Redlands City Council
June 3, 2025

Therefore, the General Plan EIR determined that operational impacts would remain significant and unavoidable (City of Redlands, 2017b, p. 3.3-26).

Sensitive Receptors. The General Plan EIR describes that construction related to implementation of the proposed General Plan is not anticipated to result in a long-term exposure of sensitive receptors to substantial concentration of TACs. Impacts would be less than significant. The General Plan EIR also describes that buildout of the General Plan could allow residential and other sensitive land uses to locate in the vicinity of air pollutant sources such as stationary sources and freeways. Policies in the proposed General Plan would serve to protect new sensitive receptors from exposure to substantial pollutant concentrations. Proposed policies would require applicants for sensitive land uses to minimize the potential for air pollution exposure through siting and design. Proposed policies also would require the development of requirements for retrofitting existing residential buildings within a 500-foot buffer along the freeway to abate air pollution and limit new residential developments within the buffer. The SCAQMD permitting process for new emissions sources and existing sources in the vicinity of new sensitive developments would further help to ensure that substantial exposure to air pollutants would be avoided. Thus, the General Plan EIR determined that impacts to sensitive receptors from operation of the General Plan land uses would be less than significant (City of Redlands, 2017b, p. 3.3-29).

Proposed Project
The proposed Project would rezone 24 sites for the purpose of increasing residential development capacity.

Buildout of the proposed Project would change the maximum buildout of the Project area from 828,349.93 SF of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 111 multi-family dwelling units, 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses to residential uses with an allowed capacity of 2,436 units and approximately 151,048.46 SF of Public/Institutional uses. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings). As detailed in Section 5.10, Transportation, the proposed Project is anticipated to result in a total reduction of approximately 27,540 daily vehicle and truck trips compared to the trips that would result from buildout of the Project site under the existing General Plan land use designations.

IMPACT AQ-1: THE PROJECT WOULD CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF AN APPLICABLE AIR QUALITY PLAN.

Significant and Unavoidable Impact. The SCAQMD’s 2022 AQMP is the applicable air quality plan for the proposed Project area. Pursuant to Consistency Criterion No. 1, projects that are consistent with the regional population, housing, and employment forecasts identified by SCAG are considered to be consistent with the AQMP growth projections, since the forecast assumptions by SCAG forms the basis of the land use and transportation control portions of the AQMP. Additionally, because SCAG’s regional growth forecasts are based upon, among other things, land uses designated in general plans, a project that is consistent with the land use designated in a general plan would also be consistent with the SCAG’s regional forecast projections, and thus also with the AQMP growth projections.

As detailed in Section 5.8, Population and Housing , buildout of the proposed Project would allow development of 2,436 residential units and 151,048.46 square feet of public/institutional development, representing a population of approximately 6,456 persons and 550 employees at buildout and full Redlands Regular Meeting of 06-03-25
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occupancy (maximum impact condition). This would result in an increase of 6,162 residents and a reduction of 1,713 employees compared to the buildout of the area pursuant to the City’s General Plan.

Development pursuant to the proposed Project would consist mostly of projects that are market and need dependent. Because the employment generating areas in the Project area are existing, the 550 jobs expected from buildout of the Project are included in the SCAG projections. The SCAG 2020 RTP/SCS projections for the City of Redlands anticipate a 32.2 percent increase in employment in the City between 2016 and 2045 (an increase of 13,700 jobs). The 550 jobs that are anticipated to occur within the Project area would be approximately 4 percent of the anticipated job growth, and within the growth assumptions of the 2020 SCAG AQMP. The SCAG 2024 RTP/SCS projections for the City show a 21.7 percent increase in employment in the City between 2019 and 2050 (an increase of 10,700 jobs). The 550 jobs that are anticipated to occur within the Project area would be approximately 5.1 percent of the anticipated job growth, and within the growth assumptions of the 2024 SCAG RTP/SCS.

The housing added by the Project would help to meet housing demands from projected employment growth in the City while maintaining a healthy vacancy rate. The City of Redlands is jobs rich, with an existing jobs- housing ratio of 1.93. The proposed Project would reduce (improve) the jobs-housing ratio slightly by adding 2,325 residential units compared to buildout pursuant to the General Plan. The proposed Project would provide a regional beneficial effect of providing the opportunity for housing in a jobs-rich area, where employees can easily travel to nearby employment opportunities. Thus, provision of housing within the City would reduce vehicle miles traveled related to employment and the related air quality emissions. In addition, buildout pursuant to the Project would implement infill development, located in an urbanized area with existing infrastructure. This is consistent with the SCAG objective to “Encourage patterns of urban development and land use that reduce costs in infrastructure construction and make better use of existing facilities.” Thus, the proposed Project would support AQMP objectives to reduce trips, promote infill development, and balance jobs and housing, and would not conflict with implementation of the AQMP under Consistency Criterion No. 1. As a result, the proposed Project would comply with SCAQMD AQMP Consistency Criterion No. 1.

Regarding Consistency Criterion No. 2, which evaluates the potential of the proposed Project to increase the frequency or severity of existing air quality violations: as described previously, an impact related to Consistency Criterion No. 2 would occur if the long-term emissions associated with the proposed Project would exceed the SCAQMD’s regional significance thresholds for operation-phase emissions. As detailed below under Impact AQ-2, although the proposed Project would result in decreased emissions in comparison to those occurring under buildout of the existing General Plan land uses, the Project would continue to result in regional operational-source emissions that would exceed the thresholds of significance for CO, VOCs, and NO
X emissions after implementation of regulatory requirements and Mitigation Measures AQ-1 and AQ-2.

Therefore, the Project would result in an increase in the frequency or severity of existing air quality violations and contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP. As a result, the proposed Project would result in an impact related to Consistency Criterion No. 2.

Overall, despite the Project’s consistency with SCAG’s regional growth forecasts, and reduction in emissions compared to buildout of the existing General Plan land uses, buildout of the Project would lead to regional air quality emissions that would exceed thresholds. Therefore, the proposed Project would result in a conflict with, or obstruct, implementation of the AQMP and impacts would be significant and unavoidable after implementation of the mitigation measures detailed below. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to conflict with the AQMP would be less than significant.

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

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

ATTAINMENT UNDER AN APPLICABLE FEDERAL OR STATE AMBIENT AIR QUALITY STANDARD.

Construction
Significant and Unavoidable. Construction activities associated with buildout of the Project would result in emissions of CO, VOCs, NOx, SOx, PM
10, and PM 2.5. Pollutant emissions associated with construction would be generated from the following construction activities: (1) demolition, grading, and excavation; (2) construction workers traveling to and from the construction area; (3) delivery and hauling of construction supplies to, and debris from, the construction area; (4) fuel combustion by onsite construction equipment; and (5) building construction; application of architectural coatings; and paving. These construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants.

As described previously, the timing of development and operation of the development pursuant to the Project would be dependent upon market conditions and development applications for new projects. Thus, construction activities associated with buildout of the proposed Project would likely occur sporadically over a 10-year period or longer. Because of the uncertainty of the specific timing and methods of construction activities for future site-specific development projects that would occur pursuant to the proposed Project, construction-related emissions are speculative and cannot be accurately determined at this stage of the planning process, per CEQA Guidelines Section 15145. Due to the variables that must be considered when examining construction impacts (e.g., development rate, disturbance area per day, specific construction equipment and operating hours, etc.), it would be speculative to state conclusively that construction activity associated with the Project would not cause a significant air quality impact. Conversely, implementation of the Project has a potential to result in a significant and unavoidable impact with respect to construction activity associated with future development projects particularly if multiple construction projects overlap for emissions of CO, VOCs, NO
x, SO X, PM 10, and PM 2.5. Thus, Mitigation Measure AQ-1 has been included to require that future projects prepare a technical assessment of potential air quality impacts from construction and include appropriate mitigation to reduce emissions to the greatest extent feasible. However, it is possible that emissions from future construction projects could exceed thresholds with implementation of feasible mitigation. Therefore, impacts related to construction air quality would be significant and unavoidable after implementation of mitigation. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to construction emissions would be significant and unavoidable.

Operation
Significant and Unavoidable. Consistent with the existing General Plan land use and zoning of the Project site, development pursuant to the proposed Project would consist of projects that are market and need dependent. Both buildout of the existing land use and zoning designations would generate long-term emissions of criteria air pollutants from area sources generated by vehicular emissions, natural gas consumption, landscaping, applications of architectural coatings, and use of consumer products, which are typical of residential, commercial/industrial, and office uses.

The operational emissions from buildout of the existing General Plan land use designations of the 24 Rezone sites with 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi- family dwellings are shown in Table 5.2-6, which identifies that emissions would exceed the SCAQMD numerical thresholds of significance for emissions of VOCs, NOx, CO, PM 10, and PM 2.5. This is consistent with
the findings of the General Plan EIR.

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Table 5.2-6: Existing General Plan Buildout Peak Operational Emissions Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Mobile Source 221.10 201.66 1,439.33 3.32 258.06 67.62
Area Source 72.21 2.71 103.10 0.02 0.32 0.28
Energy Source 0.46 8.32 6.86 0.05 0.63 0.63
Total Maximum Daily Emissions 293.77 212.70 1,549.29 3.38 259.01 68.54 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? Yes Yes Yes No Yes Yes
Winter
Mobile Source 203.24 215.05 1,255.01 3.13 258.06 67.63
Area Source 55.88 1.84 0.78 0.01 0.15 0.15
Energy Source 0.46 8.32 6.86 0.05 0.63 0.63
Total Maximum Daily Emissions 259.58 225.21 1,262.66 3.19 258.84 68.41 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? Yes Yes Yes No Yes Yes
Source: Appendix C
The operational emissions from buildout of the proposed rezoning, which would result in 2,436 multi-family dwelling units and 151,048.46 SF Public/Institutional uses, is shown in Table 5.2-7. As detailed, operation of the proposed land uses at buildout and full occupancy under the proposed Project would generate emissions that would also exceed the applicable SCAQMD thresholds for VOC, CO, and NO X.

Table 5.2-7: Summary of Project Peak Operational Emissions Area Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Mobile Source 47.35 40.23 441.68 1.29 131.89 33.93
Area Source 73.20 41.74 162.66 0.26 3.34 3.32
Energy Source 0.45 7.77 3.71 0.05 0.62 0.62
Total Maximum Daily Emissions 121.01 89.74 608.04 1.61 135.85 37.88 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? Yes Yes Yes No No No
Winter
Mobile Source 45.11 43.17 369.10 1.21 131.89 33.93
Area Source 60.17 40.41 17.20 0.26 3.27 3.27
Energy Source 0.45 7.77 3.71 0.05 0.62 0.62
Total Maximum Daily Emissions 105.73 91.35 390.00 1.52 135.78 37.82 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? Yes Yes No No No No
Source: Appendix C
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Table 5.2-8 provides a comparison of emissions from buildout of the existing General Plan land uses (Table

5.2-6) and buildout under the proposed Project (Table 5.2-7). As shown, the proposed Project would result in fewer operational emissions than buildout of the existing General Plan. As such, the proposed Project would not result in any new or more severe impacts to air quality beyond what was disclosed by the 2017 EIR.

Table 5.2-8: Comparison of Operational Emissions
Area Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Proposed Project 121.01 89.74 608.04 1.61 135.85 37.88
Approved General Plan Buildout 293.77 212.70 1549.29 3.38 259.01 68.54 Net Emissions (Proposed – Approved) -172.76 -122.96 -941.25 -1.78 -123.16 -30.66 Winter
Proposed Project 105.73 91.35 390.00 1.52 135.78 37.82
Approved General Plan Buildout 259.58 225.21 1262.66 3.19 258.84 68.41 Net Emissions (Proposed – Approved) -153.85 -133.87 -872.65 -1.67 -123.07 -30.59 Source: Appendix C
Because buildout of the proposed land uses would continue to result in exceedance of the operational SCAQMD thresholds for VOC, CO, and NOx, Mitigation Measure AQ-2 would be implemented to require developments in the Project area to prepare a technical air quality analysis and include all applicable mitigation measures to reduce operational emissions. However, the details of future proposed projects are unknown, and the volume of emissions that could be reduced through mitigation measures are specific to each proposed development, which are currently unknown. Thus, similar to the analysis presented in the General Plan EIR, even with implementation of Mitigation Measures AQ-1 and AQ-2, emissions have the potential to continue to exceed regional thresholds of significance established by the SCAQMD, and impacts would be significant and unavoidable.

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

Additionally, it should be noted that the majority of the Project’s CO and NO X emissions are derived from
vehicle usage. Since neither future project applicants nor the City have regulatory authority to control tailpipe emissions, no feasible mitigation measures exist that would reduce these emissions to levels that are less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to operational emissions would be significant and unavoidable.

Health Impacts of Exceeded Criteria Pollutant Emissions. The Draft EIR identifies a significant and unavoidable impact with respect to CO, NOx, and VOC emissions, due largely to the use of consumer products and vehicle trips. NOx is a “criteria” pollutant, a pollutant that is regulated by the US EPA pursuant to the federal Clean Air Act. The potential health impacts of criteria pollutants are analyzed on a regional level, not on a facility/project level. The SCAQMD and the San Joaquin Valley Unified Air Pollution Control District (SJVAPD), experts in the area of air quality, both recognize that a meaningful, accurate analysis of potential health impacts resulting from criteria pollutants is not currently possible and not likely to yield Redlands Regular Meeting of 06-03-25
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substantive information that promotes informed decision making. 2 The SJVAPD, in its amicus curiae brief for the recent California Supreme Court decision inSierra Club v. County of Fresno(2018)6 Cal.5 th 502, explained that “it is not feasible to conduct a [health impact analysis] for criteria air pollutants because currently available computer modeling tools are not equipped for this task.” The SJVAPD described a project-specific health impact analysis as “not practicable and not likely to yield valid information” because “currently available modeling tools are not well suited for this task.” The SJVAPD further noted that “…the CEQA air quality analysis for criteria pollutants is not really a localized, project-level impact analysis but one of regional” cumulative impacts.

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

Thus, the difficulties with preparing potential health impact analysis related to the Project’s CO, NOx, and VOC emissions are twofold. First, current modeling is not capable of correlating emissions of criteria pollutants to concentrations that can be reasonably linked to specific health impacts. Second, CO, NOx, and VOCs are precursor emissions and concentrations of CO, NOx, and VOC are impacted by regional atmospheric conditions. CO, NOx, and VOCs emitted by the Project may, depending upon interactions with the sun and other emissions, convert to ozone by complex chemical processes. Thus, there is a significant level of unpredictability associated with such conversion to ozone, as noted by the SCAQMD and the SJVAPD. It should also be noted that the EIR does identify health concerns related to CO and NOx emissions. Table 5.2- 1 includes a list of criteria pollutants and summarizes common sources and effects. Furthermore, due to the programmatic nature of the Rezone, modeling of health impacts associated with criteria pollutants would be infeasible due to lack of specific site plans and the speculative nature of future development and its associated traffic distribution. Thus, the EIR’s analysis is reasonable and intended to foster informed decision making.
2 In April 2019, the Sacramento Metropolitan Air Quality Management District (SMAQMD) published an Interim Recommendation on implementing Sierra Club v. County of Fresno (2018) 6 Cal.5 th 502 (“Friant Ranch”) in the review and analysis of development projects under CEQA in Sacramento County. Consistent with the expert opinions submitted to the court in the Friant Ranch case by SJVAPD and SCAQMD, the SMAQMD guidance confirms the absence of an acceptable or reliable quantitative methodology that would correlate the expected criteria air pollutant emissions of development to likely human health impacts from project- generated criteria air pollutant emissions. The SMAQMD guidance explains that while it is in the process of developing a methodology to assess these impacts, lead agencies should follow the court’s advice to explain in a meaningful way why this analysis is infeasible. Since this interim memorandum, SMAQMD has provided methodology to address impacts; however, a similar analysis for projects within SCAQMD jurisdiction is not yet available.

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IMPACT AQ-3: THE PROJECT COULD EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT CONCENTRATIONS.

Localized Air Quality Impacts
Construction
Significant and Unavoidable. As described previously, an LST analysis can only be conducted at a development project level, and quantification of LSTs is not applicable for this program-level environmental analysis. However, implementation of developments pursuant to the Project could result in localized emissions that exceed air quality standards. Thus, implementation of the Project could result in a significant impact related to LST’s. As a result, Mitigation Measure AQ-1 is included, which requires development projects to provide modeling of localized emissions (NO
X, CO, PM 10, and PM 2.5) associated with the maximum daily grading activities for the proposed development, and requires use of Tier 3 or Tier 4 construction equipment.

However, future project specific construction activities are currently unknown, and therefore, impacts were determined to be potentially significant. Hence, impacts related to localized construction air quality impacts would be significant and unavoidable despite implementation of Mitigation Measure AQ-1. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to construction emissions impacting sensitive receptors would be less than significant.

Operational
Less than Significant Impact. According to the SCAQMD LST methodology, LSTs apply to project-related stationary mobile sources. Projects that involve mobile sources that spend long periods queuing and idling at a site, such as transfer facilities or warehousing and distribution buildings, have the potential to exceed the operational LSTs. Buildout of the proposed Project would result in additional residential and public developments, which do not typically involve vehicles idling or queueing for long periods. Therefore, due to the lack of significant stationary source emissions, impacts related to operational LSTs would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to operational emissions impacting sensitive receptors would be less than significant.

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

The 2003 AQMP estimated traffic volumes that could generate CO concentrations to result in a “hot spot.” As shown in Table 5.2-9, according to the 2003 AQMP, the Wilshire-Veteran intersection had a daily traffic volume of approximately 100,000 vehicles per day, and the 1-hour CO concentration was 4.6 ppm. This indicates that, even with a traffic volume of 400,000 vehicles per day, CO concentrations (4.6 ppm x 4=

18.4 ppm) would still not exceed the most stringent 1-hour CO standard (20.0 ppm). 3 Table 5.2-9: Traffic Volumes for Intersections Evaluated in 2003 AQMP Intersection Location
Peak Traffic Volumes (vehicles per hour [vph])
Eastbound
(a.m./p.m.)
Westbound
(a.m./p.m.)
Southbound
(a.m./p.m.)
Northbound
(a.m./p.m.)
Total
(a.m./p.m.)
Wilshire-Veteran 4,954/2,069 1,830/3,317 721/1,400 560/933 8,062/7,719 Sunset-Highland 1,417/1,764 1,342/1,540 2,304/1,832 1,551/2,238 6,614/5,374 3 Based on the ratio of the CO standard (20.0 ppm) and the modeled value (4.6 ppm).

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Intersection Location
Peak Traffic Volumes (vehicles per hour [vph])
Eastbound
(a.m./p.m.)
Westbound
(a.m./p.m.)
Southbound
(a.m./p.m.)
Northbound
(a.m./p.m.)
Total
(a.m./p.m.)
La Cienega-Century 2,540/2,243 1,890/2,728 1,384/2,029 821/1,674 6,634/8,674 Long Beach-Imperial 1,217/2,020 1,760/1,400 479/944 756/1,150 4,212/5,514 Source: Appendix C
Operation of the proposed Project at buildout during AM peak hour would result in a total increase of 1,034 trips throughout the Project area and a total decrease of 1,716 trips in the PM peak hour throughout the Project area. These trips distributed throughout the Project area would not result in daily traffic volumes of 100,000 vehicles per day or more. As such, Project-related traffic volumes are less than the traffic volumes identified in the 2003 AQMP; and are not high enough to generate a CO “hot spot.” Therefore, impacts related to CO “hot spots” from operation of the proposed Project would be less than significant.

Toxic Air Contaminants
Less than Significant with Mitigation Incorporated. CARB has issued advisory recommendations for siting new sensitive land uses in proximity to sources associated with Toxic Air Contaminants (TACs) and recommends performing site specific environmental evaluations. However, it is currently unknown what development projects that could include a sensitive receptor would be proposed next to an existing TAC, such as warehouses, industrial areas, freeways, roadways, and rail lines with traffic volumes over 10,000 vehicle per day. Therefore, consistent with CARB guidance, Mitigation Measure AQ-3 is included to require a site- specific evaluation prior to approving any sensitive land use in proximity to an existing TAC within the Project area. Implementation of Mitigation Measure AQ-3 would reduce potential impacts related to TACs to a less- than-significant level.

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

As described under Impact AQ-2 above, emissions from construction of the proposed Project could exceed the SCAQMD’s thresholds after implementation of SCAQMD rules and mitigation measures. Also, emissions from operation of the proposed Project at buildout would exceed SCAQMD’s threshold for CO, VOC, and NOx after implementation of mitigation measures. Because the large majority of operational-source CO and NOx emissions (by weight) would be generated by project vehicles, and the VOC emissions would be generated by consumer products that neither future project applicants nor the City have the ability to reduce emissions of. Therefore, similar to the analysis presented in the General Plan EIR, operational-source CO, VOC, and NOx emissions from implementation of the proposed Project would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable.

5.2.7 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
State
• Airborne Toxic Control Measure to Limit Diesel-Fuel Commercial Vehicle Idling (13 CCR 2485) • In-Use Off-Road Diesel Idling Restriction (13 CCR 2449) Redlands Regular Meeting of 06-03-25
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• California Green Building Standards Code (Code of Regulations, Title 24 Part 6) Regional
• SCAQMD Rule 201: Permit to Construct
• SCAQMD Rule 402: Nuisance Odors
• SCAQMD Rule 403: Fugitive Dust
• SCAQMD Rule 1108: Volatile Organic Compounds
• SCAQMD Rule 1113: Architectural Coatings
• SCAQMD Rule 1143: Paint Thinners and Solvents
Plans, Programs, or Policies
None.

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

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

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

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

5.2.9 MITIGATION MEASURES
General Plan EIR Mitigation Measures
None.

Proposed Project Mitigation Measures
Mitigation Measure AQ-1: Construction Emissions. Prior to issuance of grading permits, project applicants shall prepare and submit a technical assessment evaluating potential project construction-related air quality impacts (regional and localized) and greenhouse gas impacts to the City for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the SCAQMD’s most recent adopted thresholds of significance, the City shall require that applicants for new development projects incorporate feasible mitigation measures to reduce air pollutant emissions during construction activities to below applicable significance thresholds. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City. Mitigation measures to reduce construction- related emissions are dependent upon the activity causing the impact and could include, but are not limited to:
• Require construction equipment that meets or exceeds CARB Certified Tier 3 or Tier 4 engine standards.

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• Limit the idling time of diesel off-road construction equipment to no more than five (5) minutes. • Require the use of “Super-Compliant” low VOC paints which have been reformulated to exceed the regulatory VOC limits put forth by SCAQMD’s Rule 1113. Super-Compliant low VOC paints shall be no more than 10g/L of VOC. Alternatively, projects may utilize building materials that do not require the use of architectural coatings.
• The Construction Contractor shall require by contract specifications that construction operations rely on the electricity infrastructure surrounding the construction site, if available rather than electrical generators powered by internal combustion engines.
• The Construction Contractor shall require the use of alternative fueled, engine retrofit technology, after- treatment products (e.g., diesel oxidation catalysts, diesel particulate filters), including all off-road and portable diesel-powered equipment.
• The Construction Contractor shall require that construction equipment be maintained in pursuant to manufacturer specifications to reduce emissions. The Construction Contractor shall ensure that all construction equipment is being properly serviced and maintained as per the manufacturer’s specification. Maintenance records shall be available at the construction site for City verification.

Mitigation Measure AQ-2: Operational Emissions. Prior to issuance of grading permits, project applicants shall prepare and submit a technical assessment evaluating potential project operation air quality impacts (regional and localized) and greenhouse gas impacts to the City for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology in assessing air quality and greenhouse gas impacts. If operation-related emissions are determined to have the potential to exceed the SCAQMD’s most recent adopted thresholds of significance, the City shall require that applicants for new development projects incorporate all feasible mitigation measures to reduce air quality and/or greenhouse gas emissions during operational activities to below the applicable significance thresholds. The identified measures shall be included as part of the conditions of approval. Possible mitigation measures to reduce operational emissions could include, but are not limited to the following:
• Installation of modestly enhanced insulation (walls R-13; roof/attic R-38) such that heat transfer and thermal bridging is minimized;
• Installation of modestly enhanced window insulation (0.4 U-Factor, 0.32 SHGC); • Installation of a heating/cooling distribution system with modest duct insulation (R-6) or enhanced duct insultation (R-8);
• Use of high efficiency HVAC (SEER 15/72% AFUE or 8.5 HSPF); • Use of interior and exterior energy efficient lighting that exceeds then incumbent California Title 24 Energy Efficiency performance standards;
• Installation of automatic devices to turn off lights where they are not needed; • Application of a paint and surface color palette that emphasizes light and off-white colors that reflect heat away from buildings;
• Design of buildings with “cool roofs” using products certified by the Cool Roof Rating Council, and/or exposed roof surfaces using light and off-white colors; • Design of buildings to accommodate photo-voltaic solar electricity systems or the installation of photo- voltaic solar electricity systems;
• Installation of ENERGY STAR-qualified energy-efficient appliances, heating and cooling systems, office equipment, and/or lighting products.
• Landscaping palette of drought tolerant plants exceeding City requirements; • Use of weather-based irrigation control systems or moisture sensors (demonstrate 20% reduced water use);
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• U.S. EPA Certified WaterSense labeled or equivalent faucets, high-efficiency toilets (HETs), and water- conserving shower heads.

Mitigation Measure AQ-3: Toxic Air Contaminants. Applicants for residential within 1,000 feet of a major sources of Toxic Air Contaminants (TACs) (e.g., warehouses, industrial areas, freeways, roadways, and rail lines with traffic volumes over 10,000 vehicle per day), as measured from the property line of the project to the property line of the source/edge of the nearest travel lane, shall submit a health risk assessment (HRA) to the City of Redlands prior to future discretionary Project approval. The HRA shall be prepared in accordance with policies and procedures of CEQA and the SCAQMD. If the HRA shows that the incremental cancer risk exceeds ten in one million (10E-06), PM
10 concentrations exceed 2.5 microgram per cubic meter
(µg/m3), PM2.5 concentrations exceed 2.5 µg/m 3, or the appropriate noncancer hazard index exceeds 1.0, the applicant will be required to identify and demonstrate that mitigation measures are capable of reducing potential cancer and non-cancer risks to an acceptable level (i.e., below ten in one million or a hazard index of 1.0), including appropriate enforcement mechanisms. Measures to reduce risk may include but are not limited to:
• Air intakes located away from high volume roadways and/or truck loading zones. • Heating, ventilation, and air conditioning systems of the buildings provided with appropriately sized maximum efficiency rating value (MERV) filters (e.g., MERV 13 or better).

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

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

Emissions from operation of the proposed Project at buildout would exceed SCAQMD’s thresholds for CO, VOC, and NOx after implementation of regulations and Mitigation Measure AQ-2. Because a majority of operational-source CO and NOx emissions (by weight) would be generated by vehicle trips, and the VOC emissions would be generated by consumer products that neither future Project applicants nor the City have the ability to reduce emissions of. Therefore, operational-source CO, VOC, and NOx emissions from implementation of the proposed Project would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable.

Impact AQ-3: After implementation of Mitigation Measures AQ-1 through AQ-3, localized emissions could exceed the SCAQMD’s localized significance threshold for a pollutant. Thus, impacts would be significant and unavoidable.

5.2.11 REFERENCES
City of Redlands. (2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Retrieved July 2, 2024, from https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 Redlands Regular Meeting of 06-03-25
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City of Redlands. (2024). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Southern California Association of Governments (SCAG). (n.d.). 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction. https://scag.ca.gov/sites/main/files/file- attachments/2016_2040rtpscs_finalgrowthforecastbyjurisdiction.pdf?1605576071 Urban Crossroads. (2024a). Regional Housing Needs Assessment Rezone Air Quality Impact Analysis. (Appendix C)
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5.3 Cultural Resources

5.3.1 INTRODUCTION
This section addresses potential environmental impacts from buildout pursuant to the Redlands RHNA Rezone Project on cultural resources, which include historical and archaeological resources. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035 , December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), July 2017; and
• City of Redlands Municipal Code.

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

Cultural Resources Terminology
• Archaeological resources include any material remains of human life or activities that are at least 100 years of age, and that are of scientific interest. A unique or significant archaeological resource is an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it (1) contains information needed to answer important scientific research questions and there is a demonstrable public interest in that information; (2) has a special and particular quality, such as being the oldest of its type or the best available example of its type; and (3) is directly associated with a scientifically recognized important prehistoric or historic event or person.
• Cultural resources are defined as buildings, sites, structures, or objects, each of which may have historic, architectural, archaeological, cultural, or scientific importance, according to the California Environmental Quality Act (CEQA).
• Historic building or site is one that is noteworthy for its significance in local, State, or national history or culture, its architecture or design, or its works of art, memorabilia, or artifacts. • Historic context refers to the broad patterns of historical development in a community or its region that is represented by cultural resources. A historic context statement is organized by themes such as economic, residential, and commercial development.
• Historic integrity is defined as “the ability of a property to convey its significance.” • Historical resources are defined as “a resource listed or eligible for listing on the California Register of Historical Resources” (CRHR) (Public Resources Code, Section 5024.1; 14 CCR 15064.5). Under CEQA Guidelines Section 15064.5(a), the term “historical resources” includes the following:
(1) A resource listed in or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Public Resources Code, Section 5024.1). (2) A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public Resources Code or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. (3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, Redlands Regular Meeting of 06-03-25
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economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (Public Resources Code Section 5024.1) including the following:
(A) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;
(B) Is associated with the lives of persons important in California’s past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or (D) Has yielded, or may be likely to yield, information important in prehistory or history. (4) The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to Section 5020.1(k) of the Public Resources Code), or identified in a historical resources survey (meeting the criteria in Section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code Sections 5020.1(j) or 5024.1.

5.3.2 REGULATORY SETTING

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

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

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

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

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

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

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

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

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

5.3.2.2 State Regulations
California Register of Historical Resources
Eligibility for inclusion in the California Register of Historical Resources (CRHR) is determined by applying the following criteria:

1. It is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. It is associated with the lives of persons important in California’s past;

3. embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic value; or

4. It has yielded or is likely to yield information important in prehistory or history. The Register includes properties which are listed or have been formally determined to be eligible for listing in the National Register, State Historical Landmarks, and eligible Points of Historical Interest (PRC §5024.1).

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In addition to meeting one or more of the above criteria, the CRHR requires that sufficient time has passed since a resource’s period of significance to “obtain a scholarly perspective on the events or individuals associated with the resources.” (CCR 4852 [d][2]). The CRHR also requires that a resource possess integrity.

This is defined as the ability for the resource to convey its significance through seven aspects: location, setting, design, materials, workmanship, feeling, and association.

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

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

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

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

Principle 2-P.8 Identify, maintain, protect, and enhance Redlands’ cultural, historic, social, economic, architectural, agricultural, archaeological, and scenic heritage. In so doing, Redlands will preserve its unique character and beauty, foster community pride, conserve the character and architecture of its neighborhoods and commercial and Redlands Regular Meeting of 06-03-25
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rural areas, enable citizens and visitors to enjoy and learn about local history, and provide a framework for making appropriate physical changes.

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

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

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

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

Action 2-A.25 Require any application that would alter or demolish an undesignated and unsurveyed resource over 50 years old to be assessed on the merits of the structure, and to be approved by the Historic and Scenic Preservation Commission.

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

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

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

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

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

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

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

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

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

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

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

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

Redlands has eight locally-designated historic districts, none of which are located in proximity to the Rezone sites:
• Eureka Street Historic District
• West Highland Avenue Historic and Scenic District
• Early Redlands Historic and Scenic District
• Normandie Court Historic District
• East Fern Avenue Historic and Scenic District
• Garden Hill Historic and Scenic District
• La Verne Street Historic and Scenic District
• Smiley Park Historic and Scenic District
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Redlands Historic Architectural Design Guidelines
The City of Redlands adopted an update to the City of Redlands Historic Architectural Design Guidelines on September 3, 2024. The Redlands Historic Architectural Design Guidelines provide historic preservation standards and resources for property owners, design professionals, the City of Redlands Planning Department, and the Historic and Scenic Preservation Committee. The Design Guidelines provide standards for best preservation practices and contextual design when undertaking an exterior alteration or addition, changes to site or accessory features, restoration or rehabilitation of a historic building, or new construction on or adjacent to a historic site, historic and/or scenic district, or Character Category. The Design Guidelines also inform the reviews of demolition permit applications for structures that may be eligible or potentially eligible for local designation or preservation.

East Valley Corridor Specific Plan Preservation Overlay District The East Valley Corridor Specific Plan provides for a Preservation – Historical/Archaeological Overlay District (“Preservation Overlay District”) in Division 5 of the Specific Plan, which is intended to preserve and protect historical and archaeological resources. The Preservation Overlay District provides development standards for developments within the district that are in addition to those required by the Specific Plan.

Within the East Valley Corridor Specific Plan, the Preservation Overlay District is applied to areas approximately 600 feet on either side of the historic alignment of the Mission Zanja irrigation canal and to potential historic structures. The development standards set forth within the Preservation Overlay District set forth requirements for investigation, data recovery, and preservation of archaeological and historic resources (City of Redlands, 2024).

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

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

Archaeological Resources
Archaeological sensitivity in the City of Redlands is often related to proximity to the City’s numerous waterways, many of which were constructed to serve as storm water ditches in the 1800s. As shown in Figure

5.3-1, multiple Rezone sites are located in close proximity to the Morey Arroyo. The Morey Arroyo borders Sites 2, 24, 7, 12, and 16 to the south and Site 8 to the north. Site 11 contains a portion of the Morey Arroyo Redlands Regular Meeting of 06-03-25
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in the southern part of the site, within the property line. The Morey Arroyo is a partially improved natural drainage that has been used as a storm water ditch since the 1800s. A portion of the Morey Arroyo (Site 36-029388) was originally recorded in 2014 and subsequently an additional portion was recorded in 2018 (McKenna, 2015).

Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. Similar to the proposed Project, future development pursuant to the General Plan could involve grading, excavation, and other ground disturbing activities to previously undisturbed depths, which could result in inadvertent discovery of buried archaeological resources.

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Figure 5.3-1
Morey Arroyo Buffer Area
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5.3.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:

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

The Initial Study established that the proposed Project would result in less-than-significant impacts with mitigation related to Threshold CUL-1 and less-than-significant impacts related to Threshold CUL-3, and no further assessment of these impacts is required in this Draft Subsequent EIR. Mitigation Measures CUL-1 and CUL-2 from the Initial Study are included below in Section 5.3.10, Mitigation Measures.

5.3.5 METHODOLOGY
In determining whether an archaeological related impact would result from the proposed Project, the programmatic analysis includes consideration of the archaeologic sensitivity of the Rezone sites and the past disturbance within the Rezone sites. The analysis combines these factors to identify the potential of construction from implementing projects to impact any unknown archaeological resources. This analysis is partially based on the records search results conducted for the General Plan EIR at the South Central Coastal Information Center (SCCIC), located at the California State University, Fullerton, and at the Eastern Information Center (EIC), located at University of California Riverside.

5.3.6 ENVIRONMENTAL IMAPCTS
Summary of Impacts Identified in the General Plan EIR
The General Plan EIR addressed impacts related to cultural resources in Chapter 3.8. The General Plan EIR described that future development pursuant to the General Plan could result in impacts on historical and archaeological resources within the city. The EIR describes that policies included in the General Plan would serve to protect cultural resources. In addition, the General Plan EIR describes that future projects would require project-level CEQA analysis, which would identify potential impacts on known or potential historic sites and structures. Therefore, the EIR concluded that implementation of the General Plan would result in less-than-significant impacts to historical resources with adherence to General Plan policies and federal, State, and local regulations. The General Plan EIR discussed that the entire city has not been surveyed for archaeological resources and that there is potential for new archaeological resources to be discovered in the future. Future development pursuant to the General Plan may involve grading, excavation, or other ground-disturbing activities, which could disturb or damage unknown archaeological resources. However, the General Plan EIR concluded that General Plan policies would require that areas identified to contain archaeological resources be evaluated and include mitigation, and impacts would be less than significant. In addition, the General Plan EIR concluded that adherence to Public Resources Code Section 5097.98 and Health and Safety Code Section 7050.5 would reduce impacts related to the disturbance of human remains to a less-than-significant level (City of Redlands, 2017b, pp. 3.8-23 – 3.8-24).

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Proposed Project
The proposed Project would rezone 24 sites for the purpose of increasing residential development capacity.

Buildout of the proposed Project would change the maximum buildout of the Project area from 828,349.93 square feet (SF) of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 111 multi-family dwelling units, 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses to residential uses with an allowed capacity of 2,436 units and approximately 151,048.46 SF of Public/Institutional uses. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings).

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

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

Less than Significant with Mitigation Incorporated. The Project site is located in an urbanized or urbanizing area. Sites 1, 3 through 6, 9, 10, 13 through 15, and 17 through 23 are heavily disturbed by development, current agricultural activities, or previous agricultural activities and do not contain any known resources that would increase the archaeological sensitivity of the sites. In addition, these sites are already slated for urban development activities pursuant to their respective current General Plan land use and zoning designations, as analyzed in the General Plan EIR. However, future development pursuant to the Redlands RHNA Rezone Project could involve grading, excavation, and other ground disturbing activities to previously undisturbed depths, which could result in inadvertent discovery of buried archaeological resources. As such, future development projects within Sites 1, 3 through 6, 9, 10, 13 through 15, and 17 through 23 would be required to implement Mitigation Measure CUL-3, which requires preparation of an archaeological resource assessment of the specific site and proposed development in accordance with the California Office of Historic Preservation. On properties where the potential for resources is identified through implementation of Mitigation Measure CUL-3, such studies shall provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the recommendations of a qualified cultural preservation expert, included as Mitigation Measure CUL-4.

In addition, the Morey Arroyo is located adjacent to or partially within Sites 2, 7, 8, 11, 12, 16, and 24.

While other segments of the Morey Arroyo were found to not constitute significant archaeological resources, water sources within the City are known to result in increased archaeological sensitivity in the surrounding areas. Therefore, future site-specific development projects pursuant to the Redlands RHNA Rezone Project within proximity to the Morey Arroyo could result in ground disturbing activities in areas highly sensitive for archaeological resources and could result in disturbance of unknown archaeological resources. Therefore, any future development in Sites 2, 7, 8, 11, 12, 16, and 24 that results in ground disturbing activities within 50 feet of the Morey Arroyo would be required to implement Mitigation Measure CUL-4 due to the high archaeological sensitivity.

With implementation of Mitigation Measures CUL-3 and CUL-4, impacts related to a substantial adverse change in the significance of an archaeological resource during buildout pursuant to the Redlands RHNA Rezone Project would be less than significant. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to archaeological resources would be less than significant.

5.3.7 CUMULATIVE IMPACTS
Cumulative impacts on cultural resources occur as the result of multiple projects affecting cultural resources involving a resource type or theme, such as historic ethnic sites or an industry (e.g., Santa Fe Depot), that Redlands Regular Meeting of 06-03-25
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occur within a larger geographic context than a site-specific development project site. Thus, this analysis considers cumulative development within the Valley Region of San Bernardino County, which is identified as sensitive for archaeological resources.

As described above, there is a possibility that ground-disturbing activities during future construction may uncover or disturb unknown archaeological resources. However, implementation of Mitigation Measures CUL- 3 and CUL-4 would reduce the potential impact to unknown resources. The likelihood of uncovering multiple currently unknown resources within the previously developed area that is sufficient to create a significant cumulative impact is low given the disturbed nature of the Sites and the few archaeological resources that have been found in the City to date. Thus, the cumulative effects of development on archaeological resources from implementation of the proposed Project with mitigation in combination with other projects would be less than significant.

5.3.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
None.

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

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

5.3.10 MITIGATION MEASURES
Initial Study Mitigation Measures
MM CUL-1 Demolition or alteration of a building or structure that is at least 50 years old at the time of permit application and has not previously been evaluated for demolition or renovation within the last five years from the time demolition or alternation is proposed shall be subject to review at the request of the City by a qualified architectural historian who meets the Secretary of the Interior’s Professional Qualifications Standards (PQS) in architectural history or history. The qualified architectural historian or historian shall conduct an intensive- level evaluation in accordance with the guidelines and best practices recommended by the State Office of Historic Preservation to identify if the building or structure proposed for demolition or alteration qualifies as a historical resource under CEQA guidelines. Buildings and structures shall be evaluated within their historic context and documented in a technical report and on Department of Parks and Recreation Series 523 forms. The report shall be submitted to the City for review and approval prior to the issuance of a building permit. If no historic resources are identified, no further analysis is warranted. If historic resources are identified, the applicant shall be required to implement Mitigation Measure CR-2.

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MM CUL-2 For renovations involving historical resources identified through the process described in the architectural history evaluation mitigation measure (MM CUL-1, project activities shall comply with the Secretary of the Interior’s Standards for the Treatment of Historic Properties (Standards). During the project planning phase (prior to any construction activities), input shall be sought from a qualified architectural historian or historic architect meeting the Secretary of the Interior’s Professional Qualifications Standards to ensure project compliance with the Standards for Rehabilitation. This input will ensure the avoidance of any direct/indirect physical changes to historical resources. The findings and recommendations of the architectural historian or historic architect shall be documented in a Standards Project Review Memorandum at the schematic design phase. This memorandum shall analyze all project components for compliance with the Standards for Rehabilitation. The memorandum should recommend design modifications necessary to bring projects into compliance with the Standards for Rehabilitation, which shall be incorporated into project designs to ensure compliance with the Standards. The memorandum shall be submitted to the City for review and approval prior to the issuance of a building permit.

EIR Mitigation Measures
MM CUL-3 Archeological Resources Assessment. Prior to the issuance of a grading permit for developments within the Sites 1, 3 through 6, 9, 10, 13 through 15, and 17 through 23 shall be required to prepare archaeological resource assessments in accordance with the California Office of Historic Preservation: Archaeological Resources Management Report Guidelines, with the purpose to assess, avoid, and mitigate potential impacts to archeological and tribal cultural resources as set forth in CEQA Regulations: Appendix G.

Archaeological resources assessments shall be performed under the supervision of an archaeologist that meets the Secretary of the Interior’s Professional Qualification Standards in either prehistoric or historic archaeology. The archaeological resources assessment shall include a Phase I pedestrian survey, undertaken to locate any surface cultural materials that may be present, and records search from the California Historical Resources Information System (CHRIS). The assessment shall be submitted to the City of Redlands prior to issuance of any demolition or grading permits. If an area identified as having a moderate to high potential for archaeological resources identified by the archaeological resource assessment, Mitigation Measure CUL-4 shall apply.

MM CUL-4 Archaeological Monitoring/Preservation.
• Highly Sensitive Sites: Prior to development within Sites 2, 7, 8, 11, 12, and 16 or where the Archaeological Resources Assessment conducted pursuant to Mitigation Measure CUL-3 finds the site to be highly sensitive for archaeological resources, a Secretary of the Interior (SOI) qualified archaeologist with at least 3 years of regional experience in archaeology shall monitor all ground-disturbing pre-construction and construction activities in areas of high sensitivity. Prior to issuance of grading permits, the qualified archaeologist shall develop a Cultural Resources Management Plan to address the details, timing, and responsibility of all archaeological and cultural resource activities that occur on the Project site and ensure that any discovered resources are avoided and preserved in place. The Cultural Resources Management Plan shall be developed in coordination with the consulting tribe(s) and address the details of all activities and provides procedures that must be followed in order to reduce the impacts to cultural resources to a level that is less than significant as well as address potential impacts to undiscovered buried archaeological resources associated with implementing projects.

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pre-construction meeting (with consultants, contractors, and monitors), a monitoring schedule during all initial ground-disturbance related activities, safety requirements, and protocols to follow in the event of previously unknown cultural resources discoveries that could be subject to a cultural resources evaluation. The Archaeologist shall conduct Cultural Resource Sensitivity Training, in conjunction with the Tribe(s) Tribal Historic Preservation Officer (THPO), and/or designated Tribal Representative. The training session shall focus on the archaeological and tribal cultural resources that may be encountered during ground-disturbing activities as well as the procedures to be followed in such an event. The Cultural Resources Management Plan shall be submitted to the City and the Consulting Tribe(s) for review and comment, prior to final approval by the City. In case of disagreements on the terms and procedures set forth in the Cultural Resources Management Plan, the City of Redlands Director of Development Services shall have the ultimate authority for approving or revising the Cultural Resources Management Plan.

In the event that cultural resources are discovered during project activities, all work in the immediate vicinity of the find (within a 60-foot buffer) shall cease and the qualified archaeologist shall assess the find. Work on other portions of the project outside the buffered area may continue during the assessment period. The Cultural Resources Management Plan shall stipulate that the landowner(s) and/or project applicant shall relinquish ownership of all cultural resources and provide evidence to the satisfaction of the City of Redlands Director of Development Services that all archaeological materials recovered during the archaeological investigations have been handled through one of the following methods:
• Avoidance and preservation in place or reburial onsite. This shall include measures and provisions to protect the reburial area from any future impacts.

Reburial shall not occur until all cataloging, analysis, and special studies have been completed on the cultural resources. Details of contents and location of the reburial shall be included in a Monitoring Report.
• Curation at a San Bernardino County curation facility that meets federal standards per 36 CFR (Code of Federal Regulations) Part 79 and, therefore, will be professionally curated and made available to other archaeologists/researchers and tribal members for further study. The collection and associated records shall be transferred, including title, and are to be accompanied by payment of the fees necessary for permanent curation.

Evidence shall be in the form of a letter from the curation facility identifying that archaeological materials have been received and that all fees have been paid.

In addition, the project would be required to adhere to Mitigation Measure TCR-1.

Consulting Tribe(s) shall be contacted regarding any pre-contact and/or historic-era finds and be provided information after the archaeologist makes his/her initial assessment of the nature of the find, so as to provide Tribal input with regards to significance and treatment. Should the Consulting Tribe(s) and archaeologist disagree on preferred treatment, the ultimate authority shall be the City of Redlands Director of Development Services.

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shall cease and the County Coroner shall be contacted pursuant to State Health and Safety Code Section 7050.5 and that code enforced for the duration of the project.

A Monitoring Report documenting the field and analysis results and interpreting the artifact and research data within the research context shall be completed and submitted to the City of Redlands Development Services Department prior to issuance of certificate of occupancy. The report will include DPR Primary and Archaeological Site Forms if any are required.
• Moderately Sensitive Sites: If the Archaeological Resources Assessment conducted under Mitigation Measure CUL-3 finds the site to be moderately sensitive for archaeological resources, a Secretary of the Interior (SOI) qualified archaeologist with at least 3 years of regional experience in archaeology shall be retained on-call. Prior to the start of construction activities, the archaeologist shall inform all construction personnel about the proper procedures to follow in the event of an inadvertent archaeological discovery. In the event that archaeological resources are discovered during ground-disturbing activities, construction activities in the immediate vicinity of the find (within a 60-foot buffer) shall cease and the qualified archaeologist shall be contacted to assess the find.

Work on other portions of the project outside the buffered area may continue during the assessment period. The Cultural Resources Management Plan shall stipulate that the landowner(s) and/or project applicant shall relinquish ownership of all cultural resources and provide evidence to the satisfaction of the City of Redlands Director of Development Services that all archaeological materials recovered during the archaeological investigations have been handled through one of the following methods:
• Avoidance and preservation in place or reburial onsite. This shall include measures and provisions to protect the reburial area from any future impacts.

Reburial shall not occur until all cataloging, analysis, and special studies have been completed on the cultural resources. Details of contents and location of the reburial shall be included in a Monitoring Report.
• Curation at a San Bernardino County curation facility that meets federal standards per 36 CFR (Code of Federal Regulations) Part 79 and, therefore, will be professionally curated and made available to other archaeologists/researchers and tribal members for further study. The collection and associated records shall be transferred, including title, and are to be accompanied by payment of the fees necessary for permanent curation.

Evidence shall be in the form of a letter from the curation facility identifying that archaeological materials have been received and that all fees have been paid.

In addition, the project would be required to adhere to Mitigation Measure TCR-1.

Consulting Tribe(s) shall be contacted regarding any pre-contact and/or historic-era finds and be provided information after the archaeologist makes his/her initial assessment of the nature of the find, so as to provide Tribal input with regards to significance and treatment. Should the Consulting Tribe(s) and archaeologist disagree on preferred treatment, the ultimate authority shall be the City of Redlands Director of Development Services.

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shall cease and the County Coroner shall be contacted pursuant to State Health and Safety Code Section 7050.5 and that code enforced for the duration of the project.

A Monitoring Report documenting the field and analysis results and interpreting the artifact and research data within the research context shall be completed and submitted to the City of Redlands Development Services Department prior to issuance of certificate of occupancy. The report will include DPR Primary and Archaeological Site Forms if any are required.

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

5.3.12 REFERENCES
Architectural Resources Group. (August 2018). Redlands Historic Architectural Design Guidelines. Retrieved July 2, 2024, from https://cityofredlands.org/sites/main/files/file- attachments/redlands_design_guidelines_draft_pages_reduced.pdf City of Redlands. (2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Retrieved July 2, 2024, from https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 City of Redlands. (2024). City of Redlands East Valley Corridor Specific Plan. Retrieved October 17, 2024, from https://www.cityofredlands.org/sites/main/files/file-attachments/ev-division-

5.pdf?1582744515
City of Redlands. (N.D.) City of Redlands Municipal Code . Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 EPD Solutions, Inc. (July 2022). Redlands General Plan Transit Villages District and Specific Plan Project Draft Environmental Impact Report. Retrieved July 2, 2024, from https://ceqanet.opr.ca.gov/2021080622/2
McKenna, Jeanette A. (2015). California Historical Resources Inventory site record, 36-029388 . On file, South Central Coastal Information Center, California State University, Fullerton.

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5.4 Energy

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

Refer to Section 5.5, Greenhouse Gas Emissions , for a discussion of the relationship between energy consumption and greenhouse gas (GHG) emissions, and Section 5.12 , Utilities and Service Systems, for a discussion of water consumption.

This section includes data from the following City documents and reports:
• City of Redlands General Plan 2035 , December 2017;
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report, July 2017; • City of Redlands Municipal Code; and
• Regional Housing Needs Assessment Energy Tables , Urban Crossroads, September 2024. Appendix D.

5.4.2 REGULATORY SETTING

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

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

5.4.2.2 State Regulations
Title 24 Energy Efficiency Standards and California Green Building Standards California Code of Regulations (CCR) Title 24, Part 6, California Energy Code , was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption. CCR Title 24, Part 11, California Green Building Standards (CALGreen), was first published in 2008 and took effect in 2009.

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California Green Building Standards that became effective January 1, 2023. The updated 2022 standards include the following:

Residential Mandatory Measures
• Electric vehicle (EV) charging stations. New construction shall comply with Section 4.106.4.1, 4.106.4.2,

4.106.4.3, to facilitate future installation and use of EV chargers. Electric vehicle supply equipment (EVSE) shall be installed in accordance with the California Electrical Code, Article 625. (4.106.4). o New one- and two-family dwellings and town-houses with attached private garages. For each dwelling unit, install a listed raceway to accommodate a dedicated 208/240-volt branch circuit.

The raceway shall not be less than trade size 1 (nominal 1-inch inside diameter). The raceway shall originate at the main service or subpanel and shall terminate into a listed cabinet, box or other enclosure in close proximity to the proposed location of an EV charger. Raceways are required to be continuous at enclosed, inaccessible or concealed areas and spaces. The service panel and/or subpanel shall provide capacity to install a 40-ampere 208/240-volt minimum dedicated branch circuit and space(s) reserved to permit installation of a branch circuit overcurrent protective device. o New hotels and motels. All newly constructed hotels and motels shall provide EV spaces capable of supporting future installation of EVSE. The construction documents shall identify the location of the EV spaces. The number of required EV spaces shall be based on the total number of parking spaces provided for all types of parking facilities in accordance with Table 4.106.4.3.1. • Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with Sections 4.303.1.1, 4.303.1.2, 4.303.1.3, and 4.303.1.4. • Outdoor potable water use in landscape areas. Residential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources‘ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent. • Operation and maintenance manual. At the time of final inspection, a manual, compact disc, web-based reference or other media acceptable to the enforcing agency which includes all of the following shall be placed in the building:
o Directions to the owner or occupant that the manual shall remain with the building throughout the life cycle of the structure.
o Operations and maintenance instructions for the following:
 Equipment and appliances, including water-saving devices and systems, HVAC systems, photovoltaic systems, EV chargers, water-heating systems and other major appliances and equipment.
 Roof and yard drainage, including gutter and downspouts.  Space conditioning systems, including condensers and air filters.  Landscape irrigation systems.
 Water reuse systems.
o Information from local utility, water and waste recovery providers on methods to further reduce future resource consumption, including recycling programs and locations. o Public transportation and/or carpool options available in the area. o Educational material on the positive impacts of an interior relative humidity between 30-60% and what methods occupants may use to maintain the relative humidity level in that range. o Information about water-conserving landscape and irrigation design and controllers which conserve water.

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o Instructions for maintaining gutters and downspouts and the importance of diverting water at least 5 feet away from the foundation.
o Information about state solar energy and incentive programs available. o A copy of all special inspection verifications required by the enforcing agency of this code. o Information from CALFIRE on maintenance of defensible space around residential structures. • Any installed gas fireplace shall be direct-vent sealed-combustion type. Any installed woodstove or pellet stove shall comply with U.S. EPA New Source Performance Standards (NSPS) emission limits as applicable and shall have a permanent label indicating they are certified to meet the emission limits.

Woodstoves, pellet stoves and fireplaces shall also comply with applicable local ordinances. • Paints and coatings. Architectural paints and coatings shall comply with VOC limits in Table 1 of the CARB [California Air Resources Board] Architectural Suggested Control Measure, as shown in Table

4.504.3, unless more stringent local limits apply. The VOC content limit for coatings that do not meet the definitions for the specialty coatings categories listed in Table 4.504.3 shall be determined by classifying the coating as a Flat, Nonflat, or Nonflat-high Gloss coating, based on its glass, as defined in subsections

4.21, 4.36, and 4.37 of the 2007 CARB, Suggested Control Measure, and the corresponding Flat, Nonflat, Nonflat-high Gloss VOC limit in Table 4.504.3 shall apply.

Nonresidential Mandatory Measures
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with a minimum of one two-bike capacity rack (5.106.4.1.1). • Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant- occupants, provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility (5.106.4.1.2). • EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The compliance requires empty raceways for future conduit and documentation that the electrical system has adequate capacity for the future load. The number of spaces to be provided for is contained in T able 5.106.

5.3.3 (5.106.5.3). Additionally, T able 5.106.5.4.1 specifies requirements for the installation of raceway conduit and panel power requirements for medium- and heavy-duty EV supply equipment for warehouses, grocery stores, and retail stores.
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight and glare ratings per T able 5.106.8 (5.106.8).
• Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the nonhazardous construction and demolition waste in accordance with Section 5.408.1.1. 5.405.1.2, or 5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever is more stringent (5.408.1).
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reuse or recycled. For a phased project, such material may be stockpiled onsite until the storage site is developed (5.408.3). • Recycling by Occupants. Provide readily accessible areas that serve the entire building andare identified for the depositing, storage, and collection of non-hazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully enacted local recycling ordinance, if more restrictive (5.410.1). • Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with the following:

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o Water Closets. The effective flush volume of all water closets shall not exceed 1.28 gallons per flush (5.303.3.1)
o Urinals. The effective flush volume of wall-mounted urinals shall not exceed 0.125 gallons per flush (5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed

0.5 gallons per flush (5.303.3.2.2).
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons per minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the combine flow rate of all showerheads and/or other shower outlets controlled by a single valve shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2). o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not more than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum flow rate of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall have a maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering faucets shall not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash fountains shall have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5). • Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources’ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1). • Water meters. Separate submeters or metering devices shall be installed for new buildings or additions in excess of 50,000 sf or for excess consumption where any tenant within a new building or within an addition that is project to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and

5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 sf. Rehabilitated landscape projects with an aggregate landscape area equal to or greater than 2,500 sf requiring a building or landscape permit (5.304.3).
• Commissioning. For new buildings 10,000 sf and over, building commissioning shall be included in the design and construction processes of the building project to verify that the building systems and components meet the owner’s or owner representative’s project requirements (5.410.2).

CALGreen has been adopted by the City of Redlands by reference in Municipal Chapter 15.16.

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

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

Action 8-A.8 Implement and enforce California Code of Regulations Title 24 building standards (parts 6 and 11) to improve energy efficiency in new or substantially remodeled construction.

Consider implementing incentives for builders that exceed the standards included in Title 24 and recognize their achievements over the minimum standards.

Action 8-A.9 Encourage the use of construction, roofing materials, and paving surfaces with solar reflectance and thermal emittance values per the California Green Building Code (Title 24, Part 11 of the California Code of Regulations) to minimize heat island effects.

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5.4.3 ENVIRONMENTAL SETTING
Electricity
The Southern California Edison Company (SCE) is the electrical purveyor in the City of Redlands. SCE provides electricity service to more than 14 million people in a 50,000 square-mile area of central, coastal and Southern California. California utilities are experiencing increasing demands that require modernization of the electric distribution grid to, among other things, accommodate two-way flows of electricity and increase the grid's capacity. SCE is in the process of implementing infrastructure upgrades to ensure the ability to meet future demands. In addition, as described by the Edison International 2023 Annual Report, the SCE electrical grid modernization effort supports implementation of California Senate Bill 32 that requires the State to cut GHG emissions 40 percent below 1990 levels by 2030 and 80 percent from the same baseline by 2050 in order to help achieve carbon neutrality by 2045. It describes that in 2023 approximately 49 percent of power that SCE delivered to customers came from carbon-free resources (SCE, 2023).

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

Natural Gas
The Southern California Gas Company (SoCalGas) is the natural gas purveyor in the City of Redlands and is the principal distributor of natural gas in Southern California. SoCalGas estimates that gas demand will decline at an annual rate of 2 percent each year through 2040 due to modest economic growth, mandated energy efficiency standards and programs, renewable electricity goals, and conservation savings linked to advanced metering infrastructure. The gas supply available to SoCalGas is regionally diverse and includes supplies from California sources (onshore and offshore), Southwestern U.S. supply sources, the Rocky Mountains, and Canada. SoCalGas designs its facilities and supplies to provide continuous service during extreme peak demands and has identified the ability to meet peak demands through 2040 in its 2024 report (CGEU, 2024).

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

Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. This would result in the annual consumption of 4,330,815 gallons of fuel per year from traffic, 31,062,419 kBTU per year, and 19,869,824 kWh per year.

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

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

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

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

According to Appendix F of the CEQA Guidelines, conserving energy is defined as decreasing overall per capita energy consumption, decreasing reliance on natural gas and oil, and increasing reliance on renewable energy sources. Neither Appendix F of the CEQA Guidelines nor Public Resources Code Section 21100(b)(3) offer a numerical threshold of significance that might be used to evaluate the potential significance of energy consumption of a project. Rather, the emphasis is on reducing “the wasteful, inefficient, and unnecessary consumption of energy.”
Construction activities would result in wasteful, inefficient, or unnecessary use of energy if construction equipment is old or not well maintained, if equipment is left to idle when not in use, if travel routes are not planned to minimize vehicle miles traveled, or if excess lighting or water is used. Energy usage during project operation would be considered “wasteful, inefficient, and unnecessary” if the project were to violate federal, State, and/or local energy standards, including Title 24 of the California Code of Regulations, inhibit pedestrian or bicycle mobility, inhibit access to transit, or inhibit feasible opportunities to use alternative energy sources, such as solar energy, or otherwise inhibit the conservation of energy.

5.4.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
The General Plan EIR determined that future development would result in an increased use of energy since there would be an additional demand for electricity and natural gas supply and services. Despite the overall increase in future energy use with implementation of the State’s current and future energy code and the General Plan policies, energy efficient designs in new developments would be ensured. As a result, the General Plan EIR concluded that there is a less-than-significant impact related to development under the General Plan causing a wasteful, inefficient, and unnecessary consumption of energy during construction, operation, and/or maintenance. It was also determined that the General Plan would have a less-than- significant impact related to conflict with the California Energy Efficiency Standards, the California Air Resources Board (CARB) passenger vehicle GHG emission reduction targets for 2020 and 2035, or any other applicable energy conservation regulations.

Proposed Project
As detailed in Section 3.0, Project Description, the proposed Project would rezone 24 sites totaling 116.19 acres for the City of Redlands Housing Element Regional Housing Needs Allocation (RHNA). Buildout of the proposed Project would change the maximum buildout of the Project area form 828,349.93 square feet (SF) of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses, 111 multi-family dwelling units, to residential uses with an allowed capacity of 2,436 units and 151,048.46 SF of Public/Institutional development. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings). However, the timing of development and operation of the development pursuant to the RHNA rezone would be dependent upon market conditions and development applications for new projects.

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

ENVIRONMENTAL IMPACT DUE TO WASTEFUL, INEFFICIENT, OR UNNECESSARY

CONSUMPTION OF ENERGY RESOURCES, DURING PROJECT CONSTRUCTION OR OPERATION.

Construction
Less than Significant Impact. Construction of future new uses pursuant to the proposed zoning would consume energy in three general forms:

1. Petroleum-based fuels used to power off-road construction vehicles and equipment, construction worker travel to and from the Project site, and delivery truck trips;

2. Electricity associated with providing temporary power for lighting and electric equipment; and

3. Energy used in the production of construction materials, such as asphalt, steel, concrete, pipes, and manufactured or processed materials such as lumber and glass.

Construction activities pursuant to buildout of the proposed rezoned sites would not involve consumption of natural gas because the construction-related equipment would not be powered by natural gas. Construction activities are not expected to result in demand for fuel greater on a per-unit-of-development basis than either that used to buildout the existing land use and zoning designations and other development projects in Southern California as each project would be reviewed and permitted pursuant to City requirements, including Title 24 and CALGreen. Also, CCR Title 13, Motor Vehicles, Section 2449(d)(3), Idling, limits idling times of construction vehicles to no more than 5 minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment.

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

Overall, construction activities would be required by City permitting to comply with all existing regulations and would therefore not be expected to use large amounts of energy or fuel in a wasteful manner. Thus, impacts related to construction energy usage would be less than significant.

Operation
Less than Significant Impact. Once operational, the new developments from both the buildout of the existing General Plan land uses and the proposed rezoning provide for urban uses that would generate demand for electricity and natural gas, as well as gasoline for motor vehicle trips. Operational use of energy includes the heating, cooling, and lighting of buildings, water heating, operation of electrical systems and plug-in appliances within buildings, parking lot and outdoor lighting, and the transport of electricity, natural gas, and water to the areas where they would be used. This use of energy is typical for urban development, and no operational activities or land uses are included that would result in extraordinary energy consumption.

As described above, buildout of the Project site with the existing General Plan land uses would result in development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family residences, whereas buildout of the proposed Project would result in development of 2,436 residential units and 151,048.46 SF of Public/Institutional development. As detailed in Section 5.10, Transportation, buildout pursuant to the proposed Project is forecasted to generate a net decrease of 27,450 average daily trips, net increase of 1,034 AM trips, and net decrease of 1,716 PM trips. As such, buildout pursuant to the Project would result in decreased daily vehicle trips compared to buildout pursuant to the existing General Plan. The estimated transportation energy demands from the existing General Plan buildout are summarized in Table 5.4-1.

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Table 5.4-1: Existing General Plan Buildout Traffic Annual Fuel Consumption Vehicle Type Annual VMT Estimated Annual Fuel
Consumption (gallons)
Approved GP Buildout (All Vehicles) 93,509,476 4,330,815 Source: Appendix D.

As detailed in Table 5.4-2, operation of the proposed Project at buildout is estimated to annually use 2,081,210 gallons of fuel, which is an net decrease of 2,249,606 gallons of fuel compared to buildout of the existing General Plan land uses of the Project sites.

Table 5.4-2: Project-Generated Traffic Annual Fuel Consumption Vehicle Type Average Vehicle Fuel
Economy (mpg) Annual VMT 1 Estimated Annual Fuel
Consumption (gallons)
LDA 39.94 29,560,918 740,041
LDT1 30.29 2,006,017 66,234
LDT2 30.34 14,420,934 475,322
MDV 25.15 9,321,507 370,627
LHD1 23.08 1,667,662 72,259
LHD2 21.02 455,739 21,678
MHD 12.16 1,238,093 101,833
HHD 7.82 1,254,368 160,374
OBUS 8.08 32,700 4,046
UBUS 12.86 17,884 1,391
MCY 43.29 1,214,606 28,060
SBUS 7.28 62,867 8,637
MH 5.98 183,552 30,707
Total (All Vehicles) 61,436,848 2,081,210
Approved GP Buildout (All Vehicles) 93,509,476 4,330,815 Net (Proposed – Approved GP Buildout) -32,072,628 -2,249,606 Source: Appendix D.

Table 5.4-3 details that operation of the proposed rezoning at buildout would use approximately 30,522,697 thousand British thermal units (kBTU) per year of natural gas and 11,493,948 kWh per year of electricity. The proposed Project would result in an estimated annual net decrease of 539,722 kBTU/year of natural gas and an annual decrease of 8,375,876 kWh/year in electricity compared to operation of the existing General Plan land uses at buildout.

Table 5.4-3: Project Annual Operational Natural Gas and Electricity Demand Summary Land Use Natural Gas Demand
(kBTU/year)
Electricity Demand
(kWh/year)
Multi-family Housing 26,886,569 10,514,171
Day Care Center 3,636,128 979,777
Total Project Energy Demand 30,522,697 11,493,948
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Land Use Natural Gas Demand
(kBTU/year)
Electricity Demand
(kWh/year)
Approved GP Buildout Energy Demand 31,062,419 19,869,824 Net (Proposed – Approved GP Buildout) -539,722 -8,375,876 Source: Appendix D.

The proposed Project would result in less energy consumption compared to buildout of the existing General Plan. Additionally, because this use of energy is typical for urban development, no operational activities or land uses would occur that would result in extraordinary energy consumption, and through City permitting, assurance would be provided that existing regulations related to energy efficiency and consumption, such as Title 24 regulations, would be implemented. Likewise, many of the future developments would include solar panels on rooftops and over parking areas to provide onsite energy generation. Each future project would be reviewed for inclusion of solar infrastructure as required by CALGreen regulations through the City’s development review and permitting process. Therefore, impacts related to wasteful, inefficient, or unnecessary consumption of energy resources from operational activities would be less than significant.

IMPACT E-2: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT A STATE OR LOCAL PLAN FOR RENEWABLE ENERGY OR ENERGY EFFICIENCY.

No Impact. As described previously, the development that would occur pursuant to the proposed Project would be required to meet the CCR Title 24 energy efficiency standards in effect during permitting of future development projects. The City’s administration of the CCR Title 24 requirements includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. Likewise, the Project would not conflict with or obstruct opportunities to use renewable energy, such as solar energy. Future buildings pursuant to the proposed zoning would have solar infrastructure as required by CCR Title 24 requirements. Thus, the Project would not obstruct use of renewable energy or energy efficiency. Overall, the Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR.

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

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

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

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

Plans, Programs, or Policies
None.

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

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

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

5.4.12 REFERENCES
California Energy Commission (CEC). (2022). 2022 Title 24 Building Energy Standards . https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency- standards/2022-building-energy-efficiency
California Gas and Electric Utilities (CGEU). (2024). 2024 California Gas Report https://www.socalgas.com/sites/default/files/2024-California-Gas-Report-Final.pdf Southern California Edison (SCE). (2023). Edison International 2023 Annual Report. https://www.edison.com/investors/financial-reports-information/annual-reports Southern California Edison (SCE). (2024). Reliability. http://sce.com/wps/portal/home/about-us/reliability.

City of Redlands. (2017a). Redlands General Plan 2035 . https://www.cityofredlands.org/post/planning- division-general-plan
City of Redlands. (2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2024). City of Redlands Municipal Code. https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Southern California Association of Governments (SCAG). (n.d.). 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction. https://scag.ca.gov/sites/main/files/file- attachments/2016_2040rtpscs_finalgrowthforecastbyjurisdiction.pdf?1605576071 Redlands Regular Meeting of 06-03-25
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Urban Crossroads. (2024). Regional Housing Needs Assessment Rezone Energy Tables. (Appendix D) Redlands Regular Meeting of 06-03-25
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5.5 Greenhouse Gases

5.5.1 INTRODUCTION
This section evaluates the potential for implementation of the proposed Project to cumulatively contribute to greenhouse gas (GHG) emissions impacts. Because no single project is large enough to result in a measurable increase in global concentrations of GHG emissions, impacts of the proposed Project are considered on a cumulative basis. This evaluation is based on the methodology recommended by the South Coast Air Quality Management District (SCAQMD). This section also addresses the Project’s consistency with applicable plans, policies, and public agency regulations adopted for the purpose of reducing GHG emissions. The analysis within this section is based on the following City documents and technical report prepared for the Project:
• City of Redlands General Plan 2035 , December 2017;
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report, July 2017; • City of Redlands Municipal Code; and
• Regional Housing Needs Assessment Rezone Greenhouse Gas Impact Analysis, Urban Crossroads, September 2024. Included as Appendix E.

5.5.2 REGULATORY SETTING

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

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

5.5.2.2 State Regulations
California Assembly Bill 1493– Pavley
In 2002, the California Legislature adopted Assembly Bill (AB) 1493 requiring the adoption of regulations to reduce GHG emissions in the transportation sector. In September 2004, pursuant to AB 1493, the CARB approved regulations to reduce GHG emissions from new motor vehicles beginning with the 2009 model year (Pavley Regulations). In September 2009, CARB adopted amendments to the Pavley Regulations to reduce GHG from 2009 to 2016. CARB, EPA, and the U.S. Department of Transportation’s National Highway Redlands Regular Meeting of 06-03-25
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Traffic and Safety Administration (NHTSA) have coordinated efforts to develop fuel economy and GHG standards for model 2017-2025 vehicles. The GHG standards are incorporated into the “Low Emission Vehicle” (LEV) Regulations.

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

California Assembly Bill 32 (AB 32), Global Warming Solutions Act of 2006 (Chapter 488, Statutes of 2006)
In 2006, the Legislature passed the California Global Warming Solutions Act of 2006 (Assembly Bill [AB] 32), which created a comprehensive, multi-year program to reduce GHG emissions in California to 1990 levels by 2020. This goal has been met. 1 GHGs as defined under AB 32 include carbon dioxide (CO 2), methane (CH 4), nitrous oxide (N 2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6). Since AB 32 was enacted, a seventh chemical, nitrogen trifluoride (NF 3), has also been added to the list of GHGs. CARB is the State agency charged with monitoring and regulating sources of GHGs. Pursuant to AB 32, CARB adopted regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions. AB 32 states the following:
“Global warming poses a serious threat to the economic well-being, public health, natural resources, and the environment of California. The potential adverse impacts of global warming include the exacerbation of air quality problems, a reduction in the quality and supply of water to the state from the Sierra snowpack, a rise in sea levels resulting in the displacement of thousands of coastal businesses and residences, damage to marine ecosystems and the natural environment, and an increase in the incidences of infectious diseases, asthma, and other human health-related problems.”
Senate Bill 375 (Chapter 728, Statutes of 2008)
In August 2008, the Legislature passed, and on September 30, 2008, Governor Schwarzenegger signed, Senate Bill [SB] 375, which addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. Regional GHG reduction targets for the automobile and light-truck sector for 2020 and 2035, as determined by CARB, are required to consider the emission reductions associated with vehicle emission standards (see SB 1493), the composition of fuels (see Executive Order S-1-07), and other CARB-approved measures to reduce GHG emissions. Regional metropolitan planning organizations (MPOs) will be responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a development plan for the region, which, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, an MPO must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through 1 Based upon the 2019 GHG inventory data (i.e., the latest year for which data are available) for the 2000-2017 GHG emissions period, California emitted an average 424.1 MMTCO 2e (Appendix E). This is less than the 2020 emissions target of 431 MMTCO 2e.

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alternative development patterns, infrastructure, or additional transportation measures or policies. SB 375 provides incentives for streamlining CEQA requirements by substantially reducing the requirements for “transit priority projects,” as specified in SB 375, and eliminating the analysis of the impacts of certain residential projects on global warming and the growth-inducing impacts of those projects when the projects are consistent with the SCS or Alternative Planning Strategy. On September 23, 2010, CARB adopted the SB 375 targets for the regional MPOs.

Executive Order B-30-15 – 2030 Statewide Emission Reduction Target Executive Order B-30-15 was signed by Governor Jerry Brown on April 29, 2015, establishing an interim statewide GHG reduction target of 40 percent below 1990 levels by 2030, which is necessary to guide regulatory policy and investments in California in the midterm, and put California on the most cost-effective path for long-term emission reductions. Under this Executive Order, all State agencies with jurisdiction over sources of GHG emissions are required to continue to develop and implement emissions reduction programs to reach the State’s 2050 target and attain a level of emissions necessary to avoid dangerous climate change. According to the Governor’s Office, this Executive Order is in line with the scientifically established levels needed in the United States to limit global warming below 2°C, the warming threshold at which scientists say there will likely be major climate disruptions such as super droughts and rising sea levels.

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

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

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

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that a project’s cumulative effect is not cumulatively considerable, according to proposed Section 15183.5(b).

California Air Resources Board Scoping Plan
On December 15, 2022, CARB adopted the 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan). The 2022 Scoping Plan builds on the previous 2017 Scoping Plan as well as the requirements set forth by AB 1279, which directs the State to become carbon neutral no later than 2045. To achieve this statutory objective, the 2022 Scoping Plan lays out how California can reduce GHG emissions by 85 percent below 1990 levels and achieve carbon neutrality by 2045. The Scoping Plan scenario to do this is to “deploy a broad portfolio of existing and emerging fossil fuel alternatives and clean technologies, and align with statutes, Executive Orders, Board direction, and direction from the governor.” The 2022 Scoping Plan sets one of the most aggressive approaches to reach carbon neutrality in the world. Unlike the 2017 Scoping Plan, CARB no longer includes a numeric per capita threshold and instead advocates for compliance with a local GHG reduction strategy (CAP) consistent with CEQA Guidelines section 15183.5.

The key elements of the 2022 CARB Scoping Plan focus on transportation; the regulations that effect this sector are adopted and enforced by CARB on vehicle manufacturers and outside the jurisdiction and control of local governments. As stated in the Plan’s executive summary:
“The major element of this unprecedented transformation is the aggressive reduction of fossil fuels wherever they are currently used in California, building on and accelerating carbon reduction programs that have been in place for a decade and a half. That means rapidly moving to zero-emission transportation; electrifying the cars, buses, trains, and trucks that now constitute California’s single largest source of planet-warming pollution.” “[A]pproval of this plan catalyzes a number of efforts, including the development of new regulations as well as amendments to strengthen regulations and programs already in place, not just at CARB but across state agencies.”
Under the 2022 Scoping Plan, the 2045 carbon neutrality goal is to be implemented by the following objectives:
• Reimagine roadway projects that increase VMT in a way that meets community needs and reduces the need to drive.
• Double local transit capacity and service frequencies by 2030. • Complete the High-Speed Rail (HSR) System and other elements of the intercity rail network by 2040. • Expand and complete planned networks of high-quality active transportation infrastructure. • Increase availability and affordability of bikes, e-bikes, scooters, and other alternatives to light-duty vehicles, prioritizing needs of underserved communities. • Shift revenue generation for transportation projects away from the gas tax into more durable sources by 2030.
• Authorize and implement roadway pricing strategies and reallocate revenues to equitably improve transit, bicycling, and other sustainable transportation choices. • Prioritize addressing key transit bottlenecks and other infrastructure investments to improve transit operational efficiency over investments that increase VMT. • Develop and implement a statewide transportation demand management (TDM) framework with VMT mitigation requirements for large employers and large developments. • Prevent uncontrolled growth of autonomous vehicle (AV) VMT, particularly zero-passenger miles. • Channel new mobility services towards pooled use models, transit complementarity, and lower VMT outcomes.

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• Establish an integrated statewide system for trip planning, booking, payment, and user accounts that enables efficient and equitable multimodal systems.
• Provide financial support for low-income and disadvantaged Californians’ use of transit and new mobility services.
• Expand universal design features for new mobility services. • Accelerate infill development in existing transportation-efficient places and deploy strategic resources to create more transportation-efficient locations.
• Encourage alignment in land use, housing, transportation, and conservation planning in adopted regional plans (RTP/SCS and RHNA) and local plans (e.g., general plans, zoning, and local transportation plans). • Accelerate production of affordable housing in forms and locations that reduce VMT and affirmatively further fair housing policy objectives.
• Reduce or eliminate parking requirements (and/or enact parking maximums, as appropriate) and promote redevelopment of excess parking, especially in infill locations. • Preserve and protect existing affordable housing stock and protect existing residents and businesses from displacement and climate risk.

Included in the 2022 Scoping Plan is a set of Local Actions (Appendix D to the 2022 Scoping Plan) aimed at providing local jurisdictions with tools to reduce GHGs and assist the State in meeting the ambitious targets set forth in the 2022 Scoping Plan. Appendix D to the 2022 Scoping Plan includes a section on evaluating plan-level and project-level alignment with the State’s Climate Goals in CEQA GHG analyses. In this section, CARB identifies several recommendations and strategies that should be considered for new development in order to determine consistency with the 2022 Scoping Plan. Notably, this section is focused on Residential and Mixed-Use Projects; CARB states in Appendix D (page 4) that this section “…focuses primarily on climate action plans (CAPs) and local authority over new residential development. It does not address other land use types (e.g., industrial) or air permitting.”
Additionally on Page 21 in Appendix D, CARB states: “The recommendations outlined in this section apply only to residential and mixed-use development project types. California currently faces both a housing crisis and a climate crisis, which necessitates prioritizing recommendations for residential projects to address the housing crisis in a manner that simultaneously supports the State’s GHG and regional air quality goals. CARB plans to continue to explore new approaches for other land use types in the future.” As such, it would be inappropriate to apply the requirements contained in Appendix D of the 2022 Scoping Plan to any land use types other than residential or mixed-use residential development.

California Title 24 Energy Efficiency Standards and California Green Building Standards California Code of Regulations (CCR) Title 24 Part 6: California Energy Code was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption. CCR Title 24 Part 11:

California Green Building Standards (CALGreen) was first published in 2008 and took effect in 2009.

CALGreen is updated on a regular basis, with the most recent approved update consisting of the 2022 California Green Building Code Standards that became effective January 1, 2023.

The 2022 CALGreen Building Standards Code has been adopted by the City of Redlands in Section 15.16 of the City’s Municipal Code.

Residential Mandatory Measures
• Electric vehicle (EV) charging stations. New construction shall comply with Section 4.106.4.1, 4.106.4.2,

4.106.4.3, to facilitate future installation and use of EV chargers. Electric vehicle supply equipment (EVSE) shall be installed in accordance with the California Electrical Code, Article 625. (4.106.4).

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o New one- and two-family dwellings and town-houses with attached private garages. For each dwelling unit, install a listed raceway to accommodate a dedicated 208/240-volt branch circuit.

The raceway shall not be less than trade size 1 (nominal 1-inch inside diameter). The raceway shall originate at the main service or subpanel and shall terminate into a listed cabinet, box or other enclosure in close proximity to the proposed location of an EV charger. Raceways are required to be continuous at enclosed, inaccessible or concealed areas and spaces. The service panel and/or subpanel shall provide capacity to install a 40-ampere 208/240-volt minimum dedicated branch circuit and space(s) reserved to permit installation of a branch circuit overcurrent protective device. o New hotels and motels. All newly constructed hotels and motels shall provide EV spaces capable of supporting future installation of EVSE. The construction documents shall identify the location of the EV spaces. The number of required EV spaces shall be based on the total number of parking spaces provided for all types of parking facilities in accordance with Table 4.106.4.3.1. • Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with Sections 4.303.1.1, 4.303.1.2, 4.303.1.3, and 4.303.1.4. • Outdoor potable water use in landscape areas. Residential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources‘ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent. • Operation and maintenance manual. At the time of final inspection, a manual, compact disc, web-based reference or other media acceptable to the enforcing agency which includes all of the following shall be placed in the building:
o Directions to the owner or occupant that the manual shall remain with the building throughout the life cycle of the structure.
o Operations and maintenance instructions for the following:
 Equipment and appliances, including water-saving devices and systems, HVAC systems, photovoltaic systems, EV chargers, water-heating systems and other major appliances and equipment.
 Roof and yard drainage, including gutter and downspouts.  Space conditioning systems, including condensers and air filters.  Landscape irrigation systems.
 Water reuse systems.
o Information from local utility, water and waste recovery providers on methods to further reduce future resource consumption, including recycling programs and locations. o Public transportation and/or carpool options available in the area. o Educational material on the positive impacts of an interior relative humidity between 30-60% and what methods occupants may use to maintain the relative humidity level in that range. o Information about water-conserving landscape and irrigation design and controllers which conserve water.
o Instructions for maintaining gutters and downspouts and the importance of diverting water at least 5 feet away from the foundation.
o Information about state solar energy and incentive programs available. o A copy of all special inspection verifications required by the enforcing agency of this code. o Information from CALFIRE on maintenance of defensible space around residential structures. • Any installed gas fireplace shall be direct-vent sealed-combustion type. Any installed woodstove or pellet stove shall comply with U.S. EPA New Source Performance Standards (NSPS) emission limits as applicable and shall have a permanent label indicating they are certified to meet the emission limits.

Woodstoves, pellet stoves and fireplaces shall also comply with applicable local ordinances.

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• Paints and coatings. Architectural paints and coatings shall comply with VOC limits in Table 1 of the CARB Architectural Suggested Control Measure, as shown in Table 4.504.3, unless more stringent local limits apply. The VOC content limit for coatings that do not meet the definitions for the specialty coatings categories listed in Table 4.504.3 shall be determined by classifying the coating as a Flat, Nonflat, or Nonflat-high Gloss coating, based on its glass, as defined in subsections 4.21, 4.36, and 4.37 of the 2007 CARB, Suggested Control Measure, and the corresponding Flat, Nonflat, Nonflat-high Gloss VOC limit in Table 4.504.3 shall apply.

Nonresidential Mandatory Measures
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with a minimum of one two-bike capacity rack (5.106.4.1.1). • Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant- occupants, provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility (5.106.4.1.2). • EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The compliance requires empty raceways for future conduit and documentation that the electrical system has adequate capacity for the future load. The number of spaces to be provided for is contained in T able 5.106.

5.3.3 (5.106.5.3). Additionally, T able 5.106.5.4.1 specifies requirements for the installation of raceway conduit and panel power requirements for medium- and heavy-duty EV supply equipment for warehouses, grocery stores, and retail stores.
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight and glare ratings per T able 5.106.8 (5.106.8).
• Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the nonhazardous construction and demolition waste in accordance with Section • 5.408.1.1. 5.405.1.2, or 5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever is more stringent (5.408.1).
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reuse or recycled. For a phased project, such material may be stockpiled on site until the storage site is developed (5.408.3). • Recycling by Occupants. Provide readily accessible areas that serve the entire building andare identified for the depositing, storage, and collection of non-hazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully enacted local recycling ordinance, if more restrictive (5.410.1). • Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed o 1.28 gallons per flush (5.303.3.1)
o Urinals. The effective flush volume of wall-mounted urinals shall not exceed o 0.125 gallons per flush (5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed 0.5 gallons per flush (5.303.3.2.2).
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons per minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the combine flow rate of all showerheads and/or other shower outlets controlled by a single valve shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).

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o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not more than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum flow rate of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall have a maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering faucets shall not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash fountains shall have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5). • Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources’ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1). • Water meters. Separate submeters or metering devices shall be installed for new buildings or additions in excess of 50,000 SF or for excess consumption where any tenant within a new building or within an addition that is project to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and

5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 SF. Rehabilitated landscape projects with an aggregate landscape area equal to or greater than 2,500 SF requiring a building or landscape permit (5.304.3).
• Commissioning. For new buildings 10,000 SF and over, building commissioning shall be included in the design and construction processes of the building project to verify that the building systems and components meet the owner’s or owner representative’s project requirements (5.410.2).

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

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

Action 8-A.8 Implement and enforce California Code of Regulations Title 24 building standards (parts 6 and 11) to improve energy efficiency in new or substantially remodeled construction.

Consider implementing incentives for builders that exceed the standards included in Title 24 and recognize their achievements over the minimum standards.

Action 8-A.9 Encourage the use of construction, roofing materials, and paving surfaces with solar reflectance and thermal emittance values per the California Green Building Code (Title 24, Part 11 of the California Code of Regulations) to minimize heat island effects.

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

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

City of Redlands Climate Action Plan
The City of Redlands Climate Action Plan (CAP) was designed to reinforce the City’s commitment to reducing GHG emissions and demonstrate compliance with the State’s GHG emissions reduction standards. The CAP includes goals and policies to promote energy efficiency, waste reduction, and resource conservation and Redlands Regular Meeting of 06-03-25
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recycling. The CAP’s GHG emission targets and goals were based on meeting the goals in Executive Order B-30-15 and SB 32 and the 2017 Scoping Plan. The CAP used the 2017 Scoping Plan’s recommended Plan Level emissions target of 6.0 MTCO 2e per capita per year for 2030. Based on the CAP analysis, the City of Redlands will achieve the 2030 target based on State actions and existing development standards and would not require any specific measures to reduce GHG emissions. Regardless, the CAP does recommend some actions including encouraging the development of solar photovoltaic systems on residential and non- residential development, increasing energy efficiency 5 percent over standards, increasing the use of high efficiency lighting, and reducing the intensity of GHG emissions associated with water delivery and treatment.

5.5.3 ENVIRONMENTAL SETTING
Gases that trap heat in the atmosphere are called greenhouse gases (GHGs). The major concern with GHGs is that increases in their concentrations are contributing to global climate change. Global climate change is a change in the average weather on Earth that can be measured by wind patterns, storms, precipitation, and temperature. Although there is disagreement as to the rate of global climate change and the extent of the impacts attributable to human activities, most in the scientific community agree that there is a direct link between increased emissions of GHGs and long-term global temperature increases.

The principal GHGs are carbon dioxide (CO
2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF 6), perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs). Because different GHGs have different warming potentials, and CO 2 is the most common reference gas for climate change, GHG emissions are often quantified and reported as CO 2 equivalents (CO2e). For example, SF 6 is a GHG commonly used in the utility industry as an insulating gas in circuit breakers and other electronic equipment. SF 6, while comprising a small fraction of the total GHGs emitted annually world-wide, is a much more potent GHG, with 22,800 times the global warming potential as CO

2. Therefore, an emission of one metric ton (MT) of SF 6 could be reported as an emission of 22,800 MT of CO 2e. Large emission sources are reported in million metric tons (MMT) of CO2e. The principal GHGs are described below, along with their global warming potential.

Carbon dioxide (CO 2): CO2 is an odorless, colorless, natural GHG. Carbon dioxide’s global warming potential is 1. Natural sources include decomposition of dead organic matter; respiration of bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic (manmade) sources are from burning coal, oil, natural gas, and wood.

Methane (CH 4): CH4 is a flammable gas and is the main component of natural gas. It has a lifetime of 12 years, and its global warming potential is 28. Methane is extracted from geological deposits (natural gas fields). Other sources are landfills, fermentation of manure, and decay of organic matter.

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

Sulfur hexafluoride (SF 6): SF6 is an inorganic, odorless, colorless, and nontoxic, nonflammable gas that has a lifetime of 3,200 years and a high global warming potential of 23,500. This gas is manmade and used for insulation in electric power transmission equipment, in the magnesium industry, in semiconductor manufacturing, and as a tracer gas.

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

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

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

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

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

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

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

Existing Project Site Conditions
The Project site area consists of about 116.19 acres, which includes 24 sites. Sites 1 through 16A and 24 are located south of Citrus Avenue. Many of these sites are vacant or are being used for agricultural purposes; however, a few sites contain single-family residences, and others are used for industrial storage.

Sites 17 through 23 are located 0.25 miles east of SR-210, just south of West San Bernardino Avenue. These sites are currently vacant and covered with non-native grasses. No activities other than occasional disking occur. The existing GHG emissions from the Project site are limited due to the limited development of the area. The existing primary GHG emissions in the Project site area are from on-road transportation, building energy, and waste.

Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. This would generate approximately 46,446.76 MT per year of CO2e or18.16 CO2e per service population.

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

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

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

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

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

The SCAQMD formed a working group to identify greenhouse gas emissions thresholds for land use projects that could be used by local lead agencies in the Basin in 2008. The working group developed several different options that are contained in the SCAQMD Draft Guidance Document – Interim CEQA Greenhouse Gas Significance Threshold that could be applied by lead agencies, which includes the following tiered approach:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA.
• Tier 2 consists of determining whether the project is consistent with a greenhouse gas reduction plan. If a project is consistent with a qualifying local greenhouse gas reduction plan, it does not have significant greenhouse gas emissions.
• Tier 3 consists of screening values, which the lead agency can choose, but must be consistent with all projects within its jurisdiction. A project’s construction emissions are averaged over 30 years and are added to the project’s operational emissions. If a project’s emissions are below one of the following screening thresholds, then the project is less than significant:
o All land use types: 3,000 MTCO
2e per year
o Based on land use type:
 Residential: 3,500 MTCO 2e per year
 Commercial: 1,400 MTCO 2e per year
 Mixed use: 3,000 MTCO 2e per year
• Tier 4 has the following options:
o Option 1: Reduce business as usual emissions by a certain percentage; this percentage is currently undefined.

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o Option 2: Early implementation of applicable AB 32 Scoping Plan measures. o Option 3, 2020 Target: For service populations (SP), including residents and employees, 4.8 MTCO2e/SP/year for projects and 6.6 MTCO 2e/SP/year for plans. o Option 3, 2035 Target: 3.0 MTCO 2e/SP/year for projects and 4.1 MTCO 2e/SP/year for plans.

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

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

Relevant to the proposed Project, the SCAQMD Tier 4 Option 3 is to utilize an efficiency target. The SCAQMD has proposed targets for project-level and plan-level analysis. At the September 2010 working group meeting the SCAQMD recommended a project-level efficiency target of 4.1 MTCO 2e/SP as a 2035
target2.

The calculations behind this option are based on a 40 percent reduction by the SB 375 target date of 2020 and the same inventory calculated by CARB. The 2020 4.8 MT/SP target is based on the same statewide 2020 GHG inventory in the CARB Scoping Plan. Overall, GHG reductions by the SB 375 target date of 2035 would be approximately 40 percent. This 40 percent reduction was applied to the 2020 targets, resulting in an efficiency threshold for plans of 4.1 MTCO 2e/yr and an efficiency threshold at the project
level of 3.0 MTCO 2e/yr.

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

The SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans identifies a screening threshold to determine whether additional analysis is required. As noted by the SCAQMD:
“…the…screening level for stationary sources is based on an emission capture rate of 90 percent for all new or modified projects...the policy objective of [SCAQMD’s] recommended interim GHG significance threshold proposal is to achieve an emission capture rate of 90 percent of all new or modified stationary source projects. A GHG significance threshold based on a 90 percent emission capture rate may be more appropriate to address the long-term adverse impacts associated with global climate change because most projects will be required to implement GHG reduction measures. Further, a 90 percent emission capture rate sets the emission threshold low enough to capture a substantial fraction of future stationary source projects that will be constructed to accommodate future statewide population and economic growth, while setting the emission threshold high enough to exclude small projects that will in aggregate contribute a relatively small fraction of the cumulative statewide GHG emissions. This assertion is based on the fact that [SCAQMD] staff estimates that these GHG emissions would account for slightly less than one percent of future 2050 statewide GHG emissions target (85 [MMTCO
2e/yr]). In addition, these small projects may
be subject to future applicable GHG control regulations that would further reduce their 2 It should be noted that SCAQMD identifies a plan-level threshold of 4.1 MTCO 2e per SP. As a conservative measure, the Project utilizes the 3.0 MTCO 2e per SP as the basis of establishing long-term thresholds for buildout conditions.

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overall future contribution to the statewide GHG inventory. Finally, these small sources are already subject to [Best Available Control Technology] (BACT) for criteria pollutants and are more likely to be single-permit facilities, so they are more likely to have few opportunities readily available to reduce GHG emissions from other parts of their facility.” Based on the type of programmatic planning project being proposed and the SCAQMD guidance described above, the City has determined that the SCAQMD’s Tier 4, Option 3 project-level efficiency threshold methodology is an appropriate significance criterion by which to determine whether the Project emits a significant amount of GHG due to the threshold’s applicability to programmatic planning projects. As such, based on SCAQMD guidance and to provide a conservative analysis of GHG emissions from buildout of the proposed Project, the SP threshold for the Project’s buildout year of 2035 is 3.0 MTCO 2e/yr. The proposed
Project would be considered to create a significant cumulative GHG impact if implementation of the Project would exceed this threshold.

5.5.5 METHODOLOGY
The California Emissions Estimator Model (CalEEMod) version 2022.1.1.23 has been used to determine construction and operational GHG emissions for buildout of the proposed Project, based on the maximum development assumptions outlined in Section 3.0 , Project Description and from buildout of the approved General Plan land uses. The purpose of the CalEEMod model is to calculate construction-source and operational-source GHG emissions from direct and indirect sources; and quantify applicable air quality and GHG reductions achieved from measures incorporated into the Project to reduce or minimize GHG emissions.

For construction phase Project emissions, GHGs are quantified and, per SCAQMD methodology, the total GHG emissions for construction activities are divided by 30-years, and then added to the annual operational phase of GHG emissions to determine whether the applicable threshold would be exceeded.

In addition, CEQA requires the lead agency consider the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. Therefore, this section provides an analysis that details the relevant plans and policies and details whether the Project is consistent or would result in a conflict with the measures designed to reduce GHG emissions.

5.5.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
The General Plan EIR determined that development under the proposed General Plan would increase GHG emissions. Future development projects and land uses proposed under the proposed General Plan would increase the population and employment in the city, and associated GHG emissions above existing conditions.

However, implementation of the General Plan policies aimed at reducing GHG emissions, and the CAP that serves as the implementation tool for GHG monitoring and reporting, the General Plan would serve to implement a number of strategies and measures aimed at reducing GHG emissions. Therefore, future development projects under the General Plan and CAP would, by nature, result in reduced transportation GHG emissions. This achieves the overarching goals of local, regional, and State plans to reduce GHG emissions. As such, the General Plan EIR determined that buildout of the General Plan would result in less- than-significant GHG emissions and would not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. The General Plan EIR concluded that impacts from implementation of the proposed General Plan and CAP would be less than significant (City of Redlands, 2017b, p. 3.5-38).

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Proposed Project
The proposed Project would rezone 24 sites for the purpose of increasing residential development capacity.

Buildout of the proposed Project would change the maximum buildout of the Project area from 828,349.93 SF of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 111 multi-family dwelling units, 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses to residential uses with an allowed capacity of 2,436 units and approximately 151,048.46 SF of Public/Institutional uses. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings). As detailed in Section 5.10, Transportation, the proposed Project is anticipated to generate a total reduction of approximately 27,540 daily vehicle and truck trips compared to the trips that would result from buildout of the Project site under the existing General Plan land use designations.

Service Population (SP)
As detailed in Section 5.8, Population and Housing, the buildout of the proposed 2,325 extra residential units under the proposed Project would result in an increase of approximately 6,162 residents and the reduction on non-residential square footage would result in a reduction of approximately 1,713 employees compared to buildout of the existing zoning.

SCAG Connect SoCal Demographics and Growth Forecast information shows that the City had approximately 25,600 households and approximately 49,400 jobs in 2019 (SCAG, 2024). Thus, the City of Redlands has 1.93 jobs for each household. The proposed Project would reduce (improve) the jobs-housing ratio slightly by adding 2,325 residential units and provide a regional beneficial effect of providing the opportunity for housing where employees can easily travel to nearby employment opportunities. Thus, the additional residential units would only result in an increase in residents that would be new to the SP. As shown in Table 5.8-7, General Plan and Proposed Project Population Growth, of this Draft Subsequent EIR, the proposed Project would result in an increase of 6,162 residents at buildout, which is the SP that would be generated by the Project.

IMPACT GHG-1: THE PROJECT WOULD GENERATE GREENHOUSE GAS EMISSIONS, EITHER DIRECTLY OR INDIRECTLY, THAT MAY HAVE A SIGNIFICANT IMPACT ON THE ENVIRONMENT.

Significant and Unavoidable.

Construction
Construction activities would occur at different sites throughout the Project area pursuant to individual proposed developments. The site-specific development projects that would occur pursuant to the Project would be temporary at any one location, but numerous site-specific development projects are anticipated to occur pursuant to buildout of the proposed rezoning parcels. Construction of site-specific development projects would create new sources of GHGs and could contribute to global climate change. Construction activities would result in the emission of GHGs from equipment exhaust, construction-related vehicular activity, and construction worker automobile trips. Emission levels for construction activities would vary depending on the number and type of equipment, duration of use, operation schedules, and the number of construction workers. As described previously, the timing of development and operation of the development pursuant to the Project would be dependent upon market conditions and development applications for new projects.

Thus, construction activities associated with buildout of the proposed Project would likely occur sporadically over a 10-year period or longer. Because of the uncertainty of the specific timing and methods of construction activities for future site-specific development projects that would occur under the proposed Project, construction-related GHG emissions are speculative and cannot be accurately determined at this stage of the planning process, per CEQA Guidelines Section 15145. Thus, Mitigation Measure AQ-1 has been Redlands Regular Meeting of 06-03-25
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included to require that future projects prepare a technical assessment of GHG emissions from construction and include appropriate mitigation to reduce emissions to the greatest extent feasible. Due to the variables that must be considered when examining GHG construction emissions, and because SCAQMD methodology includes amortizing construction emissions over 30 years and adding them to the operation of the Project to determine significance, it would be speculative to state conclusively that construction activity associated with the Project would not cause a significant GHG impact. Further, the volume of GHG emissions that could be reduced through mitigation measures are specific to each proposed development, which are currently unknown.

Operation
Long-term operations from both buildout of the existing General Plan land uses and the proposed Project would generate GHG emissions from the following primary sources:
• Area Source Emissions. Landscape maintenance equipment would generate emissions from fuel combustion and evaporation of unburned fuel. Equipment in this category would include lawnmowers, shedders/grinders, blowers, trimmers, chain saws, and hedge trimmers used to maintain the landscaping. • Energy Source Emissions. GHGs are emitted from buildings as a result of activities for which electricity and natural gas are typically used as energy sources. Combustion of any type of fuel emits CO 2 and
other GHGs directly into the atmosphere; these emissions are considered direct emissions associated with a building. GHGs are also emitted during the generation of electricity from fossil fuels; these emissions are considered to be indirect emissions.
• Mobile Source Emissions. The Project related GHG emissions are derived primarily from vehicle trips generated by the Project, including employee trips to and from the Project area, truck trips associated with the proposed uses, and trips related to residential uses. Trip characteristics from the Project’s Trip Generation (Appendix F) were utilized to quantify the GHGs from operation of the Project at buildout. • Water Supply, Treatment, and Distribution. Indirect GHG emissions result from the production of electricity used to convey, treat, and distribute water and wastewater. The amount of electricity required depends on the volume of water as well as the sources of the water. For purposes of analysis, CalEEMod default parameters were used in modeling GHGs from Project water demand. • Solid Waste. The proposed land uses would result in the generation and disposal of solid waste. A percentage of this waste would be diverted from landfills by a variety of means, such as reducing the amount of waste generated, recycling, and/or composting. The remainder of the waste not diverted would be disposed of at a landfill. GHG emissions from landfills are associated with the anaerobic breakdown of material. For purposes of analysis, CalEEMod default parameters were used in modeling GHGs from Project generation of solid waste.

The operational emissions from buildout of the existing General Plan land use designations of the 24 Project sites, which would include 1,656,699.86 SF of commercial/industrial land uses, 552,340.90 SF of commercial land uses, and 111 multi-family dwellings are shown in Table 5.5-1. As shown, 46,446.76 MTCO 2e per year
would be generated by operation of the existing General Plan land uses at buildout, which equates to 18.16 MTCO2e/SP annually.

Table 5.5-1: Existing General Plan Buildout Operational GHG Emissions Emission Source Emissions (MT/yr)
CO2 CH4 N2O Refrigerants Total CO2e
Mobile Source 39,117.93 2.76 2.67 67.32 40,049.49
Area Source 73.21 0.00 0.00 0.00 73.41
Energy Source 4,790.37 0.44 0.04 0.00 4,813.13
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Water Usage 455.87 10.67 0.26 0.00 799.25
Waste 203.19 20.31 0.00 0.00 710.90
Refrigerants 0.00 0.00 0.00 0.59 0.59
Total CO2e (All Sources) 46,446.76
Service Population (SP) 2,557.00
Total CO2e/SP 18.16
Source: Appendix E
The annual GHG emissions from operation of the proposed Project at buildout are summarized in Table 5.5-

2. As shown, operation of the Project at buildout and full occupancy would generate 23,660.41 MTCO 2e per year, which equates to a MTCO 2e/SP of 3.56, which would be substantially less than the emissions generated from buildout of the existing General Plan land uses; but would exceed the threshold of 3.0 MTCO2e/SP. Thus, operational impacts related to GHG emissions would be significant.

Table 5.5-2: Proposed Project Operational Greenhouse Emissions at Buildout Emission Source Emissions (MT/yr)
CO2 CH4 N2O Refrigerants Total CO2e
Mobile Source 18,890.95 0.73 0.87 10.34 19,180.17
Area Source 626.61 0.01 0.00 0.00 627.37
Energy Source 2,979.17 0.32 0.02 0.00 2,994.18
Water Usage 121.25 3.52 0.08 0.00 234.64
Waste 178.25 17.82 0.00 0.00 623.62
Refrigerants 0.00 0.00 0.00 0.42 0.42
Total CO2e (All Sources) 23,660.41
Service Population (SP) 6,637.00
Total CO2e/SP 3.56
Screening Threshold (CO 2e) 3.00
Threshold Exceeded? Yes
Source: Appendix E
Table 5.5-3 provides a comparison of the operational emissions from buildout of the existing General Plan land use designations (Table 5.5-1) and buildout of the proposed Project (Table 5.5-2). As shown on Table

5.5-3, the proposed Project would result in fewer GHG emissions per capita than emissions occurring under buildout of the existing General Plan.

Table 5.5-3: Comparison of Operational Greenhouse Emissions Emission Source Emissions (MT/yr)
Proposed Project 3.56
Approved General Plan Buildout 18.16
Net Emissions (Proposed – Approved) -14.60
Source: Appendix E
However, because buildout of the proposed land uses would result in exceedance of the SP screening threshold, Mitigation Measures AQ-1 and AQ-2 would be implemented to require development projects to prepare a technical GHG analysis and include all applicable mitigation measures to reduce project specific operational emissions. Because the details of future proposed projects are currently unknown, the volume of emissions that could be reduced through mitigation measures are specific to each proposed development Redlands Regular Meeting of 06-03-25
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and are also currently unknown. Therefore, even with implementation of Mitigation Measures AQ-1 and AQ- 2, emissions could continue to exceed SP screening threshold, and impacts related to GHG emissions would be significant and unavoidable. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to GHG emissions would be less than significant.

IMPACT GHG-2: THE PROJECT COULD CONFLICT WITH AN APPLICABLE PLAN, POLICY OR

REGULATION ADOPTED FOR THE PURPOSE OF REDUCING THE EMISSIONS OF GREENHOUSE GASES.

Significant and Unavoidable. The proposed rezoning would be consistent with SCAG strategies to provide infill residential development, as further detailed in Section 5.6, Land Use and Planning. The proposed Project would provide for housing near freeways, transit, employment, and commercial uses to plan for projected growth in the City pursuant to the HCD RHNA allocations and the City’s Housing Element. Likewise, the proposed Public/Institutional use would complement the future housing, employment, and services. The close location of complementary uses would reduce the need to travel far distances to access amenities and retail/service needs, which would reduce VMT and the related GHG emissions. Providing additional residential within mixed-use areas is consistent with the intent of the AB 32 Scoping Plan and SB 375, which is focused on changing land use patterns and improving transportation alternatives.

The future development pursuant to the proposed Project would be implemented pursuant to the CALGreen Building/Title 24 requirements, included in the Redlands Municipal Code in Section 15.16, that would provide new land uses in a sustainable manner. The City’s administration of the Title 24 requirements includes review of proposed energy conservation measures during the permitting process, which ensures that all requirements are met. Typical Title 24 measures include insulation; use of energy-efficient heating, ventilation, and air conditioning equipment; solar-reflective roofing materials; energy-efficient indoor and outdoor lighting systems; reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of skylights, and solar infrastructure. In complying with the Title 24 standards, the proposed Project would be implementing regulations that reduce GHG emissions.

In addition, the proposed Project would be consistent with the following State policies that were adopted for the purpose of reducing GHG emissions.
• Pavley emissions standard and Low Carbon Fuel Standard: Pavley emissions standards (AB 1493) apply to all new passenger vehicles and the Low Carbon Fuel Standard became effective in 2010 and regulates the transportation fuel used. The second phase of implementation of the Pavley regulations per AB 1493 is referred to as the Advanced Clean Car program, which combines the control of smog- causing pollutants and GHG emissions into a single coordinated package of requirements for current model years through 2025. The regulation reduces GHGs from new cars by 34 percent from 2016 levels by 2025. The proposed Project is consistent with these requirements as they apply to all new passenger vehicles and vehicle fuel purchased in California. • Medium/Heavy-Duty Vehicle Regulations: Medium/heavy-duty vehicle regulations are implemented by the State to reduce emissions from trucks. Since the new development that would occur pursuant to the proposed RHNA rezoning would utilize trucks for construction and some operational purposes, these regulations would aid in reducing GHG emissions. The proposed Project is consistent with this measure and its implementation as medium and heavy-duty vehicles associated with construction and operation would be required to comply with the requirements of this regulation. • Tractor-Trailer Greenhouse Gas Regulation: Tractor-trailers subject to this State regulation are primarily 53-foot or longer box -type trailers, are required to either use USEPA SmartWay certified tractors and trailers or retrofit their existing fleet with SmartWay verified technologies. The proposed Project would be consistent with this regulation, as it applies to specific trucks that are used throughout the state.

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• Renewable Portfolio Standard. As a customer of Southern California Edison (SCE), the new development that would occur pursuant to the proposed Project would include onsite solar infrastructure and would purchase from an increasing supply of renewable energy sources and more efficient baseload generations, reduce GHG emissions, and be consistent with this requirement. • Million Solar Roofs Program: The proposed Project is consistent with this scoping plan measure as the new development that would occur pursuant to the proposed Project would be required to comply with existing CALGreen/Title 24 standards, including the installation of solar panels.

CARB Scoping Plan
As detailed in the Section 5.5.2, Regulatory Setting, the CARB Scoping Plan recommends actions for achieving carbon neutrality through reduced GHG emissions levels. New development pursuant to the proposed RHNA rezoning would include energy-efficient/energy-conserving design features and would not interfere with the State’s implementation of AB 1279’s target of 85 percent below 1990 levels and carbon neutrality by 2045 because it does not interfere with implementation of the GHG reduction actions listed in CARB’s most recent Scoping Plan (2022), as demonstrated in Table 5.5-4.

Table 5.5-4: Project Consistency with the CARB 2022 Scoping Plan Actions Action Consistency
GHG Emissions Reductions Relative to the SB 32 Target
40 percent below 1990 levels by 2030. Consistent. Future development pursuant to the proposed rezoning would comply with the Title 24, Part 6, building energy requirements along with other local and State
initiatives that aim to achieve the 40 percent below 1990 levels by 2030 goal. This would be ensured through the
City’s existing development permitting process. Further, Mitigation Measures AQ-1 and AQ-2 would require project specific GHG emission studies and emissions reduction
measures, which would lower GHG emissions from operation of buildout of the proposed rezoning area.

Smart Growth/Vehicle Miles Traveled VMT
VMT per capita reduced 25 percent below 2019
levels by 2030, and 30 percent below 2019 levels
by 2045.

Consistent. As discussed in Section 5.10, Transportation, in Table 5.10-10, although it is possible that a VMT impact may occur from buildout of three of the sites included in the proposed Project, the cumulative Redlands Citywide
VMT/SP with buildout of the entire Project would be 3.1 percent lower than cumulative VMT without the Project. As such, the Project’s cumulative impacts related to VMT would be less than significant.

Light-Duty Vehicle (LDV) Zero-Emission Vehicles (ZEVs)
100 percent of LDV sales are ZEV by 2035.

Consistent. Future development Projects would be designed and constructed in accordance with the Title 24 Part 6 and Part 11 requirements, which includes ZEV designated
parking spaces and charging stations.

Truck ZEVs
100 percent of medium-duty (MDV)/HDC sales are
ZEV by 2040 (AB 74 University of California Institute
of Transportation Studies [ITS] report).

Consistent. The new development pursuant to the proposed rezoning would be designed and constructed in accordance with the most updated Title 24 regulations, which includes prewiring for truck ZEV charging stations and/or providing electrical plug-ins at applicable locations.

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Action Consistency
Aviation
20 percent of aviation fuel demand is met by
electricity (batteries) or hydrogen (fuel cells) in 2045.

Sustainable aviation fuel meets most or the rest of the aviation fuel demand that has not already
transitioned to hydrogen or batteries.

Not Applicable. Development and operation of the
proposed rezoning sites would not utilize aviation fuel.

Ocean-going Vessels (OGV)
2020 OGV At-Berth regulation fully implemented,
with most OGVs utilizing shore power by 2027.
25 percent of OGVs utilize hydrogen fuel cell electric
technology by 2045.

Not Applicable. Development and operation of the
proposed rezoning sites would not utilize any OGVs.

Port Operations
100 percent of cargo handling equipment is zero-
emission by 2037. 100 percent of drayage trucks are
zero emission by 2035.

Not Applicable. Development and operation of the
proposed rezoning sites would not impact any operations at any ports.

Freight and Passenger Rail
100 percent of passenger and other locomotive sales
are ZEV by 2030. 100 percent of line haul locomotive
sales are ZEV by 2035. Line haul and passenger rail
rely primarily on hydrogen fuel cell technology, and
others primarily utilize electricity.

Not Applicable. Development and operation of the
proposed rezoning sites would not involve any rail
operations.

Oil and Gas Extraction
Reduce oil and gas extraction operations in line with
petroleum demand by 2045.

Not Applicable. The proposed Project would not involve
any oil or gas extraction.

Petroleum Refining
CCS on majority of operations by 2030, beginning in
2028. Production reduced in line with petroleum
demand.

Not Applicable. The proposed Project would not involve
any petroleum refining.

Electricity Generation
Sector GHG target of 38 million metric tons of carbon
dioxide equivalent (MTCO 2e) in 2030 and 30
MTCO2e in 2035. Retail sales load coverage of 20
gigawatts (GW) of offshore wind by 2045. Meet
increased demand for electrification without new
fossil gas-fired resources.

Consistent. The development and operation of the rezoning sites would comply with the Title 24, Part 6 building
requirements, including related to renewable energy
generation requirements as well as improved insulation
reducing energy consumption.

New Residential and Commercial Buildings
All electric appliances beginning 2026 (residential)
and 2029 (commercial), contributing to 6 million heat
pumps installed statewide by 2030.

Consistent. The development and operation of the rezoning sites would comply with the Title 24, Part 6 building energy requirements.

Existing Residential Buildings
80 percent of appliance sales are electric by 2030
and 100 percent of appliance sales are electric by
2035. Appliances are replaced at end of life such
that by 2030 there are 3 million all- electric and
electric-ready homes—and by 2035, 7 million
homes—as well as contributing to 6 million heat
pumps installed statewide by 2030 .

Consistent. The proposed Project does not involve the
operation of any existing residential buildings. However, appliances within future residences would comply with the Title 24, Part 6 building energy requirements.

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Action Consistency
Existing Commercial Buildings
80 percent of appliance sales are electric by 2030,
and 100 percent of appliance sales are electric by
2045. Appliances are replaced at end of life,
contributing to 6 million heat pumps installed
statewide by 2030.

Consistent. The proposed Project does not involve the
continued operations of existing commercial buildings.

However, appliances within future buildings would comply with the Title 24, Part 6 building energy requirements.

Energy Demand

7.5 percent of energy demand electrified directly
and/or indirectly by 2030; 75 percent by 2045.

Consistent. The new development pursuant to the proposed rezoning would comply with the Title 24, Part 6 building energy requirements, including renewable energy
generation requirements, as well as improved insulation reducing energy consumption.

Construction Equipment
25 percent of energy demand electrified by 2030
and 75 percent electrified by 2045.

Consistent. Through City permitting, the new development pursuant to the proposed rezoning would be required to use construction equipment that is registered by CARB and meet CARB’s standards. CARB sets its standards to be in line with the goal of reducing energy demand by 25 percent in 2030 and 75 percent in 2045.

Energy Generation
Electrify 0 percent of boilers by 2030 and 100
percent of boilers by 2045. Hydrogen for 25 percent
of process heat by 2035 and 100 percent by 2045.

Electrify 100 percent of other energy demand by
2045.

Consistent. The new development pursuant to the proposed rezoning would comply with the Title 24, Part 6 building energy requirements, including installing electrical wiring for all built in appliances, electric outlets for landscape equipment, solar panels, and provision of electric charging stations.

Stone, Clay, Glass, and Cement
CCS on 40 percent of operations by 2035 and on all
facilities by 2045. Process emissions reduced through
alternative materials and CCS.

Not Applicable . Uses proposed in the rezoning sites do not involve manufacturing or storage of stone, clay, glass, or cement.

Other Industrial Manufacturing
0 percent energy demand electrified by 2030 and
50 percent by 2045.

Not Applicable . The proposed rezoning does not include industrial manufacturing, but would comply with the Title 24, Part 6, including increases in renewable energy generation requirements as well as improved insulation reducing
energy consumption.

Combined Heat and Power
Facilities retire by 2040. Not Applicable. The proposed rezoning does not involve any existing combined heat and power facilities.
25 percent energy demand electrified by 2030 and
75 percent by 2045.

Not Applicable. The proposed rezoning does not involve
generation of energy; but future development per the
proposed rezoning would comply with the Title 24
renewable energy generation requirements.

Low Carbon Fuels for Transportation
Biomass supply is used to produce conventional and
advanced biofuels, as well as hydrogen.

Not Applicable. The proposed rezoning does not involve
any production of biofuels.

Low Carbon Fuels for Buildings and Industry
In 2030s, biomethane135 blended in pipeline
Renewable hydrogen blended in fossil gas pipeline
at 7
percent ener gy (~20 percent b y volume),
Not Applicable. The proposed rezoning does not involve
any production of fuels for buildings and industry.

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Action Consistency
ramping up between 2030 and 2040. In 2030s,
dedicated hydrogen pipelines constructed to serve
certain industrial clusters
Non-combustion Methane Emissions
Increase landfill and dairy digester methane capture.

Some alternative manure management deployed for
smaller dairies.

Moderate adoption of enteric strategies by 2030.

Divert 75 percent of organic waste from landfills by
2025.

Oil and gas fugitive methane emissions reduced 50
percent by 2030 and further reductions as
infrastructure components retire in line with reduced
fossil gas demand.

Not Applicable. The proposed rezoning does not involve
any landfill and/or dairy uses.

High GWP Potential Emissions
Low GWP refrigerants introduced as building
electrification increases, mitigating HFC emissions.

Consistent. The new development pursuant to the proposed rezoning would comply with the Title 24, Part 6, building energy requirements, including use of low GWP
refrigerants, which would be verified through the City’s existing development permitting process.

Scoping Plan Appendix D, Local Actions
The 2022 CARB Scoping Plan includes a set of Local Actions set forth in Appendix D to the Scoping Plan, which aim at providing local jurisdictions with tools to reduce GHG emissions to assist the State in reaching the reduction targets set forth in the 2022 Scoping Plan. Appendix D to the 2022 Scoping Plan includes a section for evaluating plan-level and project-level alignment with the State’s Climate Goals within CEQA GHG analysis. Within this section, CARB identifies multiple recommendations and strategies that should be considered for new development to demonstrate consistency with the 2022 Scoping Plan. Specifically, this section is focused on strategies for residential and mixed-use projects. The document is organized into two categories: examples of plan-level GHG reduction actions that could be implemented by local governments and examples of onsite project design features and mitigation measures that could be applied to individual projects under CEQA.

The future development that would occur pursuant to the proposed rezoning would include a number of example project design features and mitigation measures from the 2022 CARB Scoping Plan for construction and operation. For instance, the Scoping Plan’s construction measures include enforcing idling time restrictions on construction vehicles, requiring construction vehicles to operate highest tier engines commercially available, diverting and recycling construction waste, minimizing tree removal, and increased use of electric and renewable fuel powered construction equipment and required renewable diesel fuel where commercially available. These measures are consistent with existing requirements for idling trucks [CCR Title 13, Motor Vehicles, Section 2449(d)(3)].

Appendix D notes that residential and mixed-use projects that include key project attributes are clearly consistent with the State’s goals and would accommodate growth in a manner which is consistent with the State’s GHG reduction and equity prioritization goals. The Project’s consistency with the 2022 CARB Scoping Plan Appendix D, Local Actions is detailed in Table 5.5-5.

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Table 5.5-5: Project Consistency with the CARB 2022 Scoping Plan Appendix D, Local Actions Priority Areas Key Project Attribute Proposed Project Consistency with Attribute
Transportation Electrification Provides EV charging infrastructure that, at minimum, meets the most
ambitious voluntary standard in the
California Green Building Standards
Code at the time of project approval
Potentially Inconsistent. Future
implementing projects in Sites 1 through
24 would be required to include EV
charging infrastructure as required by
the California Green Building
Standards Code; it is unknown if all
future development projects would meet
the most ambitious voluntary standards.

Therefore, the Project has the potential
to be inconsistent with this attribute.

VMT Reduction Is located on infill sites that are
surrounded by existing urban uses
and reuses or redevelops previously
undeveloped or underutilized land
that is presently served by existing
utilities and essential public services
(e.g., transit, streets, water, sewer)
Potentially Inconsistent. Future
implementing projects in Sites 1 through
24 would be developed on
underdeveloped or underutilized land
which may or may not be served by
existing infrastructure and public
services. Therefore, the Project has the
potential to be inconsistent with this
attribute.

Does not result in the loss or
conversion of natural and working
lands
Potentially Inconsistent. Future
implementing projects in Sites 1 through
24 are currently developed or vacant.

The Project would have the potential to
result in the loss or conversion of natural
and working lands. Therefore, the
Project has the potential to be
inconsistent with this attribute.

Consists of transit-supportive
densities (minimum of 20 residential
dwelling units per acre), or
Is in proximity to existing transit stops
(within a half mile), or
Satisfies more detailed and stringent
criteria specified in the region’s SCS
Potentially Inconsistent. The overall
density for future implementing
residential projects in Sites 1 through 23
would be 15 to 30 dwelling units per
acre; and thus, could be less than the 20
units per acre minimum. Therefore, the
Project has the potential to be
inconsistent with this attribute.

Reduces parking requirements by:

Eliminating parking requirements or
including maximum allowable
parking ratios (i.e., the ratio of
parking spaces to residential units or
square feet); or
Providing residential parking supply
at a ratio of less than one parking
space per dwelling unit; or
Potentially Inconsistent. As this is a
programmatic analysis, and parking
specifics about future implementing
projects are not known at this time. As
such, the Project would have the
potential to be inconsistent with parking
reductions provided by the 2022
Scoping Plan.

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Priority Areas Key Project Attribute Proposed Project Consistency with Attribute
For multifamily residential
development, requiring parking costs
to be unbundled from costs to rent or
own a residential unit.

At least 20 percent of units included
are affordable to lower-income
residents
Potentially Inconsistent. Although the
Project’s intent is to meet the City’s
RHNA allocation, including lower income
residential units, this is a programmatic
analysis, and specifics about future
implementing projects are not known at
this time. As such, future development
under the Project could have the
potential to be inconsistent with
provision of at least 20 percent of units
for lower-income residents.

Results in no net loss of existing
affordable units
Consistent. Sites 1 through 23 are
currently underdeveloped or
underutilized. The Project’s intent is to
meet RHNA requirements per the City’s
2021-2029 Housing Element, including
provision of affordable units. No net loss
of affordable units would occur.

Therefore, the Project would be
consistent with this attribute.

Building Decarbonization Uses all-electric appliances without any natural gas connections and
does not use propane or other fossil
fuels for space heating, water
heating, or indoor cooking
Potentially Inconsistent. Future
developments pursuant to the proposed
rezoning would be required to meet
CALGreen energy efficiency standards
as included in the Redlands Municipal
Code Section 15.16, including installing
electrical wiring for all built in
appliances, electric outlets for
landscape equipment, solar panels, and
provision of electric charging stations.

Also, Mitigation Measure AQ-2 requires
implementation of project specific
mitigation measures to reduce GHG
emissions. Therefore, the future
development that would occur pursuant
to the proposed rezoning would be
developed in a manner that promotes
energy efficiency and minimizes the
reliance on fossil fuels. However, it is
possible that future development would
include natural gas, propane, or other
fossil fuels. Therefore, the Project could
have the potential to be inconsistent with
this attribute.

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The proposed Project would implement key residential and related mixed-use attributes included in 2022 Scoping Plan Appendix, Local Actions ; however, as detailed in Table 5.5-5, the proposed Project would have the potential to be inconsistent with the key project attributes that include: sites presently served by utilities, loss of natural and working lands, residential densities less than 20 units per acre, reduction in parking, and affordable housing guarantees. Due to the potential inconsistency with the 2022 Scoping Plan Appendix D the proposed Project would result in a significant and unavoidable impact regarding conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the GHG emissions.

Redlands CAP
As described previously, the City of Redlands CAP was designed to reinforce the City’s commitment to reducing GHG emissions and demonstrate compliance with the State’s GHG emissions reduction standards.

The CAP used the 2017 Scoping Plan recommended Plan Level emissions target of 6.0 MTCO 2e per capita
per year for 2030. As described under Impact GHG-1, the Project would result in GHG emissions of 3.56 MTCO2e/SP, which is less than the 6.0 MTCO 2e target and therefore would be consistent with the CAP emission goals. Also, the Project would implement energy and water efficiency standards per CALGreen (as included in the Redlands Municipal Code Section 15.16), as verified through the City’s permitting process, which include requirements such as solar photovoltaic systems, increased energy and water efficiency.

General Plan
As detailed in Table 5.5-6, the Project would not conflict with the relevant General Plan policies related to GHG emissions.

Table 5.5-6: Project Consistency with the City General Plan Sustainable Community Element Policies General Plan Policy Consistency
Principle 8-P.1 Promote energy efficiency and
conservation technologies and practices that reduce the use and dependency of nonrenewable resources of
energy by both City government and the community.

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

Action 8-A.8 Implement and enforce California Code of
Regulations Title 24 building standards (parts 6 and 11) to improve energy efficiency in new or substantially
remodeled construction. Consider implementing
incentives for builders that exceed the standards
included in Title 24 and recognize their achievements
over the minimum standards.

Consistent. As described previously, the future
development under the proposed rezoning would
implement the most current CALGreen requirements per
Redlands Municipal Code Section 15.16. Therefore, the
proposed Project is consistent with Action 8-A.8.

Action 8-A.9 Encourage the use of construction, roofing materials, and paving surfaces with solar reflectance
and thermal emittance values per the California Green
Building Code (Title 24, Part 11 of the California Code of Regulations) to minimize heat island effects.

Consistent. As described previously, the future
development under the proposed rezoning would
implement the most current CALGreen requirements per
Redlands Municipal Code Section 15.16. This includes use of materials with solar reflectance and thermal emittance required by Title 24. Therefore, the proposed Project is consistent with Action 8-A.9.

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

Consistent. The future development under the proposed
rezoning would include landscaping throughout the
public realm and private development areas as required
by the City’s Municipal Code and development
standards. Therefore, the proposed Project is consistent with Action 8-A.10.

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

Consistent. The pattern of infill residential development that would be implemented by the proposed rezoning
would reduce vehicle miles traveled and related GHG
emissions while providing for projected growth. Thus, the proposed Project is consistent with Action 8-P.8.

Overall, the future development implemented by the proposed rezoning would be in compliance with State energy standards provided in Title 24 and other statewide standards for fuel and solar use. The Project would also be consistent with the relevant City General Plan policies and the City’s Climate Action Plan.

However, as detailed in Table 5.5-5, the proposed Project would have the potential to be inconsistent with the 2022 Scoping Plan Appendix D, Local Actions key project attributes. Due to this potential inconsistency, the proposed Project could result in a conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs, and impacts would be significant and unavoidable. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to consistency with applicable plan, policies, or regulations for reducing GHG emissions would be less than significant.

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

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

The analysis of GHG emission impacts under CEQA contained in this Draft EIR effectively constitutes an analysis of the Project’s contribution to the cumulative impact of GHG emissions. As described previously, the estimated GHG emissions from development pursuant to the proposed Project at buildout would be substantially less than those from buildout of the existing General Plan land uses but could exceed the service population threshold of 3.0 MTCO
2e per year after implementation of mitigation. Therefore, buildout of the Project would result in a cumulatively considerable significant impact. In addition, the Project would have the potential to be inconsistent with the 2022 Scoping Plan Appendix D, Local Actions , key project attributes, which could combine with inconsistencies of potential other/future projects. Therefore, impacts related to conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs, could be cumulatively considerable, and therefore, significant.

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

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

Impact GHG-1: Buildout of the proposed Project would generate GHG emissions directly and indirectly that would have a potentially significant impact.

Impact GHG-2: Construction and operation associated with buildout of the proposed Project could conflict with an applicable plan, policy, or regulation adopted to reduce GHG emissions, and impacts are potentially significant.

5.5.10 MITIGATION MEASURES
General Plan EIR Mitigation Measures
None.

Proposed Project Mitigation Measures
The mitigation measures listed below are also listed in Section 5.2, Air Quality, of this Draft Subsequent EIR.

Mitigation Measure AQ-1: Construction Emissions. Prior to issuance of grading permits, project applicants shall prepare and submit a technical assessment evaluating potential project construction-related air quality impacts (regional and localized) and greenhouse gas impacts to the City for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the SCAQMD’s most recent adopted thresholds of significance, the City shall require that applicants for new development projects incorporate feasible mitigation measures to reduce air Redlands Regular Meeting of 06-03-25
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pollutant emissions during construction activities to below applicable significance thresholds. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City. Mitigation measures to reduce construction- related emissions are dependent upon the activity causing the impact and could include, but are not limited to:
• Require construction equipment that meets or exceeds CARB Certified Tier 3 or Tier 4 engine standards. • Limit the idling time of diesel off-road construction equipment to no more than five (5) minutes. • Require the use of “Super-Compliant” low VOC paints which have been reformulated to exceed the regulatory VOC limits put forth by SCAQMD’s Rule 1113. Super-Compliant low VOC paints shall be no more than 10g/L of VOC. Alternatively, projects may utilize building materials that do not require the use of architectural coatings.
• The Construction Contractor shall require by contract specifications that construction operations rely on the electricity infrastructure surrounding the construction site, if available rather than electrical generators powered by internal combustion engines.
• The Construction Contractor shall require the use of alternative fueled, engine retrofit technology, after- treatment products (e.g., diesel oxidation catalysts, diesel particulate filters), including all off-road and portable diesel-powered equipment.
• The Construction Contractor shall require that construction equipment be maintained in pursuant to manufacturer specifications to reduce emissions. The Construction Contractor shall ensure that all construction equipment is being properly serviced and maintained as per the manufacturer’s specification. Maintenance records shall be available at the construction site for City verification.

Mitigation Measure AQ-2: Operational Emissions. Prior to issuance of grading permits, project applicants shall prepare and submit a technical assessment evaluating potential project operation air quality impacts (regional and localized) and greenhouse gas impacts to the City for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology in assessing air quality and greenhouse gas impacts. If operation-related emissions are determined to have the potential to exceed the SCAQMD’s most recent adopted thresholds of significance, the City shall require that applicants for new development projects incorporate all feasible mitigation measures to reduce air quality and/or greenhouse gas emissions during operational activities to below the applicable significance thresholds. The identified measures shall be included as part of the conditions of approval. Possible mitigation measures to reduce operational emissions could include, but are not limited to the following:
• Installation of modestly enhanced insulation (walls R-13; roof/attic R-38) such that heat transfer and thermal bridging is minimized;
• Installation of modestly enhanced window insulation (0.4 U-Factor, 0.32 SHGC); • Installation of a heating/cooling distribution system with modest duct insulation (R-6) or enhanced duct insultation (R-8);
• Use of high efficiency HVAC (SEER 15/72% AFUE or 8.5 HSPF); • Use of interior and exterior energy efficient lighting that exceeds then incumbent California Title 24 Energy Efficiency performance standards;
• Installation of automatic devices to turn off lights where they are not needed; • Application of a paint and surface color palette that emphasizes light and off-white colors that reflect heat away from buildings;
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• Design of buildings to accommodate photo-voltaic solar electricity systems or the installation of photo- voltaic solar electricity systems;
• Installation of ENERGY STAR-qualified energy-efficient appliances, heating and cooling systems, office equipment, and/or lighting products.
• Landscaping palette of drought tolerant plants exceeding City requirements; • Use of weather-based irrigation control systems or moisture sensors (demonstrate 20% reduced water use);
• U.S. EPA Certified WaterSense labeled or equivalent faucets, high-efficiency toilets (HETs), and water- conserving shower heads.

5.5.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact GHG-1: GHG emissions at buildout of the proposed Project could exceed thresholds after implementation Mitigation Measures AQ-1 and AQ-2. Thus, impacts related to GHG emissions would be significant and unavoidable and cumulatively considerable.

Impact GHG-2: The proposed Project would have the potential to be inconsistent with the 2022 Scoping Plan Appendix D, Local Actions key project attributes, which could combine with potential inconsistencies of other/future projects. Thus, impacts related to conflict with a policy, plan or regulation adopted for the purpose of reducing GHG emissions would be significant and unavoidable and cumulatively considerable.

5.5.12 REFERENCES
City of Redlands. (2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Retrieved July 2, 2024 from https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 City of Redlands. (2024). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Southern California Association of Governments (SCAG). (2024). Connect SoCal 2024 2019-2050 Demographics and Growth Forecast Technical Report. https://scag.ca.gov/sites/main/files/file- attachments/23-2987-tr-demographics-growth-forecast-final-040424.pdf?1712261839 Urban Crossroads. (2024). Regional Housing Needs Assessment Rezone Greenhouse Gas Impact Analysis . (Appendix E)
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5.6 Land Use and Planning

5.6.1 INTRODUCTION
This section provides an analysis of the consistency of the proposed Project with applicable land use plans, policies, and regulations that guide development of the Project site and evaluates the relationship of the Project with surrounding land uses. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035 , December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), July 2017; and
• City of Redlands Municipal Code.

5.6.2 REGULATORY SETTING

5.6.2.1 Regional Regulations
SCAG Regional Transportation Plan and Sustainable Communities Strategy The Southern California Association of Governments (SCAG) is designated by federal law as a Metropolitan Planning Organization (MPO) and under State law as a Regional Transportation Planning Agency and a Council of Governments. The SCAG region encompasses six counties (Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura) and 191 cities in an area covering more than 38,000 square miles.

SCAG develops transportation and housing strategies for southern California as a whole. On September 3, 2020, SCAG’s Regional Council adopted Connect SoCal - The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020 RTP/SCS), which includes long-range regional transportation plans, regional transportation improvement programs, regional housing needs allocations, and other plans for the region. Most of the plan’s goals are related to regional transportation infrastructure and the efficiency of transportation in the region (SCAG 2020).

The 2024 SCAG Connect SoCal RTP/SCS was officially adopted in April 2024 as the new RTP/SCS for the SCAG jurisdiction. Several updates are reflected within Connect SoCal 2024 plan, including growth projections and forecasting for the region. Connect SoCal 2024 reflects a continuation of the shift toward more efficient resource management. This refers to transportation infrastructure, land resources, and environmental resources. This plan projects that 66 percent of new households and 54 percent of new jobs between 2019–2050 will be located in Priority Development Areas, either near transit or in walkable communities.

5.6.2.2 Local Regulations
Redlands General Plan 2035
The City of Redlands adopted the 2035 General Plan on December 5, 2017. The General Plan serves as a policy document or blueprint for future development to guide future growth in Redlands. The seven themes in the 2035 General Plan include the following:

1. Distinctive City. This chapter sets policies to preserve and enhance the City’s unique architectural, historical, and cultural resources.

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2. Prosperous Economy. This chapter sets forth principles and actions specific to major sectors of Redlands’ economy – including tourism, innovation, and retail, - in order to ensure prosperity and opportunity for all Redlanders.

3. Livable Community. This chapter describes the existing land use pattern and growth management framework. Development and other factors impacting quality of life – including public facilities, public safety, and education – are guided so as to retain the community’s character.

4. Connected City. This chapter includes policies, programs, and standards to maintain efficient circulation for all modes of travel. It identifies future street and traffic improvements, and addresses walking, biking, transit, and parking to enable a multi-model circulation system.

5. Vital Environment. Redlands is renowned for its natural beauty. This chapter sets forth policies regarding land conservation, open space, agriculture, and water supply, in order to protect the Planning Area’s natural environment.

6. Healthy Community. This chapter shapes policy specific to health outcomes of Redlanders. Topics addressed include recreational activity, public health, safety, and air quality.

7. Sustainable Community. This chapter outlines strategies to preserve Redlands’ natural resources for the benefit of future Redlanders. This chapter incorporates innovative strategies to minimize the environmental footprint associated with water, energy, and resource consumption.

City of Redlands Municipal Code
Chapter 18.16, Districts and Zoning Map
The City’s Code of Ordinances Chapter 18.16, Districts and Zoning Maps , establishes the zoning districts and boundaries of those districts within the City.

5.9.3 ENVIRONMENTAL SETTING
The City of Redlands is located near the base of the San Bernardino Mountains in San Bernardino County, approximately 60 miles east of the City of Los Angeles and approximately 45 miles west of the City of Palm Springs. The City is situated along the Interstate 10 (I-10) corridor, which links it with the cities of San Bernardino, Fontana, Ontario, and Los Angeles to the west, and Yucaipa, Beaumont, and Coachella Valley to the east. State Route 210 (SR-210) originates in the city of Redlands and traverses the northwest part of the city, heading north then west towards the cities of Highland and Pasadena (see Figure 3-1, Regional Location).

The City of Redlands Housing Element Regional Housing Needs Allocation (RHNA) includes 196 housing sites.

Of the 196 sites, 23 sites totaling approximately 109.25 acres were identified as requiring future rezone (rezone sites). The entire Project site including Site 24 (which is not included in the Housing Element) is approximately 116.19 acres. The rezone sites are a subset of the Housing Element Sites Inventory, included in Appendix B of the Housing Element, which represent sites that require rezoning by the City to achieve housing targets. Site 24 is not included in the Housing Element but would require a zone change as part of the Project in order to conform with the existing onsite school use and achieve land use compatibility with the surrounding proposed residential designations. The rezoning of these 24 sites constitutes the proposed Redlands RHNA Rezone Project (“proposed Project”, or “Project”). The 24 sites are broken up into two distinct areas:
• Sites 1 through 16A and 24 are in the western portion of the City, approximately 0.75 miles south of the I-10, bordered to the north by Citrus Avenue, the south by Orange Avenue, the west by New Jersey Street, and the east by Kansas Street. These sites are within the East Valley Corridor Specific Plan (EVCSP) which aims to strengthen the local economy, attract major businesses, and result in the orderly and aesthetic development of industrial, commercial, and residential areas.

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• Sites 17 through 23 are the western portion of the City, approximately 1.25 miles northeast of Sites 1 through 16A and 0.32 miles east of SR-210, just south of East San Bernardino Boulevard. The sites are located in North Redlands just north of I-10 and Downtown Redlands.

Regional location and local vicinity maps are provided in Figure 3-1, Regional Location, Figure 3-2, Local Vicinity, Figure 3-3a, Aerial View, and Figure 3-3b, Aerial View, in Section 3.0, Project Description.

5.6.3 ENVIRONMENTAL SETTING
Existing General Plan
The City of Redlands General Plan currently designates the Rezone sites as Commercial/Industrial (CI), Commercial (C), Medium Density Residential (MDR), and High Density Residential (HDR). Figure 3-4a, Existing General Plan Land Use, and Figure 3-4b, Existing General Plan Land Use, show the existing General Plan land use designations.

Existing Zoning
The Rezone sites currently have zoning designations of Commercial Industrial (EV/IC), Concept Plan 4 (CP- 4), Agriculture (A-1), Single Family Residential (R-1) and Multiple Family Residential (R-2). Figures 3-5a, Existing Zoning, and 3-5b, Existing Zoning, show the existing zoning designations for the Rezone Sites. Table 3-1, Existing General Plan Buildout, shows the existing General Plan land use and zoning designations for each Rezone site and the potential buildout of each site pursuant to buildout of the existing General Plan land use designation.

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

LU-1 Physically divide an established community; or
LU-2 Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

The Initial Study established that the proposed Project would result in less-than-significant impacts related to Threshold LU-1; thus, no further assessment of this impact is required in this Draft Subsequent EIR.

5.6.5 METHODOLOGY
This analysis of land use consistency impacts considers whether the proposed Project would be inconsistent with (or conflict with) regional and local plans, policies, and regulations that are applicable to the proposed Project and Rezone sites, including the SCAG RTP/SCS, the City of Redlands General Plan, and the City’s Municipal Code. Consistent with the scope and purpose of this Draft EIR, this discussion primarily focuses on those goals and policies that relate to avoiding or mitigating environmental impacts, and an assessment of whether any inconsistency with these standards creates a significant physical impact on the environment. Thus, a project’s inconsistency with a policy is only considered significant if such inconsistency would cause significant physical environmental impacts (as defined by CEQA Guidelines Section 15382).

CEQA Guidelines Section 15125(d) requires that an EIR discuss inconsistencies with applicable plans that the decision-makers should address. A project need not be consistent with each and every policy and objective in a planning document. Rather, a project is considered consistent with the provisions of the identified regional Redlands Regular Meeting of 06-03-25
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and local plans if it meets the general intent of the plans and would not preclude the attainment of the primary goals of the land use plan or policy.

5.6.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
The General Plan EIR determined that the General Plan would not physically divide an established community since it does not propose the development of highways or infrastructure that would physically divide the community, thus there would be no impact. Additionally, the General Plan EIR found that there would be no impact related to applicable land use plans, policies, or regulations. The General Plan proposed an increase of housing units from 30,200 to 36,600 by 2035 specifically focusing on infill development; thus, the General Plan would not displace substantial numbers of existing housing or people. If residents were to be displaced, they would be able to find housing elsewhere since buildout of the General Plan would result in additional housing units and impacts would be less than significant (City of Redlands, 2017, p.3.10-11 through 3.10- 16).

Proposed Project
The proposed Project would rezone 24 sites for the purpose of increasing residential development capacity.

Buildout of the proposed Project would change the maximum buildout of the Project area from 828,349.93 square feet (SF) of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses, and 111 multi-family dwelling units, to residential uses with an allowed capacity of 2,436 units and approximately 151,048.46 SF of Public/Institutional uses. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings).

IMPACT LU-2: THE PROJECT WOULD NOT CAUSE A SIGNIFICANT ENVIRONMENTAL IMPACT DUE

TO A CONFLICT WITH ANY LAND USE PLAN, POLICY, OR REGULATION ADOPTED FOR THE PURPOSE OF AVOIDING OR MITIGATING AN ENVIRONMENTAL EFFECT.

Less than Significant Impact.

SCAG Regional Transportation Plan/Sustainable Communities Strategy SCAG’s RTP/SCS goals that are relevant to the proposed Project focus largely on maximizing mobility, encouraging development patterns and densities that reduce infrastructure costs, and provide for efficiency.

The proposed Project would be consistent with the applicable 2020 and 2024 RTP/SCS goals, as detailed below in Table 5.6-1 and Table 5.6-2. Therefore, implementation of the proposed Project would not result in conflict with RTP/SCS goals.

Table 5.6-1: 2020 SCAG RTP/SCS Consistency Analysis
RTP/SCS Goal Statements Project Consistency Discussion

1. Encourage regional economic prosperity and global
competitiveness.

Consistent. As discussed in Section 5.8, Population and Housing, the proposed Project would bring more housing
to the City to assist with the jobs and housing balance.

2. Improve mobility, accessibility, reliability, and travel safety for people and goods.

Consistent. While no development is proposed at this
time, future projects developed pursuant to the RHNA
Rezone would be required to comply with applicable
roadway standards.

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RTP/SCS Goal Statements Project Consistency Discussion

3. Enhance the preservation, security, and resilience of the regional transportation system.

Consistent. As a Rezone, the proposed Project is limited in its ability to ensure security and resilience of the regional transportation system. There are no components of the proposed Project that would result in the
deterioration of the transportation system. However, as a measure to safeguard security, the proposed Project
would comply with applicable policies included in the
City of Redlands Hazards Element, including
development outside 100-year flood zones, dam
inundation areas, Alquist-Piolo earthquake fault zones, and very high fire severity zones.

4. Increase person and goods movement and travel
choices within the transportation system.

Consistent. As a RHNA Rezone, the proposed Project is
limited in its ability to maximize the goods movement and travel choices within the SCAG region. The proposed
Project would not create substantial traffic impediments and would provide infill residential development in the City of Redlands.

5. Reduce greenhouse gas emissions and improve air
quality.

Consistent. The Proposed Project would not prevent
SCAG from implementing actions that would improve air
quality within the region. As discussed in Section 5.2, Air Quality, and Section 5.5, Greenhouse Gas Emissions ,
implementing projects would incorporate various
measures related to building design, landscaping, and
energy systems to promote the efficient use of energy,
pursuant to Title 24 CALGreen Code and Building Energy
Efficiency Standards.

6. Support healthy and equitable communities. Consistent. Implementing projects would be required to comply with the City of Redlands Health Community
Element goals and policies to support healthy and
equitable communities, which are listed in Table 5.6-3.

Additionally, implementing projects would construct
frontage improvements, including landscaping which
would not hinder pedestrian access near the proposed
Project area.

7. Adapt to a changing climate and support an
integrated regional development pattern and
transportation network.

Consistent. This policy would be implemented by cities
and the counties within the SCAG region as part of the
overall planning and maintenance of the regional
transportation system.

8. Leverage new transportation technologies and data-
driven solutions that result in more efficient travel.

Consistent. This policy would be implemented by cities
and the counties within the SCAG region as part of the
overall planning and maintenance of the regional
transportation system. The Proposed Project would not
conflict with this goal.

9. Encourage development of diverse housing types in
areas that are supported by multiple transportation
options
Consistent. The RHNA Rezone Project would result in the development of infill residential which would comply with the Municipal Code design standards. The development
of infill residential would also assist in the growth of Redlands.

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RTP/SCS Goal Statements Project Consistency Discussion

10. Promote conservation of natural and agricultural
lands and restoration of habitats
Consistent. The Project would be consistent with goals
and policies of the General Plan. Although the Project
would result in the loss of agricultural land, the existing farming uses on the Project site are lawful nonconforming uses that would otherwise not be permitted under the
site’s General Plan or zoning designations which include Commercial and Industrial uses. This loss of agricultural land was already accounted for within the 2017
General Plan EIR as a significant and unavoidable
impact, and therefore does not represent a conflict. In addition, Initial Study (Appendix A) Mitigation Measures BIO-1 and BIO-2 would reduce potential impacts
associated with biological resources. The Project would not conflict with this goal.

Table 5.6-2: 2024 SCAG RTP/SCS Consistency Analysis
Goals Project Consistency
Transit and Multimodal Integration
Increase multimodal connectivity (e.g., first/last mile transit and airport connections), which includes planning for and developing mobility hubs throughout the SCAG
region
Consistent. As discussed in Section 5.10, Transportation, The Project would develop infill residential units which are of close proximity to a variety of public transit access points. The Project site is served by Omnitrans and the San Bernardino County Transportation Authority (SBCTA)
and there are two bus stops within one mile of the Project site. Furthermore, specific infrastructure improvements required to support future residential would be required to fund transit facilities as deemed necessary.

Through land use planning, support residential
development along high-frequency transit corridors and
around transit/rail facilities and centers
Expand the region’s networks of bicycle and pedestrian
facilities. This includes creating more low stress facilities, such as separated bikeways and bike paths, slow
streets, and open streets
Consistent. As discussed in Section 5.10, Transportation, potential future projects would be required, if deemed
necessary, to provide bicycle facilities, as ensured and verified by the City during the plan check and permitting process, prior to obtaining building permits.

Safety
Work with local, state and federal partners to advance
safer roadways, including reduced speeds to achieve
zero deaths and reduce GHGs
Consistent. As discussed in Section 5.10, Transportation, future development implemented pursuant to the
proposed Project would be required to comply with the
circulation system standards and to adhere to uniform
standards and practices. Compliance with standards for
roadway and intersection classifications, right-of-way
width, pavement width, design speed, warrant
requirements, capacity, maximum grades and associated
features such as medians would be ensured and verified
by the City during the plan check and permitting process, prior to obtaining building permits.
15-Minute Communities
Develop technical-assistance resources and research
that support 15-minute communities across the SCAG
region by deploying strategies that include, but are not limited to, redeveloping underutilized properties and
increasing access to neighborhood amenitie s, open
space and urban greening, job centers and multimodal
mobility options
Consistent. As discussed in Section 3.0, Project
Description, the Project would develop underutilized
properties and create infill residential units. The site has two bus stops within one mile and is surrounded by a
variety of open spaces including Heritage Park, Texonia Park, and Orange Blossom Trail.

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Goals Project Consistency
Sustainable Development
Research the availability of resources that can support the development of water and energy-efficient building
practices, including green infrastructure
Consistent. As discussed in Section 5.4, Energy, the
proposed Project would comply with CALGreen/Title 24
requirements to implement energy conservation
measures and water efficient plumbing.

Air Quality
Coordinate with local, regional, state and federal
partners to meet federal and state ambient air-quality
standards and improve public health
Consistent. As described in Section 5.2, Air Quality , the proposed Project would result in cumulatively
considerable impact and would be required to comply
with all relevant State, regional, and local regulations and policies for reducing particulate emissions.

Clean Transportation
Facilitate development of EV charging infrastructure
through public-private partnerships
Consistent. As discussed in Section 5.4, Energy, future developments under the proposed Project would comply
with CALGreen/Title 24 requirements and include EV
charging infrastructure.

Support the deployment of clean transit and
technologies to reduce greenhouse gas emissions as
part of the CARB innovative clean technology (ICT) rule Consistent. The Project would not conflict with this
measure and future developments under the proposed
Project would comply with CALGreen/Title 24
requirements and include EV charging infrastructure.

Natural and Agricultural Lands Preservation
Work with implementation agencies to support,
establish or supplement voluntary regional advance
mitigation programs (RAMP) for regionally significant
transportation projects to mitigate environmental
impacts, reduce per-capita VMT and provide mitigation
opportunities through the Intergovernmental Review
Process
Consistent. As discussed in Section 5.10, Transportation, future developments under the proposed Project would
be required, if deemed necessary, to fund transit
facilities, pedestrian facilities, and bicycle facilities as ensured and verified by the City during the plan check
and permitting process, prior to obtaining building
permits. Since Sites 20, 21 and 23 could have a
potentially significant VMT impact, future developments on these sites would be required to conduct project-
specific VMT screening analysis to determine if the
development would screen out of a VMT analysis.

Continue efforts to support partners in identifying
priority conservation areas— including habitat, wildlife corridors, and natural and agricultural lands—for
permanent protection
Consistent. As discussed in the Initial Study (Appendix A), the Rezone sites are located in an urbanized and
developed area, with some vacant sites. Mitigation
Measure BIO-1 would be implemented to require future
projects within the area to have a biologist evaluate the site prior to any ground disturbing activities.

Support the integration of nature-based solutions into
implementing agency plans to address urban heat,
organic waste reduction, protection of wetlands, habitat and wildlife corridor restoration, greenway connectivity and similar efforts
Climate Resilience
Develop partnerships and programs to support local
and regional climate adaptation, mitigation and
resilience initiatives
Consistent. As discussed in Section 5.12, Utilities and Service Systems, the proposed Project would be required to implement the CALGreen requirements for efficient
use of water. Additionally, as discussed in the Initial Study, included as Appendix A, development and
construction of the Project site would require preparation and adherence to SWPPP and WQMP. Therefore,
development of the site would not deplete or pollute
groundwater resources.

Collaborate with partners to foster adoption of systems and technologies that can reduce water demand
and/or increase water supply, such as alternative
groundwater recharge technologies, stormwater
capture systems, urban cooling infrastructure and
greywater usage systems
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City of Redlands General Plan 2035
Table 5.6-3 lists the policies from the City of Redlands General Plan that are relevant to the proposed rezone. For each topic of the General Plan, the General Plan established policies that consist of principles and actions that form the supporting policies for the goal. As shown in Table 5.6-3 below, the Project would be consistent with the actions and policies of the City’s General Plan.

Table 5.6-3: Project Consistency with Applicable General Plan Principles, Actions and Policies General Plan Policy Proposed Project
Principle 2-P.2 Embrace the unique identities of
individual neighborhoods in Redlands and encourage the
celebration and enhancement of characteristics that
make each neighborhood distinct.

Consistent. While no development is proposed at this time, future projects developed pursuant to the RHNA Rezone
would be required to comply with Municipal Code design
standards.

Action 2-A.4 Maintain continuity in streetscape design
along major streets and avenues that traverse north and south – California, Nevada, Alabama, Tennessee,
Orange, Church, University, Judson, and Wabash; and
those that traverse east and west – Pioneer, San
Bernardino, Lugonia, Redlands Boulevard, and Citrus.

Consistent. While no development is proposed at this time, future projects developed pursuant to the RHNA Rezone
would be required to comply with applicable roadway
standards.

Action 2-A.8 Insist on high-quality development and
revitalization in older neighborhoods, such as the Orange Street and Colton Avenue commercial corridors, that is
sensitive to historic architecture, and provides a broad range of retail, restaurants, professional services, and offices that meet the community’s needs. Build a sense of community in these commercial areas.

Consistent. As discussed in Section 3.0, Project Description, the General Plan designated some of the Project sites as Industrial and Commercial and this Project is proposing a zone change to Residential for these sites. The proposed General Plan Amendment and zone changes would
preserve the sense of community within the respective
commercial areas in comparison to the original land use and zoning designations.

Action 2-A.10 Permit densities, design, and uses that will help preserve the character and amenities of existing
neighborhoods.

Consistent. While no development is proposed at this time, future projects developed pursuant to the RHNA Rezone
would be required to comply with Municipal Code design
standards.

Action 2-A.13 Maintain continuity in land uses, including commercial and residential uses, across barriers such as I-10 and Highway 210. These barriers should not be
seen as “walls” that define completely different
neighborhoods or divide the city by land use.

Consistent. All developments within the RHNA Rezone
Project area would be consistent with the surrounding area and land uses.

Action 2-A.14 Use development standards to ensure
smooth transitions for neighborhoods that border one
another so that neighborhoods maintain their unique
qualities while being compatible with one another.

Consistent. While no development is proposed at this time, future projects developed pursuant to the RHNA Rezone
would be required to comply with Municipal Code design
standards.

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

Consistent. The RHNA Rezone area includes the
development of infill residential which would comply with the Municipal Code design standards. The development of infill residential would also assist in the growth of Redlands unique community and enable future tenants to enjoy the local history.

Policy 2-P.9 Provide incentives to protect, preserve, and maintain the city’s heritage.

Consistent. As discussed in the Initial Study (Appendix A), there are no structures in the Project site that are considered historic resources. However, Mitigation Measures CUL-1
and CUL-2 are included to require proper evaluation ofPolicy 2-P.11 Encourage retention of the character of existing historic structures and urban desi gn elements that Redlands Regular Meeting of 06-03-25
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define the built environment of the city’s older
neighborhoods.
historic resources for future projects developed pursuant to the RHNA Rezone.

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

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

Consistent. As discussed in the Initial Study (Appendix A), the Project area consists of an urbanized environment that does not include or provide scenic vistas. Land use changes that would occur under the RHNA Rezone are in or near
already developed areas of the City and coincide with
areas designated for development under the General Plan.

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

Consistent. As discussed in the Initial Study (Appendix A), there are no structures in the Project site that are considered historic resources. However, Mitigation Measures CUL-1
and CUL-2 are included to require proper evaluation of
historic resources for future Projects developed pursuant to the RHNA Rezone.

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

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

Consistent. As discussed in the Initial Study (Appendix A), the proposed Project area is in an urban environment that has been previously disturbed. Future projects would also be required to adhere to Mitigation Measure PAL-1 and
PAL-2 which would require proper analysis and
management of paleontological resources.

Policy 2-P.17 Protect archaeological and
paleontological resources for their aesthetic, scientific, educational, and cultural values.

Consistent. As discussed in Section 5.3, Cultural Resources , the Project sites are located in urbanized areas. Many of the sites have been disturbed by agricultural activities and are not known to contain any archeological or
paleontological resources. Future development projects
within the RHNA Rezone Project area would be required to implement Mitigation Measure CUL-3 which requires an
archeological resource assessment prior to ground
disturbing activities. If resources are discovered Mitigation Measure CUL-4, would require a mitigation plan be
prepared. Mitigation Measure CUL-4 will be required for any ground disturbing activities with 50 feet of the Morey Arroyo due to the areas of high archeological sensitivity.

Action 2-A.25 Require any application that would alter
or demolish an undesignated and unsurveyed resource
over 50 years old to be assessed on the merits of the
structure, and to be approved by the Historic and Scenic Preservation Commission.

Consistent. As discussed in the Initial Study, included as Appendix A, implementing developments could impact
historic structures. However, the proposed Project would require evaluation of potential historic resources for
implementing projects that could potentially impact a
building or structure in excess of 45 years of age as
included as Mitigation Measure CUL-1.

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

Consistent. As discussed above, any future development
within the RHNA Rezone area would be required to adhere to Mitigation Measure CUL-1 which requires evaluation of potential historical buildings. If a structure is identified as a historical resource, then Mitigation Measure CUL-2 would be required. Mitigation Measure CUL- 2 requires
modification of identified historical resources to meet the Secretar
y of the Interior's Professional Qualification
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Standards to ensure compliance with Standards for
Rehabilitation.

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

Consistent. As discussed in the Initial Study (Appendix A) all rehabilitations and additions to historic buildings shall conform to the recommendations of the Secretary of the
Interior’s Standards for Rehabilitation and Illustrated Guidelines for Rehabilitation of Historic Structures and/or the Redlands Historic Architectural Design Guidelines .

Action 2-A.49 Encourage compatibility of new land uses
and new construction adjacent to historical buildings.

Encourage construction that is physically and
aesthetically complementary to the historic buildings in architectural features and relationship to adjoining
structures.

Consistent. As discussed in the Initial Study (Appendix A) new development and redevelopment would be visually
compatible with the surrounding environment.

Action 2-A.51 Encourage new construction that ties the
new with the old in a harmonious fashion, enhancing the historic pattern.

Action 2-A.66 Promote neighborhood preservation and
stabilization.

Consistent. The new residential developments would help preserve the livelihood of preexisting neighborhoods and add to the value of the area.

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

Consistent. Future residential developments within the
RHNA Rezone site would be within the permitted densities of the site. As stated above the new developments and
redevelopments would be visually compatible with the
surrounding environment.

Action 2-A.68 Discourage changes in residential areas
that would disturb the character or clearly have a
destabilizing effect on the neighborhood.

Action 2-A.69 Encourage shared parking or in-lieu
parking in older neighborhoods.

Consistent. Future development designs would receive
approval from the City and in compliance with parking
requirements.

Action 2-A.71 Using an annually updated
Archaeological Resource Sensitivity Map, review
proposed development projects to determine whether a
site contains known prehistoric or historic cultural
resources and/or to determine the potential for
discovery of additional cultural resources.

Consistent. As discussed in Section 5.3, Cultural Resources , the Rezone sites are located in urbanized areas. Many of the sites have been disturbed by agricultural activities and do not contain any known archeological or paleontological resources. Future development projects within the RHNA
Rezone Project area would be required to implement
Mitigation Measure CUL-3 which requires an archeological resource assessment prior to ground disturbing activities. If resources are discovered Mitigation Measure CUL-4 would require a mitigation plan be prepared. Mitigation Measure CUL-4 will also be required for any ground disturbing
activities with 50 feet of the Morey Arroyo due to the areas of known high archeological sensitivity.

Action 2-A.72 Require that applicants for projects
identified by the South Coastal Information Center as
potentially affecting sensitive resource sites hire a
consulting archaeologist to develop an archaeological
resource mitigation plan and to monitor the project to
ensure that mitigation measures are implemented.

Action 2-A.73 Require that areas found during
construction to contain significant historic or prehistoric archaeological artifacts be examined by a qualified
consulting archaeologist (RPA certified) or historian for appropriate protection and preservation.

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

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Action 2-A.75 Require, as a standard condition of
approval, that project applicants provide an assessment as to whether grading for the proposed project would
impact underlying soil units or geologic formations that have a moderate to high potential to yield fossiliferous materials, prior to issuance of a grading permit. If the potential for fossil discovery is moderate to high, require applicants to provide a paleontological monitor during
rough grading of the project.

Action 2-A.76 Establish a procedure for the
management of paleontological materials found onsite
during a development, including the following provisions:

If materials are found onsite during grading, require that work be halted until a qualified professional evaluates the find to determine if it represents a significant
paleontological resource.

If the resource is determined to be significant, the
paleontologist shall supervise removal of the material
and determine the most appropriate archival storage of
the material.

Appropriate materials shall be prepared, catalogued,
and archived at the applicant’s expense and shall be
retained within San Bernardino County if feasible.

Principle 2-P.18 Reinforce Redlands’ identity as a “Tree City” through cohesive streetscapes that enhance its sense of place and its heritage, and that promote pedestrian
comfort.

Consistent. The RHNA Rezone area would comply with the
municipal code design standards and receive approval
from the City prior to buildout.

Action 2-A.79 Avoid sound walls as a standard on
arterial streets in residential areas.

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

Consistent. There are sites within the RHNA Rezone that are currently occupied by citrus groves; however, these sites are already zoned for industrial uses. The City has land designated for farming on the fringes of the City but these sites are not within those areas.

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

Action 2-A.86 Take advantage of desirable
environments, such as the Crafton subarea, that can
provide citrus groves and agricultural land that otherwise would be subject to strong development pressures.

Encourage or incentivize homeowners to maintain the
groves.

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

Consistent. As discussed previously, all rehabilitations and additions to historic buildings shall conform to the
recommendations of the Secretary of the Interior’s
Standards for Rehabilitation and Illustrated Guidelines for Rehabilitation of Historic Structures and/or the Redlands Historic Architectural Design Guidelines .

Principal 4-P.1 Promote a balanced rate and
distribution of development and uses pursuant to the
Consistent. Future residential developments within the
RHNA Rezone sites would be within the permitted densities of the site. As stated above, the new develo pments and Redlands Regular Meeting of 06-03-25
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standards identified in Measure U and compatible with
the fabric of the existing community.
redevelopments would be visually compatible with the
surrounding environment.

Principal 4-P.2 Provide for the expansion of housing and employment opportunities while ensuring that a high
quality of life is maintained in Redlands.

Consistent. As discussed in Section 3.0, Project Description, the Project would rezone 23 sites for future residential development. The RHNA Rezone would expand the
available housing within the City of Redlands.

Principal 4-P.3 Focus new development in infill areas in order to preserve open space, agriculture, and citrus
groves, particularly around the edges of the city.

Consistent. As discussed in Section 3.0, Project Description, the sites within the RHNA Rezone Project are located in infill areas. While some sites contain orange groves, these sites are already designated by the Redlands General Plan for industrial or commercial development. The City has land designated for farming on the fringes of the City but these sites are not within those areas.

Action 4-A.1 Promote the orderly development and
growth of urban areas in infill areas and the city center while encouraging the ongoing cultivation of agricultural land and the preservation of rural living areas in the
canyons, Crafton, and Mentone.

Action 4-A.3 Ensure that infill development complements existing development in use, design, and scale, and that it supports the cohesion and integration of the city’s
development pattern.

Consistent. As discussed in the Initial Study, included herein as Appendix A, new development and redevelopment
would be visually compatible with the surrounding
environment.

Principle 1.A.20 Development within the planning area
and sphere of influence of the City of Redlands shall
conform to development standards within the City.

Development Agreements- All development agreements
entered into by the City and developers pursuant to
California Government Code Sections 65864 et. seq., -
after the Effective Date of this initiative measure as
defined in Section 3 hereof, shall conform to the policies contained in the Redlands General Plan.

Extension of Public Utilities Outside the City Limits - No extension of City provided utility services to areas
outside the City limits shall occur until such areas are properly annexed to the City, except that utility services may be extended to areas outside the City limits without prior annexation if all of the following conditions are met:

The area to be served is not contiguous to the City of
Redlands; and
The City and the land owner have entered into a
properly recorded and binding pre-annexation
agreement establishing covenants running with the land
that assure full compliance with all development
standards of the City of Redlands, payment of all capital improvement and other development fees which would
be applicable to the property if it were within the City limits at the time of extension of such services, and
immediate processing of annexation to the City at the
City’s request; and;
Impacts of New Development on Public Schools Shall Be
Mitigated - A mandatory component of the socio-
economic cost/benefit studies shall be an analysis of the effect of the proposed development on public schools
facilities and resources, and shall include proposed
measures to mitigate any identified adverse impacts on
school facilities to the greatest extent permitted under California law.

Consistent. Implementing projects pursuant to the RHNA
Rezone would undergo development review pursuant to the Redlands Municipal Code in order to ensure that the
development would adhere to all applicable building
codes and standards. Proposed development plans would
be reviewed by the City.

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Principle 1.A.30 Land use classifications set forth in the Redlands General Plan provide for an appropriate
range of densities for residential development and
intensity of commercial and industrial development in the City of Redlands.
a) Number of Land Use Classifications and Density
Standards Shall Not Be Increased -The density
standards set forth in Paragraph 4.40, Residential
Land Use Classifications, of Section 4.0, Land Use
Element, of the Redlands General Plan shall not be
increased, and no new residential land use
classification shall be added, without a vote of the
people.
b) Prohibition on Transfers of Density - In order to
assure that development occurs in a rational way, no
transfer of residential development rights from lands
other than those designated for single family
residential shall be permitted, and then such
transfers of single family residential density shall
only be permitted to create or preserve agricultural,
open space, school or park uses.

Consistent. The future developments within the Redlands RHNA Rezone area would be consistent with the Redlands
General Plan, based on the proposed General Plan
Amendment, and all residential developments would be
within the appropriate density allowed under the Municipal Code. The proposed General Plan Amendment and zone
change would allow for increased compatibility between
the Rezone sites and surrounding residential areas
compared to buildout of the existing General Plan land use designations, which would result in commercial and
industrial development.

Principle 1.A.40 Agricultural uses of land are important to the culture, economy and stability of the City of
Redlands and shall be preserved to the greatest extent
possible consistent with the will of the people as
expressed in Proposition R and Measure N, and
consistent with the policies of the State of California set forth in Government Code Section 51220 .

Consistent. There are sites within the RHNA Rezone that are currently occupied by citrus groves; however, these sites are already zoned for industrial uses. The City has land designated for farming on the fringes of the City but these sites are not within those areas.

Policy 4.40s No land undeveloped as of March 1, 1997
and designated in whole or in part as “Urban Reserve”
or “Urban Reserve (Agricultural)” in the Redlands
general plan in effect as of June 1, 1987, and/or any
land parcel that was in active agricultural production on November 3, 1986 regardless of zoning, shall be re-
designated or rezoned to permit residential density
greater than the Estate Residential (R-E) classification, as the same existed on June 1, 1987, in the Redlands City
Zoning Ordinance, unless the following mandatory
findings are made and the re-designation or rezoning is approved by four-fifths (4/5) vote of the total
authorized membership of the City Council. Land
designated by the General Plan as Urban Reserve as of
June 1, 1987, shall not exceed a density higher than
permitted by the R-E zone designation unless otherwise
approved by a 4/5 vote of the City Council.

1. There are substantial and overriding economic or
social benefits to the City and its residents and
taxpayers from the proposed density increase.

2. The proposed density increase will not cause
adverse environmental impacts, either individually
or cumulatively, directly or indirectly.

3. The proposed density increase will not convert
viable agricultural land to nonagricultural uses.

4. The proposed density increase will not have a
growth-inducing effect on other property.

Consistent. None of the Rezone sites are designated as
Urban Reserve or Urban Reserve (Agricultural). As certain Rezone sites were in active agricultural production in 1986, the City Council must make the applicable findings to allow the rezone.

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5. The resulting use will be compatible with uses on
adjacent land.

6. The proposed density increase will not require
substantial expansion of public infrastructure,
facilities or services.

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

Consistent. Future development pursuant to the Project
would be urban and of high densities. As stated in Section

5.10, Transportation, the Project site is served by Omnitrans and SBCTA, which would allow for high-density
development near transit routes. Furthermore, the Rezone sites are located in the vicinity of employment centers, shopping areas, and public services.

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

Consistent. As discussed in the Initial Study (Appendix A), new development and redevelopment would be visually
compatible with the surrounding environment.

Principle 4-P.15 Preserve existing residential
neighborhoods, particularly older neighborhoods.

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

Consistent. Future development pursuant to the Project
would develop a variety of different medium to high
density housing throughout the City. The Project would
provide a variety of housing options to the community of Redlands.

Principle 4-P.17 Limit negative impacts to residential
neighborhoods from incompatible uses.

Consistent. The RHNA Rezone Project would only rezone
sites for residential uses therefore there would be no result in incompatible uses to residential neighborhoods. The
proposed General Plan Amendment and zone change
would allow for increased compatibility between the
Rezone sites and surrounding residential areas compared to buildout of the existing General Plan land use
designations, which would result in commercial and
industrial development.

Principle 4-P.23 Preserve agricultural land in the
Planning Area and protect it from premature
development.

Consistent. There are sites within the RHNA Rezone that are currently occupied by citrus groves; however, these sites are already zoned for industrial uses. The City has land designated for farming on the fringes of the City but these sites are not within those areas.

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

Consistent. The Redlands RHNA Rezone would provide
additional residential capacity in the City that would be favorable for a variety of different housing types.

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.

Action 4-A.10 Promote availability of senior and
independent assisted living facilities to meet the needs of the community’s aging population, distributed equitably throughout the community.

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

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Action 4-A.13 Permit densities, design, and uses that will help preserve the character and amenities of existing
older neighborhoods.

Consistent. As discussed in the Initial Study (Appendix A), new development and redevelopment would be visually
compatible with the surrounding environment. The future developments would also be within the permitted density for each site.

Action 4-A.14 Discourage changes in residential areas
that would disturb the character of or clearly have a
destabilizing effect on the neighborhood.

Consistent. As discussed above, the new development and redevelopment within the Redlands RHNA Rezone Project
would be visually compatible with the surrounding
environment.

Action 4-A.34 Preserve agricultural land and protect
agricultural operations and soils by identifying and
designating these lands as Agriculture.

Consistent. The Project site does not include any parcels that are designated for agricultural uses.

Action 4-A.35 Preserve connections between
agricultural lands with other agricultural lands and
supporting uses.

Consistent. The sites within the Project area that currently contain agricultural uses are surrounded by developed
areas. These agricultural sites are also zoned for industrial and commercial uses.

Action 4-A.37 Ensure adequate buffers and transitions
between agricultural land and non-agricultural
development in order to reduce the potential for land
use conflicts.

Consistent. The Project sites proposed zoning would be
consistent with the surrounding area and the site plans would be subject to approval prior to groundbreaking
activities.

Principle 4-A.51 Promote the development of land uses
that reduce the number and length of vehicle trips in the East Valley Corridor.

Consistent. The Project would increase residential
development within the East Valley Corridor. As a result, this would increase the walkability within the corridor for these residents. These residential developments could also help attract major business to the area due to the growing population and further the walkability of the community.

Principle 4-A.52 Improve access and movement of all
modes of transportation in the East Valley Corridor and enhance linkages to transit.

Consistent. As discussed in Section 5.10, Transportation, specific infrastructure improvements required to support future residential uses are not known at this time. However, if necessary, potential future projects would fund transit facilities as ensured and verified City during the plan check and permitting process.

Principle 4-A.53 Maintain development standards to
implement the goals and policies of the EVCSP.

Consistent. All future potential projects within the RHNA Rezone area would be required to be consistent with
development standards, which would be verified by the
City during the plan check and permitting process prior to obtaining building permits.

Principle 4-A.54 Create a visually aesthetic appearance for the East Valley Corridor from the freeways as well
as from the Planning Area.

Consistent. The potential infill developments within the Project site would improve the value of the area. These potential developments would make each site more visually consistent with the surrounding uses and provide amenities to the developing area.

Principle 4-A.55 Enhance the beauty of the East Valley
Corridor and the overall quality of life for users and
residents of the area.

Principle 4-A.56 Create buffers and appropriate
transitions between the East Valley Corridor industrial and commercial areas and adjacent residential
neighborhoods.

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

Action 4-A.96 Encourage site designs that create an
active street frontage and screen parking from the
Colton Avenue and Orange Street frontages.

Consistent. All future potential projects within the RHNA Rezone area would be required to be consistent with design standards which would be verified by the City during the Redlands Regular Meeting of 06-03-25
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plan check and permitting process prior to obtaining
building permits.

Action 4-A.141 Regulate land uses within safety and
noise compatibility zones in accordance with the Airport Land Use Compatibility Plan.

Consistent. As stated in the Initial Study, included as Appendix A, Site 23 is the only site within an airport
compatibility zone; however, it is not within the modeled noise contours of neighboring airport.

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

Consistent. Implementing projects pursuant to the RHNA
Rezone would undergo development review pursuant to the Redlands Municipal Code in order to ensure that the
development would adhere to all applicable building
codes and standards. Proposed development plans would
be reviewed by the City’s Fire Department in order to
ensure that new development minimizes potential fire
hazards through building design.

Principle 5-P.1 Maintain a cohesive circulation system
through a “layered network” approach promoting
complete streets and mobility for all modes while
emphasizing specific transportation modes for specific
corridors and geographic areas.

Consistent. As stated in Section 5.10, Transportation, future projects under the proposed Project would be required to comply with the circulation system standards and to adhere to uniform standards and practices.

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

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

Policy 5-A.77 Encourage developers to meet their
minimum parking requirements via shared parking
between uses, payment of in-lieu fees, joint parking
districts, or off-site parking within a reasonable walking time of 10 minutes or less.

Consistent. Future projects within the Project would be required to meet the minimum parking requirements for the lot and would be subject to approval by the City prior to receiving building permits.

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

Consistent. All of the sites that require rezoning within the RHNA Rezone are currently zoned for industrial uses so the proposed Project would not alter any sites that were
previously preserved for the protection of natural
resources.

Action 6-A.10 Maintain and enhance Redlands’ network
of urban forest and street trees.

Consistent. Future developments within the Project site would be required to include landscaping pursuant to City design standards, which would be subject to approval by the City prior to being granted building permits.

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

Consistent. As discussed in the Initial Study, included as Appendix A, future projects would be subject to Mitigation Measure BIO-1 which requires a survey by a qualified
biologist to determine if any special-status plant or wildlife species have the potential to occur onsite.Principle 6-P.8 Minimize disruption of wildlife and valued habitat throughout the Planning Area and
emphasize that open space is for more than just human
use, but also serves as habitat for biological resources.

Principle 6-P.10 Landscape public areas using native
vegetation where practical.

Consistent. Future developments within the Project site would be required to include landscaping pursuant to City design standards, which would be subject to approval by the City prior to being granted building permits.

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

Consistent. As discussed in the Initial Study, included as Appendix A, future projects would be subject to Mitigation Measure BIO-1 which requires a survey by a qualified
biologist to determine if any special-status plant or wildlife species have the potential to occur on-site.

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Action 6-A.15 Enhance the Mill Creek Zanja and Morey
Arroyo and tributary drainages as riparian corridors,
where feasible, to provide habitat as well as
recreational and aesthetic value consistent with an
overall master plan for habitat preservation.

Consistent. As discussed in the Initial Study (Appendix A), there are no sites located within the Mill Creek Zanja. As for the sites located near the Morey Arroyo, if jurisdictional waters are present, the project would be subject to
jurisdictional assessment pursuant to Mitigation Measure BIO-2.

Principle 6-P.11 Retain the maximum feasible amount of
agricultural land for its contributions to the local
economy, lifestyle, air quality, habitat value and sense of Redlands’ heritage.

Consistent. All of the sites within the Project area are designated for urban uses including industrial, commercial, and residential uses. The rezone would not affect the land that is being preserved for agricultural uses within the city of Redlands.

Action 6-A.23 Permit transfer of development rights
(TDR) between agreeable owners to preserve
agricultural land and citrus groves. Develop an
agricultural land mitigation program to conserve
agricultural land through agricultural conservation
easements at a ratio of 1:1 or greater.

Action 6-A.26 Ensure that new development adjacent to
an agricultural use is compatible with the continuation of the use by requiring appropriate design criteria, such as site layout, landscaping, and buffer areas.

Consistent. Sites that are adjacent to agricultural uses would be properly designed to accommodate the
neighboring uses. Potential projects would also be subject to design approval by the City prior to receiving building permits.

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

Consistent. As discussed in the Initial Study (Appendix A), implementing developments would be required to prepare
a Water Quality Management Plan that includes post-
development BMPs and a Stormwater Pollution Prevention
Plan that includes construction BMPs in order to ensure that implementing projects would not result in any water quality issues.

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

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

Action 6-A.36 Promote the use of Low Impact
Development strategies, BMPs, pervious paving
materials, and onsite infiltration for treating and
reducing stormwater runoff before it reaches the
municipal stormwater system.

Action 6-A.37 Protect and, where feasible, enhance or
restore the city’s waterways, including zanjas and
ditches, preventing erosion along the banks, removing
litter and debris, and promoting riparian vegetation and buffers.

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

Consistent. All projects within the Project site would be required to landscape and they would be subject to design approval by the City prior to being granted building
permits.

Action 6-A.43 Ensure that post-development peak
stormwater runoff discharge rates do not exceed the
estimated pre-development rate. Dry weather runoff
from new development must not exceed the pre-
development baseline flow rate to receiving
waterbodies.

Consistent. As discussed in the Initial Study, included as Appendix A, the Project would not result in increased flows compared to the current potential buildout. Proposed
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improvements or payment of a storm drain impact
development fee.

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

Consistent. As discussed in Section 5.10, Transportation, Potential future development facilitated by the Project may include sidewalk improvements. Specific sidewalk
improvements required to support residential or school
development within the Project area are not known at this time and will not be known until a development project is proposed. Future projects under the proposed Project
would be required to comply with and adhere to uniform
standards and practices, including provision of adequate sidewalk, as ensured and verified by the city during the plan check and permitting process, prior to obtaining
building permits.

Principle 7-P.10 Equitably share the cost of parkland
creation and maintenance between existing and new
residents, businesses, and property owners
Consistent. Implementing projects would be required to
pay all development impact fees in order to ensure that the City can continue to provide adequate recreational
facilities.

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

Principle 7-P.16 Ensure that all Redlands residents have access to a variety of transportation and physical activity options that enhance health and that work for diverse
lifestyles, incomes, and abilities
Consistent. As discussed previously, potential future
development facilitated by the Project may include
sidewalk improvements. Specific sidewalk improvements
required to support residential or school development
within the Project area are not known at this time and will not be known until a development project is proposed.

Future projects under the proposed Project would be
required to comply with and adhere to uniform standards and practices, including provision of adequate sidewalk, as ensured and verified by the City during the plan check and permitting process, prior to obtaining building permits.

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

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

Action 7-A.89 Require adherence to applicable
buildings codes and standards in accordance with Fire
Hazard Overlay Districts, California Fire Code, and the California Building Code.

Consistent. Implementing projects pursuant to the RHNA
Rezone would undergo development review pursuant to the Redlands Municipal Code in order to ensure that the
development would adhere to all applicable building
codes and standards. Proposed development plans would
be reviewed by the City’s Fire Department in order to
ensure that new development minimizes potential fire
hazards through building design.

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

Action 7-A.95 Coordinate with the Redlands Fire
Department and other fire prevention agencies to review all applications for new development. The Fire
Department’s review should ensure compliance with fire
safety regulations and assess potential impacts to
existing fire protection services and the need for
additional and expanded services
Principle 7-P.41 Ensure that new development is
compatible with the noise environment by continuing to
use potential noise exposure as a criterion in land use planning
Consistent. As discussed in Section 5.7, Noise, new
development would be required to be compatible with the existing noise environment through implementation of noise Mitigation Measures NOI-1 and NOI-2. Implementing
developments within areas where projected noise levels
are higher would be required to submit an acoustical
analysis demonstrating that the project would meet the
applicable noise standards.

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

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

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

Consistent. As discussed in Section 5.7, Noise, new
development would be required to be compatible with the existing noise environment through implementation of
Mitigation Measures NOI-1 and NOI-2. Implementing non-
residential developments would be required to prepare a noise analysis in order to ensure that the proposed project would not result in impacts to sensitive receptors.

Action 9.0w Limit hours for all construction or demolition work where site-related noise is audible beyond the site boundary
Consistent. As discussed in Section 5.7, Noise, new
development would be constructed pursuant to the
Redlands Municipal Code, which limits hours of construction.

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

Consistent. As discussed in Section 5.2, Air Quality,
Mitigation Measures AQ-1 and AQ-2 are included, which
requires development projects to provide modeling of the regional and the localized emissions (NO X, CO, PM 10, and PM2.5) associated with the maximum daily grading activities for the proposed development; and requires grading
activity to be limited to ensure that there would be no impacts to sensitive receptors.

Action 8-A.9 Encourage the use of construction, roofing materials, and paving surfaces with solar reflectance
and thermal emittance values per the California Green
Building Code (Title 24, Part 11 of the California Code of Regulations) to minimize heat island effects.

Consistent. Implementing projects pursuant to the RHNA
Rezone would be required to adhere to the California
Building Code.

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

Consistent. The future projects within the RHNA Rezone
Project would be required to be in line with City Municipal Code standards and would contain landscaping throughout the sites.

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

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

Consistent. Implementing projects pursuant to the RHNA
Rezone would be required to adhere to the California
Building Code, Title 24, and the California Energy Code.

Action 8-A.40 Promote the Leadership in Energy and
Environmental Design (LEED) certification program for the design, operation, and construction of high-performance green buildings.

City of Redlands Municipal Code
Upon adoption of the proposed Project, the development regulations and design criteria within the new zoning designations would apply to the Project area. Future development projects pursuant to the proposed Project would be required to adhere to City Municipal Code standards, which would be verified through the City’s review process. As such, the proposed rezone would not result in conflicts with the City of Redlands zoning code, and impacts would be less than significant.

Overall, the Project would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts would be less than significant.

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

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

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5.9.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
• City of Redlands Municipal Code
• City of Redlands General Plan
Plans, Programs, or Policies
None.

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

5.6.9 MITIGATION MEASURES
No mitigation measures are required.

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

5.6.11 REFERENCES
City of Redlands. (2017a). Redlands General Plan 2035. Retrieved August 8, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2017b ). Redlands General Plan Environmental Impact Report. Retrieved August 8, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2022). City of Redlands Zoning Map . Retrieved August 8, 2024, from https://www.cityofredlands.org/sites/main/files/file-attachments/zoning.pdf?1633557844 SCAG. (2024). Regional Transportation Plan and Sustainable Communities Strategy . Retrieved July 11, 2024, from https://scag.ca.gov/sites/main/files/file-attachments/23-2987-connect-socal-2024- final-complete-040424.pdf?1714175547
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5.7 Noise

5.7.1 INTRODUCTION
This Draft Subsequent EIR section evaluates the potential noise and vibration impacts that would result from buildout pursuant to the proposed Project. It discusses the existing noise environment within and around the proposed rezone areas as well as the regulatory framework for regulation of noise. This section analyzes the effect of the proposed Project on the existing ambient noise environment during future demolition, construction, and operational activities that would occur from buildout pursuant to the proposed rezoning, and evaluates the proposed Project’s noise effects for consistency with relevant local agency noise policies and regulations. This section includes data from the following:
• City of Redlands General Plan 2035 , December 2017;
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report , July 2017; and
• City of Redlands Municipal Code.

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

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

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

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

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

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

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

Ambient noise level: the background noise level associated with a given environment at a specified time; usually a composite of sound from many sources from many directions.

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

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

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

Hard sites are those with a reflective surface between the source and the receiver, such as asphalt or concrete surfaces or smooth bodies of water. No excess ground attenuation is assumed for hard sites and the changes in noise levels with distance (drop-off rate) is simply the geometric spreading of the noise from the source.

Soft sites have an absorptive ground surface such as soft dirt, grass, or scattered bushes and trees. In addition to geometric spreading, an excess ground attenuation value of 1.5 dBA (per doubling distance) is normally assumed for soft sites. Line sources (such as traffic noise from vehicles) attenuate at a rate between 3 dBA for hard sites and 4.5 dBA for soft sites for each doubling of distance from the reference measurement .

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Fundamentals of Vibration
Vibration is energy transmitted in waves through the ground or man-made structures. These energy waves generally dissipate with distance from the vibration source. There are several different methods that are used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal. The PPV is most frequently used to describe vibration impacts to buildings but is not always suitable for evaluating human response (annoyance) because it takes some time for the human body to respond to vibration signals. Instead, the human body responds to average vibration amplitude often described as the root mean square (RMS). The RMS amplitude is defined as the average of the squared amplitude of the signal and is most frequently used to describe the effect of vibration on the human body.

Decibel notation (VdB) is commonly used to measure RMS. VdB serves to reduce the range of numbers used to describe human response to vibration. Typically, ground-borne vibration generated by man-made activities attenuates rapidly with distance from the source of the vibration. Sensitive receivers for vibration include structures (especially older masonry structures), people (especially residents, the elderly, and sick), and vibration-sensitive equipment.

The background vibration-velocity level in residential areas is generally 50 VdB. Ground-borne vibration is normally perceptible to humans at approximately 65 VdB. For most people, a vibration-velocity level of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels. Typical outdoor sources of perceptible ground-borne vibration are construction equipment, steel-wheeled trains, and traffic on rough roads. If a roadway is smooth, the ground-borne vibration is rarely perceptible. The range of interest is from approximately 50 VdB, which is the typical background vibration-velocity level, to 100 VdB, which is the general threshold where minor damage can occur in fragile buildings.

5.7.2 REGULATORY SETTING

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

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

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

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

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

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

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

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

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

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

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

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

Action 7-A.137 For all projects that have noise exposure levels that exceed the standards in Table 7- 10, require site planning and architecture to incorporate noise-attenuating features.

With mitigation, development should meet the allowable outdoor and indoor noise exposure standards in Table 7-11. When a building’s openings to the exterior are required to be closed to meet the interior noise standard, mechanical ventilation shall be provided.

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

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

Table 7-10 of the General Plan Healthy Community Element (included as Table 5.7-1 of this Draft Subsequent EIR) identifies the specific criteria to evaluate proposed developments based on exterior and interior noise level limits for land uses and requires a noise analysis to determine needed mitigation measures if necessary. The Healthy Community Element identifies schools, hospitals, places of worship, and homes as a noise-sensitive land use.

Also, as shown in Table 5.7-2, the City of Redlands General Plan has an exterior (outdoor) noise standard of 60 dBA CNEL related to private yards of single-family residences as measured at the property line; multifamily private patios or balconies which is served by a means of exit from inside; mobile home parks; hospital patios; park picnic areas; school playgrounds; hotel and recreational areas.

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

Measure U 9.0e Use the criteria specified in General Plan Table 9.1 [Table 5.7-1] to assess the compatibility of proposed land uses with the projected noise environment and apply the noise standards in General Plan Table 9.2 [Table 5.7-2], which prescribe interior and exterior noise standards in relation to specific land uses. Do not approve projects that would not comply with the standards in General Plan Table 9.2 [Table 5.7-2]. These Redlands Regular Meeting of 06-03-25
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tables are the primary tools which allow the City to ensure noise-integrated planning for compatibility between land uses and outdoor noise.

Measure U 9.0f Require a noise impact evaluation based on noise measurements at the site for all projects in Noise Referral Zones (B, C, or D) as shown on General Plan Table 9.1 [Table

5.7-1] and on General Plan Figure 9.1 [Table 5.7-2] or as determined from tables in the Appendix, as part of the project review process. Should measurements indicate that unacceptable noise levels will be created or experienced, require mitigation measures based on a detailed technical study prepared by a qualified acoustical engineer (i.e., a Registered Professional Engineer in the State of California with a minimum of three years’ experience in acoustics).

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

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

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

Measure U 9.0v Consider the following impacts as possibly “significant”:
• An increase in exposure of four or more dB if the resulting noise level would exceed that described as clearly compatible for the affected land use, as established in General Plan Table 9.1 [Table 5.7-1] and General Plan Table 9.2 [Table 5.7-2]; • Any increase of six dB or more, due to the potential for adverse community response.

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

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

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Table 5.7-1: City of Redlands General Plan Noise/Land Use Compatibility Matrix Source: City of Redlands General Plan Noise Element, Chapter 7 Healthy Community, Section 7.5 Noise, Table 7-10.

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Table 5.7-2: City of Redlands General Plan Interior and Exterior Noise Standards Source: City of Redlands General Plan Noise Element, Chapter 7 Healthy Community, Section 7.5 Noise, Table 7-11.

City of Redlands Municipal Code
The City of Redlands Municipal Code Chapter 8.06 establishes noise standards by land use. For the noise- sensitive residential uses, Municipal Code Section 8.06.070[A] identifies the base exterior noise level standard of 60 dBA Leq during the daytime hours (7:00 a.m. to 10:00 p.m.) and 50 dBA Leq during the Redlands Regular Meeting of 06-03-25
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nighttime (10:00 p.m. to 7:00 a.m.) hours. As shown in Table 5.7-3, higher noise levels are allowed for shorter periods of time.

Table 5.7-3: City of Redlands Operational Noise Standards Land
Use Time Period
Exterior Noise Level Standards (dBA)
L50
(30 mins)
L25
(15 mins)
L8
(5 mins)
L2
(1 min)
Lmax
(0 min)
Residential Daytime 60 65 70 75 80
Nighttime 50 55 60 65 70
Commercial Daytime 65 70 75 80 85
Nighttime 60 65 70 75 80
Industrial Anytime 75 80 85 90 95
Source: City of Redlands Municipal Code, Section 8.06.070 [A]-Table 1. Section 8.06.070[C] states that if the measured ambient level exceeds the allowable noise exposure standard within any of the first four noise limit categories above, the allowable noise exposure standard shall be adjusted in five dB increments in each category as appropriate to encompass or reflect said ambient noise level. The percent noise level is the level exceeded "n" percent of the time during the measurement period. L50 is the noise level exceeded 50% of the time. "Da
ytime" = 7:00 a.m. to 10:00 p.m.; "Nighttime" = 10:00 p.m. to 7:00 a.m.

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

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

1. The exterior noise standard of the applicable land use category for a cumulative period of 30 minutes in any hour (L 50); or

2. The exterior noise standard of the applicable land use category, plus 5 dBA, for a cumulative period of more than 15 minutes in any hour (L ₂₅); or

3. The exterior noise standard of the applicable land use category, plus 10 dBA, for a cumulative period of more than 5 minutes in any hour (L 8); or

4. The exterior noise standard of the applicable land use category, plus 15 dBA, for a cumulative period of more than 1 minute in any hour (L 2).

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

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

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

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

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

Existing Noise
Major noise sources within proximity to the Rezone sites include traffic noise and stationary noise. The background ambient noise levels in the areas surrounding the Rezone sites are dominated by the transportation-related noise associated with surface streets. The volume of noise is dependent on the traffic volumes and structures, such as walls, that are located between streets and receptors. Estimated roadway noise volumes are depicted in Figure 3.12-1, Existing Noise Contours (2017), of the City of Redlands General Plan EIR (City of Redlands, 2017b, p. 3.12-19).

Airports
The nearest airports to the proposed Project site are San Bernardino International Airport, approximately

2.5 miles to the northwest of Site 17, and Redlands Municipal Airport, approximately 1.85 miles northeast of Site 23. Site 23 is the only Rezone site within airport compatibility Zone D for the Redlands Municipal Airport (City of Redlands, 2017b, p. 3.7-2). None of the proposed sites are within the modeled noise contours for the Redlands Municipal Airport (City of Redlands, 2017b, Figure 3.12-3) or San Bernardino International Airport according to the County of San Bernardino General Plan Figure HZ-9 , Airport Safety and Planning Areas (San Bernardino County, 2020). Thus, the proposed Rezone sites are not subject to excessive noise levels from airport operations.

Existing Vibration
Aside from periodic construction work that may occur in the vicinity of the proposed Rezone sites, other sources of groundborne vibration include heavy-duty trucks on area roadways related to the existing urban uses throughout the City. Trucks traveling at a distance of 50 feet typically generate groundborne vibration velocity levels of around 63 VdB (approximately 0.006 in/sec PPV) and could reach 72 VdB (approximately

0.016 in/sec PPV) when trucks pass over bumps in the road (FTA, 2006).

Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. Similar to the proposed Project, construction activity would be required to comply with Section 8.06.090(F) of the City’s Municipal Code allows construction noise to exceed the City noise standards provided that construction activities occur between 7:00 a.m. and 6:00 p.m., Monday through Saturday, and not on Sundays and Federal holidays. However, the City construction noise standards do not provide any limits to the noise levels that may be created from construction activities and, even with adherence to the City standards, the resultant construction noise levels may result in a significant substantial temporary noise increase to the nearby residents. As discussed in General Plan EIR, buildout of the General Plan would result in a 1.2 dBA increase from roadway noise, which is barely perceptible. The development of new commercial and industrial uses pursuant to the General Plan may generate noise levels that exceed the City’s maximum exterior and interior limit due to the establishment of new stationary noise sources. New projects developed under the proposed Redlands Regular Meeting of 06-03-25
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General Plan would be subject to the City’s noise ordinance. The General Plan EIR determined that compliance with the City’s noise ordinance in the Municipal Code in Sections 8.06.070 and 8.06.080.

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

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

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

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

Operational Noise
A significant operational noise impact would occur under the following conditions:
• If Project related operational increase in ambient noise levels result in:
o An increase in exposure of 4 or more dB, if the resulting noise level would exceed that described as clearly compatible for the affected land use, as established in General Plan Table 9.1 [EIR Table

5.7-1] and General Plan Table 9.2 [EIR Table 5. 7-2];
o Any increase of 6 dB or more, due to the potential for adverse community response (Measure U Policy 9.0v).

5.7.5 METHODOLOGY
Construction Noise
To identify the temporary construction noise contribution to the existing ambient noise environment, the construction noise levels anticipated from usage of construction equipment needed for typical construction Redlands Regular Meeting of 06-03-25
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projects were analyzed through comparison of construction noise levels to the thresholds to assess the level of significance associated with temporary construction noise level impacts. The City’s Municipal Code limits construction hours to reduce noise. The FTA considers a daytime exterior construction noise level of 80 dBA Leq and a nighttime exterior construction noise level of 70 dBA Leq as a reasonable threshold for noise sensitive residential land use. The construction noise levels are compared against the FTA’s threshold to assess the level of significance associated with temporary construction noise level impacts.

Operational Noise
The primary source of noise associated with the operation of buildout pursuant to the Project would be from vehicular trips and new stationary sources (such as heating, ventilation, and air conditioning units) associated with the new site-specific development that would occur under the proposed zoning. The increase in noise levels generated by these activities has been estimated and compared to the applicable noise standards listed previously.

Vibration
Aside from noise levels, groundborne vibration would also be generated during construction of future uses pursuant to the proposed zoning by various construction-related activities and equipment; and could be generated by truck traffic traveling to and from the construction sites. The potential ground-borne vibration levels resulting from construction activities were estimated by data published by the FTA. Thus, the groundborne vibration levels generated by these sources have also been estimated and compared to the applicable thresholds of significance listed previously.

5.7.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
Construction Noise. The General Plan EIR describes that the exact location of projects and construction activities that would be implemented under the General Plan are not known, though it is likely that construction activities would take place within the vicinity of sensitive receptors. The City regulates noise associated with construction equipment and activities through its Noise Control Ordinance in the Municipal Code. Thus, compliance with the City’s Noise Control Ordinance in the Municipal Code in Section 8.06.090 would be required for any future construction. Therefore, the General Plan EIR determined the noise impact from construction activities associated with implementation of the proposed General Plan would be less than significant (City of Redlands, 2017b, p. 3.12-34).

Traffic Noise. The General Plan EIR describes that buildout of the General Plan update would generate traffic, which would increase traffic noise levels along existing and future roadways. Draft EIR Table 3.12- 8 shows that traffic noise would increase by up to 1.2 dBA, which is normally not perceptible by the human ear in an outdoor environment. Therefore, the General Plan EIR determined that potential traffic noise impacts associated with buildout of the General Plan land uses would be less than significant (City of Redlands, 2017b, p. 3.12-35).

Stationary Noise. The General Plan EIR describes that buildout of the General Plan update could expose existing and/or new sensitive uses to stationary noise sources, such as industrial and/or commercial uses. The development of new commercial and industrial uses pursuant to the General Plan may generate noise levels that exceed the City’s maximum exterior and interior limit due to the establishment of new stationary noise sources. New projects developed under the proposed General Plan would be subject to the City’s noise ordinance. The General Plan EIR determined that compliance with the City’s noise ordinance in the Municipal Redlands Regular Meeting of 06-03-25
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Code in Sections 8.06.070 and 8.06.080 would result in less than significant noise impact (City of Redlands, 2017 p. 3.12-49).

Vibration. The General Plan EIR describes that during construction activities related to buildout of the General Plan, the use of large bulldozers and trucks would generate the highest groundborne vibration levels of 0.089 PPV in/sec and 0.076 PPV in/sec, respectively, when measured at 25 feet. General Plan EIR Table 3.12-10 shows that for fragile structures located within 19 feet, residential structures constructed with non-engineered timber located within 12 feet, and modern industrial/commercial structures constructed with engineered concrete and masonry located within 8 feet of construction activity, the use of a large bulldozer would potentially damage the structure. The General Plan EIR determined that construction activities with the use of a large bulldozer would not likely occur within the structure type and their corresponding distance mentioned above. Therefore, vibration levels generated during construction were determined to be less than significant. Also, the General Plan EIR determined that groundborne vibration impacts generated by vehicles from buildout of the General Plan land uses would be less than significant (City of Redlands, 2017, p. 3.12-53).

Proposed Project
The proposed Project would rezone 24 sites for the purpose of increasing residential development capacity.

Buildout of the proposed Project would change the maximum buildout of the Project area from 828,349.93 SF of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 111 multi-family dwelling units, 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses to residential uses with an allowed capacity of 2,436 units and approximately 151,048.46 SF of Public/Institutional uses. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings). As detailed in Section 5.10, Transportation, the proposed Project is anticipated to result in a total reduction of approximately 27,540 daily vehicle and truck trips compared to the trips that would result from buildout of the Project site under the existing General Plan land use designations.

IMPACT NOI-1: THE PROJECT WOULD NOT GENERATE A SUBSTANTIAL TEMPORARY OR PERMANENT

INCREASE IN AMBIENT NOISE LEVELS IN EXCESS OF STANDARDS ESTABLISHED IN

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

Construction
Less than Significant with Mitigation Incorporated. The timing of development and various construction activities pursuant to the proposed Project would be dependent upon market conditions and development applications for new projects. Thus, construction activities associated with buildout of the proposed Project would likely occur sporadically and include different development-specific construction activities.

Noise generated by construction equipment could include a combination of trucks, power tools, concrete mixers, and portable generators that, when combined, can reach high levels. Construction projects are generally expected to occur in the following stages: demolition, excavation, and grading, building construction, architectural coating, and paving. Combined noise levels generated by heavy construction equipment range from approximately 77 dBA (Lmax) to 83 dBA (Lmax) at 50 feet from the noise source, as shown in Table 5.7-4.

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Table 5.7-4: Construction Reference Noise Levels
Construction
Stage
Reference
Construction Activity
Reference Noise
Level @ 50 Feet
(dBA Leq)1
Combined
Noise Level
(dBA Leq)2
Combined Sound
Power Level
(PWL)3
Demolition
Demolition Equipment 82
83 115Backhoes 74
Hauling Trucks 72
Site
Preparation
Crawler Tractors 78
80 112Hauling Trucks 72
Rubber Tired Dozers 75
Grading
Graders 81
83 115Excavators 77
Compactors 76
Building
Construction
Cranes 73
81 113Tractors 80
Welders 70
Paving
Pavers 74
83 115Paving Equipment 82
Rollers 73
Architectural
Coating
Cranes 73
77 109Air Compressors 74
Generator Sets 70
1 FHWA Roadway Construction Noise Model (RCNM).
2 Represents the combined noise level for all equipment assuming they operate at the same time consistent with FTA Transit Noise and Vibration Impact Assessment guidance.
3 Sound power level represents the total amount of acoustical energy (noise level) produced by a sound source independent of distance or surroundings. Sound power levels calibrated usin g the CadnaA noise model at the reference distance to the noise source.

Hard site conditions are used in this construction noise analysis which result in noise levels that attenuate (or decrease) at a rate of 6 dBA for each doubling of distance from a point source (i.e., construction equipment).

For example, a noise level of 83 dBA measured at 50 feet from the noise source to the receiver would be reduced to 77 dBA at 100 feet from the source to the receiver and would be further reduced to 71 dBA at 200 feet from the source to the receiver.

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

Because buildout pursuant to the proposed Project could result in construction in proximity to existing or future sensitive receptors, temporary intermittent construction noise impacts could occur. Therefore, Mitigation Measures NOI-1 and NOI-2 have been included to provide construction measures to reduce potential construction noise impacts to a less-than-significant level.

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Operation
Less than Significant Impact.

Increase in Roadway Noise
Buildout pursuant to the proposed Project would result in new residential development and an overall decrease in nonresidential development compared to buildout under the existing General Plan and zoning designations. The primary source of noise impacts related to the new development would be from traffic- related noise from vehicle and truck trips.

As described in Section 3.0, Project Description, the proposed Project would convert approximately 2,057,992.2 SF of planned nonresidential land uses, based on allowed FAR under the General Plan, to residential uses with an allowed additional capacity of 2,325 compared to the existing General Plan land uses. As detailed in Section 5.10, Transportation, the proposed Project is anticipated to result in a total reduction of approximately 27,540 daily trips, including a reduction of 1,716 p.m. peak hour trips compared to buildout of the existing zoning. As the Project would result in a reduction in daily trips compared to buildout of the existing General Plan land uses, impacts related to increased traffic noise from implementation of the proposed Project would be less than significant.

Roadway Noise Compatibility
As described previously, the General Plan EIR determined that buildout of the General Plan update would generate traffic, which would increase traffic noise levels by up to 1.2 dBA, which is normally not perceptible by the human ear in an outdoor environment; therefore, it was determined to be less than significant. (City of Redlands, 2017b, p. 3.12-35)
With implementation of the proposed Project, it is possible that new noise sensitive land uses adjacent to arterial roadways could experience future unmitigated exterior noise levels greater than 65 dBA CNEL, which is normally incompatible for residential uses based on the General Plan Noise/Land Use Compatibility Matrix (Table 5.7-1). Therefore, based on the proximity of future noise sensitive land uses, traffic-related noise impacts at future residential uses within the Project area would be potentially significant. However, this would be dependent upon the specific location and design of future projects. Thus, existing General Plan policies would be implemented to protect future uses. As listed previously, General Plan Healthy Community Element Action 7-A.136 requires a noise analysis be conducted for all development proposals located where projected noise exposure would be other than “clearly” or “normally compatible” and Action 7-A.137 requires site planning and architecture to incorporate noise-attenuating features. Likewise, Measure U 9.0e requires noise level compliance for new projects, Measures U 9.0f, U 9.0u, and U 9.0v require noise studies or other verification that impacts would not occur, and Measure U 9.0i requires noise barriers. Therefore, with implementation of existing General Plan policies, impacts related to future residences within traffic noise impacted areas would be less than significant.

Noise from New Land Use Operations
Buildout pursuant to the proposed Project would result in development of new residential and public/institutional uses that would generate a combination of noise sources that include air conditioning units, parking lots, trash enclosures, and outdoor activities in park and recreation areas. These Project-related noise sources are consistent with existing noise sources throughout the City of Redlands and consistent with or less intensive than the noise sources that would occur from development of the existing zoning. Although, operation of new uses developed pursuant to the proposed Project could result in a substantial increase the ambient noise levels at sensitive receptors if not designed appropriately, the City’s review and development permitting process ensures future project compliance with Municipal Code Section 8.06.090(F). As described previously, the General Plan Healthy Community Element Action 7-A.137 requires site planning and architecture to incorporate noise-attenuating features. Through implementation of the City’s existing General Redlands Regular Meeting of 06-03-25
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Plan and Municipal Code regulations that would be verified through the City’s development review and permitting process, impacts would be less than significant.

As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to noise would be less than significant.

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

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

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

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

5.7-5. Based on the representative vibration levels presented for various construction equipment types, it is possible to estimate construction vibration levels using the following vibration assessment methods defined by the FTA. To describe the human response (annoyance) associated with vibration impacts, the FTA provides the following equation: PPVequip = PPVref x (25/D).

Table 5.7-5: Vibration Source Levels for Construction Equipment Equipment PPV (in/sec) at 25 feet
Small bulldozer 0.003
Jackhammer 0.035
Loaded Trucks 0.076
Large bulldozer 0.089
The primary source of vibration during infill and redevelopment construction would be from the operation of a bulldozer. As shown in Table 5.7-5, a large bulldozer would create a vibration level of 0.089 in/sec PPV at 25 feet. The Caltrans Transportation and Construction Vibration Guidance Manual (Caltrans, 2020), describes that fragile historic buildings have the potential to be impacted at a 0.08 in/sec PPV.

To describe the RMS vibration level and demonstrate compliance with the Municipal Code perceptible vibration threshold of 0.01 in/sec RMS, PPV velocities are converted to RMS vibration levels based on the Caltrans Transportation and Construction Vibration Guidance Manual conversion factor of 0.71 and are listed in Table 5.7-6 at distances ranging from 25 to 150 feet from construction activity. As shown, construction vibration levels would range from 0.004 to 0.063 in/sec RMS, and would exceed the perceptible vibration threshold of 0.01 in/sec RMS at distances of 100 feet or less. Therefore, Mitigation Measures NOI-3 is included to ensure that vibratory equipment shall be prohibited within 100 feet of existing residential structures or occupied noise-sensitive uses, and that other equipment be used to reduce potential vibration impacts to below the vibration threshold of 0.01 in/sec RMS, which would reduce impacts to a less-than- significant level. In addition, Mitigation Measure NOI-4 is included to require an assessment of fragile historic Redlands Regular Meeting of 06-03-25
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buildings within 25 feet of construction to ensure that construction vibration from implementation of the proposed Project would not damage any historic structures. With implementation of these mitigation measures, potential impacts related to construction vibration would be less than significant.

Table 5.7-6: Construction Equipment Vibration Levels
Distance to
Const. Activity
(Feet)
Receiver Levels (in/sec) PPV Velocity
Levels
(in/sec)
RMS
Threshold
(in/sec)
RMS
Threshold
Exceeded?Small
Bulldozer
Jack-
hammer
Loaded
Trucks
Large
Bulldozer
Peak
Vibration
25 0.0030 0.0350 0.0760 0.0890 0.0890 0.063 0.01 Yes
50 0.0011 0.0124 0.0269 0.0315 0.0315 0.022 0.01 Yes
100 0.0004 0.0044 0.0095 0.0111 0.0111 0.008 0.01 No
125 0.0003 0.0031 0.0068 0.0080 0.0080 0.006 0.01 No
150 0.0002 0.0024 0.0052 0.0061 0.0061 0.004 0.01 No
Source: Caltrans, 2020
Operation
Less than Significant Impact. The proposed Project would consist of infill and redevelopment of sites with new residential and public/institutional uses instead of commercial and industrial uses as currently planned for under the existing General Plan land use designations. The operation of residential and public/institutional land uses would not include the operation of any vibration sources other than typical onsite vehicle and truck operations, which result in negligible vibration levels. Therefore, impacts related to operational vibration from buildout pursuant to the proposed Project would be less than significant.

As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to vibration would be less than significant.

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

Buildout of the proposed Project in combination with surrounding cumulative projects through the year 2035 would result in an increase in construction-related and traffic-related noise. However, Municipal Code Section

8.06.090(F) requires construction activities to not occur within the hours of 6:00 p.m. and 7:00 a.m. on weekdays or anytime on Sundays and federal holidays. Also, construction noise and vibration are localized in nature and decrease substantially with distance. Consequently, in order to achieve a substantial cumulative increase in construction noise and vibration levels, more than one source emitting high levels of construction noise would need to be in close proximity to the Rezone sites with construction activity. As the timing of development and various construction activities pursuant to the proposed Project would be dependent upon market conditions and development applications for new projects, construction activities associated with buildout pursuant to the rezoning would occur sporadically through the year 2035. Thus, it is currently unknown if future construction projects would occur adjacent to one another. As shown in Figure 5-1, Cumulative Projects , there are several existing cumulative projects within the general vicinity of the Rezone sites, which are listed in Table 5.7-7. As detailed, several projects are completed, entitled, and in planning, and one project is under construction.

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Table 5.7-7: Existing Cumulative Projects Related to Noise and Vibration No. Cumulative Project Location/Address Description Project Status City of Redlands

2. Liberty Lane Apartments, CUP
1045
SWC Lugonia Ave &
Texas Street
80 multi-family residential units Under
Construction

3. Luxview Apartments, CUP 1108,
TTM 20244, SPA 45 & 46
1616 Orange Street 328 multi-family residential units Completed

4. Heritage Specific Plan, TTM
20257, SP 62, GPA 141
NWC Texas St & W.

San Bernardino Avenue
207 single-family residential units Completed

25. Lugonia Village, GPA 143, ZC
469, SPA 48 to EVCSP, TTM
40490 & 40491, TPM 40469,
CRAs 940, 941, 942
NEC Tennessee St &
W. Lugonia Ave
90 single-family residences, 451
multi-family residences
Entitled

29. Luxview Phase 2, CRA 958 SWC Alabama St &
Orange Ave
164 multi-family residences with
affordable housing
In Planning

31. CRA 912 10797 & 10843 New
Jersey St
179,400 SF warehouse building Completed

36. CRA 928 10756 Nevada St 88,400 SF warehouse building Completed

49. CRA 938, CUP 1187 350 Iowa St 181,100 SF warehouse Entitled

56. CRA 952 Alabama St & W
Citrus Ave
8,853 SF medical clinic Entitled

57. CRA 963 SWC Lugonia Ave &
New York St
16,027 SF grocery store Entitled

61. CUP 1184 & 1185 SWC Lugonia Ave &
New York St
Two fast food restaurants w/
drive-thrus totaling 6,020 SF
Entitled

65. CRA 959, CUP 1174, & 1175 NEC Lugonia Ave &
Tennessee St
Two fast food restaurants with
drive-thrus totaling 13,300 SF and
47,085 SF shopping center with
four retail buildings
In Planning

66. Carmax, CRA 962, CUP 1179,
SPA 52 to EVCSP
New York St. at
Brockton Ave.
4,958 SF used automobile sales
building, 47,085 SF automobile
repair
In Planning
Source: Section 5.0, Table 5-1.

Due to the unknown timing of future developments under the proposed zoning, it is unknown what construction activities would concurrently within proximity to each other. However, implementation of construction Mitigation Measures NOI-1 and NOI-2 and vibration Mitigation Measures NOI-3 and NOI-4 provided herein would reduce the potential of noise and vibration levels from different construction projects combining to become cumulatively considerable to a less than significant level. Therefore, with implementation of mitigation, cumulative noise and vibration impacts associated with construction activities would be less than significant.

Development resulting from approval of the proposed Project in combination with other projects could result in an increase in ambient noise. However, all development projects would be subject to the operational noise standards established by the General Plan and Municipal Code, which would ensure that noise from new uses would stay below City standards, and therefore, not combine with other development projects to be cumulatively significant. Thus, operational noise from new land in combination with buildout pursuant to the proposed Project would result in less-than-significant cumulative noise impacts.

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5.7.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
• California Code of Regulations, Title 24 included in the City’s Municipal Code in Chapter 18. • City’s Municipal Code Section 8.06.090(F), all construction activities shall be limited to the daytime hours of between 7:00 a.m. to 6:00 p.m. Monday to Saturdays; with no activity allowed on Sundays or holidays
• City’s Municipal Code Section 8.06.020, defines the vibration perception threshold as 0.01 inches per second (in/sec) RMS.
• City of Redlands General Plan Healthy Community Element Action 7-A.136 and Action 7-A.137. • City of Redlands Measure U 9.0, et al.

Plans, Programs, or Policies
None.

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

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

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

5.7.10 MITIGATION MEASURES
General Plan EIR Mitigation Measures
None.

Proposed Project Mitigation Measures
Mitigation Measure NOI-1: Construction Noise Levels. Prior to the issuance of a demolition, grading, or building permit for new development, the project plans and specifications shall demonstrate that all construction activity shall satisfy the exterior construction noise level of 80 dBA L eq at a sensitive receiver (defined as residences, schools, and recreation areas) and include the following measures to reduce construction related noise at sensitive receptors:
• Construction contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturers’ standards, and all stationary construction equipment shall be placed so that emitted noise is directed away from the noise-sensitive use nearest the construction activity.
• Construction contractors shall locate equipment staging in areas that will create the greatest distance between construction-related noise sources and noise-sensitive receiver nearest to the construction activity.

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Mitigation Measure NOI-2: Construction Noise Barriers. Prior to the issuance of a demolition, grading, or construction permit for new development that could exceed the exterior construction noise level of 80 dBA Leq at a sensitive receiver (defined as residences, schools, and recreation areas), the project plans and specifications shall detail the installation of temporary construction noise barriers for occupied noise-sensitive uses for the duration of construction activities that could exceed the construction noise level thresholds. The noise control barrier(s) must provide a solid face from top to bottom and shall:
• Provide a minimum transmission loss of 20 dBA and be constructed with an acoustical blanket (e.g., vinyl acoustic curtains or quilted blankets) attached to the construction site perimeter fence or equivalent temporary fence posts;
• Be maintained and any damage be repaired within 24-hours. Gaps, holes, or weaknesses in the barrier or openings between the barrier and the ground shall be repaired within 24-hours; and • Be removed and the site appropriately restored upon the conclusion of the construction activity.

Mitigation Measure NOI-3: Construction Vibration. Prior to approval of a demolition permit, grading plans, and/or issuance of building permits for construction activities within 100 feet of existing residential structures that require the use of large bulldozers, large loaded trucks, jackhammers, pile drivers, and/or caisson drills, the City of Redlands Building and Safety Division shall ensure that construction plans and specifications state that the use of such vibratory equipment shall be prohibited within 100 feet of existing residential structures or occupied noise-sensitive uses. Instead, small rubber-tired bulldozers shall be used within this area during demolition and/or grading operations to reduce vibration effects.

Mitigation Measure NOI-4: Construction Vibration Near Fragile Historic. Any site-specific development project within 25 feet of an extremely fragile historic building shall engage a qualified structural engineer to conduct a pre-construction assessment of the structural integrity of the nearby historic structure(s) and submit evidence to the City of Redlands Building and Safety Division detailing that the operation of vibration- generating equipment associated with the new development would be below the vibration threshold of 0.01 inches per second (in/sec) RMS, and would not result in structural damage to the adjacent historic building(s).

If recommended by the pre-construction assessment, groundborne vibration monitoring of nearby historic structures shall be required.

5.7.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact NOI-1: After implementation of Mitigation Measures NOI-1 and NOI-2, buildout pursuant to the proposed Project would not result in a substantial temporary or permanent increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance. Thus, impacts would be less than significant.

Impact NOI-2: After implementation of Mitigation Measures NOI-3 and NOI-4, buildout pursuant to the proposed Project would not result in excessive groundborne vibration or groundborne noise levels. Thus, impacts would be less than significant.

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

5.7.12 REFERENCES
Caltrans. (2020). Transportation and Construction Vibration Guidance Manual. https://dot.ca.gov/- /media/dot-media/programs/environmental-analysis/documents/env/tcvgm-apr2020-a11y.pdf Redlands Regular Meeting of 06-03-25
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Caltrans. (2024). Standard Environmental Reference Volume 1: Guidance for Compliance . https://dot.ca.gov/programs/environmental-analysis/standard-environmental-reference- ser/volume-1-guidance-for-compliance/ch-12-noise
Federal Transit Administration (FTA). (2006). Transit Noise and Vibration Impact Assessment. https://docs.vcrma.org/images/pdf/planning/ceqa/FTA_Noise_and_Vibration_Manual.pdf City of Redlands. (July 2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (July 2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669. Accessed July 2, 2024.

City of Redlands. (2024). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 San Bernardino County. (2020). HZ-9 Airport Safety & Planning Areas [map]. https://www.arcgis.com/apps/webappviewer/index.html?id=5dc02b81369c49c9a1947aedfc3 00a45
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5.8 Population and Housing

5.8.1 INTRODUCTION
This section examines the existing population, housing, and employment conditions in the City of Redlands and assesses the Project’s environmental impacts related to direct and indirect growth. The demographic data and analysis in this section is based, in part, on the following documents and resources:
• Connect SoCal, The 2020-20545 Regional Transportation Plan/Sustainable Communities Strategy, SCAG, April 2024
• Local Profiles Report 2019, Profile of the City of Redlands , SCAG, May 2019 • Population Estimates for Cities, Counties, and the State, California Department of Finance (DOF), 2024 • C
ity of Redlands General Plan 2035 , December 5, 2017; and • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), July 2017.

Although evaluation of population, housing, and employment typically involves economic and social, rather than physical environmental issues, population, housing, and employment growth are often precursors to physical environmental impacts. According to Section 15382 of the CEQA Guidelines, “[a]n economic or social change by itself shall not be considered a significant impact on the environment.” Socioeconomic characteristics should be considered in an EIR only to the extent that they create adverse impacts on the physical environment.

5.8.2 REGULATORY SETTING

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

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

Southern California Association of Governments
SCAG is a council of governments representing Orange, Imperial, Los Angeles, Riverside, San Bernardino, and Ventura counties. It is the federally recognized metropolitan planning organization (MPO) for this region, which encompasses over 38,000 square miles. SCAG actions in San Bernardino County are partially the Redlands Regular Meeting of 06-03-25
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result of input from the San Bernardino County Council of Governments (SBCOG), which offers recommendations regarding SCAG’s initiatives.

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

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

For the 2021–2029 planning period, SCAG determined that the City of Redlands RHNA allocation is 3,516 housing units (City of Redlands, 2022). As shown in Table 5.8-1, 45 percent are identified for extremely low through low income housing and 55 percent for moderate and above moderate income housing.

Table 5.8-1: City of Redlands SCAG Regional Housing Needs Allocation, 2021-2029 Category Percent of County
Median
2021 Household
Income
2021-2029 Housing
Need
Extremely Low-Income Less than 30% Less than $26,500 483 (14%)
Very Low-Income 30-50% $26,500 - $39,500 484
(14%)
Low-Income 50-80% $39,500 - $63,200 615
(17%)
Moderate Income 80-120% $63,200 - $93,000 652
(19%)
Above Moderate Income Over 120% More than $93,000 1,282 (36%)
Total -- -- 3,516
Source: City of Redlands 2021-2029 Housing Element
SCAG Regional Transportation Plan/Sustainable Communities Strategy The Southern California Association of Governments (SCAG) is designated by federal law as a Metropolitan Planning Organization (MPO) and under State law as a Regional Transportation Planning Agency and a Council of Governments. The SCAG region encompasses six counties (Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura) and 191 cities in an area covering more than 38,000 square miles.

SCAG develops transportation and housing strategies for southern California as a whole. On September 3, 2020, SCAG’s Regional Council adopted Connect SoCal - The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020 RTP/SCS), which includes long-range regional transportation plans, regional transportation improvement programs, regional housing needs allocations, and other plans Redlands Regular Meeting of 06-03-25
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for the region. Most of the Plan’s goals are related to regional transportation infrastructure and the efficiency of transportation in the region.

On April 4, 2024, SCAG adopted “Connect SoCal,” the 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). The California Air Resources Board (CARB) has yet to approve of the technical methodology contained in the 2024-2050 RTP/SCS. This section will provide analysis showing consistency with both the 2020 and the 2024 SCAG RTP/SCS. Connect SoCal integrates transportation planning with economic development and sustainability planning to comply with State greenhouse gas (GHG) emissions reduction goals, such as Senate Bill 375. The RTP/SCS is updated every four years as required by federal and State regulations.

According to the RTP/SCS (Connect SoCal 2020), by 2045, the population of Southern California is projected to increase by 3.7 million people, with an increase of 1.6 million housing units and 1.6 million jobs.

However, growth is not expected to be uniform across the region’s counties or cities. The RTP/SCS states that during that time, transportation infrastructure will need to substantially expand while also meeting the GHG emissions-reduction targets set by the California Air Resources Board.

SCAG is empowered by State law to assess regional housing needs and provide a specific allocation of housing needs for all economic segments of the community for each of the region’s counties and cities. The determination of each city’s and county’s share of regional housing needs (RHNA as described previously) that is required by law to be reflected in municipal general plan housing elements is based on the growth projections of the RTP/SCS.

SCAG Regional Growth Projections
SCAG is responsible for producing socioeconomic forecasts and developing, refining, and maintaining macro and small-scale forecasting models. The forecasts are developed in five-year increments. The current SCAG projections are provided in the Connect SoCal 2020 through the year 2045. Consistency with the growth forecast, at the sub-regional level, is one criterion that SCAG uses in exercising its federal mandate to review “regionally significant” development projects for conformity with regional plans. 2020 SCAG Connect SoCal projects that the number of local employment opportunities in the City of Redlands will increase from 42,600 in 2016 (Based on SCAG’s most recent data which is from 2016) to 56,300 in 2045. Additionally, SCAG projects the City’s households will increase from 24,400 in 2016 to 30,800 in 2045 (SCAG, 2020).
2024 SCAG Connect SoCal projects that the number of local employment opportunities in the City of Redlands will increase from 49,400 in 2019 (Based on SCAG’s most recent data which is from 2019) to 60,100 in 2050. Additionally, SCAG projects the City’s households will increase from 25,600 in 2019 to 31,200 in 2050 (SCAG, 2024).

5.8.2.2 Regional/Local Regulations
City of Redlands General Plan
Livable Community Element
The Livable Community Element provides for managed, balanced and quality growth in keeping with the city’s scale, services, and environment and include the following policies related to population and housing and the Project:

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Policy 4-P.2 Provide for the expansion of housing and employment opportunities while ensuring that a high quality of life is maintained in Redlands.

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

Policy 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-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.

City of Redlands 2021-2029 General Plan Housing Element The Housing Element include the following policies related to population and housing and the Project:

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

Policy 1.3 Provide housing capacity near public services.

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

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

5.8.3 ENVIRONMENTAL SETTING
The Project site includes approximately 116 acres of land that is divided into two general areas (Sites 1- 16A and 24, and Sites 17-23). The City of Redlands General Plan 2035 designates the Project site with a mix of land uses including: Commercial/Industrial (CI), Commercial (C), Medium Density Residential (MDR), and High Density Residential (HDR). Figure 3-4a and 3-4b, Existing General Plan Land Use, in Section 3.0, Project Description, show the existing General Plan land use designations for the Project site.

Sites 1-16A and 24 consists of non-residential land use designations except for the medium density residential designation for Site 8. Sites 17-23 are also primarily non-residential, with medium and high density residential allowed at sites 20, 21, and 23. There are a number of vacant parcels located within the Project area, including all of Sites 17-23. Figures 3-5a and 3-5b, Existing Zoning, in Section 3.0, Project Description, show the existing zoning designation of the Project site.

Population
The California Department of Finance (DOF) estimates that as of 2024, the City of Redlands has a population of 72,696, representing approximately 3.3 percent of the County’s total population (DOF, 2024). SCAG estimates that the City will have a population increase of 16.2 percent between 2016 and 2045 1, and the County will have population growth rate of 31.5 percent over the same period. Table 5.8-2 provides population figures for the City of Redlands and the County in 2016, and SCAG projections for year 2045 Redlands Regular Meeting of 06-03-25
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and Table 5.8-3 provides population figures for the City of Redlands and the County in 2019, and SCAG projections for year 2050.

Table 5.8-2: SCAG Population Estimates and Projections, 2016–2045 2016 2045 Projection 2016-2045 Change
City of Redlands 69,500 80,800 16.2%
San Bernardino County 2,141,000 2,815,000 31.5%
Source: (SCAG, 2020)
Table 5.8-3: SCAG Population Estimates and Projections, 2019–2050 2019 2050 Projection 2019-2050 Change
City of Redlands 72,800 85,874 18.0%
San Bernardino County 2,175,000 2,623,000 20.6%
Source: (SCAG, 2024)
Housing and Households
The California DOF estimates that there were 28,139 housing units in Redlands in 2024, which is 3.7 percent of the County total. The City’s housing stock is about 64 percent single-family residential and is estimated to be 94.9 percent occupied, as shown in Table 5.8-4. The DOF estimates persons per household to be 2.62.

Table 5.8-4: City of Redlands Existing Housing Stock, 2024 Residence Type Number Percentage
Single-Family Detached 17,975 63.9%
Single-Family Attached 1,282 4.6%
Two to Four Units 3,122 11.1%
Five Plus 4,411 15.7%
Mobile Homes 1,049 3.7%
Total 28,139 100%
Occupied 26,693 94.9%
Vacancy 1,446 5.1%
California Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2024.

According to SCAG’s Connect SoCal 2020-2045 RTP/SCS, the City of Redlands is projected to add approximately 6,400 households by 2045 (Table 5.8-5). This averages approximately 221 new households annually through 2045.

Table 5.8-5: SCAG Household Projections, 2016–2045
2016
Households
2045
Households
2016-2045
Increase
City of Redlands 24,400 30,800 26.2%
San Bernardino County 630,000 875,000 38.9%
Source: (SCAG, 2024)
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According to SCAG’s Connect SoCal 2024-2050 RTP/SCS, the City of Redlands is projected to add approximately 5,600 households by 2050 (Table 5.8-6). This averages approximately 224 new households annually through 2050.

Table 5.8-6: SCAG Household Projections, 2019–2050
2019
Households
2050
Households
2019-2050
Increase
City of Redlands 25,600 31,200 21.9%
San Bernardino County 657,000 953,000 45.1%
Source: (SCAG, 2024)
Employment
According to SCAG’s 2020-2045 RTP/SCS, the number of jobs within the City is projected to increase from 42,600 jobs in 2016 to 56,300 jobs in 2045 (Table 5.8-7). This represents an increase of over 32 percent, and an average of 472 jobs annually through the year 2045.

Table 5.8-7: SCAG Projected Employment Trends, 2016-2045 2016 2045 2016 – 2045 Increase
City of Redlands 42,600 56,300 13,700 (32.2%)
San Bernardino County 791,000 1,064,000 273,000 (34.5%) Source: (SCAG, 2024)
According to SCAG’s 2024-2050 RTP/SCS, the number of jobs within the City is projected to increase from 49,400 jobs in 2019 to 60,100 jobs in 2050 (Table 5.8-8). This represents an increase of over 21 percent, and an average of 345 jobs annually through the year 2050.

Table 5.8-8: SCAG Projected Employment Trends, 2019-2050 2019 2050 2019 – 2050 Increase
City of Redlands 49,400 60,100 10,700 (21.7%)
San Bernardino County 860,000 1,145,000 285,000 (33.1%) Source: (SCAG, 2024)
The SCAG 2019 Local Profile for Redlands identifies that 22.5 percent of Redlands residents work and live in the City, while 77.5 percent commute to other places (Southern California Association of Governments, 2019). Of the commuters residing in Redlands, the largest percentage commute to the City of San Bernardino (15.3 percent), Loma Linda (7.5 percent), Riverside (5.6 percent), and Los Angeles (3.8 percent).

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

Such a reduction in vehicle trips lowers air pollutant emissions (including lower greenhouse gas emissions) and Redlands Regular Meeting of 06-03-25
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causes less congestion on area roadways and intersections. A major focus of SCAG’s regional planning efforts has been to improve this balance. SCAG defines the jobs-housing balance as follows:

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

There is no ideal ratio adopted in State, regional, or City policies. However, the American Planning Association recommends a target ratio of 1.5 jobs per housing unit; communities with more than 1.5 jobs per dwelling unit are considered “jobs rich,” meaning that more employment opportunities are provided that housing in the area, and those with fewer than 1.5 are “housing rich,” meaning that more housing is provided than employment opportunities in the area (Weitz, 2003). A job-housing imbalance can indicate potential air quality and traffic problems associated with commuting. Table 5.8-9 provides the projected jobs-to- housing ratios for the City, based on SCAG’s 2020-2045 RTP/SCS.

As described above and shown in Table 5.8-6, the City had approximately 24,400 households and approximately 42,600 jobs in 2016, which results in a jobs-to-housing ratio of 1.75 jobs per household (SCAG, 2020). SCAG projects a jobs-to-housing ratio of 1.83 in 2045, which indicates that employees would be commuting into the City for employment, and that additional housing would improve the jobs to housing balance within the City. The City is projected to have a higher percentage of jobs to households in comparison to the County, which is projected to have a jobs to housing ratio of 1.22 in 2045. That indicates that since the City of Redlands is a jobs rich community, it is possible that people employed in the City are commuting from elsewhere. Table 5.8-6 provides the existing and projected jobs-to-housing ratios for the City and the County from 2016 and 2045.

Table 5.8-9: Existing and Projected Jobs - Housing Balance in the City and County (2016-2045) Year Employment Households Jobs-Housing
Ratio
City of Redlands 2016 42,600 24,400 1.75
2045 56,300 30,800 1.83
San Bernardino County 2016 791,000 630,000 1.26
2045 1,064,000 875,000 1.22
Source: (SCAG, 2024)
As described above and shown in Table 5.8-10, the City had approximately 25,600 households and approximately 49,400 jobs in 2019, which results in a jobs-to-housing ratio of 1.93 jobs per household (SCAG, 2024). SCAG projects a jobs-to-housing ratio of 1.93 in 2050, which indicates that employees would be commuting into the City for employment, and that additional housing would improve the jobs to housing balance within the City. The City is projected to have a higher percentage of jobs to households in comparison to the County, which is projected to have a jobs to housing ratio of 1.20 in 2050. That indicates that since the City of Redlands is a jobs rich community, it is possible that people employed in the City are commuting from elsewhere. Table 5.8-10 provides the existing and projected jobs-to-housing ratios for the City and the County from 2019 and 2050.

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Table 5.8-10: Existing and Projected Jobs - Housing Balance in the City and County (2019-2045) Year Employment Households Jobs-Housing
Ratio
City of Redlands 2019 49,400 25,600 1.93
2050 60,100 31,200 1.93
San Bernardino County 2019 860,000 657,000 1.31
2050 1,145,000 953,000 1.20
Source: (SCAG, 2024)
Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. This would result in the generation of 2,263 jobs and 294 residents according to the General Plan EIR growth induction rate shown on Table 2.3-6 (City of Redlands, 2008).

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

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

The Initial Study established that the proposed Project would not result in impacts related to Threshold POP- 2; thus, no further assessment of this impact is required in this SEIR.

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

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

The methodology used to determine population, housing, and employment impacts includes data collection of population and housing trends, which was obtained from DOF, the General Plan, and SCAG. The determination of impacts is based on an analysis of the number of residents and employees anticipated at buildout of the proposed Project. The scale of population at buildout is then compared with General Plan buildout and growth forecasts for the Project area. Growth is considered in the context of local and regional plans that include population projections for the City and the County. The SCAG population projections are used to prepare the Connect SoCal 2024 RTP/SCS. If projected growth within the Project area from Redlands Regular Meeting of 06-03-25
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implementation of the Project would exceed SCAG growth projections, RHNA housing requirements, and/or the City’s General Plan, a significant impact may result.

5.8.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
The General Plan EIR addressed impacts related to population and housing in Chapter 3.10. The 20-year buildout projected in the proposed General Plan assumes the majority of development would occur on infill sites within urbanized areas of the city. As infill sites are scattered throughout the city and are generally already served by public services and facilities, there should not be a significant increase in population and business in one particular part of the city. The General Plan EIR determined that redevelopment of existing uses would likely occur; however, such development would take place over time as the market allows and would result in a net increase in residential units. Though it is impossible to guarantee residents would not be displaced as a result of implementation of the General Plan, proposed General Plan policies seek to preserve existing neighborhoods, thus impacts were found to be less than significant (City of Redlands, 2017a, pg. 3.10-11).

Proposed Project
As detailed in Section 3.0, Project Description , the proposed Project would rezone 24 sites to allow for the development of a total of 2,436 residential dwelling units and approximately 151,048.46 square feet (SF) of public/institutional development. Buildout pursuant to the proposed Project would result in an increase in 2,325 residential units and a decrease of 2,057,992.20 SF of nonresidential development compared to the buildout of the existing General Plan. The timing of development and operation of the development pursuant to the proposed Project would be dependent upon market conditions and development applications for new projects.

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

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

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

Less Than Significant Impact. The proposed Project provides for infill development, redevelopment, and development of a number of vacant parcels located within the Project area under a different urban zoning designation. The maximum development that would occur from buildout of the proposed Project is 2,436 residential units and 151,048.46 SF of public/institutional development. Buildout pursuant to the proposed Project would result in an increase in 2,325 residential units and a decrease of 2,057,992.20 SF of nonresidential development compared to buildout of the existing General Plan.

Using the Redlands General Plan EIR growth induction rate of 2.65 people per household, buildout of the proposed residential units would generate up to 6,456 residents. Employee generation for the proposed Project was calculated using Table 2.3-6, Projected Non-Residential Buildout (2035) , from the Redlands General Plan using the projected Public/Institutional square feet of development and projected jobs creation, which results in a generation of 550 jobs.

Table 5.8-11 lays out the growth of buildout of the approved General Plan compared to growth induced from the proposed Project. As shown, compared to the existing General Plan buildout, the proposed Project would result in a reduction of 1,713 employees and an increase of 6,162 residents.

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Table 5.8-11: General Plan and Proposed Project Population Growth Approved General Plan Proposed Project
Difference (Proposed
Project – approved
General Plan)
Employees 2,263 550 -1,713
Residents 294 6,456 6,162
As shown previously in Table 5.8-2, SCAG Population Estimates and Projections, 2016–45 , population in the City of Redlands is expected to increase by 11,300 persons between 2016 and 2045. As shown previously in Table 5.8-5, SCAG Household Projections, 2020–2045 , housing stock in the City is expected to increase by 6,400 dwelling units between 2016 and 2045. Based on these growth projections, full buildout of the Project would represent approximately 54.5 percent of the projected population growth and 36.3 percent of the projected housing stock growth in the City if built out and at full capacity in 2045. In addition, according to the population estimates and projections provided in the 2024-2050 SCAG RTP/SCS which has not yet been approved by CARB, the proposed Project would result in approximately 47.1% of the anticipated population growth and approximately 41.5% of the project housing stock growth in the City by 2050 (SCAG, 2024). Thus, while the Project would result in an increase in population and housing units in an area not previously planned for housing, the increase in population and number of housing units that would result from the proposed Project would not exceed projections for the City through the Project and General Plan buildout year of 2035.

Further, as reflected in Table 5.8-1, City of Redlands SCAG Regional Housing Needs Allocation, 2021-2029 , SCAG determined the City needs to provide a total of 3,516 housing units by 2029 to meet their RHNA.

The City’s 2021–2029 Housing Element identifies several adequate sites that are able to accommodate the development of additional housing units for the City to meet its estimated housing growth needs identified in the SCAG’s RHNA allocation (Redlands, 2022). Of the Housing Element inventory sites, 23 of them were identified as necessary for rezoning under Housing Element Program 1.1-1 to allow for high and medium density residential development. Thus, while the proposed Project would result in an increase of population, the Project would in part satisfy the State requirements to provide new housing opportunities to increase housing supply. Additionally, the proposed Project supports goals and policies of the Housing Element (see page 5.8-3) aimed to support a variety of housing types and densities. Thus, the proposed Project would not induce substantial unplanned population growth in the area.

Employment Growth: As described in Section 3.0, Project Description , the Project anticipates a future nonresidential capacity buildout of 151,048.46 SF within the portion of the Project site that allows non- residential development. However, buildout of the proposed Project would result in the loss of 2,057,992.20 SF of nonresidential development and a reduction of 1,713 employees in the area. Since the Project would result in a net loss of future employment opportunities, the Project would not result in any unplanned employment growth.

Jobs-Housing Balance. Effects of the proposed Project on jobs-housing balance are evaluated by adding project-generated jobs and housing units to forecasts of employment and housing. As described previously, the City of Redlands is jobs rich, with an existing jobs-housing ratio of 1.75. The proposed Project would reduce (improve) the jobs-housing ratio slightly by adding 2,325 residential units and reducing the employment square footage of the Project area at buildout. The proposed Project would provide a beneficial effect of providing the opportunity for housing in a jobs-rich area, where employees can easily travel to nearby employment opportunities.

In addition, because the area is jobs-rich, the addition of residential units in the area would not require additional jobs that could result in growth. Conversely, the new residents would fill the need for employees that are anticipated by SCAG projections. Thus, the additional residential units would not indirectly result in Redlands Regular Meeting of 06-03-25
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the need for additional employment opportunities, which could result in growth. Therefore, this indirect impact related to growth would be less than significant.

Construction. A specific development project is not proposed as part of this Project; however, construction of future residential uses from buildout of the proposed RHNA zoning would result in a temporary increased demand for construction workers. Construction workers are anticipated to come from the City and surrounding jurisdictions and commute daily to the jobsite. Although it is possible that the demand for workers could induce some people to move to the region, this consideration would be de minimis, relative to the total number of construction workers in the region. According to the U.S. Census Bureau, 1,322 individuals are employed in the construction industry in the City of Redlands and 80,351 individuals are employed in the construction industry in San Berardino County as a whole (United States Census Bureau, 2024). In addition, buildout of the proposed Project would not occur all at one time; developments would occur one project at a time in response to market conditions and would not result in a constraint on the construction workforce. Therefore, implementation of the Project would not induce substantial unplanned population growth directly or indirectly through construction employment that could cause substantial adverse physical changes in the environment.

Impacts would be less than significant.

Infrastructure. Future buildout of the proposed zoning may require expansion of infrastructure to serve the proposed uses, including installation of new storm drains, wastewater, water (potable and reclaimed), and dry utilities that would connect to existing facilities. However, as outlined in Section 3.0, Project Description, specific infrastructure improvements required to support residential development within the proposed rezone sites are not known at this time and would not be known until development projects are proposed. Future development associated with allowed uses in accordance with the proposed zoning would be required to undergo project-level environmental review under CEQA on a case-by-case basis. As such, future development projects would be required to analyze project-specific needs related to infrastructure improvements. Overall, the Project does not provide for infrastructure improvements that could lead to substantial unplanned growth.

As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to population and housing would be less than significant.

5.8.7 CUMULATIVE IMPACTS
Impacts from cumulative population growth are considered in the context of their consistency with local and regional planning efforts. As detailed previously, buildout of the proposed zoning would represent approximately 47.1 percent of projected employment growth and 41.5 percent of projected housing growth in the City through 2050, and is consistent with SCAG RHNA allocation needs and the City’s Housing Element.

Thus, the Project is within the regional and local growth projections, and would not result in an exceedance that could become cumulatively considerable. Therefore, impacts related to cumulative growth would be less than significant and not cumulatively considerable.

5.8.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
California Government Code Sections 65300, 65580–65589
Plans, Programs, or Policies
None.

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

5.8.10 MITIGATION MEASURES
No mitigation measures are required.

5.8.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts related to population and housing would be less than significant.

5.8.12 REFERENCES
California Department of Finance (DOF). (2024). E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2024 with 2020 Benchmark.
https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates- for-cities-counties-and-the-state-2020-2024/
City of Redlands. (2022). 2021-2029 Housing Element. https://www.cityofredlands.org/post/2021-2029- housing-element
City of Redlands. (July 2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2024). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 City of Redlands. (July 2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Retrieved July 2, 2024, from https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 SCAG. (2024) Connect SoCal 2024 Demographics and Growth Forecast Technical Report. https://scag.ca.gov/sites/main/files/file-attachments/23-2987-tr-demographics-growth-forecast- final-040424.pdf?1712261839
SCAG. (2019). Profile of the City of Redlands . https://scag.ca.gov/sites/main/files/file- attachments/redlands_localprofile.pdf?1606014831
United States Census Bureau. (2024). Industry by Sex for the Full-Time, Year-Round Civilian Employed Population 16 Years and Over. American Community Survey, ACS 1-Year Estimates Subject Tables, Table S2404.
https://data.census.gov/table?q=San%20bernardino%20County,%20California&t=Industry&g= 160XX00US0680854
Weitz, J. (2003). American Planning Association. Planning Advisory Service Report Number 516: Jobs- Housing Balance.

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5.9 Public Services

5.9.1 INTRODUCTION
This section of the Draft Subsequent EIR addresses impacts of the Project to public services, including fire protection and emergency services, police protection, and school services. This section addresses whether there would be physical environmental effects of new or expanded public facilities that would necessary to maintain acceptable service levels as a result of the proposed Project. An increase in staffing associated with public services or an increase in calls for services would not, by itself, be considered a physical change in the environment. However, physical changes in the environment resulting from the construction of new facilities or an expansion of existing facilities to accommodate the increased staff or equipment needs resulting from the Project could constitute a significant impact. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035 , December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), July 2017; and
• City of Redlands Municipal Code.

The Initial Study, included in Appendix A, established that the proposed Project would not result in impacts related to parks or other public services; thus, only fire protection, police protection, and school services are evaluated in this section.

5.9.2 REGULATORY SETTING

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

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

California Fire Code
California Code of Regulations (CCR) Title 24, Part 9 (2016 California Fire Code) contains regulations relating to construction and maintenance of buildings, the use of premises, and the management of wildland- urban interface areas, among other issues. The California Fire Code is updated every three years by the California Building Standards Commission and was last updated in 2022 (effective January 1, 2023)..

The Fire Code sets forth regulations regarding building standards, fire protection and notification systems, fire protection devices such as fire extinguishers and smoke alarms, high-rise building standards, and fire suppression training. It contains regulations relating to construction, maintenance, and use of buildings. Topics addressed in the code also include fire department access, fire hydrants, automatic sprinkler systems, fire alarm systems, fire and explosion hazards safety, hazardous materials storage and use, provisions intended Redlands Regular Meeting of 06-03-25
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to protect and assist fire responders, industrial processes, and many other general and specialized fire- safety requirements for new and existing buildings and the surrounding premises. Development under the Project would be subject to applicable regulations of the California Fire Code.

California Government Code (Section 65995(b)) and Education Code (Section 17620) California Senate Bill 50 (SB 50), which passed in 1998, amended California Government Code Sections 65995.5 through 65998, which contains limitations on Education Code Section 17620. The statute authorizes school districts to assess development fees within school district boundaries. Government Code Section 65995(b)(3) requires the maximum square footage assessment for development to be increased every two years, according to inflation adjustments.

According to California Government Code Section 65995(3)(h), the payment of statutory fees is “deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental organization or reorganization...on the provision of adequate school facilities.” The school district is responsible for implementing the specific methods for mitigating school impacts under the Government Code.

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

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

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

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

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

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

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

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

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

Action 7-A.89 Require adherence to applicable buildings codes and standards in accordance with Fire Hazard Overlay Districts, California Fire Code, and the California Building Code.

Action 7-A.96 Require that new development minimizes risks to life and property from fire hazard through:
• Assessing site-specific characteristics such as topography, slope, vegetation type, wind patterns etc.;
• Siting and designing development to avoid hazardous locations; • Incorporating fuel modification and brush clearance techniques in accordance with applicable fire safety requirements and carried out in a manner which reduces impacts to environmentally sensitive habitat to the maximum feasible extent; • Using appropriate building materials and design features to ensure the minimum amount of required fuel modification; and
• Using fire-retardant, native plant species in landscaping.

Action 7-A.95 Coordinate with the Redlands Fire Department and other fire prevention agencies to review all applications for new development. The Fire Department’s review should ensure compliance with fire safety regulations and assess potential impacts to existing fire protection services and the need for additional and expanded services.

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

City of Redlands Public Facilities Fees
The Project is required to comply with the provisions of the City of Redlands Public Facility Fee (Municipal Code Chapter 3.60) which requires a fee payment for any developments requiring permitting that the City applies to the funding of such civic center, corporate yard, fire and police required public facilities and related improvements.

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

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

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

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

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

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

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

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

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

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

5.9.3 ENVIRONMENTAL SETTING

5.9.3.1 Redlands Fire Department
The Redlands Fire Department (RFD) provides services including fire prevention and suppression, emergency medical services, technical rescue, and hazardous materials response to the city of Redlands including the Project area.

According to the Redlands General Plan EIR, the RFD recognizes two response time standards. The first is from the National Fire Protection Association (NFPA), which recommends that the first unit arrive within four minutes 90 percent of the time. The second is a more lenient goal of arriving within seven minutes 90 percent of the time, as recommended by the 2008 High-Level Fire Department Review for the RFD. According to the City of Redlands, the current 90 percent response time is eight and a half minutes, which is over twice the NFPA standard and one and a half minutes slower than the more lenient guideline. In 2023, the RFD received 14,757 calls for service and had 71,776 residents, which results in 0.21 calls per resident (California Department of Finance, 2024a).

The Project area would be served by four fire stations as shown in Table 5.9-1 below, and on Figure 5.9-1.

The City currently has plans to relocate Station 264 based on the annual increase in calls for service and location of service needed. RFD is also in the beginning stages of a planned capital improvement project that would include the construction of two new fire stations within the City. The specifications and locations of those stations are not known at this time (Appendix I).

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Table 5.9-1: Fire Station Serving the Project Sites
Fire Station Location Equipment Staffing
Station 261 525 East Citrus Avenue Engine 261
Truck 261
Battalion Chief
Incident Su pport Unit
(1) Battalion Chief
(2) Fire Captains
(3) Engineers
(4) Firefighter-Medics
Station 262 1690 Garden Street Engine 262 (1) Fire Captain (1) Engineer
(1) Firefighter-Medic
Station 263 10 West Pennsylvania
Avenue
Engine 263 (1) Fire Captain
(1) Engineer
(1) Firefighter-Medics
Station 264 1270 West Park Avenue Engine 264
Medic Squad 264
(1) Fire Captain
(1) Engineer
(3) Firefighter-Medics
Source: (Appendix I)

5.9.3.2 Redlands Police Department
Public safety services in the City, including for the Project sites, are provided by the Redlands Police Department (RPD). The RPD’s main police station is located at 1270 West Park Avenue within the boundaries of the New York Street/Esri Transit Village. The RPD personnel is made up of approximately 46 sworn officers and 5 part-time civilians, resulting in a service level of 0.54 officers per 1,000 residents (Appendix I).

Based on existing staffing levels, RPD estimates response times to Sites 1 through 16A and Site 24 are 13 minutes and 47 seconds for Priority 1 police service calls and 9 minutes and 44 seconds for Priority 2 police service calls. The RPD estimates a response time of 11 minutes and 22 seconds for Priority 1 police service calls and 14 minutes and 21 seconds for Priority 2 police service calls for Sites 17 through 23. Although there are no industry standards for response time to emergency calls, according to the RPD, a response time below the national response time average of 8 to 12 minutes for Priority 1 calls is desirable (Appendix I).

The location and staffing descriptions of the RPD stations within the City are listed below in Table 5.9-2 and shown in Figure 5.9-1.

Table 5.9-2: Police Stations
Location Staffing Description
1270 W. Park Avenue Patrol, Custody, Dispatch Records
30 Cajon Street Administration, Investigations, MET, Traffic/Special Events, Crime Analysis, Community Policing, Property/Evidence
1150 Brookside Avenue Records Processing
Source: (Appendix I)

5.9.3.3 School Services
The City, including the Project site, is within the Redlands Unified School District (RUSD). The RUSD has 16 elementary school (grades K-5), four middle schools (grades 6-8), three comprehensive high schools (grades 9-12), an alternative high school, an independent study program, a home education leaning program, and a K-12 online academy (City of Redlands, 2017b, pg. 5.13-9). Current enrollment is approximately 19,773 students with an excess capacity of 1,676 students (RUSD, n.d., a).

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Table 5.9-3: RUSD School Serving the Project site
School Type (Grades) School Name Location (in Redlands) Elementary School 1
(K-5)
Lugonia 202 E. Pennsylvania Ave.

Kingsbury 600 Cajon St.

Mission 10568 California St
Smiley 1210 W. Cypress Ave.

Middle School (6-8) 2 Clement 501 E. Pennsylvania Ave.

Cope 1000 W. Cypress Ave.

High School (9-12) 3 Redlands 840 E. Citrus Ave.

Citrus Valley 800 W. Pioneer Ave.
1(RUSD, n.d., b)
2(RUSD, n.d., c)
3(RUSD, n.d., d)
Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. As discussed in Section 5.8, Population and Housing , this would result in the generation of 2,263 employees and 294 new residences in the City. Similar to the proposed Project, implementing projects of the General Plan would be required to pay Development Impacts Fees which would go towards the maintenance and expansion of service facilities such as police and fire stations to ensure that acceptable levels of service are met.

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Figure5.9-1
City of RedlandsEmergency ServicesStations
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5.9.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the State CEQA Guidelines indicates that a project could have a significant effect if it were to result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

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

5.9.5 METHODOLOGY
The evaluation of impacts to public services is based on whether the existing public services can meet the demands of the Project based on established thresholds, including maintaining acceptable service ratios, staffing levels, adequate equipment, response times, or other performance objectives that may result in the need for new or expanded services and facilities.

5.9.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
The General Plan EIR addressed impacts related to public services in Chapter 3.13. The Certified EIR found that implementation of the proposed Project could result in a population increase of up to 16,355 new residents. The General Plan policies that seek to address park, recreation, and safety needs as development occurs, in combination with the City’s development impact fees, would serve to ensure the maintenance of existing facilities and the timely provision of new facilities in order to prevent the deterioration of existing and new facilities. Thus, impacts related to public services were determined to be less than significant upon implementation of the General Plan (Redlands, 2017b, pg. 3.13-18).

IMPACT PS-1: THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS

ASSOCIATED WITH THE CONSTRUCTION OR EXPANSION OF FIRE PROTECTION FACILITIES.

Less than Significant Impact. Buildout pursuant to the proposed Project would result in an increase in 2,325 residential units and a decrease of 2,057,992.20 square feet (SF) of nonresidential development. While there would be an increase in 6,162 residents compared to the existing General Plan Buildout, which may increase the demand for fire protection and emergency medical services, the Project would also result in a large decrease in non-residential development which would lead to a decrease in demand for fire and emergency services for those uses. Thus, the proposed Project is not expected to result in a large increase in demand for fire and emergency services compared to the buildout of the approved General Plan.

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waterless fire suppression systems pursuant to the California Fire Code, adopted as Chapter 15.20 of the Redlands Municipal Code, the CBC, and other existing regulations regarding fire safety. Site access would be reviewed by City planning and the RFD to ensure that the proposed improvements would have adequate access for large fire trucks and vehicles. The nearest fire station to Sites 1 through 16A and Site 24 would be Station 264, which is located approximately 0.60 miles east of the Rezone sites. The nearest station to Sites 17 through 23 would be Station 263, which is located approximately 0.58 miles east of the sites. Future development within the Project sites would be required to meet fire and life safety standards, including smoke and carbon monoxide detectors, fire alarms, and residential fire sprinklers, among other building requirements. Development plans would be reviewed by the City planning and fire department to ensure that State and local codes and requirements are implemented.

The General Plan EIR described that the RFD has stated the needs for expansion in order to accommodate continued increase in population. The RFD is currently considering relocating Station 264 to the east side of Alabama Street just south of Orange Avenue. This new station would be approximately 0.25 miles south of Site 1 through 16A and 24 and would serve those sites. The Fire Department is also considering the expansion of Station 263 to provide expanded services to the northern portion of the City. Development Impact Fees, included as PPP PS-1 in Section 5.9.8 below, would serve to ensure the maintenance of existing facilities and the timely provision of new facilities as needed. Each implementing project would be required to pay these fees which are proportional to the increased needs for service. Thus, while implementation of the proposed Project would result in increased needs for fire services, the payment of Development Impact Fees would ensure that RFD has adequate facilities to serve the City as the City continues to expand. As stated above, the City is also in the initial stage of a long range capital improvement project that includes the construction of new and expansion of existing fire stations. The specifics about the stations, including the locations, are not known at this time. As discussed above, the City’s current response times do not meet the City’s requirements, thus the payment of fees would assist RFD in the future expansions and purchasing of additional equipment to improve response times. The fees collected by each implementing project would ensure that fire protection service levels are maintained and can be applied to the purchase of equipment, maintenance of existing facilities, and the construction of additional facilities, if needed in the future.

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

Therefore, with the payment of development fees included as PPP PS-1, Project impacts to fire services would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to public services would be less than significant.

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

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

Less than Significant Impact. The service ratio for the City of Redlands is 0.54 officers per 1,000 residents.

According to the RPD, the City would need to hire approximately 10 new officers to maintain the service ratio in the City to accommodate the proposed Project (A. Colerick, Redlands Police Department, email, April 18, 2024). The increased residential population from the buildout of the proposed Project could increase the frequency of emergency and non-emergency calls to the RPD, as compared to existing conditions.

However, implementation of the proposed Project would result in a decrease of approximately 2,057,992.20 SF of nonresidential development and would thus result in a decrease in calls related to those types of uses. Thus, compared to the buildout of the existing General Plan which includes significantly more non-residential development, buildout of the proposed Project’s residential uses is not expected to generate an increase in the frequency of emergency and non-emergency calls to the RPD. Buildout of the proposed Redlands Regular Meeting of 06-03-25
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Project is not expected to increase demand for police protection to the extent that new facilities would be required beyond what has already been planned for. Currently, the RPD is in the development of an additional police station to meet future demand. Any potential improvements would be subject to City policies that are designed to protect environmental resources as well as environmental review under CEQA, separate from this Project. Payment of development impact fees included as PPP PS-1 would serve to ensure the maintenance of existing facilities. In addition, property tax revenue generated by development of the Project would provide funding for police services and would help to offset the Project’s increase in the demand for services. Therefore, impacts to police protection facilities would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to public services would be less than significant.

IMPACT PS-3 THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS

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

Less than Significant Impact. As discussed in Section 5.8, Population and Housing, full buildout of the Project site would result in the generation of up to 6,162 additional residents compared to buildout of the approved General Plan. According to the Department of Finance, San Bernardino’s school aged (5-17 years old) population would be 14.7% by 2035 (Department of Finance, 2024b). Thus, the proposed Project is expected to generate 906 school aged children by full buildout in 2035. As discussed above, the Project site is located within the RUSD and is served by four elementary schools, two middle schools, and two high schools. According to the RUSD, the school district currently has an enrollment of 19,773 students with an excess capacity of 1,676 students (RUSD, n.d., a).

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

Pursuant to California Government Code Section 65995.5-7, the RUSD has instituted school facility fees that would apply to future developments pursuant to the future developments pursuant to the Project, specifically fees for new residential construction based on square footage. Accordingly, future project applicants would be required to pay school fees to the RUSD to offset the impact of additional student enrollment at schools serving the individual development project site.

Pursuant to State law, payment of the school fees established by the RUSD in accordance with existing rules and regulations regarding the calculation and payment of such fees, would, by law, mitigate the proposed Project’s impacts on schools’ facilities. Therefore, impacts to school facilities would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to public services would be less than significant.

5.9.7 CUMULATIVE IMPACTS
The Project would not significantly increase the need for public services in Redlands, cities surrounding Redlands, or the region. As discussed above, the Project applicant would pay the required City development Redlands Regular Meeting of 06-03-25
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impact fees included as PPP PS-1. Additionally, as discussed above, the Project is not anticipated to impact acceptable service ratios, staffing levels, adequate equipment, response times, or other performance objectives to the extent that new or expanded government services and facilities would be needed. Related projects in the region would be required to demonstrate their level of impact on public services and also pay their proportionate development fees. Therefore, the proposed Project would not contribute to a cumulative impact related to the provision of public services.

5.9.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
None.

Plans, Programs, or Policies
PPP PS-1: Development Impact Fees. As a standard requirement for implementing projects within the Project site, and prior to issuance of any building permits for the implementing project, the Project applicants/developers shall pay all applicable City of Redlands Development Impact Fees (DIF) pursuant to the Redlands Municipal Code Chapter 3.60 and/or adopted fee schedules.

5.9.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impacts PS-1, PS-2, and PS-3 would be less than significant.

5.9.10 MITIGATION MEASURES
No mitigation measures are required.

5.9.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Compliance with regulatory programs would reduce potential impacts related to public services to less than significant.

5.9.12 REFERENCES
California Department of Finance (DOF). (2024a). E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2024 with 2020 Benchmark. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates- for-cities-counties-and-the-state-2020-2024/
California Department of Finance (DOF). (2024b).P-2B County Population by Age. Retrieved July10, 2024 from https://dof.ca.gov/Forecasting/Demographics/Projections/ California Legislative Information. (n.d.). Chapter 5. Fees for development Projects. Retrieved July 5, 2024, from
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=GOV&division=1.&tit le=7.&part=&chapter=5.&article
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City of Redlands. (July 2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2024). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 City of Redlands. (July 2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Retrieved July 2, 2024, from https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 City of Redlands. (n.d.). Fire Station Locations . Retrieved July 1, 2024, from https://www.cityofredlands.org/pod/fire-station-locations-0 Citygate Associates, LLC. (2020) Fire Department Assessment and Deployment Study. Retrieved July 1, 2024, from https://destinyhosted.com/redladocs/2020/CC/20200901_218/2879_Vol_1_- _Final_Redlands_FD_Assessment_and_Deployment_Study_Technical_Report_%2806-25- 20%29.pdf
Redlands Unified School District (RUSD). (n.d., a). Our District. Retrieved August 12, 2024, from https://www.redlandsusd.net/our-
district#:~:text=Current%20enrollment%20in%20grades%20K,7.8%25%20Asian Redlands Unified School District (RUSD) (n.d., b). Elementary School Attendance Areas Trasnition Class - 5th Grade. [Map].
https://resources.finalsite.net/images/v1684313866/redlandsusdnet/e5gkfgyw7r97kscd2agn/e lementary_boundaries_2022.pdf
RUSD. (n.d., c). Middle School Attendance Areas Grades 6 - 8. [Map]. https://resources.finalsite.net/images/v1684313868/redlandsusdnet/ufbh5teewfqadjtaxjyn/mid dle-2013-2014.pdf
RUSD. (n.d., d). High School Attendance Areas Grades 9 - 12. [Map]. https://resources.finalsite.net/images/v1684313871/redlandsusdnet/f8vjctebv4gqopdlnkhh/hig h-2013-2014.pdf
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5.10 Transportation

5.10.1 INTRODUCTION
This section addresses potential transportation impacts that may result from implementation of the Redlands RHNA Rezone Project. The following discussion addresses the existing transportation conditions in the Project area, identifies applicable regulations, evaluates the proposed Project’s consistency with applicable goals and policies, identifies and analyzes environmental impacts, and recommends measures to reduce or avoid adverse impacts anticipated from implementation of the proposed Project. The analysis in this section is based on the following resources:
• City of Redlands General Plan 2035 , December 2017;
• City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report, July 2017; • City of Redlands Municipal Code;
• City of Redlands CEQA Assessment VMT Analysis Guidelines; and • Redlands RHNA Rezone Project VMT Analysis , EPD Solutions, July 2024. Included as Appendix F.

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

5.10.2 REGULATORY SETTING

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

SB 743 requires the California Governor’s Office of Planning and Research to amend the State CEQA Guidelines to provide an alternative to level of service (LOS) as the metric for evaluating transportation impacts under CEQA. Particularly within areas served by transit, SB 743 requires the alternative criteria to promote the reduction of GHG emissions, development of multimodal transportation networks, and diversity Redlands Regular Meeting of 06-03-25
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of land uses. The alternative metric for transportation impacts detailed in the State CEQA Guidelines is VMT.

Jurisdictions had until July 1, 2020, to adopt and begin implementing VMT thresholds for traffic analysis.

AB 1358: California Complete Streets Act
The California Complete Streets Act was implemented on January 1, 2011, which required circulation elements to address the transportation system from a multimodal perspective. The bill states that streets, roads, and highways must “meet the needs of all users…in a manner suitable to the rural, suburban, or urban context of the general plan.” This bill requires a circulation element to plan for all modes of transportation where appropriate—including walking, biking, car travel, and transit. The Complete Streets Act also requires circulation elements to consider the multiple users of the transportation system, including children, adults, seniors, and people with disabilities.

5.10.2.2 Regional Regulations
Regional Transportation Plan/Sustainable Communities Strategy The Southern California Association of Governments (SCAG) is the designated metropolitan planning organization for six Southern California counties (Ventura, Los Angeles, San Bernardino, Riverside, Orange, and Imperial). As the designated metropolitan planning organization, SCAG is mandated by the federal and State governments to prepare plans for regional transportation and air quality conformity. The most recent plan adopted by SCAG is the 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also known as Connect SoCal, which was adopted in April 2024. The California Air Resources Board (CARB) has yet to approve of the technical methodology contained in the 2024-2050 RTP/SCS. The RTP/SCS integrates transportation planning with economic development and sustainability planning and aims to comply with State GHG emissions reduction goals, such as SB 375. With respect to transportation infrastructure, SCAG anticipates, in the RTP/SCS, that the six-county region will have to accommodate 20,909,000 residents by 2050 while also meeting the GHG emissions reduction targets set by the California Air Resources Board (CARB). SCAG is empowered by State law to assess regional housing needs and provide a specific allocation of housing needs for all economic segments of the community for each of the region’s counties and cities. In addition, SCAG has taken on the role of planning for regional growth management.

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

Principle 5-P.1 Maintain a cohesive circulation system through a “layered network” approach promoting complete streets and mobility for all modes while emphasizing specific transportation modes for specific corridors and geographic areas.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5.10.3 ENVIRONMENTAL SETTING
Table 5.10-1, Existing Major Roadway Characteristics Within the Project Area, lists the roadway characteristics that are observed within the Project area.

Table 5.10-1: Existing Major Roadway Characteristics Within the Project Area Roadway Classification Number of Lanes Bike Lane
Citrus Avenue
(E/W) Collector
2-lane divided with painted median
east of Alabama Street; 2-lane
undivided west of Alabama Street
Existing Class I west of
Alabama Street
Nevada Street
(N/S) Minor Arterial
2-lane divided with painted median
south of Orange Avenue; 2-lane
undivided between Orange Avenue
and Citrus Avenue; 2-Lane divided
with painted median north of Citrus
Avenue
None existing; proposed
General Plan bicycle route
Orange Avenue
(E/W) Collector
2-lane divided with painted median
east of Nevada Street; 2-lane
undivided west of Nevada Street
None existing; proposed
General Plan bicycle route
Iowa Street
(N/S) Collector
3-lane divided with painted median
south of Orange Avenue; 2-lane
undivided north of Orange Avenue
None
Alabama Street
(N/S) Major Arterial 4-lane divided with painted median Existing Class II Orange Street
(N/S)
Minor Arterial north
of West Sun Avenue
and south of I-10;
Boulevard south of
West Sun Avenue to
I-10
4-lane divided with painted median
directly south of San Bernardino
Road; 2-lane divided with painted
median between San Bernardino
Avenue and Colton Avenue; and 4-
lane divided with painted median
south of West Colton Avenue
None existing; proposed
General Plan bicycle route
Texas Street
(N/S) Minor Arterial
2-lane divided with painted median
between I-10 and San Bernardino
Avenue; 3-lane divided with painted
median north of San Bernardino
Avenue
None existing; proposed
General Plan bicycle route
New York Street
(N/S) Collector 2-lane divided with painted median None existing; proposed General Plan bicycle route
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Roadway Classification Number of Lanes Bike Lane
Pennsylvania
Avenue (E/W) Collector 2-lane divided with painted median Existing Class III between
North University Street and
Judson Street
Lugonia Avenue
(E/W)
Major Arterial
(between I-210 and
Orange Street);
Minor Arterial east of
Orange Street
3-lane divided with painted median
west of Texas Street; 4-Lane divided
with painted median between Texas
Street and Clay Street; 3-lane
divided with painted median
between Clay Street and Orange
Street; 3-lane divided with raised
median east of Orange Street
None existing; proposed
General Plan bicycle route
San Bernardino
Avenue
(E/W)
Major Arterial
(between I-210 and
Orange Street);
Minor Arterial east of
Orange Street
2-lane divided with painted median
west of Clay Street; 3-lane divided
with painted median between Clay
Street and Orange Street; 2-lane
divided with painted median east of
Orange Street
Existing Class II east of
Texas Street
Existing Transit Service
The Project area is served by bus service via Omnitrans, which serves the San Bernardino Valley. Omnitrans Route 8 connects the cities of San Bernardino and Yucaipa through the cities of Loma Linda, Redlands (including the Project area), and Mentone, with buses running every 60 minutes Monday through Sunday, and has stops along Redlands Boulevard and Lugonia Avenue. Omnitrans Route 15 connects the cities of Fontana and Redlands (including the Project area) through the cities of San Bernardino and Rialto, with buses running every 60 minutes Monday through Sunday, and has stops along Orange Street, Redlands Boulevard, and Eureka Street. Omnitrans Route 19 provides service between Fontana, the San Bernardino Transit Center, and Yucaipa. Route 19 has stops at the Redlands Mall and has buses running every 60 minutes, Monday through Sunday.

Additionally, the San Bernardino County Transportation Authority’s (SBCTA) Arrow line connects the City of Redlands to the City of San Bernardino and provides further direct rail trips once a day to the City of Los Angeles. During morning and afternoon peak commute hours, trains operate every 30 minutes. During non- commute or off-peak hours, trains operate every 60 minutes. Services start at 5 a.m. and run until 10 p.m.

In addition to standard passenger rail service, the Metrolink Express train serves the Redlands – Downtown Station with limited stop service from Los Angeles during peak commute hours.

Existing Bicycle and Pedestrian Facilities
As listed in Table 5.10-1, within the Project site area, Citrus Avenue, Alabama Street, East Pennsylvania Avenue, and West San Bernardino Avenue contain bicycle lanes. The Orange Blossom Trail, a paved walking and cycling path, is located approximately 150 feet north of Sites-16 along the northern edge of the drainage channel just north of Citrus Avenue.

Generally, throughout the Project area, sidewalks are provided on both sides of the street. West San Bernardino Avenue currently lacks sidewalks on some segments near I-210. In addition, multiple segments of Texas Street, Orange Street, Citrus Avenue, Nevada Street, Iowa Street, and Alabama Street lack sidewalks.

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Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. Buildout according to the General Plan would result in approximately 45,792 trips.

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

TR-1 Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities;
TR-2 Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b); TR-3 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or TR-4 Result in inadequate emergency access.

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

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

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

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

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

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

2. The project is in a low VMT area.

3. The project is one of the following land uses:
o Local serving K-12 school
o Local park
o Daycare center
o Local-serving gas station
o Local-serving bank
o Local-serving hotel (e.g., non-destination hotel)
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o Local-serving community college that is consistent with the assumptions noted in the RTP/SCS o Affordable or supportive housing
o Assisted living facility
o Senior housing (as defined by the Federal Department of Housing and Urban Development)

4. The project generates less than 3,000 metric tons of carbon dioxide equivalent (MTCO 2e) per year. This includes:
o Single family residential – 167 dwelling units (DU) or fewer o Multifamily residential (low-rise) – 232 DU or fewer
o Multifamily residential (mid-rise) – 299 DU or fewer
o Office – 59,100 square feet (SF) or less
o Local-serving retail – 112.400 SF or less (no stores larger than 50,000 SF) o Warehousing – 463,600 SF or less
o Light industrial – 74,600 SF or less
With regards to criterion 2, as described in Section 5.10.1, Introduction, a low VMT area is defined as a TAZ with a total daily VMT/SP that is 15 percent below the baseline level for the County. Based on the San Bernardino County average VMT/SP, the VMT/SP baseline for Project Base Year 2024 is 35.63 VMT/SP and the 2050 baseline is 39.03 VMT/SP. Therefore, the City’s threshold of significance for Baseline 2024 is

30.29 VMT/SP, 15 percent below the 35.63 VMT/SP baseline, and the City’s threshold of significance for Cumulative Year 2050 is 33.18 VMT/SP, 15 percent below the 39.03 VMT/SP baseline.

5.10.5 METHODOLOGY
As outlined in State CEQA Guidelines Section 15064.3, except as provided for roadway capacity transportation projects, a project’s effect on automobile delay shall not constitute a significant environmental impact. Therefore, in order to comply with CEQA Guidelines Section 15064.3, impacts associated with automobile delay are not analyzed in this Draft Subsequent EIR.

Vehicle Miles Traveled Analysis Methodology
The applicability of each City of Redlands VMT Guidelines screening criterion was analyzed in relation to the potential land uses, location, and proximity to transit that could occur under buildout pursuant to the Project. If the Project meets one of the screening criteria set forth in the City of Redlands VMT Guidelines, it can be presumed that the Project would result in a less-than-significant impact. As specific future development is unknown at this time, a full VMT analysis was prepared using the San Bernardino Transportation Analysis Model (SBTAM). SBTAM was run for the Base Year 2019 and Cumulative Year 2050 without and with Project conditions. The total Origin-Destination (OD) VMT of each TAZ was evaluated using the SBTAM+ VMT post- processor from the SBTAM Base Year (2019) and Cumulative Year (2050) with-Project Model runs. To determine VMT/SP, the total OD VMT of the TAZs is divided by the service population (SP) of the TAZs. The 2024 VMT/SP was interpolated using linear interpolation between the 2019 and 2050 Model outputs.

The San Bernardino County VMT/SP for Project Baseline Year 2024 was calculated from the SBCTA VMT web map results for Base Year (2019) and Cumulative Year (2050) using linear interpolation.

The VMT/SP within the City of Redlands under the with-Project conditions for Cumulative Year (2050) was obtained using the with-Project model run. The VMT/SP within the City of Redlands under the no Project conditions for Cumulative Year (2050) was obtained using the without-Project Model run. To determine VMT/SP, the total boundary VMT of the City is divided by the SP of the City.

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5.10.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan FEIR
The General Plan EIR addressed impacts related to transportation in Chapter 3.15. The General Plan EIR described that implementation of the General Plan was anticipated to increase traffic volumes on intersections, roadway segments, and freeway segments through 2035. The General Plan EIR concluded that buildout pursuant to the General Plan would result in significant and unavoidable impacts related to worsening LOS despite the inclusion of multiple roadway and intersection improvements. The General Plan EIR discussed that the General Plan establishes policies and programs to expand the alternative transportation system and the General Plan would not conflict with the circulation network or policies. In addition, the EIR concluded that transportation policies in the General Plan would reduce design hazards and conflicts between incompatible land uses. Furthermore, the General Plan EIR discussed that implementation of regulations, combined with General Plan policies, would reduce impacts related to emergency access routes and impacts would be less than significant.

Proposed Project
The proposed Project would rezone 24 sites for the purpose of increasing residential development capacity.

Buildout of the proposed Project would change the maximum buildout of the Project area from 828,349.93 SF of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 111 multi-family dwelling units, 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses to residential uses with an allowed capacity of 2,436 units and approximately 151,048.46 SF of Public/Institutional uses. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings).

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

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

Less than Significant Impact. The following analysis has been prepared pursuant to SB 743, which requires that VMT thresholds be utilized for traffic analysis, and State CEQA Guidelines Section 15064.3 that states that a project’s effect on automobile delay shall not constitute a significant environmental impact.

Project Trip Generation
Vehicle trip estimates for buildout of the proposed Project compared to existing General Plan land use designations were generated by using trip rates from the Institute of Transportation Engineers, Trip Generation 11
th Edition, 2021. Existing General Plan buildout conditions (Baseline) were assessed using trip rates for Land Use Code 150 (Warehouse), 221 (Multi-Family Housing), 820 (Retail), and 710 (Office).

Based on the density of the proposed housing, trip rates for Land Use Code 221 (Multifamily Housing (Mid- Rise)) were used.

Table 5.10-2 identifies the trips generated by buildout pursuant to the existing General Plan land use designations of the rezone sites and compares it to the buildout of the proposed Project to determine the net increase in vehicle trips. As detailed, buildout pursuant to the Project is forecasted to generate a net decrease of 27,450 average daily trips, net increase of 1,034 AM trips, and net decrease of 1,716 PM trips. As such, buildout pursuant to the Project would result in decreased daily vehicle trips in the City of Redlands compared to buildout pursuant to the existing General Plan.

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Table 5.10-2: Proposed Project Trip Generation Comparison ScenarioLand UseITE
CodeUnit
ITE Daily
Trip
Rate/Unit
Project Size
(KSF or DU)
Project
ADTs
ITE AM Trip
Rate/Unit
Project AM
Trips
ITE PM Trip
Rate/Unit
Project PM
Trips
Buildout of the Existing
General Plan Land Uses
Warehouse (Sites 1-
7, 9-16, 24)150 KSF 1.71 828.34993 1,416 0.17 141 0.18 149 Retail (Sites 1-7, 9-
16, 24)820 KSF 37.01 828.34993 30,657 0.84 696 3.40 2,816 Multi-Family Housing
(Sites 8, 20-23)221 DU 4.54 111 504 0.37 41 0.39 43
Office (Sites 17-19) 710 KSF 10.84 276.1704 2,994 1.52 420 1.44 398 Retail (Sites 17-19) 820 KSF 37.01 276.1704 10,221 0.84 232 3.40 939 Existing General Plan
TOTAL TRIPS45,792 1,5294,345
Buildout of the Proposed
RHNA Rezoning (Project)
Proposed Multi-
Family Housing221 DU 4.54 2,436 11,059 0.37 901 0.39 950 Daycare Center1565 KSF 47.62 151.04846 7,193 11.00 1,662 11.12 1,680 Proposed Project
TOTAL TRIPS18,2522,5632,630
NET TOTAL TRIPS-27,5401,034-1,716
1Site 24 is owned by Montessori and the majority of buildings onsite are operated as a preschool. One building is leased by the Grove School, a high school. Therefore, ITE Code 565 accurately represents the trips from Site 24.

Notes: ADT = Average Daily Trips
DU = Dwelling Unit
ITE = Institute of Transportation Engineers Trip Generation Manual 11th Edition, 2021 KSF = Thousand Square Feet
Retail = Shopping Center greater than 150,000 SF
Source: Appendix F
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Roadway, Transit, Bicycle, and Pedestrian Facilities
Roadway
Regional access to the Project site is provided by I-10 and I-210. Local access to the site is provided via Alabama Street, Nevada Street, Iowa Street, Citrus Avenue, Orange Avenue, Pennsylvania Avenue, San Bernardino Avenue, Texas Street, Lugonia Avenue, and Orange Street. Each roadway is described above and in Table 5.10-1. The proposed Project would continue to provide vehicular access to the proposed rezoning parcels from the adjacent roadways and there would be no changes to the roadway access points.

Any future development under the proposed rezoning may include driveway and roadway improvements.

Specific roadway improvements required to support future development within the Project site are not known at this time and will not be known until a development project is proposed. Future projects under the proposed Project would be required to comply with the circulation system standards and to adhere to uniform standards and practices. Compliance with standards for roadway and intersection classifications, right-of- way width, pavement width, design speed, warrant requirements, capacity, maximum grades and associated features such as medians would be ensured and verified by the City during the plan check and permitting process, prior to obtaining building permits. The proposed Project would not conflict with existing facilities and would provide additional facilities as needed. Thus, impacts related to roadway facilities would not occur.

Transit Services
As described previously, the Project vicinity is served by Omnitrans and SBCTA. There are three bus routes that currently serve the Project area, and there are various Omnitrans bus stops throughout the Project area.

This existing transit service would continue to serve its ridership and new riders from implementation of future development under the proposed rezoning. Buildout of the proposed rezoning would be incremental in response to market needs and within the area currently served by Omnitrans and SBCTA. Therefore, the proposed Project would not conflict with an existing program related to transit facilities, and impacts would not occur.

Bicycle Facilities
As detailed previously and shown in Table 5.10-1, Citrus Avenue, Alabama Street, East Pennsylvania Avenue, and West San Bernardino Avenue currently contain bicycle lanes. In addition, the City’s General Plan Figure 5-3, Bicycle Facilities , identifies Nevada Street, Orange Avenue, Orange Street, Texas Street, New York Street, and Lugonia Avenue as planned bicycle routes. This existing bicycle lane infrastructure would be used by future residents and employees of new uses under the proposed RHNA rezone. As no specific development project is proposed, specific bicycle lane improvements required to support future development within the Project site are not known at this time and will not be known until a development project is proposed.

However, the General Plan has new facilities along Nevada Street, Orange Avenue, Orange Street, Texas Street, New York Street, and Lugonia Avenue; and future projects would be required, as deemed necessary, to construct these planned bicycle facilities as part of driveway and infrastructure improvements. This would be ensured and verified by the City during the plan check and permitting process, prior to obtaining building permits. Therefore, the proposed Project would not alter or conflict with existing bicycle facilities, and impacts related to bicycle facilities would not occur.

Pedestrian Facilities
Generally, throughout the Project area, sidewalks are provided on both sides of the street. West San Bernardino Avenue currently lacks sidewalks on some segments near I-210. In addition, multiple segments of Texas Street, Orange Street, Citrus Avenue, Nevada Street, Iowa Street, and Alabama Street lack sidewalks.

The Project does not propose a specific development or any demolition, including sidewalks; however, future development facilitated by the Project may be required to include sidewalk improvements. Specific sidewalk Redlands Regular Meeting of 06-03-25
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improvements required to support development within the Project area are not known at this time and will not be known until a development project is proposed. Future projects under the proposed Project would be required to comply with and adhere to uniform standards and practices, including provision of adequate sidewalk, as ensured and verified by the city during the plan check and permitting process, prior to obtaining building permits. Additionally future development is subject to compliance with applicable accessibility requirements of the American Disabilities Act, Title 24 of the Uniform Building Code as locally amended, and the Department of Housing and Urban Development's Fair Housing Accessibility Guidelines. Therefore, the proposed Project would not conflict with pedestrian facilities. Thus, impacts related to pedestrian facilities would not occur.

Policies
Section 5.6, Land Use and Planning , includes a list of applicable goals and policies related to the Project.

Tables 5.6-1 and 5.6-2 include analysis of the Project’s consistency with the SCAG Connect SoCal 2024– 2050 Regional Transportation Plan/Sustainable Communities Strategy and City of Redlands General Plan, respectively. As discussed in Section 5.6, the Project would be consistent with all applicable goals and policies. Thus, impacts related to conflict with a program, plan, ordinance, or policy addressing the circulation system of the Project site and surrounding area would not occur. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to circulation systems would be less than significant.

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

Site VMT Screening
As described previously, State CEQA Guidelines Section 15064.3(b) focus on determining the significance of VMT-related transportation impacts. The proposed Project was analyzed in comparison to the City of Redlands VMT Guidelines. As discussed in the City of Redlands VMT Guidelines, if a project meets the screening criteria set forth in the guidelines, then it would be considered to have a less-than-significant impact on VMT. The applicability of each screening criteria, in comparison to each Site of the proposed Project (Sites 1 through 24) is discussed below. The Project is located within TAZs 53827208 (Sites 1 and 2), 53827403 (Sites 3-15, 24), 53827501 (Site 16), 53836401 (Sites 17-19), 53835402 (Sites 20-21), 53836402 (Site 22), and 53835101(Site 23).

Screening Criterion 1 – TPA
According to the City’s guidelines, projects within one-half mile of an existing or planned major transit stop or an existing stop along a high-quality transit corridor are within a transit priority area (TPA). The TAZs within the proposed Rezone area and within a TPA may be presumed to have a less-than-significant VMT impact so long as developments have a floor area ratio of 0.75 or more, provide less parking than required by the City of Redlands, are consistent with the applicable Sustainable Communities Strategy, and do not replace affordable units with a smaller number of moderate- or high-income residential units. As shown in Figure 5.10-1, Transit Priority Areas & Rezone Sites, none of the proposed Rezone sites are located within a TPA. Therefore, the Project does not meet the requirements of Screening Criterion 1.

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Transit Priority Areas & Rezone Sites
Figure 5.10-1RHNA Rezone Project
City of Redlands
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Screening Criterion 2 – Low VMT Area
The City’s guidelines include a screening threshold for projects located in a low-VMT generating area, which is defined as TAZs with a total daily VMT/SP that is 15 percent less than the baseline level for the county.

For projects that are inconsistent with the land use assumptions coded into the projects’ TAZ, this screening criteria would not be appropriate, and the project would not satisfy the requirements of Screening Criterion

2. The proposed zoning designations for 19 of the 24 proposed Rezoning sites are inconsistent with the existing General Plan land use designations and would therefore not satisfy Screening Criteria 2. The proposed zoning designations and buildout of Site 8 and Sites 20 through 23 would be consistent with the existing General Plan land use designations and would meet Screening Criterion 2 if their respective TAZs are 15 percent below the County’s OD VMT/SP baseline. Based on the SBCTA VMT Screening Tool, Site 22 is located in a low VMT area and future buildout in Site 22 would satisfy Screening Criterion 2. Therefore, buildout of future projects within Site 22 would result in a less-than-significant impact to VMT.

However, Sites 8, 20, 21, and 23 are not located in a low VMT generating area. Therefore, future development projects within Sites 8, 20, 21, and 23 would not meet Screening Criterion 2.

Screening Criterion 3 – Land Use Type
If any implementing projects within the proposed Rezoning area consist of a local serving K-12 school, local park, daycare center, local-serving gas station, local-serving bank, local-serving hotel, student housing project on or adjacent to a college campus, local-serving assembly use, community institution, local-serving community college, affordable housing, assisted living facility, or senior housing, the implementing projects would screen out of further VMT analysis. Further, if an implementing project generates less than 3,000 MTCO
2e, such as a project that proposes 167 single-family dwelling units or fewer, 232 low-rise multi-family dwelling units or fewer, 299 mid-rise multi-family dwelling units or fewer, 59,100 SF or less of office space, 112,400 SF or less (with no stores larger than 50,000 SF) of local-serving retail uses, 463,600 SF or less of warehousing uses, or 74,600 SF or less of light industrial uses, the project would screen out of further VMT analysis. Implementing projects that generate less than 3,000 MTCO 2e per year would be presumed to have
a less-than-significant impact on VMT pursuant to Screening Criterion 3.

Implementing projects within Sites 1 through 24 pursuant to the new zoning designations could potentially consist of the type of developments that would screen out via Screening Criteria 3; however, specific implementing developments are unknown at this time. Given the proposed General Plan designation of Public/Institutional for Site 24, future development pursuant to the proposed General Plan and zoning designations would result in a land use that constitutes a local serving use, such as a government office or educational facility. Therefore, future development within Site 24 can be presumed to have a less-than- significant impact on VMT.

Sites 1-23 could propose an individual development that generates less than 3,000 MTCO 2e (299
Multifamily Housing (Mid-Rise) units), propose affordable housing, or propose Senior housing, and could therefore be presumed to have a less-than-significant VMT impact. However, given that the size of residential development resulting from buildout within Sites 1-23 is unknown, it cannot be determined that VMT impacts would be less than significant. Overall, since the totality of the buildout of the proposed zoning does not meet the requirements of Screening Criterion 3, and future development project specifics are not known at this time to determine if the land uses meet the requirements for Screening Criteria 3, it is determined that Screening Criterion 3 has not been met.

VMT Analysis for Sites 1 through 24
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As Screening Criteria 1 through 3 would not be met for all Project sites, a full VMT analysis has been prepared for the Project. The VMT analysis results from SBTAM for TAZs 53827208, 53827403, 53827501, 53836401, 53835402, and 53835101 (which encompass Sites 1 through 24) are provided below in Tables

5.10-3 through 5.10-9.

Sites 1 through 19, 22, & 24
Less than Significant Impact. As discussed above, Site 22 is located in a low VMT area and future buildout in Site 22 would satisfy Screening Criterion 2. Therefore, buildout of future projects within Site 22 would result in a less-than-significant impact to VMT.

As shown in Table 5.10-3, the Project VMT/SP for TAZ 53827208 (Sites 1 and 2) would be 39.6 percent below the threshold under Project Baseline 2024 conditions and 22 percent below the threshold under Cumulative Year 2050 conditions. Therefore, buildout of Sites 1 and 2 pursuant to the proposed zoning designations would result in a less-than-significant VMT impact.

Table 5.10-3: VMT Analysis of Sites 1-2 (TAZ 53827208)
Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model Base
Year 13,913 793 17.5 - - -
Project
Baseline
(2024)
14,513 793 18.3 30.29 -39.6% No
Model
Cumulative
Year (2050)
17,639 794 22.2 33.18 -33.0% No
Source: Appendix F
As shown in Table 5.10-4, the Project VMT/SP for TAZ 53827403 (Sites 3-7, 9-15, and 24) would be 23.4 percent below the threshold under Project Baseline 2024 conditions and 25.5 percent below the threshold under Cumulative Year 2050 conditions. Therefore, buildout of Sites 3 through 7, 9 through 15, and 24 under the proposed zoning designations would result in a less-than-significant VMT impact.

Table 5.10-4: VMT Analysis of Sites 3-7, 9-15 and 24 (TAZ 53827403) Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model Base
Year 96,137 4,198 22.9 - - -
Project
Baseline
(2024)
97,984 4,223 23.2 30.29 -23.4% No
Model
Cumulative
Year (2050)
107,586 4,353 24.7 33.18 -25.5% No
Source: Appendix F
As shown in Table 5.10-5, the Project VMT/SP for TAZ 53827493 (Site 8) would be 23.4 percent below the threshold under Project Baseline 2024 conditions. Additionally, since the Project is consistent with the General Redlands Regular Meeting of 06-03-25
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Plan land use designation, the Project would not require a cumulative year analysis. Therefore, buildout of Site 8 under the proposed Project would result in a less-than-significant VMT impact.

Table 5.10-5: VMT Analysis of Site 8 (TAZ 53827403)
Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model Base
Year 96,137 4,198 22.9 - - -
Project
Baseline
(2024)
97,984 4,223 23.2 30.29 -23.4% No
Model
Cumulative
Year (2050)
107,586 4,353 24.7 - - -
Source: Appendix F
As shown in Table 5.10-6, the Project VMT/SP for TAZ 53827501 (Site 16) would be 34.7 percent below the threshold under Project Baseline 2024 conditions and 44.5 percent below the threshold under Cumulative Year 2050 conditions. Therefore, buildout of Site 16 pursuant to the proposed zoning designation would result in a less-than-significant VMT impact.

Table 5.10-6: VMT Analysis of Site 16 (TAZ 53827501)
Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model Base
Year 91,664 4,571 20.1 - - -
Project
Baseline
(2024)
90,786 4,589 19.8 30.29 -34.7% No
Model
Cumulative
Year (2050)
86,221 4,682 18.4 33.18 -44.5% No
Source: Appendix F
As shown in Table 5.10-7, the Project VMT/SP for TAZ 53836401 (Sites 17-19) would be 17.6 percent below the threshold under Project Baseline 2024 conditions and 9.6 percent below the threshold under Cumulative Year 2050 conditions. Therefore, buildout of Sites 17-19 under the proposed zoning designations would result in a less-than-significant VMT impact.

Table 5.10-7: VMT Analysis of Sites 17-19 (TAZ 53836401) Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model Base
Year 42,151 1,762 23.9 - - -
Project
Baseline
(2024)
44,527 1,764 25.0 30.29 -17.6% No
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Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model
Cumulative
Year (2050)
56,879 1,896 30.0 33.18 -9.6% No
Source: Appendix F
Sites 20, 21, & 23
Significant and Unavoidable Impact. As shown in Table 5.10-8, the Project VMT/SP for TAZ 53835402 (Sites 20 and 21) would be 85.1 percent above the threshold under Project Baseline 2024 conditions.

However, since buildout of the site would be consistent with the existing General Plan land use designation, this site would not require a cumulative year analysis.

Additionally, as shown in Table 5.10-9, the Project VMT/SP for TAZ 53835101 (Site 23) would be 8.1 percent above the threshold under Project Baseline 2024 conditions. Since buildout of the site would be consistent with the existing General Plan land use designation, this site would also not require a cumulative year analysis.

Table 5.10-8: VMT Analysis of Sites 20-21 (TAZ 53835402) Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model Base
Year 52,628 945 56.7 - - -
Project
Baseline
(2024)
55,702 993 56.1 30.29 85.1% Yes
Model
Cumulative
Year (2050)
66,487 1,245 53.4 - - -
Source: Appendix F
Table 5.10-9: VMT Analysis of Site 23 (TAZ 53835101)
Scenario Project VMT
Project
Service
Population
Project VMT
per Service
Population
Threshold
Percent
Above
Threshold
Impact?
Model Base
Year 43,164 1,337 32.3 - - -
Project
Baseline
(2024)
43,760 1,337 32.7 30.29 8.1% Yes
Model
Cumulative
Year (2050)
46,859 1,337 35.0 - - -
Source: Appendix F
Therefore, buildout of Sites 20, 21, and 23 pursuant to the proposed zoning designations would result in a potentially significant VMT impact. As such, future development projects within Sites 20, 21, and 23 would be required to conduct a Project-specific VMT screening analysis to determine whether the future proposed development would screen out of a full VMT analysis pursuant to Mitigation Measure T-1. Should the future Redlands Regular Meeting of 06-03-25
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proposed development not screen out of a VMT analysis, the project would be required to conduct a full VMT analysis and implement VMT-reduction measures as outlined in Mitigation Measure T-1. However, given that future development of Sites 20, 21, and 23 is unknown, the applicability of specific VMT measures and resulting reduction in VMT cannot be determined and no credit is taken for future implementation of VMT reduction measures. As such, the Project would result in a significant and unavoidable project-level VMT impact. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which did not analyze VMT impacts.

5.10.7 CUMULATIVE IMPACTS
Roadway, Transit, Bicycle, and Pedestrian Networks
The evaluation of Impact TRA-1 concluded that the proposed Project would not result in significant impacts related to alternative transportation or policies addressing the circulation system. Cumulative development in the City and surrounding jurisdictions, as shown on Table 5-1, would be subject to site-specific reviews, including reviews of sidewalk, bike lane, and bus stop designs that would not allow potential cumulatively considerable impacts related to alternative transportation. Therefore, the Project would not cumulatively combine with other projects to result in impacts related to alternative transportation. The Project would be consistent with all applicable plans and policies. Therefore, the Project would not contribute to a cumulatively considerable impact associated with conflict with a program, plan, ordinance, or policy addressing the circulation system including roadway, transit, bicycle, or pedestrian networks.

Vehicle Miles Traveled
The cumulative traffic study area for the proposed Project includes the City of Redlands. As discussed in the City of Redlands CEQA Assessment VMT Analysis Guidelines, projects that are inconsistent with the Redlands General Plan 2035 would not have a cumulative impact so long as the project’s citywide boundary VMT/SP is lower than the no project scenario under cumulative conditions. As shown in Table 5.10-10, with buildout of the Project, the cumulative Redlands Citywide boundary VMT/SP would be 3.1 percent lower than cumulative VMT without the Project. As such, the Project’s impact on citywide VMT would be less than significant and cumulative impacts related to VMT would be less than significant.

Table 5.10-10: Project’s Effect on Citywide VMT
Cumulative 2050
Citywide Boundary VMT with Project 3,268,701
Citywide Service Population with Project 147,175
With Project Citywide Boundary VMT/SP 22.21
Citywide Boundary VMT No Project 3,238,348
Citywide Service Population No Project 141,337
No Project Citywide Boundary VMT/SP 22.91
Percent Above/Below Threshold -3.1%
Impact? No

5.10.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
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Plans, Programs, or Policies
None.

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

Regarding Impact TR-2, implementing projects within Sites 1-19, 22, and 24 would result in a less-than- significant VMT impact.

Implementing projects within Sites 20, 21, and 23 would be potentially significant.

5.10.10 MITIGATION MEASURES
Mitigation Measure TR-1: VMT Screening & Analysis. Prior to approval of any site plan, any applicant for an implementing project fully within or partially within Site 20, 21, or 23 shall prepare a VMT Screening Analysis pursuant to the City of Redlands CEQA Assessment VMT Analysis Guidelines and provide this Analysis to the City of Redlands Planning Division and Engineering Division. The VMT Screening Analysis shall demonstrate that the implementing project meets the screening criteria set forth in in the City of Redlands CEQA Assessment VMT Analysis Guidelines.

If the implementing project does not meet the screening criteria set forth in Screening Criteria 1, 2, 3, or 4, the implementing project applicant shall prepare a full VMT analysis pursuant to the City of Redlands CEQA Assessment VMT Analysis Guidelines. For projects with VMT per Service Population exceeding the City’s significance threshold, a mitigation plan shall be developed and implemented. Mitigation should consist of Transportation Demand Management (TDM) measures analyzed under a VMT-reduction methodology consistent with the California Air Pollution Control Officers Association’s (CAPCOA) Final Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (2021) and approved by the City of Redlands. Examples of measures include but are not limited to:
• Increase Residential Density: Higher residential density encourages mixed-use development and reduces sprawl. Placing more people closer to amenities, workplaces, and public transit decreases the distance people need to travel for daily activities, thereby reducing overall VMT. • Integrate Affordable and Below Market Rate Housing : Below market rate housing provides greater opportunity for lower income families to live closer to job centers and achieve a jobs/housing match near transit and can decrease the VMT generated by the project. • Implement Commute Trip Reduction Marketing: Information sharing and marketing promote and educate workers about their travel choices to the employment location beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT. This could be implemented through a home owners association (HOA).
• Provide Ridesharing Program: Ridesharing encourages carpooled vehicle trips in place of single-occupied vehicle trips, thereby reducing the number of trips, VMT. This could be implemented through an HOA. • Implement Subsidized or Discounted Transit Program: Reducing the out-of-pocket cost for choosing transit improves the competitiveness of transit against driving, increasing the total number of transit trips and decreasing vehicle trips. This decrease in vehicle trips results in reduced VMT. This could be implemented through an HOA.
• Limit Residential Parking Supply: The reduction in VMT that can be achieved by limiting the total parking supply available at a residential project. When parking is limited, scarcity is created, and additional Redlands Regular Meeting of 06-03-25
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time and inconvenience is added to trips made by private auto. The reduction in the convenience of driving results in a shift to other modes and can decrease the VMT generated by the project. • Unbundle Residential Parking Costs from Property Cost : Parking costs are passed through to the vehicle owners/drivers utilizing the parking spaces, this measure results in decreased vehicle ownership and, therefore, a reduction in VMT.
• Provide Pedestrian Network Improvement: Providing sidewalks and an enhanced pedestrian network encourages people to walk instead of drive. This mode shift results in a reduction in VMT. • Construct or Improve Bike Facility: Building or enhancing bike facilities such as dedicated bike lanes, secure parking, and bike-sharing programs promotes cycling as a convenient and safe transportation option. This reduces the number of short-distance car trips, contributing to lower VMT. • Construct or Improve Bike Boulevard: Bike boulevards are designed to prioritize cyclists by providing dedicated lanes and traffic calming measures. By creating safer and more attractive cycling routes, bike boulevards encourage residents to use bicycles for commuting and local trips, thereby reducing VMT. • Expand Bikeway Network: Expanding the bikeway network connects different parts of the community with safe and accessible bike routes. This infrastructure improvement makes cycling a more practical choice for daily transportation needs, reducing reliance on motor vehicles and lowering VMT. • Implement Conventional Carshare Program: Conventional carshare programs provide access to vehicles on a short-term basis. By promoting shared vehicle usage, particularly for occasional trips, they reduce the need for individual car ownership and decrease VMT. • Implement Electric Carshare Program: Electric carshare programs offer access to EVs for shared use.

Providing convenient access to environmentally friendly transportation options encourages residents and employees to choose EVs over traditional vehicles, thus lowering VMT and emissions. • Implement Pedal (Non-Electric) Bikeshare Program: Pedal bikeshare programs make bicycles readily available for short trips. Offering an alternative to driving for local transportation needs reduces congestion and lowers VMT.
• Implement Electric Bikeshare Program: Electric bikeshare programs provide access to electric-assisted bicycles. These bikes make cycling more accessible to a broader range of users and encourage more trips to be taken by bike instead of by car, contributing to reduced VMT. • Implement Scooter Share Program: Scooter share programs offer electric scooters for short-distance trips.

By providing a convenient alternative to driving for short trips within the community, scooter share programs reduce the number of car trips and help decrease VMT. • Provide Community-Based Travel Planning (CBTP): CBTP is a residential-based approach to outreach that provides households with customized information, incentives, and support to encourage the use of transportation alternatives in place of single occupancy vehicles, thereby reducing household VMT. This could be implemented through an HOA.
• Implement Market Price Public Parking (On-Street) : Increasing the cost of parking increases the total cost of driving to a location, incentivizing shifts to other modes and thus decreasing total VMT to and from the priced areas.
• Implement Transit-Supportive Roadway Treatments : Transit-supportive treatments incorporate a mix of roadway infrastructure improvements and/or traffic signal modifications to improve transit travel times and reliability. This results in a mode shift from single occupancy vehicles to transit, which reduces VMT.

5.10.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact TR-2: Implementing projects within Sites 20, 21, and 23 have the potential to result in significant VMT impacts after implementation of Mitigation Measure TR-1. Implementing projects within the sites that do not meet Screening Criterion 1, 2, 3, or 4 could result in VMT levels where potential VMT reductions associated Redlands Regular Meeting of 06-03-25
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with TDM measures would not be large enough to guarantee that significant impacts could be fully mitigated.

Therefore, Impact TR-2 for Sites 20, 21, and 23 would be significant and unavoidable.

5.10.12 REFERENCES
City of Redlands. (2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669. Accessed July 2, 2024.

City of Redlands. (2024). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 EPD Solutions, Inc. (July 2024). Redlands RHNA Rezone Project VMT Analysis. (Appendix F) Redlands Regular Meeting of 06-03-25
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5.11 Tribal Cultural Resources

5.11.1 INTRODUCTION
This section addresses potential impacts to tribal cultural resources (TCRs) associated with implementation of the proposed Project. The analysis in this section is based, in part, on the following documents and resources:
• City of Redlands General Plan 2035 , December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), July 2017; and
• City of Redlands Municipal Code.

Additionally, part of this analysis is based upon Project-specific coordination and consultation with California Native American tribes that are traditionally and culturally affiliated with the Project site.

5.11.2 REGULATORY SETTING

5.11.2.1 Federal Regulations
Archaeological Resources Protection Act
The Archaeological Resources Protection Act (ARPA) of 1979 regulates the protection of archaeological resources and sites on federal and Native American lands. The ARPA regulates authorized archaeological investigations on federal lands; increased penalties for looting and vandalism of archaeological resources; and required that the locations and natures of archaeological resources be kept confidential in most cases.

In 1988, amendments to the ARPA included a requirement for public awareness programs regarding archaeological resources (NPS, 2018).

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

5.11.2.2 State Regulations
California Senate Bill 18
Senate Bill 18 (SB 18) (California Government Code Section 65352.3) sets forth requirements for local governments to consult with California Native American tribes identified by the California Native American Heritage Commission (NAHC) to aid in the protection of TCRs. The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early stage of planning to protect, or mitigate impacts on, TCRs. The Tribal Consultation Guidelines: Supplement to General Plan Guidelines (OPR, 2005), identifies the following contact and notification responsibilities of local governments:
• Prior to the adoption or any amendment of a general plan or specific plan, a local government must notify the appropriate tribes (on the contact list maintained by the NAHC of the opportunity to conduct consultations for the purpose of preserving, or mitigating impacts to, cultural places located on land Redlands Regular Meeting of 06-03-25
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within the local government’s jurisdiction that is affected by the proposed plan adoption or amendment.

Tribes have 90 days from the date on which they receive notification to request consultation, unless a shorter timeframe has been agreed to by the tribe (Government Code Section 65352.3). • Prior to the adoption or substantial amendment of a general plan or specific plan, a local government must refer the proposed action to those tribes that are on the NAHC contact list and have traditional lands located within the city or county’s jurisdiction. The referral must allow a 45-day comment period (Government Code Section 65352). Notice must be sent regardless of whether prior consultation has taken place. Such notice does not initiate a new consultation process. • Local government must send a notice of a public hearing, at least 10 days prior to the hearing, to tribes who have filed a written request for such notice (Government Code Section 65092).

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

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

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

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

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

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

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

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

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

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

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

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

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

East Valley Corridor Specific Plan Preservation Overlay District The East Valley Corridor Specific Plan provides for a Preservation – Historical/Archaeological Overlay District (“Preservation Overlay District”) in Division 5 of the Specific Plan, which is intended to preserve and protect historical and archaeological resources. The Preservation Overlay District provides development standards for developments within the district that are in addition to those required by the Specific Plan.

Within the East Valley Corridor Specific Plan, the Preservation Overlay District is applied to areas approximately 600 feet on either side of the historic alignment of the Mission Zanja irrigation canal and to potential historic structures. The development standards set forth within the Preservation Overlay District set forth requirements for investigation, data recovery, and preservation of archaeological and historic resources (County of San Bernardino, 1988).

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

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Serrano
Since time immemorial, Native people have lived and gathered in the mountains, valley, and foothills of the San Gabriel and San Bernardino Mountains. This area provided plentiful resources to the Native communities whose ancestral lands encompass the Redlands area, such as the Maara’yam (Serrano) people.

Archaeological evidence of the Serrano people has been found in and around Redlands. Grinding holes provide proof of resource processing and communal living; non-local shells and obsidian tools reflect a healthy trade and well-traveled culture. The Serrano people were renowned for their sophisticated basketry made of grasses and fibers that illustrate practical yet artistic designs.

The Serrano lived in dome- shaped structures called kiič . They were generally made of willow poles and long sticks to create a frame, then covered with brush and yucca fiber. They were often dug about two feet into the ground to combat extreme temperatures. The homes of several families, along with granaries, sweathouses, and ceremonial buildings, were clustered together, forming communities.

Historical evidence of Serrano people inhabiting the Redlands area comes from the San Gabriel Missions, specifically the mission’s estancia, known as the Asistencia today, which was established in 1819. The Asistencia held many Serrano people as well as other indigenous people from nearby regions, using them as labor for mission support. One notable feat was the building of the Mill Creek Zanja, a massive irrigation system that extends from the base of the San Bernardino Mountains through Mentone, Redlands, and Loma Linda. This feature supported agriculture across the region and is listed on the National Register of Historic Places with the notation that it was built by Serrano men.

From the Mission Era onward, Native people have been forcibly removed from their traditional homelands.

Despite these hardships, the Serrano people were able to maintain their identity as sovereign nations, including the San Manuel Band of Mission Indians. Tribes maintain a connection to their ancestral lands by stewarding cultural and natural resources.

Cahuilla
The eastern portion of the Valley Region, the southeastern part of the Mountain Region, and the southern portion of the East Desert Region of San Bernardino County were once home to the Cahuilla people. It is thought that the Cahuilla migrated to southern California approximately 2,000 to 3,000 years ago with related sociolinguistic groups, most likely from the southern Sierra Nevada Mountain ranges. The Cahuilla settled in a territory that extended from the present-day city of Riverside to the central portion of the Salton Sea in the Colorado Desert, and from the San Jacinto Valley to the San Bernardino Mountains (City of Redlands, 2017b).

Gabrieleño
The Gabrieleño historically occupied the southwestern portion of San Bernardino County, including the Valley Region. The name Gabrieleño denotes the people who were under the control of the Spanish from Mission San Gabriel, which included people from the Gabrieleño proper as well as other social groups. Many contemporary Gabrieleño identify themselves as descendants of the indigenous people living across the plains of the Los Angeles Basin and use the native term Tongva. Historic-era Tongva settlements in the San Bernardino Valley were primarily located at the base of the foothills and along perennial watercourses (City of Redlands, 2017b).

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Approved General Plan 2035 Buildout
Buildout of the approved General Plan would result in the development of 1,656,699.86 SF of commercial/industrial uses, 552,340.90 SF of commercial uses, and 111 multi-family dwellings. Similar to the proposed Project, future development pursuant to the General Plan could involve grading, excavation, and other ground disturbing activities to previously undisturbed depths, which could result in inadvertent discovery of buried tribal cultural resources.

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

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

5.11.5 METHODOLOGY
The analysis within this Draft Subsequent EIR section is based on the sacred lands record search from the NAHC requested by the City. The NAHC responded on January 19, 2024, that there are known sacred lands within one-half mile of the Project boundaries.

In compliance with SB 18 and AB 52, on January 29, 2024, the City sent letters to Native American groups or individuals that may have knowledge regarding tribal cultural places in the Project area. Responses were received from two tribes. The Gabrieleño Band of Mission Indians – Kizh Nation (Kizh Nation) responded on February 5, 2024, and the Yuhaaviatam of San Manuel Nation (San Manuel) responded on March 5, 2024.

An AB 52/SB 18 consultation was requested by San Manuel. San Manuel considers the Project area sensitive for TCRs. Additionally, SB 18 consultation was requested by the Kizh Nation, which consulted with the City and considers the area sensitive for cultural resources. Furthermore, due to the presence of tribal cultural resources within the Project area, the Kizh Nation described that there is a potential of encountering historic and prehistoric resources. As such, the consulting tribes requested inclusion of mitigation due to the potential of the Project to unearth previously undocumented TCRs during construction.

5.11.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
The General Plan EIR addressed impacts related to TCRs in Chapter 3.8. The Certified EIR found that there are no known TCRs in the Planning Area. However, future development allowed under the proposed General Plan could result in direct or indirect impacts through grading, overland vehicle travel, or other ground- Redlands Regular Meeting of 06-03-25
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disturbing activities, or through facilitation of access to archaeological sites by the public. Policies in the General Plan were determined to minimize or avoid potential impacts to any resources not known at this time that may be encountered in future and would promote consultation with local Native American tribal groups during future projects to ensure the protection of TCRs. Thus, implementation of the General Plan was determined to result in less-than-significant impacts to TCRs (City of Redlands, 2017b, p. 3.8-17).

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

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

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

REGISTER OF HISTORICAL RESOURCES AS DEFINED IN PUBLIC RESOURCES CODE SECTION 5020.1(K).

Less than Significant with Mitigation Incorporated. SB 18 and AB 52 require meaningful consultation between lead agencies and California Native American tribes regarding potential impacts on TCRs. As described above, TCRs are sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either eligible or listed in the California Register of Historical Resources or local register of historical resources (PRC Section 21074). As outlined above, the NAHC’s Sacred Lands File search was positive for sacred lands within one-half mile of the Project area, and the City sent letters to Native American Tribes notifying them of the proposed Project in accordance with SB 18 and AB 52. In response, the Kizh Nation and San Manuel requested consultation and met with the City.

The Morrey Arroyo was identified as a potential site for TCRs. Due to the presence of portions of the Morrey Arroyo within the Project site, the Kizh Nation described that there is a potential of encountering historic and prehistoric resources during ground disturbing activities. No information or evidence has been disclosed to the City by any Native American Tribes regarding the potential for Tribal Cultural Resources to occur in the Project area (other than the known Morrey Arroyo), and therefore, impacts are expected to be less than significant. However, the City has agreed to implement Mitigation Measure TCR-1 in the event of any inadvertent discovery of TCRs
Implementation of the proposed Project would not directly result in physical construction that could impact TCRs. However, development and redevelopment projects pursuant to the proposed Project could involve grading and excavation to greater depths than previously undertaken that could disturb unknown buried TCRs. Thus, Initial Study Mitigation Measures CUL-3, CUL-4, and DSEIR Mitigation Measure TCR-1 are required for implementing projects and would reduce the potential for TCRs to be impacted during earthmoving activities and provides for preservation of any identified resources.

With implementation of Mitigation Measures CUL-3, CUL-4, and TCR-1, impacts related to a substantial adverse change in the significance of a TCR would be less than significant. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to tribal cultural resources would be less than significant.

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

SIGNIFICANCE OF A TRIBAL CULTURAL RESOURCE DETERMINED BY THE LEAD

AGENCY, IN ITS DISCRETION AND SUPPORTED BY SUBSTANTIAL EVIDENCE, TO BE

SIGNIFICANT PURSUANT TO CRITERIA SET FORTH IN SUBDIVISION (C) OF THE PUBLIC RESOURCES CODE SECTION 5024.1.

Less than Significant with Mitigation Incorporated. As described in Section 5.3, Cultural Resources , the Project site is located in an urbanized area; however, future site-specific development projects pursuant to the proposed Project could involve grading and excavation to greater depths than previously undertaken that could disturb buried archaeological resources, including TCRs. No information or evidence has been disclosed to the City by any Native American Tribes regarding the potential for Tribal Cultural Resources to occur in the Project area (other than the known Morrey Arroyo), and therefore, impacts are expected to be Redlands Regular Meeting of 06-03-25
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less than significant. However, the City has agreed to implement mitigation measures in the event of any inadvertent discovery of TCRs. Thus, Mitigation Measures CUL-3 and CUL-4 are included to reduce the potential for archaeological resources, including TCRs, to be impacted during earthmoving activities and provides for preservation of any identified resources. Furthermore, as a result of SB 18 and AB 52 tribal consultation, Mitigation Measure TCR-1 is included in the case if an incidental discovery of a TCR during ground disturbing activity. With implementation of Mitigation Measures CUL-3, CUL-4, and TCR-1, impacts related to a substantial adverse change in the significance of a TCR would be less than significant. As such, Project impacts would be greater than the impact conclusions set forth in the General Plan EIR, which determined that impacts related to tribal cultural resources would be less than significant.

5.11.7 CUMULATIVE IMPACTS
The cumulative study area for TCRs includes the Southern California region, which contains the same general tribal historic setting of the Gabrieleño, Cahuilla, and Serrano, as detailed previously in Section 5.11.3, Environmental Setting.

Similar to future projects implemented pursuant to the proposed Project, other projects in the vicinity of the Project site could involve ground-disturbing activities in native soils that may uncover or disturb unknown TCRs. However, the Project has included Mitigation Measure CUL-1, CUL-2, and TCR-1 that would reduce the potential impact to unknown resources. Cumulative development would also be required to undergo environmental review to establish requirements for avoidance or mitigation of impacts to potential resources.

Thus, the Project would not contribute to cumulative impacts, and cumulative effects of development on TCRs from implementation of the proposed Project in combination with other projects would be less than significant.

5.11.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
• California Government Code Sections 5097.9-5097.99
• California Health and Safety Code Section 7050.5
• California Public Resources Code Sections 21073 et seq. (AB 52) Plans, Programs, or Policies
None.

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

5.11.10 MITIGATION MEASURES
Mitigation Measure CUL-3 and Mitigation Measure CUL-4 related to archaeological resources and human remains discussed in Section 5.3, Cultural Resources, apply. In addition, the following mitigation measure would apply to all future implementing projects. Other mitigation may also be required for future projects as determined through the tribal consultation process.

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have the authority to temporarily divert and/or temporarily halt ground-disturbance operations in the area of discovery to allow for the evaluation of potentially significant cultural resources. Isolates and clearly non- significant deposits shall be minimally documented in the field and collected so the monitored grading can proceed.

If a potentially significant tribal cultural resource(s) is discovered, work shall stop within a 60-foot perimeter of the discovery and an Environmentally Sensitive Area (ESA) physical demarcation/barrier constructed. All work shall be diverted away from the vicinity of the find, so that the find can be evaluated by the Qualified Archaeologist. The Archaeologist shall notify the Lead Agency and consulting Tribe[s] of said discovery. The Qualified Archaeologist, in consultation with the Lead Agency, the consulting Tribe[s], and any Tribal Monitor[s], shall determine the significance of the discovered resource. A recommendation for the treatment and disposition of the Tribal Cultural Resource shall be made by the Qualified Archaeologist in consultation with the Tribe[s] and any Tribal Monitor[s] and shall be submitted to the Lead Agency for review and approval. Below are the possible treatments and dispositions of significant cultural resources in order of CEQA preference:

A. Full avoidance.

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

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

D. If all other options are proven to be infeasible, data recovery through excavation and then curation in a Curation Facility that meets the Federal Curation Standards (CFR 79.1)

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

5.11.12 REFERENCES
City of Redlands. (July 2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (July 2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Retrieved July 2, 2024, from https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 City of Redlands. (2024). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 County of San Bernardino. (1988). East Valley Corridor Specific Plan Final Environmental Impact Report.

Retrieved August 3, 2024, from https://www.cityofredlands.org/sites/main/files/file- attachments/evcsp_-_eir_complete.pdf?1582744548.

Governor’s Office of Planning and Research (OPR). (2005). Tribal Consultation Guidelines: Supplement to General Plan Guidelines. Retrieved July 2, 2024, from
https://www.lci.ca.gov/docs/011414_updated_guidelines_922.pdf National Park Service (NPS). (2018). Archeological Resources Protection Act of 1979. Retrieved July 3, 2024, from https://www.nps.gov/subjects/archeology/archaeological-resources-protection- act.htm
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5.12 Utilities and Service Systems

5.12.1 INTRODUCTION
This section of the Draft Subsequent EIR evaluates the potential effects on utilities and service systems from implementation of the proposed Project, identifying anticipated demand and existing and planned utility availability. This includes water supply and infrastructure, wastewater, and stormwater drainage. Electric power, natural gas, telecommunications, and renewable energy resources are described in Section 5.4, Energy. The Initial Study (included as EIR Appendix A) established that the proposed Project would not result in potentially significant impacts to solid waste, so solid waste utilities are not discussed further in this section.

Information in this section is based on the following documents and resources:
• City of Redlands General Plan 2035 , December 5, 2017; • City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report (General Plan EIR), July 2017;
• City of Redlands Municipal Code;
• Upper Santa Ana River Watershed Integrated Regional Water Management Plan (IRUWMP), San Bernardino Valley Water Conservation District, May 2021; • Redlands RHNA Rezone Water Supply Assessment, Fuscoe Engineering, Inc., July 19, 2024, Appendix G; and
• Redlands RHNA Rezone Proposed Conditions Infrastructure Report for Water and Sewer, Fuscoe Engineering, Inc., July 19, 2024, Appendix H.

Because CEQA focuses on physical environmental effects, this section analyzes whether increases in demand for water, wastewater, and stormwater utilities would result from implementation of the proposed Project that would result in significant adverse physical environmental effects. For example, an increase in wastewater generation, by itself, would not be considered a physical change in the environment; however, physical changes in the environment resulting from the construction of new facilities or an expansion of existing wastewater facilities could constitute a significant impact under CEQA.

5.12.2 REGULATORY SETTING

5.12.2.1 Federal Regulation
Clean Water Act
The Clean Water Act (CWA) was enacted by Congress in 1972 and is the primary federal law regulating water quality in the United States. The objective of the CWA is to reduce or eliminate water pollution in the nation’s rivers, streams, lakes, and coastal waters. The CWA forms the basic national framework for the management of water quality and the control of pollution discharges; it provides the legal framework for several water quality regulations, including the National Pollutant Discharge Elimination System (NPDES), effluent limitations, water quality standards, pretreatment standards, antidegradation policy, nonpoint source discharge programs, and wetlands protection. The United States Environmental Protection Agency (USEPA) has delegated the responsibility for administration of CWA portions to State and regional agencies.

In California, the State Water Resources Control Board (SWRCB) administers the NPDES permitting program and is responsible for developing NPDES permitting requirements. The SWRCB works in coordination with Redlands Regular Meeting of 06-03-25
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the Regional Water Quality Control Boards (RWQCB) to preserve, protect, enhance, and restore water quality.

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

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

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

CALGreen Building Code
California Code of Regulations Title 24, Part 11, establishes the California Green Building Standards (CALGreen). The CALGreen Code is updated every three years. It was recently updated in 2022, effective January 1, 2023. CALGreen sets forth water efficiency standards (e.g., maximum flow rates) for all new plumbing and irrigation fittings and fixtures
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5.12.2.3 Local and Regional Regulations
City of Redlands Drainage Master Plan
In June 2014, the City of Redlands adopted a Drainage Master Plan specifically devoted to its storm drain system. The Master Plan consolidates studies from multiple local and regional agencies, identifies infrastructure necessary to help protect the city from a major storm, provides long-range planning for the implementation and development of citywide drainage facilities, and determines the cost of implementing the facilities to add capacity to the existing stormwater drainage infrastructure. The Plan proposes improvements for each of the city’s drainage areas, including replacement of existing storm drainage facilities, and provides cost estimates for each.

City of Redlands 2035 General Plan
The following goals and policies from the Livable Community and Vital Environment chapters of the City of Redlands General Plan 2035, adopted December 2017, are relevant to the proposed Project:

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

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

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

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

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

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

Policy 6-A.38 Encourage development that reflects an integrated approach to building design, civil engineering, and landscape architecture that maximizes rainwater harvesting and stormwater retention for landscape irrigation.

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

City of Redlands Municipal Code Requirements
City of Redlands Water Efficient Landscape Requirements Chapter 15.54 of the Redlands Municipal Code establishes the City’s Water Efficient Landscape Requirements to promote the benefits provided by landscapes while recognizing the need to use water as Redlands Regular Meeting of 06-03-25
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efficiently as possible. The chapter requires applicable landscaping projects to submit a landscape documentation package that contains project information, hydrozone information table, water budget calculations, soil management report, and landscape, irrigation, and grading design plans. The chapter establishes requirements for irrigation scheduling, maintenance, and audits to ensure efficient use of water.

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

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

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

5.12.3 ENVIRONMENTAL SETTING

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

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

MUED Water Supply and Demand
The MUED utilizes four primary sources for water supply: groundwater, surface water, imported water, and recycled water. The MUED’s water supply is a combination of groundwater from the Bunker Hill Subbasin; groundwater from the Yucaipa Subbasin; surface water from the Santa Ana River; surface water from Mill Creek; imported water from the State Water Project (SWP); and recycled water. As shown on Table 5.12- 1, in 2020, the MUED obtained the greatest percentage of its water supply from the Bunker Hill Subbasin.

Table 5.12-1: MUED Water Supply 2020
Water Supply Source Water Quality Volume
(acre-feet) Percentage
Groundwater Bunker Hill Drinking Water 12,088 43%
Groundwater Bunker Hill Non-Potable 1,531 5.4%
Groundwater Yucaipa Non-Potable 297 1.1%
Surface Water Santa Ana River Drinking Water 5,796 20.6% Redlands Regular Meeting of 06-03-25
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Water Supply Source Water Quality Volume
(acre-feet) Percentage
Surface Water Mill Creek Drinking Water 6,045 21.5%
Purchased or Imported
Water
SWP-Direct
Deliveries
Drinking Water 535 1.9%
Recycled Recycled Water-
Direct
Recycled Water 1,806 6.5%
Total 28,098 100%
Source: San Bernardino Valley Water Conservation District, 2021.

As shown in Table 5.12-2, the 2020 IRUWMP estimates that water supplies in the future are anticipated to be obtained through a similar mix of surface water, groundwater, and purchased or imported water. The 2020 IRUWMP anticipates that the MUED’s water supply will increase from 31,039 acre feet (AF) in 2025 to 35,544 AF in 2045 (increase of 4,505 AF) to meet MUED’s anticipated growth in water demands.

Table 5.12-2: MUED Projected Water Supply (AF)
Water Supply Source 2025 2030 2035 2040 2045 2035
Percentage
Groundwater Bunker Hill 12,973 13,922 14,861 15,677 16,484 46.4% Groundwater Bunker Hill 3,766 4,015 4,275 4,513 4,760 13.4% Groundwater Yucaipa 1,000 1,000 1,000 1,000 1,000 2.8%
Surface Water Santa Ana River 5,000 5,000 5,000 5,000 5,000 14.1% Surface Water Mill Creek 5,500 5,500 5,500 5,500 5,500 15.5% Purchased or
Imported Water
SWP-Direct Deliveries 700 700 700 700 700 1.9%
Recycled Recycled Water-Direct 2,100 2,100 2,100 2,100 2,100 5.9% Total 31,039 32,238 33,436 34,490 35,544 100%
Source: San Bernardino Valley Water Conservation District, 2021 The 2035 projections anticipate that 62.6 percent of supply would be from the groundwater sources, 29.6 percent from surface water, 1.9 percent from imported/purchased sources, and 5.9 percent from recycled water. The IRUWMP also describes that there has been a historical trend associated with drier years and an increase in water use among agencies. Conservation efforts have proven to be effective in decreasing water use in dry years. Additionally, according to the IRUWMP, MUED has adequate supplies to serve 100 percent of its customers during normal, dry year, and multiple dry year demand through 2045 with projected population increases and accompanying increases in water demand San Bernardino Valley Water Conservation District, 2021).

Groundwater: Redlands MUED extracts groundwater from the Bunker Hill Subbasin (also known as San Bernardino Basin or SBB) and Yucaipa Subbasin. Extractions from both basins include potable and non- potable water. In 2020, Redlands MUED extracted 13,619 AF of groundwater from the Bunker Hill Subbasin and 297 AF from the Yucaipa Subbasin. The City of Redlands uses 15 wells to obtain water from these sources that pump directly into the water system or into reservoirs (San Bernardino Valley Water Conservation District, 2021).

Purchased or Imported Water: Imported water from the SWP is available for the MUED to purchase from Valley District when needed. The MUED has purchased supplemental water from the SWP only in years when surface water flows have not been able to meet demands and on occasion when surface water supplies are turbid and require blending or for other operational purposes. The MUED contributes to regional efforts to Redlands Regular Meeting of 06-03-25
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recharge the Bunker Hill groundwater basin with SWP water and local surface water in wet years when available so that storage is available for use in dry years when other supplies may be limited (San Bernardino Valley Water Conservation District, 2021).

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

Water from the Mill Creek watershed is treated at Henry Tate Surface Water Treatment Plant. Water from the Santa Ana River watershed is treated at the Horace P. Hinckley Surface Water Treatment Plant. The MUED has ownership in a variety of private and mutual water companies to supply water to the City’s Tate and Hinckley Surface Water Treatment Plants (San Bernardino Valley Water Conservation District, 2021).

Recycled Water: The City’s Wastewater Treatment Plant has the capability of treating 7.2 million gallons per day (mgd) of wastewater to a Title 22 Recycled Water level (San Bernardino Valley Water Conservation District, 2021). The City’s recycled water customers include Southern California Edison, a landfill, and recycled/non-potable water customers. Southern California Edison uses recycled water for its Mountain View Power Plant and recycled water customers use recycled water for irrigation.

Water Infrastructure
The City’s water treatment plants include the Henry Tate Water Treatment Plant and the Horace Hinckley Surface Water Treatment Plant. The Henry Tate Water Treatment Plant is a conventional water treatment plant built in 1967. These facilities treat surface water and groundwater to meet drinking water standards.

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

Approved General Plan Buildout Water Demand
Within the Project site, there are currently 111 planned dwelling units and approximately 2,209,041 SF of planned non-residential development. Residential uses comprise approximately 29 percent of the water demand in the Project area and non-residential uses comprise approximately 71 percent of the water demand. Buildout of the Project area according to the current General Plan would have an annual water usage of approximately 211 AF (Appendix G).

5.12.3.2 Wastewater
Wastewater Infrastructure
Sewer service on the Project site is provided by the City of Redlands. The City’s Wastewater Treatment Plant (WWTP) is located on the south side of the Santa Ana River Wash at Nevada Street. The City’s WWTP has the capacity to treat up to 9.5 mgd. The City’s WWTP includes two treatment systems: a membrane bioreactor with a capacity of 6.0 mgd for producing recycled water, and an activated sludge process with a capacity of 3.5 mgd. The WWTP’s total permitted annual average flow is 9.5 mgd and it has an average daily flow around 6 mgd. (Appendix H).

In 2020, 6,620 AF of wastewater was treated at the City’s WWTP. In 2020, 3,813 AF were treated to a secondary level and released to spreading basins east of the City’s WWTP for percolation into the Bunker Redlands Regular Meeting of 06-03-25
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Hill groundwater basin, while 1,806 AF were treated to a tertiary level and distributed as recycled water (San Bernardino Valley Water Conservation District, 2021).

The wastewater system has one lift station that serves the western-most portion of the city, south of Interstate 10 (I-10). The collections system in the City of Redlands consists of approximately 245 miles of pipelines.

Wastewater pipelines range from 6-inches to 48-inches in diameter (Appendix H).

Approved General Plan Buildout Wastewater Generation
Within the Project site, there are currently 111 planned dwelling units and approximately 2,209,041 SF of planned non-residential development. Buildout of the Project area according to the current General Plan would have an annual wastewater generation of approximately 358 AFY (Appendix H).

5.12.3.3 Stormwater
Stormwater Infrastructure
The City of Redlands’ stormwater drainage system serves an area of approximately 37 square miles.

Stormwater runoff from the City’s drainage systems flows by gravity into the Mission Channel, Morrey Arroyo Creek, and San Timoteo Canyon, and discharges to the Santa Ana River (City of Redlands, 2017a).

Drainage throughout the City is generally from east to west to one of two main existing major stormwater drainage facilities. The City is divided into five main watersheds: Mission Zanja, Reservoir Canyon, Downtown, North Redlands along the Santa Ana River, and South Redlands along the San Timoteo Channel.

Sites 1-16A and 24 are located within the South City subwatershed and Sites 17-23 are located within the North City subwatershed. The North City subwatershed contains both open channel and subsurface storm drain facilities. The facilities located within the North City generally drain to the Santa Ana River. The South City subwatershed contains both open channel and subsurface storm drain facilities. The facilities generally drain to Mission Creek, south of Citrus Avenue/West State Street (RBF Consulting, 2014).

Approved General Plan Buildout Stormwater Drainage
Within the Project site, there are currently 111 planned dwelling units and approximately 2,209,041 SF of planned non-residential development. Similar to the proposed Project, buildout of the approved General Plan would result in an increase in impervious surface area. Stormwater drainage improvements would be evaluated on a project-by-project basis as development occurs pursuant to the General Plan. Implementation of development projects pursuant to the General Plan would increase the intensity of development within the City, and future site-specific development projects would install onsite stormwater drainage infrastructure and new connections to the existing stormwater drainage system.

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

UT-1 Require or result in the relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

UT-2 Not have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

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UT-3 Result in a determination by the wastewater treatment provider that would serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

UT-4 Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

UT-5 Not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

The Initial Study (included as EIR Appendix A) established that the proposed Project would not result in potentially significant impacts related to Thresholds UT-4 and UT-5; therefore, no further assessment of these thresholds is required in this Draft EIR. As discussed at the beginning of this section, energy related facilities such as electric power, natural gas, and telecommunications facilities are evaluated in Section 5.4, Energy, of this Draft SEIR; therefore, Impact UT-1 in this section evaluates water, wastewater treatment, and stormwater drainage facilities.

5.12.5 METHODOLOGY
This analysis focuses on the nature and magnitude of the change in the demand for utilities and services due to implementation of the proposed Project, based on comparison of the maximum development assumptions from buildout of the approved General Plan land uses and from buildout of the proposed Project, as outlined in Section 3.0, Project Description. The WSA prepared for the proposed Project estimated the Project’s water demands using the developed acreage attributed to each use type (including landscape irrigation and parking area requirements). The total developed area was prorated based on the building square footage for each use type. Water demands were then estimated for the Project using land use-based water demand factors from the City of Redlands’ “Water and Sewer Demands Spreadsheet.” The land use demand factors are applied to gross estimated acreage for each land use. The evaluation of utilities identifies if utility demand from the proposed Project would be accommodated via existing utility infrastructure available to the proposed Project. The evaluation identifies if expansions would be required to serve the proposed development, and if those expansions have the potential to result in an environmental impact.

5.12.6 ENVIRONMENTAL IMPACTS
Summary of Impacts Identified in the General Plan EIR
The Certified General Plan EIR addressed impacts related to utilities and service systems in Chapter 3.14.

The Certified EIR found that while buildout of the General Plan would result in increased demand for public utility services, compliance with federal, State, and local water and wastewater regulations and the proposed General Plan policies would reduce potential impacts on water and wastewater service needs and infrastructure needs to less-than-significant levels. The General Plan EIR concluded that compliance with the City’s current grading, drainage, and stormwater regulations would ensure that any new facilities required to manage stormwater in the Planning Area would have a less-than-significant impact on the environment (City of Redlands, 2017b, pg. 3.14-19).

Proposed Project
The proposed Project would rezone 24 sites for the purpose of increasing residential development capacity.

Buildout of the proposed Project would change the maximum buildout of the Project area from 828,349.93 SF of warehouse (commercial/industrial), 828,349.93 SF of retail (commercial/industrial), 111 multi-family dwelling units, 276,170.4 SF of office (commercial), and 276,170.4 SF of retail (commercial) uses to Redlands Regular Meeting of 06-03-25
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residential uses with an allowed capacity of 2,436 units and approximately 151,048.46 SF of Public/Institutional uses. Housing types may include detached single-family dwellings with one or more dwellings per lot, two-family dwellings (two attached dwellings), and multi-family dwellings (three or more attached dwellings).

IMPACT UT-1: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR

CONSTRUCTION OF NEW OR EXPANDED WATER, WASTEWATER TREATMENT, OR

STORM WATER DRAINAGE FACILITIES, THE CONSTRUCTION OR RELOCATION OF WHICH COULD CAUSE SIGNIFICANT ENVIRONMENTAL EFFECTS.

Less than Significant Impact.

Water
The proposed Project would rezone the approximately 116-acre Project site with residential and public/institutional uses, on sites which are currently served by MUED’s water infrastructure. As discussed above, roadways surrounding the Rezone sites contain multiple water pipelines ranging in size from 1 inch to 36 inches in diameter. These water pipelines currently provide water supplies to the Project site and surrounding adjacent areas.

As discussed below under impact UT-2, the water facilities currently serving the Rezone sites would likely be sufficient to accommodate the additional residential development proposed by the Project. However, future developments proposed under the Project could necessitate further water infrastructure, including new water connections, water pumps, and other improvements to water utilities within the Rezone sites and within adjacent utility rights-of-way. Local improvements are anticipated; however, extensive offsite utility improvements are not anticipated to be required for buildout pursuant to the proposed Project.

The new onsite water systems would convey potable and non-potable water supplies to the proposed residential uses, public/institutional uses, and landscaping through plumbing/landscaping fixtures that are compliant with the CALGreen Plumbing Code for efficient use of water and with Municipal Code Chapter

15.54. Implementation of development projects pursuant to the proposed Project would increase the intensity of residential land uses within the Project area, and future site-specific development projects would install on- site water infrastructure and new connections to the water system that could include improvements to aged water pipelines and other connecting infrastructure. Such improvements would be required to be sized to accommodate the water demand of such new developments.

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

The construction of any needed water system improvements as part of future site-specific development projects under the proposed Project would generally occur from project sites to existing connection points in roadway rights-of-way and would be required to comply with all Redlands Municipal Code standards and Draft Subsequent EIR mitigation measures listed throughout this document. These requirements would ensure that construction related impacts remain less than significant. As a result, buildout of the proposed Project would not result in construction of new or expanded wastewater facilities that could result in a significant environmental effect, and impacts would be less than significant. As such, Project impacts would be consistent Redlands Regular Meeting of 06-03-25
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with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to utilities would be less than significant.

Wastewater
The proposed Project would rezone the approximately 116-acre Project site with residential and public/institutional uses, on sites which are currently served by the City’s WWTP. As discussed above, the collections system in the City of Redlands consists of approximately 245 miles of pipelines with pipes ranging from 6-inches to 48-inches in diameter (Appendix H). These sewer pipelines currently provide sewer services to the Project site and surrounding adjacent areas.

As compared to the existing General Plan buildout, the proposed development of the proposed Project would result in minor increases in the wastewater amount to the City’s existing sewer systems, as shown below on Table 5.12-3. As shown, buildout pursuant to the proposed Project would result in an increase in wastewater generation of approximately 0.172, which is equivalent to 0.32 cubic feet per second (cfs).

Further, using the peaking factor of the City’s Sewer System Standard Plans the net peak flow would be

0.27 x 3.2, which is 1.0 cfs (Appendix H).

Table 5.12-3: Net Change in Wastewater Generation for Project Site Gallons per Day Million Gallons per Day Acre Feet per Year Proposed Project Demand 339,938 0.34 381
Existing GPU Buildout Demand 167,708 0.17 188
Net Change 30,585 0.172 193
Source: Appendix H
Based on the sewer systems standards, sewer pipes larger than 12-inches in diameter are designed to flow up to 75%-full. Therefore, since most of the existing sewer systems are flowing at or less than 50%-full, there is additional capacity to handle an increase in wastewater (Appendix H). Table 5.12-4 below shows the City’s available wastewater capacity and illustrates that the existing wastewater infrastructure would be sufficient to serve the proposed Project.

Table 5.12-4: Available Wastewater Capacity in the City of Redlands Existing Sewer Reach Additional Peak Capacity
21-Inch VCP (Nevada Street, San Bernardino Avenue) 2.29 CFS 24-inch VCP (Nevada Street) 2.99 CFS
30-inch VCP (Nevada Street) 4.55 CFS
Net Increase in Peak Flow 1.0 CFS (0.54 mgd)
Therefore, based on the nominal net increase in average sewer flow of 0.172 mgd, and increase in peak sewer flow of 0.54 mgd (1.0 cfs), it is expected that the proposed Project would not adversely affect the City’s WWTP.

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

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The construction of any needed wastewater system improvements as part of future site-specific developments under the proposed Project would generally occur from project sites to existing connection points in roadway rights-of-way and would be required to comply with all Redlands Municipal Code standards and Draft Subsequent EIR mitigation measures throughout this document. These requirements would ensure that construction related impacts remain less than significant. As a result, potential impacts related to the buildout of the proposed Project would not result in construction of new or expanded wastewater facilities that could result in a significant environmental effect, and impacts would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to utilities would be less than significant.

Stormwater
Buildout pursuant to the proposed Project would result in an increase in 2,325 residential units and a decrease of 2,057,992.20 SF of nonresidential development. As the individual RHNA Rezone sites are already slated for urban development, buildout pursuant to the Project would not result in increase of impervious area compared to buildout pursuant to the existing General Plan designations. As a result, the Project would not result in increased flows compared to current potential buildout.

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

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

The construction of any needed drainage system improvements as part of future site-specific development projects under the proposed Project would generally occur from project sites to existing connection points in roadway rights-of-way. Additional, large-scale stormwater drainage improvements pursuant to the 2017 Redlands Master Plan of Drainage and implementing project site-specific stormwater drainage improvements would be required to comply with all Redlands Municipal Code standards and Draft Subsequent EIR mitigation measures, which would ensure that impacts would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to utilities would be less than significant.

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

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

Less than Significant Impact. Buildout pursuant to the proposed Project would result in an increase in 2,325 residential units (approximately 6,162 residents) and a decrease of 2,057,992.20 SF of nonresidential development. As shown in Table 5.12-5 the proposed Project would result in a total demand of 457 AFY, which would be a 231 AFY increase in comparison to water demands associated with the buildout of the approved General Plan within the Project area.

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Table 5.12-5: Net Change in Water Demands for Project Site Gallons per Day Acre Feet per year
Proposed Project Demand 407,817 457
Existing GPU Buildout Demand 201,249 225
Net Change 206,568 231
Source: Appendix G
The MUED’s 2020 IRUWMP assumed that the MUED’s total water supply would increase from 28,098 AF in 2020 to 33,436 AF in 2035, which constitutes an increase of 5,338 AF. Additionally, as shown in Table 5.12- 6, the projected MUED normal year water demand would increase from 26,866 AF in 2020 to 29,075 AF in 2035.

Table 5.12-6: Projected MUED Water Demand (AF)
2020 2025 2030 2035 2040 2045
Potable and Raw Water 25,892 25,818 26,860 27,902 28,818 29,735 Recycled Water 994 1,173 1,173 1,173 1,173 1,173
Total Water Demand 26,866 26,991 28,033 29,075 29,991 30,908 Source: San Bernardino Valley Water Conservation District, 2021 The IRUWMP assessed the projected water demand and supply in the service area and concluded that MUED has an adequate water supply to meet all demands within its service area to 2045 under varying drought conditions. The Project’s additional demands of 231 AFY, as listed in Table 5.12-5, is less than the assumed increase in demands in the IRUWMP; therefore, the Project’s relatively small increase in water demand would not cause demand to exceed the 2035 or 2045 projected demands for the MUED.

Additionally, implementing projects would be required to implement California Green Building Code policies regarding water efficiency standards for all new plumbing and irrigation fittings and fixtures.

Based on the above, it is anticipated that existing and future water entitlements from groundwater, surface water, purchased or imported water sources, and recycled water would be sufficient to meet the Project’s demand at buildout, in addition to forecast demand for MUED’s entire service area. Thus, impacts related to the need for new or expanded water supplies and entitlements would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to utilities would be less than significant.

IMPACT UT-3: THE PROJECT WOULD NOT RESULT IN A DETERMINATION BY THE WASTEWATER

TREATMENT PROVIDER THAT WOULD SERVE THE PROJECT THAT IT DOES NOT HAVE ADEQUATE CAPACITY TO SERVE THE PROJECT’S PROJECTED DEMAND IN ADDITION TO THE PROVIDER’S EXISTING COMMITMENTS.

Less than Significant Impact. Future buildout of the proposed Project would result in increased wastewater generation from Rezone sites. Based on Table 5.12-3, Net Change in Wastewater Generation for Project Site, above, the proposed Project would result in a net increase of 30,585 gallons per day (0.031 mgd) or 34 AFY compared to the buildout of the existing General Plan.

Wastewater from the Project Site is treated at the WWTP, which has a treatment capacity of 9.5 mgd (City of Redlands, 2017a). In 2020, the WWTP collected 6,620 AF (5.8 mgd) for treatment (San Bernardino Valley Water Conservation District, 2021). Therefore, the WWTP has a residual capacity of 3.7 mgd.

The amount of additional wastewater that would be generated by the proposed Project is less than one percent of WWTP’s total remaining daily treatment capacity. As a result, the WWTP serving the Project Redlands Regular Meeting of 06-03-25
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would have adequate capacity to serve the demand resulting from buildout pursuant to the proposed Project in addition to existing service commitments, and impacts would be less than significant. As such, Project impacts would be consistent with the impact conclusions set forth in the General Plan EIR, which determined that impacts related to utilities would be less than significant.

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

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

As discussed above, buildout pursuant to the proposed Project would result in an increase in water demand of 231 AFY. It is anticipated that existing and future water entitlements from groundwater, surface water, purchased or imported water sources, and recycled water, plus water conservation methods included in Title 24, would be sufficient to meet the proposed Project’s demand at buildout, in addition to forecast demand for MUED’s entire service area. As a result, the Project would not result in a cumulatively considerable increase in water supply demands that would require new or expanded entitlements, and cumulative impacts would be less than significant.

Wastewater
Cumulative wastewater infrastructure impacts are considered on a systemwide basis and are associated with the overall capacity of existing and planned infrastructure. The cumulative system evaluated includes the City’s WWTP and sewer system that serves the Project site.

As described previously, the existing sewer system and WWTP would have sufficient capacity to handle the flows resulting from implementation of the proposed Project. The continued regular assessment, maintenance, and upgrades of the sewer system by the City would reduce the potential of cumulative development projects to result in a cumulatively substantial increase in wastewater such that new or expanded facilities would be required. Thus, increases in wastewater in the sewer system would result in a less-than-significant cumulative impact.

Stormwater
The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area served by the existing stormwater infrastructure for the Project area, from capture of runoff through final discharge points. Unless a project is within a hydromodification exemption area, State and regional regulations require development projects to maintain pre-project hydrology, such that no net increase of off- site stormwater flows would occur. Santa Ana RWQCB permit conditions require a hydrology/drainage study to demonstrate that proposed storm drain systems are able to detain a minimum “Design Capture Volume,” which is dependent on the specific characteristics of each site. As a result, increases in runoff from cumulative projects that could combine to impact stormwater drainage capacity would be minimized, and cumulative impacts related to drainage infrastructure would be less than significant.

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5.12.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES Existing Regulations
The following standard regulations would reduce potential impacts related to water supplies:
• California Code of Regulations Title 24, Part 11; the California Green Building Code • Chapter 15.54 of the Redlands Municipal Code
Plans, Programs, or Policies
None.

5.12.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, Impacts UT-1, UT-2 and UT-3 would be less than significant.

5.12.10 MITIGATION MEASURES
None.

5.12.11 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts related to utilities and service systems would be less than significant.

5.12.12 REFERENCES
City of Redlands. (2017a). Redlands General Plan 2035. Retrieved July 2, 2024, from https://www.cityofredlands.org/post/planning-division-general-plan City of Redlands. (2017b). City of Redlands General Plan Update and Climate Action Plan Environmental Impact Report. Retrieved July 2, 2024, from https://www.cityofredlands.org/sites/main/files/file- attachments/redlands_deir_compiled_lo_071917_0.pdf?1554321669 City of Redlands. (2024a). City of Redlands Municipal Code. Retrieved July 2, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 City of Redlands. (2024b). Sanitary Sewer Systems Standard Specifications. Retrieved July1, 2024, from https://www.cityofredlands.org/sites/main/files/file-
attachments/sewer_systems_standard_specs_2024.pdf?1709143615 City of Redlands. (n.d.). Utilities. https://www.cityofredlands.org/utilities-0 Fuscoe Engineering. (2024a). Redlands RHNA Rezone Water Supply Assessment. (Appendix G) Fuscoe Engineering, Inc. (2024b). Redlands RHNA Rezone Proposed Conditions Infrastructure Report for Water and Sewer. (Appendix H)
RBF Consulting. (2014). C ity of Redlands Drainage Master Plan. Accessed:
https://www.cityofredlands.org/sites/main/files/file-
attachments/drainage_master_plan_2014.pdf?1584549796
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San Bernardino Valley Water Conservation District (May 2021 ). 2020 Upper Santa Ana River Watershed Integrated Regional Urban Water Management Plan.
https://www.cityofredlands.org/sites/main/files/file-
attachments/part_2_chapter_4_redlands_2020_uwmp.pdf?1622145365 Redlands Regular Meeting of 06-03-25
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5.13 Mandatory Findings of Significance

5.13.1 SIGNIFICANT AND UNAVOIDABLE IMPACTS
Section 15126.2(b) of the CEQA Guidelines requires an EIR to describe “any significant impacts, including those which can be mitigated but not reduced to a level of insignificance.” As described in detail in Section

5.0 of this Draft EIR, implementation of the Project would result in environmental impacts that cannot be reduced to a level below significance after implementation of project design features, regulatory requirements, Plans, Programs, and Policies (PPPs), and feasible mitigation measures for the below topics.

Agriculture and Forestry
Impact AG-1, Conversion of Significant Farmland. The Project site contains approximately 44.67 acres of Prime Farmland. The Project would result in conversion of the Prime Farmland to non-agricultural uses. There are no feasible mitigation measures to reduce impacts associated with the Project’s conversion to nonagricultural uses. Therefore, impacts would be significant and unavoidable.

Impact AG-5, Other Changes Resulting in Conversion of Farmland. Project implementation would result in the conversion of farmland onsite to nonagricultural use and would facilitate the conversion of farmland within the vicinity to nonagricultural use. Although implementation of the Project would result in the conversion of agricultural use on the site, the surrounding areas to the north, east, and west are proposed to be developed with uses other than for agricultural purposes. Nevertheless, the areas currently under agricultural production are privately owned and development of the site could result in an increased development pressure on the surrounding agricultural sites. Therefore, the Project would indirectly cause changes in the environment that would convert Farmland not within the Project site to nonagricultural use. There are no feasible mitigation measures to reduce impacts associated with the Project’s conversion to nonagricultural uses. Therefore, impacts would be significant and unavoidable.

Air Quality
Impact AQ-1, Conflict with AQMP (Project, Cumulative). As detailed in Section 5.2, Air Quality , due to the uncertainty of the timing and methods of construction activities related to RHNA Rezone development projects, a significant impact could occur related to construction emissions of VOCs and NOx, despite implementation of South Coast Air Quality Management District (SCAQMD) rules and mitigation measures.

In addition, operation of the proposed Project at buildout would result in exceedance of the applicable SCAQMD thresholds for VOC, NOx, CO, PM 10, and PM 2.5 after implementation of mitigation. There is no guarantee that emissions for construction and operation would be mitigated below SCAQMD thresholds, therefore, emissions generated from implementation of the proposed RHNA Rezone would be significant and unavoidable. Also, because the emissions would exceed thresholds, the Project would result in a conflict with implementation of the AQMP and impacts related to the AQMP would also be significant and unavoidable.

Impact AQ-2, Regional Construction & Operational Emissions (Project, Cumulative). Emissions from the construction of the implementing projects have the potential to overlap, which could result in a significant impact after implementation of SCAQMD rules and Mitigation Measure AQ-1. Emissions from operation of the proposed Project at buildout would exceed SCAQMD’s thresholds for CO, VOC, and NOx after implementation of regulations and Mitigation Measure AQ-2 because a majority of operational-source CO and NOx emissions (by weight) would be generated by vehicle trips, and the VOC emissions would be generated by consumer products that neither future Project applicants nor the City have the ability to reduce emissions of. Therefore, operational-source CO, VOC, and NOx emissions from implementation of the Redlands Regular Meeting of 06-03-25
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proposed Project would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable.

Impact AQ-3, Localized Construction Emissions (Project, Cumulative). Implementation of developments pursuant to the Project could result in localized emissions that exceed air quality standards. Thus, implementation of the Project could result in a significant impact related to localized significance thresholds (LSTs). As a result, Mitigation Measure AQ-1 is included, which requires development projects to provide modeling of localized emissions (NO
X, CO, PM 10, and PM 2.5) associated with the maximum daily grading activities for the proposed development; and requires use of Tier 3 or Tier 4 construction equipment.

However, future project specific construction activities are currently unknown, and therefore, impacts were determined to be potentially significant. Impacts related to localized construction air quality impacts would be significant and unavoidable despite implementation of Mitigation Measure AQ-1.

Greenhouse Gas Emissions
Impact GHG-1, Greenhouse Gas Emissions (Project, Cumulative). As described in Section 5.5, Greenhouse Gas Emissions , operation of the Project at buildout and full occupancy would generate 23,660.41 MTCO 2e per year, which equates to a CO 2e per service population of 3.56. This would be substantially less than the emissions generated from buildout of the existing General Plan land uses, but would continue to exceed the threshold of 3.0. Thus, operational impacts would be significant. Even with implementation of Mitigation Measures AQ-1 and AQ-2, emissions would continue to exceed regional thresholds of significance established by the SCAQMD, and impacts would be significant and unavoidable.