and/or concessions, and unlimited waivers or reductions to any development standards that would physically preclude the development of a project at the allowable density.

Within the C-3 District, the allowable density of development is one residential unit for every 1,450 square feet of net land area. The project site is 12.76 net acres (or 555,825.6 square feet), which allows up to 384 units. By providing 20 affordable housing units, the allowable density bonus is equivalent to 20% of the allowable base unit count (384 DU x 0.2 = 76 units). Approval of the project and the related density bonus agreement would allow a total of 460 units (384 + 76 = 460).

As shown in Table 1, the applicant is requesting a density bonus that may be approved based on the General Plan density and the allowable density bonus.

Redlands Regular Meeting of 12-03-24 291 of 875
approved based on the General Plan density and the allowable density bonus.

Table 1. Proposed Project Density
Project’s Net
Acreage
Allowable
Density
Base Units
Allowable
Density Bonus
Units Allowable Total Units

12.76 acres or
555,825.6 sq.
ft.

One unit per
1,450 sq. ft. 384 76 460
The applicant will be required to enter into a Density Bonus Agreement with the City, which requires that 20 units within the project only be rented to very low-income residents for a minimum period of 55 years. The agreement also includes verification and reporting requirements. The Density Bonus Agreement and Inclusionary Housing Agreements are required to be approved by the City Council, drafts of which have been included as Attachment H-1 and H-2 respectively.

D) Commission Review & Approval and Conditional Use Permit New construction over 500 square feet is subject to review by the Planning Commission per Redlands Municipal Code (RMC) Chapter 18.12 and requires Commission Review and Approval for architecture and site plan review. In addition, the project’s proposed mixed-use requires a Conditional Use Permit within the C-3 District as specified in RMC Chapter 18.92.080(B). Project design details are discussed below.

Site Design: The project site is a 12.7-acre property located on the east side of Tennessee Street approximately 600 feet north of Lugonia Avenue. The site is approximately 815’ wide (east to west) and 720’ long (north to south), approximately rectangular, and south of the future extension of Pennsylvania Avenue. Primary vehicular access to the site will be from Tennessee Street and Pennsylvania Avenue. The site plan also includes a potential access point along the south of the project site which may provide access to a future development.

Development Standards: The proposed zoning is C-3 District, and the density standards of the Multiple Family Residential (R-3) District are utilized. While the density standards of the R-3 District apply to the project, the development standards for the C-3 District apply to all other aspects of the project. The project meets the development standards of the C-3 District. Table 3 below summarizes the proposed development’s consistency with the development standards (see Attachment I for a complete list of applicable development standards).

Table 2: Summary of Development Standards - C-3 (General Commercial) Development Standard Requirement Proposed Complies?
Lot area No
Requirement

1.37 acres

1.49 acres

5.02 acres

4.88 acres
Yes
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Lot Coverage No
Requirement 31% Yes
Setbacks No
Requirement
Tennessee St. 25’
Pennsylvania Ave. 18’
Side (South) 55’
Side (East) 10’
Yes
Floor Area Ratio 4.0 1.1 Yes
Building Height No Maximum
Height 4 stories, up to 52’ Yes
Landscaping No
Requirement 15% of the site Yes
Parking Lot landscaping 7% Minimum 15% of the parking area Yes Total Open Space None Required 152,560 sq. ft. Yes
Private Open Space None Required 76-200 sf per unit provided Yes Open Space and Amenities: Within the C-3 Zoning district there is no open space requirement. The project includes four open space areas ranging in size from nearly 3,000 square feet to over 22,000 square feet. The two main outdoor open space areas are located in the center of the project, in the courtyard of Building 9 (14,000 square feet) as well as the courtyard between Buildings 3, 5, and 6 (22,499 square feet). Seating areas, barbeques, a pool, spa, and fire pits are located within these larger outdoor open space areas. The project also includes several indoor amenities that include a gym, theater, office space, and golf simulator.

Site Landscaping: The Landscape Plan (Attachment J) includes a variety of hardscape elements and plant materials which includes trees, shrubs, vines, and groundcover. The project will incorporate 12 tree species, primarily including Brisbane Box, Afghan Pine, Fruitless Olive and Strawberry Trees. Within the C-3 District, there is no minimum overall landscape standard for the site. The project provides over 84,000 square feet of landscaped area, which equates to 15% of the total project area.

A minimum of 7% of the parking lot area is required to be landscaped, which equates to 20,553 square feet. The complete project provides 44,886 square-feet (or 15%) of the parking area as landscaped area, which exceeds the minimum requirement.

Parking: The applicant is providing parking consistent with State Density Bonus Law contained in California Government Code 65915(p)(1), for the residential portion of the project. The project would be required to provide 571 total parking spaces for the 460 units in the residential portion of the project based on what is required by State Density Bonus Law. The project includes 17,899 square feet of neighborhood-serving commercial space, which requires a parking rate of one space per 200 square-feet of floor area (89 commercial spaces). Therefore, the entire project would require a total of 660 spaces, and the proposal provides 764 Redlands Regular Meeting of 12-03-24 293 of 875
entire project would require a total of 660 spaces, and the proposal provides 764 spaces (exceeding the minimum number by 104 spaces). Page G-1.0 of the project plans provides detailed project data including number of resident parking spaces, commercial spaces, types of spaces (e.g., garage, carport, subterranean), etc.

The applicant is requesting a waiver for parking stall dimensions pursuant to Gov. Code § 65915 et seq. (to reduce the depth by 2 feet). City standard parking spaces are required to be 19 feet deep. In certain locations, the project provides surface parking stalls that are 9 feet wide by 17 feet in clear length. As proposed, the parking stalls include 17 feet of paving plus 2 feet of overhang into planter areas, for a total depth of 19 feet.

Walls, Fences, and Gates: All entry points to the residential portions of the project are proposed to have controlled access for security. Three vehicle gates are proposed: two at the southwest portion of the site (with access from Tennessee St.), and one at the northeast corner (with access from a proposed extension of Pennsylvania Ave.). The commercial portions of the project (the southwest corner of the site) will not have gates. A total of 93 parking spaces are placed on the exterior side of the residential entry gates, and therefore vehicular access would not be limited for the commercial portion of the project site.

Architecture: The proposed building design is inspired by the Modern Industrial architectural theme. Towers and varied roof lines, arches, and various horizonal projections provide significant visual interest on all sides of the buildings.

Materials include stone veneer, brick veneer, Limestone cladding, and ceramic tile as well as decorative metal sunshades, awnings, and balcony railings. Stucco colors include varying shades of grey: Aesthetic White (SW 7035), City Loft (SW 7631), Quarry Stone (SW 9603), Soakdubg Gray (SW 6074), and Ironclad (SW 9570). Roofline treatments include squared cornice, such as decorative tile or high-density foam with cementitious finish. Table 4 summarizes the buildings sizes, heights, and treatments.

Proposed architectural elevations are provided as Attachment K-1 (Project Material and Elevations). Floor plans are included as Attachment K-2, and architectural 3-D renderings are provided as Attachment K-3. Analysis of the project’s consistency with the City’s Architectural Guidelines is included as Attachment K-4, and staff believes the project to be consistent with the architectural guidelines.

E) Tentative Parcel Map
The applicant is proposing to subdivide the 12.76-acre (net) subject site into four new parcels. As proposed, Parcel 1 will be 1.37 gross acres, Parcel 2 will be

1.49 acres, Parcel 3 will be 5.02 acres and Parcel 4 will be 4.88 acres. Within the C-3 District, there are no minimum lot sizes and no required lot dimensions. As proposed the resulting lots will be consistent with the Redlands Municipal Code requirements. A Condition of Approval has been added requiring the applicant to Redlands Regular Meeting of 12-03-24 294 of 875
requirements. A Condition of Approval has been added requiring the applicant to provide shared access across all parcels within the project. A copy of the Tentative Parcel Map is included as Attachment L.

F) Socio-Economic Cost / Benefit Study
In accordance with the Principals of Managed Development Element of the General Plan, a Socio-Economic Cost/Benefit Study (Attachment M) has been completed for the project. Based on the cost/benefit model utilized by the City, the project provides a positive cost/benefit ratio of 1.75 over the period of 2025-2034 (and results in positive net revenue to the City after development).

This project will provide the City approximately $564,399 in revenue (exceeding costs to the City of $322,042) which results in revenue of $242,357 annually and the project will not create a physical blight or overburden public services in the community.

ENVIRONMENTAL REVIEW:

The City retained an environmental consultant to fully analyze the project and prepare an Initial Study in accordance with the California Environmental Quality Act (CEQA) (see Attachment N-1– ISMND). In accordance with the CEQA Guidelines, the Initial Study/Mitigated Negative Declaration (IS/MND) was made available for public review and comment for 30 days (State Clearinghouse No. 2024040956). A Notice of Intent was filed with the County Clerk on April 24, 2024, and with the State Clearinghouse. The IS/MND was circulated for 30 days between April 24, 2024, and May 27, 2024. The public review Initial Study and Mitigated Negative Declaration was also made available via the City’s website (www.cityofredlands.org/post/environmental-documents).

One public comment letter was received from Lozeau Drury, LLP, an environmental law firm representing Supporters Alliance for Environmental Responsibility (“SAFER”). Comments within the letter focus on Air Quality and Biological Resources. There is no information or evidence identifying any potentially significant impacts as a result of the project, and the city’s environmental consultant has provided a written Response to Comments document (see Attachment N-2).

The Initial Study recommends a Mitigated Negative Declaration with 13 mitigation measures that pertain to Biological Resources, Cultural Resources, Geological Resources, Noise, and Tribal Cultural Resources. All mitigation measures will ensure that any environmental effects are less than significant.

After mitigation, no significant effects were identified as a result of the project, and the recommended mitigation measures will be incorporated into the project as mandatory Conditions of Approval. The Mitigation/ Monitoring and Reporting Program details the mitigation measures and is included as Attachment N-3.

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ALTERNATIVES:

The City Council may continue the public hearing and direct staff to address any issues or bring back additional information; or

1. The City Council may wish to deny the project, continue the public hearing and direct staff to prepare findings supporting denial of the project.

2. SUBMITTED BY:

Brian Desatnik, Development Services Director
RECOMMENDED BY:

Charles M. Duggan Jr., City Manager
REVIEWED BY:

Yvette M. Abich Garcia, City Attorney
Janice McConnell, Assistant City Manager
Christopher Boatman, Assistant City Manager
Danielle Garcia, Management Services /Finance Director
PREPARED BY:

Sean Reilly, Principal Planner
Attachments
Attachment A: Location Map
Attachment B: Site Plan
Attachment C: Project Data Sheet
Attachment D: Phasing Exhibit
Attachment E: September 24, 2024 Planning Commission Staff Report Attachment F: General Plan Land Use Map
Attachment G-1: Zoning Map (Existing)
Attachment G-2: Zoning Map (Proposed)
Attachment H-1: Density Bonus Agreement
Attachment H-2: Inclusionary Housing Agreement
Attachment I: Table of Development Standards
Attachment J: Landscape Plans
Attachment K-1: Building Materials and Elevations
Attachment K-2: Floor Plans
Attachment K-3: Architectural 3-D Renderings
Attachment K-4: Consistency with Architectural Guidelines Attachment L: Tentative Parcel Map No. 20688
Attachment M: Socio-Economic Cost/Benefit Study
Attachment N-1: Initial Study/Mitigated Negative Declaration Redlands Regular Meeting of 12-03-24 296 of 875
Attachment N-1: Initial Study/Mitigated Negative Declaration Attachment N-2: Responses to Comments
Attachment N-3: Mitigation Monitoring and Report Program Attachment O-1: Resolution No. 8641
Attachment O-2: Engineering Conditions of Approval
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Redlands Regular Meeting of 12-03-24 298 of 875
T
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A

COURTYARD

TENNESSEE STREET

PENNSYLVANIA AVENUE
C
C
D
D
E
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F F
G G
A3
B5
B5
A3UP 18R B5UP 18R B5
A1 Abv.

A1 Abv.
5' DIA.
30" DIA.
30 48
SIDE

APPROACH
+54" MAX. A.F.S.
30" DIA.
30 48
SIDE

APPROACH
+54" MAX. A.F.S.
24" DIA.
30 48SIDE

APPROACH
+54" MAX. A.F.S.

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A1 Abv.

A1 Abv.

A1 Abv.

A1-Den Abv.

ELECTRICAL MPOE
MSIa H. M.

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A1-DEN Abv.
5' DIA.
30" DIA.
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APPROACH
+54" MAX. A.F.S.
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30 48
SIDE

APPROACH
+54" MAX. A.F.S.
24" DIA.
30 48
SIDE

APPROACH
+54" MAX. A.F.S.

B1 Abv. A1 Abv. B1 Abv.

UP 18R UP 18R
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A3 A3 B5

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MSIa H. M.

EP
ELEV.RM
EP
B3
B3
EP
EP
B3
B3
B1 Abv.

B1 Abv.

B1 Abv.

UP 18R
A1 Abv.

MAINT.

A1 Abv.

A1 Abv.

A1 Abv.

A3
A3
UP 18R

ENTERTAINMENT

MAILROOM
AMAZON
LOUNGE

LEASING
24'-0" x 26'-8" OFFICE 1
13'-6" x 10'-4" OFFICE 213'-6" x 10'-5" DECORATIVE COFFERED

CEILING
10'-3" x 12'-2" BREAK RM.

BAR
W
FAU

PACKAGE

PARCEL/
10'-3" x 20'-0"
JAN./STR. 35'-0" x 35'-0" CLUBROOM
M
POOL
60-0" x 35'-0"
(+/-3,038 SQ.FT.) FITNESS
J. STR.

EQPT.
38'-0" x 36'-0" THEATER
M W

GOLF SIMULATOR
17'-9" x 20'-0"
STR.
17'-4" x 33'-6" YOGA
ELECT.

CREATIVE

BREEZEWAY
(+/-1,438 SQ.FT.)
A1 Abv.
(+/-665 SQ.FT.)
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

ELEV. RM
OFFICE
A1 Abv. A1 Abv. A1 Abv. A1 Abv. A1-den Abv. A1-den Abv. 5' DIA. 30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

UP 9R
UP 9R
DN 9R
A3
B5
B5
A3UP 18R B5UP 18R B5
A1 Abv.

A1 Abv.
5' DIA.
30" DIA.
30 48SIDE

APPROACH
+54" MAX. A.F.S.
30" DIA.
30 48
SIDE

APPROACH
+54" MAX. A.F.S.
24" DIA.
30 48
SIDE

APPROACH
+54" MAX. A.F.S.

ELEV.RM
A1 Abv.

A1 Abv.

A1 Abv.

A1-Den Abv.

ELECTRICAL MPOE
MSIa H. M.

A1 Abv.

A1 Abv.

COATS
UP
A3-LW

UPCOATS
A3-LW
B4-LW
B4
A3-LW
UP 18R
UP 18R

ELECTRICAL MPOE STORAGE
MSIa H. M.

COATS
UP
B1 Abv.

A1 Abv.

A1 Abv.

B1 Abv.

UP 18R A1
A1
A1
A1

ELECTRICAL MPOE
MSIa H. M.

UP 18R
T
BLDG 7
TYPE E

COURTYARD
2 RAMP DN.

B4
ELEV. RM

COMMERCIAL
OPEN TO ABV.

OPEN TO ABV.

OPEN TO ABV. RETAIL 1
RETAIL 2
EP
W/D

MOVABLE
ISLAND
60" TUB
P.

EP
W/D

MOVABLE
ISLAND
60" TUB
P.

A4
A4
UP 18R B5
TRASH
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

ROOM
UP 9R
DN 9R
UP 9R
B4-LW
UP 18R
A3
B5 B5

UPCOATS
A3-LW

MPOE ELECTRICAL
H. M. MSIa
6'-0"
T
GATE 1
GATE 2
BLDG 1
TYPE A

COURTYARD
1 T
GATE 3
T
TRASH

COURTYARD
4 CALL
BOX
TRASH
(RETAIL)
ELEV. RM
UP 18R
A1 Abv. A1 Abv. A1 Abv.

B1 Abv.

B4
CB CB C1
B5 B4
A3
TRASH
RM. 5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

ELECT.

UP 18R
A3 B5 B5 B5
A3
A3
A3 B1 Abv.

TRASH
ROOM 1
TRASH
ROOM
TRASH
ROOM
BLDG 8
TYPE H
T
BLDG 9
TYPE D
BLDG 10
TYPE G
TENNESSEE ST.

PROJECT
TENNESSEE ST.

PENNSYLVANIA AVE.

BLDG 6
TYPE C
TRASH
ROOM 2
TRASH
ROOM
T

PROJECT
ENTRY 3

PROJECT
ENTRY 1
GATE
4 PROP.

R/W

SETBACK
PROP. R/W
PROP.

LINE
PROP.

LINE
EX. R/W
EX. BDY.

CB CB
C1
ELEV.RM
A1-DEN Abv.
5' DIA.
30" DIA.
30 48SIDE

APPROACH
+54" MAX. A.F.S.
30" DIA.
30 48
SIDE

APPROACH
+54" MAX. A.F.S.
24" DIA.
30 48
SIDE

APPROACH
+54" MAX. A.F.S.

B1 Abv. A1 Abv. B1 Abv.

UP 18R UP 18R
A1 Abv.

A3 A3 B5

ELECTRICAL MPOE
MSIa H. M.

BLDG 5
TYPE C
C1
CB CB
ELEV.RM
A1-DEN Abv.
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S. B1 Abv.

ELECT.

CB CB C1 UP 18R
A1 Abv. B1 Abv. B1 Abv.

B5
UP 18R
(DOUBLE VOLUME)
B5 Abv. B5 Abv.

B1 Abv. B1 Abv.

B5
B1 Abv. B1 Abv.

B5 B5

CALIFORNIA ROOMBREEZEWAY
A3 A3
BLDG 3
TYPE B
C1 Abv.

AMENITY
C1 Abv.

AMENITY
TRASH
ROOM
ROOM
TRASH
ROOM
TRASH
20'-0"
20'-0"
10'-0"
10'-0"
26'-0" 26'-0"142'-3" 143'-11"
11'-2
1 8
"
25'-
15'-0"
3'-6
1 2
" 3'-6
1 2
"
1 1
1 1

PROPOSED

SETBACK
PROP
SETBA
KMLV KMLV KMLVKMLV KMLV KMLV KMLV KMLV KMLV KMLV KMLV KMLV KMLV KMLV KMLVKMLV KMLV KMLV B3X B4 B1X B2XB B1B1 B4 B3 B1 B4 B1 ABV. B3
A1
B1 ABV.

A1 A1
B1 ABV.

TRASH
T
TRASH
ELECT.RM.

BLDG 11
TYPE F
48 8
BLDG 2
TYPE A
K
K
K
k
k
k
k
k
F.H
F.H
F.H
F.H
F.H
F.H
F.H
F.H
DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730(909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 01-10-2024 JOB NO.: 2020-322 APN: 0167-171-15
1"=40'-0"
0 20' 40' 80' 120'

CONCEPTUAL SITE PLAN
A-1.0
NORTH
3 STORY
4 STORY

RETAIL/

COMMERICIAL
APN: 0167-171-07
0167-171-14
NOTE:

THE MONUMENT WALL/WIGNS ARE UNDER A
SEPARATE PERMIT. SEE L-1.0
Redlands Regular Meeting of 12-03-24 299 of 875
DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 01-10-2024 JOB NO.: 2020-322 APN: 0167-171-15 G-1.0 PROJECT DATA 1 235687910111 234567891011 Redlands Regular Meeting of 12-03-24 300 of 875
T
T
T
T
T
T

A COURTYARD

TENNESSEE STREET PENNSYLVANIA AVENUE
C
C
D
D
E
E
F F
G G
B5
B5
A3
A3UP 18R B5 UP 18R B5
A1 Abv.

A1 Abv.
5' DIA. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 24" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. ELEV.RM
A1 Abv.

A1 Abv.

A1 Abv.

A1-Den Abv.

MPOE ELECTRICAL
H. M. MSIa C1
CB CB
ELEV.RM A1-DEN Abv.
5' DIA. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 24" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. B1 Abv. A1 Abv. B1 Abv. UP 18R UP 18R A1 Abv. B5 A3 A3

MPOE ELECTRICAL
H. M. MSIa
EP
ELEV.RM
EP
B3
B3
EP
EP
B3
B3
B1 Abv.

B1 Abv.

B1 Abv.

UP 18R
A1 Abv.

MAINT.

A1 Abv.

A1 Abv.

A1 Abv.

A3
A3 UP 18R

ENTERTAINMENT

MAILROOM
AMAZON
LOUNGE

LEASING
24'-0" x 26'-8" OFFICE 1
13'-6" x 10'-4" OFFICE 213'-6" x 10'-5" DECORATIVE COFFERED

CEILING
10'-3" x 12'-2" BREAK RM.

BAR
W
FAU

PARCEL/ PACKAGE
10'-3" x 20'-0"
JAN./STR. CLUBROOM
35'-0" x 35'-0"
M
POOL 60-0" x 35'-0" FITNESS
(+/-3,038 SQ.FT.)
J. STR. EQPT.
38'-0" x 36'-0" THEATER
W M

GOLF SIMULATOR
17'-9" x 20'-0"
STR.
17'-4" x 33'-6" YOGA
ELECT.

CREATIVE BREEZEWAY
(+/-1,438 SQ.FT.)
A1 Abv.
(+/-665 SQ.FT.) 5' DIA.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
24" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.

ELEV. RM
OFFICE
A1-den Abv. A1 Abv. A1 Abv. A1 Abv. A1-den Abv. A1 Abv. 5' DIA. 30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
24" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.

UP 9R DN 9R
UP 9R
B5
B5
A3
A3UP 18R B5UP 18R B5
A1 Abv.

A1 Abv.
5' DIA. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 24" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. ELEV.RM
A1 Abv.

A1 Abv.

A1 Abv.

A1-Den Abv.

MPOE ELECTRICAL
H. M. MSIa
A1 Abv.

A1 Abv.

UP
COATS
A3-LW UP COATS A3-LW
B4-LW
B4
A3-LW
UP 18R UP 18R ELECTRICAL MPOE STORAGE MSIa H. M.

UP
COATS
B1 Abv.

A1 Abv.

A1 Abv.

B1 Abv. UP 18R A1
A1
A1
A1

ELECTRICAL MPOE
MSIa H. M. UP 18R
T
BLDG 7
TYPE E

COURTYARD
2 RAMP DN.

B4
ELEV. RM COMMERCIAL
OPEN TO ABV.

OPEN TO ABV.

OPEN TO ABV. RETAIL 1
RETAIL 2
EP W/D

MOVABLE
ISLAND
60" TUB
P.

EP W/D MOVABLE ISLAND 60" TUB P.

A4
A4 UP 18R B5
TRASH 5' DIA.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
24" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.

ROOM
UP 9R
DN 9R
UP 9R
B4-LW UP 18R
A3
B5 B5 COATS UP
A3-LW
T
GATE 1
GATE 2
BLDG 1
TYPE A

COURTYARD
1 T
GATE 3
T
TRASH

COURTYARD
4 CALL
BOX
TRASH
(RETAIL)
ELEV. RM UP 18R
A1 Abv. A1 Abv. A1 Abv.

B1 Abv.

B4
CB CB C1
B5 B4
A3
TRASH
RM. 5' DIA.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
24" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.

ELECT. UP 18R
A3 B5 B5 B5
A3
A3 B1 Abv. A3
TRASH
ROOM 1
TRASH
ROOM
TRASH
ROOM
BLDG 8
TYPE H
T
BLDG 9
TYPE D
BLDG 10
TYPE G
TENNESSEE ST.

PROJECT
ENTRY 2
TENNESSEE ST. PENNSYLVANIA AVE.

BLDG 6
TYPE C
TRASH
ROOM 2
TRASH
ROOM
T

PROJECT
ENTRY 3

PROJECT
ENTRY 1
GATE
4 PROP.

R/W

SETBACK
PROP. R/W
PROP.

LINE
PROP.

LINE
EX. R/W
EX. BDY.

CB CB C1
ELEV.RM A1-DEN Abv.
5' DIA. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 30" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. 24" DIA.
30 48 SIDE APPROACH +54" MAX. A.F.S. B1 Abv. A1 Abv. B1 Abv. UP 18R UP 18R A1 Abv. B5 A3 A3

ELECTRICAL MPOE
MSIa H. M.

BLDG 5
TYPE C CB CB C1 ELEV.RM
A1-DEN Abv. 5' DIA.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
30" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S.
24" DIA. 30
48 SIDE APPROACH +54" MAX. A.F.S. B1 Abv. ELECT. CB CB
UP 18R C1
B1 Abv. B1 Abv. A1 Abv.

B5
UP 18R (DOUBLE VOLUME)
B5 Abv. B5 Abv.

B1 Abv. B1 Abv.

B5
B1 Abv. B1 Abv.

B5 B5

CALIFORNIA ROOMBREEZEWAY
A3 A3
BLDG 3
TYPE B
C1 Abv.

AMENITY
C1 Abv.

AMENITY
TRASH
ROOM
TRASH
ROOM
TRASH
ROOM 20'-0" 20'-0" 10'-0"
25'- PROPOSED SETBACK
PROP
SETBA B3; B3
BLDG 11
TYPE F

LOADING DOCK
SHOPS 2
8,775 SF
MAJOR 1
43,000 SF
15 24
PAD 2
SHOPS 1
3,000 SF
6,032 SF
45 48
PAD 1
2,304 SF
8 41 35 13
24 14
5 20 3
8 12
8 SHOPS 3
7,500 SF
14 5
4 8
BLDG 2
TYPE A
K
K
K
K
F.H
F.H
F.H
F.H
F.H
F.H
F.H
F.H

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
1"=40'-0"
0 20' 40' 80' 120'

PHASING PLAN
P-1
NORTH
3 STORY
4 STORY

RETAIL/

COMMERICIAL
APN: 0167-171-07
0167-171-14

PHASE II PHASE I PHASE II
DATE: 01-10-2024 APN: 0167-171-15

PEOJECT
ENTRY 2
Redlands Regular Meeting of 12-03-24 301 of 875
City of Redlands

REQUEST FOR PLANNING COMMISSION ACTION
Planning Commission Agenda Item NO. 4. A.

Meeting Date: 09/24/2024
APPLICANT:

DIVERSIFIED PACIFIC DEVELOPMENT GROUP, LLC., APPLICANT
(PROJECT PLANNER: SEAN REILLY, PRINCIPAL PLANNER)
A PUBLIC HEARING to consider a recommendation to the City Council on the following development applications for the “Tennessee Village” project located on a 13.48 gross acre site located on the east side of Tennessee Street approximately 600 feet north of West Lugonia Avenue within the Special Development (EV/SD) District of the East Valley Corridor Specific Plan (APN: 0167-171-15-0000):

1. Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program prepared for the project in accordance with Section15074 of the California Environmental Quality Act.

2. Socio-Economic Cost/Benefit Study prepared for the proposed project as required by Measure U.

3. Amendment No. 50 to Specific Plan 40 – A request to amend the East Valley Corridor Specific Plan (Specific Plan No. 40) to remove the project site consisting of 13.48 acres (gross) from the boundaries of Specific Plan 40 area.

4. Zone Change No. 477 – A request to change the zoning designation of the 13.48 gross acre project site from Special Development (EV/SD) District to General Commercial (C-3) District.

5. Tentative Parcel Map No. 20688 – A request to subdivide the entire project site into four parcels consisting of 1.37 net acres, 1.49 net acres, 5.02 net acres, and 4.88 net acres in size.

6. Conditional Use Permit No. 1173 – A request to construct a mixed-use project consisting of 460 apartments and approximately 18,000 square feet of commercial space on a vacant

13.48-acre site as allowed in the C-3, General Commercial District.

7. Commission Review and Approval No. 956 – A request for site plan approval and architectural design review to construct a mixed used development composed of 460 apartment units within ten buildings and approximately 18,000 square feet of commercial space. The residential units include one-bedroom, two-bedroom, and three-bedroom floor plans ranging from 755 to 1,599 square feet each.

8. Density Bonus Agreement with Declaration of Affordable Housing Covenants and Restrictions – A request to approve a Density Bonus Agreement which sets forth the terms and conditions to allow the Density Bonus Units and increased density for the project, the concessions and waivers that the developer is entitled to pursuant to State law, and affordability covenants to ensure the affordability of twenty (20) apartment units for Very Low Income households.

Redlands Regular Meeting of 12-03-24 302 of 875

SYNOPSIS

1.  General Plan
Designation: Commercial

2.  Existing Zoning: Special Development (EV/SD) District of the East Valley Corridor Specific Plan

3.  Surrounding Zoning:

North: Concept Plan No. 4 (CP-4)
South: Special Development (EV/SD)
East: Multiple-Family Residential (R-3)
West: General Commercial (EV/CG)

4.  Existing Land Use: Vacant

5.  Surrounding Land
Use:

North: Vacant
South: Vacant
East: Vacant (future Lugonia Village multifamily residential project) West: Vacant

6.  Area / Topography: The site is generally flat with a slight down slope grade to the north.

7.  Environmental
Determination:

A Mitigated Negative Declaration has been prepared for the project in accordance with Section 15074 of the CEQA Guidelines.

8.  Socio-Economic
Cost / Benefit Study:

The project has a positive cost/revenue ratio of +1.75 and determined that the project would not create significant unmitigable physical blight or overburden public services in the community.

9.  Planning
Commission Submittal
Dates:
(A) Date Submitted:
(B) Date Accepted As Complete:
(C) Planning Commission Meeting:

November 7, 2022
March 5, 2024
September 24, 2024

PROPOSAL
The applicant proposes to develop a vacant property 13.48 acres in size (12.79 acres net) with ten buildings, which include a mix of residential and commercial uses. The site is located on the east side of Tennessee Street and approximately 600 feet north of West Lugonia Avenue (see Attachment A – Location Map and Aerial Photo).

The proposal includes 460 residential units and approximately 18,000 square feet of commercial space. The mixed-use buildings are placed adjacent to Tennessee St. and include commercial space on the ground floor, with the residential units above, and six live/work lofts (consisting of retail/office space on the ground floor and the residential unit on the second floor). Commercial uses within the project are located near the southwestern corner of the project site in Building 8 and Building 10. The remainder of the buildings within the project are residential apartments only (see Attachment B – Site Plan).

As currently proposed, there are two primary points of entry into the project, one located off Tennessee Street and one from a proposed future extension of Pennsylvania Avenue. A third access point is located on the southern boundary of the site (to the property to the south that is currently vacant), which may provide entry and exit into any future development that may occur on the vacant parcel located to the south (possibly a shopping center).

There are approximately 190,000 square feet of common/private open space proposed.

Proposed outdoor amenities include a walk-through linear park leading to a pool area in the Redlands Regular Meeting of 12-03-24 303 of 875
Proposed outdoor amenities include a walk-through linear park leading to a pool area in the center of the project as well as other open space areas. Additionally, Building 9 will hold leasing offices, a foyer, a mail room and other amenities that may include office/meeting spaces, kitchen, and movie theater.

Table 1 below summarizes the unit count and use mix within the project, by Building Number.

The apartment units include 1-bedroom, 2-bedroom, and 3-bedroom units in varying floor plans and sizes. The average sizes of the apartments are: 935sq. ft. for the 1-bedroom units; 1,230sq. ft. for the 2-bedroom units; and 1470sq. ft. for the 3-bedroom units. Attachment C: Project Data includes unit square-footage, unit mix per building, and other project data.

Table 1: Proposed Unit Mix and Commercial Square-Footage Building # 1 BR units /
Live-Work
2 BR units /
Live-Work 3 BR units Total Units(per Bldg.)
Commercial
Sq. Ft.
1 26 16 - 42 0
2 26 16 - 42 0
3 14 41 8 63 0
5 17 10 7 34 0
6 17 10 7 34 0
7 16 4 0 20 0
8 7/3 4/1 0 15 3,914
9 57 36 0 93 13,982
10 26/1 26/1 0 54 0
11 29 30 4 63 0
Sub-total: 239 DU 195 DU 26 DU -- --
Total: 460 DU 17,896 SF

To construct the proposed project, the applicant proposes legislative applications including a Specific Plan Amendment, Zone Change, Density Bonus Agreement, and Inclusionary Housing Agreement.

Specific Plan Amendment: A request to amend the East Valley Corridor Specific Plan (Specific Plan 40) land use map to remove the entire 13.48-acre project site from the Special Development (EV/SD) District.

Zone Change: A request to amend the Zoning Map to designate the project site as “Multiple Family Residential (R-3) District” in accordance with RMC Title 18 (Zoning Regulations).

Density Bonus: A total of 20 residences within the apartment community would be restricted for rental only to Very Low-income households. Therefore, the project is eligible for a Density Bonus and concessions/waivers pursuant to State Density Bonus Law (Gov. Code § 65915 et seq.).

The proposed project would restrict a total of 20 units, which is 5% of the base unit count of the project (384 DU x 0.05 = 20) for affordable housing in exchange for approval of a density bonus.

By providing 20 affordable housing units, the allowable density bonus is equivalent to 20% of the allowable base unit count (384 DU x 0.2 = 76 units). Approval of the project and the related density bonus agreement would allow a total of 460 units (384 + 76 = 460).

Phasing Plan: The project will be developed in two phases (See Attachment D). Phase 1 is Redlands Regular Meeting of 12-03-24 304 of 875
made up of the central, western and southwestern portions of the site, which includes the commercial buildings and apartments within buildings 8 through 11 (225 units). Phase 1 would also include construction of all project access points. Phase 2 consists of the remaining apartments (235 units) located on the north and eastern portions of the site (Buildings 1 through 6). The required inclusionary units will be split evenly between the two project phases with ten in each phase. The Inclusionary Housing Agreement and the project's Conditions of Approval require that all inclusionary units within the first phase are constructed prior to issuance of a Certificate of Occupancy for any unit within the second phase.

BACKGROUND
The project site currently consists of vacant and unimproved land. Historic aerial surveys indicate that the site previously supported agricultural uses (citrus groves); however, agricultural use of the property ceased between 1980 and 1984 based upon historic aerials of the project area.

Recent residential developments in the vicinity have been driven in large part by the construction of Citrus Valley High School founded in 2009 (located one-half mile to the north of the proposed project site), and further residential and commercial construction in the area can be expected.

In 2020, the Heritage Specific Plan (Specific Plan No 62) located on the northwest corner of San Bernardino Avenue and Texas Street was approved (and now fully constructed). This project allowed the construction of 207 homes on the 37-acre site.

In 2021, the Bergamot Specific Plan (Specific Plan No. 64) located north of Domestic Avenue and west of Texas Street, was approved for the construction of 317 homes on 38 acres within three neighborhoods with lot sizes ranging from 1,900 sf to over 7,200 square feet. This project is currently under construction.

In 2024, the Bergamot Specific Plan was amended to include an additional 14.6 acres located west of Citrus Valley High School and north of San Bernardino Avenue, for the construction of an additional 117 single-family homes. This project is currently in the process of obtaining building permits.

In 2024, the Lugonia Village multifamily residential project was approved by the City Council.

This project is located north of Lugonia Avenue, South of Pennsylvania Avenue and west of Karon Street (directly to the east of the proposed project).  The Lugonia Village project includes a total of 541 residential units in three distinct neighborhoods and includes single-family homes, townhomes, and apartments.
2021-2029 Housing Element: The City’s new 2021-2029 Housing Element was certified by the California Department of Housing & Community Development (HCD) on September 26, 2022.

State Law requires it to include housing programs that identify adequate sites to accommodate the jurisdiction's share of the Regional Housing Needs Allocation (RHNA); assist in the approval of housing for Very Low- and Low-income households; and remove or mitigate governmental constraints that inhibit building more affordable housing.

Housing Crisis Act of 2019: The Housing Crisis Act of 2019, also referred to as Senate Bill 330 Redlands Regular Meeting of 12-03-24 305 of 875
Housing Crisis Act of 2019: The Housing Crisis Act of 2019, also referred to as Senate Bill 330 (SB 330), became effective on January 1, 2020. SB 330 imposes several limitations on cities and counties with regard to proposed housing development projects, including the provisions listed below.

The City may conduct no more than five (5) hearings on the project (including any Commission or Board meetings, workshops, subcommittee meetings, etc.).

The City may still use its Architectural Design Guidelines that were previously adopted in 2009, provided the City does not: a) deny the project, or b) reduce the number of dwelling units based on non-conformance with subjective design criteria.

Requires any disapproval of a project that complies with objective General Plan and zoning standards (or approve it on the condition that it be developed at a lower density) to base its decision upon written findings supported by substantial evidence in the record and places the burden of proof on the local agency.

Prohibits the City from changing the zoning or development standards that would:
change the allowable land use to a less intensive use or reducing the intensity of use below that which was in effect on January 1, 2018; impose or enforce a moratorium on housing development within all or a portion of the jurisdiction of the city; and, impose or enforce new design standards established on or after January 1, 2020, that are not objective design standards, as defined.

ANALYSIS
A) General Plan
The General Plan designation of the property is ‘Commercial’ (see Attachment E). The Commercial land use category designates areas for the development of a wide range of commercial uses, including neighborhood-serving stores and convenience centers, regional commercial centers, and commercial recreation. Sites with this designation may be developed with a stand-alone commercial use, two or more commercial uses, or mixed uses. The Commercial land use category may permit residential and mixed uses consistent with the underlying zoning district.

In addition, there are several General Plan policies and actions that are relevant to this proposal.

These are as follow:

Action 4-A.7: Promote a range of residential densities to encourage a mix of housing types in varying price ranges and rental rates.

Policy 4-P.16: Promote a variety of housing types to serve the diverse needs of the community.

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

Action 4-A.8: Promote the development of a greater variety of housing types, including single-family homes on small lots, accessory dwelling units, townhomes, lofts, live-work spaces, and senior and student housing to meet the needs of future demographics and changing family sizes.

B) Specific Plan Amendment and Proposed Zoning
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The project is located in the Special Development District (EV/SD) District of the East Valley Corridor Specific Plan, which allows for a wide range of commercial, industrial, and office uses (See Attachment F-1: Existing Zoning Map). Residential uses are not permitted in this district of the Specific Plan. The applicant is proposing a Specific Plan Amendment to remove the subject parcel from the East Valley Corridor Specific Plan, in conjunction with a Zone Change to General Commercial (C-3) in accordance with Title 18 of the Redlands Municipal Code (See Attachment F-2: Proposed Zoning Map).

The C-3, General Commercial District allows a wide variety of commercial retail and service uses. It also allows residential uses subject to approval of a conditional use permit either as a mixed-use development, or as a multifamily-attached residential project. To establish a mixed-use within the General Commercial District, a Conditional Use Permit is also required.

Under C-3 zoning (which allows multifamily residential uses based on R-3 density), the base density for this project site would be a maximum of 384 units.

Density Bonus
A total of 20 units (or 5%) within the project would be restricted for rental only to Very Low-income households and would be distributed throughout the project site. Therefore, the project is eligible for a Density Bonus Agreement pursuant to State Density Bonus Law (Gov.

Code Section 65915 et seq.). Through this agreement, as specified by State law, the applicant may request and be entitled to reductions to on-site parking requirements, incentives and/or concessions, and unlimited waivers or reductions to any development standards that would physically preclude the development of a project at the allowable density.

Pursuant to State law, as well as Section 18.228.030(A) of the Redlands Municipal Code, a density bonus granted to a residential development project shall consist of an increase over the otherwise maximum allowable residential density under the applicable zoning ordinance and of the City's General Plan as of the date of application. Projects that deed restrict 5% of the project’s base units for rent to very low-income residents are eligible for a density bonus. The allowable density bonus by State law is up to a 20% increase above the base unit count.

Within the C-3 District, the allowable density of development is one residential unit for every 1,450 square feet of net land area. The project site is 12.76 net acres (or 555,825.6 square feet), which allows up to 384 units.

As shown in Table 2, the applicant is requesting a density bonus that may be approved based on the General Plan density and the allowable density bonus.

Table 2. Proposed Project Density
Project’s Net
Acreage
Allowable
Density
Base Units
Allowable
Density Bonus
Units Allowable Total Units

12.76 acres or
555,825.6 sq. ft.

One unit per
1,450 sq. ft. 384 76 460

The applicant will be required to enter into a Density Bonus Agreement with the City, which requires that 20 units within the project only be rented to very low-income residents for a minimum period of 55 years. The agreement also includes verification and reporting requirements. The Density Bonus Agreement and Inclusionary Housing Agreements are required to be approved by the City Council, drafts of which have been included as Attachment Redlands Regular Meeting of 12-03-24 307 of 875
G-1 and G-2 respectively.

C) Commission Review & Approval and Conditional Use Permit New construction over 500 square feet is subject to review by the Planning Commission per Redlands Municipal Code (RMC) Chapter 18.12 and requires Commission Review and Approval for architecture and site plan review. In addition, the project’s proposed mixed-use requires a Conditional Use Permit within the C-3 District as specified in RMC Chapter 18.92.080(B).

Project design details are discussed below.

Site Design: The project site is a 12.7-acre property located on the east side of Tennessee Street approximately 600 feet north of Lugonia Avenue. The site is approximately 815’ wide (east to west) and 720’ long (north to south), approximately rectangular, and south of the future extension of Pennsylvania Avenue. Primary vehicular access to the site will be from Tennessee Street and Pennsylvania Avenue. The site plan also includes a potential access point along the south of the project site which may provide access to a future development.

Development Standards: The proposed zoning is C-3 District, and the density standards of the Multiple Family Residential (R-3) District are utilized. While the density standards of the R-3 District apply to the project, the development standards for the C-3 District apply to all other aspects of the project. The project meets the development standards of the C-3 District. Table 3 below summarizes the proposed development’s consistency with the development standards (see Attachment H for a complete list of applicable development standards).

Table 3: Summary of Development Standards - C-3 (General Commercial) District Development
Standard Requirement Proposed Complies?
Lot area No Requirement

1.37 acres

1.49 acres

5.02 acres

4.88 acres
Yes
Lot Coverage No Requirement 31% Yes
Setbacks No Requirement
Tennessee St.  25’
Pennsylvania Ave. 18’
Side (South) 55’
Side (East) 10’
Yes
Floor Area Ratio 4.0 1.1 Yes
Building Height No Maximum Height 4 stories, up to 52’ Yes Landscaping No Requirement 15% of the site Yes
Parking Lot
landscaping 7% Minimum 15% of the parkingarea
Yes
Total Open Space None Required 152,560 sq. ft. Yes
Private Open Space None Required  76-200 sq. ft.
per unit provided Yes

Redlands Regular Meeting of 12-03-24 308 of 875

Open Space and Amenities: Within the C-3 Zoning district there is no open space requirement.

The project includes four open space areas ranging in size from nearly 3,000 square feet to over 22,000 square feet. The two main outdoor open space areas are located in the center of the project, in the courtyard of Building 9 (14,000 square feet) as well as the courtyard between Buildings 3, 5, and 6 (22,499 square feet). Seating areas, barbeques, a pool, spa, and fire pits are located within these larger outdoor open space areas. The project also includes several indoor amenities that include a gym, theater, office space, and golf simulator.

Each of the apartment units includes private open space in the form of a patio or balcony. These private open spaces vary in size based upon the unit type and location, ranging from 76 square feet up to 200 square feet.

Site Landscaping: The Landscape Plan (Attachment I) includes a variety of hardscape elements and plant materials which includes trees, shrubs, vines, and groundcover. The project will incorporate 12 tree species, primarily including Brisbane Box, Afghan Pine, Fruitless Olive and Strawberry Trees. Within the C-3 District, there is no minimum overall landscape standard for the site. The project provides over 84,000 square feet of landscaped area, which equates to 15% of the total project area.

A minimum of 7% of the parking lot area is required to be landscaped, which equates to 20,553 square feet. The complete project provides 44,886 square-feet (or 15%) of the parking area as landscaped area, which exceeds the minimum requirement.

Parking: The applicant is providing parking consistent with State Density Bonus Law contained in California Government Code 65915(p)(1), which states that upon the request of the developer, a city, county, or city and county shall not require a vehicular parking ratio, inclusive of handicapped and guest parking, that exceeds the following ratios.

Table 4: Parking Ratios
Unit Type Required Spaces
per Unit
1 BR 1 Space
2 BR 1.5 Spaces
3 BR 1.5 Spaces

According to the above ratios, the project would be required to provide 571 total parking spaces for the residential portion of the project, and each unit will be provided the required amount of parking. The project includes 17,899 square feet of neighborhood-serving commercial floor area, and the code requires parking at a rate of one (1.0) space per 200 square-feet of floor area which equates to a minimum of 89 commercial spaces. Therefore, the entire project would require a total of 668 spaces, and the proposal provides 673 spaces (exceeding the minimum number by 5 spaces). Page G-1.0 of the project plans provides detailed project data including number of resident parking spaces, commercial spaces, types of spaces (e.g., garage, carport, subterranean), etc.

It should be noted that the reduced standards for the number of parking spaces required per dwelling unit is not considered a concession or incentive under Gov. Code § 65915(d). A separate section in Gov. Code § 65915(p) provides the mandated parking ratio per dwelling unit within a housing development that invokes State Density Bonus Law.

The applicant is requesting a waiver for parking stall dimensions pursuant to Gov. Code § 65915 Redlands Regular Meeting of 12-03-24 309 of 875
et seq. (to reduce the depth by 2 feet). City standard parking spaces are required to be 19 feet deep. In certain locations, the project provides surface parking stalls that are 9 feet wide by 17 feet in clear length. As proposed, the parking stalls include 17 feet of paving plus 2 feet of overhang into planter areas, for a total depth of 19 feet.

Walls, Fences, and Gates: All entry points to the residential portions of the project are proposed to have controlled access for security. Three vehicle gates are proposed: two at the southwest portion of the site (with access from Tennessee St.), and one at the northeast corner (with access from a proposed extension of Pennsylvania Ave.). The commercial portions of the project (the southwest corner of the site) will not have gates. A total of 93 parking spaces are placed on the exterior side of the residential entry gates, and therefore vehicular access would not be limited for the commercial portion of the project site.

The project plans show 6’0” tubular steel fencing surrounding the residential portions of the project along Pennsylvania Avenue and the project’s southern perimeter. Along the east side of the project, there is a difference in elevation between the project site and the future Lugonia Village project (up to 6’0” high in some places). The east side of the proposed project will include a combination of slopes up to 3’0” high with retaining walls and tubular steel fencing on top. Wall heights are up to 3’0” high in this location (east side) with a 6’0” high tube steel fence on top. A Minor Exception Permit will be required for locations where this wall/fence combination exceeds 6’0” high.

Site Lighting:  The proposed apartment complex will require lighting to illuminate the parking lot and walkway areas for safety and security. Several standard conditions of approval are included to ensure that lighting will not have a negative effect on neighboring properties. These include requirements for the approval of a lighting plan prior to building permit issuance, indicating design details of all light fixtures, and a photometric plan designed by an electrical engineer demonstrating the adequate lighting ranges will be provided throughout the development without creating light spillover. The illumination within the parking lot shall be a minimum of 0.5-foot candle and illumination along all property lines of the project site shall not exceed 0.5-foot candle. Additionally, the conditions of approval require that all exterior lighting be approved in Plan Check and that all lighting be shielded and pointed downward, so that light and glare do not impact surrounding properties.

Architecture:  The proposed building design is inspired by the Modern Industrial architectural theme. Towers and varied roof lines, arches, and various horizonal projections provide significant visual interest on all sides of the buildings. Materials include stone veneer, brick veneer, Limestone cladding, and ceramic tile as well as decorative metal sunshades, awnings, and balcony railings. Stucco colors include varying shades of grey: Aesthetic White (SW 7035), City Loft (SW 7631), Quarry Stone (SW 9603), Soakdubg Gray (SW 6074), and Ironclad (SW 9570). Roofline treatments include squared cornice, such as decorative tile or high-density foam with cementitious finish. Table 4 summarizes the buildings sizes, heights, and treatments.

Table 5: Summary of Building Size and Height
Building # Total Floor Area
(square feet) Building Height Architectural Treatment
1 55,888 4 stories (49'9")
Stucco
Stone veneer
2 55,888 4 stories (49'9")
3 99,570 4 stories (51'8")
4 n/a n/a
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Stone veneer
Brick veneer
(entrances)
Metal awnings,
storefronts, trim,
railings
5 52,722 4 stories (51'8")
6 52,722 4 stories (51'8")
7 23,762 3 stories (41'1")
8 24,505 3 stories (40’1”)
9 152,860 4 stories (52’6”)
10 114,105 4 stories (52’0”)
11 84,293 4 stories (49’6”)
Total: 716,315

Proposed architectural elevations are provided as Attachment J-1 (Project Material and Elevations). Floor plans are included as Attachment J-2, and architectural 3-D renderings are provided as Attachment J-3. Analysis of the project’s consistency with the City’s Architectural Guidelines is included as Attachment J-4, and staff believes the project to be consistent with the architectural guidelines.

D) Architectural Review Criteria
New Construction over 500 square-feet is subject to review by the Planning Commission per Redlands Municipal Code (RMC) Chapter 18.12 and requires Commission Review and Approval. The Planning Commission reviews the project to determine whether the proposed development is in conformity with RMC Section 18.12.170, Architectural Review Criteria, and if approval of the site plan is in the best interest of the public health, safety, and general welfare. It is intended that design submittals be compatible with the character of adjacent and surrounding developments, and that they be of comparable composition, materials, textures and colors.

Conformance is evaluated based on the following seven criteria.

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

The proposed site layout, building orientation, location of structures and relationship to one another are suitable to support the development while including adequate open space and recreational amenities. The primary access to the site will be Tennessee Street and Pennsylvania Avenue with accommodation for access to potential future development to the south of the project.

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

The project site is in an area that is surrounded by properties that are proposed for development or in the process of being entitled. To the east of the site, the Lugonia Village project has been entitled, which includes a mix of residential uses including multi-family apartments and condos.

Anticipated future development of the properties located to the immediate south of the project is likely to include commercial development which will compliment this proposed mixed-use development. The proposed mixed-use project is compatible with the context of the area which is anticipated to be built out with both residential and commercial uses.

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

The proposed project will meet all applicable development standards of the General Commercial (C-3) District including floor-area ratio, setbacks, building height, and lot coverage upon approval. The proposed buildings will have a maximum height of approximately 54 feet and any Redlands Regular Meeting of 12-03-24 311 of 875
proposed roof-mounted mechanical equipment will be screened from the public right-of-way through the incorporation of parapet walls and roof elements.

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

The proposed architectural design of the proposed buildings is harmonious throughout the site.

The buildings include similar modern industrial architectural treatments on all sides of each building. Building architecture is consistent throughout the project in terms of material, color, and scale. The design of the building provides variation in parapet height, popouts, detailed metal railings, awnings and balcony elements with varied materials, which tie the project together.

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

The project proposes to landscape 27% of the total site area and the proposal meets the landscaping requirements of the Municipal Code in terms of the landscaping requirement within parking areas. The site is currently vacant with little to no significant vegetation. There are no specimen trees located within the development area of the site.

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

No signs are proposed as part of this application.

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

A condition of approval has been added to the project that glazing or image reflective surfaces (specular reflectance) shall be limited to a maximum reflectance of 25%.

E) Tentative Parcel Map
The applicant is proposing to subdivide the 12.76-acre (net) subject site into four new parcels.

As proposed, Parcel 1 will be 1.37 gross acres, Parcel 2 will be 1.49 acres, Parcel 3 will be

5.02 acres and Parcel 4 will be 4.88 acres. Within the C-3 District, there are no minimum lot sizes and no required lot dimensions. As proposed the resulting lots will be consistent with the Redlands Municipal Code requirements. A Condition of Approval has been added requiring the applicant to provide shared access across all parcels within the project. A copy of the Tentative Parcel Map is included as Attachment K.

Table 6: Proposed Parcels
Proposed Lot # Proposed Lot Size Proposed Development
1 1.37 acres Building 11
2 1.49 acres Buildings 1, 2
3 5.02 acres Buildings 3, 5, 6, 7
4 4.88 acres Buildings 8, 9, 10
Total: 12.76 acres

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F) Socio-Economic Cost / Benefit Study
In accordance with the Principals of Managed Development Element of the General Plan, a Socio-Economic Cost/Benefit Study (Attachment L) has been completed for the project. Based on the cost/benefit model utilized by the City, the project provides a positive cost/benefit ratio of 1.75 over the period of 2025-2034 (and results in positive net revenue to the City after development). This project will provide the City approximately $564,399 in revenue (exceeding costs to the City of $322,042) which results in revenue of $242,357 annually and the project will not create an unmitigable physical blight or overburden public services in the community.

ENVIRONMENTAL REVIEW
The City retained an environmental consultant to fully analyze the project and prepare an Initial Study in accordance with the California Environmental Quality Act (CEQA) (see Attachment M-1 – ISMND). In accordance with the CEQA Guidelines, the Initial Study/Mitigated Negative Declaration (IS/MND) was made available for public review and comment for 30 days (State Clearinghouse No. 2024040956). A Notice of Intent was filed with the County Clerk on April 24, 2024, and with the State Clearinghouse. The IS/MND was circulated for 30 days between April 24, 2024, and May 27, 2024. The public review Initial Study and Mitigated Negative Declaration was also made available via the City’s website
( www.cityofredlands.org/post/environmental-documents).

One public comment letter was received from Lozeau Drury, LLP, an environmental law firm representing Supporters Alliance for Environmental Responsibility (“SAFER”). Comments within the letter focus on Air Quality and Biological Resources. There is no information or evidence identifying any potentially significant impacts as a result of the project, and the city’s environmental consultant has provided a written Response to Comments document (see Attachment M-2).

The Initial Study recommends a Mitigated Negative Declaration with 13 mitigation measures that pertain to Biological Resources, Cultural Resources, Geological Resources, Noise, and Tribal Cultural Resources. All mitigation measures will ensure that any environmental effects are less than significant. After mitigation, no significant effects were identified as a result of the project, and the recommended mitigation measures will be incorporated into the project as mandatory Conditions of Approval. The Mitigation/ Monitoring and Reporting Program details the mitigation measures and is included as Attachment M-3.

FINDINGS
Each of the entitlements for the proposed project has specific Findings which are established by the Redlands Municipal Code, and are required to be satisfactorily made by Planning Commission before the Commission can recommend approval for the requested entitlements. A complete list of findings are included in the Planning Commission Resolutions (see Attachment N).

RECOMMENDATIONS
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Based on the above analysis and the findings contained within the Resolution, staff recommends that the Planning Commission recommend approval of project entitlements, subject to the attached conditions of approval.

MOTIONS
Should the Planning Commission concur with staff’s recommendation, the following motion is suggested:
"I move that the Planning Commission adopt Resolution No. 1688 recommending that the City Council:

Adopt a Mitigated Negative Declaration and Mitigation Monitoring & Reporting Program for the proposed project;
Approve a Socio-Economic Cost/Benefit Study for the project; Approve Amendment No. 50 to Specific Plan 40;
Approve Zone Change No. 477;
Approve Tentative Parcel Map No. 20688;
Approve Conditional Use Permit No. 1173;
Approve Commission Review & Approval Nos. 956; and,
Approve the Density Bonus and Inclusionary Housing Agreements for the project.” Attachments
Attachment A: Location Map
Attachment B: Site Plan
Attachment C: Project Data Sheet
Attachment D: Phasing Exhibit
Attachment E: General Plan Land Use Map
Attachment F-1: Zoning Map (existing)
Attachment F-2: Zoning Map (proposed)
Attachment G-1: Density Bonus Agreement
Attachment G-2: Inclusionary Housing Agreement
Attachment H: Table of Development Standards
Attachment I: Landscape Plans
Attachment I-1: Building Materials and Elevations
Attachment I-2: Project Floor Plans
Attachment I-3: Architectural 3-D Renderings
Attachment I-4: Consistency with Architectural Guidelines Attachment K: Tentative Parcel Map
Attachment L: Socio-Economic Cost/Benefit Study
Attachment M-1: Initial Study/Mitigated Negative Declaration Attachment M-2: Responses to Comments
Attachment M-3: Mitigation Monitoring and Report Program Attachment N-1: Resolution No. 1688
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Resolution N-2: Engineering Conditions of Approval
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City of Redlands
O
R-S
R-1
R-1
EV/CG
EV/CG
R-1
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R-1
EV/CG
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EV/IC
EV/SD
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R-1
A-1
R-1
R-2
R-1
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R-1
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R-1
R-1
R-1
M-1
R-1
R-1
R-1
R-S
R-1
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R-1
C-3
R-1
R-1
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0 305 610 1,220 1,830 2,440
US Feet
³
Author: Redlands GIS Date: 9/3/2024
Legend
City Boundary
Parcels
Zoning

CATEGORY
Administrative
Agricultural
Single Family Residential
Multi-Family Residential
Commercial
Medical
Industrial
Transitional
Public Institutional
Airport
Specific Plan
Flood Plain
Open Space
APN
Streets
Streets
Proposed Zoning
C-3
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General Commercial (C-3) District
(RMC Title 18, Ch. 18.92)

DEVELOPMENT

STANDARD

REQUIREMENT PROPOSED COMPLIES
?
Lot Area

18.92.110
No requirements The project is
proposing to
subdivide a 13.48
acre parcel (Gross)
into four parcels.

1.37 acres

1.49 acres

5.02 acres

4.88 acres
Yes
Lot Dimensions

18.92.120
No requirements Varies Yes
Max. Structure Height

18.92.130
No height limit, except that the relationship between
building floor area and lot area shall not exceed four (4) square feet of total floor area for each one square foot of total lot area. The floor area of parking garages and
related structures located at or above ground level shall be included in the calculation ratio.
54’ Yes
Floor-Area Ratio (F.A.R.)

18.92.130

4.0 Maximum 1.1 Yes
Lot Coverage

18.92.170
No requirements 31% Yes
Front Yard & Rear Yard

18.92.140 No requirements Tennessee St. 25’Pennsylvania Ave. 18’
Yes
Side Yard

18.92.140(B) No side yard requirements;
Except where the C-3 zone adjoins or is across the street from a residential zone, in which case there shall be a side yard of not less than 10 ft. on the side or sides
adjoining the street or residential zone (the yard shall be landscaped and maintained).

Side (South) 55’
Side (East) 10’
Yes
Access to Street

18.92.160 All lots in C-3 zones shall have access on a dedicated and improved street.

Access from
Tennessee Street
and Future
Pennsylvania
Avenue
Yes
On-Site Parking Required

18.164.240
Neighborhood center: 1 space/200 sq. ft.

Minimum Required = __89_____
Residential Density Bonus Parking
# Bedrooms Required Spaces
1 BR 1 Space
2 BR 1.5 Spaces
3 BR 1.5 Spaces
571 spaces required
Total required - 668
Total Parking
Required = 673
Yes
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DEVELOPMENT

STANDARD

REQUIREMENT PROPOSED COMPLIES
?
Parking Space Location

18.164.250
The off street parking facilities required by this title shall be located on the same lot or parcel of land as the use they are intended to serve, except that in cases of
practical difficulty, the planning commission may
approve a substitute location which meets the following conditions:

A. All or part of the substitute location is within two hundred feet (200') of the principal use for which the
parking is being provided;
B. The substitute lot is in the same possession as the use it is intended to serve. Such possession may be by
deed or long term lease, the terms of which meet the
approval of the city.

Commercial parking
is located on the
parcel which it is
intended to serve.

Residential parking
is not provided
based upon this
title.

Shared parking
agreements or
mutual access will
be provided.

Yes
Parking Space Dimensions

18.164.260
• Standard spaces: 9’ wide by 19’ deep.
• Compact spaces: 8’ wide by 15’ deep.
• Compact spaces are permitted for projects that
provide more than 25 off-street parking spaces. The
first 25 spaces shall be standard size stalls; 25% of the remaining parking may be compact spaces.
- Including one of the following to be determined by staff:
a. Compact parking spaces are permitted in areas of the city where parking does not currently meet code upon a finding by the planning commission that the use of compact parking stalls will alleviate an existing parking problem; or
b. Compact spaces are permitted for long term parking when there is a proportionate increase in parking lot landscaping as follows: for each proposed compact space, 30 sq. ft. of landscaping shall be provided in the parking area in addition to the minimum landscape requirements of this code.
• Parallel spaces: 8’ wide by 24’ deep.
• Stall depths may be reduced up to 1 ft. (or 18’0” total) where pkg space adjacent to a 6 ft. or wider sidewalk.
• Where automobile bumpers overhang landscaped
planters, 2' of clear areas unobstructed by trees or
shrubs shall be provided for overhang.
(See RMC 18.168.210(A)(11) referenced below.)
9x19 minimum with
certain exceptions.

Project proposes
shortened stall
depths in some
locations the
applicant is
requesting a
reduction through
approval of the
density bonus
agreement
Yes with
approval of a
density bonus
agreement.

Access to Parking

18.164.270
A. Forward travel to and from parking facilities from a dedicated street or alley is required. The parking area shall be adequate to facilitate the turning of vehicles to permit forward travel upon entering a street.

B. All uses which adjoin a major or secondary highway
shall, wherever possible, have access by way of a
service road or alley.

C. The access to all off street parking facilities shall be designed in a manner which will not interfere with the
safe movement of traffic.

D. Concrete driveway approaches shall be provided for
ingress to and egress from all parking facilities. Each parking space shall be easily accessible to the intended user. The width of driveway entrances and exits from a
public street shall be measured at the property line and Forward travel to all
street is provided
via service roads
and parking area
circulation routes
Driveway on
Pennsylvania
Avenue is 30’
Driveway on
Tennessee Street is
a divided two way
driveway with 20’
drivelanes
Yes
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DEVELOPMENT

STANDARD

REQUIREMENT PROPOSED COMPLIES
?
shall comply with the following standards, unless
specific exemptions are made by the director of public
works:
- single lane: 14 ft.
- combined entrances or exits: 26 ft.
- maximum driveway width: 30 ft.

Parking Area Circulation

18.164.280
- Stall depths may be reduced up to one foot (1') where the parking space is adjacent to a six foot (6') or wider sidewalk, or adjacent to a landscaped planter with an
interior diameter of five feet (5') or more.
- Wheel stops shall be provided only along the side and rear property lines when necessary to protect adjacent
property from vehicle encroachment.
- Circulation within a parking area with more than one
aisle must be such that a car need not enter the street to reach another aisle within the same parking area.
- Parking angle and required dimensions:
90-degree spaces: 19’ deep & 26’ two-way aisle
60-degree spaces: 21’ deep & 22’ two-way aisle
45-degree spaces: 20’ deep & 20’ two-way aisle
- Directional signs shall be required to differentiate
between entrance and exit access points to the street.
9x19 minimum with
certain exceptions.

Project proposes
shortened stall
depths in some
locations the
applicant is
requesting a
reduction through
approval of the
density bonus
agreement
All drive aisle are a
minimum of 26’
Yes
Parking Area
Improvements

18.164.290

18.164.310
- Where such areas adjoin residential districts, they shall be separated therefrom by a solid masonry wall 6' in
height, provided such wall shall not exceed 3' in height where it is in the front yard area of an abutting residential use or district. Where no fence or wall is required along a boundary of an area covered by this section, there shall be a concrete curb or concrete wheel stops not less than six inches (6") in height securely installed and
maintained as a safeguard to abutting property or public right of way. The barrier shall not be less than two feet (2') from a property line.
- Where such area adjoins a residential district, there shall be a border of appropriate landscaping, not less than 6' in depth, along the residential street frontage to protect the character of the adjoining residential property.
- No part of any parking area for more than five (5)
vehicles shall be closer than 10' to any residential use, school, hospital, or other institution for human care
located on an adjoining lot, unless screened by a masonry wall not less than 4' in height.
- When more than five (5) parking spaces are proposed
for a parcel, a minimum of seven percent (7%) of such
parking area shall be landscaped and maintained in
accordance with the provisions of Chapter 18.168.
- Parking lots intended for nighttime use shall be
adequately lighted for safe vehicular and pedestrian
Residential parking
areas on the east
side of the project
are adjacent to the
Lugonia Village
project’s parking
area. These are
separated by
stepped walls and
slopes exceeding 6’
Appropriate
landscaping is
provided along the
east side of the
project exceeding 6’
Both the Lugonia
Village project and
proposed project
include landscaped
perimeters adjacent
to their abutting
parking areas. 10’
of separation is
provided.

Yes
Redlands Regular Meeting of 12-03-24 386 of 875

DEVELOPMENT

STANDARD

REQUIREMENT PROPOSED COMPLIES
?
movements. Lighting shall be arranged to reflect away
from adjoining properties and streets.
15% of the
proposed parking
area is landscaped.

Lighting plans are
required to be
submitted prior to
building permit
issuance. These will
be reviewed for
compliance prior to
permit issuance.

Off-Street Loading

18.92.190

18.164.330
E. Loading space required by this title may occupy a required rear yard, but in no case shall any part of an alley or street be used for loading.

Loading are not
clearly indicated
Yes with
conditions of
approval. Two
spaces
required.

Corner Cutoff

18.168.010
• Streets; streets & alleys; private driveways &
streets/alleys.
• Where all private driveways intersect street or alley. • 45 degree angle with side or front P/L.
• Minimum 10 ft. deep for 45 degree angle.
• No visual obstruction within corner cutoff area.

Appropriate corner
cut-offs are
provided Buildings
are setback from
property lines
between 15 and 25’.

Yes
Fences & Walls;
Permitted When

18.168.020
• Fences & Walls 3 ft. max. in front yard area.
• Open fences 4 ft. max. within front yard (90% open).
• Fences & Walls 6 ft. max. on side or rear P/L.
• Minor exceptions: see 18.168.040 to 18.168.100.

No walls exceeding
6’ are proposed. No
setbacks are
required for this
zone. A condition of
approval has been
added requiring a
Minor Exception
Permit in the event
walls or fences
exceeding 6’ tall are
proposed at the time
of building permit.

Yes, with
conditions
Fences & Walls;
Required When

18.168.030
• 6 ft. fence or wall at top of all slopes where tops of slopes are property lines.
• 6 ft. fence or wall along P/L or zone boundary lines to separate industrial & commercial districts and/or uses
from abutting residential districts, as follows:
1) Along rear lot line (if no street);
2) Along side lot line (except 3 ft. max. within front
setback of the abutting residential zone);
3) If street is boundary, wall set back from P/L by 10
ft. min., with landscaping;
4) If alley is boundary, wall shall be on P/L at alley. 6’ fencing is
provided on the
south side of the
project. A
combination of
walls, slopes and 6’
fences are proposed
along the east side
for the project
Yes
Landscaping;
Minimum Dimensions

18.168.180
The minimum width of any required landscaped area, or
any form of fixed planter box used to satisfy required
landscaping, shall be five feet (5'), unless otherwise
specified in this title.

Required
landscaping areas
are minimum of 5’
wide.

Yes
Redlands Regular Meeting of 12-03-24 387 of 875

DEVELOPMENT

STANDARD

REQUIREMENT PROPOSED COMPLIES
?
Transportation Control
Measures

18.224.020
When discretionary review is required:

A. New nonresidential and multi-family (of 10 or more
units) developments or remodel, when discretionary
review is required, shall install bicycle racks or secured lockers at a rate of one per thirty (30) parking spaces with a minimum of a three (3) space bicycle rack.

B. New nonresidential and multi-family (of 10 or more
units) developments shall provide on site pedestrian
walkways and bicycle facilities to connect each building in the development to public streets.

D. New nonresidential and multi-family (of 10 or more
units) developments with one hundred (100) or more
parking spaces shall have a passenger loading area with a curb length of at least one hundred feet (100') in a
location close to the building entrance. The loading area shall be designed so as not to interfere with vehicle
circulation.

E. New nonresidential development shall designate
preferential parking spaces for vanpools near building
entrances at a rate of one parking space per one hundred (100) spaces.

F. New nonresidential and residential (of 10 or more
units) developments along existing or planned transit
routes shall install transit improvements such as bus
pullouts, bus pads and bus shelters. The need for and
nature of these improvements are to be defined by the
city in cooperation with Omnitrans.

Conditions of
approval have been
added requiring
bike racks to be
clearly shown on
the project plan
prior to building
permit issuance.

Yes. Pedestrian
paths are provided
between buildings
and open space
areas.

To be verified at
building permit
issuance
Project is
conditioned to
provide evidence of
coordination with
Omnitrans
regarding the need
for any
improvements.

Yes, with
conditions of
approval.

Redlands Regular Meeting of 12-03-24 388 of 875
Redlands Regular Meeting of 12-03-24 389 of 875
Redlands Regular Meeting of 12-03-24 390 of 875
Redlands Regular Meeting of 12-03-24 391 of 875
Redlands Regular Meeting of 12-03-24 392 of 875
Redlands Regular Meeting of 12-03-24 393 of 875
ARCHITECT AO (ARCHITECTS ORANGE) 144 N. ORANGE ST. ORANGE, CA 92866 Contact: Contact: CIVIL ENGINEER KIMLEY - HORN PLANNING DESIGN ENGINEERING CONSULTANTS 1100 TOWN AND COUNTRY RD. SUITE 700, ORANGE, CA 92868 ROB OTTE (951)534-5630 G 1.0 PROJECT TEAM TENNESSEE VILLAGE REDLANDS, CALIFORNIA COVER SHEET LANDSCAPE ARCHITECT COMMUNITY WORKS DESIGN GROUP 4649 BROCKTON AVE. RIVERSIDE, CA 92506 W. LUGONIA AVE. SAN BARNARDINO AVE.

ALABAMA ST.

NEW YORK ST.

FWY. 210 FWY. 10
TEXAS ST. VICINITY MAP
KARON ST. PENNSYLVANIA AVE. C-1 GRADING & DRAINAGE MASTER PLAN C-2 CROSS SECTIONS C-3 UTILITY PLAN LANDSCAPE L-1 CONCEPTUAL LANDSCAPE L-2 COURTYARD 1 ENLARGEMENT L-3 COURTYARD 2 ENLARGEMENT L-4 COURTYARD 3 & 4 ENLARGEMENT L-5 FENCE & WALL PLAN CIVIL SHEET DESCRIPTION ARCHITECTURE - RESIDENTIAL G-0.0 COVER SHEET G-1.0 PROJECT DATA A-1.0 CONCEPTUAL SITE PLAN A-1.2 FIRE MASTER PLAN A-1.3 OPEN SPACE EXHIBIT A-1.4-1 WASTE MANAGEMENT EXHIBIT A-1.4-2 PATH OF TRAVEL EXHIBIT A-1.5 SITE / BUILDING SECTION A-A A-1.6 PERSPECTIVE VIEW 1 A-1.7 PERSPECTIVE VIEW 2 A-1.8 PERSPECTIVE VIEW 3 A-1.9 PERSPECTIVE VIEW 4 A-1.10 PERSPECTIVE VIEW 5 A-1.11 PERSPECTIVE VIEW 6 A-1.12 PERSPECTIVE VIEW 7 A-2.1 TYPE A BUILDING 1&2 - FLOOR PLANS A-2.1-1 TYPE A BUILDING 1&2 - ELEVATIONS A-2.2 TYPE B BUILDING 3 - FLOOR PLANS A-2.2-1 TYPE B BUILDING 3 - ELEVATIONS A-2.3 TYPE C BUILDING 5 & 6 - FLOOR PLANS A-2.3-1 TYPE C BUILDING 5 & 6 - ELEVATIONS A-2.4 TYPE D BUILDING 9 - 1ST FLOOR PLAN A-2.4-1 TYPE D BUILDING 9 - 2ND FLOOR PLAN A-2.4-2 TYPE D BUILDING 9 - 3RD FLOOR PLAN A-2.4-3 TYPE D BUILDING 9 - 4TH FLOOR PLAN A-2.4-4 TYPE D BUILDING 9 - ROOF PLAN A-2.4-5 TYPE D BUILDING 9 - ELEVATIONS A-2.4-6 TYPE D BUILDING 9 - ELEVATIONS A-2.5 TYPE E BUILDING 7 - FLOOR PLANS A-2.5-1 TYPE E BUILDING 7 - ELEVATIONS A-2.6 TYPE F BUILDING 11 - 1 ST FLOOR PLAN A-2.6-1 TYPE F BUIDLING 11 - 2ND, 3RD & 4TH FLOOR PLAN A-2.6-2 TYPE F - BUILDING 11 - ROOF PLAN A-2.6-3 TYPE F - BLDG 11 ELEVATIONS 1 A-2.6.4 TYPE F - BLDG 11 ELEVATIONS 2 A-2.7 TYPE G BUILDING 10 - BASEMENT FLOOR PLAN A-2.7.1 TYPE G BUILDING 10 - 1ST FLOOR PLAN A-2.7.2 TYPE G BUILDING 10 - 2ND FLOOR PLAN A-2.7.3 TYPE G BUILDING 10 - 3RD & 4TH FLOOR PLAN A-2.7.4 TYPE G BUILDING 10 - ROOF PLAN A-2.7.5 TYPE G BUILDING 10 - ELEVATIONS 1 A-2.7.6 TYPE G BUILDING 10 - ELEVATIONS 2 A-2.8 TYPE H BUILDING 8 - 1ST, 2ND & 3RD FLOOR PLANS A-2.8.1 TYPE H BUILDING 8 - ELEVATIONS A-3.1 UNIT FLOOR PLANS A-3.2 UNIT FLOOR PLANS A-4.1 AMENITY /FITNESS FLOOR PLAN A-5.1 PARKING EXHIBIT A-6.0 MATERIAL BOARD A-6.1 ENLARGED ELEVATION DETAILS TENNESSEE ST. W. LUGONIA AVE. APPLICANT / OWNER DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE RANCHO CUCAMONGA, CA 91730 DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 SHEET DESCRIPTION PHASE I P-1 PHASE I - PHASING EXHIBIT P-2 PHASE I - NEIGHBORHOOD DATA P-3 PHASE I - FIRE MASTER PLAN P-4 PHASE I - WASTE MANAGEMENT EXHIBIT P-5 PHASE I - CIVIL IMPROVEMENT EXHIBIT DESIGN REVIEW SUBMITTAL JANUARY 10, 2024 COMMISSION REVIEW & APPROVAL NO. # 956 CUP NO. # 1173 TMP NO. # 20688 Contact: Contact: NOLAN C. LEGGIO (909)373-2628 Contact: Contact: ALLISON RUSH (951)369-0700 Contact: Contact: SERAFIN MARANAN (714)639-9860 A-2.2 TYPE B BUILDING 3 - FLOOR PLANS Redlands Regular Meeting of 12-03-24 394 of 875
DATE: 10-10-2023
Redlands Regular Meeting of 12-03-24 395 of 875

DIVERSIFIED PACIFIC COMMUNITIES
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 02-06-2023 DATE: 10-10-2023
Redlands Regular Meeting of 12-03-24 396 of 875
8" 10'-1" 10'-1" 10'-1" 10'-1" 6'-2"
47'-3" 8 3 1 9 11 1 1
8" 10'-1" 10'-1" 10'-1" 10'-1" 8'-5"
49'-6" 6 11 3 9 1 8 13 1 2 12 6
8" 10'-1" 10'-1" 10'-1" 10'-1" 8'-5"
49'-6" 3 1 6 12 8
8" 10'-1" 10'-1" 10'-1" 10'-1" 6'-2"
47'-3" 8 12 6 1 3 WEST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 SCALE : 3/32"= 1'-0" TYPE A - BLDG. 1 & 2 ELEVATIONS A-2.1-1 1 S WEXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNING 2 N E NORTH ELEVATION SOUTH ELEVATION EAST ELEVATION Redlands Regular Meeting of 12-03-24 397 of 875
10'-1" 10'-1" 10'-1" 10'-1" 9'-5"
50'-6" 8 1 12 1 3
8"
8" 10'-1" 10'-1" 10'-1" 10'-1" 9'-5"
50'-6" 1 2 11 3 1 9 10 7 13 2 1 8 1
8" 10'-1" 10'-1" 10'-1" 10'-1" 9'-0"
50'-1" 3 1 12 1 8
8" 10'-1" 10'-1" 10'-1" 10'-1" 6'-2"
47'-3" 3 8 1 3 11 8 3 1 8 1 WEST ELEVATION SCALE : N.T.S. TYPE B - BLDG. 3 ELEVATIONS A-2.2-1 S W EXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNING N 3E SOUTH ELEVATION NORTH ELEVATION EAST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 Redlands Regular Meeting of 12-03-24 398 of 875
8" 10'-1" 10'-1" 10'-1" 10'-1" 6'-2"
47'-3" 8 12 6 1 3
8" 10'-1" 10'-1" 10'-1" 10'-1" 8'-5"
49'-6" 3 1 6 12 8
8" 10'-1" 10'-1" 10'-1" 10'-1" 9'-5"
50'-6" 8 12 3 1 13 7 9 8 1 2 8 11 7 13 1 10 8
8" 10'-1" 10'-1" 10'-1" 10'-1" 6'-2"
47'-3" 8 3 1 11 9 1 8 1 WEST ELEVATION SCALE : 3/32"= 1'-0" TYPE C - BLDG. 5 & 6 ELEVATIONS A-2.3-1 5 S W EXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNING N 6 E NORTH ELEVATION SOUTH ELEVATION EAST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 Redlands Regular Meeting of 12-03-24 399 of 875
8" 10'-1" 10'-1" 10'-1" 10'-1" 11'-5" 4 1 8 6 3 8 9 12 11 1 52'-6"
8" 10'-1" 10'-1" 10'-1" 10'-1" 1 1
11'-5" 8 1 3 9 8 11 7 4
52'-6" 5 12 11 WEST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 SCALE : 3/32"= 1'-0" TYPE D - BLDG. 9 ELEVATIONS A-2.4-5 S 9W SOUTH ELEVATION EXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNING Redlands Regular Meeting of 12-03-24 400 of 875
8" 10'-1" 10'-1" 10'-1" 10'-1" 6'-2"
47'-3" 1 3 8 5 1
8" 10'-1" 10'-1" 10'-1" 10'-1" 6'-2"
47'-3" 1 8 1 3 11 1 5 EAST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 SCALE : 3/32"= 1'-0" TYPE D - BLDG. 9 ELEVATIONS A-2.4-6 9 NORTH ELEVATION EXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNINGE N Redlands Regular Meeting of 12-03-24 401 of 875
8" 10'-1" 10'-1" 10'-1" 8'-5"
39'-6" 9 12 1 3 6 2 1 6
8" 13'-1" 10'-1" 10'-1"
34'-0" 1 3 8 5 1
8" 10'-1" 10'-1" 10'-1" 8'-5"
39'-6" 3 1 6
8" 13'-1" 10'-1" 10'-1"
34'-0" 3 6 1 EAST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 SCALE : 3/32"= 1'-0" TYPE E - BLDG. 7 ELEVATIONS A-2.5-1 E N NORTH ELEVATION W SOUTH ELEVATION WEST ELEVATION EXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNING 7 S Redlands Regular Meeting of 12-03-24 402 of 875
8" 10'-1" 10'-1" 10'-1" 10'-1" 10'-6" 9 8 7 1 12 6 2
51'-6" 9 1 3
8" 10'-1" 10'-1" 10'-1" 10'-1" 8'-6" 9 6 3 7 1 8 11 12 2 49'-6" WEST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 SCALE : 3/32"= 1'-0" TYPE F - BLDG. 11 ELEVATIONS A-2.6-3 11 S W SOUTH ELEVATION EXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNING Redlands Regular Meeting of 12-03-24 403 of 875
8" 10'-1" 10'-1" 10'-1" 10'-1" 10'-8" 1 2 1 9 3 9
51'-6"
8" 10'-1" 10'-1" 10'-1" 10'-1" 10'-8" 1
51'-6" 2 8 1 3 13 1 12 1 EAST ELEVATION DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 08-30-2024 JOB NO.: 2020-322 APN: 0167-171-15 SCALE : 3/32"= 1'-0" TYPE F - BLDG. 11 ELEVATIONS A-2.6-4 N 11E NORTH ELEVATION EXTERIOR ELEVATION KEYNOTES 1. STUCCO 2. BRICK VENEER 3. VINYL WINDOW 4. SHADE CANOPY 5. GARAGE DOOR 6. VENEER STONE 7. PORCELAIN TILE 8. BALCONY RAILING 9. SUN SHADE LOUVER 10. STORE FRONT SYSTEM 11. EXTERIOR LIGHTING 12. JULIET BALCONY RAILING 13. METAL AWNING Redlands Regular Meeting of 12-03-24 404 of 875
W/D
P.

DW
REF
L
L W/D
P.

DW
REF
COAT
L
L W/D
P.

DW
REF
COAT
W/D
P.

DW
REF
UP 18R
L
L W/D
P.

DW
REF
COAT
UP 18R
L
L W/D
P.

DW
REF
COAT
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

MSIa H. M.

A3 B5 A3
B5 B5 BREEZEWAY
A1 Abv. A1 Abv. A1 Abv. A1 Abv.

B5
A1-Den Abv.

TRASH
RM.

ELEV.

ELEV.

RM.

A1-Den Abv. BOILER

FIRE RISER
MPOE
ELECT.

CLOSET
2ND - 3RD FLOOR PLAN
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

W/D
P.

DW
REF
L
L W/D
P.

DW
REF
COAT
L
L W/D
P.

DW
REF
COAT
W/D
P.

DW
REF
UP 18R
L
L W/D
P.

DW
REF
COAT
UP 18R
L
L W/D
P.

DW
REF
COAT
A3 B5 A3 B5 B5B5
A1 A1 A1 A1 A1-Den A1

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE A BUILDING 1 & 2 - COMPOSITE LEVEL
1, 2, 3 & 4 FLOOR PLANS
A-2.1
SCALE : 3/32"= 1'-0"
1st LEVEL FLOOR PLAN
2nd - 4th LEVEL FLOOR PLAN
Redlands Regular Meeting of 12-03-24 405 of 875
CB CB C1
ELEV.RM
A1-DEN Abv.
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S. B1 Abv.

ELECT.

CB CB
UP 18R C1
B1 Abv. B1 Abv. A1 Abv.

B5
L
L W/D
P.

DW
REF
COAT
UP 18R
(DOUBLE VOLUME)
B5 Abv. B5 Abv.

B1 Abv. B1 Abv.

B5
L
L W/D
P.

DW
REF
COAT
B1 Abv. B1 Abv.

B5
L
L W/D
P.

DW
REF
COAT
B5
L
L W/D
P.

DW
REF

COAT CALIFORNIA ROOMBREEZEWAY
A3 A3
W/D
P.

DW
REF
W/D
P.

DW
REF
BOILER

FIRE RISER
CB CB C1CB CB
UP 18R C1 B5
L
L W/D
P.

DW
REF
COAT
UP 18R B5 Abv. B5 Abv.

B5
L
L W/D
P.

DW
REF
COAT
B5
L
L W/D
P.

DW
REF
COAT
B5
L
L W/D
P.

DW
REF
COAT
W/D
B1 A1-Den

W/D W/D W/D W/D W/D W/D
B1 B1 B1 B1 A1 B1 B1 5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

OPEN TO BLW. A3
W/D
P.

DW
REF
W/D
P.

DW
REF
A3
CB CB C1CB CB
UP 18R C1 B5
L
L W/D
P.

DW
REF
COAT
UP 18R B5
L
L W/D
P.

DW
REF
COAT
B5
L
L W/D
P.

DW
REF
COAT
B5
L
L W/D
P.

DW
REF
COAT
W/D
B1 A1-Den

W/D W/D W/D W/D W/D W/D
B1 B1 B1 B1 A1 B1 B1 5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

B5 A3
L
L W/D
P.

DW
REF
COAT
B5
L
L W/D
P.

DW
REF
COAT
W/D
P.

DW
REF
W/D
P.

DW
REF
A3

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE B BUILDING 3 - COMPOSITE LEVEL
1, 2, 3 & 4 FLOOR PLANS
A-2.2
SCALE : 3/32"= 1'-0"
1st LEVEL FLOOR PLAN
2nd LEVEL FLOOR PLAN
3rd & 4th LEVEL FLOOR PLAN
Redlands Regular Meeting of 12-03-24 406 of 875
CB CB
C1
ELEV.RM
A1-DEN Abv.
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

B1 Abv. A1 Abv. B1 Abv.

UP 18R UP 18R
A1 Abv.

A3 A3 B5

ELECTRICAL MPOE
MSIa H. M.

AMENITY
C1-Abv.

BOILER

FIRE RISER

CB CBCB CB
W/D
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

B1 A1-DEN
C1-DEN C1
A1
W/D
B1
UP 18R
A1
A3 A3 B5 UP 18R

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
A-2.3
SCALE : 3/32"= 1'-0" TYPE C (BLDG. 5 &6) - COMPOSITE LEVEL 1st-4th FLOOR PLANS
BLDG. 5 & 6,1st LEVEL FLOOR PLAN
BLDG.5 & 6, 2nd - 4th LEVEL FLOOR PLAN
Redlands Regular Meeting of 12-03-24 407 of 875
EP
ELEV.RM
EP
B3
B3
EP
EP
B3
B3
B1 Abv.

B1 Abv.

B1 Abv.

UP 18R
A1 Abv.

MAINT.

A1 Abv.

A1 Abv.

A1 Abv.

A3
A3
UP 18R

ENTERTAINMENT

MAILROOM
AMAZON
LOUNGE

LEASING
24'-0" x 26'-8" OFFICE 1
13'-6" x 10'-4"
OFFICE 2
13'-6" x 10'-5" DECORATIVE

COFFERED

CEILING
10'-3" x 12'-2"
BREAK RM.

BAR
W
FAU

PARCEL/

PACKAGE
10'-3" x 20'-0"
JAN./STR.

CLUBROOM
35'-0" x 35'-0"
M
POOL
60-0" x 35'-0"

FITNESS
(+/-3,038 SQ.FT.)
J. STR.

EQPT.
38'-0" x 36'-0"

THEATER
W M

GOLF SIMULATOR
17'-9" x 20'-0"
STR.
17'-4" x 33'-6"
YOGA
ELECT.

CREATIVE

BREEZEWAY
(+/-1,438 SQ.FT.)
A1 Abv.
(+/-665 SQ.FT.)
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

ELEV.

RM
OFFICE
A1-den Abv. A1 Abv. A1 Abv. A1 Abv. A1-den Abv. A1 Abv. 5' DIA. 30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

UP 9R
DN 9R
UP 9R
TRASH
ROOM
ELEV.

BOILER

FIRE RISER
TRASH
ROOM

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE D BUILDING 9 - COMPOSITE LEVEL
1st FLOOR PLAN
A-2.4
SCALE : 3/32"= 1'-0"
Redlands Regular Meeting of 12-03-24 408 of 875
EP
EP
B3
B3
EP
EP
B3
B3

W/D W/D
W/D A1
B1
B1
B1
A3
A3

LEASING/CLUBHOUSE
OPEN TO BLW.

DOUBLE VOLUME
A1
A1
A1
UP 9R
DN 9R
UP 9R

FITNESS
DOUBLE VOLUME / OPEN TO BLW.

A3
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

UP 18R
EP
EP
B3
B3
A1-den A1 A1 A1 A1 A1 A1
A3
A1
A1-den
STR.

UP 18R
TRASH
ROOM
TRASH
ROOM
ELEV.

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE D TYPE D BUILDING 9 - COMPOSITE LEVEL
2nd FLOOR PLAN
SCALE : 3/32"= 1'-0"
A-2.4-1
Redlands Regular Meeting of 12-03-24 409 of 875
EP
EP
B3
B3
EP
EP
B3
B3
A3
A3
A1
EP
EP
B3
B3
W/D
A1 B1
A1
UP 9R
DN 9R
UP 9R
A1

W/D W/D
W/D A1
B1
B1
A1 B1
EP
EP
B3
B3
B5 A3 A3
UP 18R
A3
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

A1-den A1 A1 A1 A1 A1 A1-den A1 5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

A1
STR.

UP 18R
TRASH
ROOM
TRASH
ROOM
ELEV.

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE D BUILDING 9 - COMPOSITE LEVEL
3rd FLOOR PLAN
SCALE : 3/32"= 1'-0"
A-2.4-2
Redlands Regular Meeting of 12-03-24 410 of 875
EP
EP
B3
B3
EP
EP
B3
B3
A3
A3
A1
A1

W/D W/D
W/D A1
B1
B1
A1 B1
EP
EP
B3
B3
B5 A3 A3
UP 18R
A3
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

A1 A1 A1 A1 A1 A1
UP 9R
DN 9R
UP 9R
A1
STR.

UP 18R

ROOF DECK
A1-den A1-den
ELEV.

TRASH
ROOM
TRASH
ROOM

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
SCALE : 3/32"= 1'-0"
A-2.4-3
TYPE D BUILDING 9 - COMPOSITE LEVEL
4th FLOOR PLAN
Redlands Regular Meeting of 12-03-24 411 of 875

ROOF DECK
(+/-6,200 SF.)
UP 9R
DN 9R
UP 9R
ROOF

CONDENSER ROOF SLOPE TO DRAIN
FLAT
ROOF
FLAT
ROOF
FLAT
ROOF
FLAT
ROOF
FLAT
ROOF
FLAT
ROOF
FLAT

ROOF ROOF SLOPE TO DRAIN ROOF SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
FLAT

ROOF ROOF SLOPE TO DRAIN ROOF SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN ROOF SLOPE TO DRAIN ROOF SLOPE TO DRAIN

DIVERSIFIED PACIFIC COMMUNITIES
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 02-06-2023
JOB NO.: 2020-322
SCALE : 3/32"= 1'-0"
A-2.4-4
TYPE D BUILDING 9 - ROOF PLAN
DATE: 10-10-2023
Redlands Regular Meeting of 12-03-24 412 of 875

W/D W/D
UP 18R
MSIa H. M.

UP 9R DN 9R
UP 9R
UP 9R
UP 18R
DN 9RUP 9R
B1 Abv.

A1 Abv.

B1 Abv.

A1
A1 Abv. A1
A1
A1
A1
A1
A1
A1
A1
A1
B1
B1
BOILER

FIRE RISER MPOE
ELECT.

CLOSET

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE E BUILDING 7 - COMPOSITE LEVEL
1, 2 & 3 FLOOR PLANS
A-2.5
SCALE : 3/32"= 1'-0"
1st LEVEL FLOOR PLAN 2nd - 3rd LEVEL FLOOR PLAN
Redlands Regular Meeting of 12-03-24 413 of 875
ELEV.

RM
UP 18R
A1 Abv. A1 Abv. A1 Abv.

B1 Abv.

B4

CB CB W/D
C1
B5 B4
A3
TRASH
RM. 5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

ELECT.

UP 18R
A3 B5 B5 B5
A3
A3 B1 Abv. A3
A1 Abv.

BOILER

FIRE RISER
ELEV.

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE F(BLDLG. 11) - COMPOSITE LEVEL
1st FLOOR PLAN
A-2.6
SCALE : 3/32"= 1'-0"
Redlands Regular Meeting of 12-03-24 414 of 875
A1 A1 A1
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

W/D
W/D
B1
B4 B4 UP 18R

CB CB W/D
C1
UP 18R
B5 A3 A3 B5 B5 B5
A3
A3 A3
B1
STR.

LEASING/CLUBHOUSE
ELEV.

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE F(BLDLG. 11) - COMPOSITE LEVEL
2nd, 3rd & 4th FLOOR PLAN
A-2.6-1
SCALE : 3/32"= 1'-0"
Redlands Regular Meeting of 12-03-24 415 of 875

FLAT ROOF ROOF CONDENSER
ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
UP 18R
ROOF

SLOPE TO DRAIN ROOF CONDENSER FLAT ROOF FLAT ROOFFLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF ROOF

SLOPE TO DRAIN ROOF SLOPE TO DRAIN ROOF SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF
SLOPE TO DRAIN ROOF SLOPE TO DRAIN DIVERSIFIED PACIFIC COMMUNITIES 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 02-06-2023 TYPE F(BLDLG. 11) - ROOF PLAN JOB NO.: 2020-322 A-2.6-2 SCALE : 3/32"= 1'-0" DATE: 10-10-2023 Redlands Regular Meeting of 12-03-24 416 of 875
ELEV. RM
UP 18R
UP 18R TRASH TERMINATION ROOM DIVERSIFIED PACIFIC COMMUNITIES 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 02-06-2023 JOB NO.: 2020-322 TYPE G - COMPOSITE LEVEL BASEMENT LEVEL FLOOR PLAN A-2.7 SCALE : 3/32"= 1'-0" TYPE G BUILDING 10 DATE: 10-10-2023 Redlands Regular Meeting of 12-03-24 417 of 875
B4
ELEV.

RM

COMMERCIAL
OPEN TO ABV.

OPEN TO ABV.

OPEN TO ABV.

RETAIL 1
RETAIL 2
EP
EP
A4
A4
UP 18R
B5
TRASH
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

ROOM
UP 9R
DN 9R
UP 9R
B4-LW
UP 18R
A3
B5 B5
COATS
UP
A3-LW

ELECTRICAL MPOE
MSIa H. M.

A3
BOILER

FIRE RISER

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE G BUILDING 10 - COMPOSITE LEVEL
1st LEVEL FLOOR PLAN
SCALE : 3/32"= 1'-0"
A-2.7-1
Redlands Regular Meeting of 12-03-24 418 of 875
OPEN TO BLW.

OPEN TO BLW.

OPEN TO BLW.

RETAIL 1
RETAIL 2

COMMERCIAL
EP
UP 18R
A4-DEN
B4
EP A4
B5
ROOM
TRASH
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

W/D
P.

REF
DW
B4-LW
UP 18R
A3
B5 B5
W/D P.

DW
REF
DN
A3-LW
UP 9R
DN 9R
UP 9R
str.

B3

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE G BUILDING 10 - COMPOSITE LEVEL
2nd LEVEL FLOOR PLAN
SCALE : 3/32"= 1'-0"
A-2.7-2
Redlands Regular Meeting of 12-03-24 419 of 875
B4
B4
A3
EP A4-DEN
A3 A3
A3 A3
A3
5' DIA.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
30" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.
24" DIA.
30 48
SIDE APPROACH +54" MAX. A.F.S.

TRASH
EP A4
B5
UP 18R
B4
ROOM
UP 18R
A3
B5 B5
B5
B5
B5
A3
UP 9R
DN 9R
UP 9R
B3
A1

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
TYPE G BUILDING 10 - COMPOSITE LEVEL
3rd & 4rd LEVEL FLOOR PLAN
SCALE : 3/32"= 1'-0"
A-2.7-3
Redlands Regular Meeting of 12-03-24 420 of 875
ROOF

SLOPE TO DRAIN ROOF CONDENSER ROOF CONDENSER FLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF FLAT ROOF ROOF SLOPE TO DRAIN ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN ROOF SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF

SLOPE TO DRAIN
ROOF
SLOPE TO DRAIN DIVERSIFIED PACIFIC COMMUNITIES 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730 (909) 373-2628 144 NORTH ORANGE ST., ORANGE, CA 92866 (714) 639-9860 AO ARCHITECTS TENNESSEE VILLAGE REDLANDS, CA 92374 DATE: 02-06-2023 TYPE G BUILDING 10 - ROOF PLAN JOB NO.: 2020-322 A-2.7-4 DATE: 10-10-2023 Redlands Regular Meeting of 12-03-24 421 of 875
UP 18R
A1 Abv.

A1 Abv.

A1
A1
UP 18R
A1
B4 A1
A3
A3
A2
B4
UP 18R A3-LW
P. W/D
DW
REF
DN
UP
COATS
A3-LW W/D P. DW REF DN
A3-LW UPCOATS A3-LW
A2A-LW
A2A-LW W/D P. REF DW
B4-LW
B4-LW UP 18R
B4UP 18RB4UP 18R

DIVERSIFIED PACIFIC COMMUNITIES
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 02-06-2023
JOB NO.: 2020-322
TYPE H BUILDING 8 - COMPOSITE LEVEL
1, 2 & 3 FLOOR PLANS
A-2.8
SCALE : 3/32"= 1'-0"
1st LEVEL FLOOR PLAN 2nd LEVEL FLOOR PLAN 3rd LEVEL FLOOR PLAN DATE: 10-10-2023
Redlands Regular Meeting of 12-03-24 422 of 875

BEDROOM
11'-7"x11'-2" LIVING
ROOM
12'-0"x12'-8"
M. BDRM
11'-0"x12'-8"
W.I.C.

KITCHEN

BALCONY
7'-8"x10'-3"
ENTRY
BATH
W/D
W.I.C.

BATH
UNIT B1: 2BR/2BA
RENTABLE: 1,097 SQ.FT.

PATIO/BALCONY: 78 SQ.FT.

EP W/D
P.

W.I.C.

BDRM.
12'-5" X 11'-1"

PATIO /

BALCONY
9'-3" X 5'-9"

KITCHEN
UNIT B3: 2BR/2BA
RENTABLE: 1,111 SQ.FT.

PATIO/BALCONY: 54 SQ.FT.

LIVING
13'-0" X 12'-7"
W.I.C.

M.BATH BATH
M.BDRM.
11'-1" X 12'-0"
HUB E.P.

W/D
P.

REF
DW
W.I.C.

BDRM.
11'-2" X 11'-0"

PATIO /

BALCONY
7'-8" X 8'-6"
KIT
BATH
UNIT B4: 2BR/2BA
RENTABLE: 1,246 SQ.FT.

PATIO/BALCONY: 71 SQ.FT.

M.BATH
M.BDRM.
12'-0" X 13'-11"
W.I.C.

LIVING
16'-3" X 12'-2"
DINING
ENTRY

COATS COATS
L
L
HUB
E.P.

W/D
P.

DW
REF
COAT
W.I.C.

M.BDRM.
11'-2" X 12'-7"

PATIO /

BALCONY
11'-0" X 7'-0"

KITCHEN
BATH
LIVING
12'-11" X 16'-2"
M.BDRM.
11'-4" X 13'-9"
UNIT B5: 2BR/2BA
RENTABLE: 1,145 SQ.FT.

PATIO/BALCONY: 77 SQ.FT. CB CB
W/D W.I.C.

M.BDRM.
11'-0" X 13'-0"

PATIO /

BALCONY
10'-10" X 8'-11"

KITCHEN
BATH
UNIT C1: 3BR/2BA
RENTABLE: 1,342 SQ.FT.

PATIO/BALCONY: 84 SQ.FT.

LIVING
13'-4" X 14'-0"
BDRM.2
12'-0" X 11'-2"
BDRM.3
11'-0" X 11'-0"
PATIO
8'-0" X 8'-8"
PWDR
UNIT
ENTRY
COATS/

STORAGE
UP

LIVE/WORK SPACE
29'-9" X 35'-3"
UNIT B4 LW: 2BR / 2.5BA/ LW
LEVEL 1 AREA: 1303 SQ. FT.

LEVEL 2 AREA: 1256 SQ. FT.

TOTAL AREA: 2,559 SQ. FT.

BALCONY + PATIO: 75 SQ. FT. + 75 SQ. FT. = 150 SQ. FT. E.P.

W/D
P.

REF
DW
W.I.C.

BDRM.
11'-2" X 11'-0"
KIT
BATH
LIVING
16'-3" X 11'-4"
M.BATH M.BDRM.

W.I.C. 11'-0" X 16'-0"
DINING

BALCONY
8'-0" X 8'-6"
DN

DIVERSIFIED PACIFIC COMMUNITIES
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
A-3.2
UNIT PLANS 2
SCALE : 3/16"= 1'-0"
Redlands Regular Meeting of 12-03-24 423 of 875
HUB
E.P.

W/D
P.

DW
REF
W.I.C.

BDRM.
11'-2" X 12'-10"

PATIO /

BALCONY
13'-0" X 8'-2"

KITCHEN
BATH
UNIT A3: 1BR/1BA
RENTABLE: 766 SQ.FT.

PATIO/BALCONY: 100 SQ.FT.

LIVING
12'-11" X 15'-2"
EP W/D

MOVABLE
ISLAND
60" TUB
P.

W.I.C.

BDRM.
11'-0" X 12'-5"

PATIO /

BALCONY
5'-9" X 9'-3"

KITCHEN
W.I.C.

BATH
UNIT A4: 1BR/1BA
RENTABLE: 765 SQ.FT.

PATIO/BALCONY: 54 SQ.FT.

LIVING
12'-0" X 13'-4"
HUB
E.P.

W/D P.

DW
REF
W.I.C.

BDRM.
11'-2" X 12'-7"

BALCONY
13'-0" X 8'-5"

KITCHEN
BATH
LIVING
12'-11" X 11'-2"
DN
UNIT
ENTRY
PWDR
UP
COATS
PATIO
11'-0" X 8'-5"

LIVE/WORK SPACE
24'-0" X 24'-4"
UNIT A3 LW: 1BR / 1.5BA/ LW
LEVEL 1 AREA: 764 SQ. FT.

LEVEL 2 AREA: 697 SQ. FT.

TOTAL AREA: 1,461 SQ. FT.

ALCONY + PATIO: 100 SQ. FT. + 100 SQ. FT. = 200 SQ. FT.

W/D
COATS
FIXED
ISLAND
L
LIVING
ROOM
11'-6"x15'-1"
DINING
ROOM
PATIO/

BALCONY
7'-6"x10'-5"

KITCHEN

BEDROOM
11'-6"x11'-0"
BATH
ENTRY
W.I.C.

UNIT A1: 1BR/1BA
RENTABLE: 767 SQ.FT.

PATIO/BALCONY: 78 SQ.FT.

DIVERSIFIED PACIFIC COMMUNITIES
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
A-3.1
UNIT PLANS 1
SCALE : 3/16"= 1'-0"
Redlands Regular Meeting of 12-03-24 424 of 875

ENTERTAINMENT

MAILROOM
AMAZON
LOUNGE

LEASING
24'-0" x 26'-8" OFFICE 1
13'-6" x 10'-4"
OFFICE 2
13'-6" x 10'-5" DECORATIVE

COFFERED

CEILING
10'-3" x 12'-2"
BREAK RM.

BAR
W
FAU

PARCEL/

PACKAGE
10'-3" x 20'-0"
JAN./STR.

CLUBROOM
35'-0" x 35'-0"
M
POOL
60-0" x 35'-0"

FITNESS
(+/-3,038 SQ.FT.)
J. STR.

EQPT.
38'-0" x 36'-0"

THEATER
W M

GOLF SIMULATOR
17'-9" x 20'-0"
STR.
17'-4" x 33'-6"
YOGA
R

CREATIVE
(+/-1,438 SQ.FT.)
OFFICE
48 SIDE APPROAC +54" MAX. A.

Monday, November 20, 2023 1:51:39 PMR:\2020\2020-322 DIVERSIFIED PACIFIC REDLANDS APTS REDLANDS\03 DESIGN\SCHEM\AUTOCAD\A4.1_AMENITY-FLOOR PLANS.DWG DIVERSIFIED PACIFIC 10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
A-4.1

AMENITY FLOOR PLAN
LEASING / CLUBHOUSE =
+/-12,064 + +/-1,438 =+/-13,502 SQ.FT.

Redlands Regular Meeting of 12-03-24 425 of 875

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
PERSPECTIVE OF PROJECT ENTRY 1

ON TENNESSEE STREET
A-1.6
TENNESSEE ST.

PROJECT
11 10
9 5 6
2 3
8 7
1 PENNSYLVANIA AVE.

ENTRY 2

PROJECT
ENTRY 1

PROJECT
ENTRY 3
Redlands Regular Meeting of 12-03-24 426 of 875

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322

VIEW TO PROJECT FROM
TENNESSEE STREET INTERSECTION -1
A-1.7
TENNESSEE ST.

PROJECT
11 10
9 5 6
2 3
8 7
1 PENNSYLVANIA AVE.

ENTRY 2

PROJECT
ENTRY 1

PROJECT
ENTRY 3
Redlands Regular Meeting of 12-03-24 427 of 875

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
A-1.8
TENNESSEE ST.

PROJECT
11 10
9 5 6
2 3
8 7
1 PENNSYLVANIA AVE.

ENTRY 2

PROJECT
ENTRY 1

PROJECT
ENTRY 3

VIEW TO PROJECT FROM
TENNESSEE STREET INTERSECTION - 2
Redlands Regular Meeting of 12-03-24 428 of 875

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
PROJECT ENTRY 2 STREET SCENE JOB NO.: 2020-322
A-1.9
TENNESSEE ST.

PROJECT
11 10
9 5 6
2 3
8 7
1 PENNSYLVANIA AVE.

ENTRY 2

PROJECT
ENTRY 1

PROJECT
ENTRY 3
Redlands Regular Meeting of 12-03-24 429 of 875

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
PROJECT ENTRY 2 &
BUILDING 8 PERSPECTIVE
A-1.10
TENNESSEE ST.

PROJECT
11 10
9 5 6
2 3
8 7
1 PENNSYLVANIA AVE.

ENTRY 2

PROJECT
ENTRY 1

PROJECT
ENTRY 3
Redlands Regular Meeting of 12-03-24 430 of 875

INTERNAL STREET PERSPECTIVE
at BUILDING 10

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
A-1.11
TENNESSEE ST.

PROJECT
11 10
9 5 6
2 3
8 7
1 PENNSYLVANIA AVE.

ENTRY 2

PROJECT
ENTRY 1

PROJECT
ENTRY 3
Redlands Regular Meeting of 12-03-24 431 of 875

DIVERSIFIED PACIFIC
10621 CIVIC CENTER DRIVE, RANCHO CUCAMONGA, CA 91730
(909) 373-2628
144 NORTH ORANGE ST., ORANGE, CA 92866
(714) 639-9860

AO ARCHITECTS
TENNESSEE VILLAGE REDLANDS, CA 92374
DATE: 10-10-2023
JOB NO.: 2020-322
A-1.12
TENNESSEE ST.

PROJECT
11 10
9 5 6
2 3
8 7
1 PENNSYLVANIA AVE.

ENTRY 2

PROJECT
ENTRY 1

PROJECT
ENTRY 3

INTERNAL STREET PERSPECTIVE
of BUILDING 8 &10
Redlands Regular Meeting of 12-03-24 432 of 875
ARCHITECTURAL DESIGN GUIDELINES (Tennessee Village)

DESIGN GUIDELINES PROPOSED PROJECT
I. Project Architecture
Provide architectural treatment to all elevations that are visible from either public or private vantage points.

Consistent. All sides and elevations have architectural treatments of varying types.

Avoid expanses of blank wall, devoid of any articulation or embellishment for both buildings and freestanding walls.

Consistent. There are no large expanses of blank walls without openings (e.g., windows, doors, pathways, etc.) or utilization of different colors or materials.

Elevations should be visually attractive by providing surface articulation in all areas of the building plane, including vertical and horizontal variation to the roofline.

Consistent. All buildings have a significant amount of wall plane offsets and articulation.

All sides of all buildings present varying amounts of surface articulation with vertical and horizontal wall plane offsets.

Rooftop equipment shall be concealed by providing raised architectural elements around equipment to screen roof
equipment on buildings or integrating the screening within the roof slopes. Screening is acceptable by parapets or by
equipment screens when a parapet is not feasible.

Consistent. Parapets can conceal any rooftop equipment. A condition of approval will be included that requires appropriate screening of all rooftop equipment, and will be verified in Plan Check.

Vary the roof through the use of vertical separations, varying roof structure, varying the parapet line or ridge line.

Consistent. Roofs and rooflines vary and are offset on all sides of all buildings.

Within developments, provide a safe and comfortable walking environment for pedestrians. Pedestrian areas should be shaded and contain small niches, landscaped planters, or raised planters, and other amenities to create additional visible interest.

Consistent. Features throughout the development are designed as pedestrian-friendly, with open space areas, recreation amenities, trees, landscape areas, and lighting.

Redlands Regular Meeting of 12-03-24 433 of 875

DESIGN GUIDELINES PROPOSED PROJECT
Provide focal points in the architectural theme to create a strong entry statement and provide a sense of place. Towers, spires, massing, colors, trellises, fountains, public art, and plazas are encouraged.

Consistent. Enhanced entries are provided to commercial portions of the project with open space amenities planned near building entries as a focal point.

Building articulation shall be included in the design of building, in order to create a formal entry statement.

Consistent. Exterior façades include architectural features significant articulation.

All projects are strongly encouraged to be designed by a licensed architect with experience in commercial architecture.

Consistent. Project plans prepared by licensed architects.

Use building materials that provide texture and character to building surfaces.

Consistent. A variety of materials/textures are proposed.

Architectural details may include accent colors treatments, however projects should avoid an excessive amount of bright or highly reflective colors which overpower the building.

Consistent. A variety of materials, textures, and colors are proposed (including brick veneer, tile, and stucco finishes) None of the proposed materials or colors are brightly colored or highly reflective.

Consider site amenities, such as walls, raised planters, hardscape, street furniture, trash enclosures, lighting, and monument signs, as part of the total architectural package for the project. Articulate and integrate bike racks and other components into design of buildings, placing racks in visible locations.

Consistent. The project plans carefully consider the landscaping and hardscape elements of the project.

The Site Plan can accommodate multiple bike racks.

27. Project signage must be incorporated into the overall architectural theme of a development. Sign programs shall consider different types of signage designed for pedestrian and auto orientation and shall develop ways to integrate the specific type of sign being used (building, monument, freeway oriented) to a project’s design.

Consistent. Space for signs is anticipated. Future signs will fall under separate review and approval.

Redlands Regular Meeting of 12-03-24 434 of 875

DESIGN GUIDELINES PROPOSED PROJECT
II. Site Design

1. Whenever possible, new structures should be clustered.

This creates plazas or pedestrian mall and prevents long “barracks-like” rows of structures. When clustering is
impractical, a visual link between separate structures should be established. This link can be accomplished through the use of an arcade system, trellis, other open structures, open space planting scheme, plaza, pedestrian areas and enhanced
paving.

Consistent. The proposed site plan arranges new buildings around open space areas and pedestrian paths. New buildings are placed at or near the areas which encourage pedestrian use.

2. Plot buildings to create plazas and logical pedestrian connections. Pedestrian walkways should connect public
transportation, street access, parking lots, and buildings.

Pedestrians should be able to access buildings without walking in drive aisles. Major pedestrian components should have amenities such as shade, adjacent landscaping, and visual interest. All intersections with drive aisles should be clearly marked and signed for safety.

Consistent. The proposed site plan arranges new buildings around a open space areas. New buildings are placed at or near the areas which encourage pedestrian use.

3. Recognize the importance of spaces between structures as “outdoor rooms” on the site. Outdoor spaces should have clear, recognizable shapes that reflect careful planning and are not simply “left over” areas between structures. Outdoor spaces should provide pedestrian amenities such as shade, benches, water features, etc.

Consistent. The proposed site plan arranges new buildings around a new central green belt. New buildings are placed at or near the areas which encourage pedestrian use.
.

29. Screen trash enclosures, ground-mounted equipment and utilities from public view with landscaping or orientation of the building.

Consistent. Service areas are screened.

Redlands Regular Meeting of 12-03-24 435 of 875
T T T T T T COURTYARD 2 RAMP DN. GATE 1 GATE 2 COURTYARD 1 GATE 3 TRASH COURTYARD 4 BOX CALL TRASH (RETAIL) ROOM 1 TRASHROOM TRASH ROOM TRASH ROOM 2 TRASH ROOM TRASH GATE 4 C1 Abv. AMENITY C1 Abv. AMENITY ROOM TRASH ROOM TRASH ROOM TRASH T T T T T T COURTYARD 2 RAMP DN. GATE 1 GATE 2 COURTYARD 1 GATE 3 TRASH COURTYARD 4 BOX CALL TRASH (RETAIL) ROOM 1 TRASHROOM TRASH ROOM TRASH ROOM 2 TRASH ROOM TRASH GATE 4 C1 Abv. AMENITY C1 Abv. AMENITY ROOM TRASH ROOM TRASH ROOM TRASH C C D D E E

SF ACRES
LOT 1 59,558 1.37
LOT 2 65,014 1.49
LOT 3 218,575 5.02
LOT 4 212,514 4.88
SUB-TOTAL (NET AREA) 555,661 12.76
ADDITIONAL TENNESSEE ST. R/W 6,429 0.15
ADDITIONAL PENNSYLVANIA AVE. R/W25,038 0.57
SUB-TOTAL 31,467 0.72
Totals 587,128 13.48 ©
3801 UNIVERSITY AVENUE, SUITE 300, RIVERSIDE, CA 92501
PHONE: 951.543.9868
WWW.KIMLEY-HORN.COM
Redlands Regular Meeting of 12-03-24 436 of 875

SOCIO-ECONOMIC EVALUATION CHECKLIST FORM

BACKGROUND

1. Project Title: Tennessee Village Mixed-Use Project
Amendment No. 50 to Specific Plan 40
Zone Change No. 477
Parcel Map No. 20688
Conditional Use Permit No. 1173
Commission Review and Approval No. 956

2. Lead Agency Name and Address: Mailing Address:

City of Redlands City of Redlands
Development Services Department Development Services – Planning 35 Cajon Street, Suite 20 P.O. Box 3005
Redlands, CA 92373 Redlands, CA 92373

3. Contact Person & Telephone: Sean Reilly, (909) 798-7555

4. Project Location: The project is located on the east side of Tennessee Street approximately 600 feet north of West Lugonia Avenue within the Special Development (EV/SD) District of the East Valley Corridor Specific Plan (APN: 0167- 171-15-0000)

5. Project Sponsor's Name and Address: Diversified Pacific Development Group, LLC

6. General Plan Designation: Commercial

7. Existing Zoning Designation: EV/SD (Special Development)

8. Proposed Zoning Designation: C-3 (General Commercial)

9. Description of Project: The applicant proposes to develop a vacant 12.79-acre (net) project site with ten buildings, which include a mix of residential and commercial uses.

The project includes 460 residential units and approximately 18,000 square feet of commercial space. Mixed-use buildings include ground floor commercial space with residential units above and six live/work lofts that incorporate retail/office in the bottom story and a residential unit on the second story. Commercial uses within the project are located near the southwestern corner of the project in Building 8 and Building 10. The remainder of the buildings are residential apartments only.

A total of 20 residences within the apartment community would be restricted for rental only to Very Low-income households, as defined. Therefore, the project is eligible for a Density Bonus and concessions and waivers pursuant to State Density Bonus Law (Gov. Code § 65915 et seq.).

Redlands Regular Meeting of 12-03-24 437 of 875
The proposed project would restrict a total of 20 units, which is 5% of the unit count of the project (384 DU x 0.05 = 20), for affordable housing in exchange for approval of a density bonus. By providing 20 affordable housing units, the allowable density bonus is equivalent to 20% of the allowable base unit count (384 DU x 0.2 = 76 units). Approval of the project and the related density bonus agreement would allow a total of 460 units (382 + 76 = 460).

10. Existing On-site Land Use and Setting:

The project site is a nearly square 12.7-acre property located on the east side of Tennessee Street approximately 600 feet north of Lugonia Avenue. The site is approximately 815’ wide (east to west) and 720’ long (north to south), approximately rectangular in shape, and located abutting the east side of the existing Tennessee Street, south of the future alignment of Pennsylvania Avenue.

The project site is in an area that is surrounded by properties that are proposed for development or in the process of being entitled. To the east of the site, the Lugonia Villages project has been entitled, which includes a mix of residential uses including multi-family apartments and condos. Anticipated future development of the properties located to the immediate south of the project is likely to include commercial development which will complement this proposed mixed-use development.

11. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement): None.

COST BENEFIT FACTORS:

The cost benefit factors are evaluated independently using the cost benefit model. A positive or negative cost/benefit ratio will be derived by evaluating projects. A complete model used to evaluate the project is available in the Development Services Department.

A summary of that analysis is provided here:

According to the Cost Benefit Model used by the City, this project will provide the City approximately $564,399 in revenue and costs of $322,042 resulting in a positive balance of $242,357 with a Cost Benefit Ratio of 1.75 over the period of 2025-2034.

PUBLIC INFRASTRUCTURE AND EFFECT ON THE CITY OF REDLANDS:

Identify the public infrastructure required for development of this project and identify the source(s) of funding for these improvements. Identify the effects of such development Redlands Regular Meeting of 12-03-24 438 of 875
upon the City of Redlands.
a) List of public infrastructure required for the project:

The applicant will provide the infrastructure as required by the Municipal Utilities and Engineering Department. The project has an immediate street frontage on Tennessee Street and Pennsylvania Avenue. The following items will be required.

Road Lane Miles: Tennessee Street: 0.28
Pennsylvania Avenue: 0.15
Storm Drain Facilities:

Street Lights: Tennessee Street: 3
Pennsylvania Avenue: 4
Parkway landscaping: Tennessee Street: 4,380 sf
Pennsylvania Avenue: 4,634 sf

b) Sources of funding for these improvements to include developer installed payment of impact fees, assessment districts, etc.:

The developer will directly find the construction of required new infrastructure to serve the project and the developer will be required to pay applicable Development Impact Fees and permit fees as required by the Redlands Municipal Code. c) The effect of the project upon the City of Redlands relative to public infrastructure is as follows:

This project will impact existing public infrastructure systems. However, any impact or maintenance costs will be offset by the developer’s payment of Development Impact Fees and extension of utility lines into the project site.

BENEFITS OF THE PROJECT TO THE CITY OF REDLANDS:

The following is a list of benefits that can be attributed to the proposed project. The benefits may fall into the categories identified or a miscellaneous category. Each benefit identified will be described in detail with supporting reasons as to how the item benefits the community.

A. Citrus Enhancements or Preservation. Does the project preserve citrus? The following are accepted ways to enhance or preserve citrus which may be determined to be Redlands Regular Meeting of 12-03-24 439 of 875
a benefit to the City of Redlands.

1. Provide conservation easement(s) on citrus groves the City hopes to preserve.

2. Acquire citrus grove(s) and donate all or a portion of the grove to the City.

3. Enhance viability and productivity of existing groves by enhancing irrigation or adding frost water.

4. Maintain a viable buffer of citrus around the project (at least 3 rows).

5. Other ways to preserve citrus.

If this project provides benefit(s) that apply to citrus enhancement or preservation, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project will not benefit citrus or agriculture. No citrus will be removed by the project and no agriculture or citrus preservation is proposed.

B. Cultural Enhancements or Preservation. Does the project enhance or preserve cultural aspects of the community? The following are accepted ways to enhance and/or preserve cultural aspects of the community which may be determined to be a benefit to the City of Redlands.

1. Contributes to “art in public places” concept to a minimum of 1% of total project value.

2. Contributes to the alleviation of problems at cultural sites.

3. Provides an electronic library available to the public.

4. Enhances or contributes to current services or cultural resources.

5. Contribute to performing arts venues.

If this project provides benefit(s) that apply to cultural enhancements or preservation, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project does not propose contributions or enhancements to cultural aspects of the community. The project will pay City established Development Impact Fees and provide additional revenue from increased property tax assessment, business license tax, and other revenue sources that will indirectly provide funding that will contribute to enhancing and/or maintaining some of the cultural facilities within the City.

C. Heritage Enhancements or Preservation. Does the project enhance or preserve Redlands Regular Meeting of 12-03-24 440 of 875
heritage aspects of the community? The following are accepted ways to enhance and/or preserve heritage aspects of the community which may be determined to be a benefit to the City of Redlands.

1. Renovates existing historic homes.

2. The project has design features which include garage doors do not face street; 50% wrap around porch on 1-1/2 sides; broad overhangs on roof; driveway located on the side of house or a circular drive; decorative wood, masonry or wrought iron fence.

3. Adaptive reuse of historic structures in appropriate zones.

4. Forming a new or annexing to an existing historic district.

5. Designation of a structure as an individual historic resource.

If this project provides benefit(s) that apply to heritage enhancements or preservation, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The property is not located within a Historic and Scenic District.

The site does not contain any historical structures. No structures on site are considered historic and therefore no structures on the site will be adaptively reused.

D. Architectural Enhancements. Does the project enhance architectural aspects of the community? The following are accepted ways to enhance architectural aspects of the community which may be determined to be a benefit to the City of Redlands.

1. Provide architectural or decorative enhancements to the project which exceed normal architectural standards.

2. Trees or other landscaping amenities that exceed minimum requirements.

3. Contribution of off-site enhancements in the public right-of-way, such as sidewalk installation and street tree replacement.

4. Assisting in undergrounding of utility lines.

If this project provides benefit(s) that apply to architectural enhancements, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project includes public landscape areas within parkway areas and landscaped setback areas along Tennessee Street, Pennsylvania Avenue. The project includes 360-degree architecture with projections and recessed elements on all four sides and significantly exceeds landscaping for the C-3 District by landscaping 15% of the site area.

E. Historic Downtown Enhancements or Preservation. Does the project enhance or Redlands Regular Meeting of 12-03-24 441 of 875
preserve the historic downtown of the community? The following are accepted ways to enhance and/or preserve the historic downtown of the community which may be determined to be a benefit to the City of Redlands.

1. Contributes financially to viability of core downtown within expanded downtown.

2. Renovate old buildings.

3. Within an expanded downtown extends DRBA streetscape enhancements.

4. Contributing to the restoration of original building facades of existing structures

5. Re-establishing historical “pedestrian oriented” street frontages where original buildings have been removed.

6. Provides unique adaptive use of historic building.

7. Contributes to alternative means of transportation.

If this project provides benefit(s) that apply to historic downtown enhancements or preservation, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project is not located within the historic downtown district.

The project will pay City established Development Impact Fees and provide significant additional revenue from increased property tax assessment, business license tax, and other revenue sources that will indirectly provide funding that could be utilized to enhance and/or maintain the downtown district.

F. Job Enhancements. Does the project enhance jobs for the community? The following are accepted ways to enhance jobs for the community which may be determined to be a benefit to the City of Redlands.

1. Provides jobs for the community.

2. Brings in revenue from outside the city.

3. Internship opportunities for students at universities, high school and colleges.

If this project provides benefit(s) that apply to job enhancements, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project is a mixed-use development, which will create some jobs. Jobs created may be related to those related to the construction activities necessary to develop the apartment project area and those required to provide the services related to the operation and maintenance of the project upon completion. The commercial area portion of the project is anticipated to create up to 89 jobs.

Redlands Regular Meeting of 12-03-24 442 of 875
The additional housing opportunities provided by the project will be available to local and regional employees who work in Redlands, and some may be able to relocate to Redlands as a result of expanded housing opportunities. It is also anticipated that the presence of these new residents will stimulate other sectors of the local economy (i.e., goods, services, and other expenditures in Redlands due to the additional local residents and their family members).

G. Open Space Enhancements or Preservation. Does the project enhance or preserve open space aspects of the community? The following are accepted ways to enhance and/or preserve open space within the community which may be determined to be a benefit to the City of Redlands.

1. Hardscape feature that enhances wildlife-water/food/ shelter.

2. Enhanced landscape on commercial project which conceals infrastructure.

3. Waterscaping which increases illusion of open space.

4. Provides open space in addition to zoning requirement.

5. Provides a Planned Residential Development

6. Provides a usable conservation easement across open space in perpetuity.

7. Preserves access for wildlife migration corridor.

8. Provides undisturbed refuge area for wildlife.

If this project provides benefit(s) that apply to open space enhancements or preservation, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project will not detrimentally impact any open space features or amenities of the City of Redlands, nor affect wildlife. The project will provide both private and common outdoor open space areas that exceed the minimum requirements.

H. Park Enhancements or Preservation. Does the project enhance or preserve parks of the community? The following are accepted ways to enhance and/or preserve parks within the community which may be determined to be a benefit to the City of Redlands.

1. Adds improved parkland.

2. Adds parkland beyond requirements.

3. Provides pedestrian and/or bike trails to parks or provides extension of existing pedestrian and/or bike trails from the project site.

4. Adds meeting rooms accessible to local groups on a frequent basis.

5. Improves or adds to existing landscape and/or streetscape at or near the project site.

Redlands Regular Meeting of 12-03-24 443 of 875
If this project provides benefit(s) that apply to park enhancements or preservation, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The proposed project does not enhance or preserve parks of the community but will provide onsite amenities for the onsite residents. The project will pay City established Development Impact Fees and provide additional revenue from increased property tax assessment, business license tax, and other revenue sources that will indirectly provide funding that will contribute to enhancing and/or maintaining some of the existing park facilities within the City.

I. Public Safety Enhancements. Does the project enhance public safety aspects of the community? The following are accepted ways to enhance public safety within the community which may be determined to be a benefit to the City of Redlands.

1. Security infrastructure is provided in an architecturally acceptable manner.

2. Exterior television monitoring on commercial project.

3. Provide a building site or fully equipped fire station or contributes to dedicated City account for future construction.

4. Provides significant additional fire equipment as determined by the Fire Department.

5. Provides for a police substation (subject to City approval).

6. Provides for a building site for a new facility.

If this project provides benefit(s) that apply to public safety enhancements, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project will pay Development Impact Fees which have been established by the City to fund public facilities, including police and public safety services. The project will include security lighting adjacent to the building and parking areas. The project and its future residents will also provide additional revenue from increased property tax assessment and sales tax revenue, which will assist in funding police and public safety operations.

J. School Enhancements. Does the project enhance schools or their operations within the community? The following are accepted ways to enhance schools within the community which may be determined to be a benefit to the City of Redlands.

1. Senior citizen development adds revenue but no impact.

2. Provides day care and after school program(s).

Redlands Regular Meeting of 12-03-24 444 of 875

3. Project is close to schools serving the project.

4. Contributes equipment or other enhancements to existing day care and after school programs.

5. Assist schools with land or financing (such as Mello Roos).

If this project provides benefit(s) that apply to schools, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project site is within close proximity to schools in the community. The project will pay State-established School Fees that will assist in the future funding of school facilities. Future property owners will also pay the applicable annual property taxes.

K. Traffic. Does the project reduce traffic, enhance systems to improve traffic conditions or otherwise improve traffic within the community? The following are accepted ways to improve traffic within the community which may be determined to be a benefit to the City of Redlands.

1. Provide financial mitigation which helps alleviate parking problems in town i.e. by contributing to the parking district.

2. Incorporate “traffic calming” elements into the design of the circulation system.

3. Support for alternative forms of public transportation or public transportation facilities.

4. Add biking and pedestrian access to off campus intellectual or entertainment resources.

5. Have a unique method of product/inventory delivery.

If this project provides benefit(s) that apply to traffic, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The proposed project will consist of 460 apartment units and approximately 18,000 square feet of commercial space. The project does not include specific traffic reduction measures.

L. Wastewater System Enhancements. Does the project enhance the wastewater system within the community? The following are accepted ways to improve the wastewater system within the community which may be determined to be a benefit to the City of Redlands.

1. Provide a dual system to use potable and non-potable water.

2. Provide financial contributions to tertiary facilities at the Wastewater Redlands Regular Meeting of 12-03-24 445 of 875
Treatment Plant.

3. Improve water quality.

If this project provides benefit(s) that apply to the wastewater system, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project will be required to construct any required public infrastructure and connections as a standard requirement for such development projects. The project does not warrant any improvements or expansion to the Citywide system, and the project does not propose any enhancements to the larger wastewater system. However, the project applicant will be required to pay their fair share of development impact fees for wastewater systems as a standard requirement for such development projects.

M. Miscellaneous Preservation or Enhancements. Does the project enhance or preserve elements within the community?
If this project provides benefit(s) that apply to enhancement or preservation of elements that are important to the City, describe in detail the benefit(s) with supporting reasons as to how the item(s) benefits the community.

Proposed Project: The project does not provide any additional or miscellaneous enhancements or preservation of elements within the community other than those previously identified (discussion above).

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SOCIAL FACTORS POTENTIALLY AFFECTED:

This project may create unmitigable physical blight or overburden public services for those social factors checked below within the "Potentially Significant," “Potentially Significant Unless Mitigation” or "Less Than Significant" as indicated by the checklist on the following pages.
_ Agricultural/Citrus Removal
Wildlife/Habitat
Traffic
Fire Services
Paramedic Services
 Police Services
Downtown Impacts
 Residential Design
Cultural Facilities
 Park Facilities
Recreational Programs
 Land Use Compatibility
Schools

DETERMINATION
On the basis of this initial evaluation:

X I find that the proposed project will not create unmitigable physical blight or overburden public services in the community, and no additional information or evaluation is needed.

I find that although the proposed project could create unmitigable physical blight or overburden public services in the community, there will not be a significant effect in this case because the mitigation measures described on an attached sheet have been added to the project by the applicant.

I find that the proposed project may create unmitigable physical blight or overburden public services in the community, and additional information or evaluation is needed in the following areas:

I find that the proposed project has already been evaluated for socio-economic impacts and the prior evaluation adequately evaluated this project.

Signed:

Sean Reilly
Principal Planner
City of Redlands
August 27, 2024
Redlands Regular Meeting of 12-03-24 447 of 875

EVALUATION OF SOCIAL FACTORS
Explanations of all "Potentially Significant," "Potentially Significant Unless Mitigation Incorporated," "Less Than Significant Impact," and "No Impact" answers are provided on the attached pages.

Issues and Supporting Information Sources:

Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

1. AGRICULTURAL/CITRUS REMOVAL.

Would the proposal:
a) Affect agricultural resources or operations (e.g.
impacts to soils or farmlands, or impacts from
incompatible land uses)? _ 
b) Remove active citrus groves from production? _ 
Agricultural/Citrus Removal – Discussion
a, b) No Impact. None of the project area is zoned for or in agricultural production. The project has a General Plan Designation of Commercial. There is no active agricultural use onsite. The property is not currently part of a larger farmland, orchard, or other agricultural purpose. However, while the project site has been used for agricultural purposes in the past, the site is zoned for Commercial uses. Impacts would be less than significant.

Redlands Regular Meeting of 12-03-24 448 of 875
Issues and Supporting Information Sources:

Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

2. WILDLIFE/HABITAT/OPEN SPACE PRESERVATION.

Would the proposal:
a) Eliminate or have negative impact upon wildlife
corridors?
b) Tend to urbanize open space
impacting preservation and
conservation of natural resources?




c) Interfere with use of recognized trails
used by joggers, hikers, equestrians
or bicyclists?
d) Eliminate, reduce, or have any negative
impact upon wildlife habitat areas to include
the protection of fringe or buffer areas?




Wildlife/Habitat/Open Space Preservation – Discussion
a) No Impact. The project site is expected to be utilized by common, non-special-status wildlife for foraging and possibly breeding. However, the project site is situated in an urbanized area and does not represent a wildlife movement corridor as it (along with other small neighboring vacant lots) is largely bound on all sides by developments, possesses vegetation that is largely non-native that would support high levels of species diversity, and it is too small of an area to support significant wildlife movement. According to the Biological Resources Assessment, no migratory wildlife corridors or native wildlife nursery sites were identified within the project site. The project site and surrounding area does not connect large areas of native habitats and development at this site would not preclude wildlife movement in otherwise open areas. Therefore, no impacts would occur as a result of the project. b) No Impact. The project would not urbanize planned open space as designated on the General Plan Land Use Map there are no conservation areas located within the immediate vicinity of the project.
c) The project will not interfere with the use of recognized trails used by joggers, hikers, equestrians or bicyclists. The project is proposed on a generally flat, vacant Redlands Regular Meeting of 12-03-24 449 of 875
parcel and it will include new sidewalk and bike lanes, which provide connectivity for pedestrian circulation within the area.
d.) Less than Significant Impact with Mitigation. The entire project area has been historically altered by mowing and discing, and all the landcover at the project site can be classified as Disturbed and/or Developed. Disturbed habitat type is composed primarily of early successional /ruderal plant species. Much of the vegetation present at the project site is non-native, and the site receives regular clearing to maintain compliance with fire code.

As determined in the General Biological Resources Assessment prepared for the project, none of the 90 special status plant species that are present in the region are expected to occur on the project site, primarily due to disturbance such as historical discing and recent mowing. Therefore, impacts to special-status plant species would not occur as a result of the proposed project.

According to the General Biological Resources Assessment, it was initially determined that 62 special-status wildlife species have been recorded in the vicinity of the project site. Of these wildlife species, 56 are not expected to occur on the project site. Reasons include the absence of essential habitat requirements for the species, the distance to known occurrences and/or the species distributional range, the limited availability of foraging and nesting habitat, amount of site disturbance from past and present land uses, and/or the proximity of existing human-related disturbances. The wildlife species that occur or have some potential to occur on-site include six (6) birds: Cooper's hawk [Accipiter cooperii], burrowing owl [Athene cunicularia], Swainson's hawk [Buteo swainsoni], California horned lark [Eremonphila alpestris actia], merlin [Falco columbarius], and loggerhead shrike [Lanius ludovicianus]. It is assumed that all of these species could potentially be present at the site because they have been observed in disturbed habitats and/or in similar habitats close proximity to the Project Site. These species could be affected by project construction and/or habitatloss due the construction of the project. As such, and as detailed below, implementation of Mitigation Measures BIO-1 and BIO-2 would be required to reduce potential impacts to special status wildlife species to a less than significant level.

Nesting Birds
Nesting birds are protected under California Fish and Game Code (CFGC) 3503, 3503.5, and 3512, which prohibits the take of active bird nests. Native and non-native shrubs and trees within the project site provide highly suitable nesting habitat for songbirds, including common species protected by the code. There is potential for ground- and tree-nesting birds to establish nests on the project site prior to any project-related construction.

Construction activities including site mobilization, vegetation clearing, grading, and noise and vibration from the operation of heavy equipment have the potential to result in significant direct (i.e., death or physical harm) and/or indirect (i.e., nest abandonment) impacts to nesting birds. The loss of an active nest of common or special-status bird Redlands Regular Meeting of 12-03-24 450 of 875
species and/or their eggs or young as a result of project construction would be considered a violation of the CDFGC, Section 3503, 3503.5, 3513. Therefore, implementation of Mitigation Measure BIO-1 is required to reduce impacts to nesting birds to a less than significant level.

Burrowing Owls
As determined in the Burrowing Owl Survey Report, suitable habitat type (Disturbed and/or Developed) for burrowing owl was determined to be present on the project site. While no burrowing owls or sign thereof were observed on the project site, it was determined that burrows and other round structures present on the project site could potentially provide habitat for burrowing owls. Burrowing owls are commonly found in disturbed sites like the project site and can also be found in a wide variety of other open habitats such as grassland or deserts with sparse vegetation. As such, construction activities may impact burrowing owls in a manner like those already described under the discussion of nesting birds above. Therefore, implementation of Mitigation Measure BIO-2 is required to reduce impacts to burrowing owls to a less than significant level.

BIO-1 Pre-construction Survey for Nesting Birds. To the extent feasible, construction activities should be scheduled to avoid the nesting season. If construction activities are scheduled to take place outside the nesting season, all impacts to nesting birds protected under the MBTA and California Fish and Game Code would be avoided. The nesting season for most birds in San Bernardino County extends from February 1 through September 1.

If it is not possible to schedule construction activities between September 1 and January 31, then pre-construction surveys for nesting birds will be conducted by a qualified biologist to ensure that no nests would be disturbed during project implementation. These surveys will be conducted no more than 5 days prior to the initiation of any site disturbance activities and equipment mobilization, vegetation removal, fence installation, grading, etc. If project activities are delayed by more than 5 days, an additional nesting bird survey will be performed. During this survey, the biologist will inspect all vegetation and other potential nesting habitats (e.g., shrubs) in and immediately adjacent to the impact area for nests.

Active nesting is present if a bird is building a nest, sitting in a nest, a nest has eggs or chicks in it, or adults are observed carrying food to the nest. The results of the surveys will be documented.

If an active nest is found sufficiently close to work areas to be disturbed by these activities, the qualified biologist will determine the extent of a construction-free bufferzone to be established around the nest (typically up to 300 feet for raptors and up to 100 feet for other species), to ensure that no nests of species protected by the MBTA and California Fish and Game Code will be disturbed during project implementation. Within the buffer zone, no site disturbance and mobilization of heavy equipment, including but not limited to equipment staging, fence installation, clearing, grubbing, vegetation removal, demolition, and grading Redlands Regular Meeting of 12-03-24 451 of 875
will be permitted until the chicks have fledged.

A qualified biologist is an individual who has a degree in biological sciences or related resource management with a minimum of two seasonal years post-degree experience conducting surveys for nesting birds. During or following academic training, the qualified biologist will have achieved a high level of professional experience and knowledge in biological sciences and special-status species identification, ecology, and habitat requirements.

BIO-2: Pre-construction Survey for Burrowing Owl. No more than 14 days prior to ground disturbance a focused survey for burrowing owl will be required to ensure take avoidance. Even though burrowing owls were not located as part of the general biological survey, a pre-construction survey for burrowing owl is required because burrowing owls may encroach or migrate to the property at any time, and therefore steps should be taken to ensure avoidance, including reevaluating the locations/presence of burrowing owl or burrows. Pre-construction surveys shall be conducted in accordance with the survey requirements outlined in Appendix D of the CDFW’s Staff Report on Burrowing Owl, dated March 7, 2012. If burrowing owl are found on the project site during pre-construction surveys, the biologist conducting surveys shall immediately contact the CDFW to develop a plan for avoidance and/or translocation prior to construction crews initiating any ground disturbance on the project site.

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Issues and Supporting Information Sources:

Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

3. TRAFFIC.

Would the proposal:
a) Result in increased vehicle trips or
congestion?
b.) Create additional traffic so as to be in
conflict with the policies of the General Plan?
c.) Does traffic impact livability of a residential
neighborhood on streets which, due to design
or terrain features, street side development or
other factors, have greater than usual
sensitivity to increased traffic?

__


_

d.) Create additional traffic so as to increase the level of service on roadways that are adjacent to or in the
vicinity of the project? _ _
Traffic – Discussion
a, b, and d) Less than Significant Impact. The proposed project will result in increased vehicle trips within the project area; however, these vehicle trips would not cause an impact that would be in conflict with the policies of the General Plan. Measure U was an initiative approved by the voters of Redlands in 1997 to enact several principles of managed development within the City of Redlands. The principles in Measure U have been incorporated throughout the new 2035 General Plan, as well as several sections of the Redlands Municipal Code. The Measure U Growth Management Analysis evaluated the project using the applicable Measure U Policies identified in the Connected City Element of the City of Redlands 2035 General Plan as well as the County of San Bernardino Transportation Impact Study Guidelines (TIS Guidelines). The Measure U Policies are largely based on Level of Service (LOS) standards that measure traffic congestion. A detailed LOS evaluation is included in the Measure U Growth Management Analysis in order to demonstrate project compliance with Measure U. The Measure U Growth Management Analysis analyzes intersections surrounding the project site. All study intersections are currently operating and at satisfactory levels of services with the exception of the following:

Redlands Regular Meeting of 12-03-24 453 of 875
• Tennessee Street and Lugonia (am and pm peak hours)
• Tennessee Street and Redlands Avenue (am and pm peak hours) The Measure U Growth Analysis also includes a forecast of the levels of service in a “with project” condition. In the with project conditions, all study area intersections are forecast to operate at satisfactory levels of services with the exception of the two previously listed intersections.

Based on Measure U guidelines, where the current LOS at a location within the city is below the LOS standard C, no development project shall be approved that cannot be mitigated so that it does not reduce the existing LOS at that location. While these intersections operate at unsatisfactory LOS D under both “without and with” project conditions, the project does reduce the level of service. Therefore, no improvements are recommended at that intersection. As such, the project would not result in any unsatisfactory LOS; therefore, the project would be in compliance with Measure U, no mitigation is required, and impacts would be less than significant. c) Less than Significant Impact The project will not create a traffic impact in terms of livability of a residential neighborhood which, due to design or terrain features, street side development or other factors, have greater than usual sensitivity to increased traffic. The project is a residential use. 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.

Furthermore, a construction work site traffic control plan shall be submitted to the City for review and approval prior to the start of any construction work. The plans shall show the location of any roadway, sidewalk, bike route, bus stop or driveway closures, traffic detours, haul routes, hours of operation, protective devices, warning signs and access to abutting properties.

Temporary traffic controls used around the construction area should adhere to the standards set forth in the California Manual of Uniform Traffic Control Devices and construction activities should adhere to applicable local ordinances.

Consequently, on-site improvements and improvements adjacent to the site will be required in conjunction with the proposed development to ensure adequate circulation within the project.

A construction work site traffic control plan shall be submitted to the City for review and approval prior to the issuance of a grading permit or start of any construction work. The plans shall show the location of any roadway, Redlands Regular Meeting of 12-03-24 454 of 875
sidewalk, bike route, bus stop or driveway closures, traffic detours, haul routes, hours of operation, protective devices, warning signs and access to abutting properties. Temporary traffic controls used around the construction area must adhere to the standards set forth in the California Manual of Uniform Traffic Control Devices (2014) and construction activities should adhere to applicable local ordinances.

Site development would require the use of haul trucks during site clearing and excavation and the use of a variety of other construction vehicles throughout the construction work at the site. Transportation of heavy construction equipment and or materials, which requires the use of oversized vehicles, will require the appropriate transportation permit. The City shall review all proposed development and construction work site traffic control plans to ensure that public, pedestrian, and school safety are addressed.

Redlands Regular Meeting of 12-03-24 455 of 875
Issues and Supporting Information Sources: Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

4. FIRE & PARAMEDIC SERVICES.

Will the proposal result in:
a) Requiring fire and paramedic services that are
beyond the current capabilities of the Fire
Department?

b) An increase in response time for essential fire or
paramedic services to the remainder of the
community? 
c) The need for additional fire or paramedic facilities or equipment?

Fire & Paramedic Services – Discussion
a-c) The project is located in the service area of the City of Redlands Fire Department.

The Fire Department responds to medical emergencies, hazardous materials incidents, rescue calls, and motor-related accidents, in addition to regular fire suppression services. There are four stations in Redlands:
• Fire Station 261: 525 E Citrus Ave.
• Fire Station 262: 1690 Garden St.
• Fire Station 263: 10 W Pennsylvania Ave.
• Fire Station 264: 1270 W Park Ave.

The nearest fire station to the project site is Station 263, located approximately one mile directly east of the project site off Pennsylvania Avenue. The project may create an incremental increase in demand for fire services. To offset any incremental demand in fire protection and emergency medical services, development impact fees are collected at the time of building permit issuance for approved projects. The project as proposed is a mixed-use development that will incorporate 460 multi-family residential units with approximately 17,899 square feet of commercial space. developments and commercial. Fees would be charged at a rate of $528.21 per multi-family dwelling unit, and $69.89 per 1,000 square feet of commercial space, and would go towards fire facilities and staffing. Impacts related to expansion of fire protection services would be less than significant with payment of fees.

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Issues and Supporting Information Sources: Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

5. POLICE SERVICES.

Would the proposal result in:
a) Requiring police services that are beyond the
current capabilities of the Police Department? 
b) An increase in response time for essential police
services to the remainder of the community? 
c) The need for additional police facilities or
equipment?
d) Increase in crime as a result of the
type of business?




_
Police Services – Discussion
a-d) The City of Redlands Police Department will provide services to the project site. The Police Department contains an Operations Division and an Investigations and Support Services Division. In addition to sworn patrol officers, the Department has several sub-units, including Investigations, the Multiple Enforcement Team, Narcotics, and volunteers. Police services are generally financed through the General Fund. The project will pay Development Impact Fees, which have been established by the City to fund public facilities, including police. The project and its future residents will also provide additional revenue to the City resulting from increased property tax assessment revenue, which will assist in funding police operations. Additionally, the project will be required to provide and implement a site security plan during grading and construction to ensure that impacts from construction site theft are kept at a less than significant level.. Less than significant impacts are anticipated, and no special mitigation measures are required.

Redlands Regular Meeting of 12-03-24 457 of 875
Issues and Supporting Information Sources:

Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

6. DOWNTOWN IMPACTS.

Would the proposal result in:
a) A reduction of the number or types of businesses
located in the downtown? 
b) An unfair or unreasonable competitive disadvantage
to existing businesses downtown?

c) Creation of vacant buildings and the potential for
blight?
d) Cause an unreasonable increase in
traffic downtown?
e) Economic and social effects of
businesses competing with downtown
businesses?




Downtown Impacts – Discussion
a-e) The proposed project includes a mixed-use development located approximately 1.5 miles to the north of the downtown area of the City and does not have the potential to detrimentally affect the Downtown Business District. The future residents of this project may patronize the downtown area and provide an additional source of revenue to the Downtown Business District.

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Issues and Supporting Information Sources:

Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

7. RESIDENTIAL DESIGN.

Would the proposal:
a) Conflict with existing codes and or standards?
 __
b) Meet minimum point standards of the Residential
Development Allocation process? _
Residential Design– Discussion
a) Upon City Council approval of the Density Bonus Agreement accompanying the project, the proposed project will comply with the applicable provisions of the Redlands Municipal Code, including Title 18 (Zoning Regulations) and Title 15 (Buildings and Construction). The proposed project includes residential dwelling units (apartments) and commercial uses. The buildings are designed with highquality architecture and building materials. Conditions of approval are included in the project for the plan check process (subsequent to entitlement), which will ensure compliance. No impacts are anticipated in terms of conflicts with existing codes and standards.
b) Due to current State law (SB 330 known as the “Housing Crisis Act of 2019”), residential projects and residential subdivisions are not evaluated by a point system or the standards of the Residential Development Allocation process. SB 330 prohibits annual limits on the number of permits issued for the approval and construction of housing during any one year. City Council Resolution No. 8082 suspended certain provisions of RMC Chapter 19.04 relating to the competitive evaluation of residential development projects as long as the State law remain in effect.

Redlands Regular Meeting of 12-03-24 459 of 875
Issues and Supporting Information Sources: Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

8. CULTURAL FACILITIES.

Would the proposal result in:
a) Impacts to an historic residential structure,
neighborhood, or district?

b) Impacts to an historic commercial structure or
district?

c) Impacts to cultural facilities such as the Smiley
Library, Redlands Bowl, Lincoln Shrine, Joslyn
Center, Community Center, etc?

d) Have the potential to cause a physical change which
would affect unique ethnic cultural values?

e) Potential to disturb existing religious facilities.
f) Impact or restrict religious or sacred uses.



Cultural Facilities – Discussion
a, b) There are no historic residential or commercial structures on the project site, nor is the project site located within a historic district. No impacts are anticipated. c) The project will ultimately result in the construction of 460 apartment units and 18,000 square feet of commercial space, and would not impact cultural facilities such as the Smiley Library, Redlands Bowl, Lincoln Shrine, Joslyn Center, Community Center, etc. The development will provide revenue to the City through increased property tax assessment generated by the future homes which may assist in the operation of some cultural facilities. Thus, the project will not have an adverse impact to cultural facilities.
d) No part of this project has the potential to affect unique ethnic cultural values. No impacts are anticipated.
e, f) No part of this project has the potential to affect existing religious facilities, or impact or otherwise restrict any religious or sacred uses or activities. Tribal cultural resources are addressed separately in the Mitigated Negative Declaration. No impacts are anticipated.

Redlands Regular Meeting of 12-03-24 460 of 875
Issues and Supporting Information Sources: Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
,
No
Impact

9. PARK FACILITIES & RECREATIONAL PROGRAMS.

Will the proposal result in:
a) Increases in use or demand for park facilities or
programs to include manpower, facilities or
equipment?

b) A ratio of parkland to population which exceeds
standards and or goals established by the General
Plan?

Park Facilities & Recreational Programs – Discussion
a, b) The current standard for the City of Redlands parkland and open recreational space is 5.0 acres per 1,000 residents. The project is expected to generate new residents, which could cause an increase in the use of parkland in Redlands.

General Plan buildout would create a demand for 55 acres of new parkland at the standard ratio of 5 acres per 1,000 residents (City of Redlands, 2017). The project will pay all associated development impact fees in relation to parks.

Additionally, the project is part of a development with significant recreational amenities for the residents on site, including a clubhouse with gym, yoga and Pilates studio, and game room, as well as outdoor recreational amenities, including an outdoor swimming pool, hot tub, an outdoor fireplace, a walking trail, and an outdoor lounge and BBQ area. These amenities, as well as the payment of development impact fees, could serve to reduce impacts on public recreational amenities. Because the project would be consistent with Redlands General Plan 2035 buildout, development of park facilities would accommodate the anticipated increase in population, and impacts to parks would be less than significant.

Redlands Regular Meeting of 12-03-24 461 of 875
Issues and Supporting Information Sources: Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

10. LAND USE COMPATIBILITY. Would the proposal result in:
a) Land uses that are not compatible or consistent with the General Plan?

b) Economic impacts on businesses and
small property owners from a project
c) Physical separation or division of an
existing community
d) Loss of jobs for the community?
e) Overcrowding of housing?





Land Use Compatibility – Discussion
a) The Commercial land use category designates areas for the development of a wide range of commercial uses, including neighborhood-serving stores and convenience centers, regional commercial centers, and commercial recreation. Sites with this designation may be developed with a stand-alone commercial use, two or more commercial uses, or mixed uses. The Commercial land use category may permit residential and mixed uses consistent with the underlying zoning district. The mixed uses proposed by the project are consistent with the General Plan designation. b) The design of the project includes a use and density consistent with future nearby residential development. The commercial uses proposed are limited in scale and which not create an economic impact related to local businesses or small properties.

No detrimental economic impacts on businesses or small property owners are anticipated.
c) The project site is located in an areas that is surrounded by vacant land with anticipated development in the near future. There is no existing community to divide in the immediate area. The project will continue the trend of anticipated multiplefamily residential uses in the area and in no way will physically divide or separate the existing community. No impacts are anticipated.
d) The proposed project would be consistent with the General Plan Land Use Designation. This type of development is consistent with the expected transition of the surrounding area to residential and commercial use. The eventual construction Redlands Regular Meeting of 12-03-24 462 of 875
of the project will create jobs, which will not result in the loss of jobs to the community. No impacts are anticipated.
e) The project does not have the potential to result in overcrowding of the current housing stock within the City. The project will construct up to 460 residential units with provisions to include up to 20 apartments for Very Low-Income Families and is anticipated to fill a demand for additional housing stock within the City as identified by the Housing Element.

Issues and Supporting Information Sources: Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

11. SCHOOLS. Would the proposal result in:
a) Creating an overcapacity in schools? 
b) The need for additional school facilities or
equipment?
c) Land uses not consistent with or
compatible with existing educational
facilities in community?
d) Social or academic impacts on
students resulting from school
closures.





Schools – Discussion
a-d) The project proposes construction of a mixed-use development incorporating 460 apartment units with approximately 17,899 square feet of commercial space, and is anticipated to lead to a population growth of approximately 1,339 persons (See Threshold 4.14a above). This growth will most likely have a direct growth on the student population of the Redlands Unified School District. To offset this impact, payment of development impact fees towards the cost of increased demand of school district facilities is required under State law. The Redlands Unified School District has established a school fee and charge a current rate of $4.79 per square foot of “assessable space” (space within the perimeter of a residential structure) within new residential construction. Additionally, the District charges a rate of $0.78 per square foot of commercial/industrial space. Payment of these development impact fees would offset any project impacts on school facilities. As such, impacts would be less than significant.

Redlands Regular Meeting of 12-03-24 463 of 875
TABLE 1
CITY OF REDLANDS : MODEL
LAND USE SUMMARY:

FISCAL IMPACT ANALYSIS
YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 LAND USE 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 TOTAL

RESIDENTIAL UNITS
RURAL LIVING (0.2 - 0.4 du/acre) 00000000000
VERY-LOW-DENSITY RESIDENTIAL (0 - 2.7 du/acre) 00000000000 LOW-DENSITY RESIDENTIAL (0 - 6.0 du/acre) 00000000000 DEVELOPER LOW-MEDIUM-DENSITY RESIDENTIAL (0 - 8.0 du/acre) 00000000000 MEDIUM-DENSITY RESIDENTIAL (0 - 15.0 du/acre) 00000000000 HIGH DENSITY (0 - 27.0 du/acre) 225 0235 0 0 0 0 0 0 0460 TOTAL, RESIDENTIAL UNITS 225 0 235 0 0 0 0 0 0 0 460
CUMULATIVE, RESIDENTIAL UNITS 225 225 460 460 460 460 460 460 460 460 NA PROJECT RESIDENTS /1
RURAL LIVING (0.4 - 0.2 du/acre) 00000000000
VERY-LOW-DENSITY RESIDENTIAL (0 - 2.7 du/acre) 00000000000 LOW-DENSITY RESIDENTIAL (0 - 6.0 du/acre) 00000000000
LOW-MEDIUM-DENSITY RESIDENTIAL (0 - 8.0 du/acre) 00000000000 MEDIUM-DENSITY RESIDENTIAL (0 - 15.0 du/acre) 00000000000 HIGH DENSITY (0 - 27 du/acre) 630 0 658 0 0 0 0 0 0 0 1,288 TOTAL, PROJECT RESIDENTS 630 0 658 0000000 1,288
CUMULATIVE, PROJECT RESIDENTS 630 630 1,288 1,288 1,288 1,288 1,288 1,288 1,288 1,288 NA CUMULATIVE PROJECT ACREAGE /2
RURAL LIVING (0.4 - 0.2 du/acre) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 NA VERY-LOW-DENSITY RESIDENTIAL (0 - 2.7 du/acre) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 NA LOW-DENSITY RESIDENTIAL (0 - 6.0 du/acre) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 NA LOW-MEDIUM-DENSITY RESIDENTIAL (0 - 8.0 du/acre) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 NA MEDIUM-DENSITY RESIDENTIAL (0 - 15.0 du/acre) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 NA HIGH DENSITY (0 - 27 du/acre) 6.59 6.59 13.48 13.48 13.48 13.48 13.48 13.48 13.48 13.48 NA CUMULATIVE, PROJECT ACREAGE 6.59 6.59 13.48 13.48 13.48 13.48 13.48 13.48 13.48 13.48 NA LAND NON-RESIDENTIAL ACRES, ANNUAL /3
RETAIL 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5
INDUSTRIAL 0.0 0 0 0 0 0 0 0 0 00.0
OTHER NON-RESIDENTIAL 0 0 0 0 0 0 0 0 0 00.0
ANNUAL TOTAL, NON-RESIDENTIAL 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5

LAND NON-RESIDENTIAL ACRES, CUMULATIVE
RETAIL 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 NA
INDUSTRIAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 NA
OTHER NON-RESIDENTIAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 NA CUMULATIVE TOTAL, NON-RESIDENTIAL 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 NA LAND NON-RESIDENTIAL EDU'S, CUMULATIVE /4
RETAIL 3.0 3.0 3.0 3.0 3.0 3.0 3.0 3.0 3.0 3.0 NA
INDUSTRIAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 NA
OTHER NON-RESIDENTIAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 NA CUMULATIVE TOTAL, NON-RESIDENTIAL EDU'S 3.0 3.0 3.0 3.0 3.0 3.0 3.0 3.0 3.0 3.0 NA BUILDING NON-RESIDENTIAL SQ.FT., ANNUAL
RETAIL 18,000 000000000 18,000
INDUSTRIAL 00000000 00
OTHER NON-RESIDENTIAL 0000000000
ANNUAL TOTAL, NON-RESIDENTIAL 18,000 000000000 18,000
BUILDING NON-RESIDENTIAL SQ.FT., CUMULATIVE
RETAIL 18,000 18,000 18,000 18,000 18,000 18,000 18,000 18,000 18,000 18,000 NA INDUSTRIAL 0 0 0 0 0 0 0 0 0 0NA
OTHER NON-RESIDENTIAL 0 0 0 0 0 0 0 0 0 0 NA
CUMULATIVE TOTAL, NON-RESIDENTIAL 18,000 18,000 18,000 18,000 18,000 18,000 18,000 18,000 18,000 18,000 NA SHADED CELLS ARE VARIABLE ASSUMPTIONS OR INPUTS UNIQUE TO THE PROJECT.

NOTES:

1. Average number of residents per Dwelling Unit ("DU") provided by the California Department of Finance. 3. Assumes average non-residential site coverage of the following (based on the General Plan):

Residents per DU = 2.801 OTHER Retail 20.0%
Industrial 0.0%

2. Assumes residential acreage per unit of the following: Other Non-Residential 0.0% DEVELOPER Rural Living (less than 0.2 - 0.4 du/acre) NA
Very-Low-Density Residential (0 - 2.7 du/acre) N/A
Low-Density Residential (0 - 6.0 du/acre) NA 4. Assumes non-residential equivalent dwelling units of the following:

Low-Medium-Density Residential (0 - 8.0 du/acre) NA DEVELOPER EDUs per acre = 6.0 OTHER Medium-Density Residential (0 - 15.0 du/acre) 0.00
High Density (0 - 27.0 du/acre) 0.03 GENERAL PLAN BUILDOUTPROJ. Sq. Ft.* F.A.R.* Projected Acreage RETAIL 8,646,200 0.30 661.63
INDUSTRIAL 10,048,400 0.40 576.70 OTHER
OTHER NON-RESIDENTIA 21,641,990 0.45 1,104.07
40,336,590 2,342.40
*As disclosed in the General Plan
Typical Home Size: 2,682 OTHER
Estimated Equivalency: 6.42
Redlands Regular Meeting of 12-03-24 464 of 875
TABLE 2
CITY OF REDLANDS : MODEL
LAND USE SUMMARY:

FISCAL IMPACT ANALYSIS

ASSESSED VALUATION ASSUMPTIONS SECURED PROPERTY TAX ASSUMPTIONS RESIDENTIAL NET APPORTIONMENT FACTORS AS A FRACTION OF 1.0% TAX RATE RURAL LIVING ASSESSED VALUE $0
VERY-LOW-DENSITY ASSESSED VALUE $0 PROPERTY TAXES PASSED THROUGH TO CITY /1 20.00% CITY LOW-DENSITY ASSESSED VALUE $0 DEVELOPER
LOW-MEDIUM-DENSITY ASSESSED VALUE $0 1. Based on amount disclosed in the adopted 1998-99 budget.

MEDIUM-DENSITY ASSESSED VALUE $0
HIGH DENSITY ASSESSED VALUE $421,739

NON-RESIDENTIAL UNSECURED PROPERTY TAX ASSUMPTIONS
RETAIL ASSESSED VALUE $333.00
INDUSTRIAL ASSESSED VALUE $0.00 RESIDENTIAL:

OTHER NON-RESIDENTIAL ASSESSED VALUE N/A DEVELOPER UNSECURED TAXES AS A % OF SECURED 2.75% CITY NON-RESIDENTIAL:

UNSECURED TAXES AS A % OF SECURED 10.00%
YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 SECURED ASSESSED VALUE CALCULATION:

ANNUAL ASSESSED VALUES (YEARLY INCREASE)

RESIDENTIAL
RURAL LIVING $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
VERY-LOW-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 LOW-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
LOW-MEDIUM-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MEDIUM-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 HIGH DENSITY RESIDENTIAL $94,891 $0 $99,109 $0 $0 $0 $0 $0 $0 $0 TOTAL RESIDENTIAL $94,891 $0 $99,109 $0 $0 $0 $0 $0 $0 $0

NON-RESIDENTIAL
RETAIL $5,994 $0 $0 $0 $0 $0 $0 $0 $0 $0
INDUSTRIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
OTHER NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL NON-RESIDENTIAL $5,994 $0 $0 $0 $0 $0 $0 $0 $0 $0 TOTAL YEARLY VALUATION INCREASE: $100,885 $0 $99,109 $0 $0 $0 $0 $0 $0 $0

CUMULATIVE ASSESSED VALUES

RESIDENTIAL
RURAL LIVING $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
VERY-LOW-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 LOW-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
LOW-MEDIUM-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MEDIUM-DENSITY RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 HIGH DENSITY RESIDENTIAL $94,891 $94,891 $194,000 $194,000 $194,000 $194,000 $194,000 $194,000 $194,000 $194,000 TOTAL RESIDENTIAL $94,891 $94,891 $194,000 $194,000 $194,000 $194,000 $194,000 $194,000 $194,000 $194,000

NON-RESIDENTIAL
RETAIL $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 INDUSTRIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
OTHER NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL NON-RESIDENTIAL $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 $5,994 TOTAL CUMULATIVE ASSESSED VALUE $100,885 $100,885 $199,994 $199,994 $199,994 $199,994 $199,994 $199,994 $199,994 $199,994 SECURED PROPERTY TAX REVENUE CALCULATION:

CITY OF REDLANDS
RESIDENTIAL $190 $190 $388 $388 $388 $388 $388 $388 $388 $388 NON-RESIDENTIAL $12 $12 $12 $12 $12 $12 $12 $12 $12 $12 TOTAL SECURED TAX REVENUES TO CITY $202 $202 $400 $400 $400 $400 $400 $400 $400 $400 UNSECURED PROPERTY TAX REVENUE CALCULATION:

CITY OF REDLANDS
RESIDENTIAL $5 $5 $11 $11 $11 $11 $11 $11 $11 $11
NON-RESIDENTIAL $1 $1 $1 $1 $1 $1 $1 $1 $1 $1
TOTAL UNSECURED TAX REVENUES TO CITY $6 $6 $12 $12 $12 $12 $12 $12 $12 $12 TOTAL PROPERTY TAXES TO CITY $208 $208 $412 $412 $412 $412 $412 $412 $412 $412 Redlands Regular Meeting of 12-03-24 465 of 875
TABLE 3
CITY OF REDLANDS : MODEL
LAND USE SUMMARY:

FISCAL IMPACT ANALYSIS

RESIDENTIAL INDIRECT SALES TAX GENERATION ASSUMPTIONS BUSINESS DIRECT SALES & USE TAX GENERATION ASSUMPTIONS PROPERTY TRANSFER TAX ASSUMPTIONS AVERAGE HOUSEHOLD INCOME ASSUMPTIONS: SALES TAXES PASSED THROUGH TO CITY, APPLIED TO COSTS: /1 1.00% CITY RESIDENTIAL PROPERTY TURNOVER RATE 10.00% CITY MEASURE 'I' TAXES PASSED THROUGH TO TRANSIT AUTHORITY 0.00% BUS & COM PROPERTY TURNOVER RATE 5.00% WEIGHTED AVERAGE RESIDENTIAL PRICE $421,739 LOCAL TRANSPORTATION SALES TAXES 0.00% TRANSFER TAX AS A % OF RESALE DOLLAR 0.11% AVERAGE RESIDENTIAL MORTGAGE (20% DOWN) $337,391 DISPLACED EXISTING CITY SALES TAX 33.33% PROPERTY TRANSFER TAX PASSED THROUGH TO CITY 50.00% ANNUAL MORTGAGE PAYMENTS @ 6.50% & 30 YEARS $25,591 CITY PROJECT RETAIL TAXABLE SALES PER SQ. FT:

AVG. HOUSEHOLD INCOME (3:1 INCOME/PAYMENT RATIO): $76,772 RETAIL $300.00 RETAIL TAXABLE EXPENDITURE (% OF INCOME): 25.0% INDUSTRIAL $0.00 PROJECT RESIDENTS' PURCHASES OUTSIDE PROJECT 50.0% OTHER NON-RESIDENTIAL 0 AND WITHIN INCORPORATED CITY:

1. Based on amount passed through to city in the adopted 1997-98 budget.

YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 SALES & USE TAX REVENUE CALCULATION (CUMULATIVE):

INDIRECT SALES TAX GENERATION
RESIDENTIAL TAXABLE EXPENDITURES $4,318 $4,318 $8,829 $8,829 $8,829 $8,829 $8,829 $8,829 $8,829 $8,829 TOTAL TAXABLE PURCHASES WITHIN CITY $2,159 $2,159 $4,414 $4,414 $4,414 $4,414 $4,414 $4,414 $4,414 $4,414 RESIDENTIAL SALES TAX GENERATION $22 $22 $44 $44 $44 $44 $44 $44 $44 $44

DIRECT SALES TAX GENERATION
RETAIL TAXABLE SALES $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 INDUSTRIAL TAXABLE SALES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
OTHER NON-RESIDENTIAL TAXABLE SALES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 SUB-TOTAL DIRECT TAXABLE SALES $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 $5,400 LESS: DISPLACED EXISTING CITY SALES TAX $1,800 $1,800 $1,800 $1,800 $1,800 $1,800 $1,800 $1,800 $1,800 $1,800 TOTAL DIRECT TAXABLE SALES $3,600 $3,600 $3,600 $3,600 $3,600 $3,600 $3,600 $3,600 $3,600 $3,600 TOTAL DIRECT SALES TAX GENERATION $36 $36 $36 $36 $36 $36 $36 $36 $36 $36 TOTAL PROJECT SALES & USE TAX REVENUES, APPLIED TO COSTS $58 $58 $80 $80 $80 $80 $80 $80 $80 $80 RESIDENTIAL MEASURE 'I' SALES TAXES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 NON-RESIDENTIAL MEASURE 'I' SALES TAXES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 RESIDENTIAL LOCAL TRANSPORTATION SALES TAXES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 NON-RESIDENTIAL LOCAL TRANSPORTATION SALES TAXES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 TOTAL PROJECT SALES & USE TAX REVENUES, FOR TRANSPORTATION $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 PROPERTY TRANSFER TAX CALCULATION (CUMULATIVE):

RESIDENTIAL PROPERTY TRANSFER TAXES $5.22 $5.22 $10.67 $10.67 $10.67 $10.67 $10.67 $10.67 $10.67 $10.67 NON-RESIDENTIAL PROPERTY TRANSFER T AXES $0.16 $0.16 $0.16 $0.16 $0.16 $0.16 $0.16 $0.16 $0.16 $0.16 TOTAL ANNUAL PROPERTY TRANSFER TAXES $5 $5 $11 $11 $11 $11 $11 $11 $11 $11 SHADED CELLS ARE VARIABLE ASSUMPTIONS OR INPUTS UNIQUE TO THE PROJECT.

Redlands Regular Meeting of 12-03-24 466 of 875
TABLE 4
CITY OF REDLANDS : MODEL
LAND USE SUMMARY:

FISCAL IMPACT ANALYSIS

BUSINESS LICENSE FEE REVENUE FRANCHISE FEES (PER CAPITA) TRANSIENT OCCUPANCY TAX

RESIDENTIAL NA RESIDENTIAL NON-RESIDENTIAL NUMBER OF AVAILABLE HOTEL ROOMS NON-RESIDENTIAL TOTAL FRANCHISE $16.71 $16.71 OCCUPANCY RATE

BUSINESS LICENSE FEES ARE CHARGED AT A RATE EQUAL AVERAGE BILLING RATE PER ROOM TO $12 FOR THE FIRST $5,000 IN GROSS SALES, PLUS $3 % PASSED THROUGH TO CITY FOR EACH ADDITIONAL $5,000 INCREMENT IN GROSS SALES. AVERAGE YEARLY OCCUPANCY REVENUES TO CITY YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034

BUSINESS LICENSE FEE REVENUE

RESIDENTIAL

RURAL LIVING NA NA NA NA NA NA NA NA NA NA

VERY-LOW-DENSITY RESIDENTIAL NA NA NA NA NA NA NA NA NA NA

LOW-DENSITY RESIDENTIAL NA NA NA NA NA NA NA NA NA NA

LOW-MEDIUM-DENSITY RESIDENTIAL NA NA NA NA NA NA NA NA NA NA

MEDIUM-DENSITY RESIDENTIAL NA NA NA NA NA NA NA NA NA NA

HIGH DENSITY RESIDENTIAL NA NA NA NA NA NA NA NA NA NA

TOTAL RESIDENTIAL NA NA NA NA NA NA NA NA NA NA

NON-RESIDENTIAL
RETAIL $3 $3 $3 $3 $3 $3 $3 $3 $3 $3
INDUSTRIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
OTHER NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL NON-RESIDENTIAL $3 $3 $3 $3 $3 $3 $3 $3 $3 $3
TOTAL, BUSINESS LICENSE FEE REVENUE $3 $3 $3 $3 $3 $3 $3 $3 $3 $3

FRANCHISE FEE REVENUE
RESIDENTIAL FRANCHISE FEES $10.532 $10.532 $21.532 $21.532 $21.532 $21.532 $21.532 $21.532 $21.532 $21.532 NON-RESIDENTIAL FRANCHISE FEES $0.050 $0.050 $0.050 $0.050 $0.050 $0.050 $0.050 $0.050 $0.050 $0.050 TOTAL, FRANCHISE FEE REVENUE $11 $11 $22 $22 $22 $22 $22 $22 $22 $22

TRANSIENT OCCUPANCY TAX REVENUE
TOTAL, TRANSIENT OCCUPANCY TAX REVENUE $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 SHADED CELLS ARE VARIABLE ASSUMPTIONS OR INPUTS UNIQUE TO THE PROJECT.

Redlands Regular Meeting of 12-03-24 467 of 875
TABLE 5
CITY OF REDLANDS : MODEL

OTHER REVENUE AND REVENUE SUMMARY

FISCAL IMPACT ANALYSIS
OTHER GENERAL REVENUES (PER CAPITA METHOD) /1 INCOME FROM INVESTMENTS OTHER TAXES /2 $10.86 EFFECTIVE INTEREST 2.50% OTHER
OTHER REVENUES $6.96

COMMUNITY DEVELOPMENT NA

LIBRARY NA

POLICE DEPARTMENT NA

POLICE - ANIMAL CONTROL NA

POLICE - RECREATION NA

POLICE - SENIOR SERVICES NA

FIRE NA

PUBLIC WORKS NA
SUBTOTAL, OTHER REVENUES PER CAPITA: $17.83

1. See Appendix for calculation of per capita multipliers. For items without values, a net cost technique is being employed.

2. Other Taxes includes Public Safety Sales Tax.

YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034

PER CAPITA REVENUES

OTHER TAXES
RESIDENTIAL $7 $7 $14 $14 $14 $14 $14 $14 $14 $14
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, OTHER TAXES $7 $7 $14 $14 $14 $14 $14 $14 $14 $14

OTHER REVENUES
RESIDENTIAL $4 $4 $9 $9 $9 $9 $9 $9 $9 $9
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, OTHER LICENSES, PERMITS & FINES $4 $4 $9 $9 $9 $9 $9 $9 $9 $9

COMMUNITY DEVELOPMENT
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, STATE REVENUES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

LIBRARY
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, FEDERAL REVENUES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

POLICE DEPARTMENT
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, CITY ATTORNEY $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

POLICE - ANIMAL CONTROL
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, ENGINEERING SERVICES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

POLICE - RECREATION
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, FIRE DEPARTMENT $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

POLICE - SENIOR SERVICES
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, JOSLYN CENTER $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
FIRE
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, LIBRARY $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

PUBLIC WORKS
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL, PARKS $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
TOTAL RESIDENTIAL PER CAPITA REVENUES $11 $11 $23 $23 $23 $23 $23 $23 $23 $23 TOTAL NON-RESIDENTIAL PER CAPITA REVENUES $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 TOTAL PER CAPITA REVENUES $11 $11 $23 $23 $23 $23 $23 $23 $23 $23 TOTAL RESIDENTIAL CASE STUDY REVENUES $232 $232 $475 $475 $475 $475 $475 $475 $475 $475 TOTAL NON-RESIDENTIAL CASE STUDY REVENUES $53 $53 $53 $53 $53 $53 $53 $53 $53 $53 TOTAL CASE STUDY REVENUES $285 $285 $528 $528 $528 $528 $528 $528 $528 $528 RESIDENTIAL REV AVAILABLE FOR INV. INCOME $244 $244 $498 $498 $498 $498 $498 $498 $498 $498 NON-RESIDENTIAL REV AVAILABLE FOR INV. INCOME $53 $53 $53 $53 $53 $53 $53 $53 $53 $53 TOTAL REVENUES AVAILABLE FOR INVESTMENT INCOME $296 $296 $551 $551 $551 $551 $551 $551 $551 $551 RESIDENTIAL INVESTMENT INCOME $6 $6 $12 $12 $12 $12 $12 $12 $12 $12 NON-RESIDENTIAL INVESTMENT INCOME $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 TOTAL INVESTMENT INCOME $7 $7 $14 $14 $14 $14 $14 $14 $14 $14 SHADED CELLS ARE VARIABLE ASSUMPTIONS OR INPUTS UNIQUE TO THE PROJECT.

Redlands Regular Meeting of 12-03-24 468 of 875
TABLE 6
CITY OF REDLANDS : MODEL

POLICE DEPARTMENT, FIRE DEPARTMENT, PUBLIC WORKS & PER CAPITA COSTS

FISCAL IMPACT ANALYSIS

POLICE DEPARTMENT COSTS
RESIDENTIAL CALLS 16,562 CITY
COST PER DWELLING UNIT $295
NON-RESIDENTIAL RETAIL CALLS 8,987
COST PER BUILDING SQUARE FOOT $0.47
NON-RESIDENTIAL INDUSTRIAL CALLS 344
COST PER BUILDING SQUARE FOOT $0.02
OTHER NON-RESIDENTIAL CALLS 7,948
COST PER BUILDING SQUARE FOOT $0.42
MISCELLANEOUS CALLS /2 17,628
TOTAL CALLS 51,469

1. Based on Net Cost and number of calls to residential or non-residential properties.

2. Based on conversations with the Police Chief, these incidences are not related to residences or businesses in the City.

EXISTING DWELLING UNITS 25,984 CITY
EXISTING NON-RESIDENTIAL SQUARE FOOTAGE 8,824,690
RESIDENTIAL FIRE DEPARTMENT COSTS [1]
RESIDENTIAL CALLS 3,579 CITY
COST PER DWELLING UNIT $168
NON-RESIDENTIAL RETAIL CALLS 446
COST PER BUILDING SQUARE FOOT $0.06
NON-RESIDENTIAL INDUSTRIAL CALLS 155
COST PER BUILDING SQUARE FOOT $0.02
OTHER NON-RESIDENTIAL CALLS 1,459
COST PER BUILDING SQUARE FOOT $0.20
MISCELLANEOUS CALLS /2 1,988
TOTAL CALLS 7,627

1. Based on Net Cost and number of calls to residential or non-residential properties.

2. Based on information from Fire Chief, these incidences are not related to residences or businesses in the City.

PUBLIC INFRASTRUCTURE REQUIREMENTS /1 PUBLIC WORKS MAINTENANCE COSTS ROADS (LANE MILES) 0.0 DEVELOPER PAVEMENT MAINTENANCE PER LANE MILE /1 $5,000 CITY TRAFFIC INTERSECTIONS REQUIRING SIGNALS 0.4 STREET SWEEPING PER CURB MILE - ALL STREETS /1 $9 AGGREGATE LANDSCAPING (ACRES) 0.0 TRAFFIC SIGNAL OPERATIONS & MAINTENANCE PER INTERSECTION /1 $5,560 PARK ACREAGE (GROSS) 0.0 LANDSCAPE MAINTENANCE PER ACRE /1 $12,500 STREET LIGHTS 7.0 PARK MAINTENANCE PER ACRE /1 $7,000
OPEN SPACE (ACRES) 0.0 STREET LIGHT MAINTENANCE COST PER LIGHT /1 $125 TRAILS (LINEAL MILE) 0.0 OPEN SPACE MAINTENANCE PER ACRE /2 $125 STORM DRAINS (MILES) 0.0 TRAIL MAINTENANCE PER LINEAL MILE /2 $500 STORM DRAIN MAINTENANCE PER MILE /2 $750

1. Infrastructure should exclude privately maintained facilities.

1. Based on consultations with the City of Redlands Public Works Department.

2. Based on consultant's experience.

CITY GENERAL GOVERNMENT COSTS* CITY GENERAL GOVERNMENT COSTS CONTINUED CITY COUNCIL $174,090 TOTAL CITY OPERATING BUDGET* $49,046,241 CITY CLERK $285,939
CITY MANAGER $314,819 *Excludes Debt Service, Utilities and Capital Improvements.

FINANCE $605,155
CITY TREASURER $2,875,064 OVERHEAD AS A % OF OPERATING BUDGET 11.04% CITY ATTORNEY $1,159,167
TOTAL, CITY GENERAL GOVERNMENT COSTS $5,414,234 OVERHEAD AS A % OF DIRECT COSTS 12.41% *Costs have been reduced to reflect department specific revenues. OVERHEAD BY DEFINITION CAUSING NO COST 0.00% OVERHEAD AS % OF DIRECT, AVERAGE 6.20%
OTHER NET COSTS (PER CAPITA METHOD) /1
COMMUNITY DEVELOPMENT $29.49
LIBRARY $28.43

1. See Appendix for calculation of per capita multipliers.

YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034

CITY DIRECT COSTS

POLICE DEPARTMENT COSTS
RESIDENTIAL $66.376 $66.376 $135.701 $135.701 $135.701 $135.701 $135.701 $135.701 $135.701 $135.701 NON-RESIDENTIAL RETAIL $8.484 $8.484 $8.484 $8.484 $8.484 $8.484 $8.484 $8.484 $8.484 $8.484 NON-RESIDENTIAL INDUSTRIAL $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 OTHER NON-RESIDENTIAL $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 TOTAL, POLICE DEPARTMENT COSTS $74.860 $74.860 $144.185 $144.185 $144.185 $144.185 $144.185 $144.185 $144.185 $144.185

FIRE DEPARTMENT COSTS
RESIDENTIAL $37.842 $37.842 $77.367 $77.367 $77.367 $77.367 $77.367 $77.367 $77.367 $77.367 NON-RESIDENTIAL RETAIL $1.111 $1.111 $1.111 $1.111 $1.111 $1.111 $1.111 $1.111 $1.111 $1.111 NON-RESIDENTIAL INDUSTRIAL $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 OTHER NON-RESIDENTIAL $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 TOTAL, FIRE DEPARTMENT COSTS $38.953 $38.953 $78.478 $78.478 $78.478 $78.478 $78.478 $78.478 $78.478 $78.478

PUBLIC WORKS COSTS
PAVEMENT MAINTENANCE $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 STREET SWEEPING $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 TRAFFIC SIGNAL OPERATION $1.095 $1.095 $2.224 $2.224 $2.224 $2.224 $2.224 $2.224 $2.224 $2.224 LANDSCAPE MAINTENANCE $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 PARK MAINTENANCE $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 STREET LIGHT MAINTENANCE $0.431 $0.431 $0.875 $0.875 $0.875 $0.875 $0.875 $0.875 $0.875 $0.875 OPEN SPACE MAINTENANCE $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 TRAIL MAINTENANCE $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 STORM DRAIN MAINTENANCE $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 TOTAL, PUBLIC WORKS COSTS $1.526 $1.526 $3.099 $3.099 $3.099 $3.099 $3.099 $3.099 $3.099 $3.099

COMMUNITY DEVELOPMENT
RESIDENTIAL $18.584 $18.584 $37.994 $37.994 $37.994 $37.994 $37.994 $37.994 $37.994 $37.994 NON-RESIDENTIAL $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 TOTAL, COMMUNITY DEVELOPMENT $18.584 $18.584 $37.994 $37.994 $37.994 $37.994 $37.994 $37.994 $37.994 $37.994

LIBRARY
RESIDENTIAL $17.915 $17.915 $36.625 $36.625 $36.625 $36.625 $36.625 $36.625 $36.625 $36.625 NON-RESIDENTIAL $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 TOTAL, LIBRARY $17.915 $17.915 $36.625 $36.625 $36.625 $36.625 $36.625 $36.625 $36.625 $36.625

CITY DIRECT COSTS
RESIDENTIAL $104.380 $104.380 $213.400 $213.400 $213.400 $213.400 $213.400 $213.400 $213.400 $213.400 NON-RESIDENTIAL $66.396 $66.396 $135.721 $135.721 $135.721 $135.721 $135.721 $135.721 $135.721 $135.721 TOTAL, CITY DIRECT COSTS $170.776 $170.776 $349.121 $349.121 $349.121 $349.121 $349.121 $349.121 $349.121 $349.121

CITY GENERAL GOVERNMENT COSTS
RESIDENTIAL $6.476 $6.476 $13.240 $13.240 $13.240 $13.240 $13.240 $13.240 $13.240 $13.240 NON-RESIDENTIAL $4.119 $4.119 $8.421 $8.421 $8.421 $8.421 $8.421 $8.421 $8.421 $8.421 TOTAL, CITY GENERAL GOVERNMENT COSTS $10.596 $10.596 $21.661 $21.661 $21.661 $21.661 $21.661 $21.661 $21.661 $21.661 SHADED CELLS ARE VARIABLE ASSUMPTIONS OR INPUTS UNIQUE TO THE PROJECT.

Redlands Regular Meeting of 12-03-24 469 of 875
TABLE 7
CITY OF REDLANDS : MODEL

FISCAL IMPACT ANALYSIS DETAILED SUMMARY
YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 % FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 OF TOTAL

ONGOING REVENUES

SECURED PROPERTY TAXES
RESIDENTIAL $190 $190 $388 $388 $388 $388 $388 $388 $388 $388 68.75% NON-RESIDENTIAL $12 $12 $12 $12 $12 $12 $12 $12 $12 $12 2.12%

UNSECURED PROPERTY TAXES
RESIDENTIAL $5 $5 $11 $11 $11 $11 $11 $11 $11 $11 1.89% NON-RESIDENTIAL $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 0.21%

TRANSFER PROPERTY TAXES
RESIDENTIAL $5 $5 $11 $11 $11 $11 $11 $11 $11 $11 1.89% NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.03%

SALES TAXES
RESIDENTIAL $22 $22 $44 $44 $44 $44 $44 $44 $44 $44 7.82% NON-RESIDENTIAL $36 $36 $36 $36 $36 $36 $36 $36 $36 $36 6.38%

MEASURE 'I' SALES TAXES
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

LOCAL TRANSPORTATION SALES TAXES
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

TRANSIENT OCCUPANCY TAX
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

FRANCHISE FEE REVENUES
RESIDENTIAL $11 $11 $22 $22 $22 $22 $22 $22 $22 $22 3.82% NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.01%

BUSINESS LICENSE REVENUES
RESIDENTIAL NA NA NA NA NA NA NA NA NA NA 0.00%
NON-RESIDENTIAL $3 $3 $3 $3 $3 $3 $3 $3 $3 $3 0.58%

OTHER TAXES
RESIDENTIAL $7 $7 $14 $14 $14 $14 $14 $14 $14 $14 2.48% NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

OTHER REVENUES
RESIDENTIAL $4 $4 $9 $9 $9 $9 $9 $9 $9 $9 1.59%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

COMMUNITY DEVELOPMENT
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

LIBRARY
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

POLICE DEPARTMENT
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

POLICE - ANIMAL CONTROL
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

POLICE - RECREATION
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

POLICE - SENIOR SERVICES
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
FIRE
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

PUBLIC WORKS
RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

INVESTMENT INCOME REVENUES
RESIDENTIAL $6 $6 $12 $12 $12 $12 $12 $12 $12 $12 2.21% NON-RESIDENTIAL $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 0.23%
TOTAL RESIDENTIAL REVENUES $250 $250 $510 $510 $510 $510 $510 $510 $510 $510 90.44% TOTAL NON-RESIDENTIAL REVENUES $54 $54 $54 $54 $54 $54 $54 $54 $54 $54 9.56% TOTAL ON-GOING REVENUES $304 $304 $564 $564 $564 $564 $564 $564 $564 $564

ONGOING COSTS

POLICE DEPARTMENT COSTS
RESIDENTIAL $66 $66 $136 $136 $136 $136 $136 $136 $136 $136 42.14% NON-RESIDENTIAL $8 $8 $8 $8 $8 $8 $8 $8 $8 $8 2.63%

FIRE DEPARTMENT COSTS
RESIDENTIAL $38 $38 $77 $77 $77 $77 $77 $77 $77 $77 24.02% NON-RESIDENTIAL $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 0.34%

PUBLIC WORKS DEPARTMENT COST
RESIDENTIAL $2 $2 $3 $3 $3 $3 $3 $3 $3 $3 0.96%
NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.01%

GENERAL GOVERNMENT COSTS
RESIDENTIAL $6 $6 $13 $13 $13 $13 $13 $13 $13 $13 4.11% NON-RESIDENTIAL $4 $4 $8 $8 $8 $8 $8 $8 $8 $8 2.61%

COMMUNITY DEVELOPMENT COSTS
RESIDENTIAL $19 $19 $38 $38 $38 $38 $38 $38 $38 $38 11.80% NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%

LIBRARY COSTS
RESIDENTIAL $18 $18 $37 $37 $37 $37 $37 $37 $37 $37 11.37% NON-RESIDENTIAL $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 0.00%
TOTAL RESIDENTIAL COSTS $149 $149 $304 $304 $304 $304 $304 $304 $304 $304 94.40% TOTAL NON-RESIDENTIAL COSTS $14 $14 $18 $18 $18 $18 $18 $18 $18 $18 5.60% TOTAL ON-GOING COSTS $162 $162 $322 $322 $322 $322 $322 $322 $322 $322 ANNUAL RESIDENTIAL ONGOING SURPLUS/(DEFICIT) $101 $101 $206 $206 $206 $206 $206 $206 $206 $206 ANNUAL NON-RESIDENTIAL ONGOING SURPLUS/(DEFICIT) $40 $40 $36 $36 $36 $36 $36 $36 $36 $36 TOTAL ANNUAL ONGOING SURPLUS/(DEFICIT) $141 $141 $242 $242 $242 $242 $242 $242 $242 $242 ANNUAL RESIDENTIAL REVENUE/COST RATIO 1.68 1.68 1.68 1.68 1.68 1.68 1.68 1.68 1.68 1.68 ANNUAL NON-RESIDENTIAL REVENUE/COST RATIO 3.93 3.93 2.99 2.99 2.99 2.99 2.99 2.99 2.99 2.99 TOTAL ANNUAL REVENUE/COST RATIO 1.87 1.87 1.75 1.75 1.75 1.75 1.75 1.75 1.75 1.75 Redlands Regular Meeting of 12-03-24 470 of 875
TABLE 8a
LAND USE SUMMARY:

FISCAL IMPACT ANALYSIS SUMMARY (Residential Only))
YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034

ONGOING REVENUES
TOTAL RESIDENTIAL REVENUES $249.6681 $249.6681 $249.6681 $249.6681 $249.6681 $249.6681 $249.6681 $249.6681 $249.6681 $249.6681

ONGOING COSTS
TOTAL RESIDENTIAL COSTS $148.6989 $148.6989 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 ANNUAL RESIDENTIAL ONGOING SURPLUS/(DEFICIT) $100.9693 $100.9693 ($54.3384) ($54.3384) ($54.3384) ($54.3384) ($54.3384) ($54.3384) ($54.3384) ($54.3384) ANNUAL RESIDENTIAL REVENUE/COST RATIO 1.68 1.68 0.82 0.82 0.82 0.82 0.82 0.82 0.82 0.82 Redlands Regular Meeting of 12-03-24 471 of 875
TABLE 8b
LAND USE SUMMARY: FISCAL IMPACT ANALYSIS SUMMARY (Commercial Only) YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034ONGOING REVENUESTOTAL NON-RESIDENTIAL REVENUES $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670ONGOING COSTSTOTAL NON-RESIDENTIAL COSTS $13.7345 $13.7345 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357ANNUAL NON-RESIDENTIAL ONGOING SURPLUS/(DEFICIT) $40.2325 $40.2325 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313ANNUAL NON-RESIDENTIAL REVENUE/COST RATIO 3.93 3.93 2.99 2.99 2.99 2.99 2.99 2.99 2.99 2.99 Redlands Regular Meeting of 12-03-24 472 of 875
TABLE 8c
CITY OF REDLANDS : MODELFISCAL IMPACT ANALYSIS SUMMARY (MIXED) YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 % FISCAL YEAR ($s x1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 OF TOTALONGOING REVENUESTOTAL RESIDENTIAL REVENUES $249.6681 $249.6681 $510.4326 $510.4326 $510.4326 $510.4326 $510.4326 $510.4326 $510.4326 $510.4326 90.44%TOTAL NON-RESIDENTIAL REVENUES $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 $53.9670 9.56% TOTAL ON-GOING REVENUES $303.6352 $303.6352 $564.3997 $564.3997 $564.3997 $564.3997 $564.3997 $564.3997 $564.3997 $564.3997ONGOING COSTSTOTAL RESIDENTIAL COSTS $148.6989 $148.6989 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 $304.0066 94.40%TOTAL NON-RESIDENTIAL COSTS $13.7345 $13.7345 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357 $18.0357 5.60% TOTAL ON-GOING COSTS $162.4334 $162.4334 $322.0423 $322.0423 $322.0423 $322.0423 $322.0423 $322.0423 $322.0423 $322.0423ANNUAL RESIDENTIAL ONGOING SURPLUS/(DEFICIT) $100.9693 $100.9693 $206.4261 $206.4261 $206.4261 $206.4261 $206.4261 $206.4261 $206.4261 $206.4261ANNUAL NON-RESIDENTIAL ONGOING SURPLUS/(DEFICIT) $40.2325 $40.2325 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313 $35.9313 TOTAL ANNUAL ONGOING SURPLUS/(DEFICIT) $141.2018 $141.2018 $242.3574 $242.3574 $242.3574 $242.3574 $242.3574 $242.3574 $242.3574 $242.3574ANNUAL RESIDENTIAL REVENUE/COST RATIO 1.68 1.68 1.68 1.68 1.68 1.68 1.68 1.68 1.68 1.68ANNUAL NON-RESIDENTIAL REVENUE/COST RATIO 3.93 3.93 2.99 2.99 2.99 2.99 2.99 2.99 2.99 2.99TOTAL ANNUAL REVENUE/COST RATIO 1.87 1.87 1.75 1.75 1.75 1.75 1.75 1.75 1.75 1.75 Redlands Regular Meeting of 12-03-24 473 of 875
TABLE 9
CITY OF REDLANDS : MODELSCHOOL FEE MITIGATION (SB 50)FISCAL IMPACT ANALYSIS ELEMENTARY SCHOOL Capacity Acreage SBE 50 fees
SFD 0.2260 SCHOOL DIST Elementary 600 10 $5,200
MFA 0.1362 Middle School 1000 20 $5,500
DEVELOPER FEE REVENUE PER SINGLE FAMILY DETACHED UNIT /1 $3,113 Mobile Home 0.1068 High School 2200 50 $7,200DEVELOPER FEE REVENUE PER MULTI-FAMILY ATTACHED UNIT /2 $1,431 MIDDLE SCHOOL DEVELOPER FEE REVENUE PER MOBILE HOME /3 $1,212 SFD 0.1310 MFA 0.0574 Mobile Home 0.0548
HIGH SCHOOL SFD 0.1690 MFA 0.0565 Mobile Home 0.0493
YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 YEAR 7 YEAR 8 YEAR 9 YEAR 10 TOTAL FISCAL YEAR ($s ×1,000) end of: 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 CITY OF REDLANDS ANNUAL PROJECTED RESIDENTIAL DEVELOPMENT SFD 0000000 0000 DEVELOPER MFA 225 0235 0 0 0 0 0 0 0460 Mobile Home 0000000 0000

STUDENT PROJECTIONS ELEMENTARY
SFD 0000000 0000 MFA 30.645 0 32.007 0 0 0 0 0 0 063
Mobile Home 0000000 0000
MIDDLE SCHOOL SFD 0 0 0 0 0 0 0 0 0 0 0 MFA 12.915 0 13.489 0 0 0 0 0 0 0 26 Mobile Home 0000000 0000 HIGH SCHOOL SFD 0 0 0 0 0 0 0 0 0 0 0 MFA 12.7125 0 13.2775 0 0 0 0 0 0 026 Mobile Home 0000000 0000

ANNUAL SCHOOL FEE MITIGATION
ELEMENTARY SFD $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
MFA $159,354 $0 $166,436 $0 $0 $0 $0 $0 $0 $0
Mobile Home $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
Total $325,790
MIDDLE SCHOOL SFD $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MFA $71,033 $0 $74,190 $0 $0 $0 $0 $0 $0 $0 Mobile Home $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
Total $145,222
HIGH SCHOOL SFD $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MFA $91,530 $0 $95,598 $0 $0 $0 $0 $0 $0 $0 Mobile Home $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
Total $187,128
TOTAL SCHOOL FEE MITIGATION SFD $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MFA $321,917 $0 $336,224 $0 $0 $0 $0 $0 $0 $0 $658,140 Mobile Home $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 TOTAL $321,917 $0 $336,224 $0 $0 $0 $0 $0 $0 $0

STUDENT GENERATION FACTORS

RESIDENTIAL SCHOOL FEE MITIGATION
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July 29, 2024
To: Sean Reilly, Principal Planner
City of Redlands Planning Department
35 Cajon Street, Suite 15-A
Redlands, California 92373
From: Cameron Hile, Senior Analyst
MIG, Inc. Planning and Environmental Services
1650 Spruce Street, Suite 106
Riverside, California 92507
Subject: Response to Comments on the Tennessee Village Mixed-Use Project Dear Mr. Reilly,
This letter is in response to comments submitted by Marjan R. Abubo of Lozeau Drury, LLP on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”), dated Tuesday May 28, 2024, regarding the Initial Study and Mitigated Negative Declaration (“IS/MND”) prepared for the proposed Tennessee Village Mixed-Use Project in the city of Redlands, California. The comments submitted by Mr. Abubo are included as Attachment 1 of this response letter. Provided below are our responses to Ms. Lenhardt’s comments. Based on the responses to comments provide below, no further analysis of impacts is required.

Comment 1. “There is Substantial Evidence of a Fair Argument that the Project May Have Significant Indoor Air Quality Impacts. Certified Industrial Hygienist, Francis Offermann, PE, CIH, conducted a review of the Project and relevant documents regarding the Project’s indoor air emissions and that Mr. Offermann concludes that the Project may expose future residents of the Project to significant health impacts related to indoor air quality, and in particular, emissions of the cancer-causing chemical formaldehyde. The Project’s emissions of formaldehyde to the air may result in very significant cancer risks to future residents of the Project’s residential units.

Mr. Offermann explains that many composite wood products typically used in home and apartment building construction contain formaldehyde-based glues which off-gas formaldehyde over a very long period. He states, “[t]he primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.” (Ex. A, p. 3.)
Formaldehyde is a known human carcinogen and is listed by the State as a toxic air contaminant (“TAC”). The South Coast Air Quality Management District (“SCAQMD”) has established a significance threshold of health risks for carcinogenic TACs of 10 in one million. (Ex. A, p. 3.) Mr. Offermann found that future residents of the Project’s residential units may be exposed to a cancer risk of 120 per million, even assuming all materials are compliant with the California Air Resources Board’s (“CARB”) formaldehyde airborne toxics control measure.

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(Ex. A, p. 4.) This is more than 12 times SCAQMD’s CEQA significance threshold of 10 per million and constitutes a potentially significant impact.

Mr. Offermann concludes that this significant environmental impact must be analyzed in an EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. (Ex. A, pp. 13-14.) He prescribes a methodology for estimating the Project’s formaldehyde emissions in order to do a more project-specific health risk assessment. (Id., pp. 9-10.). Mr. Offermann also suggests several feasible mitigation measures, such as requiring the use of noadded-formaldehyde composite wood products, which are readily available. (Id., p. 13.) Mr. Offermann also suggests requiring air ventilation systems which would reduce formaldehyde levels. (Id., pp. 11-12.) Since the EIR does not analyze this impact at all, none of these or other mitigation measures have been considered.

When a Project exceeds a duly adopted CEQA significance threshold, as here, this alone establishes a fair argument that the project may have a significant environmental impact and an EIR is required. Indeed, in many instances, such air quality thresholds are the only criteria reviewed and treated as dispositive in evaluating the significance of a project’s air quality impacts. (See, e.g. Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 [County applies Air District’s “published CEQA quantitative criteria” and “threshold level of cumulative significance”]; see also Communities for a Better Environment v.

California Resources Agency (2002) 103 Cal.App.4th 98, 110-111 [“A ‘threshold of significance’ for a given environmental effect is simply that level at which the lead agency finds the effects of the project to be significant”].) The California Supreme Court made clear the substantial importance that an air district significance threshold plays in providing substantial evidence of a significant adverse impact. (Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 327 [“As the District’s established significance threshold for NOx is 55 pounds per day, these estimates [of NOx emissions of 201 to 456 pounds per day] constitute substantial evidence supporting a fair argument for a significant adverse impact.”].) Since expert evidence demonstrates that the Project may exceed the SCAQMD’s CEQA significance threshold, there is substantial evidence that an “unstudied, potentially significant environmental effect” exists. (See Friends of Coll. of San Mateo Gardens v. San Mateo Cty. Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 958 [emphasis added].)
The failure of the MND to address the Project’s formaldehyde emissions is contrary to the California Supreme Court’s decision in California Building Industry Ass’n v. Bay Area Air Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 (“CBIA”).

In that case, the Supreme Court expressly holds that potential adverse impacts to future users and residents from pollution generated by a proposed project must be addressed under CEQA. At issue in CBIA was whether the Air District could enact CEQA Guidelines that advised lead agencies that they must analyze the impacts of adjacent environmental conditions on a project. The Supreme Court held that CEQA does not generally require lead agencies to consider the environment’s effects on a project. (CBIA, 62 Cal.4th at 800-01.) However, to the extent a project may exacerbate existing environmental conditions at or near a Redlands Regular Meeting of 12-03-24 617 of 875
project site, those would still have to be considered pursuant to CEQA. (Id. at 801.) In so holding, the Court expressly held that CEQA’s statutory language required lead agencies to disclose and analyze “impacts on a project’s users or residents that arise from the project’s effects on the environment.” (Id. at 800 [emphasis added].)
The carcinogenic formaldehyde emissions identified by Mr. Offermann is not an existing environmental condition. Those emissions to the air will be from the Project. People will be residing in the Project’s buildings once built and emitting formaldehyde. Once built, the Project will begin to emit formaldehyde at levels that may pose significant direct and cumulative health risks. The Supreme Court in CBIA expressly finds that this type of air pollution emission and health impact by the project on the environment and a “project’s users and residents” must be addressed in the CEQA process. The existing TAC sources near the Project site would have to be considered in evaluating the cumulative effect on future residents of both the Project’s TAC emissions as well as those existing off-site emissions.

The Supreme Court’s reasoning is well-grounded in CEQA’s statutory language.

CEQA expressly includes a project’s effects on human beings as an effect on the environment that must be addressed in an environmental review. “Section 21083(b)(3)’s express language, for example, requires a finding of a ‘significant effect on the environment’ (§ 21083(b)) whenever the ‘environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.’” (CBIA, 62 Cal.4th at 800.) Likewise, “the Legislature has made clear—in declarations accompanying CEQA’s enactment—that public health and safety are of great importance in the statutory scheme.” (Id. [citing e.g., PRC §§ 21000, 21001].) It goes without saying that the future residents of the Project are human beings and their health and safety must be subject to CEQA’s safeguards.

The City has a duty to investigate issues relating to a project’s potential environmental impacts. (See County Sanitation Dist. No. 2 v. County of Kern, (2005) 127 Cal.App.4th 1544, 1597–98. [“[U]nder CEQA, the lead agency bears a burden to investigate potential environmental impacts.”].) The proposed buildings may have significant impacts on air quality and health risks by emitting cancer-causing levels of formaldehyde into the air that may expose future residents to cancer risks potentially in excess of SCAQMD’s threshold of significance for cancer health risks of 10 in a million. Currently, outside of Mr.

Offermann’s comments, the City does not have any idea what risks will be posed by formaldehyde emissions from the Project. As a result, the City must include an analysis and discussion in an EIR which discloses and analyzes the health risks that the Project’s formaldehyde emissions may have on future residents and identifies appropriate and feasible mitigation measures.

Because Mr. Offermann’s expert review is substantial evidence of a fair argument of a significant environmental impact to future users of the project, an EIR must be prepared to disclose and mitigate those impacts.” Response 1. The comment does not describe how the asserted formaldehyde related cancer risk of 120 per million would occur and does not identify any Project-specific Redlands Regular Meeting of 12-03-24 618 of 875
conditions (other than the fact that the Project' s construction may use wood building materials) that would lead to impacts. Current federal and state regulations exist, which limit the potential formaldehyde emissions from building materials. On June 1, 2018, the U. S. Toxic Substances Control Act (TSCA) Title VI was implemented, which requires composite wood products sold, supplied, offered for sale, manufactured, or imported in the United States to meet new emission standards for formaldehyde from composite wood products to reduce exposures to formaldehyde and avoid adverse health effects. Typical composite wood products include hardwood plywood, medium-density fiberboard, and particleboard, as well as household and other finished goods containing these products. The new emission limits include the following:
• Hardwood Plywood: 0.05 parts per million ( ppm)
• Particleboard: 0.09 ppm
• Medium-density fiberboard: 0. 1 1 ppm
• Thin Medium-density fiberboard: 0. 13 ppm
These emission levels were determined to be in compliance with and result in less exposure ( e. g., daily intake) than the California Proposition 65 safe harbor level for formaldehyde ( 40 μg/ day), which is based on Proposition 65's risk criterion of 1 in 100,000. Thus, products manufactured to TSCA Title VI and California Proposition 65 safe harbor standards, which is now required by the U.S. EPA for all products manufactured or imported into the United States, would not generate formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million.

CARB has determined that these standards are projected to lead to a reduction in statewide formaldehyde emissions of 500 tons per year. Reduced risk of cancer from formaldehyde exposure is also a resulting benefit, and implementation of these standards is estimated to reduce excess cancer cases per million people from formaldehyde exposure by about 40 percent (https://ww2.arb.ca.gov/sites/default/files/classic/toxics/compwood/outreach/pa mphpanelmanufac.pdf). The CalGreen Building Code also includes similar formaldehyde limits for building products.

The proposed project would be implemented pursuant to these formaldehyde requirements, as all products manufactured or imported into the United States are required to meet these regulations. This would limit the potential of human health and cancer risks to a less than significant level pursuant to the SCAQMD significance threshold of 10 per million. Thus, building material manufacturer compliance with existing regulations would avoid potentially significant impacts related to formaldehyde. The Project would result in less than significant impacts.

Comment 2. “There is Substantial Evidence of a Fair Argument that the Project May Have Significant Biological Resources Impacts. An EIR is required because substantial evidence in the record indicates a fair argument that the Project may have significant biological impacts. Expert wildlife biologist Shawn Smallwood, Ph.D. reviewed the Project and MND and concluded that the Project may have significant impacts on special-status species. Dr. Smallwood’s comments and CV are attached hereto as Exhibit B. Dr. Smallwood’s comments are supported Redlands Regular Meeting of 12-03-24 619 of 875
by a site visit by wildlife biologist Noriko Smallwood (“Ms. Smallwood”). (Ex. B, p. 1.) Ms. Smallwood is an expert wildlife ecologist with a focus on urban ecology, avian ecology, and habitat conservation. Ms. Smallwood visited the site for approximately 4.5 hours on May 9, 2024, starting at 6:15 am. (Id.) She walked the site’s perimeter, using binoculars and camera to scan for and photograph wildlife. (Id.).”
Response 2. The City has reviewed the materials provided by SWAPE and finds that they inaccurately characterize the conditions of the project site and do not make a “fair argument” that the project would significantly impact biological resources with the proposed mitigation measures. We find that both Ms. Smallwood and Dr. Smallwood are qualified biologists; however, we do not feel that their methods are consistent with those used in typical CEQA / NEPA studies, as discussed in further detail in the responses below.

Comment 3. “The Project May Have Significant Impacts on Special Status Species. An EIR is required because there is substantial evidence establishing a fair argument that the Project may have significant adverse impacts on special status species. Dr. Smallwood concluded that the Project may have significant impacts on biological resources. (Ex. B, p. 1.) Ms. Smallwood also detected the Lawrence’s goldfinch (Spinus lawrencei), which is classified as “Birds of Conservation Concern”, calling near the site1 (Id.) Birds of Conservation Concern include “migratory nongame birds that without additional conservation action are likely to become candidates for listing under the Endangered Species Act (ESA) of 1973.”2 Ms. Smallwood further detected a Southern grasshopper mouse (Onychomys torridus ramona), a “California Species of Special Concern”, captured as prey in a raven’s bill. (Id.)3 Altogether, these species are considered “Special Status Species”, a universal term used in the scientific community for species that are considered sufficiently rare that they require special consideration and/or protection and should be, or have been, listed as rare, threatened, or endangered by the Federal and/or State governments.” Response 3. The commenter is referring to the “Birds of Conservation Concern” (BBC) list when referring to Lawrence’s goldfinch as “special-status”; however, the BCC list is not used as a special-status list on typical biological analyses for CEQA/NEPA documents. Some of the statuses considered by Smallwood (i.e., BCC, TWL, BOP) are not typically evaluated in CEQA biological assessments because they do not meet the documentation and report preparation requirements of CDFW; they are acknowledged here but were not discussed in further detail.

Nonetheless, Lawrence’s goldfinch is provided protection under mitigation measure BIO-1, which requires a preconstruction survey and avoidance of nesting birds.

Ms. Noriko Smallwood reported a sighting of a Southern Grasshopper Mouse, which was documented in their report as being identified from a photograph; however, the photograph is not provided or labeled in their report. Since Smallwood did not include or properly label the photograph, we cannot review it to ensure that it was properly identified. We consider this unverifiable information since we have not been provided with the existing photograph. Typical biological reports include photographs of species when observed.

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Comment 4. “Dr. Smallwood concludes that the Project may have a substantial adverse effect on these special status species, either directly due to traffic collisions or through the habitat modifications stemming from the Project. Dr. Smallwood also concludes that the Project may fragment the few remaining habitat for special status species, disturb their reproductive capacity, increase mortality due to traffic collisions, and overall impede their movement. (Ex. B, pp. 20-33.) Dr.

Smallwood’s findings constitute substantial evidence of a fair argument that the Project may have an adverse effect on special status species.” Response 4. The City has reviewed Exhibit B. Please see responses to the comments below regarding, wildlife movement (Comment 5 and 6), habitat modifications (as habitat loss, Comment 7), habitat fragmentation (Comment 7), or traffic collisions (Comment 8), where applicable.

Comment 5. “The Project May Have Significant Impact on Wildlife Movement. The MND’s analysis of the Project’s impacts to wildlife movement is flawed. The MND claims that the “Project Area does is situated in an urbanized area and does not represent a wildlife movement corridor as it (along with other small neighboring vacant lots) is largely bound on all sides by developments, possesses vegetation that is largely non-native that would support high levels of species diversity, and it is too small of an area to support significant wildlife movement. This Project Area does not connect large areas of native habitats and development at this site would not preclude wildlife movement in otherwise open areas.” (General Biological Resources Assessment, p. 12.) However, the proper standard under CEQA is whether the Project would “[i]nterfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors.” (MND, p. 60.) As Dr. Smallwood notes, the conclusion reached in one portion of the assessment is inconsistent with its own description of how a wildlife corridor can be constructed because the MND also acknowledges that wildlife corridors can also constitute “discontinuous areas of habitat” much like the Project site’s relationship to the area (General Biological Resources Assessment, p. 12.)”
Response 5. The project would not significantly impact wildlife movement based on CEQA criteria because it is in an already disturbed site and not within any known migration corridor. CEQA does not protect all lands as “wildlife movement” areas but instead protects designated or “established native resident or migratory wildlife corridors.” It is not expected that the project removal of vegetation (primarily non-native vegetation) would reasonably be considered an impact on wildlife movement because there are alternate sites available in the vicinity that wildlife may use. The discontinuous habitat was not meant to refer to parcels comprised of non-native vegetation but rather habitats such as ponds or wetlands which are known to support sensitive wildlife.

Comment 6. “The MND relies on the conclusion that the Project site is not located in any wildlife corridor, but such finding is inconclusive of whether the Project site would substantially interfere with wildlife movement. As Dr. Smallwood notes, “[t]he primary phrase of the CEQA standard goes to wildlife movement regardless of whether the movement is channeled by a corridor. In fact, a site such as the project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of Redlands Regular Meeting of 12-03-24 621 of 875
anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol [citations omitted].” (Ex. B, p. 27.) Conversely, Ms. Smallwood’s in-person site visit yielded findings that contradict MIG’s assessment, as evidenced by the wildlife species she photographed perching on and flying over the Project site. (Id., p. 12.) Given the documented use by wildlife species of the Project site and aerosphere for movement, Dr. Smallwood concludes that the Project may have adverse impacts on wildlife movement. An EIR is required to analyze and mitigate this impact.”
Response 6. The information provided in reference to channelization was developed by Dr.

Smallwood and does not correspond to CEQA Appendix G question 4.4(D), which is provided below here:

Does the project 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?

We agree that the question does not require the corridor to be channelized; however, in general, this question is intended to evaluate if a project would significantly block the movement of a species, such that it results in substantial negative impacts (a good example would be freeway development that cougars cannot cross that prevents breeding). The proposed project would not block the movement of any known species, due to existing development on all sides.

Comment 7. “Habitat Loss and Fragmentation. The Project may adversely affect the special status species identified because the Project will result in direct loss of habitat.

Habitat loss and fragmentation impede the movement of wildlife species, thereby exacerbating an area’s productive capacity. In particular, “[h]abitat loss results in diminished productive capacity of affected wildlife species, but MIG (2023a) and the IS/MND make no attempt to estimate this lost capacity for any of the wildlife species potentially affected.” (Ex. B, p. 26.) Dr. Smallwood calculated that the Project would result in a reduction of approximately 50 nest sites and 70 nest attempts annually. (Id.) Given that the area has already undergone severe habitat fragmentation, proceeding with this Project would only further exacerbate the habitat loss and the area’s productive capacity for wildlife species. As such, an EIR is necessary to ensure the wildlife impacts from habitat loss and fragmentation is mitigated to the fullest extent.”
Response 7. While CEQA requires consideration of potential impacts on the environment, it doesn't directly protect all habitats. Instead, it focuses on a project's potential impacts on special-status species that rely on those habitats. It is common knowledge that not all special-status species found near or on a site may occupy it permanently as its habitat (i.e., natal site). Many species, especially avian species, are habitat-specific in selecting roosting, foraging, and nesting locations, and occurrences nearby do not indicate potential impacts to the species or habitat loss. The attempt to quantify nests lost and fewer births annually is overly speculative and not supported by empirical evidence and site conditions.

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Again, the project site does not contain any habitats considered sensitive or protected by any resource agency or entity, such as wetlands or native grasslands; therefore, the project owner would not be expected to mitigate habitat loss. Further, the estimated losses per year are not a reasonable estimate. The Smallwood projections are flawed because they assume 100% of the deaths of birds when, realistically, there are other possible sites for nesting birds to nest other than the project site. Mitigation Measure BIO-1 (for nesting birds) calls for avoiding nests during the nesting period and preconstruction surveys for nests, which should lower the potential to impact nesting birds to below the significance level.

Comment 8. “Traffic/Window Collisions. The Project may have significant impacts related to window collisions that the MND fails to evaluate. The Project will include glass facades that would intercept with and potentially kill bird species that rely on the surrounding aerosphere. (Ex. B, p. 28.) “The aerosphere is where birds and bats and other volant animals with wings migrate, disperse, forage, perform courtship and where some of them mate…Many special-status species of birds have been recorded at or near the aerosphere of the project site, and Noriko saw many birds using the aerosphere while she surveyed the site. Bird-window collision mortality is a potentially significant impact that warrants analysis.” (Id.) Despite numerous studies emphasizing the significant impacts that buildings have on bird species, the MND does not analyze the extent to which the Project’s use of windows would have on bird species utilizing the existing aerosphere. In response, Dr.

Smallwood reviewed the Project renderings and predicts that the Project may lead to 609 annual bird deaths. (Ex. B, p. 30.)”
Response 8. The project will comply with existing window design standards required for buildings in the planning area.

The comment is based on an analysis by Sean Smallwood, Ph.D., which may overestimate the amount of bird strike, and which makes assumptions about the amount and type of glass that will be included in future development. The analysis that is presented is based on empirical data collected at several buildings, resulting in an estimated bird strike rate of 0.073 bird deaths per square meter of glass per year, and extrapolated to the project design to provide an estimate of 609 annual bird deaths. It does not describe anything about the glazing on the buildings that were studied, or the landscaping around them, or their physical setting.

As reported in the San Francisco Standards for Bird-Safe Buildings and other documents, the typical bird strike zone is from grade to 60 feet, the primary concern is with any uninterrupted glazing 24 square feet or larger in size, and the likelihood of strike depends on the glazing used, the angle of the glass, the orientation of the building, and landscaping. In the urban setting, birds spend the majority of their time in landscape vegetation in the bird strike zone, where the vegetation may be reflected in glass, making the glass look like vegetation and undetectable to the bird.

Currently, the land uses and habitat conditions in and around the project area consist primarily of developed and landscaped uses. Vegetation is limited and consists primarily of non-native trees and shrubs. The birds that will occur in the Redlands Regular Meeting of 12-03-24 623 of 875
landscaping around buildings are common, urban-adapted songbird species – none of which are special-status – and these are the species most at risk for collision with windows. The vast majority of these species would continue to move in and around the area unimpeded by the new construction. Thus, although some birds may collide with window glass installed in future development, the impact would be less than significant.

Comment 9. “The Project may also have an adverse effect on wildlife species movement due to traffic collisions. According to the MND, the Project’s annual vehicle miles traveled (“VMT”) is 7,131,868. (Appendix E, p. 4.) As a result, Dr. Smallwood estimates that collisions with vehicles as a result of the Project would kill approximately 3,908 vertebrate wildlife fatalities per year. (Ex. B, p. 32.) Especially due to the special-status species likely to occur at or near the Project, these collisions represent an adverse impact to wildlife that has not been discussed or mitigated in the MND. Dr. Smallwood’s calculations constitute substantial evidence of a fair argument of significant impacts and must be addressed in an EIR.”
Response 9. The commenter raises concerns about road-kill being increased by the project due to the vehicle miles traveled (VMT) estimated for the project. There is no evidence that increased traffic in the already urbanized project area will result in a significant increase in wildlife roadkill. Because the area is disturbed and not pristine wildlife habitat, and does not support high quality habitat for specialstatus species, or significant wildlife corridors, or significant nursery sites, the likelihood of roadkill of wildlife, including special-status species is low. CEQA does not specify that the analysis address project impacts to commonly occurring species. Many of these species thrive in an urban setting because they have adapted to traffic, either through behavior or reproductive rates. It is not expected that the project will result in a significant impact related to roadkill.

Comment 10. “Since there is substantial evidence of a fair argument that the Project may have adverse biological impacts, as it relates to movement, habitat loss/fragmentation, and wildlife collisions/mortalities, an EIR is required to analyze these impacts and propose feasible mitigation measures. Dr. Smallwood suggests multiple mitigation measures related to protecting wildlife from traffic, funding wildlife rehabilitation facilities, and applying native landscaping on the Project site. (Ex.

B, p. 36.) These mitigation measures should be analyzed in an EIR and incorporated where feasible. Unless and until such impacts are addressed and mitigated, the City cannot proceed with any further approvals.” Response 10. An EIR is not required to propose mitigation measures, as an MND may propose mitigation measures to mitigate impacts. The mitigation measures proposed in the MND are typical for similar projects commonly permitted by the City. The City finds the measures proposed by Smallwood in Exhibit B to be atypical for projects with similar impacts. No additional mitigation measures are typically proposed for projects of this type, and therefore, no additional mitigation measures are proposed.

Comment 11. “The MND’s Proposed Mitigation Measures are Ineffective, Unenforceable, and Infeasible. A public agency may not rely on mitigation measures of Redlands Regular Meeting of 12-03-24 624 of 875
uncertain efficacy or feasibility. (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 727 [finding groundwater purchase agreement inadequate mitigation measure because no record evidence existed that replacement water was available].) “Feasible” means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social and technological factors. (14 CCR § 15364.) Mitigation measures must be fully enforceable through permit conditions, agreements, or other legally binding instruments. (14 CCR § 15126.4(a)(2).) The MND concludes that Project-specific impacts will be less than significant with the implementation of mitigation measures. However, the MND’s proposed mitigation measures are ineffective and there is no guarantee that implementation of these mitigation measures will reduce potentially significant biological resources impacts to a level below significance.” Response 11. The mitigation measures provided in the MND have been garnered from a review of many similar projects in the region, and are typically used for mitigation of impacts for projects with similar potential impacts. The MND’s measures are enforceable, as they are conditions of approval for the project; hence, the project cannot proceed without the applicant documenting compliance. The City is responsible for ensuring that mitigation measures are in place, and also maintains an administrative record for all projects, as legally required, which is available for audit by the general public through a public records request. No additional mitigation is required based on this comment.

Comment 12. “The IS/MND Fails to Adequately Describe the Project’s Environmental Setting. The City inadequately characterized the existing environmental setting and the site’s ability to provide habitat for special-status species. Every CEQA document must start from a “baseline” assumption. The CEQA “baseline” is the set of environmental conditions against which to compare a project’s anticipated impacts. (Communities for a Better Envt. v. So. Coast Air Qual. Mgmt. Dist. (2010) 48 Cal. 4th 310, 321.) Section 15125(a) of the CEQA Guidelines (14 C.C.R., § 15125(a)) states in pertinent part that a lead agency’s environmental review under CEQA: “…must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time [environmental analysis] is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a Lead Agency determines whether an impact is significant.” (emphasis added.) (See, Save Our Peninsula Committee v. County of Monterey (2001) 87 Cal.App.4th 99, 124- 125.) As the court of appeal has explained, “the impacts of the project must be measured against the ‘real conditions on the ground,’” and not against hypothetical permitted levels. (Save Our Peninsula, supra, 87 Cal.App.4th 99, 121-123.)”
Response 12. The City disagrees with the commenter regarding the characterization of the environmental baseline. The biologist who conducted the survey and report is qualified to conduct biological surveys and reports. MIG’s report followed standard topics that are typically analyzed in similar projects of this scale and scope. We do not find that any significant inaccuracies were detected, and the competing survey conducted by Dr. Smallwood does not nullify previous surveys.

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record use. However, no additional mitigation measures are required based on the findings of their report.

Comment 13. “The Field Surveys Prepared for the MND are Unreliable. The field survey prepared by the City’s expert, MIG, which was used to inform the environmental setting, is deficient. MIG’s survey combined both a reconnaissance survey as well as a more-specific burrowing owl survey, which is a concern because Dr.

Smallwood explains that the combined survey “cannot be expected to achieve” fulfilling the multiple objectives satisfactorily. (Ex. B, p. 16.) This is evidenced, for example, by the fact that MIG’s survey did not fulfill the minimum requirements outlined under the California Department of Fish and Wildlife (“CDFW”) for surveying burrowing owls. (Id., p. 16.) For instance, the survey did not prepare any habitat assessments prior to the breeding-season survey nor were any surveys actually performed prior to April 15. (Id.) Moreover, the reconnaissance survey did not report for any other special-status species that potentially occur on the Project site despite conceding that many special-status species occur or have the potential to occur on the Project site. (Id.)” Response 13. The initial burrowing owl survey was conducted on the same day as the general habitat assessment for this project. It is common practice for MIG biologists to conduct compatible surveys at the same time, and it is also common practice for most other firms to perform some surveys simultaneously. The CDFW also allows for modifications to the survey guidelines when appropriate, as long as such modifications would not completely impede the detection of burrowing owls.

Regarding reporting for other specific species -- the purpose of a habitat assessment is to assess what habitats are present at the site that may support special-status species. The species identified in tables included in the Smallwood report do not all require focused surveys. Special-status species would not require focused surveys unless suitable habitats exist on the project site. The Smallwoods' report does not contain a habitat assessment – the database assessments provided in their report of “very close, in the region, etc.” are not an assessment of habitat suitability for a given species. Many specialstatus species are confined to specific habitats (such as particular types of wetlands, soils, and vegetation communities), and the mere evaluation of distances to the site does not trigger the need for a focused survey. Sensitive habitats that require surveys are sites that are essential to the continued persistence of a special-status species or population, and areas outside of those that species may use to forage, perch, or flyover, would not necessarily trigger the need for a focused survey either.

We do not find any significant inaccuracies, and the competing survey conducted by Dr. Smallwood does not nullify previous surveys. The Smallwood report has been recorded for the administrative record; however, no additional mitigation measures are required based on its findings.

Comment 14. “MIG’s failure to include the methodological details or statement of objectives that shaped the survey findings is alarming because such information is essential “to characterize the environmental setting as a basis for opining on, or predicting, potential project impacts to biological resources.” (Ex. B, pp. 15-16.) Dr.

Smallwood concludes that the Project site has not been adequately surveyed “to Redlands Regular Meeting of 12-03-24 626 of 875
obtain a representative sample of the wildlife community,” explaining that additional surveys would yield more detections. (Id., p. 16.) For example, Ms.

Smallwood observed 28 species of vertebrate wildlife at and/or near the Project site, and at least three of which were special-status species. (Id., p. 2.) Comparatively, however, Ms. Smallwood detected 13 species that MIG’s report did not, while MIG identified five species that Ms. Smallwood did not – a combined total of 33 species. (Id., p. 16.) The clear disparities between what MIG’s and Ms. Smallwood’s surveys as well as the unclear method in which the surveys were conducted and documented render the resulting environmental setting unreliable for the purposes of determining the Project baseline.” Response 14. The methods section is in Section 3.0 of MIG’s report and follows standard protocols regularly used by local firms, including a desktop review and field survey to verify habitats. We see that the type of survey, a wildlife species inventory, performed by Ms. Noriko Smallwood to be a different type of survey, and atypical for projects of this size and scope. The Smallwood report does not nullify the conclusions in the report simply because they surveyed the site for longer and generated a longer list of species – the goal of a habitat assessment is not to conduct a floristic or faunal inventory, but rather a description of the habitats and features present on the site that could support sensitive species or biological resources. Please also see Response 13, above for a discussion of items typically included in habitat assessments.

Comment 15. “The MND’s Reliance on an Improper Desktop Survey is Erroneous. The desktop survey performed by MIG is misleading, making the resulting MND document inaccurate. From the onset, MIG narrowed its survey of special-status species because the Project site does not include essential habitat, low occurrences of species based on distributional range, limited nesting and foraging, and the disturbance of the Project site. (General Biological Resources Assessment, p. 11.) This decision by MIG has led to unreliable and speculative determinations as a result. First, the MND is incorrect in concluding that the disturbed conditions of the Project site mean that there is no suitable habitat on it. As evidenced by Ms. Smallwood, disturbances to the site, such as the disking event Ms. Smallwood witnessed, uncovered the species diversity of the Project site. Disturbance of the area highlighted the numerous wildlife species, including special-status species, that inhabit and rely on the Project site for foraging, hunting, and cover from predators. (See generally, Ex. B, Photos 1-31.) Furthermore, even MIG’s survey detected a long-tailed weasel, a discovery that Dr. Smallwood indicates “is not a type of animal that would occur in a wildlife community that has been suppressed by disturbance, as the IS/MND repeatedly claims as a leading reason that the Project site should not be expected to support special-status species.” (Id., p. 16.)”
Response 15. We disagree with the statement that the desktop review makes the MND inaccurate. The species included in tables assessed for habitat suitability in MIG’s study were derived from a desktop review of the positive occurrence databases (including the CNDDB in addition to others indicated on page 7 of MIG’s report) and is a typical practice for habitat assessments. Reviewing local species occurrence records to establish a list of species to evaluate is common practice for habitat assessments, and we do not find this an unusual Redlands Regular Meeting of 12-03-24 627 of 875
methodology to follow. Please also see the response to Comments 13 and 14 above for a response regarding criteria used in habitat assessments.

We agree with Dr. Smallwood that the detection of a long-tailed weasel is indeed an unusual finding for the area; however, the site is close to homes, and it is assumed that the animal may have been introduced/released in the field as it is not typically known from this area. Detection of a species that may have been introduced to the site does not make the results of MIG’s study inaccurate and no further mitigation is required.

Comment 16. “Additionally, the MIG improperly relied on the California Natural Diversity Database (“CNDDB”) because CNDDB “is not designed to support absence determinations or to screen out species from characterization of a site’s wildlife community…There are many areas of the state where no surveys have been conducted” but “that does not mean that there are no special status species present.” (Ex. B, p. 18.) As such, Dr. Smallwood concludes that reliance on CNDDB to establish a reconnaissance survey for special-status species is flawed. (Id.)”
Response 16. Please see the response to Comment 15 above. The use of the CNDDB and other databases is only to provide a list of species for review that are known from the area. It was not used to “screen out” species. We understand that it is a positive-occurrence database and additional species may be detected in some circumstances; however, it is common practice to use databases to illustrate that species reported to occur in the local area are evaluated, at minimum. Whenever a surveying biologist detects an additional rare species based on their knowledge, additional species are added to the table. The biologists surveying the site are familiar with more species than just the project area, as their survey experience extends throughout most of southern California, and would report a new occurrence of a special-status species if found regardless of the initial database searches.

Comment 17. “Given the abundance of wildlife detected on the Project site, including those identified as special-status species, the MND’s determinations on environmental impacts relies on an unreliable and misleading analysis of the Project’s environmental setting. Therefore, the IS/MND fails to accurately describe the Project’s environmental setting. Dr. Smallwood recommends preparing additional, and more detailed, surveys in order to better capture the existing environmental setting and site conditions for wildlife species.” Response 17. The detection of additional species by the Smallwoods in their analysis does not warrant an additional habitat assessment. The Smallwoods did not conduct a competing habitat assessment in their study; however, nonetheless, their findings are incorporated into the administrative record for the project. No new information presented by the Smallwoods requires additional surveys, and no additional mitigation is warranted.

Comment 18. “Mitigation Measure BIO-1 is an Ineffective Mitigation Measure. The MND proposes Mitigation Measure BIO-1 (Pre-construction Survey for Nesting Birds) in response to the Project site’s potential to host ground- and tree-nesting bird nests protected by state law. (Cal. Fish and Game Code (“CFGC”) §§ 3503, Redlands Regular Meeting of 12-03-24 628 of 875
3503.5, and 3512.) This mitigation measure explains that “[t]o the extent feasible, construction activities should be scheduled to avoid the nesting season. If construction activities are scheduled to take place outside the nesting season, all impacts to nesting birds protected under the MBTA and California Fish and Game Code would be avoided.” (MND, p. 63.)”
Response 18. Projects of similar scope and size include a similar mitigation measure and phrase for scheduling construction activities in a manner that avoids the nesting season. The City does not find this to be an ineffective mitigation measure.

Comment 19. “Dr Smallwood underlines that the proposed preconstruction surveys are ineffective because bird species have varying nesting seasons. (Ex. B, p. 34.) Additionally, pre-construction surveys are intended as a follow-up to a breeding season detection survey. As Dr. Smallwood emphasizes, no breeding-season detection surveys that meet CDFW standards have been prepared for the Project site. (Id.) This means that the measure’s protections will not extend to future breeding seasons and would likely lead to the permanent destruction of the site’s productive capacity for burrowing owls. (Id., pp. 34-35.)” Response 19. Preconstruction surveys are attended to serve as avoidance measures for construction, and they are intended for the detection of species for avoidance during the initial phases of construction. Pre-construction surveys are not intended as a follow-up survey for a breeding detection survey, as the goal is avoidance. Burrowing owls were not found during the protocol surveys, and therefore, one cannot conclude that burrowing owl habitat has been lost. Per CEQA we must evaluate the environmental baseline, not the potential for future occupation of a species.

Comment 20. “Even if a pre-construction detection survey was prepared, Dr. Smallwood opines that it would achieve very little. Dr. Smallwood explains that “[w]henever a preconstruction survey is conducted, its biologists would be searching only for the nests of the birds that happen to be breeding at the time and would miss the nests begun between the survey and the state of construction.” (Ex. B, p. 34.) Dr. Smallwood further explains that even with the implementation of BIO-1, preconstruction surveys will not mitigate the significant impacts related to the loss of productive capacity on the Project site. “All subsequent years of productivity would be destroyed by the project regardless of the success of a preconstruction survey.” (Id.).”
Response 20. The intent of the pre-construction surveys is to avoid active nesting prior to the project's construction. Construction crews are required to comply with existing laws, including the Migratory Bird Treaty Act and avoid nests if they form on the site later. The purpose of a biologist performing a preconstruction survey is to have trained personnel perform the initial surveys since vegetation can often obscure nests. The project is not required to mitigate for loss of non-sensitive habitats.

Comment 21. “Furthermore, the contours of Mitigation Measure BIO-1 would allow unfettered control for a biologist to make critical determinations about the adequacy of surveying for nesting birds. This mitigation measure lacks objective criteria because the language allows a single individual (qualified biologist) “to make a Redlands Regular Meeting of 12-03-24 629 of 875
subjective decision, outside the public’s view, to determine the buffer area within stated maxima for any given species. (Ex. B, p. 34.) Mitigation Measure BIO- 1 therefore violates CEQA’s requirements for mitigation measures.” Response 21. This comment makes an incorrect assertion. Qualified biologists are required to submit reports to the City documenting the results and activities conducted during surveys and monitoring for projects. The City is responsible for ensuring that mitigation measures are in place, and also maintains an administrative record for all projects, as legally required, which is available for audit by the general public through a public records request. No additional mitigation is required based on this comment.

Comment 22. “Mitigation Measure BIO-2 is an Ineffective Mitigation Measure. Mitigation Measure BIO-2 (Pre-construction Survey for Burrowing Owls) proposes that “[n]o more than 14 days prior to ground disturbance a focused survey for burrowing owl will be required to ensure take avoidance.” (MND, p. 64.) This mitigation measure is similarly ineffective for a variety of reasons. Much like Mitigation Measure BIO-1 above, no breeding-season detection surveys have been performed on the Project site. (Ex. B, p. 34.) Therefore, relying on a mitigation measure for pre-construction surveys to be conducted without first having done any breeding-season detection surveys renders Mitigation Measure BIO-2 ineffective.”
Response 22. This statement is incorrect, as a modified breeding survey was conducted. The mitigation measure included in the report is consistent with the 2012 Staff Report on Burrowing Owl Mitigation.

Comment 23. “The MND Fails to Adequately Address the Project’s Cumulative Impacts on Biological Resources. A project may have a significant effect on the environment if “the possible effects of a project are individually limited but cumulatively considerable. . . . ‘Cumulatively considerable’ means that the incremental effects of an individual 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.” “Cumulative impacts” are defined as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” (CEQA Guidelines section 15355(a).) “[I]ndividual effects may be changes resulting from a single project or a number of separate projects.” (CEQA Guidelines section 15355(a).) The MND concludes that the Project would not have any cumulative impacts with mitigation implemented, and that therefore, “the project would not contribute considerably to regional impacts on such species.” (MND, p. 124.) However, the discussion of cumulative impacts to wildlife is flawed because the MND falsely assumes that cumulative impacts are “really residual impacts left over by inadequate mitigation of project impacts.” (Ex. B, p.33.) This is not the standard under CEQA. Under CEQA, individually insignificant impacts can nevertheless be cumulatively considerable. Dr.

Smallwood asserts that the Project may have cumulative impacts on biological resources due to the exacerbation of habitat fragmentation in the area, increased mortality rates of wildlife due to window and traffic collisions, and the decreased productive capacity of the region. (Ex. B, p. 33.) None of these impacts were adequately reviewed, therefore underestimating the cumulative impacts that this Redlands Regular Meeting of 12-03-24 630 of 875
Project may have. Furthermore, and as explained above, the proposed mitigation measures to address biological resources impacts are ineffective. As such, even with implementation of mitigation, the Project may still contribute considerably to wildlife impacts locally and in the region. Thus, the MND’s conclusion that the cumulative impacts would be less than significant is unfounded and should be revised in an EIR.”
Response 23. Consistent with Appendix G of the CEQA Guidelines, the Initial Study does not directly address cumulative impacts or evaluate impacts to common wildlife beyond the thresholds identified in the checklist (e.g., impacts to wildlife migratory corridors or nursery sites). Cumulative effects were considered as part of the overall evaluation of effects on biological resources, consistent with CEQA Guidelines section 15063(b)(1). The comment letter does not specify what cumulative impacts have been overlooked. Since the project site is already disturbed and is surrounded by parcels providing little to no suitable habitat for special-status species or other significant habitat functions, and the project is not expected to result in significant impacts to wildlife species when implemented with the required mitigation measures, the project is not expected to result in significant cumulative impacts to biological resources.

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ATTACHMENT 1:

Lozeau Drury, LLP Comment Letter
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Via Email
May 28, 2024
Sean Reilly, Principal Planner
Development Services Department
City of Redlands
35 Cajon St., Ste. 20
Redlands, CA 92373
[email protected]
Re: Comment on the Mitigated Negative Declaration
Tennessee Village Mixed-Use Project
Dear Mr. Reilly:

I am writing on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) and its members living and working in and around the City of Redlands (“City”) regarding the Initial Study and Mitigated Negative Declaration (“IS/MND”) prepared for the Tennessee Village Mixed-Use Project (“Project”).

After careful review of the IS/MND and its accompanying documents prepared by environmental consulting firm MIG, Inc. (“MIG”), SAFER believes that the IS/MND is improper under the California Environmental Quality Act, and that an environmental impact report (“EIR”) is required. As explained in more detail below, there is a fair argument that the Project may have significant environmental impacts.

Additionally, the MND violates CEQA because it fails to evaluate the feasibility of increasing reliance on renewable energy sources such as using 100% renewable energy for the Project some lesser amount that is beyond the minimum Title 24 requirements. The MND also fails to evaluate strategies for reducing reliance on fossil fuels by prohibiting natural gas.

Furthermore, the Project is inconsistent with the City’s General Plan.

Accordingly, SAFER requests that the City not proceed with certifying the MND and to instead prepare an EIR to ensure that potentially significant environmental impacts of this Project are fully disclosed, analyzed, and mitigated.

PROJECT DESCRIPTION
The Project proposes the development of 460 new apartment units, approximately 17,899 square feet of commercial space, and associated landscaping and roadway improvements. The Redlands Regular Meeting of 12-03-24 635 of 875
Project would consist of two (2) three-story buildings and eight (8) four-story buildings Eight (8) of the proposed buildings would include only residential uses and two (2) of the proposed buildings would include mixed uses that incorporate ground-floor commercial space with residential units on the floors above. Approximately 5% of the proposed residential units would be designated as “very low-income” units.

Parking would be provided through a combination of underground, garage, outdoorcovered, outdoor-uncovered, and commercial parking spaces throughout the project. The project would include 673 residential parking spaces, and 91 commercial spaces, for a total of 764 spaces.

LEGAL STANDARD
As the California Supreme Court has held “[i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” (Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310, 319-320 [citing No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 88; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491, 504–505].) “Significant environmental effect” is defined very broadly as “a substantial or potentially substantial adverse change in the environment.” (Pub. Res. Code § 21068; see also 14 CCR § 15382.)

The EIR is the very heart of CEQA. Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927. The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” Bakersfield Citizens, 124 Cal.App.4th at 1220. The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392. The EIR process “protects not only the environment but also informed selfgovernment.” Pocket Protectors, 124 Cal.App.4th at 927.

Where an initial study shows that the project may have a significant effect on the environment, a mitigated negative declaration may be appropriate. However, a mitigated negative declaration is proper only if the project revisions would avoid or mitigate the potentially significant effects identified in the initial study “to a point where clearly no significant effect on the environment would occur, and…there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” PRC §§ 21064.5 and 21080(c)(2); Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331. In that context, “may” means a reasonable possibility of a significant effect on the environment. PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, 124 Cal.App.4th at 927; League for Protection of Oakland's etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904–05.

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Under the “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have significant environmental impacts —even if contrary evidence exists to support the agency’s decision. 14 CCR § 15064(f)(1); Pocket Protectors, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602. The “fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. Pocket Protectors, 124 Cal.App.4th at 928. The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains:

This ‘fair argument’ standard is very different from the standard normally followed by public agencies in making administrative determinations. Ordinarily, public agencies weigh the evidence in the record before them and reach a decision based on a preponderance of the evidence. [Citations]. The fair argument standard, by contrast, prevents the lead agency from weighing competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact.

The lead agency’s decision is thus largely legal rather than factual; it does not resolve conflicts in the evidence but determines only whether substantial evidence exists in the record to support the prescribed fair argument.

Kostka & Zishcke, Practice Under CEQA, §6.29, pp. 273–74.

The Courts have explained that “it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” Pocket Protectors, 124 Cal.App.4th at 928 (emphasis in original).

DISCUSSION
I. There is Substantial Evidence of a Fair Argument that the Project May Have Significant Indoor Air Quality Impacts.

Certified Industrial Hygienist, Francis Offermann, PE, CIH, conducted a review of the Project and relevant documents regarding the Project’s indoor air emissions. Mr. Offermann concludes that the Project may expose future residents of the Project to significant health impacts related to indoor air quality, and in particular, emissions of the cancer-causing chemical formaldehyde. Mr. Offermann is one of the world’s leading experts on indoor air quality and has published extensively on the topic. As discussed below and in Mr. Offermann’s comments, the Project’s emissions of formaldehyde to the air may result in very significant cancer risks to future residents of the Project’s residential units. Mr. Offermann’s expert comments and CV are attached as Exhibit A.
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Mr. Offermann explains that many composite wood products typically used in home and apartment building construction contain formaldehyde-based glues which off-gas formaldehyde over a very long period. He states, “[t]he primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.” (Ex. A, p. 3.)
Formaldehyde is a known human carcinogen and is listed by the State as a toxic air contaminant (“TAC”). The South Coast Air Quality Management District (“SCAQMD”) has established a significance threshold of health risks for carcinogenic TACs of 10 in one million. (Ex. A, p. 3.) Mr. Offermann found that future residents of the Project’s residential units may be exposed to a cancer risk of 120 per million, even assuming all materials are compliant with the California Air Resources Board’s (“CARB”) formaldehyde airborne toxics control measure. (Ex.

A, p. 4.) This is more than 12 times SCAQMD’s CEQA significance threshold of 10 per million and constitutes a potentially significant impact.

Mr. Offermann concludes that this significant environmental impact must be analyzed in an EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. (Ex. A, pp. 13-14.) He prescribes a methodology for estimating the Project’s formaldehyde emissions in order to do a more project-specific health risk assessment. (Id., pp. 9-10.). Mr.

Offermann also suggests several feasible mitigation measures, such as requiring the use of noadded-formaldehyde composite wood products, which are readily available. (Id., p. 13.) Mr.

Offermann also suggests requiring air ventilation systems which would reduce formaldehyde levels. (Id., pp. 11-12.) Since the EIR does not analyze this impact at all, none of these or other mitigation measures have been considered.

When a Project exceeds a duly adopted CEQA significance threshold, as here, this alone establishes a fair argument that the project may have a significant environmental impact and an EIR is required. Indeed, in many instances, such air quality thresholds are the only criteria reviewed and treated as dispositive in evaluating the significance of a project’s air quality impacts. (See, e.g. Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 [County applies Air District’s “published CEQA quantitative criteria” and “threshold level of cumulative significance”]; see also Communities for a Better Environment v. California Resources Agency (2002) 103 Cal.App.4th 98, 110-111 [“A ‘threshold of significance’ for a given environmental effect is simply that level at which the lead agency finds the effects of the project to be significant”].)
The California Supreme Court made clear the substantial importance that an air district significance threshold plays in providing substantial evidence of a significant adverse impact. (Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 327 [“As the District’s established significance threshold for NOx is 55 pounds per day, these estimates [of NOx emissions of 201 to 456 pounds per day] constitute substantial evidence supporting a fair argument for a significant adverse impact.”].) Since expert evidence demonstrates that the Project may exceed the SCAQMD’s CEQA significance threshold, there is 1 (cont).

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substantial evidence that an “unstudied, potentially significant environmental effect[]” exists. (See Friends of Coll. of San Mateo Gardens v. San Mateo Cty. Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 958 [emphasis added].)
The failure of the MND to address the Project’s formaldehyde emissions is contrary to the California Supreme Court’s decision in California Building Industry Ass’n v. Bay Area Air Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 (“CBIA”). In that case, the Supreme Court expressly holds that potential adverse impacts to future users and residents from pollution generated by a proposed project must be addressed under CEQA. At issue in CBIA was whether the Air District could enact CEQA Guidelines that advised lead agencies that they must analyze the impacts of adjacent environmental conditions on a project. The Supreme Court held that CEQA does not generally require lead agencies to consider the environment’s effects on a project. (CBIA, 62 Cal.4th at 800-01.) However, to the extent a project may exacerbate existing environmental conditions at or near a project site, those would still have to be considered pursuant to CEQA. (Id. at 801.) In so holding, the Court expressly held that CEQA’s statutory language required lead agencies to disclose and analyze “impacts on a project’s users or residents that arise from the project’s effects on the environment.” (Id. at 800 [emphasis added].)
The carcinogenic formaldehyde emissions identified by Mr. Offermann is not an existing environmental condition. Those emissions to the air will be from the Project. People will be residing in the Project’s buildings once built and emitting formaldehyde. Once built, the Project will begin to emit formaldehyde at levels that may pose significant direct and cumulative health risks. The Supreme Court in CBIA expressly finds that this type of air pollution emission and health impact by the project on the environment and a “project’s users and residents” must be addressed in the CEQA process. The existing TAC sources near the Project site would have to be considered in evaluating the cumulative effect on future residents of both the Project’s TAC emissions as well as those existing off-site emissions.

The Supreme Court’s reasoning is well-grounded in CEQA’s statutory language. CEQA expressly includes a project’s effects on human beings as an effect on the environment that must be addressed in an environmental review. “Section 21083(b)(3)’s express language, for example, requires a finding of a ‘significant effect on the environment’ (§ 21083(b)) whenever the ‘environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.’” (CBIA, 62 Cal.4th at 800.) Likewise, “the Legislature has made clear—in declarations accompanying CEQA’s enactment—that public health and safety are of great importance in the statutory scheme.” (Id. [citing e.g., PRC §§ 21000, 21001].) It goes without saying that the future residents of the Project are human beings and their health and safety must be subject to CEQA’s safeguards.

The City has a duty to investigate issues relating to a project’s potential environmental impacts. (See County Sanitation Dist. No. 2 v. County of Kern, (2005) 127 Cal.App.4th 1544, 1597–98. [“[U]nder CEQA, the lead agency bears a burden to investigate potential environmental impacts.”].) The proposed buildings may have significant impacts on air quality and health risks by emitting cancer-causing levels of formaldehyde into the air that may expose 1 (cont).

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future residents to cancer risks potentially in excess of SCAQMD’s threshold of significance for cancer health risks of 10 in a million. Currently, outside of Mr. Offermann’s comments, the City does not have any idea what risks will be posed by formaldehyde emissions from the Project. As a result, the City must include an analysis and discussion in an EIR which discloses and analyzes the health risks that the Project’s formaldehyde emissions may have on future residents and identifies appropriate and feasible mitigation measures.

Because Mr. Offermann’s expert review is substantial evidence of a fair argument of a significant environmental impact to future users of the project, an EIR must be prepared to disclose and mitigate those impacts.

II. There is Substantial Evidence of a Fair Argument that the Project May Have Significant Biological Resources Impacts.

An EIR is required because substantial evidence in the record indicates a fair argument that the Project may have significant biological impacts. Expert wildlife biologist Shawn Smallwood, Ph.D. reviewed the Project and MND and concluded that the Project may have significant impacts on special-status species. Dr. Smallwood’s comments and CV are attached hereto as Exhibit B. Dr. Smallwood’s comments are supported by a site visit by wildlife biologist Noriko Smallwood (“Ms. Smallwood”). (Ex. B, p. 1.) Ms. Smallwood is an expert wildlife ecologist with a focus on urban ecology, avian ecology, and habitat conservation. Ms.

Smallwood visited the site for approximately 4.5 hours on May 9, 2024, starting at 6:15 am. (Id.) She walked the site’s perimeter, using binoculars and camera to scan for and photograph wildlife. (Id.)
A. The Project May Have Significant Impacts on Special Status Species.

An EIR is required because there is substantial evidence establishing a fair argument that the Project may have significant adverse impacts on special status species. Dr. Smallwood concluded that the Project may have significant impacts on biological resources. (Ex. B, p. 1.) Ms. Smallwood also detected the Lawrence’s goldfinch (Spinus lawrencei), which is classified as “Birds of Conservation Concern”, calling near the site1 (Id.) Birds of Conservation
Concern include “migratory nongame birds that without additional conservation action are likely to become candidates for listing under the Endangered Species Act (ESA) of 1973.”2 Ms.

Smallwood further detected a Southern grasshopper mouse (Onychomys torridus ramona), a “California Species of Special Concern”, captured as prey in a raven’s bill. (Id.)3 Altogether,
these species are considered “Special Status Species”, a universal term used in the scientific community for species that are considered sufficiently rare that they require special consideration 1 See, US Fish & Wildlife Service (“USFW”), Birds of Conservation Concern 2021, pp. 18-19 https://www.fws.gov/sites/default/files/documents/birds-of-conservation-concern-2021.pdf. 2 Id., p. 4. 3 Taxa of animals identified by the CDFW as a Species of Special Concern. See, https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109406&inline. 1 (cont).

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and/or protection and should be, or have been, listed as rare, threatened, or endangered by the Federal and/or State governments.”4
Dr. Smallwood concludes that the Project may have a substantial adverse effect on these special status species, either directly due to traffic collisions or through the habitat modifications stemming from the Project. Dr. Smallwood also concludes that the Project may fragment the few remaining habitat for special status species, disturb their reproductive capacity, increase mortality due to traffic collisions, and overall impede their movement. (Ex. B, pp. 20-33.) Dr.

Smallwood’s findings constitute substantial evidence of a fair argument that the Project may have an adverse effect on special status species.

1. The Project May Have Significant Impact on Wildlife Movement.

The MND’s analysis of the Project’s impacts to wildlife movement is flawed. The MND claims that the “Project Area does is situated in an urbanized area and does not represent a wildlife movement corridor as it (along with other small neighboring vacant lots) is largely bound on all sides by developments, possesses vegetation that is largely non-native that would support high levels of species diversity, and it is too small of an area to support significant wildlife movement. This Project Area does not connect large areas of native habitats and development at this site would not preclude wildlife movement in otherwise open areas.” (General Biological Resources Assessment, p. 12.) However, the proper standard under CEQA is whether the Project would “[i]nterfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors.” (MND, p. 60.) As Dr. Smallwood notes, the conclusion reached in one portion of the assessment is inconsistent with its own description of how a wildlife corridor can be constructed because the MND also acknowledges that wildlife corridors can also constitute “discontinuous areas of habitat” much like the Project site’s relationship to the area (General Biological Resources Assessment, p. 12.)
The MND relies on the conclusion that the Project site is not located in any wildlife corridor, but such finding is inconclusive of whether the Project site would substantially interfere with wildlife movement. As Dr. Smallwood notes, “[t]he primary phrase of the CEQA standard goes to wildlife movement regardless of whether the movement is channeled by a corridor. In fact, a site such as the project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol [citations omitted].” (Ex. B, p. 27.) Conversely, Ms. Smallwood’s in-person site visit yielded findings that contradict MIG’s assessment, as evidenced by the wildlife species she photographed perching on and flying over the Project site. (Id., p. 12.)
4 Sacramento County, Planning and Environmental Review, “Special Status Species,” https://planning.saccounty.net/InterestedCitizens/Pages/ER_SpecialStatusSpecies.

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Given the documented use by wildlife species of the Project site and aerosphere for movement, Dr. Smallwood concludes that the Project may have adverse impacts on wildlife movement. An EIR is required to analyze and mitigate this impact.

2. Habitat Loss and Fragmentation.

The Project may adversely affect the special status species identified because the Project will result in direct loss of habitat. Habitat loss and fragmentation impede the movement of wildlife species, thereby exacerbating an area’s productive capacity. In particular, “[h]abitat loss results in diminished productive capacity of affected wildlife species, but MIG (2023a) and the IS/MND make no attempt to estimate this lost capacity for any of the wildlife species potentially affected.” (Ex. B, p. 26.) Dr. Smallwood calculated that the Project would result in a reduction of approximately 50 nest sites and 70 nest attempts annually. (Id.) Given that the area has already undergone severe habitat fragmentation, proceeding with this Project would only further exacerbate the habitat loss and the area’s productive capacity for wildlife species. As such, an EIR is necessary to ensure the wildlife impacts from habitat loss and fragmentation is mitigated to the fullest extent.

3. Traffic/Window Collisions.

The Project may have significant impacts related to window collisions that the MND fails to evaluate. The Project will include glass facades that would intercept with and potentially kill bird species that rely on the surrounding aerosphere. (Ex. B, p. 28.) “The aerosphere is where birds and bats and other volant animals with wings migrate, disperse, forage, perform courtship and where some of them mate…Many special-status species of birds have been recorded at or near the aerosphere of the project site, and Noriko saw many birds using the aerosphere while she surveyed the site. Bird-window collision mortality is a potentially significant impact that warrants analysis.” (Id.)
Despite numerous studies emphasizing the significant impacts that buildings have on bird species, the MND does not analyze the extent to which the Project’s use of windows would have on bird species utilizing the existing aerosphere. In response, Dr. Smallwood reviewed the Project renderings and predicts that the Project may lead to 609 annual bird deaths. (Ex. B, p.

30.)
The Project may also have an adverse effect on wildlife species movement due to traffic collisions. According to the MND, the Project’s annual vehicle miles traveled (“VMT”) is 7,131,868. (Appendix E, p. 4.) As a result, Dr. Smallwood estimates that collisions with vehicles as a result of the Project would kill approximately 3,908 vertebrate wildlife fatalities per year. (Ex. B, p. 32.) Especially due to the special-status species likely to occur at or near the Project, these collisions represent an adverse impact to wildlife that has not been discussed or mitigated in the MND. Dr. Smallwood’s calculations constitute substantial evidence of a fair argument of significant impacts and must be addressed in an EIR.

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Since there is substantial evidence of a fair argument that the Project may have adverse biological impacts, as it relates to movement, habitat loss/fragmentation, and wildlife collisions/mortalities, an EIR is required to analyze these impacts and propose feasible mitigation measures. Dr. Smallwood suggests multiple mitigation measures related to protecting wildlife from traffic, funding wildlife rehabilitation facilities, and applying native landscaping on the Project site. (Ex. B, p. 36.) These mitigation measures should be analyzed in an EIR and incorporated where feasible. Unless and until such impacts are addressed and mitigated, the City cannot proceed with any further approvals.

III. The MND’s Proposed Mitigation Measures are Ineffective, Unenforceable, and Infeasible.

A public agency may not rely on mitigation measures of uncertain efficacy or feasibility. (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 727 [finding groundwater purchase agreement inadequate mitigation measure because no record evidence existed that replacement water was available].) “Feasible” means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social and technological factors. (14 CCR § 15364.) Mitigation measures must be fully enforceable through permit conditions, agreements, or other legally binding instruments. (14 CCR § 15126.4(a)(2).)
The MND concludes that Project-specific impacts will be less than significant with the implementation of mitigation measures. However, the MND’s proposed mitigation measures are ineffective and there is no guarantee that implementation of these mitigation measures will reduce potentially significant biological resources impacts to a level below significance.

B. The IS/MND Fails to Adequately Describe the Project’s Environmental Setting.

The City inadequately characterized the existing environmental setting and the site’s ability to provide habitat for special-status species. Every CEQA document must start from a “baseline” assumption. The CEQA “baseline” is the set of environmental conditions against which to compare a project’s anticipated impacts. (Communities for a Better Envt. v. So. Coast Air Qual. Mgmt. Dist. (2010) 48 Cal. 4th 310, 321.) Section 15125(a) of the CEQA Guidelines (14 C.C.R., § 15125(a)) states in pertinent part that a lead agency’s environmental review under CEQA:
“…must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time [environmental analysis] is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a Lead Agency determines whether an impact is significant.” (emphasis added.)
(See, Save Our Peninsula Committee v. County of Monterey (2001) 87 Cal.App.4th 99, 124- 125.) As the court of appeal has explained, “the impacts of the project must be measured against Redlands Regular Meeting of 12-03-24 643 of 875
the ‘real conditions on the ground,’” and not against hypothetical permitted levels. (Save Our Peninsula, supra, 87 Cal.App.4th 99, 121-123.)

1. The Field Surveys Prepared for the MND are Unreliable.

The field survey prepared by the City’s expert, MIG, which was used to inform the environmental setting, is deficient. MIG’s survey combined both a reconnaissance survey as well as a more-specific burrowing owl survey, which is a concern because Dr. Smallwood explains that the combined survey “cannot be expected to achieve” fulfilling the multiple objectives satisfactorily. (Ex. B, p. 16.) This is evidenced, for example, by the fact that MIG’s survey did not fulfill the minimum requirements outlined under the California Department of Fish and Wildlife (“CDFW”) for surveying burrowing owls. (Id., p. 16.) For instance, the survey did not prepare any habitat assessments prior to the breeding-season survey nor were any surveys actually performed prior to April 15. (Id.) Moreover, the reconnaissance survey did not report for any other special-status species that potentially occur on the Project site despite conceding that many special-status species occur or have the potential to occur on the Project site. (Id.) MIG’s failure to include the methodological details or statement of objectives that shaped the survey findings is alarming because such information is essential “to characterize the environmental setting as a basis for opining on, or predicting, potential project impacts to biological resources.” (Ex. B, pp. 15-16.) Dr. Smallwood concludes that the Project site has not been adequately surveyed “to obtain a representative sample of the wildlife community,” explaining that additional surveys would yield more detections. (Id., p. 16.) For example, Ms.

Smallwood observed 28 species of vertebrate wildlife at and/or near the Project site, and at least three of which were special-status species. (Id., p. 2.) Comparatively, however, Ms. Smallwood detected 13 species that MIG’s report did not, while MIG identified five species that Ms.

Smallwood did not – a combined total of 33 species. (Id., p. 16.) The clear disparities between what MIG’s and Ms. Smallwood’s surveys as well as the unclear method in which the surveys were conducted and documented render the resulting environmental setting unreliable for the purposes of determining the Project baseline.

2. The MND’s Reliance on an Improper Desktop Survey is Erroneous.

The desktop survey performed by MIG is misleading, making the resulting MND document inaccurate. From the onset, MIG narrowed its survey of special-status species because the Project site does not include essential habitat, low occurrences of species based on distributional range, limited nesting and foraging, and the disturbance of the Project site. (General Biological Resources Assessment, p. 11.) This decision by MIG has led to unreliable and speculative determinations as a result.

First, the MND is incorrect in concluding that the disturbed conditions of the Project site mean that there is no suitable habitat on it. As evidenced by Ms. Smallwood, disturbances to the site, such as the disking event Ms. Smallwood witnessed, uncovered the species diversity of the Project site. Disturbance of the area highlighted the numerous wildlife species, including specialstatus species, that inhabit and rely on the Project site for foraging, hunting, and cover from Redlands Regular Meeting of 12-03-24 644 of 875
predators. (See generally, Ex. B, Photos 1-31.) Furthermore, even MIG’s survey detected a longtailed weasel, a discovery that Dr. Smallwood indicates “is not a type of animal that would occur in a wildlife community that has been suppressed by disturbance, as the IS/MND repeatedly claims as a leading reason that the Project site should not be expected to support special-status species.” (Id., p. 16.)
Additionally, the MIG improperly relied on the California Natural Diversity Database (“CNDDB”) because CNDDB “is not designed to support absence determinations or to screen out species from characterization of a site’s wildlife community…There are many areas of the state where no surveys have been conducted” but “that does not mean that there are no special status species present.” (Ex. B, p. 18.) As such, Dr. Smallwood concludes that reliance on CNDDB to establish a reconnaissance survey for special-status species is flawed. (Id.) Given the abundance of wildlife detected on the Project site, including those identified as special-status species, the MND’s determinations on environmental impacts relies on an unreliable and misleading analysis of the Project’s environmental setting. Therefore, the IS/MND fails to accurately describe the Project’s environmental setting. Dr. Smallwood recommends preparing additional, and more detailed, surveys in order to better capture the existing environmental setting and site conditions for wildlife species.

1. Mitigation Measure BIO-1 is an Ineffective Mitigation Measure.

The MND proposes Mitigation Measure BIO-1 (Pre-construction Survey for Nesting Birds) in response to the Project site’s potential to host ground- and tree-nesting bird nests protected by state law. (Cal. Fish and Game Code (“CFGC”) §§ 3503, 3503.5, and 3512.) This mitigation measure explains that “[t]o the extent feasible, construction activities should be scheduled to avoid the nesting season. If construction activities are scheduled to take place outside the nesting season, all impacts to nesting birds protected under the MBTA and California Fish and Game Code would be avoided.” (MND, p. 63.)
Dr Smallwood underlines that the proposed preconstruction surveys are ineffective because bird species have varying nesting seasons. (Ex. B, p. 34.) Additionally, pre-construction surveys are intended as a follow-up to a breeding season detection survey. As Dr. Smallwood emphasizes, no breeding-season detection surveys that meet CDFW standards have been prepared for the Project site. (Id.) This means that the measure’s protections will not extend to future breeding seasons and would likely lead to the permanent destruction of the site’s productive capacity for burrowing owls. (Id., pp. 34-35.) Even if a pre-construction detection survey was prepared, Dr. Smallwood opines that it would achieve very little. Dr. Smallwood explains that “[w]henever a preconstruction survey is conducted, its biologists would be searching only for the nests of the birds that happen to be breeding at the time and would miss the nests begun between the survey and the state of construction.” (Ex. B, p. 34.) Dr. Smallwood further explains that even with the implementation of BIO-1, preconstruction surveys will not mitigate the significant impacts related to the loss of Redlands Regular Meeting of 12-03-24 645 of 875
productive capacity on the Project site. “All subsequent years of productivity would be destroyed by the project regardless of the success of a preconstruction survey.” (Id.) Furthermore, the contours of Mitigation Measure BIO-1 would allow unfettered control for a biologist to make critical determinations about the adequacy of surveying for nesting birds.

This mitigation measure lacks objective criteria because the language allows a single individual (qualified biologist) “to make a subjective decision, outside the public’s view, to determine the buffer area within stated maxima for any given species. (Ex. B, p. 34.) Mitigation Measure BIO1 therefore violates CEQA’s requirements for mitigation measures.

2. Mitigation Measure BIO-2 is an Ineffective Mitigation Measure.

Mitigation Measure BIO-2 (Pre-construction Survey for Burrowing Owls) proposes that “[n]o more than 14 days prior to ground disturbance a focused survey for burrowing owl will be required to ensure take avoidance.” (MND, p. 64.) This mitigation measure is similarly ineffective for a variety of reasons. Much like Mitigation Measure BIO-1 above, no breedingseason detection surveys have been performed on the Project site. (Ex. B, p. 34.) Therefore, relying on a mitigation measure for pre-construction surveys to be conducted without first having done any breeding-season detection surveys renders Mitigation Measure BIO-2 ineffective.

IV. The MND Fails to Adequately Address the Project’s Cumulative Impacts on Biological Resources.

A project may have a significant effect on the environment if “the possible effects of a project are individually limited but cumulatively considerable. . . . ‘Cumulatively considerable’ means that the incremental effects of an individual 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.” “Cumulative impacts” are defined as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” (CEQA Guidelines section 15355(a).) “[I]ndividual effects may be changes resulting from a single project or a number of separate projects.” (CEQA Guidelines section 15355(a).)
The MND concludes that the Project would not have any cumulative impacts with mitigation implemented, and that therefore, “the project would not contribute considerably to regional impacts on such species.” (MND, p. 124.) However, the discussion of cumulative impacts to wildlife is flawed because the MND falsely assumes that cumulative impacts are “really residual impacts left over by inadequate mitigation of project impacts.” (Ex. B, p.33.) This is not the standard under CEQA. Under CEQA, individually insignificant impacts can nevertheless be cumulatively considerable.

Dr. Smallwood asserts that the Project may have cumulative impacts on biological resources due to the exacerbation of habitat fragmentation in the area, increased mortality rates of wildlife due to window and traffic collisions, and the decreased productive capacity of the region. (Ex. B, p. 33.) None of these impacts were adequately reviewed, therefore Redlands Regular Meeting of 12-03-24 646 of 875
underestimating the cumulative impacts that this Project may have. Furthermore, and as explained above, the proposed mitigation measures to address biological resources impacts are ineffective. As such, even with implementation of mitigation, the Project may still contribute considerably to wildlife impacts locally and in the region.

Thus, the MND’s conclusion that the cumulative impacts would be less than significant is unfounded and should be revised in an EIR.

CONCLUSION
For the reasons set forth above, SAFER respectfully requests that the City prepare and circulate an EIR for the Project prior to approval.

Sincerely,

Marjan R. Abubo

LOZEAU DRURY LLP
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Exhibit A
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IEE INDOOR ENVIRONMENTAL ENGINEERING IEE
1448 Pine Street, Suite 103 San Francisco, California 94109 Telephone: (415) 567-7700
E-mail: [email protected]
http://www.iee-sf.com
Date: May 15, 2024
To: Marjan R. Abubo
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, California 94612
From: Francis J. Offermann PE CIH
Subject: Indoor Air Quality: The Tennessee Village Mixed-Use Project, Redlands, CA. (IEE File Reference: P-4803
Pages: 19
Indoor Air Quality Impacts
Indoor air quality (IAQ) directly impacts the comfort and health of building occupants, and the achievement of acceptable IAQ in newly constructed and renovated buildings is a well-recognized design objective. For example, IAQ is addressed by major highperformance building rating systems and building codes (California Building Standards Commission, 2014; USGBC, 2014). Indoor air quality in homes is particularly important because occupants, on average, spend approximately ninety percent of their time indoors with the majority of this time spent at home (EPA, 2011). Some segments of the population that are most susceptible to the effects of poor IAQ, such as the very young and the elderly, occupy their homes almost continuously. Additionally, an increasing number of adults are working from home at least some of the time during the workweek.

Indoor air quality also is a serious concern for workers in hotels, offices and other business establishments.

The concentrations of many air pollutants often are elevated in homes and other buildings relative to outdoor air because many of the materials and products Redlands Regular Meeting of 12-03-24 649 of 875
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used indoors contain and release a variety of pollutants to air (Hodgson et al., 2002; Offermann and Hodgson, 2011). With respect to indoor air contaminants for which inhalation is the primary route of exposure, the critical design and construction parameters are the provision of adequate ventilation and the reduction of indoor sources of the contaminants.

Indoor Formaldehyde Concentrations Impact. In the California New Home Study (CNHS) of 108 new homes in California (Offermann, 2009), 25 air contaminants were measured, and formaldehyde was identified as the indoor air contaminant with the highest cancer risk as determined by the California Proposition 65 Safe Harbor Levels (OEHHA, 2017a), No Significant Risk Levels (NSRL) for carcinogens. The NSRL is the daily intake level calculated to result in one excess case of cancer in an exposed population of 100,000 (i.e., ten in one million cancer risk) and for formaldehyde is 40 µg/day. The NSRL concentration of formaldehyde that represents a daily dose of 40 µg is 2 µg/m3, assuming a continuous 24-hour exposure, a total daily inhaled air volume of 20 m3, and 100% absorption by the respiratory system. All of the CNHS homes exceeded this NSRL concentration of 2 µg/m3. The median indoor formaldehyde concentration was 36 µg/m3, and ranged from 4.8 to 136 µg/m3 , which corresponds to a median exceedance of the 2
µg/m3 NSRL concentration of 18 and a range of 2.3 to 68.

Therefore, the cancer risk of a resident living in a California home with the median indoor formaldehyde concentration of 36 µg/m3, is 180 per million as a result of formaldehyde alone. The CEQA significance threshold for airborne cancer risk is 10 per million, as established by the San Diego County Air Pollution Control District (SDAPCD, 2021).

Besides being a human carcinogen, formaldehyde is also a potent eye and respiratory irritant. In the CNHS, many homes exceeded the non-cancer reference exposure levels (RELs) prescribed by California Office of Environmental Health Hazard Assessment (OEHHA, 2017b). The percentage of homes exceeding the RELs ranged from 98% for the Chronic REL of 9 µg/m3 to 28% for the Acute REL of 55 µg/m3.

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The primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.

In January 2009, the California Air Resources Board (CARB) adopted an airborne toxics control measure (ATCM) to reduce formaldehyde emissions from composite wood products, including hardwood plywood, particleboard, medium density fiberboard, and also furniture and other finished products made with these wood products (California Air Resources Board 2009). While this formaldehyde ATCM has resulted in reduced emissions from composite wood products sold in California, they do not preclude that homes built with composite wood products meeting the CARB ATCM will have indoor formaldehyde concentrations below cancer and non-cancer exposure guidelines.

A follow up study to the California New Home Study (CNHS) was conducted in 2016- 2018 (Singer et. al., 2019), and found that the median indoor formaldehyde in new homes built after 2009 with CARB Phase 2 Formaldehyde ATCM materials had lower indoor formaldehyde concentrations, with a median indoor concentrations of 22.4 µg/m3 (18.2 ppb) as compared to a median of 36 µg/m3 found in the 2007 CNHS. Unlike in the CNHS study where formaldehyde concentrations were measured with pumped DNPH samplers, the formaldehyde concentrations in the HENGH study were measured with passive samplers, which were estimated to under-measure the true indoor formaldehyde concentrations by approximately 7.5%. Applying this correction to the HENGH indoor formaldehyde concentrations results in a median indoor concentration of 24.1 µg/m3 , which is 33% lower than the 36 µg/m3
found in the 2007 CNHS.

Thus, while new homes built after the 2009 CARB formaldehyde ATCM have a 33% lower median indoor formaldehyde concentration and cancer risk, the median lifetime cancer risk is still 120 per million for homes built with CARB compliant composite wood products. This median lifetime cancer risk is more than 12 times the OEHHA 10 in a million cancer risk threshold (OEHHA, 2017a).

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With respect to the Tennessee Village Mixed-Use Project, Redlands, CA, the buildings consist of residential and commercial spaces.

The residential occupants will potentially have continuous exposure (e.g. 24 hours per day, 52 weeks per year). These exposures are anticipated to result in significant cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in residential construction.

Because these residences will be constructed with CARB Phase 2 Formaldehyde ATCM materials, and be ventilated with the minimum code required amount of outdoor air, the indoor residential formaldehyde concentrations are likely similar to those concentrations observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which is a median of 24.1 µg/m3 (Singer et. al., 2020)
Assuming that the residential occupants inhale 20 m3 of air per day, the average 70-year lifetime formaldehyde daily dose is 482 µg/day for continuous exposure in the residences. This exposure represents a cancer risk of 120 per million, which is more than 12 times the CEQA cancer risk of 10 per million. For occupants that do not have continuous exposure, the cancer risk will be proportionally less but still substantially over the CEQA cancer risk of 10 per million (e.g. for 12/hour/day occupancy, more than 6 times the CEQA cancer risk of 10 per million).

The employees of the commercial spaces are expected to experience significant indoor exposures (e.g., 40 hours per week, 50 weeks per year). These exposures for employees are anticipated to result in significant cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in offices, warehouses, residences and hotels.

Because the commercial spaces will be constructed with CARB Phase 2 Formaldehyde ATCM materials and ventilated with the minimum code required amount of outdoor air, the indoor formaldehyde concentrations are likely similar to those concentrations observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which Redlands Regular Meeting of 12-03-24 652 of 875
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is a median of 24.1 µg/m3 (Singer et. al., 2020)
Assuming that the employees of commercial spaces work 8 hours per day and inhale 20 m3 of air per day, the formaldehyde dose per work-day at the offices is 161 µg/day.

Assuming that these employees work 5 days per week and 50 weeks per year for 45 years (start at age 20 and retire at age 65) the average 70-year lifetime formaldehyde daily dose is 70.9 µg/day.

This is 1.77 times the NSRL (OEHHA, 2017a) of 40 µg/day and represents a cancer risk of 17.7 per million, which exceeds the CEQA cancer risk of 10 per million. This impact should be analyzed in an environmental impact report (“EIR”), and the agency should impose all feasible mitigation measures to reduce this impact. Several feasible mitigation measures are discussed below and these and other measures should be analyzed in an EIR.

In addition, we note that the average outdoor air concentration of formaldehyde in California is 3 ppb, or 3.7 µg/m3, (California Air Resources Board, 2004), and thus represents an average pre-existing background airborne cancer risk of 1.85 per million.

Thus, the indoor air formaldehyde exposures describe above exacerbate this pre-existing risk resulting from outdoor air formaldehyde exposures.

Additionally, the SCAQMD’s Multiple Air Toxics Exposure Study (“MATES V”) identifies an existing cancer risk at the Project site of 401 per million due to the site’s elevated ambient air contaminant concentrations, which are due to the area’s high levels of vehicle traffic. These impacts would further exacerbate the pre-existing cancer risk to the building occupants, which result from exposure to formaldehyde in both indoor and outdoor air.

Appendix A, Indoor Formaldehyde Concentrations and the CARB Formaldehyde ATCM, provides analyses that show utilization of CARB Phase 2 Formaldehyde ATCM materials will not ensure acceptable cancer risks with respect to formaldehyde emissions from Redlands Regular Meeting of 12-03-24 653 of 875
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composite wood products.

Even composite wood products manufactured with CARB certified ultra low emitting formaldehyde (ULEF) resins do not insure that the indoor air will have concentrations of formaldehyde the meet the OEHHA cancer risks that substantially exceed 10 per million.

The permissible emission rates for ULEF composite wood products are only 11-15% lower than the CARB Phase 2 emission rates. Only use of composite wood products made with no-added formaldehyde resins (NAF), such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

The following describes a method that should be used, prior to construction in the environmental review under CEQA, for determining whether the indoor concentrations resulting from the formaldehyde emissions of specific building materials/furnishings selected exceed cancer and non-cancer guidelines. Such a design analyses can be used to identify those materials/furnishings prior to the completion of the City’s CEQA review and project approval, that have formaldehyde emission rates that contribute to indoor concentrations that exceed cancer and non-cancer guidelines, so that alternative lower emitting materials/furnishings may be selected and/or higher minimum outdoor air ventilation rates can be increased to achieve acceptable indoor concentrations and incorporated as mitigation measures for this project.

Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment This formaldehyde emissions assessment should be used in the environmental review under CEQA to assess the indoor formaldehyde concentrations from the proposed loading of building materials/furnishings, the area-specific formaldehyde emission rate data for building materials/furnishings, and the design minimum outdoor air ventilation rates. This assessment allows the applicant (and the City) to determine, before the conclusion of the environmental review process and the building materials/furnishings are specified, purchased, and installed, if the total chemical emissions will exceed cancer and non-cancer guidelines, and if so, allow for changes in the selection of specific Redlands Regular Meeting of 12-03-24 654 of 875
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material/furnishings and/or the design minimum outdoor air ventilations rates such that cancer and non-cancer guidelines are not exceeded.

1.) Define Indoor Air Quality Zones. Divide the building into separate indoor air quality zones, (IAQ Zones). IAQ Zones are defined as areas of well-mixed air. Thus, each ventilation system with recirculating air is considered a single zone, and each room or group of rooms where air is not recirculated (e.g. 100% outdoor air) is considered a separate zone. For IAQ Zones with the same construction material/furnishings and design minimum outdoor air ventilation rates. (e.g. hotel rooms, apartments, condominiums, etc.) the formaldehyde emission rates need only be assessed for a single IAQ Zone of that type.

2.) Calculate Material/Furnishing Loading. For each IAQ Zone, determine the building material and furnishing loadings (e.g., m2 of material/m2 floor area, units of furnishings/m2 floor area) from an inventory of all potential indoor formaldehyde sources, including flooring, ceiling tiles, furnishings, finishes, insulation, sealants, adhesives, and any products constructed with composite wood products containing urea-formaldehyde resins (e.g., plywood, medium density fiberboard, particleboard).

3.) Calculate the Formaldehyde Emission Rate. For each building material, calculate the formaldehyde emission rate (µg/h) from the product of the area-specific formaldehyde emission rate (µg/m2-h) and the area (m2) of material in the IAQ Zone, and from each furnishing (e.g. chairs, desks, etc.) from the unit-specific formaldehyde emission rate (µg/unit-h) and the number of units in the IAQ Zone.

NOTE: As a result of the high-performance building rating systems and building codes (California Building Standards Commission, 2014; USGBC, 2014), most manufacturers of building materials furnishings sold in the United States conduct chemical emission rate tests using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers,” (CDPH, 2017), or other equivalent chemical emission rate testing methods. Most manufacturers of building furnishings sold in the United States conduct chemical emission rate tests using ANSI/BIFMA M7.1 Standard Test Method for Redlands Regular Meeting of 12-03-24 655 of 875
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Determining VOC Emissions (BIFMA, 2018), or other equivalent chemical emission rate testing methods.

CDPH, BIFMA, and other chemical emission rate testing programs, typically certify that a material or furnishing does not create indoor chemical concentrations in excess of the maximum concentrations permitted by their certification. For instance, the CDPH emission rate testing requires that the measured emission rates when input into an office, school, or residential model do not exceed one-half of the OEHHA Chronic Exposure Guidelines (OEHHA, 2017b) for the 35 specific VOCs, including formaldehyde, listed in Table 4-1 of the CDPH test method (CDPH, 2017). These certifications themselves do not provide the actual area-specific formaldehyde emission rate (i.e., µg/m2-h) of the product, but rather provide data that the formaldehyde emission rates do not exceed the maximum rate allowed for the certification. Thus, for example, the data for a certification of a specific type of flooring may be used to calculate that the area-specific emission rate of formaldehyde is less than 31 µg/m2-h, but not the actual measured specific emission rate, which may be 3, 18, or 30 µg/m2-h. These area-specific emission rates determined from the product certifications of CDPH, BIFA, and other certification programs can be used as an initial estimate of the formaldehyde emission rate.

If the actual area-specific emission rates of a building material or furnishing is needed (i.e. the initial emission rates estimates from the product certifications are higher than desired), then that data can be acquired by requesting from the manufacturer the complete chemical emission rate test report. For instance if the complete CDPH emission test report is requested for a CDHP certified product, that report will provide the actual areaspecific emission rates for not only the 35 specific VOCs, including formaldehyde, listed in Table 4-1 of the CDPH test method (CDPH, 2017), but also all of the cancer and reproductive/developmental chemicals listed in the California Proposition 65 Safe Harbor Levels (OEHHA, 2017a), all of the toxic air contaminants (TACs) in the California Air Resources Board Toxic Air Contamination List (CARB, 2011), and the 10 chemicals with the greatest emission rates.

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Alternatively, a sample of the building material or furnishing can be submitted to a chemical emission rate testing laboratory, such as Berkeley Analytical Laboratory (https://berkeleyanalytical.com), to measure the formaldehyde emission rate.

4.) Calculate the Total Formaldehyde Emission Rate. For each IAQ Zone, calculate the total formaldehyde emission rate (i.e. µg/h) from the individual formaldehyde emission rates from each of the building material/furnishings as determined in Step 3.

5.) Calculate the Indoor Formaldehyde Concentration. For each IAQ Zone, calculate the indoor formaldehyde concentration (µg/m3) from Equation 1 by dividing the total formaldehyde emission rates (i.e. µg/h) as determined in Step 4, by the design minimum outdoor air ventilation rate (m3/h) for the IAQ Zone. (Equation 1) where:

Cin = indoor formaldehyde concentration (µg/m3)
Etotal = total formaldehyde emission rate (µg/h) into the IAQ Zone.

Qoa = design minimum outdoor air ventilation rate to the IAQ Zone (m3/h) The above Equation 1 is based upon mass balance theory, and is referenced in Section

3.10.2 “Calculation of Estimated Building Concentrations” of the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers”, (CDPH, 2017).

6.) Calculate the Indoor Exposure Cancer and Non-Cancer Health Risks. For each IAQ Zone, calculate the cancer and non-cancer health risks from the indoor formaldehyde concentrations determined in Step 5 and as described in the OEHHA Air Toxics Hot Spots Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk Assessments (OEHHA, 2015).

7.) Mitigate Indoor Formaldehyde Exposures of exceeding the CEQA Cancer and/or Non-Cancer Health Risks. In each IAQ Zone, provide mitigation for any formaldehyde exposure risk as determined in Step 6, that exceeds the CEQA cancer risk of 10 per Redlands Regular Meeting of 12-03-24 657 of 875
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million or the CEQA non-cancer Hazard Quotient of 1.0.

Provide the source and/or ventilation mitigation required in all IAQ Zones to reduce the health risks of the chemical exposures below the CEQA cancer and non-cancer health risks.

Source mitigation for formaldehyde may include:

1.) reducing the amount materials and/or furnishings that emit formaldehyde

2.) substituting a different material with a lower area-specific emission rate of formaldehyde
Ventilation mitigation for formaldehyde emitted from building materials and/or furnishings may include:

1.) increasing the design minimum outdoor air ventilation rate to the IAQ Zone.

NOTE: Mitigating the formaldehyde emissions through use of less material/furnishings, or use of lower emitting materials/furnishings, is the preferred mitigation option, as mitigation with increased outdoor air ventilation increases initial and operating costs associated with the heating/cooling systems.

Further, we are not asking that the builder “speculate” on what and how much composite materials be used, but rather at the design stage to select composite wood materials based on the formaldehyde emission rates that manufacturers routinely conduct using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers,” (CDPH, 2017), and use the procedure described earlier above (i.e. PreConstruction Building Material/Furnishing Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Outdoor Air Ventilation Impact. Another important finding of the CNHS, was that the outdoor air ventilation rates in the homes were very low. Outdoor air ventilation is a very Redlands Regular Meeting of 12-03-24 658 of 875
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important factor influencing the indoor concentrations of air contaminants, as it is the primary removal mechanism of all indoor air generated contaminants. Lower outdoor air exchange rates cause indoor generated air contaminants to accumulate to higher indoor air concentrations. Many homeowners rarely open their windows or doors for ventilation as a result of their concerns for security/safety, noise, dust, and odor concerns (Price, 2007). In the CNHS field study, 32% of the homes did not use their windows during the 24‐hour Test Day, and 15% of the homes did not use their windows during the entire preceding week. Most of the homes with no window usage were homes in the winter field session.

Thus, a substantial percentage of homeowners never open their windows, especially in the winter season. The median 24‐hour measurement was 0.26 air changes per hour (ach), with a range of 0.09 ach to 5.3 ach. A total of 67% of the homes had outdoor air exchange rates below the minimum California Building Code (2001) requirement of 0.35 ach. Thus, the relatively tight envelope construction, combined with the fact that many people never open their windows for ventilation, results in homes with low outdoor air exchange rates and higher indoor air contaminant concentrations.

The Tennessee Village Mixed-Use Project, Redlands, CA is close to roads with moderate to high traffic (e.g., Tennessee Street, W. Lugonia Avenue, Foothill Freeway-210, San Bernadino Avenue, etc.). Thus, the Project is located in a sound impacted area.

According to the Initial Study and Mitigated Negative Declaration - The Tennessee Village Mixed-Use Project, Redlands, CA (MIG Inc. 2024), there have only been shortterm (i.e., 3.5-4.0 hours) on Tuesday, December 12, 2023. These short-term measurements indicated high ambient noise levels ranging from 60.3 to 70.3 dBA Leq.

In order to design the building for this Project such that interior noise levels are acceptable, an acoustic study with actual on-site measurements of the existing ambient noise levels and modeled future ambient noise levels needs to be conducted. The acoustic study of the existing ambient noise levels should be conducted over a minimum of a oneweek period and report the dBA CNEL or Ldn. This study will allow for the selection of a building envelope and windows with a sufficient STC such that the indoor noise levels are acceptable. A mechanical supply of outdoor air ventilation to allow for a habitable Redlands Regular Meeting of 12-03-24 659 of 875
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interior environment with closed windows and doors will also be required. Such a ventilation system would allow windows and doors to be kept closed at the occupant’s discretion to control exterior noise within building interiors.

PM2.5 Outdoor Concentrations Impact. An additional impact of the nearby motor vehicle traffic associated with this project, are the outdoor concentrations of PM2.5. According to the Initial Study and Mitigated Negative Declaration - The Tennessee Village Mixed-Use Project, Redlands, CA (MIG Inc. 2024), the Project is located in the South Coast Air Basin, which is a State and Federal non-attainment area for PM2.5. Additionally, the SCAQMD’s MATES V study cites an existing cancer risk of 401 per million at the Project site due to the site’s high concentration of ambient air contaminants resulting from the area’s high levels of motor vehicle traffic.

An air quality analyses should be conducted to determine the concentrations of PM2.5 in the outdoor and indoor air that people inhale each day. This air quality analyses needs to consider the cumulative impacts of the project related emissions, existing and projected future emissions from local PM2.5 sources (e.g. stationary sources, motor vehicles, and airport traffic) upon the outdoor air concentrations at the Project site. If the outdoor concentrations are determined to exceed the California and National annual average PM2.5 exceedence concentration of 12 µg/m3 , or the National 24-hour average exceedence
concentration of 35 µg/m3, then the buildings need to have a mechanical supply of outdoor air that has air filtration with sufficient removal efficiency, such that the indoor concentrations of outdoor PM2.5 particles is less than the California and National PM2.5 annual and 24-hour standards.

It is my experience that based on the projected high traffic noise levels, the annual average concentration of PM2.5 will exceed the California and National PM2.5 annual and 24-hour standards and warrant installation of high efficiency air filters (i.e. at least MERV 13, or possibly MERV 14 or 15 depending on the results of the Project ambient PM2.5 concentrations) in all mechanically supplied outdoor air ventilation systems.

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Indoor Air Quality Impact Mitigation Measures
The following are recommended mitigation measures to minimize the impacts upon indoor quality:

Indoor Formaldehyde Concentrations Mitigation. Use only composite wood materials (e.g. hardwood plywood, medium density fiberboard, particleboard) for all interior finish systems that are made with CARB approved no-added formaldehyde (NAF) resins (CARB, 2009). CARB Phase 2 certified composite wood products, or ultra-low emitting formaldehyde (ULEF) resins, do not insure indoor formaldehyde concentrations that are below the CEQA cancer risk of 10 per million. Only composite wood products manufactured with CARB approved no-added formaldehyde (NAF) resins, such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

Alternatively, conduct the previously described Pre-Construction Building Material/Furnishing Chemical Emissions Assessment, to determine that the combination of formaldehyde emissions from building materials and furnishings do not create indoor formaldehyde concentrations that exceed the CEQA cancer and non-cancer health risks.

It is important to note that we are not asking that the builder “speculate” on what and how much composite materials be used, but rather at the design stage to select composite wood materials based on the formaldehyde emission rates that manufacturers routinely conduct using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers”, (CDPH, 2017), and use the procedure described above (i.e.

Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Outdoor Air Ventilation Mitigation. Provide each habitable room with a continuous mechanical supply of outdoor air that meets or exceeds the California 2016 Building Redlands Regular Meeting of 12-03-24 661 of 875
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Energy Efficiency Standards (California Energy Commission, 2015) requirements of the greater of 15 cfm/occupant or 0.15 cfm/ft2 of floor area. Following installation of the system conduct testing and balancing to insure that required amount of outdoor air is entering each habitable room and provide a written report documenting the outdoor airflow rates. Do not use exhaust only mechanical outdoor air systems, use only balanced outdoor air supply and exhaust systems or outdoor air supply only systems. Provide a manual for the occupants or maintenance personnel, that describes the purpose of the mechanical outdoor air system and the operation and maintenance requirements of the system.

PM2.5 Outdoor Air Concentration Mitigation. Install air filtration with sufficient PM2.5 removal efficiency (e.g. MERV 13 or higher) to filter the outdoor air entering the mechanical outdoor air supply systems, such that the indoor concentrations of outdoor PM2.5 particles are less than the California and National PM2.5 annual and 24-hour standards. Install the air filters in the system such that they are accessible for replacement by the occupants or maintenance personnel. Include in the mechanical outdoor air ventilation system manual instructions on how to replace the air filters and the estimated frequency of replacement.

References
BIFA. 2018. BIFMA Product Safety and Performance Standards and Guidelines. www.bifma.org/page/standardsoverview
California Air Resources Board. 2004. Formaldehyde in the Home. https://ww3.arb.ca.gov › research › indoor › formaldgl08-04.pdf California Air Resources Board. 2009. Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products. California Environmental Protection Agency, Sacramento, CA.
https://www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf Redlands Regular Meeting of 12-03-24 662 of 875
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California Air Resources Board. 2011. Toxic Air Contaminant Identification List.

California Environmental Protection Agency, Sacramento, CA. https://www.arb.ca.gov/toxics/id/taclist.htm
California Building Code. 2001. California Code of Regulations, Title 24, Part 2 Volume 1, Appendix Chapter 12, Interior Environment, Division 1, Ventilation, Section 1207:
2001 California Building Code, California Building Standards Commission. Sacramento, CA.

California Building Standards Commission (2014). 2013 California Green Building Standards Code. California Code of Regulations, Title 24, Part 11. California Building Standards Commission, Sacramento, CA http://www.bsc.ca.gov/Home/CALGreen.aspx.

California Energy Commission, PIER Program. CEC-500-2007-033. Final Report, ARB Contract 03-326. Available at: www.arb.ca.gov/research/apr/past/03-326.pdf. California Energy Commission, 2015. 2016 Building Energy Efficiency Standards for Residential and Nonresidential Buildings, California Code of Regulations, Title 24, Part 6. http://www.energy.ca.gov/2015publications/CEC-400-2015-037/CEC-400-2015-037- CMF.pdf
CDPH. 2017. Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers, Version 1.1.

California Department of Public Health, Richmond, CA.
https://www.cdph.ca.gov/Programs/CCDPHP/ DEODC/EHLB/IAQ/Pages/VOC.aspx.

Environmental Impact Report. SCH No. 2018011001.

EPA. 2011. Exposure Factors Handbook: 2011 Edition, Chapter 16 – Activity Factors.

Report EPA/600/R-09/052F, September 2011. U.S. Environmental Protection Agency, Washington, D.C.

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MIG Inc. 2024. Initial Study and Mitigated Negative Declaration - The Tennessee Village Mixed-Use Project, Redlands, CA
OEHHA (Office of Environmental Health Hazard Assessment). 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk Assessments.

OEHHA (Office of Environmental Health Hazard Assessment). 2017a. Proposition 65 Safe Harbor Levels. No Significant Risk Levels for Carcinogens and Maximum Allowable Dose Levels for Chemicals Causing Reproductive Toxicity. Available at:
http://www.oehha.ca.gov/prop65/pdf/safeharbor081513.pdf OEHHA - Office of Environmental Health Hazard Assessment. 2017b. All OEHHA Acute, 8-hour and Chronic Reference Exposure Levels. Available at:
http://oehha.ca.gov/air/allrels.html
Offermann, F. J. 2009. Ventilation and Indoor Air Quality in New Homes. California Air Resources Board and California Energy Commission, PIER Energy‐Related Environmental Research Program. Collaborative Report. CEC-500-2009-085. https://www.arb.ca.gov/research/apr/past/04-310.pdf
Offermann, F. J. and A. T. Hodgson. 2011. Emission Rates of Volatile Organic Compounds in New Homes. Proceedings Indoor Air 2011 (12th International Conference on Indoor Air Quality and Climate 2011), June 5-10, 2011, Austin, TX.

Singer, B.C, Chan, W.R, Kim, Y., Offermann, F.J., and Walker I.S. 2020. Indoor Air Quality in California Homes with Code-Required Mechanical Ventilation. Indoor Air, Vol 30, Issue 5, 885-899.

South Coast Air Quality Management District (SCAQMD). 2015. California Environmental Quality Act Air Quality Handbook. South Coast Air Quality Management Redlands Regular Meeting of 12-03-24 664 of 875
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District, Diamond Bar, CA, http://www.aqmd.gov/home/rules-compliance/ceqa/airquality-analysis-handbook USGBC. 2014. LEED BD+C Homes v4. U.S. Green Building Council, Washington, D.C. http://www.usgbc.org/credits/homes/v4
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APPENDIX A

INDOOR FORMALDEHYDE CONCENTRATIONS

AND THE

CARB FORMALDEHYDE ATCM
With respect to formaldehyde emissions from composite wood products, the CARB ATCM regulations of formaldehyde emissions from composite wood products, do not assure healthful indoor air quality. The following is the stated purpose of the CARB ATCM regulation - The purpose of this airborne toxic control measure is to “reduce formaldehyde emissions from composite wood products, and finished goods that contain composite wood products, that are sold, offered for sale, supplied, used, or manufactured for sale in California”. In other words, the CARB ATCM regulations do not “assure healthful indoor air quality”, but rather “reduce formaldehyde emissions from composite wood products”.

Just how much protection do the CARB ATCM regulations provide building occupants from the formaldehyde emissions generated by composite wood products? Definitely some, but certainly the regulations do not “assure healthful indoor air quality” when CARB Phase 2 products are utilized. As shown in the Chan 2019 study of new California homes, the median indoor formaldehyde concentration was of 22.4 µg/m3 (18.2 ppb), which corresponds to a cancer risk of 112 per million for occupants with continuous exposure, which is more than 11 times the CEQA cancer risk of 10 per million.

Another way of looking at how much protection the CARB ATCM regulations provide building occupants from the formaldehyde emissions generated by composite wood products is to calculate the maximum number of square feet of composite wood product that can be in a residence without exceeding the CEQA cancer risk of 10 per million for occupants with continuous occupancy.

For this calculation I utilized the floor area (2,272 ft2), the ceiling height (8.5 ft), and the number of bedrooms (4) as defined in Appendix B (New Single-Family Residence Scenario) of the Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers, Version 1.1, Redlands Regular Meeting of 12-03-24 666 of 875
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2017, California Department of Public Health, Richmond, CA. https://www.cdph.ca.gov/Programs/CCDPHP/ DEODC/EHLB/IAQ/Pages/VOC.aspx.

For the outdoor air ventilation rate I used the 2019 Title 24 code required mechanical ventilation rate (ASHRAE 62.2) of 106 cfm (180 m3/h) calculated for this model residence.

For the composite wood formaldehyde emission rates I used the CARB ATCM Phase 2 rates.

The calculated maximum number of square feet of composite wood product that can be in a residence, without exceeding the CEQA cancer risk of 10 per million for occupants with continuous occupancy are as follows for the different types of regulated composite wood products.

Medium Density Fiberboard (MDF) – 15 ft2 (0.7% of the floor area), or Particle Board – 30 ft2 (1.3% of the floor area), or
Hardwood Plywood – 54 ft2 (2.4% of the floor area), or
Thin MDF – 46 ft2 (2.0 % of the floor area).

For offices and hotels the calculated maximum amount of composite wood product (% of floor area) that can be used without exceeding the CEQA cancer risk of 10 per million for occupants, assuming 8 hours/day occupancy, and the California Mechanical Code minimum outdoor air ventilation rates are as follows for the different types of regulated composite wood products.

Medium Density Fiberboard (MDF) – 3.6 % (offices) and 4.6% (hotel rooms), or Particle Board – 7.2 % (offices) and 9.4% (hotel rooms), or Hardwood Plywood – 13 % (offices) and 17% (hotel rooms), or Thin MDF – 11 % (offices) and 14 % (hotel rooms)
Clearly the CARB ATCM does not regulate the formaldehyde emissions from composite wood products such that the potentially large areas of these products, such as for flooring, baseboards, interior doors, window and door trims, and kitchen and bathroom cabinetry, Redlands Regular Meeting of 12-03-24 667 of 875
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could be used without causing indoor formaldehyde concentrations that result in CEQA cancer risks that substantially exceed 10 per million for occupants with continuous occupancy.

Even composite wood products manufactured with CARB certified ultra low emitting formaldehyde (ULEF) resins do not insure that the indoor air will have concentrations of formaldehyde the meet the OEHHA cancer risks that substantially exceed 10 per million.

The permissible emission rates for ULEF composite wood products are only 11-15% lower than the CARB Phase 2 emission rates. Only use of composite wood products made with no-added formaldehyde resins (NAF), such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

If CARB Phase 2 compliant or ULEF composite wood products are utilized in construction, then the resulting indoor formaldehyde concentrations should be determined in the design phase using the specific amounts of each type of composite wood product, the specific formaldehyde emission rates, and the volume and outdoor air ventilation rates of the indoor spaces, and all feasible mitigation measures employed to reduce this impact (e.g. use less formaldehyde containing composite wood products and/or incorporate mechanical systems capable of higher outdoor air ventilation rates). See the procedure described earlier (i.e. Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Alternatively, and perhaps a simpler approach, is to use only composite wood products (e.g. hardwood plywood, medium density fiberboard, particleboard) for all interior finish systems that are made with CARB approved no-added formaldehyde (NAF) resins.

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Francis (Bud) J. Offermann III PE, CIH
Indoor Environmental Engineering
1448 Pine Street, Suite 103, San Francisco, CA 94109
Phone: 415-567-7700
Email: [email protected]
http://www.iee-sf.com
Education
M.S. Mechanical Engineering (1985)
Stanford University, Stanford, CA.

Graduate Studies in Air Pollution Monitoring and Control (1980) University of California, Berkeley, CA.

B.S. in Mechanical Engineering (1976)
Rensselaer Polytechnic Institute, Troy, N.Y.

Professional Experience
President: Indoor Environmental Engineering, San Francisco, CA. December, 1981 - present.

Direct team of environmental scientists, chemists, and mechanical engineers in conducting State and Federal research regarding indoor air quality instrumentation development, building air quality field studies, ventilation and air cleaning performance measurements, and chemical emission rate testing.

Provide design side input to architects regarding selection of building materials and ventilation system components to ensure a high quality indoor environment.

Direct Indoor Air Quality Consulting Team for the winning design proposal for the new State of Washington Ecology Department building.

Develop a full-scale ventilation test facility for measuring the performance of air diffusers; ASHRAE 129, Air Change Effectiveness, and ASHRAE 113, Air Diffusion Performance Index.

Develop a chemical emission rate testing laboratory for measuring the chemical emissions from building materials, furnishings, and equipment.

Principle Investigator of the California New Homes Study (2005-2007). Measured ventilation and indoor air quality in 108 new single family detached homes in northern and southern California.

Develop and teach IAQ professional development workshops to building owners, managers, hygienists, and engineers.

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2 Air Pollution Engineer: Earth Metrics Inc., Burlingame, CA, October, 1985 to March, 1987.

Responsible for development of an air pollution laboratory including installation a forced choice olfactometer, tracer gas electron capture chromatograph, and associated calibration facilities. Field team leader for studies of fugitive odor emissions from sewage treatment plants, entrainment of fume hood exhausts into computer chip fabrication rooms, and indoor air quality investigations.

Staff Scientist: Building Ventilation and Indoor Air Quality Program, Energy and Environment Division, Lawrence Berkeley Laboratory, Berkeley, CA. January, 1980 to August, 1984.

Deputy project leader for the Control Techniques group; responsible for laboratory and field studies aimed at evaluating the performance of indoor air pollutant control strategies (i.e. ventilation, filtration, precipitation, absorption, adsorption, and source control).

Coordinated field and laboratory studies of air-to-air heat exchangers including evaluation of thermal performance, ventilation efficiency, cross-stream contaminant transfer, and the effects of freezing/defrosting.

Developed an in situ test protocol for evaluating the performance of air cleaning systems and introduced the concept of effective cleaning rate (ECR) also known as the Clean Air Delivery Rate (CADR).

Coordinated laboratory studies of portable and ducted air cleaning systems and their effect on indoor concentrations of respirable particles and radon progeny.

Co-designed an automated instrument system for measuring residential ventilation rates and radon concentrations.

Designed hardware and software for a multi-channel automated data acquisition system used to evaluate the performance of air-to-air heat transfer equipment.

Assistant Chief Engineer: Alta Bates Hospital, Berkeley, CA, October, 1979 to January, 1980.

Responsible for energy management projects involving installation of power factor correction capacitors on large inductive electrical devices and installation of steam meters on physical plant steam lines. Member of Local 39, International Union of Operating Engineers.

Manufacturing Engineer: American Precision Industries, Buffalo, NY, October, 1977 to October, 1979.

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3 Responsible for reorganizing the manufacturing procedures regarding production of shell and tube heat exchangers. Designed customized automatic assembly, welding, and testing equipment. Designed a large paint spray booth. Prepared economic studies justifying new equipment purchases. Safety Director.

Project Engineer: Arcata Graphics, Buffalo, N.Y. June, 1976 to October, 1977.

Responsible for the design and installation of a bulk ink storage and distribution system and high speed automatic counting and marking equipment. Also coordinated material handling studies which led to the purchase and installation of new equipment.

PROFESSIONAL ORGANIZATION MEMBERSHIP
American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) • Chairman of SPC-145P, Standards Project Committee - Test Method for Assessing the Performance of Gas Phase Air Cleaning Equipment (1991-1992) • Member SPC-129P, Standards Project Committee - Test Method for Ventilation Effectiveness (1986-97)
- Member of Drafting Committee
• Member Environmental Health Committee (1992-1994, 1997-2001, 2007-2010) - Chairman of EHC Research Subcommittee
- Member of Man Made Mineral Fiber Position Paper Subcommittee - Member of the IAQ Position Paper Committee
- Member of the Legionella Position Paper Committee
- Member of the Limiting Indoor Mold and Dampness in Buildings Position Paper Committee
• Member SSPC-62, Standing Standards Project Committee - Ventilation for Acceptable Indoor Air Quality (1992 to 2000)
- Chairman of Source Control and Air Cleaning Subcommittee • Chairman of TC-4.10, Indoor Environmental Modeling (1988-92) - Member of Research Subcommittee
• Chairman of TC-2.3, Gaseous Air Contaminants and Control Equipment (1989-92) - Member of Research Subcommittee
American Society for Testing and Materials (ASTM)
• D-22 Sampling and Analysis of Atmospheres
- Member of Indoor Air Quality Subcommittee
• E-06 Performance of Building Constructions
American Board of Industrial Hygiene (ABIH)
American Conference of Governmental Industrial Hygienists (ACGIH) • Bioaerosols Committee (2007-2013)
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4 American Industrial Hygiene Association (AIHA)
Cal-OSHA Indoor Air Quality Advisory Committee
International Society of Indoor Air Quality and Climate (ISIAQ) • Co-Chairman of Task Force on HVAC Hygiene
U. S. Green Building Council (USGBC)
- Member of the IEQ Technical Advisory Group (2007-2009) - Member of the IAQ Performance Testing Work Group (2010-2012) Western Construction Consultants (WESTCON)

PROFESSIONAL CREDENTIALS
Licensed Professional Engineer - Mechanical Engineering Certified Industrial Hygienist - American Board of Industrial Hygienists

SCIENTIFIC MEETINGS AND SYMPOSIA
Biological Contamination, Diagnosis, and Mitigation, Indoor Air’90, Toronto, Canada, August, 1990.

Models for Predicting Air Quality, Indoor Air’90, Toronto, Canada, August, 1990.

Microbes in Building Materials and Systems, Indoor Air ’93, Helsinki, Finland, July, 1993.

Microorganisms in Indoor Air Assessment and Evaluation of Health Effects and Probable Causes, Walnut Creek, CA, February 27, 1997.

Controlling Microbial Moisture Problems in Buildings, Walnut Creek, CA, February 27, 1997.

Scientific Advisory Committee, Roomvent 98, 6th International Conference on Air Distribution in Rooms, KTH, Stockholm, Sweden, June 14-17, 1998.

Moisture and Mould, Indoor Air ’99, Edinburgh, Scotland, August, 1999.

Ventilation Modeling and Simulation, Indoor Air ’99, Edinburgh, Scotland, August, 1999.

Microbial Growth in Materials, Healthy Buildings 2000, Espoo, Finland, August, 2000.

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5 Co-Chair, Bioaerosols X- Exposures in Residences, Indoor Air 2002, Monterey, CA, July 2002.

Healthy Indoor Environments, Anaheim, CA, April 2003.

Chair, Environmental Tobacco Smoke in Multi-Family Homes, Indoor Air 2008, Copenhagen, Denmark, July 2008.

Co-Chair, ISIAQ Task Force Workshop; HVAC Hygiene, Indoor Air 2002, Monterey, CA, July 2002.

Chair, ETS in Multi-Family Housing: Exposures, Controls, and Legalities Forum, Healthy Buildings 2009, Syracuse, CA, September 14, 2009.

Chair, Energy Conservation and IAQ in Residences Workshop, Indoor Air 2011, Austin, TX, June 6, 2011.

Chair, Electronic Cigarettes: Chemical Emissions and Exposures Colloquium, Indoor Air 2016, Ghent, Belgium, July 4, 2016.

SPECIAL CONSULTATION
Provide consultation to the American Home Appliance Manufacturers on the development of a standard for testing portable air cleaners, AHAM Standard AC-1.

Served as an expert witness and special consultant for the U.S. Federal Trade Commission regarding the performance claims found in advertisements of portable air cleaners and residential furnace filters.

Conducted a forensic investigation for a San Mateo, CA pro se defendant, regarding an alleged homicide where the victim was kidnapped in a steamer trunk. Determined the air exchange rate in the steamer trunk and how long the person could survive.

Conducted in situ measurement of human exposure to toluene fumes released during nailpolish application for a plaintiffs attorney pursuing a California Proposition 65 product labeling case. June, 1993.

Conducted a forensic in situ investigation for the Butte County, CA Sheriff’s Department of the emissions of a portable heater used in the bedroom of two twin one year old girls who suffered simultaneous crib death.

Consult with OSHA on the 1995 proposed new regulation regarding indoor air quality and environmental tobacco smoke.

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6 Consult with EPA on the proposed Building Alliance program and with OSHA on the proposed new OSHA IAQ regulation.

Johnson Controls Audit/Certification Expert Review; Milwaukee, WI. May 28-29, 1997.

Winner of the nationally published 1999 Request for Proposals by the State of Washington to conduct a comprehensive indoor air quality investigation of the Washington State Department of Ecology building in Lacey, WA.

Selected by the State of California Attorney General’s Office in August, 2000 to conduct a comprehensive indoor air quality investigation of the Tulare County Court House.

Lawrence Berkeley Laboratory IAQ Experts Workshop: “Cause and Prevention of Sick Building Problems in Offices: The Experience of Indoor Environmental Quality Investigators”, Berkeley, California, May 26-27, 2004.

Provide consultation and chemical emission rate testing to the State of California Attorney General’s Office in 2013-2015 regarding the chemical emissions from ecigarettes.

PEER-REVIEWED PUBLICATIONS :

F.J.Offermann, C.D.Hollowell, and G.D.Roseme, "Low-Infiltration Housing in Rochester, New York: A Study of Air Exchange Rates and Indoor Air Quality," Environment International, 8, pp. 435-445, 1982.

W.W.Nazaroff, F.J.Offermann, and A.W.Robb, "Automated System for Measuring Air Exchange Rate and Radon Concentration in Houses," Health Physics, 45, pp. 525-537, 1983.

F.J.Offermann, W.J.Fisk, D.T.Grimsrud, B.Pedersen, and K.L.Revzan, "Ventilation Efficiencies of Wall- or Window-Mounted Residential Air-to-Air Heat Exchangers," ASHRAE Annual Transactions, 89-2B, pp 507-527, 1983.

W.J.Fisk, K.M.Archer, R.E Chant, D. Hekmat, F.J.Offermann, and B.Pedersen, "Onset of Freezing in Residential Air-to-Air Heat Exchangers," ASHRAE Annual Transactions, 91- 1B, 1984.

W.J.Fisk, K.M.Archer, R.E Chant, D. Hekmat, F.J.Offermann, and B.Pedersen, "Performance of Residential Air-to-Air Heat Exchangers During Operation with Freezing and Periodic Defrosts," ASHRAE Annual Transactions, 91-1B, 1984.

F.J.Offermann, R.G.Sextro, W.J.Fisk, D.T.Grimsrud, W.W.Nazaroff, A.V.Nero, and K.L.Revzan, "Control of Respirable Particles with Portable Air Cleaners," Atmospheric Environment, Vol. 19, pp.1761-1771, 1985.

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7 R.G.Sextro, F.J.Offermann, W.W.Nazaroff, A.V.Nero, K.L.Revzan, and J.Yater, "Evaluation of Indoor Control Devices and Their Effects on Radon Progeny Concentrations," Atmospheric Environment, 12, pp. 429-438, 1986.

W.J. Fisk, R.K.Spencer, F.J.Offermann, R.K.Spencer, B.Pedersen, R.Sextro, "Indoor Air Quality Control Techniques," Noyes Data Corporation, Park Ridge, New Jersey, (1987).

F.J.Offermann, "Ventilation Effectiveness and ADPI Measurements of a Forced Air Heating System," ASHRAE Transactions , Volume 94, Part 1, pp 694-704, 1988.

F.J.Offermann and D. Int-Hout "Ventilation Effectiveness Measurements of Three Supply/Return Air Configurations," Environment International , Volume 15, pp 585-592 1989.

F.J. Offermann, S.A. Loiselle, M.C. Quinlan, and M.S. Rogers, "A Study of Diesel Fume Entrainment in an Office Building," IAQ '89, The Human Equation: Health and Comfort, pp 179-183, ASHRAE, Atlanta, GA, 1989.

R.G.Sextro and F.J.Offermann, "Reduction of Residential Indoor Particle and Radon Progeny Concentrations with Ducted Air Cleaning Systems," submitted to Indoor Air, 1990.

S.A.Loiselle, A.T.Hodgson, and F.J.Offermann, "Development of An Indoor Air Sampler for Polycyclic Aromatic Compounds", Indoor Air , Vol 2, pp 191-210, 1991.

F.J.Offermann, S.A.Loiselle, A.T.Hodgson, L.A. Gundel, and J.M. Daisey, "A Pilot Study to Measure Indoor Concentrations and Emission Rates of Polycyclic Aromatic Compounds", Indoor Air , Vol 4, pp 497-512, 1991.

F.J. Offermann, S. A. Loiselle, R.G. Sextro, "Performance Comparisons of Six Different Air Cleaners Installed in a Residential Forced Air Ventilation System," IAQ'91, Healthy Buildings, pp 342-350, ASHRAE, Atlanta, GA (1991).

F.J. Offermann, J. Daisey, A. Hodgson, L. Gundell, and S. Loiselle, "Indoor Concentrations and Emission Rates of Polycyclic Aromatic Compounds", Indoor Air, Vol 4, pp 497-512 (1992).

F.J. Offermann, S. A. Loiselle, R.G. Sextro, "Performance of Air Cleaners Installed in a Residential Forced Air System," ASHRAE Journal, pp 51-57, July, 1992.

F.J. Offermann and S. A. Loiselle, "Performance of an Air-Cleaning System in an Archival Book Storage Facility," IAQ'92, ASHRAE, Atlanta, GA, 1992.

S.B. Hayward, K.S. Liu, L.E. Alevantis, K. Shah, S. Loiselle, F.J. Offermann, Y.L.

Chang, L. Webber, “Effectiveness of Ventilation and Other Controls in Reducing Exposure to ETS in Office Buildings,” Indoor Air ’93, Helsinki, Finland, July 4-8, 1993.

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8 F.J. Offermann, S. A. Loiselle, G. Ander, H. Lau, "Indoor Contaminant Emission Rates Before and After a Building Bake-out," IAQ'93, Operating and Maintaining Buildings for Health, Comfort, and Productivity, pp 157-163, ASHRAE, Atlanta, GA, 1993.

L.E. Alevantis, Hayward, S.B., Shah, S.B., Loiselle, S., and Offermann, F.J. "Tracer Gas Techniques for Determination of the Effectiveness of Pollutant Removal From Local Sources," IAQ '93, Operating and Maintaining Buildings for Health, Comfort, and Productivity, pp 119-129, ASHRAE, Atlanta, GA, 1993.

L.E. Alevantis, Liu, L.E., Hayward, S.B., Offermann, F.J., Shah, S.B., Leiserson, K.

Tsao, E., and Huang, Y., "Effectiveness of Ventilation in 23 Designated Smoking Areas in California Buildings," IAQ '94, Engineering Indoor Environments, pp 167-181, ASHRAE, Atlanta, GA, 1994.

L.E. Alevantis, Offermann, F.J., Loiselle, S., and Macher, J.M., “Pressure and Ventilation Requirements of Hospital Isolation Rooms for Tuberculosis (TB) Patients: Existing Guidelines in the United States and a Method for Measuring Room Leakage”, Ventilation and Indoor air quality in Hospitals, M. Maroni, editor, Kluwer Academic publishers, Netherlands, 1996.

F.J. Offermann, M. A. Waz, A.T. Hodgson, and H.M. Ammann, "Chemical Emissions from a Hospital Operating Room Air Filter," IAQ'96, Paths to Better Building Environments, pp 95-99, ASHRAE, Atlanta, GA, 1996.

F.J. Offermann, "Professional Malpractice and the Sick Building Investigator," IAQ'96, Paths to Better Building Environments, pp 132-136, ASHRAE, Atlanta, GA, 1996.

F.J. Offermann, “Standard Method of Measuring Air Change Effectiveness,” Indoor Air, Vol 1, pp.206-211, 1999.

F. J. Offermann, A. T. Hodgson, and J. P. Robertson, “Contaminant Emission Rates from PVC Backed Carpet Tiles on Damp Concrete”, Healthy Buildings 2000, Espoo, Finland, August 2000.

K.S. Liu, L.E. Alevantis, and F.J. Offermann, “A Survey of Environmental Tobacco Smoke Controls in California Office Buildings”, Indoor Air, Vol 11, pp. 26-34, 2001.

F.J. Offermann, R. Colfer, P. Radzinski, and J. Robertson, “Exposure to Environmental Tobacco Smoke in an Automobile”, Indoor Air 2002, Monterey, California, July 2002.

F. J. Offermann, J.P. Robertson, and T. Webster, “The Impact of Tracer Gas Mixing on Airflow Rate Measurements in Large Commercial Fan Systems”, Indoor Air 2002, Monterey, California, July 2002.

M. J. Mendell, T. Brennan, L. Hathon, J.D. Odom, F.J.Offermann, B.H. Turk, K.M.

Wallingford, R.C. Diamond, W.J. Fisk, “Causes and prevention of Symptom Complaints Redlands Regular Meeting of 12-03-24 676 of 875
9 in Office Buildings: Distilling the Experience of Indoor Environmental Investigators”, submitted to Indoor Air 2005, Beijing, China, September 4-9, 2005.

F.J. Offermann, “Ventilation and IAQ in New Homes With and Without Mechanical Outdoor Air Systems”, Healthy Buildings 2009, Syracuse, CA, September 14, 2009.

F.J. Offermann, “ASHRAE 62.2 Intermittent Residential Ventilation: What’s It Good For, Intermittently Poor IAQ”, IAQVEC 2010, Syracuse, CA, April 21, 2010.

F.J. Offermann and A.T. Hodgson, “Emission Rates of Volatile Organic Compounds in New Homes”, Indoor Air 2011, Austin, TX, June, 2011.

P. Jenkins, R. Johnson, T. Phillips, and F. Offermann, “ Chemical Concentrations in New
California Homes and Garages”, Indoor Air 2011, Austin, TX, June, 2011.

W. J. Mills, B. J. Grigg, F. J. Offermann, B. E. Gustin, and N. E. Spingarm, “Toluene and Methyl Ethyl Ketone Exposure from a Commercially Available Contact Adhesive”, Journal of Occupational and Environmental Hygiene, 9:D95-D102 May, 2012.

F. J. Offermann, R. Maddalena, J. C. Offermann, B. C. Singer, and H, Wilhelm, “The Impact of Ventilation on the Emission Rates of Volatile Organic Compounds in Residences”, HB 2012, Brisbane, AU, July, 2012.

F. J. Offermann, A. T. Hodgson, P. L. Jenkins, R. D. Johnson, and T. J. Phillips, “Attached Garages as a Source of Volatile Organic Compounds in New Homes”, HB 2012, Brisbane, CA, July, 2012.

R. Maddalena, N. Li, F. Offermann, and B. Singer, “Maximizing Information from Residential Measurements of Volatile Organic Compounds”, HB 2012, Brisbane, AU, July, 2012.

W. Chen, A. Persily, A. Hodgson, F. Offermann, D. Poppendieck, and K. Kumagai, “Area-Specific Airflow Rates for Evaluating the Impacts of VOC emissions in U.S.

Single-Family Homes”, Building and Environment, Vol. 71, 204-211, February, 2014.

F. J. Offermann, A. Eagan A. C. Offermann, and L. J. Radonovich, “Infectious Disease Aerosol Exposures With and Without Surge Control Ventilation System Modifications”, Indoor Air 2014, Hong Kong, July, 2014.

F. J. Offermann, “Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposures”, Building and Environment, Vol. 93, Part 1, 101-105, November, 2015.

F. J. Offermann, “Formaldehyde Emission Rates From Lumber Liquidators Laminate Flooring Manufactured in China”, Indoor Air 2016, Belgium, Ghent, July, 2016.

F. J. Offermann, “Formaldehyde and Acetaldehyde Emission Rates for E-Cigarettes”, Indoor Air 2016, Belgium, Ghent, July, 2016.

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10 OTHER REPORTS:

W.J.Fisk, P.G.Cleary, and F.J.Offermann, "Energy Saving Ventilation with Residential Heat Exchangers," a Lawrence Berkeley Laboratory brochure distributed by the Bonneville Power Administration, 1981.

F.J.Offermann, J.R.Girman, and C.D.Hollowell, "Midway House Tightening Project: A Study of Indoor Air Quality," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-12777, 1981.

F.J.Offermann, J.B.Dickinson, W.J.Fisk, D.T.Grimsrud, C.D.Hollowell, D.L.Krinkle, and G.D.Roseme, "Residential Air-Leakage and Indoor Air Quality in Rochester, New York," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-13100, 1982.

F.J.Offermann, W.J.Fisk, B.Pedersen, and K.L.Revzan, Residential Air-to-Air Heat Exchangers: A Study of the Ventilation Efficiencies of Wall- or Window- Mounted Units," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-14358, 1982.

F.J.Offermann, W.J.Fisk, W.W.Nazaroff, and R.G.Sextro, "A Review of Portable Air Cleaners for Controlling Indoor Concentrations of Particulates and Radon Progeny," An interim report for the Bonneville Power Administration, 1983.

W.J.Fisk, K.M.Archer, R.E.Chant, D.Hekmat, F.J.Offermann, and B.S. Pedersen, "Freezing in Residential Air-to-Air Heat Exchangers: An Experimental Study," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-16783, 1983.

R.G.Sextro, W.W.Nazaroff, F.J.Offermann, and K.L.Revzan, "Measurements of Indoor Aerosol Properties and Their Effect on Radon Progeny," Proceedings of the American Association of Aerosol Research Annual Meeting, April, 1983.

F.J.Offermann, R.G.Sextro, W.J.Fisk, W.W. Nazaroff, A.V.Nero, K.L.Revzan, and J.Yater, "Control of Respirable Particles and Radon Progeny with Portable Air Cleaners," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-16659, 1984.

W.J.Fisk, R.K.Spencer, D.T.Grimsrud, F.J.Offermann, B.Pedersen, and R.G.Sextro, "Indoor Air Quality Control Techniques: A Critical Review," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-16493, 1984.

F.J.Offermann, J.R.Girman, and R.G.Sextro, "Controlling Indoor Air Pollution from Tobacco Smoke: Models and Measurements,", Indoor Air, Proceedings of the 3rd International Conference on Indoor Air Quality and Climate, Vol 1, pp 257-264, Swedish Council for Building Research, Stockholm (1984), Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-17603, 1984.

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11 R.Otto, J.Girman, F.Offermann, and R.Sextro,"A New Method for the Collection and Comparison of Respirable Particles in the Indoor Environment," Lawrence Berkeley Laboratory, Berkeley, CA, Special Director Fund's Study, 1984.

A.T.Hodgson and F.J.Offermann, "Examination of a Sick Office Building," Lawrence Berkeley Laboratory, Berkeley, CA, an informal field study, 1984.

R.G.Sextro, F.J.Offermann, W.W.Nazaroff, and A.V.Nero, "Effects of Aerosol Concentrations on Radon Progeny," Aerosols, Science, & Technology, and Industrial Applications of Airborne Particles, editors B.Y.H.Liu, D.Y.H.Pui, and H.J.Fissan, p525, Elsevier, 1984.

K.Sexton, S.Hayward, F.Offermann, R.Sextro, and L.Weber, "Characterization of Particulate and Organic Emissions from Major Indoor Sources, Proceedings of the Third International Conference on Indoor Air Quality and Climate, Stockholm, Sweden, August 20-24, 1984.

F.J.Offermann, "Tracer Gas Measurements of Laboratory Fume Entrainment at a SemiConductor Manufacturing Plant," an Indoor Environmental Engineering R&D Report, 1986.

F.J.Offermann, "Tracer Gas Measurements of Ventilation Rates in a Large Office Building," an Indoor Environmental Engineering R&D Report, 1986.

F.J.Offermann, "Measurements of Volatile Organic Compounds in a New Large Office Building with Adhesive Fastened Carpeting," an Indoor Environmental Engineering R&D Report, 1986.

F.J.Offermann, "Designing and Operating Healthy Buildings", an Indoor Environmental Engineering R&D Report, 1986.

F.J.Offermann, "Measurements and Mitigation of Indoor Spray-Applicated Pesticides", an Indoor Environmental Engineering R&D Report, 1988.

F.J.Offermann and S. Loiselle, "Measurements and Mitigation of Indoor Mold Contamination in a Residence", an Indoor Environmental Engineering R&D Report, 1989.

F.J.Offermann and S. Loiselle, "Performance Measurements of an Air Cleaning System in a Large Archival Library Storage Facility", an Indoor Environmental Engineering R&D Report, 1989.

F.J. Offermann, J.M. Daisey, L.A. Gundel, and A.T. Hodgson, S. A. Loiselle, "Sampling, Analysis, and Data Validation of Indoor Concentrations of Polycyclic Aromatic Hydrocarbons", Final Report, Contract No. A732-106, California Air Resources Board, March, 1990.

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12 L.A. Gundel, J.M. Daisey, and F.J. Offermann, "A Sampling and Analytical Method for Gas Phase Polycyclic Aromatic Hydrocarbons", Proceedings of the 5th International Conference on Indoor Air Quality and Climate, Indoor Air '90, July 29-August 1990.

A.T. Hodgson, J.M. Daisey, and F.J. Offermann "Development of an Indoor Sampling and Analytical Method for Particulate Polycyclic Aromatic Hydrocarbons", Proceedings of the 5th International Conference on Indoor Air Quality and Climate, Indoor Air '90, July 29-August, 1990.

F.J. Offermann, J.O. Sateri, “Tracer Gas Measurements in Large Multi-Room Buildings”, Indoor Air ’93, Helsinki, Finland, July 4-8, 1993.

F.J.Offermann, M. T. O’Flaherty, and M. A. Waz “Validation of ASHRAE 129 - Standard Method of Measuring Air Change Effectiveness”, Final Report of ASHRAE Research Project 891, December 8, 1997.

S.E. Guffey, F.J. Offermann et. al., “Proceedings of the Workshop on Ventilation Engineering Controls for Environmental Tobacco smoke in the Hospitality Industry”, U.S. Department of Labor Occupational Safety and Health Administration and ACGIH, 1998.

F.J. Offermann, R.J. Fiskum, D. Kosar, and D. Mudaari, “A Practical Guide to Ventilation Practices & Systems for Existing Buildings”, Heating/Piping/Air Conditioning Engineering supplement to April/May 1999 issue.

F.J. Offermann, P. Pasanen, “Workshop 18: Criteria for Cleaning of Air Handling Systems”, Healthy Buildings 2000, Espoo, Finland, August 2000.

F.J. Offermann, Session Summaries: Building Investigations, and Design & Construction, Healthy Buildings 2000, Espoo, Finland, August 2000.

F.J. Offermann, “The IAQ Top 10”, Engineered Systems, November, 2008.

L. Kincaid and F.J. Offermann, “Unintended Consequences: Formaldehyde Exposures in Green Homes, AIHA Synergist, February, 2010.

F.J. Offermann, “ IAQ in Air Tight Homes”, ASHRAE Journal, November, 2010.

F.J. Offermann, “The Hazards of E-Cigarettes”, ASHRAE Journal, June, 2014.

PRESENTATIONS :
"Low-Infiltration Housing in Rochester, New York: A Study of Air Exchange Rates and Indoor Air Quality," Presented at the International Symposium on Indoor Air Pollution, Health and Energy Conservation, Amherst, MA, October 13-16,1981.

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13 "Ventilation Efficiencies of Wall- or Window-Mounted Residential Air-to-Air Heat Exchangers," Presented at the American Society of Heating, Refrigeration, and Air Conditioning Engineers Summer Meeting, Washington, DC, June, 1983. "Controlling Indoor Air Pollution from Tobacco Smoke: Models and Measurements," Presented at the Third International Conference on Indoor Air Quality and Climate, Stockholm, Sweden, August 20-24, 1984.
"Indoor Air Pollution: An Emerging Environmental Problem", Presented to the Association of Environmental Professionals, Bar Area/Coastal Region 1, Berkeley, CA, May 29, 1986.
"Ventilation Measurement Techniques," Presented at the Workshop on Sampling and Analytical Techniques, Georgia Institute of Technology, Atlanta, Georgia, September 26, 1986 and September 25, 1987.
"Buildings That Make You Sick: Indoor Air Pollution", Presented to the Sacramento Association of Professional Energy Managers, Sacramento, CA, November 18, 1986. "Ventilation Effectiveness and Indoor Air Quality", Presented to the American Society of Heating, Refrigeration, and Air Conditioning Engineers Northern Nevada Chapter, Reno, NV, February 18, 1987, Golden Gate Chapter, San Francisco, CA, October 1, 1987, and the San Jose Chapter, San Jose, CA, June 9, 1987.
"Tracer Gas Techniques for Studying Ventilation," Presented at the Indoor Air Quality Symposium, Georgia Tech Research Institute, Atlanta, GA, September 22-24, 1987. "Indoor Air Quality Control: What Works, What Doesn't," Presented to the Sacramento Association of Professional Energy Managers, Sacramento, CA, November 17, 1987. "Ventilation Effectiveness and ADPI Measurements of a Forced Air Heating System," Presented at the American Society of Heating, Refrigeration, and Air Conditioning Engineers Winter Meeting, Dallas, Texas, January 31, 1988. "Indoor Air Quality, Ventilation, and Energy in Commercial Buildings", Presented at the Building Owners &Managers Association of Sacramento, Sacramento, CA, July 21, 1988.
"Controlling Indoor Air Quality: The New ASHRAE Ventilation Standards and How to Evaluate Indoor Air Quality", Presented at a conference "Improving Energy Efficiency and Indoor Air Quality in Commercial Buildings," National Energy Management Institute, Reno, Nevada, November 4, 1988.
"A Study of Diesel Fume Entrainment Into an Office Building," Presented at Indoor Air '89: The Human Equation: Health and Comfort, American Society of Heating, Refrigeration, and Air Conditioning Engineers, San Diego, CA, April 17-20, 1989.

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14 "Indoor Air Quality in Commercial Office Buildings," Presented at the Renewable Energy Technologies Symposium and International Exposition, Santa Clara, CA June 20, 1989.
"Building Ventilation and Indoor Air Quality", Presented to the San Joaquin Chapter of the American Society of Heating, Refrigeration, and Air Conditioning Engineers, September 7, 1989.
"How to Meet New Ventilation Standards: Indoor Air Quality and Energy Efficiency," a workshop presented by the Association of Energy Engineers; Chicago, IL, March 20-21, 1989; Atlanta, GA, May 25-26, 1989; San Francisco, CA, October 19-20, 1989; Orlando, FL, December 11-12, 1989; Houston, TX, January 29-30, 1990; Washington D.C., February 26-27, 1990; Anchorage, Alaska, March 23, 1990; Las Vegas, NV, April 23-24, 1990; Atlantic City, NJ, September 27-28, 1991; Anaheim, CA, November 19-20, 1991; Orlando, FL, February 28 - March 1, 1991; Washington, DC, March 20-21, 1991; Chicago, IL, May 16-17, 1991; Lake Tahoe, NV, August 15-16, 1991; Atlantic City, NJ, November 18-19, 1991; San Jose, CA, March 23-24, 1992.
"Indoor Air Quality," a seminar presented by the Anchorage, Alaska Chapter of the American Society of Heating, Refrigeration, and Air Conditioning Engineers, March 23, 1990.
"Ventilation and Indoor Air Quality", Presented at the 1990 HVAC & Building Systems Congress, Santa, Clara, CA, March 29, 1990.

"Ventilation Standards for Office Buildings", Presented to the South Bay Property Managers Association, Santa Clara, May 9, 1990.
"Indoor Air Quality", Presented at the Responsive Energy Technologies Symposium & International Exposition (RETSIE), Santa Clara, CA, June 20, 1990. "Indoor Air Quality - Management and Control Strategies", Presented at the Association of Energy Engineers, San Francisco Bay Area Chapter Meeting, Berkeley, CA, September 25, 1990.
"Diagnosing Indoor Air Contaminant and Odor Problems", Presented at the ASHRAE Annual Meeting, New York City, NY, January 23, 1991.
"Diagnosing and Treating the Sick Building Syndrome", Presented at the Energy 2001, Oklahoma, OK, March 19, 1991.
"Diagnosing and Mitigating Indoor Air Quality Problems" a workshop presented by the Association of Energy Engineers, Chicago, IL, October 29-30, 1990; New York, NY, January 24-25, 1991; Anaheim, April 25-26, 1991; Boston, MA, June 10-11, 1991; Atlanta, GA, October 24-25, 1991; Chicago, IL, October 3-4, 1991; Las Vegas, NV, December 16-17, 1991; Anaheim, CA, January 30-31, 1992; Atlanta, GA, March 5-6, 1992; Washington, DC, May 7-8, 1992; Chicago, IL, August 19-20, 1992; Las Vegas, Redlands Regular Meeting of 12-03-24 682 of 875
15 NV, October 1-2, 1992; New York City, NY, October 26-27, 1992, Las Vegas, NV, March 18-19, 1993; Lake Tahoe, CA, July 14-15, 1994; Las Vegas, NV, April 3-4, 1995; Lake Tahoe, CA, July 11-12, 1996; Miami, Fl, December 9-10, 1996. "Sick Building Syndrome and the Ventilation Engineer", Presented to the San Jose Engineers Club, May, 21, 1991.
"Duct Cleaning: Who Needs It ? How Is It Done ? What Are The Costs ?" What Are the Risks ?, Moderator of Forum at the ASHRAE Annual Meeting, Indianapolis ID, June 23, 1991.
"Operating Healthy Buildings", Association of Plant Engineers, Oakland, CA, November 14, 1991.
"Duct Cleaning Perspectives", Moderator of Seminar at the ASHRAE Semi-Annual Meeting, Indianapolis, IN, June 24, 1991.
"Duct Cleaning: The Role of the Environmental Hygienist," ASHRAE Annual Meeting, Anaheim, CA, January 29, 1992.
"Emerging IAQ Issues", Fifth National Conference on Indoor Air Pollution, University of Tulsa, Tulsa, OK, April 13-14, 1992.
"International Symposium on Room Air Convection and Ventilation Effectiveness", Member of Scientific Advisory Board, University of Tokyo, July 22-24, 1992. "Guidelines for Contaminant Control During Construction and Renovation Projects in Office Buildings," Seminar paper at the ASHRAE Annual Meeting, Chicago, IL, January 26, 1993.
"Outside Air Economizers: IAQ Friend or Foe", Moderator of Forum at the ASHRAE Annual Meeting, Chicago, IL, January 26, 1993.
"Orientation to Indoor Air Quality," an EPA two and one half day comprehensive indoor air quality introductory workshop for public officials and building property managers; Sacramento, September 28-30, 1992; San Francisco, February 23-24, 1993; Los Angeles, March 16-18, 1993; Burbank, June 23, 1993; Hawaii, August 24-25, 1993; Las Vegas, August 30, 1993; San Diego, September 13-14, 1993; Phoenix, October 18-19, 1993; Reno, November 14-16, 1995; Fullerton, December 3-4, 1996; Fresno, May 13-14, 1997. "Building Air Quality: A Guide for Building Owners and Facility Managers," an EPA one half day indoor air quality introductory workshop for building owners and facility managers. Presented throughout Region IX 1993-1995.
“Techniques for Airborne Disease Control”, EPRI Healthcare Initiative Symposium; San Francisco, CA; June 7, 1994.

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16 “Diagnosing and Mitigating Indoor Air Quality Problems”, CIHC Conference; San Francisco, September 29, 1994.
”Indoor Air Quality: Tools for Schools,” an EPA one day air quality management workshop for school officials, teachers, and maintenance personnel; San Francisco, October 18-20, 1994; Cerritos, December 5, 1996; Fresno, February 26, 1997; San Jose, March 27, 1997; Riverside, March 5, 1997; San Diego, March 6, 1997; Fullerton, November 13, 1997; Santa Rosa, February 1998; Cerritos, February 26, 1998; Santa Rosa, March 2, 1998.

ASHRAE 62 Standard “Ventilation for Acceptable IAQ”, ASCR Convention; San Francisco, CA, March 16, 1995.
“New Developments in Indoor Air Quality: Protocol for Diagnosing IAQ Problems”, AIHA-NC; March 25, 1995.
"Experimental Validation of ASHRAE SPC 129, Standard Method of Measuring Air Change Effectiveness", 16th AIVC Conference, Palm Springs, USA, September 19-22, 1995.
“Diagnostic Protocols for Building IAQ Assessment”, American Society of Safety Engineers Seminar: ‘Indoor Air Quality – The Next Door’; San Jose Chapter, September 27, 1995; Oakland Chapter, 9, 1997.
“Diagnostic Protocols for Building IAQ Assessment”, Local 39; Oakland, CA, October 3, 1995.
“Diagnostic Protocols for Solving IAQ Problems”, CSU-PPD Conference; October 24, 1995.
“Demonstrating Compliance with ASHRAE 62-1989 Ventilation Requirements”, AIHA; October 25, 1995.
“IAQ Diagnostics: Hands on Assessment of Building Ventilation and Pollutant Transport”, EPA Region IX; Phoenix, AZ, March 12, 1996; San Francisco, CA, April 9, 1996; Burbank, CA, April 12, 1996.
“Experimental Validation of ASHRAE 129P: Standard Method of Measuring Air Change Effectiveness”, Room Vent ‘96 / International Symposium on Room Air Convection and Ventilation Effectiveness"; Yokohama, Japan, July 16-19, 1996. “IAQ Diagnostic Methodologies and RFP Development”, CCEHSA 1996 Annual Conference, Humboldt State University, Arcata, CA, August 2, 1996. “The Practical Side of Indoor Air Quality Assessments”, California Industrial Hygiene Conference ‘96, San Diego, CA, September 2, 1996.

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17 “ASHRAE Standard 62: Improving Indoor Environments”, Pacific Gas and Electric Energy Center, San Francisco, CA, October 29, 1996.
“Operating and Maintaining Healthy Buildings”, April 3-4, 1996, San Jose, CA; July 30, 1997, Monterey, CA.
“IAQ Primer”, Local 39, April 16, 1997; Amdahl Corporation, June 9, 1997; State Compensation Insurance Fund’s Safety & Health Services Department, November 21, 1996.
“Tracer Gas Techniques for Measuring Building Air Flow Rates”, ASHRAE, Philadelphia, PA, January 26, 1997.
“How to Diagnose and Mitigate Indoor Air Quality Problems”; Women in Waste; March 19, 1997.
“Environmental Engineer: What Is It?”, Monte Vista High School Career Day; April 10, 1997.
“Indoor Environment Controls: What’s Hot and What’s Not”, Shaklee Corporation; San Francisco, CA, July 15, 1997.
“Measurement of Ventilation System Performance Parameters in the US EPA BASE Study”, Healthy Buildings/IAQ’97, Washington, DC, September 29, 1997. “Operations and Maintenance for Healthy and Comfortable Indoor Environments”, PASMA; October 7, 1997.
“Designing for Healthy and Comfortable Indoor Environments”, Construction Specification Institute, Santa Rosa, CA, November 6, 1997. “Ventilation System Design for Good IAQ”, University of Tulsa 10th Annual Conference, San Francisco, CA, February 25, 1998.
“The Building Shell”, Tools For Building Green Conference and Trade Show, Alameda County Waste Management Authority and Recycling Board, Oakland, CA, February 28, 1998.
“Identifying Fungal Contamination Problems In Buildings”, The City of Oakland Municipal Employees, Oakland, CA, March 26, 1998.
“Managing Indoor Air Quality in Schools: Staying Out of Trouble”, CASBO, Sacramento, CA, April 20, 1998.
“Indoor Air Quality”, CSOOC Spring Conference, Visalia, CA, April 30, 1998. “Particulate and Gas Phase Air Filtration”, ACGIH/OSHA, Ft. Mitchell, KY, June 1998.

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18 “Building Air Quality Facts and Myths”, The City of Oakland / Alameda County Safety Seminar, Oakland, CA, June 12, 1998.
“Building Engineering and Moisture”, Building Contamination Workshop, University of California Berkeley, Continuing Education in Engineering and Environmental Management, San Francisco, CA, October 21-22, 1999.
“Identifying and Mitigating Mold Contamination in Buildings”, Western Construction Consultants Association, Oakland, CA, March 15, 2000; AIG Construction Defect Seminar, Walnut Creek, CA, May 2, 2001; City of Oakland Public Works Agency, Oakland, CA, July 24, 2001; Executive Council of Homeowners, Alamo, CA, August 3, 2001.
“Using the EPA BASE Study for IAQ Investigation / Communication”, Joint Professional Symposium 2000, American Industrial Hygiene Association, Orange County & Southern California Sections, Long Beach, October 19, 2000. “Ventilation,” Indoor Air Quality: Risk Reduction in the 21st Century Symposium, sponsored by the California Environmental Protection Agency/Air Resources Board, Sacramento, CA, May 3-4, 2000.
“Workshop 18: Criteria for Cleaning of Air Handling Systems”, Healthy Buildings 2000, Espoo, Finland, August 2000.
“Closing Session Summary: ‘Building Investigations’ and ‘Building Design & Construction’, Healthy Buildings 2000, Espoo, Finland, August 2000. “Managing Building Air Quality and Energy Efficiency, Meeting the Standard of Care”, BOMA, MidAtlantic Environmental Hygiene Resource Center, Seattle, WA, May 23rd, 2000; San Antonio, TX, September 26-27, 2000.
“Diagnostics & Mitigation in Sick Buildings: When Good Buildings Go Bad,” University of California Berkeley, September 18, 2001.
“Mold Contamination: Recognition and What To Do and Not Do”, Redwood Empire Remodelers Association; Santa Rosa, CA, April 16, 2002. “Investigative Tools of the IAQ Trade”, Healthy Indoor Environments 2002; Austin, TX; April 22, 2002.
“Finding Hidden Mold: Case Studies in IAQ Investigations”, AIHA Northern California Professionals Symposium; Oakland, CA, May 8, 2002.
“Assessing and Mitigating Fungal Contamination in Buildings”, Cal/OSHA Training; Oakland, CA, February 14, 2003 and West Covina, CA, February 20-21, 2003.

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19 “Use of External Containments During Fungal Mitigation”, Invited Speaker, ACGIH Mold Remediation Symposium, Orlando, FL, November 3-5, 2003.

Building Operator Certification (BOC), 106-IAQ Training Workshops, Northwest Energy Efficiency Council; Stockton, CA, December 3, 2003; San Francisco, CA, December 9, 2003; Irvine, CA, January 13, 2004; San Diego, January 14, 2004; Irwindale, CA, January 27, 2004; Downey, CA, January 28, 2004; Santa Monica, CA, March 16, 2004; Ontario, CA, March 17, 2004; Ontario, CA, November 9, 2004, San Diego, CA, November 10, 2004; San Francisco, CA, November 17, 2004; San Jose, CA, November 18, 2004; Sacramento, CA, March 15, 2005.
“Mold Remediation: The National QUEST for Uniformity Symposium”, Invited Speaker, Orlando, Florida, November 3-5, 2003.
“Mold and Moisture Control”, Indoor Air Quality workshop for The Collaborative for High Performance Schools (CHPS), San Francisco, December 11, 2003. “Advanced Perspectives In Mold Prevention & Control Symposium”, Invited Speaker, Las Vegas, Nevada, November 7-9, 2004.
“Building Sciences: Understanding and Controlling Moisture in Buildings”, American Industrial Hygiene Association, San Francisco, CA, February 14-16, 2005. “Indoor Air Quality Diagnostics and Healthy Building Design”, University of California Berkeley, Berkeley, CA, March 2, 2005.
“Improving IAQ = Reduced Tenant Complaints”, Northern California Facilities Exposition, Santa Clara, CA, September 27, 2007.
“Defining Safe Building Air”, Criteria for Safe Air and Water in Buildings, ASHRAE Winter Meeting, Chicago, IL, January 27, 2008.
“Update on USGBC LEED and Air Filtration”, Invited Speaker, NAFA 2008 Convention, San Francisco, CA, September 19, 2008.
“Ventilation and Indoor air Quality in New California Homes”, National Center of Healthy Housing, October 20, 2008.
“Indoor Air Quality in New Homes”, California Energy and Air Quality Conference, October 29, 2008.
“Mechanical Outdoor air Ventilation Systems and IAQ in New Homes”, ACI Home Performance Conference, Kansas City, MO, April 29, 2009. “Ventilation and IAQ in New Homes with and without Mechanical Outdoor Air Systems”, Healthy Buildings 2009, Syracuse, CA, September 14, 2009.

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20 “Ten Ways to Improve Your Air Quality”, Northern California Facilities Exposition, Santa Clara, CA, September 30, 2009.
“New Developments in Ventilation and Indoor Air Quality in Residential Buildings”, Westcon meeting, Alameda, CA, March 17, 2010.
“Intermittent Residential Mechanical Outdoor Air Ventilation Systems and IAQ”, ASHRAE SSPC 62.2 Meeting, Austin, TX, April 19, 2010.
“Measured IAQ in Homes”, ACI Home Performance Conference, Austin, TX, April 21, 2010.
“Respiration: IEQ and Ventilation”, AIHce 2010, How IH Can LEED in Green buildings, Denver, CO, May 23, 2010.
“IAQ Considerations for Net Zero Energy Buildings (NZEB)”, Northern California Facilities Exposition, Santa Clara, CA, September 22, 2010. “Energy Conservation and Health in Buildings”, Berkeley High SchoolGreen Career Week, Berkeley, CA, April 12, 2011.
“What Pollutants are Really There ?”, ACI Home Performance Conference, San Francisco, CA, March 30, 2011.
“Energy Conservation and Health in Residences Workshop”, Indoor Air 2011, Austin, TX, June 6, 2011.
“Assessing IAQ and Improving Health in Residences”, US EPA Weatherization Plus Health, September 7, 2011.
“Ventilation: What a Long Strange Trip It’s Been”, Westcon, May 21, 2014. “Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposures”, Indoor Air 2014, Hong Kong, July, 2014.
“Infectious Disease Aerosol Exposures With and Without Surge Control Ventilation System Modifications”, Indoor Air 2014, Hong Kong, July, 2014. “Chemical Emissions from E-Cigarettes”, IMF Health and Welfare Fair, Washington, DC, February 18, 2015.
“Chemical Emissions and Health Hazards Associated with E-Cigarettes”, Roswell Park Cancer Institute, Buffalo, NY, August 15, 2014.
“Formaldehyde Indoor Concentrations, Material Emission Rates, and the CARB ATCM”, Harris Martin’s Lumber Liquidators Flooring Litigation Conference, WQ Minneapolis Hotel, May 27, 2015.

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21 “Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposure”, FDA Public Workshop: Electronic Cigarettes and the Public Health, Hyattsville, MD June 2, 2015.
“Creating Healthy Homes, Schools, and Workplaces”, Chautauqua Institution, Athenaeum Hotel, August 24, 2015.
“Diagnosing IAQ Problems and Designing Healthy Buildings”, University of California Berkeley, Berkeley, CA, October 6, 2015.
“Diagnosing Ventilation and IAQ Problems in Commercial Buildings”, BEST Center Annual Institute, Lawrence Berkeley National Laboratory, January 6, 2016. “A Review of Studies of Ventilation and Indoor Air Quality in New Homes and Impacts of Environmental Factors on Formaldehyde Emission Rates From Composite Wood Products”, AIHce2016, May, 21-26, 2016.
“Admissibility of Scientific Testimony”, Science in the Court, Proposition 65 Clearinghouse Annual Conference, Oakland, CA, September 15, 2016. “Indoor Air Quality and Ventilation”, ASHRAE Redwood Empire, Napa, CA, December 1, 2016.

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Exhibit B
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1 Shawn Smallwood, PhD
3108 Finch Street
Davis, CA 95616
Attn: Sean Reilly, Principal Planner
City of Redlands
35 Cajon St., Ste. 20/P.O. Box 3005
Redlands, CA 92373 22 May 2024
RE: Tennessee Village Project
Dear Mr. Reilly,
I write to comment on potential impacts to biological resources that could result from the proposed Tennessee Village Project, which I understand would add 460 apartment units and 18,000 square feet of commercial space on 13.48 acres located on Tennessee Street between San Bernardino Avenue and West Lugonia Ave in Redlands, California. I comment on the analyses of impacts to biological resources in MIG (2023) and the IS/MND.

My qualifications for preparing expert comments are the following. I hold a Ph.D. degree in Ecology from University of California at Davis, where I also worked as a postgraduate researcher in the Department of Agronomy and Range Sciences. My research has been on animal density and distribution, habitat selection, wildlife interactions with the anthrosphere, and conservation of rare and endangered species. I authored many papers on these and other topics. I served as Chair of the Conservation Affairs Committee for The Wildlife Society – Western Section. I am a member of The Wildlife Society and Raptor Research Foundation, and I’ve lectured part-time at California State University, Sacramento. I was Associate Editor of wildlife biology’s premier scientific journal, The Journal of Wildlife Management, as well as of Biological Conservation, and I was on the Editorial Board of Environmental Management. I have performed wildlife surveys in California for thirty-seven years. My CV is attached.

SITE VISIT
On my behalf, Noriko Smallwood, a wildlife biologist with a Master’s Degree from California State University Los Angeles, visited the site of the proposed project for 4.9 hours from 06:15 to 11:09 hours on 9 May 2024. She walked the site’s perimeter, stopping to scan for wildlife with use of binoculars. Noriko recorded all species of vertebrate wildlife she detected, including those whose members flew over the site or were seen nearby, off the site. Animals of uncertain species identity were either omitted or, if possible, recorded to the Genus or higher taxonomic level.

Conditions were cloudy in the early morning then sunny with no wind and temperatures of 53-72° F. The site was covered in annual grass and mustard at the start of the survey, but was disked during the survey resulting in exposed dirt with no vegetation remaining by the end of the survey (Photos 1 and 2).

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2 Photos 1 and 2. Views of the project site before and after it was disked, 8 April 2024.

Photos by Noriko Smallwood.

Noriko detected 28 species of vertebrate wildlife at or adjacent to the project site, including at least three species with special status (Table 1). Noriko saw deer mouse (Photos 3, 4, 12-17), common raven (Photos 5, 8, 9, 10-17, 19) desert cottontail (Photos 5, 8, 9, 11, 22), coyote and California ground squirrel (Photos 6 and 7, 23), red-tailed hawk (Photos 8, 9, 19, 21), American crow (Photo 18), American kestrel (Photo 20), Lawrence’s goldfinch and house finch (Photos 24 and 25), northern mockingbird and Anna’s hummingbird (Photos 26 and 27), cliff swallow and white-throated swift (Photos 28 and 29), bushtit and great-tailed grackle (Photos 30 and 31), among the other species listed in Table 1.

Noriko Smallwood certifies that the foregoing and following survey results are true and accurately reported.

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3 As depicted in the photos, the disking of the field killed many animals, and it exposed many animals to predators, who exploited the situation as is their nature. Furthermore, the disking was done right in the middle of the avian breeding season, and therefore undoubtedly destroyed many bird nests. Unless there was a compelling reason to disk the field, doing so produced a cruel outcome to both adult and juvenile animals.

Photos 3 and 4. Deer mice exposed on the project site after disking, 9 May 2024.

Photos by Noriko Smallwood.

Photo 5. Common ravens harassing a desert cottontail after it was exposed by disking on the project site, 9 May 2024. Photo by Noriko Smallwood.

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4 Photo 6. Coyote with a California ground squirrel that was likely displaced by disking on the project site, 9 May 2024. Photo by Noriko Smallwood.

Photo 7. Common raven harassing a California ground squirrel that was exposed after disking on the project site, 9 May 2024. Photo by Noriko Smallwood.

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5 Photos 8 and 9. Red-tailed hawk attempted to catch a desert cottontail that was exposed after disking (top), but failed, causing common ravens to attempt to catch the cottontail (bottom) on the project site, 9 May 2024. Photos by Noriko Smallwood.

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6 Photos 10 and 11. Common raven with a Jerusalem cricket (left), and half of a desert cottontail that likely died from the tractor disking the site (right), 9 May 2024. Photos by Noriko Smallwood.

Photos 12 and 13. Common ravens with two different Deer mice on the project site, 9 May 2024. Photos by Noriko Smallwood.

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7 Photos 14, 15, 16, and 17. Common ravens with four different deer mice on the project site, 9 May 2024. Photos by Noriko Smallwood.

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8 Photo 18. Common ravens and American crows gathered at the project site while disking was occurring to feast on the small mammals that were exposed and displaced by disking, 9 May 2024. Photo by Noriko Smallwood.

Photos 19 and 20. Common raven harassed a red-tailed hawk that was entering the project site (left), and an American kestrel hunted over the project site (right), 9 May 2024. Photos by Noriko Smallwood.

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9 Photos 21, 22, and 23. Red-tailed hawk with a Deer mouse (top), and a desert cottontail (bottom left) and California ground squirrel (bottom right) that were displaced and exposed due to disking on the project site, 9 May 2024. Photos by Noriko Smallwood.

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10 Photos 24 and 25. Lawrence’s goldfinch (left), and house finch (right) foraging in mustard on the project site before it was disked, 9 May 2024. Photos by Noriko Smallwood.

Photos 26 and 27. Northern mockingbird searching for insects after disking (left), and Anna’s hummingbird (right) on the project site, 9 May 2024. Photos by Noriko Smallwood.

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11 Photos 28 and 29. Cliff swallow (left), and white-throated swift (right) foraged for insects over the project site, 9 May 2024. Photos by Noriko Smallwood.

Photos 30 and 31. Bushtit (left) next to the project site, and great-tailed grackle (right) flying over the project site, 9 May 2024. Photos by Noriko Smallwood.

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12 Table 1. Species of wildlife Noriko observed during 4.9 hours of survey on the project site, 9 May 2024.

Common name Species name Status1 Notes
Harvester ant Pogonomyrmex sp
Rock pigeon Columba livia Non-native Flew over
Eurasian collared-dove Streptopelia decaocto Non-native Mourning dove Zenaida macroura
White-throated swift Aeronautes saxatalis Flock foraged over site Anna’s hummingbird Calypte anna
Red-tailed hawk Buteo jamaicensis BOP Hunted small mammals displaced by disking American kestrel Falco sparverius BOP Hunted small mammals displaced by disking Cassin’s kingbird Tyrannus vociferans
Black phoebe Sayornis nigricans Calling next to site
American crow Corvus brachyrhynchos Hunted small mammals displaced by disking Common raven Corvus corax Hunted small mammals displaced by disking Barn swallow Hirundo rustica Foraged over site
Cliff swallow Petrochelidon pyrrhonota Large flock foraged over site Bushtit Psaltriparus minimus Flock in pepper tree next to site Northern mockingbird Mimus polyglottos Hunted insects likely displaced by disking on site European starling Sturnus vulgaris Non-native Next to site House sparrow Passer domesticus Non-native
House finch Haemorphous mexicanus Foraged on mustard before disking Lesser goldfinch Spinus psaltria Foraged on mustard before disking Lawrence’s goldfinch Spinus lawrencei BCC Calling next to site California towhee Melozone crissalis Calling next to site Great-tailed grackle Quiscalus mexicanus Flew over
Desert cottontail Sylvilagus audubonii Many, were being chased, harassed, and hunted California ground squirrel Otospermophilus beecheyi At least 4 were on site before disking, Coyote Canis latrans
Ran onto site after it caught a California ground
squirrel that was likely displaced by disking
Deer mouse Peromyscus manicularus Many hunted by predatory birds Southern grasshopper mouse Onychomys torridus ramona SSC Photo-captured in raven’s bill Botta’s pocket gopher Thomomys bottae Many burrows, destroyed by disking 1 SSC = California Species of Special Concern, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, and BOP = Birds of Prey (California Fish and Game Code 3503.5).

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13 Although Noriko saw 28 species of vertebrate wildlife during her brief survey, I must point out that the species of wildlife she detected comprised only a sampling of the species that were present during her survey. Reconnaissance surveys, such as the one Noriko completed at the project site, cannot support species’ absence determinations, but they can be useful for confirming presence of species. Such surveys can also be useful for estimating the number of species that were not detected, thereby revealing the degree to which the survey sampled the local wildlife community that was available at the time of the survey. One way to do this is to model the pattern in species detections with time into a survey. The cumulative number of species’ detections increases with increasing survey time, but eventually with diminishing returns (Figure 1). In the case of Noriko’s survey on the project site, the pattern in the data predicts that had she spent more time on the site, or had she help from more biologists, she would have detected 54 species of vertebrate wildlife during the morning of 9 May 2024.

Figure 1. Actual
and predicted
relationships
between the
number of
vertebrate
wildlife species
detected and the
elapsed survey
time based on
Noriko
Smallwood’s
survey on
morning of 9 May
2024. Note that
the relationships
would differ if the
surveys were
based on another
method or during
another season.

The pattern in Noriko’s data also indicate that her rate of species detections at the project site exceeded the upper bound of the 95% confidence interval I estimated from 53 surveys at other project sites that she and I have surveyed in the Inland Empire region since 2019 (Figure 1). In other words, wildlife species richness at the project site exceeds the species richness she and I have found at other project sites in the region, despite the active disking of the site during Noriko’s survey. 0 50 100 150 200 250 300
Minutes into survey
0 5
10 15
20 25
30 35
Cumulative number of wildlife species detected
Model prediction
r
2 = 0.99, loss = 28.4
95% CI of visualscan surveys 2019-2023
Actual count of species
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14 The site supports many species of wildlife, including many more than Noriko could detect during a brief reconnaissance survey. However, although this modeling approach is useful for more realistically representing the species richness of the site at the time of a survey, it cannot represent the species richness throughout the year or across multiple years because many species are seasonal or even multi-annual in their movement patterns and in their occupancy of habitat. Noriko surveyed only in May, and therefore was unlikely to see some of the species that would use the site in fall or winter.

By use of an analytical bridge, I can apply a model developed from a much larger, more robust data set at a research site to predict the number of wildlife species that would make use of the project site over the longer term. As part of my research, I completed a much larger survey effort across 167 km2 of annual grasslands of the Altamont Pass Wind Resource Area, Alameda County, where from 2015 through 2019 I performed 721 1-hour visual-scan surveys, or 721 hours of surveys, at 46 stations. I used binoculars and otherwise the methods were the same as the methods I used at the project site. At each of the 46 survey stations at my research site, I tallied new species detected with each sequential survey at that station, and then related the cumulative species detected to the hours (number of surveys, as each survey lasted 1 hour) used to accumulate my counts of species detected. I used combined quadratic and simplex methods of estimation in Statistica to estimate least-squares, best-fit nonlinear models of the number of cumulative species detected regressed on hours of survey (number of surveys) at the station: 𝑅̂ =
1 1⁄𝑎+𝑏×(𝐻𝑜𝑢𝑟𝑠)
𝑐
, where 𝑅̂ represented cumulative species richness detected.

The models’ coefficients of determination, r
2, ranged 0.88 to 1.00, with a mean of 0.97
(95% CI: 0.96, 0.98); or in other words, the models were excellent fits to the data.

I projected the predictions of each model to thousands of hours to find predicted asymptotes of wildlife species richness. The mean model-predicted asymptote of species richness was 57 after 11,857 hours of visual-scan surveys among the 46 stations. I also averaged model predictions of species richness at each incremental increase of number of surveys, i.e., number of hours (Figure 2). On average I detected 17.1 species over the first 4.9 hours of surveys in the Altamont Pass (4.9 hours to match the number of hours I surveyed at the project site), which composed 30% of the total predicted species I would detect with a much larger survey effort. Given the example illustrated in Figure 2, the 28 species Noriko detected after her 4.9 hours of survey at the project site likely represented 30% of the species to be detected after many more visual-scan surveys over another year or longer. With many more repeat surveys through the year, Noriko would likely detect 28

0.30 ⁄ = 93 species of vertebrate wildlife at the site. Assuming Noriko’s ratio of special-status to non-special-status species was to hold through the detections of all 93 predicted species, then continued surveys would eventually detect 13 specialstatus species of vertebrate wildlife.

Again, however, my prediction of 93 species of vertebrate wildlife, including 13 specialstatus species, is derived from a visual-scan survey during the daytime, and would not detect nocturnal birds and mammals such as owls and bats. The true number of species composing the wildlife community of the site must be larger. One or two reconnaissance surveys should serve only as a starting point toward characterization of a site’s wildlife Redlands Regular Meeting of 12-03-24 704 of 875
15 community, but this level of effort certainly cannot alone inform of the inventory of species that use the site.

Figure 2. Mean (95% CI)
predicted wildlife species
richness, 𝑅̂, as a nonlinear
function of hour-long
survey increments across
46 visual-scan survey
stations across the
Altamont Pass Wind
Resource Area, Alameda
and Contra Costa
Counties, 2015‒2019.

EXISTING ENVIRNMENTAL SETTING
The first step in analysis of potential project impacts to biological resources is to accurately characterize the existing environmental setting, including the biological species that use the site, their relative abundances, how they use the site, key ecological relationships, and known and ongoing threats to those species with special status. A reasonably accurate characterization of the environmental setting can provide the basis for determining whether the site holds habitat value to wildlife, as well as a baseline against which to analyze potential project impacts. For these reasons, characterization of the environmental setting, including the project site’s regional setting, is one of CEQA’s essential analytical steps. Methods to achieve this first step typically include (1) surveys of the site for biological resources, and (2) reviews of literature, databases and local experts for documented occurrences of special-status species. In the case of the proposed project, these needed steps have not been completed.

Environmental Setting Informed by Field Surveys
To CEQA’s primary objective to disclose potential environmental impacts of a proposed project, the analysis should be informed of which biological species are known to occur at the project site or nearby, which special-status species are likely to occur, as well as the limitations of the survey effort directed to the site. Analysts need this information to 0 20 40 60 80 100
0 10
20 30
40 50
Cumulative number of surveys (hours)
(95% CI)
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16 characterize the environmental setting as a basis for opining on, or predicting, potential project impacts to biological resources.

A biologist performed a 4.5-hour reconnaissance survey on 19 May 2023, beginning at 07:00 hours (MIG 2023a). According to MIG (2023a:7), the survey objectives were “to assess the existing conditions of the project site, including recording observed plant and wildlife species, identifying jurisdictional waters, characterizing the vegetation communities and associated wildlife habitats, and evaluating the potential for these habitats to support special-status species and sensitive communities.” Not mentioned in MIG’s (2023a) statement of objectives or in its methods was that the same biologist who pursued all of these objectives simultaneously was also performing the first of a series of burrowing owl surveys, which were purportedly consistent with CDFW’s (2012) survey guidelines (see below). One biologist pursuing seven objectives in the same survey cannot be expected to achieve any of them satisfactorily.

Perhaps because there were so many objectives pursued simultaneously, the survey, which preceded Noriko’s by one year but was otherwise begun at the same time of day and nearly of the same duration, yielded no more than two-thirds the number of vertebrate wildlife species detections as did Noriko’s survey. I write “no more than twothirds” because it is unreported how many of the species were actually detected by MIG (2023a) during its reconnaissance surveys, In MIG (2023b), it is revealed that the species detections reported in MIG (2023a) had been detected across all four of the burrowing owl breeding-season surveys, totaling 9.25 person-hours. Whereas MIG’s species detection rate was 2 per hour, Noriko’s was nearly three times higher at 5.7 per hour. Noriko also detected twice the number of special-status species, and that was despite the field being disked in her presence.

MIG’s biologist detected five species that Noriko did not, whereas Noriko detected 13 species that MIG’s biologist did not. Combined, Noriko and MIG’s biologist detected 33 species of vertebrate wildlife. More surveys would yield more species detections. The project site has not been sufficiently surveyed to obtain a representative sample of the wildlife community. In fact, the long-tailed weasel that MIG’s biologist saw on the project site is not the type of animal that would occur in a wildlife community that has been suppressed by disturbance, as the IS/MND repeatedly claims as a leading reason that the project site should not be expected to support special-status species. Ignoring the domestic dog, which was likely someone’s pet, only one of the species seen by MIG’s biologist was non-native. Noriko detected three more non-native species, but all these species combined between the two surveys comprise a small portion of the wildlife community, thus indicating a relatively high degree of ecological integrity. More surveys are needed, and without them, the IS/MND lacks support for its characterization of the existing environmental setting.

Based on a protocol-level burrowing owl survey (MIG 2023b), the IS/MND (p. 62) reports “…no burrowing owls or sign thereof were observed on the project site…” However, MIG’s (2023b) survey effort did not achieve the minimum standards of CDFW (2012). No habitat assessment was completed prior to the breeding-season surveys, and none of the breeding-season surveys preceded April 15. In fact, the first survey occurred Redlands Regular Meeting of 12-03-24 706 of 875
17 more than a month later, and doubled as the reconnaissance survey, both performed by the same biologist. That the first of the breeding-season surveys lacked focus should have been clearly reported in either or both MIG (2023a) and MIG (2023b).

The third breeding-season survey was completed in only 40 minutes, which seems too brief to have followed the CDFW (2012) protocol. Assuming a 20-m transect separation, the biologist needed to walk 3,220 m at 3 mph. This pace is achievable on a sidewalk, but it would be more difficult on a wild grassland while also checking all ground squirrel burrow for burrowing owls sign and stopping every 100 m to scan for burrowing owls using binoculars per the CDFW (2012) protocol. In my experience, a survey at this pace would not meet CDFW’s (2012) minimum standards.

According to MIG (2023b), “Surveys were conducted under conditions that would be ideal for detecting burrowing owl or sign thereof and were consistent with the requirements of Staff Report on Burrowing Owl (CDFG 2012).” However, this claim is not entirely true. The first and second surveys failed to meet the minimum temperature standard, and cloud cover was 100% on both of these dates. What concerns me is that the surveys did not meet the minimum standards until July, which was too late for burrowing owls in southern California. The survey effort does not support the IS/MND’s insinuation that burrowing owls are absent from the project site. Nor does the survey effort meet the needs of burrowing owls, which have been rapidly declining throughout California, resulting in a recent listing petition (Miller 2024).

No detection surveys have been performed for any other special-status species that potentially occurs on the project site. Furthermore, I have seen no evidence that protocol-level detection surveys or preconstruction take-avoidance surveys preceded the disking of the project site on 9 May 2024. As noted above, the burrowing owl surveys failed to meet the minimum standards of CDFW (2012), and therefore could not have been relied upon to conclude that burrowing owls were absent from the site prior to the disking.

Environmental Setting Informed by Desktop Review
The purpose of literature and database review, and of consulting with local experts, is to inform the reconnaissance-level survey, to augment it, and to help determine which protocol-level detection surveys should be implemented. Analysts need this information to identify which species are known to have occurred at or near the project site, and to identify which other special-status species could conceivably occur at the site due to geographic range overlap and site conditions. This step is important because the reconnaissance survey is not going to detect all of the species of wildlife that make use of the site. This step can identity those species yet to be detected at the site but which have been documented to occur nearby or whose available habitat associations are consistent with site conditions. Some special-status species can be ruled out of further analysis, but only if compelling evidence is available in support of such determinations (see below).

According to the IS/MND, the initial pool of special-status species considered for inclusion in its analysis of occurrence potential was drawn from queries of CNDDB Redlands Regular Meeting of 12-03-24 707 of 875
18 occurrence records on the local 7.5-minute Quadrangle and the eight surrounding Quads. This screening step, however, is flawed. CNDDB is not designed to support absence determinations or to screen out species from characterization of a site’s wildlife community. As noted by CNDDB, “The CNDDB is a positive sighting database. It does not predict where something may be found. We map occurrences only where we have documentation that the species was found at the site. There are many areas of the state where no surveys have been conducted and therefore there is nothing on the map. That does not mean that there are no special status species present.” MIG (2023) and the IS/MND misuses CNDDB.

CNDDB relies entirely on volunteer or permit reporting from biologists who were allowed access to whatever properties they report from. Many properties have never been surveyed by biologists. Many properties have been surveyed, but the survey outcomes never reported to CNDDB. Many properties have been surveyed multiple times, but not all survey outcomes reported to CNDDB. Furthermore, CNDDB is interested only in the findings of special-status species, which means that species more recently assigned special status will have been reported many fewer times to CNDDB than were species assigned special status since CNDDB’s inception. The lack of CNDDB records for species only recently assigned special status would have been due to insufficient time having elapsed since the assignments. And because negative findings are not reported to CNDDB, CNDDB cannot provide the basis for estimating occurrence likelihoods, either. The IS/MND’s analysis of special-status species occurrence likelihoods is fundamentally flawed.

In my assessment based on database reviews and a site visit, 129 special-status species of wildlife are known to occur near enough to the site to be analyzed for occurrence potential at one time or another (Table 2). Of these, 4 were confirmed (1 of these was probable) on the site by Noriko’s survey visit, and 34 (26%) have been documented in databases within 1.5 miles of the site (‘Very close’), 34 (26%) within 1.5 and 4 miles (‘Nearby’), and another 46 (36%) within 4 to 30 miles (‘In region’). More than half (72) of the special-status species in Table 2 have been reportedly seen within 4 miles of the project site. Therefore, the site likely supports many special-status species of wildlife.

On any given day, one or more yet-to-be documented special-status species likely makes use of the project site, but being there to document that use probably requires multiple surveys (see Figures 1 and 2). Reconnaissance surveys are not designed to support absence determinations of any of these species. Therefore, sufficient survey effort should be directed to the site to either confirm that the species in Table 2 use the site or to support absence determinations.

MIG (2023a) analyzes occurrence likelihoods of only 43 of the special-status species of wildlife in my Table 2. Of these, MIG (2023a) determines 37 are unlikely to occur, 4 have low likelihood to occur, and 2 have moderate likelihood to occur. Of the six species determined to have low to moderate likelihoods of occurrence, five have been documented within 1.5 miles of the site, and one has been documented between 1.5 and 4 miles from the site. However, of the 37 species determined unlikely to occur, one (Lawrence’s goldfinch) was observed on site, five have been documented within 1.5 miles of the site, and 14 have been documented between 1.5 and 4 miles from the site.

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19 The evidence does not comport with MIG’s (2023a) determinations of occurrence likelihood.

The IS/MND’s analyses of special-status species occurrence likelihoods are inaccurate and unreliable. One possible reason for this unfortunate outcome is that for each species analyzed, the species’ habitat characterization is unrealistically narrow. For example, MIG (2023a) reports that western pond turtles require aquatic environments, which are not present on the project site. Unreported, however, is that western pond turtles lay their eggs in mammal burrows in upland, often grassland, environments.

In another example, MIG (2023a) claims that tricolored blackbirds occur only in wetlands, which are not present on the project site. I have documented tricolored blackbirds on grasslands many times. Only last week, I again documented tricolored blackbirds on one of my grassland study sites – a regular occurrence. I have even documented tricolored blackbirds nesting on an annual grassland. MIG’s (2023a) characterization of tricolored blackbird habitat is inaccurate.

In another example, MIG (2023a) characterizes golden eagle habitat as “secluded cliffs with overhanging ledges and large tree for nesting | Hilly or mountainous with canyons,” and concludes “Habitat present at the Project Site would not support this species.” It is unclear where or how MIG came up with this characterization, but it does not include all the places where I have recorded golden eagles. In Yolo County, juvenile golden eagles hunt over alfalfa fields for desert cottontails (the survivors of which I have taken to UC Davis Wildlife Hospital) and California ground squirrels. Most of the 42 golden eagles that my colleagues and I have tracked using GPS telemetry have made use of all sorts of environments, but mostly annual grasslands in low foothills. Our telemetered golden eagles have traveled as far away from our study site in Alameda and Contra Costa Counties as Mexico and British Columbia, and all the places they have visited is habitat. Whereas some golden eagles undoubtedly prefer secluded cliffs with overhanging ledges as MIG claims, many nest in trees on open grassland, and all require forage far from where they nest.

Another example is white-tailed kite, which MIG (2023a) confines to “Coastal estuaries | Wetlands | Ponds | Irrigation ditches | Wet fields.” Again, I have to wonder where this characterization originated. No source is cited for it. And it is inconsistent with my study of this species. I have found that white-tailed kites forage mostly in grassland environments, as well as over agricultural fields (Erichsen et al. 1996, Smallwood et al. 1996). Based on my experience, the project site looks like white-tailed kite habitat.

Ferruginous hawk is reported to find habitat in “Open grassland & fields| Desert scrub | Pinyon-juniper woodland,” but despite this characterization being consistent with the conditions at the project site, MIG (2023a) nevertheless concludes that its occurrence likelihood is unlikely. In my experience, ferruginous hawks forage on fields very much like the project site, even where those fields are disked. MIG’s occurrence determination lacks any reasonable justification.

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20 Merlin is said to find its habitat in “Estuary | Great Basin grassland | Valley & foothill grassland | Open forest.” Unlike for ferruginous hawk, MIG (2023a) accepts that the site provides habitat to merlin. However, MIG (2023a) reports that the site would not support nesting by merlin. This latter conclusion is accurate, but it fails to be put into context. Merlin do no nest anywhere in southern California; the species nests far to the north. Whether the site supports nesting is not the issue for this species, nor is it the issue for ferruginous hawk, as these species are winter migrants that must find sufficient forage in southern California in order to successfully breed at their nest sites far to the north. Both of these species can find forage in a field such as the project site, but neither will find forage in an apartment complex.

In yet another example, MIG (2023a) concludes that Lawrence’s goldfinch is unlikely to occur because its habitat is “Valley foothill hardwood | Desert riparian | Palm oasis | pinyon-juniper | Lower montane | oak woodland.” And yet Noriko recorded Lawrence’s goldfinch immediately adjacent to the project site (see Photo 24).

The patterns of flawed determinations noted in the examples also apply to most of the rest of the special-status species considered by MIG (2023a). MIG (2023a) pigeon-holes species into unrealistically narrow portions of their habitat, and it does so without citing sources. Furthermore, MIG’s determinations do not always follow logically from the habitat characterizations it provides. The analysis is deeply flawed. At least a fair argument can be made for the need to prepare an EIR to appropriately analyze the occurrence likelihoods of special-status species for the purpose of accurately characterizing the wildlife community as part of the existing environmental setting, and as foundation for appropriately analyzing potential project impacts to wildlife.

POTENTIAL BIOLOGICAL IMPACTS
An impacts analysis should consider whether and how the proposed project would affect members of a species, larger demographic units of the species, the whole of a species, and ecological communities. In the following I introduce three types of impacts likely to result from the project, and which need to be analyzed in an EIR.

PRODUCTIVE CAPACITY REDUCED BY HABITAT LOSS
The project would contribute substantially to habitat fragmentation, which poses serious problems to wildlife in the region. Habitat fragmentation and habitat loss have been recognized as the most likely leading causes of a documented 29% decline in overall bird abundance across North America over the last 48 years (Rosenberg et al. 2019). Habitat loss not only results in the immediate numerical decline of wildlife, but it also results in permanent loss of productive capacity. Habitat fragmentation multiplies the negative effects of habitat loss on the productive capacities of biological species (Smallwood 2015). None of these impacts, however, are seriously addressed in the IS/MND.

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21 Table 2. Occurrence likelihoods of special-status bird species at or near the proposed project site, according to eBird/iNaturalist records (https://eBird.org, https://www.inaturalist.org) and on-site survey findings, where ‘Very close’ indicates within 1.5 miles of the site, “nearby” indicates within 1.5 and 4 miles, and “in region” indicates within 4 and 30 miles, and ‘in range’ means the species’ geographic range overlaps the site. Entries in bold font identify species Noriko detected.

Common name Species name Status1
IS/NMD
occurrence
potentials
Data base
records,
Site visits
Delhi sands flower-loving fly Rhaphiomidas terminatus
abdominalis
FE Unlikely In region
Monarch Danaus plexippus FC Very close
Quino checkerspot butterfly Euphydryas editha quino FE Unlikely In range Crotch’s bumble bee Bombus crotchii CCE Unlikely Nearby Western spadefoot Spea hammondii SSC Unlikely Nearby
Arroyo toad Anaxyrus californicus FE, SSC In region
Western pond turtle Emys marmorata SSC Unlikely In region Blainville’s horned lizard Phrynosoma blainvillii SSC Unlikely Nearby Orange-throated whiptail Aspidoscelis hyperythra WL Unlikely Nearby Coastal whiptail Aspidoscelis tigris stejnegeri SSC Unlikely In region San Diegan legless lizard Anniella stebbinsi SSC Unlikely Nearby California glossy snake Arizona elegans occidentalis SSC Unlikely In region Coast patch-nosed snake Salvadora hexalepis virgultea SSC In region Two-striped gartersnake Thamnophis hammondii SSC Unlikely In region South coast gartersnake Thamnophis sirtalis pop. 1 SSC In region Red-diamond rattlesnake Crotalus ruber SSC Unlikely Nearby Brant Branta bernicla SSC2 In region
Cackling goose (Aleutian) Branta hutchinsii leucopareia WL Nearby Redhead Aythya americana SSC2 Nearby
Western grebe Aechmophorus occidentalis BCC Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, BCC Unlikely In region Black swift Cypseloides niger SSC3, BCC In region
Vaux’s swift Chaetura vauxi SSC2, BCC Very close
Costa’s hummingbird Calypte costae BCC Very close
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22 Common name Species name Status1
IS/NMD
occurrence
potentials
Data base
records,
Site visits
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Very close
American avocet2 Recurvirostra americana BCC Very close Mountain plover Charadrius montanus SSC2, BCC In region Snowy plover Charadrius nivosus BCC In region
Whimbrel2 Numenius phaeopus BCC In region
Long-billed curlew Numenius americanus WL In region
Marbled godwit Limosa fedoa BCC In region
Short-billed dowitcher Limnodromus griseus BCC In region Willet Tringa semipalmata BCC In region
Laughing gull Leucophaeus atricilla WL In region
Heermann’s gull Larus heermanni BCC In region
Western gull Larus occidentalis BCC In region
California gull Larus californicus BCC, WL Very close
California least tern Sternula antillarum browni FE, CE, FP In region Black tern Chlidonias niger SSC2, BCC In region
Elegant tern Thalasseus elegans BCC, WL In region
Black skimmer Rynchops niger BCC, SSC3 In region
Common loon Gavia immer SSC Nearby
Double-crested cormorant Phalacrocorax auritus WL Very close American white pelican Pelacanus erythrorhynchos SSC1, BCC Very close California brown pelican Pelecanus occidentalis californicus FP In region Least bittern Ixobrychus exilis SSC2 In region
White-faced ibis Plegadis chihi WL Nearby
Turkey vulture Cathartes aura BOP Very close
Osprey Pandion haliaetus WL, BOP Very close
White-tailed kite Elanus luecurus CFP, BOP Unlikely Very close Golden eagle Aquila chrysaetos BGEPA, CFP, BOP,
WL
Unlikely Very close
Northern harrier Circus cyaneus BCC, SSC3, BOP Very close Redlands Regular Meeting of 12-03-24 712 of 875
23 Common name Species name Status1
IS/NMD
occurrence
potentials
Data base
records,
Site visits
Sharp-shinned hawk Accipiter striatus WL, BOP Very close Cooper’s hawk Accipiter cooperii WL, BOP Moderate Very close Bald eagle Haliaeetus leucocephalus CE, BGEPA Unlikely Nearby Red-shouldered hawk Buteo lineatus BOP Very close
Swainson’s hawk Buteo swainsoni CT, BOP Low Very close
Red-tailed hawk Buteo jamaicensis BOP On site
Ferruginous hawk Buteo regalis WL, BOP Unlikely Very close Zone-tailed hawk Buteo albonotatus BOP In region
Harris’ hawk Parabuteo unicinctus WL, BOP Nearby
Rough-legged hawk Buteo lagopus BOP In region
Barn owl Tyto alba BOP Very close
Western screech-owl Megascops kennicotti BOP Nearby
Great horned owl Bubo virginianus BOP Very close
Burrowing owl Athene cunicularia BCC, SSC2, BOP Low to moderate Nearby Long-eared owl Asio otus BCC, SSC3, BOP In range
Short-eared owl Asia flammeus BCC, SSC3, BOP In region
Lewis’s woodpecker Melanerpes lewis BCC Nearby
Nuttall’s woodpecker Picoides nuttallii BCC Very close
American kestrel Falco sparverius BOP On site
Merlin Falco columbarius WL, BOP Low Very close
Peregrine falcon Falco peregrinus BOP Nearby
Prairie falcon Falco mexicanus WL, BOP Nearby
Olive-sided flycatcher Contopus cooperi BCC, SSC2 Nearby Willow flycatcher Empidonax trailii CE Very close
Southwestern willow flycatcher Empidonax traillii extimus FE, CE Unlikely In range Vermilion flycatcher Pyrocephalus rubinus SSC2 Very close Least Bell’s vireo Vireo bellii pusillus FE, CE Unlikely Very close Loggerhead shrike Lanius ludovicianus SSC2 Low Very close Oak titmouse Baeolophus inornatus BCC Very close
California horned lark Eremophila alpestris actia WL Low Very close Redlands Regular Meeting of 12-03-24 713 of 875
24 Common name Species name Status
1 IS/NMD occurrence
potentials
Data base
records,
Site visits
Bank swallow Riparia riparia CT Nearby
Purple martin Progne subis SSC2 Nearby
Wrentit Chamaea fasciata BCC Very close
California gnatcatcher Polioptila c. californica FT, SSC2 Unlikely Nearby California thrasher Toxostoma redivivum BCC Very close
Cassin’s finch Haemorhous cassinii BCC Very close
Lawrence’s goldfinch Spinus lawrencei BCC Unlikely On site Grasshopper sparrow Ammodramus savannarum SSC2 Nearby
Black-chinned sparrow Spizella atrogularis BCC In region Gray-headed junco Junco hyemalis caniceps WL Nearby
Bell’s sparrow Amphispiza b. belli WL Unlikely Nearby
Southern California rufous-
crowned sparrow
Aimophila ruficeps canescens WL Unlikely Nearby
Yellow-breasted chat Icteria virens SSC3 Unlikely Nearby Yellow-headed blackbird Xanthocephalus xanthocephalus SSC3 Nearby Bullock’s oriole Icterus bullockii BCC Very close
Tricolored blackbird Agelaius tricolor CT, BCC, SSC1 Unlikely Nearby Lucy’s warbler Leiothlypis luciae SSC3, BCC Nearby
Virginia’s warbler Leiothlypis virginiae WL, BCC In region Yellow warbler Setophaga petechia SSC2 Unlikely Very close Summer tanager Piranga rubra SSC1 Nearby
Pallid bat Antrozous pallidus SSC, WBWG:H Unlikely In region Townsend’s big-eared bat Corynorhinus townsendii SSC, WBWG:H In region Silver-haired bat Lasionycteris noctivagans WBWG:M In region Spotted bat Euderma maculatum SSC, WBWG:H In range
Hoary bat Lasiurus cinereus WBWG:M In region
Western yellow bat Lasiurus xanthinus SSC, WBWG:H Unlikely In region Western small-footed myotis Myotis cililabrum WBWG:M In range Miller’s myotis Myotis evotis WBWG:M In region
Little brown myotis Myotis lucifugus WBWG:M In range
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25 Common name Species name Status1
IS/NMD
occurrence
potentials
Data base
records,
Site visits
Fringed myotis Myotis thysanodes WBWG:H In range
Long-legged myotis Myotis volans WBWG:H In range
Yuma myotis Myotis yumanensis WBWG:LM In region
Western mastiff bat Eumops perotis SSC, WBWG:H Unlikely In range Pocketed free-tailed bat Nyctinomops femorosaccus SSC, WBWG:M Unlikely In range San Diego black-tailed jackrabbit Lepus californicus bennettii SSC Unlikely Nearby Northwestern San Diego pocket
mouse
Chaetodipus fallax fallax SSC In region
Pallid San Diego pocket mouse Chaetodipus fallax pallidus SSC In region White-eared pocket mouse Perognathus alticola alticola SSC Unlikely In range Los Angeles pocket mouse Perognathus longimembris
brevinasus
SSC Unlikely In region
Southern grasshopper mouse Onychomys torridus ramona SSC Probable San Bernardino kangaroo rat Dipodomys merriami parvus FE, CCE, SSC Unlikely In region Stephens’ kangaroo rat Dipodomys stephensi FE, CT Unlikely In region San Diego desert woodrat Neotoma lepida intermedia SSC Unlikely In region Ringtail Bassariscus astutus CFP In region
American badger Taxidea taxus SSC Unlikely Nearby
1 Listed as FT or FE = federal threatened or endangered, FC = federal candidate for listing, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, CT or CE = California threatened or endangered, CCT or CCE = Candidate California threatened or endangered, CFP = California Fully Protected (California Fish and Game Code 3511), SSC = California Species of Special Concern (not threatened with extinction, but rare, very restricted in range, declining throughout range, peripheral portion of species' range, associated with habitat that is declining in extent), SSC1, SSC2 and SSC3 = California Bird Species of Special Concern priorities 1, 2 and 3, respectively (Shuford and Gardali 2008), WL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (CFG Code 3503.5), and WBWG = Western Bat Working Group with priority rankings, of low (L), moderate (M), and high (H). 2 Uncertain if BCC based on 2021 Bird of Conservation Concern list.

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26 Habitat loss results in diminished productive capacity of affected wildlife species, but MIG (2023a) and the IS/MND make no attempt to estimate this lost capacity for any of the wildlife species potentially affected. In the case of birds, two methods exist for estimating the loss of productive capacity that would be caused by the project. One method would involve surveys to count the number of bird nests and chicks produced.

The alternative method is to infer productive capacity from estimates of total nest density elsewhere.

Because the project is located within an area that has undergone severe habitat fragmentation, the habitat that remains in fragmented patches probably no longer supports its original productive capacity of wildlife (Smallwood 2015). However, several studies have estimated total avian nest density at locations that had likewise been highly fragmented. Two study sites in grassland/wetland/woodland complexes within agricultural matrices had total bird nesting densities of 32.8 and 35.8 nests per acre (Young 1948, Yahner 1982) for an average 34.3 nests per acre. To acquire a total nest density closer to conditions in California, Noriko surveyed through the breeding season of 2023 over 4.29 acres of grassland in the San Jacinto Wildlife Area. Noriko tabulated

3.72 bird nests/acre in grassland. Applying her estimated total nest density in grassland to the project site’s 13.48 acres of grassland, predicts 50 bird nest sites. Assuming 1.39 broods per nest site based on Noriko’s review of 322 North American bird species, which averaged 1.39 broods per year, then I predict the project would cost California 70 nest attempts/year.

The loss of 50 nest sites and 70 nest attempts/year would easily qualify as a significant project impact that has not been quantitatively addressed in the IS/MND. But the impact would not end with the immediate loss of nest sites as nest substrate is removed and foraging grounds graded in preparation for impervious surfaces. The reproductive capacity of the site would be lost. The average number of fledglings per nest in Young’s (1948) study was 2.9. Assuming Young’s (1948) study site typifies bird productivity, the project would prevent the production of 203 fledglings per year. Assuming an average bird generation time of 5 years, the lost capacity of both breeders and annual fledgling production can be estimated from an equation in Smallwood (2022): {(nests/year × chicks/nest × number of years) + (2 adults/nest × nests/year) × (number of years ÷ years/generation)} ÷ (number of years) = 223 birds per year denied to California.

To measure the impacts of habitat loss to wildlife caused by development projects, Noriko Smallwood and I revisited 80 sites of proposed projects that we had originally surveyed in support of comments on CEQA review documents (Smallwood and Smallwood 2023). We revisited the sites to repeat the survey methods at the same time of year, the same start time in the day, and the same methods and survey duration in order to measure the effects of mitigated development on wildlife. We structured the experiment in a before-after, control-impact experimental design, as some of the sites had been developed since our initial survey and some had remained undeveloped. All of the developed sites had included mitigation measures to avoid, minimize or compensate for impacts to wildlife. Nevertheless, we found that mitigated development resulted in a 66% loss of species on site, and 48% loss of species in the project area. Counts of vertebrate animals declined 90%. “Development impacts measured by the mean number Redlands Regular Meeting of 12-03-24 716 of 875
27 of species detected per survey were greatest for amphibians (-100%), followed by mammals (-86%), grassland birds (-75%), raptors (-53%), special-status species (-49%), all birds as a group (-48%), non-native birds (-44%), and synanthropic birds (-28%).

Our results indicated that urban development substantially reduced vertebrate species richness and numerical abundance, even after richness and abundance had likely already been depleted by the cumulative effects of loss, fragmentation, and degradation of habitat in the urbanizing environment,” and despite all of the mitigation measures and existing policies and regulations. We also found that impacts to wildlife were most severe at infill project sites, where wildlife lacked habitat on adjacent land areas.

INTERFERENCE WITH WILDLIFE MOVEMENT
One of CEQA’s principal concerns regarding potential project impacts is whether a proposed project would interfere with wildlife movement in the region. However, the IS/MND does not seriously address the question of whether the project would interfere with wildlife movement. According to the MIG 1023:12), “…the Project Area is situated in an urbanized area and does not represent a wildlife movement corridor as it (along with other small neighboring vacant lots) is largely bound on all sides by developments, possesses vegetation that is largely non-native that would support high levels of species diversity, and it is too small of an area to support significant wildlife movement. This Project Area does not connect large areas of native habitats and development at this site would not preclude wildlife movement in otherwise open areas.” In fact, the most widely applicable definition of wildlife corridor is of corridors that are created by habitat fragmentation such as the urbanization to which MIG (2023a) refers (Smallwood 2015).

Moreover, the project site’s increasing isolation from other patches of open space only heightens its relative importance to wildlife movement in the region, as wildlife attempting to traverse the region can find fewer and fewer opportunities to stopover and find refuge.

Whether the site includes or is within a wildlife movement corridor is not the only consideration when it comes to the standard CEQA Checklist question of whether the project would interfere with wildlife movement in the region. The primary phrase of the CEQA standard goes to wildlife movement regardless of whether the movement is channeled by a corridor. In fact, a site such as the project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol (Warnock 2010, Taylor et al. 2011, Runge et al. 2014). The project, due to its elimination of 13.48 acres of open space, would cut wildlife off from one of the last remaining stopover and staging opportunities in the project area, forcing volant wildlife to travel even farther between remaining stopover sites. This impact would be significant, and as the project is currently proposed, it would be unmitigated.

MIG (2023a) did not design a study or perform a program of observation capable of characterizing movement patterns or determining how and to what degrees wildlife use the project site for movement. No methods were described of how MIG might have assessed the site in the field for its role in wildlife movement in the region, and it Redlands Regular Meeting of 12-03-24 717 of 875
28 appears that nothing was done at all to investigate wildlife movement other than use of speculation about the size, level of disturbance and situation of the site within an urbanizing environment. Other than speculation, there is no analysis. At least a fair argument can be made for the need to prepare an EIR to appropriately analyze the potential of the proposed project to interfere with wildlife movement in the region.

WINDOW COLLISION MORTALITY
The IS/MND fails to consider impacts on wildlife from window collision. The project would add 460 apartment units and 18,000 sf of retail to open space that is currently habitat to many birds. These new buildings would present glass windows to birds attempting to use an essential portion of their habitat – that portion of the gaseous atmosphere that is referred to as the aerosphere (Davy et al. 2017, Diehl et al. 2017). The aerosphere is where birds and bats and other volant animals with wings migrate, disperse, forage, perform courtship and where some of them mate. Birds are some of the many types of animals that evolved wings as a morphological adaptation to thrive by moving through the medium of the aerosphere. The aerosphere is habitat. Indeed, an entire discipline of ecology has emerged to study this essential aspect of habitat – the discipline of aeroecology (Kunz et al. 2008). Many special-status species of birds have been recorded at or near the aerosphere of the project site, and Noriko saw many birds using the aerosphere while she surveyed the site. Bird-window collision mortality is a potentially significant impact that warrants analysis.

Window collisions are often characterized as either the second or third largest source or human-caused bird mortality. The numbers behind these characterizations are often attributed to Klem’s (1990) and Dunn’s (1993) estimates of about 100 million to 1 billion bird fatalities in the USA, or more recently by Loss et al.’s (2014) estimate of 365-988 million bird fatalities in the USA or Calvert et al.’s (2013) and Machtans et al.’s (2013) estimates of 22.4 million and 25 million bird fatalities in Canada, respectively. The proposed project would impose windows in the airspace normally used by birds.

Glass-façades of buildings intercept and kill many birds, but these façades are differentially hazardous to birds based on spatial extent, contiguity, orientation, and other factors. At Washington State University, Johnson and Hudson (1976) found 266 bird fatalities of 41 species within 73 months of monitoring of a three-story glass walkway (no fatality adjustments attempted). Prior to marking the windows to warn birds of the collision hazard, the collision rate was 84.7 per year. At that rate, and not attempting to adjust the fatality estimate for the proportion of fatalities not found, 4,574 birds were likely killed over the 54 years since the start of their study, and that’s at a relatively small building façade. Accounting for the proportion of fatalities not found, the number of birds killed by this walkway over the last 54 years would have been about 14,270. And this is just for one 3-story, glass-sided walkway between two college campus buildings.

Klem’s (1990) estimate was based on speculation that 1 to 10 birds are killed per building per year, and this speculated range was extended to the number of buildings estimated by the US Census Bureau in 1986. Klem’s speculation was supported by Redlands Regular Meeting of 12-03-24 718 of 875
29 fatality monitoring at only two houses, one in Illinois and the other in New York. Also, the basis of his fatality rate extension has changed greatly since 1986. Whereas his estimate served the need to alert the public of the possible magnitude of the birdwindow collision issue, it was highly uncertain at the time and undoubtedly outdated more than three decades hence. Indeed, by 2010 Klem (2010) characterized the upper end of his estimated range – 1 billion bird fatalities – as conservative. Furthermore, the estimate lumped species together as if all birds are the same and the loss of all birds to windows has the same level of impact.

By the time Loss et al. (2014) performed their effort to estimate annual USA birdwindow fatalities, many more fatality monitoring studies had been reported or were underway. Loss et al. (2014) incorporated many more fatality rates based on scientific monitoring, and they were more careful about which fatality rates to include. However, they included estimates based on fatality monitoring by homeowners, which in one study were found to detect only 38% of the available window fatalities (Bracey et al. 2016). Loss et al. (2014) excluded all fatality records lacking a dead bird in hand, such as injured birds or feather or blood spots on windows. Loss et al.’s (2014) fatality metric was the number of fatalities per building (where in this context a building can include a house, low-rise, or high-rise structure), but they assumed that this metric was based on window collisions. Because most of the bird-window collision studies were limited to migration seasons, Loss et al. (2014) developed an admittedly assumption-laden correction factor for making annual estimates. Also, only 2 of the studies included adjustments for carcass persistence and searcher detection error, and it was unclear how and to what degree fatality rates were adjusted for these factors. Although Loss et al. (2014) attempted to account for some biases as well as for large sources of uncertainty mostly resulting from an opportunistic rather than systematic sampling data source, their estimated annual fatality rate across the USA was highly uncertain and vulnerable to multiple biases, most of which would have resulted in fatality estimates biased low.

In my review of bird-window collision monitoring, I found that the search radius around homes and buildings was very narrow, usually 2 meters. Based on my experience with bird collisions in other contexts, I would expect that a large portion of bird-window collision victims would end up farther than 2 m from the windows, especially when the windows are higher up on tall buildings. In my experience, searcher detection rates tend to be low for small birds deposited on ground with vegetation cover or woodchips or other types of organic matter. Also, vertebrate scavengers entrain on anthropogenic sources of mortality and quickly remove many of the carcasses, thereby preventing the fatality searcher from detecting these fatalities. Adjusting fatality rates for these factors – search radius bias, searcher detection error, and carcass persistence rates – would greatly increase nationwide estimates of bird-window collision fatalities.

Buildings can intercept many nocturnal migrants as well as birds flying in daylight. As mentioned above, Johnson and Hudson (1976) found 266 bird fatalities of 41 species within 73 months of monitoring of a four-story glass walkway at Washington State University (no adjustments attempted for undetected fatalities). Somerlot (2003) found 21 bird fatalities among 13 buildings on a university campus within only 61 days.

Monitoring twice per week, Hager at al. (2008) found 215 bird fatalities of 48 species, or Redlands Regular Meeting of 12-03-24 719 of 875
30 55 birds/building/year, and at another site they found 142 bird fatalities of 37 species for 24 birds/building/year. Gelb and Delacretaz (2009) recorded 5,400 bird fatalities under buildings in New York City, based on a decade of monitoring only during migration periods, and some of the high-rises were associated with hundreds of fatalities each. Klem et al. (2009) monitored 73 building façades in New York City during 114 days of two migratory periods, tallying 549 collision victims, nearly 5 birds per day. Borden et al. (2010) surveyed a 1.8 km route 3 times per week during 12-month period and found 271 bird fatalities of 50 species. Parkins et al. (2015) found 35 bird fatalities of 16 species within only 45 days of monitoring under 4 building façades. From 24 days of survey over a 48-day span, Porter and Huang (2015) found 47 fatalities under 8 buildings on a university campus. Sabo et al. (2016) found 27 bird fatalities over 61 days of searches under 31 windows. In San Francisco, Kahle et al. (2016) found 355 collision victims within 1,762 days under a 5-story building. Ocampo-Peñuela et al. (2016) searched the perimeters of 6 buildings on a university campus, finding 86 fatalities after 63 days of surveys. One of these buildings produced 61 of the 86 fatalities, and another building with collision-deterrent glass caused only 2 of the fatalities, thereby indicating a wide range in impacts likely influenced by various factors. There is ample evidence available to support my prediction that the proposed Project would result in many collision fatalities of birds within the Tennessee Village project.

Bird-window impact prediction
I have reviewed and processed results of bird collision monitoring at 213 buildings and façades for which bird collisions per m2 of glass per year could be calculated and averaged (Johnson and Hudson 1976, O’Connell 2001, Somerlot 2003, Hager et al. 2008, Borden et al. 2010, Hager et al. 2013, Porter and Huang 2015, Parkins et al. 2015, Kahle et al. 2016, Ocampo-Peñuela et al. 2016, Sabo et al. 2016, Barton et al. 2017, Gomez-Moreno et al. 2018, Schneider et al. 2018, Loss et al. 2019, Brown et al. 2020, City of Portland Bureau of Environmental Services and Portland Audubon 2020, Riding et al. 2020). These study results averaged 0.073 bird deaths per m2 of glass per year (95% CI: 0.042-0.102). This average and its 95% confidence interval provide a robust basis for predicting fatality rates at a site of a proposed new project.

I found no information on the extent of glass windows on the proposed project buildings. I therefore measured the windows in the IS/MND’s renderings of the building facades, which compose 17.36% of the total project façade area. Applying my window measurements and adjusting them for the windows not depicted in the IS/MND’s renderings, I calculate a total glass window area of 8,336 m2. Multiplying the average number of bird deaths per m2 of glass per year (above) by my calculated window area in the project, I predict annual bird deaths of 609 (95% CI: 362‒857). My analysis reveals that the impacts of bird-window collision mortality would be highly significant.

This impact is not considered in the IS/MND. A fair argument can be made for the need to revise prepare an EIR to appropriately analyze potential impacts to wildlife due to collisions with windows.

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31 ROAD COLLISION MORTALITY
The IS/MND fails to consider impacts on wildlife from road collision mortality. Projectgenerated traffic would endanger wildlife that must, for various reasons, cross roads used by the project-generated traffic (Photos 32―34), including along roads far from the villages. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level (Forman et al. 2003). Across North America traffic impacts have taken devastating tolls on wildlife (Forman et al. 2003). In Canada, 3,562 birds were estimated killed per 100 km of road per year (Bishop and Brogan 2013), and the US estimate of avian mortality on roads is 2,200 to 8,405 deaths per 100 km per year, or 89 million to 340 million total per year (Loss et al. 2014). Local impacts can be more intense than nationally.

Photo 32. A Gambel’s quail dashes
across a road on 3 April 2021. Such road
crossings are usually successful, but too
often prove fatal to the animal. Photo by
Noriko Smallwood.

Photo 33. Mourning dove killed
by vehicle on a California road.

Photo by Noriko Smallwood, 21
June 2020.

Photo 34. Raccoon killed on Road 31 just east of
Highway 505 in Solano County. Photo taken on
10 November 2018.

The nearest study of traffic-caused wildlife mortality was performed along a 2.5-mile stretch of Vasco Road in Contra Costa County, California. Fatality searches in this study Redlands Regular Meeting of 12-03-24 721 of 875
32 found 1,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over 15 months of searches (Mendelsohn et al. 2009). This fatality number needs to be adjusted for the proportion of fatalities that were not found due to scavenger removal and searcher error. This adjustment is typically made by placing carcasses for searchers to find (or not find) during their routine periodic fatality searches. This step was not taken at Vasco Road (Mendelsohn et al. 2009), but it was taken as part of another study next to Vasco Road (Brown et al. 2016). Brown et al.’s (2016) adjustment factors for carcass persistence resembled those of Santos et al. (2011). Also applying searcher detection rates from Brown et al. (2016), the adjusted total number of fatalities was estimated at 12,187 animals killed by traffic on the road. This fatality number over 1.25 years and 2.5 miles of road translates to 3,900 wild animals per mile per year. In terms comparable to the national estimates, the estimates from the Mendelsohn et al. (2009) study would translate to 243,740 animals killed per 100 km of road per year, or 29 times that of Loss et al.’s (2014) upper bound estimate and 68 times the Canadian estimate. An analysis is needed of whether increased traffic generated by the project would similarly result in local impacts on wildlife.

For wildlife vulnerable to front-end collisions and crushing under tires, road mortality can be predicted from the study of Mendelsohn et al. (2009) as a basis, although it would be helpful to have the availability of more studies like that of Mendelsohn et al. (2009) at additional locations. My analysis of the Mendelsohn et al. (2009) data resulted in an estimated 3,900 animals killed per mile along a county road in Contra Costa County. Two percent of the estimated number of fatalities were birds, and the balance was composed of 34% mammals (many mice and pocket mice, but also ground squirrels, desert cottontails, striped skunks, American badgers, raccoons, and others),

52.3% amphibians (large numbers of California tiger salamanders and California redlegged frogs, but also Sierran treefrogs, western toads, arboreal salamanders, slender salamanders and others), and 11.7% reptiles (many western fence lizards, but also skinks, alligator lizards, and snakes of various species). VMT is useful for predicting wildlife mortality because I was able to quantify miles traveled along the studied reach of Vasco Road during the time period of the Mendelsohn et al. (2009), hence enabling a rate of fatalities per VMT that can be projected to other sites, assuming similar collision fatality rates.

Animal-vehicle collision mortality prediction
The IS/MND predicts 7,131,868 annual VMT. During the Mendelsohn et al. (2009) study, 19,500 cars traveled Vasco Road daily, so the vehicle miles that contributed to my estimate of non-volant fatalities was 19,500 cars and trucks × 2.5 miles × 365 days/year × 1.25 years = 22,242,187.5 vehicle miles per 12,187 wildlife fatalities, or 1,825 vehicle miles per fatality. This rate divided into the above-predicted annual VMT would predict 3,908 vertebrate wildlife fatalities per year. Even if the mortality is half this rate, it would be highly significant. Even if the mortality is a tenth of this rate, it would be highly significant.

Based on my analysis, the project-generated traffic from and within the Tennessee Village project area would cause substantial, significant impacts to wildlife. Given the Redlands Regular Meeting of 12-03-24 722 of 875
33 predicted level of traffic-caused mortality, and the lack of any proposed mitigation, it is my opinion that the proposed project would result in potentially significant adverse biological impacts. However, these impacts are not considered in the IS/MND. A fair argument can be made for the need to revise prepare an EIR to appropriately analyze potential impacts to wildlife due to collision mortality caused by increased road traffic.

CUMULATIVE IMPACTS
The IS/MND’s cumulative effects analysis is fundamentally flawed. The IS/MND reports, “The analysis provided in Section 4.4 found that no individual impacts to sensitive species or migratory birds would occur with implementation of Mitigation Measures BIO-1 and BIO-2; therefore, the project would not contribute considerably to regional impacts on such species, and impacts would be less than significant. …” However, the IS/MND contrives the false standard that a given impact is cumulatively considerable only when it is a significant project-level direct impact that has not been fully mitigated, hence leaving no residual impact. The IS/MND implies that cumulative impacts are really residual impacts left over by inadequate mitigation of project impacts.

This notion of residual impacts being the source of cumulative impacts is inconsistent with CEQA’s definition of cumulative effects. Individually mitigated projects do not negate the significance of cumulative impacts. If they did, then CEQA would not require a cumulative effects analysis. To summarize, the IS/MND presents no cumulative effects analysis as defined in two ways by CEQA.

Considering the size of the project, the degree of habitat fragmentation that has already occurred in the area, and the magnitudes of predicted perpetual wildlife mortality that would be caused by the development of the project, an analysis of the project’s contributions to cumulative impacts was required in the IS/MND. I predict the habitat loss caused the development of the project would deny California of 223 birds per year, which combined with the loss of bird productivity caused by existing, approved and planned development in the region would be highly significant. I predict the development of the project would contribute cumulatively to interference with wildlife movement in the region. I predict the development of the project would contribute annual mortality of 609 (95% CI: 362‒857) birds due to collisions with windows, and 3,908 wild animals due to collisions with project-generated road traffic. These are devastatingly large numbers of direct impacts to wildlife just at the project site alone, but these numbers would add to the tolls at the other projects recently completed, underway or foreseeable in the near future.

A serious analysis of cumulative impacts is warranted. At least a fair argument can be made for the need to prepare an EIR to appropriately analyze potential cumulative impacts.

INADEQUATE MITIGATION
BIO-1 Pre-construction Survey for Nesting Birds. To the extent feasible, construction activities should be scheduled to avoid the nesting season. … If it is not possible to schedule construction activities between September 1 and January 31, then Redlands Regular Meeting of 12-03-24 723 of 875
34 pre-construction surveys for nesting birds will be conducted by a qualified biologist to ensure that no nests would be disturbed during project implementation. These surveys will be conducted no more than 5 days prior to the initiation of any site disturbance activities and equipment mobilization, vegetation removal, fence installation, grading, etc. …If an active nest is found sufficiently close to work areas to be disturbed by these activities, the qualified biologist will determine the extent of a construction-free buffer zone to be established around the nest (typically up to 300 feet for raptors and up to 100 feet for other species), to ensure that no nests of species protected by the MBTA and California Fish and Game Code will be disturbed during project implementation...

Whereas I concur that a preconstruction survey should be performed, it should be understood that a preconstruction survey, although warranted as a follow-up to protocol-level detection surveys, actually achieves very little. Preconstruction, takeavoidance surveys consist of two steps, both of which are very difficult. First, the biologist(s) performing the survey must identify birds that are breeding. Second, the biologist(s) must locate the breeding birds’ nests. The first step is typically completed by observing bird behaviors such as food deliveries and nest territory defense. These types of observations typically require many surveys on many dates spread throughout the breeding season, and these observations are to find the nest sites of single targeted species such as burrowing owl (Smallwood et al. 2013) or loggerhead shrike (Smallwood and Smallwood 2021). To identify the birds of all species nesting on a site requires a much greater survey effort than a single survey only days prior to the start of construction. The biologists conducting the preconstruction survey would be very lucky to find any of the bird nests that are available to be found at the time of the survey.

One reason why preconstruction surveys achieve very little is because species of bird vary in their nest phenology within what is generally understand as the avian breeding season. Whereas killdeer begin nesting in mid-March, western meadowlarks begin in late April, burrowing owls usually begin in May in northern California but in April in southern California, and American goldfinches do not nest until July-August. Whenever the preconstruction survey is conducted, its biologists would be searching only for the nests of the birds that happen to be breeding at the time, and would miss the nests begun between the survey and the start of construction.

Another reason why preconstruction surveys achieve very little is because the nests they might salvage are only the nests of the year. Preconstruction surveys can do nothing to mitigate the loss of productive capacity that follows construction. All subsequent years of productivity would be destroyed by the project regardless of the success of a preconstruction survey.

Lastly, the mitigation language allows a single individual to make a subjective decision, outside the public’s view, to determine the buffer area within stated maxima for any given species. This measure lacks objective criteria, and is unenforceable.

BIO-2: Pre-construction Survey for Burrowing Owl. No more than 14 days prior to ground disturbance a focused survey for burrowing owl will be required to ensure take avoidance. … Pre-construction surveys shall be conducted in accordance Redlands Regular Meeting of 12-03-24 724 of 875
35 with the survey requirements outlined in Appendix D of the CDFW’s Staff Report on Burrowing Owl, dated March 7, 2012. ...

A preconstruction survey is only intended as a follow-up survey to breeding-season detection surveys to ensure that no burrowing owls have repopulated the site since a negative finding from the detection survey or since the passive or active relocations of burrowing owls as a mitigation measure. What is needed prior to the preconstruction survey, and prior to the circulation of an EIR, are breeding-season detection surveys that meet the standards of CDFW (2012). These surveys have yet to be completed.

RECOMMENDED MEASURES
Guidelines on Building Design to Minimize Bird-Window Collisions: If the Project goes forward, it should adhere to available Bird-Safe Guidelines, such as those prepared by American Bird Conservancy and New York and San Francisco. The American Bird Conservancy (ABC) produced an excellent set of guidelines to: (1) Minimize use of glass; (2) Placing glass behind some type of screening (grilles, shutters, exterior shades); (3) Using glass with inherent properties to reduce collisions, such as patterns, window films, decals or tape; and (4) Turning off lights during migration seasons (Sheppard and Phillips 2015). The City of San Francisco (San Francisco Planning Department 2011) also has a set of building design guidelines, based on the excellent guidelines produced by the New York City Audubon Society (Orff et al. 2007).

The ABC document and both the New York and San Francisco documents provide excellent alerting of potential bird-collision hazards as well as many visual examples.

New research results inform of the efficacy of marking windows. Whereas Klem (1990) found no deterrent effect from decals on windows, Johnson and Hudson (1976) reported a fatality reduction of about 69% after placing decals on windows. In an experiment of opportunity, Ocampo-Peñuela et al. (2016) found only 2 of 86 fatalities at one of 6 buildings – the only building with windows treated with a bird deterrent film. At the building with fritted glass, bird collisions were 82% lower than at other buildings with untreated windows. Kahle et al. (2016) added external window shades to some windowed façades to reduce fatalities 82% and 95%. Brown et al. (2020) reported an 84% lower collision probability among fritted glass windows and windows treated with ORNILUX R UV. City of Portland Bureau of Environmental Services and Portland Audubon (2020) reduced bird collision fatalities 94% by affixing marked Solyx window film to existing glass panels of Portland’s Columbia Building. Many external and internal glass markers have been tested experimentally, some showing no effect and some showing strong deterrent effects (Klem 1989, 1990, 2009, 2011; Klem and Saenger 2013; Rössler et al. 2015). For example, Feather Friendly® circular adhesive markers applied in a grid pattern across all windows reduced bird-window collision mortality by 95% in one study (Riggs et al. 2023) and by 95% in another (de Groot et al. 2021).

Another study tested the efficacy of two filmshades to be applied exteriorly to windows prior to installations: BirdShades increased bird-window avoidance by 47% and Haverkamp increased avoidance by 39% (Swaddle et al. 2023).

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36 Monitoring and the use of compensatory mitigation should be incorporated at any new building project because the measures recommended in the available guidelines remain of uncertain efficacy, and even if these measures are effective, they will not reduce collision fatalities to zero. The only way to assess mitigation efficacy and to quantify post-construction fatalities is to monitor newly constructed buildings or homes for fatalities.

Road Mortality: Compensatory mitigation is needed for the increased wildlife mortality that would be caused by project-generated road traffic in the region. I suggest that this mitigation be directed toward funding research to identify fatality patterns and effective impact reduction measures such as reduced speed limits and wildlife undercrossings or overcrossings of particularly dangerous road segments. Compensatory mitigation can also be provided in the form of donations to wildlife rehabilitation facilities (see below).

Fund Wildlife Rehabilitation Facilities: Compensatory mitigation ought also to include funding contributions to wildlife rehabilitation facilities to cover the costs of injured animals that will be delivered to these facilities for care. Many animals would likely be injured by collisions with automobiles and windows and by depredation attempts by house cats and dogs.

Landscaping: If the Project goes forward, California native plant landscaping (i.e., grassland and locally appropriate scrub plants) should be considered to be used as opposed to landscaping with lawn and exotic shrubs and trees. Native plants offer more structure, cover, food resources, and nesting substrate for wildlife than landscaping with lawn and ornamental trees. Native plant landscaping has been shown to increase the abundance of arthropods which act as importance sources of food for wildlife and are crucial for pollination and plant reproduction (Narango et al. 2017, Adams et al. 2020, Smallwood and Wood 2022.). Further, many endangered and threated insects require native host plants for reproduction and migration, e.g., monarch butterfly. Around the world, landscaping with native plants over exotic plants increases the abundance and diversity of birds, and is particularly valuable to native birds (Lerman and Warren 2011, Burghardt et al. 2008, Berthon et al. 2021, Smallwood and Wood 2022). Landscaping with native plants is a way to maintain or to bring back some of the natural habitat and lessen the footprint of urbanization by acting as interconnected patches of habitat for wildlife (Goddard et al. 2009, Tallamy 2020). Lastly, not only does native plant landscaping benefit wildlife, it requires less water and maintenance than traditional landscaping with lawn and hedges.