Impact GHG-2, Conflict with GHG Reduction Plan (Project, Cumulative). The proposed Project would have the potential to be inconsistent with key project attributes from the 2022 Scoping Plan Appendix D, Local Actions, which could combine with potential inconsistencies from 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.
Transportation
Impact TR-2, Vehicle Miles Traveled (Project). As detailed in Section 5.10, Transportation, all TAZs within the Project Site are either within a TPA or a low-VMT area or would meet Criteria 3 based on local serving uses, except for TAZs 53835402 and 53835101, which include Sites 20, 21, and 23. As such, implementing development pursuant to the proposed Project in all TAZs except Sites 20, 21, and 23 would be less than significant. However, future development projects within Sites 20, 21, and 23 would be required to conduct a project-specific VMT screening analysis to determine whether the development would screen out of a further VMT analysis pursuant to Mitigation Measure T-1. Should the development not screen out of a VMT analysis, the project would be required to conduct a full VMT analysis and implement further 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.
5.13.2 GROWTH INDUCEMENT
This section analyzes the growth inducement potential of the proposed Project and the associated secondary effects of growth the Project might permit. As required by CEQA Guidelines Section 15126.2(d), an EIR must:
“Discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.
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Included in this are projects which would remove obstacles to population growth (a major expansion of a recycled water plant might, for example, allow for more construction in service areas). Increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. Also discuss the characteristic of some projects which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.” Thus, based on CEQA, a project could have a direct effect on population growth, for example, if it would involve construction of substantial new housing. A project could also have indirect growth-inducement potential if it would:
• Establish substantial new permanent employment opportunities (e.g., commercial, industrial, governmental, or other employment-generating enterprises) or otherwise stimulate economic activity such that it would result in the need for additional housing, businesses, and services to support increased economic activities;
• Remove obstacles to growth, e.g., through the construction or extension of major infrastructure facilities that do not presently exist in the project area, or would add substantial capacity that could accommodate additional unplanned growth;
• Remove obstacles to growth through changes in existing regulations pertaining to land development; • Result in the need to expand one or more public service facilities to maintain desired levels of service; or
• Involve some other action that could encourage and facilitate other activities that could significantly affect the environment.
As CEQA Guidelines Section 15126.2(d) states that growth-inducing effects are not to be construed as necessarily beneficial, detrimental, or of little significance to the environment, the following information is provided as additional information on ways in which the proposed Project could contribute to significant changes in the environment beyond the direct consequences of developing the land use concepts examined in the preceding sections of this Draft Subsequent EIR.
Establish substantial new permanent employment opportunities or otherwise stimulate economic activity such that it would result in the need for additional housing, businesses, and services to support increased economic activities
The proposed RHNA Rezone Project would rezone 23 sites within the City to allow for increased residential development, Site 24 would be rezoned to Public/Institutional zoning in order to achieve compatibility with the sites existing uses. SCAG estimates that employment in the City will increase from 49,900 jobs in 2019 to 60,100 in 2050, which is an increase of over 21 percent (SCAG, 2024b). The employment anticipated by the proposed Project would generate approximately 550 new employees (see Section 5.8, Population and Housing), which represents about 5 percent of the estimated job growth by 2050. The 550 jobs expected in the Project area are included in SCAG projections because the employment-generating land uses within the Project area is existing pursuant to current General Plan land use designations and is decreasing with implementation of the Project. Thus, the employment that would occur within the Project area would be less than significant.
The new Project would accommodate the forecasted employment in an environmentally sustainable manner by providing for additional housing to maintain the jobs to housing balance, which would reduce citywide VMT. Also, as listed below, the City of Redlands has had recent unemployment rates ranging between 3.1 and 7.6 percent (EDD, 2024).
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Table 5.13-1: City of Redlands Unemployment Rates
Date Unemployment Rate Percent
June 2024 4.0 percent
2023 Annual Average 4.4. percent
2022 Annual Average 3.1 percent
2021 Annual Average 5.5 percent
2020 Annual Average 7.6 percent
2019 Annual Average 3.1 percent
Source: EDD, 2024
The City of Redlands is estimated by SCAG to have a population increase of 18.0 percent between 2019 and 2050 1, and San Bernardino County is estimated to have a population growth rate of 20.6 percent over the same period of time (SCAG, 2024b). Buildout of the proposed Project would contribute to approximately
49.4 percent of the projected population growth, approximately 79.96 percent of the projected housing stock growth, and approximately 5 percent of the projected employment growth in the City. 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. Additionally, the projected employment growth that would occur from buildout of the Project would not exceed employment growth projections for the City.
Further, SCAG determined the City needs to provide a total of 3,516 housing units to meet their RHNA. Thus, the Project would contribute to the City’s fair share of housing and, in part, satisfy the State requirements to provide new housing opportunities to increase housing supply. Additionally, the proposed Project implements goals and policies of the Redlands Housing Element that support a variety of housing types and densities.
Therefore, the economic effects of the proposed Project would not result in the need for additional development to support the proposed Project and would not result in a substantial impact on the environment.
Remove Obstacles to Growth, e.g., Through the Construction or Extension of Major Infrastructure Facilities that do not Presently Exist in the Project Area or Would Add Substantial Capacity that Could Accommodate Additional Unplanned Growth.
The elimination of a physical obstacle to growth is considered to be a growth inducing impact. A physical obstacle to growth typically involves the lack of public service infrastructure. The proposed Project would induce growth if it would provide public services or infrastructure with excess capacity to serve lands that would otherwise not be developable.
The RHNA Rezone area is a developed urban area that is connected to the City’s existing infrastructure system. Water, sewer, drainage, and roadway infrastructure currently provides service to all of the areas within the Project. As described in Section 5.12, Utilities and Service Systems, development projects pursuant to the RHNA Rezone would include potential installation of onsite infrastructure and new connections to the existing infrastructure systems, which include improvements to existing aged infrastructure such as increasing the size of water and sewer lines. However, these improvements would be sized to accommodate individual developments and would not provide excess capacity. As described in Section 5.12, Utilities and Service Systems, future projects pursuant to the RHNA Rezone Project would not require extension of utilities into undeveloped areas. Furthermore, buildout pursuant to the Project would not result in the extension of any 1 The 2050 population estimate was derived using the methodology presented in Section 4.5 of the SCAG Demographics & Growth Forecast which states an estimate of the future City-level population based on Connect SoCal’s household forecast can be derived using a county-level Population:Housing ratio from Table 12 and applying it to the City’s future household growth (SCAG, 2024b).
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roadways into undeveloped areas as the rezone sites are surrounded by existing roadways. Therefore, the infrastructure improvements implemented by the Project would not result in unplanned growth.
Remove Obstacles to Growth Through Changes in Existing Regulations Pertaining to Land Development A project could directly induce growth if it would remove barriers to population growth such as changes to a jurisdiction's general plan and zoning code, which allows new development to occur in underutilized areas.
The proposed Project includes amending the City of Redlands General Plan to change the land use designations of 23 sites to allow for additional residential development and a Specific Plan Amendment to remove 15 of the Rezone sites out of the East Valley Corridor Specific Plan (EVCSP). However, pursuant to the RHNA prepared by the California Department of Housing and Community Development (HCD), the City of Redlands must increase their residential zoning capacity to accommodate their 0.26% share that is 3,516 units of the RHNA (City of Redlands, 2022, P.2).
Additionally, SCAG household growth projections estimate that between 2019 and 2050 the number of housing units within the City will grow by 17.9 percent (5,600 units). Assuming that the maximum number of residential units allowed by the proposed Project are developed and occupied (no vacancy), the 2,325 additional housing units in the Project area would consist of a 9.1 percent increase of housing units citywide, which is within the SCAG anticipated growth of both the City and the County (SCAG, 2020b). Therefore, impacts related to growth from changes in existing regulations pertaining to land development would not occur.
Result in the Need to Expand One or More Public Service Facilities to Maintain Desired Levels of Service The proposed Project is expected to incrementally increase the demand for fire protection and emergency response, police protection, and school services. However, as detailed in Section 5.9, Public Services, the proposed Project would not require development of additional facilities or expansion of existing facilities to maintain existing levels of service. Based on service ratios and buildout projections, the proposed Project would not create a demand for services beyond the capacity of existing facilities or plans. Therefore, an indirect growth inducing impact as a result of expanded or new public facilities that could support other development in addition to the proposed Project would not occur. The proposed Project would not result in significant growth inducing consequences that would require the need to expand public services to maintain desired levels of service.
Involve Some Other Action that Could Encourage and Facilitate Other Activities that Could Significantly Affect the Environment
The proposed Project does not propose changes to any of the City’s building safety standards (i.e., building, grading, plumbing, mechanical, electrical, or fire codes). The development implemented pursuant to the proposed Project would be required to comply with all applicable City plans, policies, and ordinances. In addition, mitigation measures have been identified within this Draft EIR to ensure that the Project minimizes environmental impacts. The Project would not involve any precedent-setting action that could encourage and facilitate other activities that significantly affect the environment.
Environmental Impacts of Induced Growth
All physical environmental effects from construction of buildout pursuant to the proposed Project have been analyzed in the technical sections of this Draft Subsequent EIR and the Initial Study prepared for this Project (included as Appendix A). For example, activities such as excavation, grading, and construction as required for the buildout of the Project have been evaluated herein. Also, all operational aspects of future development pursuant to the Project have been analyzed in this Draft Subsequent EIR and through implementation of existing regulations, including the General Plan and zoning ordinance, would not create an environmental impact of induced growth.
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5.13.3 SIGNIFICANT IRREVERSIBLE EFFECTS
State CEQA Guidelines require the EIR to consider whether “uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely…. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.” (CEQA Guidelines Section 15126.2(c)). “Nonrenewable resource” refers to the physical features of the natural environment, such as land, waterways, mineral resources, etc. These irreversible environmental changes may include current or future uses of non-renewable resources, and secondary or growth-inducing impacts that commit future generations to similar uses.
Generally, a project would result in significant irreversible environmental changes if:
• The primary and secondary impacts would generally commit future generations to similar uses; • The project would involve a large commitment of nonrenewable resources; • The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project; or • The proposed irretrievable commitments of nonrenewable resources is not justified (e.g., the project involves the wasteful use of energy).
Agriculture
The Project site contains approximately 44.67 acres of Prime Farmland. The Project could result in conversion of the Prime Farmland to non-agricultural uses with buildout pursuant to the proposed rezoning. There are no feasible mitigation measures to reduce impacts associated with the Project’s conversion of this farmland to nonagricultural uses. Therefore, impacts would be significant and unavoidable.
Project implementation would result in the conversion of existing 44.67 acres of Farmland at the Project site to nonagricultural use and could facilitate the conversion of Farmland within the vicinity to nonagricultural use. Development of the Project site could result in increased development pressure on the surrounding agricultural sites. Therefore, the Project could indirectly cause changes in the environment that could convert other farmland 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.
Construction Impacts
Construction of implementing development projects pursuant to the proposed Project would result in the consumption of building materials, including lumber, sand, and gravel for construction. Depletion of non- renewable resources that supply building materials would represent an irreversible environmental change.
5.13.4 EFFECTS FOUND NOT TO BE SIGNIFICANT
CEQA Guidelines Section 15126.2(a) states that “[a]n EIR shall identify and focus on the significant effects on the environment.” However, CEQA Guidelines Section 15128 requires that an EIR contain a statement briefly indicating the reasons that various possible effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR. The following environmental issue areas would not be potentially impacted by the proposed Project, as detailed below and in the Initial Study prepared for the Project, which is included as Draft EIR Appendix A.
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Aesthetics
The Rezone sites are in developed areas and are not designated as having a Resource Preservation land use category and are not located within a Historic or Scenic Preservation District. The Project area does not contain scenic vistas and potential future developments would be within the heights of existing developed areas to be consistent with views presently found in the area.
Additionally, there are currently no designated State scenic highways within the vicinity of the Project site.
Future projects would also include specific setbacks, lighting standards, and building materials that would ensure the avoidance of potential lighting impacts. Further, all future projects would be required to comply with the City’s General Plan Policy 2-A.35 which develops standards for exterior lighting for new developments and would be verified through plan check prior to project approval.
Biological Resources
Implementation of the Project would implement infill development within an already highly disturbed urban environment and would not result in any direct impacts to special status species, nor involve or result in any existing habitat modifications that could indirectly result in a substantial adverse effect on any special status species. Furthermore, while it is not expected that the Rezone sites would support suitable habitat for rare plant and animal species, General Biological Surveys would be performed for future development projects within the proposed Project site to confirm whether suitable habitat exists, as outlined in Initial Study Mitigation Measure BIO-1 (included as Appendix A to this DSEIR). If rare plants/wildlife are identified and cannot be avoided, the project-level biological survey report shall justify why species-specific mitigation is necessary and propose mitigation to reduce project impacts to a less-than-significant level.
Several Project sites are located near the Morey Arroyo riverine, which is a riparian habitat according to the USFWS National Wetland Inventory. Therefore, future developments related to the proposed Project within the Rezone sites shall require a biological survey for jurisdictional features prior to the approval of any development applications, as outlined in Initial Study Mitigation Measure BIO-2 (included as Appendix A to this DSEIR). If resources under CDFW, USACE, and/or RWQCB jurisdiction are identified, impacts should be avoided where feasible. Where avoidance is not feasible, project-specific impacts to jurisdictional resources would be mitigated by federal and State regulators via the applicable consulting and permitting process. With implementation of Initial Study Mitigation Measure BIO-2 (included as Appendix A to this DSEIR), impacts to federally protected wetlands would be less than significant.
No wildlife corridors, native wildlife nursery sites, or bodies of water in which fish are present are located within the Project site or in the surrounding area. However, mature trees are scattered throughout the area.
Although the trees are mainly ornamental and nonnative, they may provide suitable habitat, including nesting habitat, for migratory birds. The City requires that all projects comply with the Migratory Bird Treaty Act of 1918 (MBTA) by either avoiding grading activities during the nesting season (February 15 to August 15) or conducting a site survey for nesting birds prior to commencing grading activities. Projects implemented under the Project would be required to comply with the provisions of the MBTA. With adherence to the MBTA requirements, less than significant impacts would occur.
Implementation of the Project is not anticipated to conflict with the provisions of Redland’s Street Tree Policy and Protection Guidelines Manual and the tree protection ordinance codified as Redlands Municipal Chapter
12.52. Future development and/or redevelopment activities that would be permitted under the Project would be required to be reviewed by the City for consistency with the existing tree policies and guidelines.
Therefore, implementation of the Project would not conflict with any local policies or ordinances protecting biological resources. Impacts would be less than significant. Furthermore, the Project would not conflict with the provisions of an adopted habitat conservation plan or natural community conservation plan.
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Geology and Soils
No known fault lines or Alquist-Priolo Fault Zones traverse the proposed Rezone sites or are within 500 feet of any potential future development as part of the proposed Project (City of Redlands, 2017b, Figure 3.6- 2). The nearest fault line to the proposed Project is the Redlands Fault of the Crafton Hills Fault Zone, located south of Highland Avenue/Fifth Avenue (approximately 2.25 miles from Site 24). Therefore, future development projects constructed under the proposed Project would not expose people or structures to potential substantial adverse effects from rupture of a known earthquake fault that is delineated on an Alquist-Priolo Earthquake Fault Zoning Map.
The proposed Project would increase the potential residential buildout within the City; however, the Project site and the immediate surrounding areas are not located in an area that is susceptible to liquefaction (City of Redlands, 2017b). Impacts from seismic ground shaking, including liquefaction, associated with future development pursuant to the proposed Project would be addressed through site specific geotechnical investigations prepared in accordance with the CBC requirements, adopted by the City of Redlands Municipal Code Chapter 15.04. Development projects would also be required to adhere to local policies in the Redlands Municipal Code that contain seismic safety requirements. Therefore, the potential impact related to seismically related ground failure including liquefaction would be less than significant.
The Rezone sites and the surrounding areas consist of relatively flat terrain. Additionally, the sites are not located in an area susceptible to landslides as mapped in Figure 3.6-3 of the General Plan EIR and are not in the path of any potential landslides. Further, the proposed Project does not propose substantial alteration to the existing topography and would not directly or indirectly exacerbate existing environmental conditions related to landslides. Therefore, no impacts would occur related to landslides.
The proposed Project would increase the potential residential buildout within the City; however, the proposed Project area is in an urbanized environment and in an area that is relatively level, with minimal rises or changes in elevation Generally, earthwork and ground-disturbing activities, unless below minimum requirements, require a grading permit, compliance with which minimizes erosion, and the City’s grading permit requirements ensure that construction practices include measures to protect exposed soils. In addition, individual development projects that disturb more than one acre would be subject to compliance with a National Pollutant Discharge Elimination System (NPDES) permit and the implementation of a stormwater pollution prevention plan (SWPPP) (and included as PPP HYD-1). Therefore, the potential for adverse soil erosion and topsoil loss would be less than significant The proposed sites are within a generally flat area that are not subject to landslides, and due to the flat topography, the potential for lateral spreading is also considered very low. The proposed Project area is also not identified as being located on a geologic unit or soil that is unstable, or that would become unstable because of development activities. The soil types within the proposed Project site include Hanford Sandy Loam (HaC), Hanford Coarse Sany Loam (HaC, HaD), and Tujunga Loamy Sand (TuB), as shown in GP EIR Figure 3.6-1. None of these soils are clay based and are not prone to expansion.
The proposed Project area is currently served by existing sewer and wastewater treatment systems. Future development projects would include connection to existing sewer mainlines and service lines. Future development under the proposed Project would not include the use of septic systems. Therefore, no impact would occur related to unstable geologic units or soil.
Any potential hazards related to unstable soils would be addressed through the integration of geotechnical information and design recommendations in the design and construction process for future individual development projects in accordance with the California Building Code (CBC) requirements which minimize the risk associated with soils hazards. Therefore, compliance with the requirements of the CBC would reduce potential impacts related to expansive soil to a less than significant level.
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Future projects would be required to adhere to Initial Study Mitigation Measure PAL-1 (included as Appendix A to this DSEIR), which would require future project applicants to provide an assessment of whether grading would impact any underlying soil units or geologic formations that have potential to yield fossiliferous materials. Initial Study Mitigation Measure PAL-2 (included as Appendix A to this DSEIR) would establish a procedure for the management of paleontological materials on sites with potential to yield paleontological resources. Therefore, with implementation of the proposed mitigation measures, impacts related to paleontological resources would be less than significant.
Hazards and Hazardous Materials
Future construction activities could involve the transport, use, and disposal of hazardous materials such as paints, solvents, oils, grease, and caulking. In addition, hazardous materials could be needed for fueling and servicing construction equipment on the site. These types of materials are not acutely hazardous, and all storage, handling, use, and disposal of these materials are regulated by federal and state requirements that are implemented by the City during building permitting for construction activities. As a result, routine transport and use of hazardous materials during construction would be consistent with applicable regulations and impacts would be less than significant.
The Project would involve routinely using household hazardous materials including solvents, cleaning agents, paints, pesticides, batteries, fertilizers, and aerosol cans. However, the Project would result in an overall decrease of nonresidential uses within the City. The normal routine use of these products pursuant to existing regulations would not result in a significant hazard to people or the environment in the vicinity of the Project site. Therefore, buildout pursuant to the Project would not result in a significant hazard to the public or to the environment through the routine transport, use, or disposal of hazardous waste, and impacts would be less than significant. All future development which would disturb more than 1-acre resulting from the implementation of proposed Project would be required to develop and implement a SWPPP with best management practices (BMPs) as required by NPDES regulations. Depending on the age of the structure that would be demolished, asbestos-containing materials (ACMs) and lead-based paints (LBPs) may be present in the existing buildings. However, demolition activities would be required to implement SCAG Rule 1403, CalOSHA, and the sections of the California Health and Safety Code Additionally, the Project would decrease nonresidential development. Therefore, construction and operation of future development would result in a less-than-significant impact relating to foreseeable upset and accident conditions involving the release of hazardous materials into the environment and a less-than-significant impact related to accidental release near a school.
None of the Rezone sites are located on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (Department of Toxic Substances Control, 2023). Therefore, buildout pursuant to the Project would result in no impact. Future development pursuant to the proposed Project would be developed pursuant to the City’s and applicable Airport Land Use Compatibility Plan development guidelines to ensure that future development would not pose a hazard to airport operations, flight patterns, or otherwise result in substantial aviation-related safety risks. Therefore, impacts would be less than significant related to applicable Airport Land Use Compatibility Plans. Relevant emergency response or emergency evacuation plans include the San Bernardino County Emergency Operations Plan, the City’s Hazard Mitigation Plan (HMP), and the San Bernardino County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP). Physical development pursuant to the proposed Project is not expected to create obstacles to the implementation of emergency response or evacuation plans adopted for the City. Emergency access and circulation during construction and operation of individual development projects under the proposed Project would be part of each project’s review and approval by the City. Therefore, as existing City development standards would require new development within the proposed Project to be designed so as to not interfere with an adopted emergency response plan or emergency evacuation plan, impacts from implementation of the proposed Project would be less than significant. The proposed sites are located in an urbanized environment that does Redlands Regular Meeting of 06-03-25
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not contain wildlands. The Rezone sites would comply with Chapter 15.04 of the Redlands Municipal Code that requires all development to adhere to safety standards provided in the CBC as well as Chapter 15.20 which adopts the California Fire Code. The close coordination of the Redlands Fire Department with the fire services of neighboring jurisdictions ensures the safety of new development from wildland fires. Therefore, impacts would be less than significant.
Hydrology and Water Quality
As discussed in the Initial Study, included as Appendix A, demolition of existing structures, grading, stockpiling or materials, excavation, the import/export of soil and building materials, construction of new structures, and landscaping activities would expose and loosen sediment and building materials, which have the potential to mix with stormwater and urban runoff and degrade surface and receiving water quality. Pollutants of concern during construction activities generally include sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. In addition, chemicals, liquid products, petroleum products (such as paints, solvents, and fuels), and concrete-related waste may be spilled or leaked during construction, which would have the potential to be transported via storm runoff into nearby receiving waters and eventually may affect surface or groundwater quality. During construction activities, excavated soil would be exposed, thereby increasing the potential for soil erosion and sedimentation to occur compared to existing conditions. In addition, during construction, vehicles and equipment are prone to tracking soil and/ or spoil from work areas to paved roadways, which is another form of erosion that could affect water quality. However, the use of BMPs during construction implemented as part of a SWPPP as required by the NPDES General Construction Permit and included as PPP HYD-1of the Initial Study, included as Appendix A to the Draft Subsequent EIR. (NPDES/SWPPP) would serve to ensure that project impacts related to construction activities resulting in a degradation of water quality would be less than significant. Furthermore, an Erosion and Sediment Transport Control Plan prepared by a qualified SWPPP developer (QSD) is required to be included in the SWPPP for the Project. Therefore, compliance with the Statewide General Construction Activity Stormwater Permit requirements, included as PPP HYD-1, which would be verified during the County’s construction permitting process, would ensure that project impacts related to construction activities resulting in a degradation of water quality would be less than significant.
The proposed Project would result in the operation of additional residential uses on the site that could generate pollutants such as, suspended solids, nutrients, bacteria/viruses/pathogens, pesticides, oil and grease, trash and debris. These pollutants could potentially discharge into surface waters and result in degradation of water quality. However, the Project would be required to comply with the NPDES permit requirements, that would limit the potential for pollutants to discharge from the site. In compliance with the NPDES Permit, development projects are required to prepare a Low Impact Development (LID) report, included as PPP HYD-2. The LID report identifies non-structural, structural, and source control and treatment control BMPs to protect surface water quality. The LID report is required to be approved prior to the issuance of a building or grading permit. In addition, the County’s permitting process would ensure that all BMPs in the LID report would be implemented during construction and operation. Overall, implementation of the LID report pursuant to the existing regulations (included as PPP HYD-2) would ensure that implementation of the proposed Project would not violate any water quality standards, waste discharge requirements, or otherwise degrade water quality; and impacts would be less than significant.
As discussed in the Initial Study, included as Appendix A, the City is in the Upper Santa Ana Valley Groundwater Basin. The City’s domestic water wells constitute approximately 50 percent of the water supply.
According to the City of Redlands Urban Water Management Plan (UWMP). The supply of water would be sufficient during both normal years and multiple dry year conditions to meet all of the service area’s estimated needs, including the proposed Project. Therefore, the Project would not result in changes to the projected groundwater pumping that would decrease groundwater supplies. Furthermore, as discussed Redlands Regular Meeting of 06-03-25
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previously, the project would comply with required LID standards, which would ensure the Project would not significantly decrease groundwater infiltration onsite. Thus, impacts related to groundwater supplies would be less than significant.
The Project site does not include, and is not adjacent to, a stream or river, or within a floodplain. The Project site and surrounding area is urban and developed. The Project would implement existing regulations and BMPs that would reduce any potential erosion or siltation. Overall, with implementation of the existing regulations and provision of BMPs that would be verified by the County during the permitting approval process, impacts related to alteration of an existing drainage pattern during construction and operation that could result in substantial erosion or siltation would be less than significant.
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. Overall, with implementation of the existing regulations and provision of BMPs that would be verified by the County during the permitting approval process, impacts related to alteration of an existing drainage pattern during construction and operation that could result in the substantial increase or depth of surface runoff resulting in flooding would be less than significant.
As discussed in the Initial Study, Included as Appendix A, according to the Flood Insurance Rate Map (FIRM), published by the Federal Emergency Management Agency, the Project area contains areas of flood risk, Proposed developments pursuant to the proposed Project would be required to be consistent with the City’s drainage plans and incorporate the Redlands Flood Danage Prevention Measures. Drainage improvements would be implemented by the City as regional drainage improvements and future developments would be required to manage any increase of onsite runoff flows through storm drain improvements or payment of storm drain management fees. Additionally, as part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, the proposed drainage system and adherence to the existing NPDES permit regulations would ensure that future development impacts related to alteration of a drainage pattern or flooding from operation and construction would be less than significant.
The City is approximately 50 miles inland from the Pacific Ocean; therefore, the proposed Project is not at risk of inundation from a tsunami. Also, the proposed Project is not located adjacent to any water retention facilities, lakes, or other bodies of water. Therefore, the Project would have a less than significant impact related to tsunamis and seiching. Development of the proposed Project would comply with applicable NPDES permits as well as the Municipal Code therefore the implementation of the Project would not conflict with or obstruct implementation of a water quality control plan.
Mineral Resources
The Project area has not historically included mineral extraction, nor does the Project area currently support mineral extraction or have identified mineral resources. Thus, implementation of the Project would not result in the loss of availability of a known mineral resource of value to the region and State or delineated on the General Plan, a specific plan, or other land use plan, and no impacts would occur.
Recreation
Individual future development projects under the proposed Project would be subject to the payment of development impact fees to the City. The addition of 6,162 new residents would increase the use of recreational facilities and would require approximately 30.81 acres of new parkland based on the City’s parkland/recreational space standard of 5.0 acres per 1000 residents. However, with a total of 79,152 residents upon buildout of the Project, the City of Redlands would need 391.53 acres of parkland based on Redlands Regular Meeting of 06-03-25
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this standard, which is exceeded by the already existing 424.2 acres. Thus, the Project would not significantly increase the use of existing parks or recreational facilities such that substantial physical deterioration would occur or be accelerated, and impacts would be less than significant.
The development of future parkland and recreational facilities would be subject to existing building and construction regulations and environmental review that would ensure that future construction activities have a minimal effect on the surrounding environment. Furthermore, individual recreational facility projects within the Project site would be subject to the mitigation measures included throughout the Initial Study and this Subsequent EIR. Adherence to existing regulations and mitigation measures included in the Initial Study and this Subsequent EIR would ensure that the Project would not result in construction or expansion of recreational facilities which might have an adverse impact on the environment, and impacts would be less than significant.
Wildfire
The Project area is an urbanized environment with moderate fire threat level and does not include, nor is it around, wildlands or areas of high fire hazard terrain or vegetation. Implementation of the Project would not exacerbate wildfire risks nor expose occupants to risk of pollutant concentrations from a wildfire or uncontrolled spread of a wildfire. The Project area is also not located in or near a state responsibility area, and the Project would not impair the implementation of an adopted emergency response plan or emergency evacuation plan. The project would not require installation of infrastructure that could exacerbate fire risks and would not expose people to downstream flooding related to post fire slope instability. Therefore, implementation of the Project would not result in any impacts related to wildfire.
5.13.5 REFERENCES
California Department of Conservation (DOC). (1997). California Agricultural Land Evaluation and Site Assessment Model, Instruction Manual. https://www.conservation.ca.gov/dlrp/Pages/qh_lesa.aspx California Department of Conservation (DOC). (2022). California Important Farmland Finder . https://maps.conservation.ca.gov/DLRP/CIFF/
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. (2022). 2021-2029 Housing Element. Retrieved September 19, 2024, from https://www.cityofredlands.org/sites/main/files/file-
attachments/redlands_housing_element_adopted_10-04-22.pdf?1697773565.
City of Redlands. (2024). City of Redlands Municipal Code. Retrieved September 9, 2024, from https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-1 Department of Toxic Substances Control. (2024). Hazardous Waste and Substances Site List. Retrieved October 18, 2024. from
https://www.envirostor.dtsc.ca.gov/public/search.asp?cmd=search&reporttype=CORTESE&site_ty pe=CSITES,OPEN,FUDS,CLOSE&status=ACT,BKLG,COM&reporttitle=HAZARDOUS+WASTE+AND +SUBSTANCES+SITE+LIST
SCAG. (2024a). 2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy. Retrieved September 9, 2024 from https://www.connectsocal.org/Pages/Connect-SoCal-Final-Plan.aspx.
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SCAG. (2024b). Connect SoCal 2024 Demographics and Growth Forecast Technical Report. Retrieved September 19, 2024 from https://scag.ca.gov/sites/main/files/file-attachments/23-2987-tr- demographics-growth-forecast-final-040424.pdf?1712261839 SCAG. (2020). Connect SoCal Demographics and Growth Forecast. Retrieved on September 9, 2024, from https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and- growth-forecast.pdf?1606001579
U.S. Department of Agriculture. (n.d.). Natural Resources Conservation Service (NRCS). Web Soil Survey .
Retrieved September 9, 2024, from
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6. Alternatives
This section addresses alternatives to the proposed Project and describes the rationale for including them in the Draft Subsequent EIR. The section also discusses the environmental impacts associated with each alternative and compares the relative impacts of each alternative to those of the proposed Project. In addition, this section describes the extent to which each alternative meets the Project objectives.
6.1 INTRODUCTION
The identification and analysis of alternatives to a project is a fundamental part of the environmental review process pursuant to CEQA. Public Resources Code (PRC) Section 21002.1(a) establishes the need to address alternatives in an EIR by stating that in addition to determining a project’s significant environmental impacts and indicating potential means of mitigating or avoiding those impacts, “the purpose of an environmental impact report is . . . to identify alternatives to the project.” Pursuant to CEQA Guidelines Section 15126.6(a), an EIR must describe a reasonable range of alternatives to the proposed Project or to the Project’s location that would feasibly avoid or lessen its significant environmental impacts while attaining most of the proposed Project’s objectives. CEQA Guidelines Section 15126.6(b) emphasizes that the selection of project alternatives be based primarily on the ability to reduce impacts relative to the proposed project. In addition, CEQA Guidelines Section 15126.6(e)(2) requires the identification and evaluation of an “Environmentally Superior Alternative.” Pursuant to CEQA Guidelines Section 15126.6(d), discussion of each alternative presented in this Draft Subsequent EIR Section is intended “to allow meaningful evaluation, analysis, and comparison with the proposed project.” As permitted by CEQA, the significant effects of each alternative are discussed in less detail than those of the proposed Project, but in enough detail to provide perspective and allow for a reasoned choice among alternatives to the proposed Project.
In addition, the “range of alternatives” to be evaluated is governed by the “rule of reason” and feasibility, which requires the Draft Subsequent EIR to set forth only those alternatives that are feasible and necessary to permit an informed and reasoned choice by the lead agency and to foster meaningful public participation (CEQA Guidelines Section 15126.6(f)). CEQA generally defines “feasible” to mean an alternative that is capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, technological, and legal factors and other considerations ( CEQA Guidelines Sections 15091(a)(3), 15364).
Based on the CEQA requirements described above, the alternatives addressed in this Draft Subsequent EIR were selected in consideration of one or more of the following factors:
• The extent to which the alternative could avoid or substantially lessen any of the identified significant environmental effects of the proposed Project;
• The extent to which the alternative could accomplish the objectives of the proposed Project; • The potential feasibility of the alternative;
• The appropriateness of the alternative in contributing to a “reasonable range” of alternatives that would allow an informed comparison of relative advantages and disadvantages of the proposed Project and potential alternatives to it; and
• The requirement of the CEQA Guidelines to consider a “no project” alternative; and to identify an “environmentally superior” alternative in addition to the no project alternative ( CEQA Guidelines Section 15126.6(e)).
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Neither the CEQA statute, the CEQA Guidelines, nor recent court cases specify a specific number of alternatives to be evaluated in an EIR. Rather, “the range of alternatives required in an EIR is governed by the rule of reason that sets forth only those alternatives necessary to permit a reasoned choice” (CEQA Guidelines 15126(f)).
6.2 ENVIRONMENTAL IMPACTS
CEQA requires the alternatives selected for comparison in an EIR to avoid or substantially lessen one or more significant effects of the project being evaluated. In order to identify alternatives that would avoid or substantially lessen any of the identified significant environmental effects of implementation of the proposed Project, the significant impacts must be considered, although it is recognized that alternatives aimed at reducing the significant and unavoidable impacts would also avoid or reduce impacts that were found to be less than significant or reduced to below a level of significance with implementation of mitigation measures.
The analysis in Section 5.0 of this Draft Subsequent EIR determined that buildout of the proposed Project would result in the following significant and unavoidable impacts.
Agricultural and Forestry Resources
Impact AG-1, Conversion of Significant Farmland. The Project site contains approximately 44.67 acres of Prime Farmland. The Project would result in the 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 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 Redlands Regular Meeting of 06-03-25
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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, 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.
Impact GHG-2, Conflict with GHG Reduction Plan (Project, Cumulative). The proposed Project would have the potential to be inconsistent with key project attributes from the 2022 Scoping Plan Appendix D, Local Actions, which could combine with potential inconsistencies from 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.
Transportation
Impact TR-2, Vehicle Miles Traveled (Project). As detailed in Section 5.10, Transportation, all TAZs within the Project Site are either within a TPA or a low-VMT area or would meet Criteria 3 based on local serving uses, except for TAZs 53835402 and 53835101, which include Sites 20, 21, and 23. As such, implementing development pursuant to the proposed Project in all TAZs except Sites 20, 21, and 23 would be less than significant. However, future development projects within Sites 20, 21, and 23 would be required to conduct a project-specific VMT screening analysis to determine whether the development would screen out of a further VMT analysis pursuant to Mitigation Measure T-1. Should the development not screen out of a VMT analysis, the project would be required to conduct a full VMT analysis and implement further 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.
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6.3 PROJECT OBJECTIVES
The following objectives have been identified in order to aid decision makers in their review of the proposed Project and its associated environmental impacts.
1. Implement Program 1.1-1 of the 6th Cycle 2021-2029 Housing Element to provide adequate capacity for at least 4,219 units on suitable sites.
2. Maintain adequate housing sites for all income groups throughout the eight-year planning period.
3. Increase the City’s overall housing capacity and capability to accommodate housing as required per the certified Housing Element for the 2021-2029 housing cycle.
4. Minimize potential land use conflicts associated with the proposed change to existing land use designations and zoning.
6.4 ALTERNATIVES CONSIDERED BUT REJECTED
Pursuant to CEQA Guidelines Section 15126.6(c), an EIR must briefly describe the rationale for selection and rejection of alternatives. The lead agency may make an initial determination as to which alternatives are potentially feasible and, therefore, merit in-depth consideration, and which are infeasible and need not be considered further. Alternatives that are remote or speculative, or the effects of which cannot be reasonably predicted, need not be considered ( CEQA Guidelines Section 15126.6(f), (f)(3)). This section identifies alternatives considered by the lead agency but rejected as infeasible and provides a brief explanation of the reasons for their exclusion. Alternatives may be eliminated from detailed consideration in the Draft Subsequent EIR if they fail to meet most of the Project objectives, are infeasible, or do not avoid any significant environmental effects.
Alternate Site Alternative: An alternate site for the Project was eliminated from further consideration. Any alternate site would need to occur within the City of Redlands. The City is required by State law to rezone housing shortfall sites according to what has been approved under the certified Housing Element (Government Code § 65583.2, Senate Bill 197). The site identified within the City’s 2021-2029 Housing Element includes the Project site, and an alternate site would fail to meet most of the Project objectives, would be infeasible, and would not be compliant with State law regarding rezoning pursuant to the City’s Housing Element. Additionally, if the Project were to occur on an alternate site and rezoning were conducted within different parcels in the City, similar impacts would result and comparable mitigation would be required; therefore, impacts would not be reduced under this alternative. Therefore, this alternative has been determined infeasible.
6.5 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
Four alternatives to the proposed Project have been identified for further analysis as representing a reasonable range of alternatives that attain most of the objectives of the Project, may avoid or substantially lessen any of the significant effects of the proposed Project, and are feasible from a planning and development perspective. These alternatives have been developed based on the criteria identified in Section
6.1, and are described below:
Alternative 1: No Project/No Development Alternative. This alternative consists of the Project not being approved, and the Project site would remain in the conditions that existed at the time the Notice of Preparation was published with no additional development occurring within the Rezone sites (July 1, 2024).
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designations, and the Project site would not be rezoned to allow for additional residential uses. Buildout of this Alternative would result in up to 2,209,040.26 square feet of non-residential uses and 111 units of residential development.
Alternative 3: Reduced Project Site Alternative. The Reduced Project Site Alternative would allow for a similar future development to occur as proposed by the Project, but the allowed area where the future rezone and potential development would be allowed to occur would be limited to only a portion of the existing Project site. Under this alternative, the parcels which are located on the Morrey Arroyo Creek (Sites 2, 7, 8, 11,12, 16, 16A, and 24) would not be rezoned. All parcels under this alternative (1, 3, 4, 5, 6, 9, 10, 10A, 13, 14, 15, 15A, and 17-23) would be rezoned the R-3 zoning designation, with a maximum density of 30 dwelling units/acre. The Reduced Project Site Alternative would allow for the potential future development of 2,439 residential units but would limit the potential future development to just 81.32 acres and would no longer propose any Public/Institutional land uses on Site 24
1. This alternative would still require
an SPA to the EVCSP, a GPA, and zone change.
Alternative 4: Reduced Project Development Intensity Alternative. The Reduced Project Development Intensity Alternative would redesignate the Rezone sites to allow for development of future residential and additional square footage of nonresidential development, similar to the proposed Project. However, potential buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. This alternative would still require approval of the GPA, adoption of a zone change, and adoption of an SPA to the EVCSP.
Furthermore, under this alternative, only 1,948 dwelling units would be allowed to be constructed and the City would have a 1,315 dwelling-unit deficit in meeting their State mandated RHNA fair share.
6.6 ALTERNATIVE 1: NO PROJECT/NO DEVELOPMENT ALTERNATIVE Pursuant to State CEQA Guidelines Section 15126.6(e), this Draft EIR is required to “discuss the existing conditions at the time the Notice of Preparation is published, or if no notice of preparation is published, at the time the environmental analysis is commenced, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services […] In certain instances, the no project alternative means ‘no build’ wherein the existing environmental setting is maintained.” The No Project/No Development Alternative allows decision-makers to compare the environmental impacts of approving the proposed Project to the environmental impacts that would occur if the Project site were to be left in its existing conditions for the foreseeable future. Under the existing conditions, Rezone sites are either currently vacant or developed with single-family residences, agricultural uses, and industrial storage facilities. See Section 4.0, Environmental Setting, for additional details and figures regarding the existing conditions of the Rezone sites.
6.6.1 Environmental Impacts
Aesthetics
Under this alternative, the Project site would remain in its existing condition, which includes undeveloped, disturbed, and some developed conditions. The visual character and quality of the site would be maintained, and no new structures or landscaping would be introduced. This alternative would not result in a change in 1 While full buildout of Site 24 under the proposed Public/Institutional Land Use was analyzed for this Draft SEIR, no development is or would be proposed as an implementing project.
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the visual height, scale, and mass of development on the sites. This alternative would not create new sources of light and glare. However, landscaping would not be added to the sites and landscaping and screening along the roadways would not be improved. Overall, the No Project/No Development Alternative would result in no impacts to aesthetics, less than the proposed Project.
Agriculture and Forestry
Under this alternative no new development would occur in the Project site, and as such, development would not impact the Farmland onsite. Sites 1, 3, 9, 10, 13, 14, 15, and 15A would continue to be used for agricultural purposes and no rezoning would occur which could put development pressure on surrounding agricultural uses. This Alternative would avoid the significant and unavoidable impact to Farmland from the Project. Therefore, the No Project/No Development Alternative would result in less impacts than the proposed Project.
Air Quality
Under this alternative no new development would occur in the Project site, and as such, no new stationary or mobile sources of air pollution would be introduced. Since buildout pursuant to the proposed Project would result in an exceedance of 2022 AQMP thresholds, this Alternative’s emissions would be greatly reduced with no construction or additional trips introduced to the Project site. In addition, the Alternative would result in no increase in emissions of criteria pollutants or diesel particulate matter (DPM) over existing conditions.
Therefore, the No Project/No Development Alternative would result in less impacts than the proposed Project.
Biological Resources
Under this alternative, periodic disturbances related to discing fallow fields for weed abatement are expected to occur at the Project site, as well as other routine maintenance activities for property upkeep.
While periodic disturbances could potentially impact biological resources, no grading would occur and there would be no potential impacts to special status plants, animals, or sensitive vegetation communities in the Project site. As such, existing vegetation communities within the Project site would remain in their existing conditions minus impacts related to periodic disturbances. Although mitigation measures required of the Project would reduce biological resource impacts to less than significant levels, this alternative would generate less impacts to biological resources as compared with the Project and would not require mitigation.
Cultural Resources
Under this alternative, no disturbances would occur to the Rezone sites due to buildout based on the proposed rezoning. No grading for construction would occur and there would be no potential impacts to historical resources or to archaeological resources that may be buried below ground, as the current environment would remain. No historical structures would be removed or altered as well. Although mitigation measures required for the Project would reduce cultural resource impacts to less-than-significant levels, this alternative would avoid impacts to cultural resources associated with the Project and would result in less impacts than the proposed Project.
Energy
No construction activities would occur at the Project site or operation of new structures that would increase consumption of energy sources under this alternative. Existing agricultural, single-family residences, and industrial storage yards within the Rezone sites would continue standard operation. Electricity, gasoline, and diesel fuel usage would all be lower for the existing uses than for the Project. While this Draft Subsequent EIR determined the Project’s impacts to energy would be less than significant, energy use associated with this Redlands Regular Meeting of 06-03-25
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alternative would be less. Therefore, the No Project/No Development alternative would result in less impacts than the proposed Project.
Geology and Soils
No new construction activities, including grading, would occur under this alternative. Thus, there would be no potential for additional workers, buildings, and structures to experience seismic ground shaking, liquefaction, lateral spreading, subsidence, or collapse within the Project site. Additionally, as no grading activities would occur under this alternative, potential impacts from erosion, loss of topsoil, or to paleontological resources would not occur. While the Project’s impacts would be less than significant with mitigation incorporated, this alternative would result in less impacts and no mitigation measures are required.
Greenhouse Gas Emissions
No new construction activities would occur at the Project site or operation of new structures that would generate GHGs under this alternative. Under this alternative, no additional vehicle trips would be introduced to the Project site, which is the source of most of the greenhouse gas emissions of the proposed Project, as discussed in Section 5.5, Greenhouse Gases . This alternative would be consistent with all applicable GHG reduction plans and would avoid the Project’s significant and unavoidable impact regarding the generation of greenhouse gas emissions. Therefore, the No Project/No Development alternative would result in less impacts than the proposed Project.
Hazards and Hazardous Materials
No new construction activities would occur at the Project site or any new residences that result in transport of hazardous materials. There would be no new operation onsite that would generate hazardous materials. The No Project/No Development Alternative would not include major construction activities that would use typical construction-related hazardous materials. Thus, potential impacts related to use, disposal, and transport of hazardous materials would be avoided by this alternative. While the Initial Study, included as Appendix A, determined that the Project’s impacts related to hazards and hazardous materials would be less than significant, this alternative would result in less impacts since no grading or construction would occur.
Hydrology and Water Quality
No changes to existing hydrology and drainage conditions would occur under this alternative. There are currently no existing stormwater drainage facilities within the Project site and no stormwater improvements would be constructed. Additionally, under this alternative, the stormwater leaving the Rezone sites would not be treated to minimize waterborne pollutants and would continue to contain sediment and other potential pollutants, as occurs under existing conditions. However, this alternative would generate fewer sources of potential water-borne pollutants due to lack of onsite buildings and number of vehicles onsite. Overall, hydrology and water quality impacts of the No Project/No Build Alternative would be less than significant, and neutral in comparison to the proposed Project.
Land Use and Planning
This alternative would not result in new development, and as such, there would be no potential for land uses to be introduced that would indirectly result in environmental impacts due to a conflict with an existing land use plan. While the current agricultural and residential uses do not align with the Commercial/Industrial designation for sites 1-16A (excluding site 8), the existing uses would continue to be allowed to operate, and no new land uses would be introduced to the site. Under this alternative no General Plan Amendment Redlands Regular Meeting of 06-03-25
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would be required. Overall, this alternative would result in no impacts to land use and planning, and therefore, would be less than the Project’s impacts.
Noise
Under this alternative, no development would occur onsite, and no new sources of noise would be introduced at the Rezone sites. Since no new development would occur and no traffic trips would be generated, this alternative would not contribute to any increase in existing area-wide traffic noise levels. In addition, this alternative would not result in construction onsite and no construction noise or vibration would occur.
Therefore, the No Project/No Development alternative would result in less impacts than the proposed Project.
Population and Housing
This alternative would not result in new development, and as such, would not result in induced growth or displacement affecting population and housing. However, this alternative would also not result in the benefit of adding new housing opportunities and the City would not reach their RHNA goals. Therefore, the No Project/Development Alternative’s impacts would be neutral compared to the proposed Project.
Public Services
This alternative would not result in new development, and as such, would not result in increased demand for public services such as fire and sheriff services, school services, library services, or health services that require the new construction of public facilities. However, this alternative would also not result in the payment of the City’s development impact fees. Therefore, while the Project’s impacts would be less than significant through compliance with regulatory programs, this alternative would result in less impacts.
Recreation
This alternative would not result in new development, and as such would not result in any new residences that would potentially impact nearby parks or require the development of additional park resources. However, this alternative would also not result in the payment of the City’s development impact fees. Therefore, the No Project/Development Alternative’s impacts would be neutral compared to the proposed Project.
Transportation
This alternative would not result in new development, and as such, would not result in any trips, traffic, or Vehicle Miles Traveled (VMT) related to operation of the Project site beyond existing vehicle trips associated with agricultural, residential, and industrial storage operations. This alternative would not impact existing transit service and alternative transportation facilities within the Project site. The proposed Project would result in less-than-significant impacts related to geometric hazards and emergency access; however, the Project would result in significant and unavoidable impacts related to VMT. As the Rezone sites would not be developed and trips would not be generated, the No Project/No Development Alternative would result in no impact on transportation. As such, this alternative would avoid the Project’s significant and unavoidable VMT impact. Therefore, the No Project/No Development alternative would result in less impacts than the proposed Project.
Tribal Cultural Resources
Under this alternative, existing conditions would remain, and no new development would occur. No grading would occur and there would be no potential impacts to tribal cultural resources that may be buried below ground. Although the Project would result in less-than-significant impacts on tribal cultural resources with Redlands Regular Meeting of 06-03-25
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incorporation of mitigation, this alternative would avoid all potential impacts to tribal cultural resources.
Therefore, the No Project/No Development alternative would result in less impacts than the proposed Project.
Utilities and Service Systems
Under this alternative, existing conditions would remain, and no new development would occur. No additional configurations or connections to existing domestic water, wastewater, stormwater drainage, electric power, natural gas, or telecommunication facilities would be needed under this alternative, and there would be no change in the demand for domestic water or wastewater treatment services. Selection of this alternative would result in no impact on utilities and service system providers. While the Project would result in less than significant impacts, this alternative would result in less impacts due to no change in demand of these service systems. Therefore, the No Project/No Development alternative would result in less impacts than the proposed Project.
Wildfire
Under this alternative, existing conditions would remain, and no new development would occur. There would be no construction or operation activities that would exacerbate the potential fire risks at the site or obstruct any evacuation routes. The Project site would continue to not be located near Moderate to Very High Fire Hazard Safety Zones. However, with this alternative there would be no additional occupants onsite that would be exposed to any fire hazards. Therefore, the No Project/No Development alternative would result in less impacts than the proposed Project.
6.6.2 Conclusion
Ability to Reduce Impacts
The No Project/No Development Alternative would result in continuation of the existing uses within the Rezone sites, and the potential buildout of additional residential units based on the proposed rezoning would not occur. As a result, this alternative would avoid the need for mitigation measures that are identified in Section
5.0 of this Draft Subsequent EIR, which include measures related to air quality, biological resources, cultural resources, greenhouse gas emissions, paleontological resources, noise, transportation, and tribal cultural resources. This alternative would also avoid the significant and unavoidable impacts to air quality, agriculture, greenhouse gas emissions, and VMT. This alternative would result in lessened impacts to all 20 of the 20 environmental topics analyzed in this Draft Subsequent EIR and Initial Study (see Table 6-3).
However, the environmental benefits of the proposed Project would also not be realized, including providing housing onsite that would result in a better jobs-housing balance in Redlands. Further, the alternative would not meet the required additional residential units, which are legally required under the City’s Housing Element pursuant to State housing regulations.
Ability to Achieve Project Objectives
As shown in Table 6-4, below, the No Project/No Development Alternative would not meet any of the Project objectives. The No Project/No Development Alternative would not introduce any additional housing within the City and the City would not be able to meet their RHNA per the 2021-2029 Housing Element.
Additionally, under this alternative the City would not be able to address land use conflicts within the City.
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6.7 ALTERNATIVE 2: NO PROJECT/BUILDOUT OF EXISTING LAND USE
ALTERNATIVE
Under this alternative, buildout of residential and nonresidential uses would occur as permitted under the existing General Plan land use designations, and the Project site would not be rezoned to allow for additional residential uses. All 24 sites would be built according to their existing General Plan land use designation. Existing General Plan land use designations within the site include Commercial/Industrial uses, Commercial/Administrative Professional, Medium Density Residential, and High Density Residential. Buildout would result in up to 2,209,040.26 square feet of non-residential uses and 111 units of residential development.
6.7.1 Environmental Impacts
Aesthetics
Under this alternative, the Project site would be developed according to the existing General Plan land use designation for each parcel. Development under the No Project/Build out of Existing Land Use Alternative would result in more industrial density throughout the Rezone sites as opposed to residential development This alternative would introduce new buildings and landscaping into the Rezone sites. The alternative would result in increased parking areas and setbacks and a smaller percentage of landscaped areas than what would be developed under implementing developments under the RHNA Rezone Project. This alternative would introduce new sources of light and glare as increased industrial and commercial development would occur but would be similarly subject to the Redlands Municipal Code. Overall, this alternative would result in similar less than significant impacts related to aesthetics.
Agriculture and Forestry
Under this alternative, the Rezone sites would be developed according to the existing General Plan land use designation for each parcel. Development under the No Project/Buildout of Existing General Plan Land Use Alternative would result in the same loss of Prime Farmland as would occur under the proposed Project and would not avoid the significant and unavoidable impact of converting Farmland to non-agricultural uses.
Overall, this alternative would result in the same significant and unavoidable impacts related to agriculture resources as the proposed Project.
Air Quality
Under this alternative, the Project site would be developed with 2,209,040.26 square feet on non-residential uses and 111 residential units. Since the buildout pursuant to the proposed Project would result in an exceedance of 2022 AQMP thresholds, this alternative’s emissions would result in similar impacts related to construction emissions. As discussed in the VMT Screening Analysis included as Appendix F, buildout pursuant to the existing General Plan would result in 45,792 trips compared to the proposed Project which would result in 18,252 trips. Due to the increase in trips generated by the existing General Plan Buildout, impacts would remain significant and unavoidable and would be increased compared to the proposed Project. In addition, the alternative would result in an increase in emissions of criteria pollutants or diesel particulate matter (DPM) as it would result in significantly more truck trips. As shown below on Table 6-1, operation of this alternative would result in the exceedance of five different criteria pollutants. Therefore, the No Project/No Development Alternative would result in more severe impacts than the proposed Project, and would remain significant and unavoidable.
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Table 6-1: 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
Biological Resources
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Development of this alternative would require removal of existing vegetation in open areas and vacant lots and could potentially impact special status plants, animals, or sensitive vegetation communities. As such, the impacts to biological resources on the Project site would be similar to the Project and require the same mitigation measures. These mitigation measures would also reduce potential impacts from this alternative to a less than significant level. This alternative would result in less than significant impacts to biological resources, and therefore, would be consistent with the Project’s impact.
Cultural Resources
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. As such, the No Project/Buildout of Existing Land Use Alternative would result in the same potential to adversely affect any historic or undiscovered archeological resources as the proposed Project as this alternative would redevelop the same area as the proposed Project and would require the implementation of Mitigation Measures CUL-3 and CUL-4. This alternative would have a similar impact on historic structures within the Project site. Similar to the proposed Project, Mitigation Measures CUL-1 and CUL-2 would be implemented and compliance with applicable City of Redlands Municipal Code provisions, including Redlands Historic Architectural Design Guidelines, would be required to reduce potential impacts to a less than significant level. Therefore, impacts to cultural resources from the No Project/Buildout of Existing Land Use Alternative would be the same as those associated with the proposed Project.
Energy
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Under this alternative, a similar volume of construction activities and the related energy demand would occur, which was determined to be less than significant. Implementing Redlands Regular Meeting of 06-03-25
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projects under this alternative would be compliant with Title 24 requirements. Therefore, impacts to energy from the No Project/Buildout of Existing Land Use Alternative would be slightly less than those associated with the proposed Project, but still less than significant.
Geology and Soils
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Potential impacts related to the potential for additional workers, buildings, and structures to experience seismic ground shaking, liquefaction, lateral spreading, subsidence, or collapse within the Project site would be similar to the Project; however, fewer residents would be exposed.
Soil erosion impacts would also be less than significant due to compliance with water quality standards, and new development would be required to comply with regulatory requirements regarding geologic considerations such as seismic hazards from ground shaking. The same mitigation regarding paleontological resources would be required for this alternative as the same area would be redeveloped. This alternative would result in less than significant impacts to geology and soils, and therefore, would be consistent with the Project’s impact.
Greenhouse Gas Emissions
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Under this alternative, a similar volume of construction activities and the related greenhouse gas production would occur. As stated above, buildout of this alternative would result in an increase in 27,540 trips compared to the proposed Project. Further, given that this alternative would include industrial development, a larger percentage of the trips occurring would include truck trips.
As shown below on Table 6-2, total CO
2 emissions per service population (CO 2e/SP) from this alternative would be 18.16, while the proposed Project would result in 3.56 CO 2e/SP. Thus, operational greenhouse gas emissions are expected to increase and would remain significant and unavoidable with implementation of the proposed mitigation measures.
Table 6-2: 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
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
Hazards and Hazardous Materials
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Like the proposed Project, construction of this alternative would be required to comply with existing regulations regarding the transport, use, and disposal of hazardous Redlands Regular Meeting of 06-03-25
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materials. While the operation of this alternative would require a higher volume of hazardous materials, use of such materials would similarly be required to adhere to state and local guidelines regarding the handling of hazardous materials. Like the proposed Project, this alternative would not require mitigation. In addition, as this alternative would result in a decrease in residents onsite, the alternative would not pose a safety hazard to the people residing in the area. This alternative would result in less than significant impacts to hazards and hazardous materials, and therefore, would be consistent with the Project’s impact.
Hydrology and Water Quality
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Due to the likely increase in parking surfaces required for this alternative, it is anticipated that development of this alternative would result in an increase in impermeable surfaces compared to those required for development pursuant to the Project. Construction of the alternative would still be required to implement drainage infrastructure improvements. In addition, preparation of a SWPPP and WQMP would be required for future development under this alternative. Therefore, this alternative would result in similar less than significant impacts as the Project, and therefore, would be consistent with the Project’s impact.
Land Use and Planning
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Under this alternative, no General Plan Amendment would be required. The No Project/Build out of Existing Land Use Alternative would be consistent with goals and policies of the Redlands General Plan and the SCAG 2020-2045 RTP/SCS. With implementation of measures to address other environmental issues (e.g., biological resources, cultural resources, etc.), potential impacts due to land use compatibility under both the Project and this alternative would remain less than significant. This alternative would also not physically disrupt or divide the arrangement of an established community. Overall, impacts related to land use and planning from the No Project/Buildout of Existing Land Use Alternative would be less than significant, and therefore, would be consistent with the Project’s impacts.
Noise
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. The construction of this alternative would require site clearing, grading, and construction activities similar to the proposed Project at similar intensity. Construction noise impacts would remain less than significant, similar to the proposed Project and would also be required to implement the same mitigation measures due to the proximity to nearby sensitive receptors. Operational impacts would result in an increase in trips as well as an increase in heavy trucks trips which would result in higher roadway volumes. Buildout of this alternative would result in industrial uses, which would result in a greater increase in onsite operational noise levels in proximity to sensitive receptors compared to the proposed Project. Due to the increase in vehicle trips going to and from the site under this alternative, and the buildout of industrial uses near sensitive receptors, impacts would be greater under the No Project/Buildout of Existing Land Use Alternative as compared to the Project and would require implementation of the same mitigation measures and General Plan policies in order to reduce impacts to a less than significant level.
Population and Housing
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. This would reduce the number of residents at buildout from 6,456 to 294 and would increase the number of employees from 550 to 2,263. The decrease in population that Redlands Regular Meeting of 06-03-25
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would be generated by this alternative would be consistent with SCAG forecasts and would not induce substantial population growth in the Project area. The No Project/Buildout of Existing Land Use Alternative and the proposed Project would result in similar less than significant impacts related to population and housing.
Public Services
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. The No Project/Buildout of Existing Land Use Alternative would result in fewer residents at full buildout of the alterative compared to the proposed Project. Thus, demand for public services, including fire protection, police protection, school services, and library services, would be slightly reduced compared to the proposed Project. Like the proposed Project, the No Project/Buildout of Existing Land Use Alternative would contribute development impact fees to the City which would result in a less than significant impact and would be similar to those associated with the proposed Project.
Recreation
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Construction of this alternative would result in generally similar impacts, if not a slightly decreased demand for park and recreation facilities. In addition, this alternative would also require the payment of development impact fees imposed by the City of Redlands. Through implementation of regulatory requirements, impacts would be less than significant. Therefore, this alternative would result in similar less-than-significant impacts as the Project.
Transportation
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. As discussed in the VMT Screening Analysis, included as Appendix F, buildout pursuant to the existing General Plan would result in 45,792 trips compared to the proposed Project which would result in 18,252 trips. As discussed in Section 5.10, Transportation, all TAZs within the Project site satisfy the City’s screening criteria, except for TAZ 53835402 and TAZ 53835101 which include sites 20, 21, and 23. As such, under the No Project/Buildout of Existing Land Use Alternative, the same sites would not screen out from further VMT analysis. Because this alternative would result in an overall increase in trips, impacts would remain significant and unavoidable. Thus, the alternative would be required to include the same mitigation included for the proposed Project. As such, impacts would increase in comparison to the proposed Project under the No Project/Buildout of Existing Land Use Alternative, and impacts would remain significant and unavoidable.
Tribal Cultural Resources
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. A similar amount of ground disturbance is proposed under this alternative compared to the proposed Project. Thus, the No Project/Buildout of Existing Land Use Alternative would result in a similar potential to adversely affect any historic or undiscovered archeological resources as the proposed Project. Similar mitigation to the Project’s mitigation measures would be required to reduce potential impacts to a less than significant level. Therefore, impacts to tribal cultural resources from the No Project/Buildout of Existing Land Use Alternative would be consistent with those associated with the proposed Project.
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Utilities and Service Systems
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Similar to the proposed Project, under this alternative, additional configurations or connections to existing domestic water, wastewater, stormwater drainage, electric power, natural gas, and telecommunication facilities could be needed with future development. As discussed in Section 5.12, Utilities and Service Systems, buildout of the existing General Plan land uses would result in a slight decrease in water use and wastewater generation compared to the proposed Project. Therefore, the No Project/Buildout of Existing Land Use Alternative would result in similar impacts as the proposed Project.
Wildfire
Under this alternative, the Rezone sites would be developed with 2,209,040.26 square feet on non- residential uses and 111 residential units. Both the Project and this alternative would be required to comply with the California Building Code and California Fire Code requirements. Development under the No Project/Build out of Existing Land Use Alternative would reduce the number of units developed and would also reduce the number of occupants onsite. Overall, this alternative would also result in less than significant impacts related to wildfires, similar to the proposed Project.
6.7.2 Conclusion
Ability to Reduce Impacts
The No Project/Buildout of Existing Land Use Alternative would not eliminate the significant and unavoidable impacts related to agricultural resources, air quality emissions, GHG emissions, and VMT that would occur from implementation of the proposed Project. In addition, this alternative would require the same mitigation to ensure less than significant impacts related to historical resources, biological resources, cultural resources, paleontological resources, and noise. This alternative would not result in lessened impacts to any of the 20 environmental topics analyzed in this Draft Subsequent EIR and Initial Study (see Table 6-3).
The environmental benefits of the proposed Project would also not be realized, including providing housing onsite that would result in a better jobs-housing balance in Redlands. Further, the alternative would not meet the required additional residential units, which are legally required under the City’s Housing Element pursuant to State housing regulations.
Ability to Achieve Project Objectives
As shown in Table 6-4, below, the No Project/No Development Alternative would not meet any of the Project objectives. The No Project/Buildout of Existing Land Use Alternative would not introduce enough additional housing within the City to able to meet their RHNA per the 2021-2029 Housing Element. Additionally, under this alternative the City would not be able to address land use conflicts within the City.
6.8 ALTERNATIVE 3: REDUCED PROJECT SITE ALTERNATIVE
The Reduced Project Site Alternative would allow for a similar future development to occur as proposed by the Project, but the area where the future rezone and potential development would be allowed to occur would be limited to only a portion of the existing Project site. Under this alternative, the parcels which are located adjacent to the Morrey Arroyo Creek (Sites 2, 7, 8, 11,12, 16, 16A, and 24) would not be rezoned.
All parcels under this alternative (1, 3, 4, 5, 6, 9, 10, 10A, 13, 14, 15, 15A, and 17-23) would be rezoned the R-3 zoning designation, with a maximum density of 30 dwelling units/acre. The Reduced Project Site Redlands Regular Meeting of 06-03-25
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Alternative would allow for the potential future development of 2,439 residential units but would limit the potential future development to just 81.32 acres and would no longer propose any Public/Institutional land uses on Site 24. This alternative would still require an SPA to the EVCSP, a GPA, and zone change.
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Figure 6-1a
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6.8.1 Environmental Impacts
Aesthetics
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. This alternative would lead to increased density within the proposed sites which would result in a decrease in landscaping and decreased setbacks. However, the visual character and quality of sites located along the Morey Arroyo would be maintained, and no new structures or landscaping would be introduced. This alternative would introduce new sources of light and glare but would be similarly subject to the Redlands Municipal Code. Therefore, aesthetic impacts would be neutral compared to the proposed Project.
Agriculture and Forestry
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. Development under the Reduced Project Site Alternative would result in the loss of 40.6 acres of Prime Farmland. While this alternative would avoid impacting the
4.07-acres of Prime Farmland located on Site 8, it would not avoid the significant and unavoidable impact of converting Farmland to non-agricultural uses. Overall, this alternative would result in the same significant and unavoidable impacts related to agriculture and forest resources.
Air Quality
The Reduced Project Site Alternative would result in a potential future buildout of three additional dwelling units, and none of the 151,048.46 square feet of Public/Institutional land compared to the Project. Therefore, a slightly reduced overall volume of construction activities and the related emissions would occur. Under the Reduced Project Site Alternative, it is possible that a combination of developments could occur, such that daily construction emissions would still exceed this threshold. Thus, construction air quality impacts would remain significant and unavoidable.
In addition, the slightly reduced amount of development by this alternative would result in less stationary source emissions from equipment and less traffic associated air emissions than the proposed Project.
Therefore, overall air quality impacts would be reduced in comparison to the proposed Project. However, the volume of VOC, NOx, and CO emissions from operational vehicular emissions generated by the Reduced Project Site Alternative would remain significant and unavoidable due to the volume of vehicular trips that would occur from operation of the alternative. As described in Section 5.2, Air Quality, operations from implementing projects under the proposed Project would generate up to 121.01 lbs/day of VOC emissions, which is substantially above the threshold of 55 lbs/day; 89.74 lbs/day of NOx, which is above the threshold of 55 lbs/day; and 608.04 lbs/day of CO, which is above the threshold of 550 lbs/day during peak summer operations. Under the Reduced Project Site Alternative, the daily VOC, NOx, and CO emissions related to residential operations would be similar to the proposed Project, but overall emissions would be slightly reduced as it would not include the additional emissions from the proposed Public/Institutional land use on Site 24. Therefore, although less emissions would occur, significant and unavoidable impacts would still occur from the Reduced Project Site Alternative.
Biological Resources
Under this alternative, a 81.32-acre portion of the Project site would be developed with residential units and off-site improvements. Development of this alternative would require removal of existing vegetation in open areas and vacant lots and could potentially impact special status plants, animals, or sensitive vegetation communities. As such, the impacts to biological resources on the Project site would be similar to the Project Redlands Regular Meeting of 06-03-25
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and require the same mitigation measures, however a smaller area would be impacted. These mitigation measures would also reduce potential impacts from this alternative to a less than significant level. This alternative would result in less-than-significant impacts to biological resources, and therefore, would be consistent with the Project’s impact.
Cultural Resources
Under the Reduced Project Site Alternative, a slightly increased density of development would occur within a reduced Project site. As such, the Reduced Project Site Alternative would result in a decreased potential to adversely affect any historic or undiscovered archeological resources as the proposed Project, as this alterative would avoid development near the Morey Arroyo, which has a greater potential to contain buried archeological resources. However, mitigation measures CUL-3 and CUL-4 would still be applicable to any ground disturbing activities related to this alternative. This alternative would have a similar impact on historic structures within the Project site. However, like the proposed Project, Mitigation Measures CUL-1 and CUL-2 would be implemented and compliance with applicable City of Redlands Municipal Code provisions, including Redlands Historic Architectural Design Guidelines, would be required to reduce potential impacts to a less than significant level. Therefore, impacts to cultural resources from the Reduced Project Site Alternative would be less than those associated with the proposed Project.
Energy
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. Under this alternative, a slightly reduced overall volume of construction activities and the related energy demand would occur, which was determined to be less than significant. Implementing projects under this alternative would be compliant with Title 24 requirements.
Therefore, impacts to energy from the Reduced Project Site Alternative would be slightly less than those associated with the proposed Project, but still less than significant.
Geology and Soils
Under the Reduced Project Site Alternative, buildout of Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17- 23 would result in a potential future buildout of three additional dwelling units, and none of the 151,048.46 square feet of Public/Institutional land compared to the Project. Potential impacts related to the potential for additional workers, building, and structures to experience seismic ground shaking, liquefaction, lateral spreading, subsidence, or collapse within the Project site would be similar to the Project, however fewer people would be exposed. Soil erosion impacts would also be less than significant due to compliance with water quality standards, and new development would be required to comply with regulatory requirements regarding geologic considerations such as seismic hazards from ground shaking. The same mitigation regarding paleontological resources would be required for this alternative. This alternative would result in less than significant impacts to geology and soils, and therefore, would be consistent with the Project’s impact.
Greenhouse Gas Emissions
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units which would result in three additional dwelling units but would not include the development of Site 24. Therefore, a slightly reduced volume of construction activities and related production of GHG emissions would occur. In addition, the slightly reduced amount of development by this alternative would result in less stationary source emissions from equipment onsite, and less traffic-associated GHG emissions than the proposed Project with the exclusion of the Public/Institutional uses on Site 24. However, development and operation of 2,439 multifamily dwelling units would result in significant GHG emissions and would require the implementation of the same mitigation measures that are Redlands Regular Meeting of 06-03-25
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required for the proposed Project. Therefore, although the Reduced Project Site Alternative would result in a slight decrease in GHG emissions, impacts would remain significant and unavoidable.
Hazards and Hazardous Materials
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units which would result in three additional dwelling units but would not include the development of Site 24. Like the proposed Project, construction of this alternative would be required to comply with existing regulations regarding the transport, use, and disposal of hazardous materials. In addition, this alternative would likely require the same utilization of hazardous materials during operation as the proposed Project. Like the proposed Project, this alternative would not require mitigation. In addition, as this alternative would result in a decrease in building square footage and employees and students onsite, the alternative would not pose a safety hazard to the people working in the area. This alternative would result in less-than-significant impacts to hazards and hazardous materials, and therefore, would be consistent with the Project’s impact.
Hydrology and Water Quality
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units which would result in three additional dwelling units but would not include the development of Site 24. Due to the increased density of development on a smaller site, it is likely that development of this alternative would result in a decrease in impermeable surfaces compared to those required for development of the Project. Construction of the alternative would still construct the identified stormwater drainage system as the Project but would likely require a smaller sized basin. In addition, preparation of a Stormwater Pollution Prevention Plan (SWPPP) and Water Quality Management Plan (WQMP) would be required for development of this alternative. Therefore, this alternative would result in similar less-than-significant impacts as the Project, and therefore, would be consistent with the Project’s impact.
Land Use and Planning
Under the Reduced Project Site Alternative, a GPA, SPA and Zone Change would still be required to accommodate residential uses within the Alternative site and increase allowed density within the General Plan. This alternative would be similar in that it would be consistent with all applicable plans and policies and would result in similar development as the Project and meet all applicable Project initiatives. The Reduced Project Site Alternative would be subject to the same goals, policies, programs, and regulations as the Project. Therefore, the Reduced Project Site Alternative would result in similar less than significant impacts as the proposed Project.
Noise
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. However, this alternative would not include development of Site 24. The construction of this alternative would require site clearing, grading, and construction activities similar to the proposed Project at a greater density. Construction activities under this alternative would be required to implement the same mitigation measures as the proposed Project and construction noise impacts would remain less than significant.
Operational noise would be reduced under this alternative as traffic-generated and stationary noise sources would decrease in relation to the removal of public/institutional uses on Site 24. Additionally, the Reduced Project Site Alternative would result in slightly fewer surrounding residents that could be exposed to noise Redlands Regular Meeting of 06-03-25
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from surrounding development and roadways. Overall, operational noise impacts from the Reduced Project Site Alternative would be similar to the impacts associated with the proposed Project and would likely require the same mitigation.
Population and Housing
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. This would increase the number of residents at buildout from 6,456 to 6,464 and would no longer provide 550 employment opportunities within the public/institutional designation. The increase in population that would be generated by this alternative would be consistent with SCAG forecasts and would not induce substantial population growth in the Project area.
The Reduced Project Site Alternative and the proposed Project would result in similar less-than-significant impacts related to population and housing.
Public Services
The Reduced Project Site Alternative would result in a slight increase of development within the Project site over a slightly reduced area. As such, the Reduced Project Site Alternative would result in eight additional residents and 550 fewer employees at full buildout of the Alterative compared to the proposed Project.
Thus, demand for public services, including fire protection, police protection, school services, and library services would be slightly reduced compared to the proposed Project. However, like the proposed Project, the Reduced Project Site Alternative would contribute development impact fees to the City which would result in a less than significant impact and would be similar to those associated with the proposed Project.
Recreation
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. Construction of this alternative would result in generally similar impacts, if not a slightly increased demand for park and recreation facilities. In addition, this alternative would also require the payment of development impact fees imposed by the City of Redlands.
Through implementation of regulatory requirements, impacts would be less than significant. Therefore, this alternative would result in similar less-than-significant impacts as the Project.
Transportation
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. As discussed in Section 5.10, Transportation, all TAZs within the Project site satisfy the City’s screening criteria, except for TAZ 53835402 and TAZ 53835101 which include sites 20, 21, and 23. As such, under the Reduced Project Site Alternative, the same sites would not screen out from further VMT analysis as they would be developed with increased intensity. Because Sites 20 and 21 are more than 80 percent over the threshold for the proposed Project, it is expected that the Reduced Site Alternative would also result in significant and unavoidable impacts at those sites. Thus, the alternative would be required to include the mitigation included for the proposed Project. As such, impacts would be similar in comparison to the proposed project under the Reduced Project Site Alternative, and impacts would be significant and unavoidable.
Tribal Cultural Resources
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. As such, the Reduced Project Site Alternative would result in a decreased potential to adversely affect any historic or undiscovered archeological resources as the Redlands Regular Meeting of 06-03-25
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Draft Subsequent EIR
January 2025
proposed Project, as this alterative would avoid development near the Morey Arroyo, which has a greater potential to contain buried tribal cultural resources. However, like the proposed Project, similar mitigation to the Project’s mitigation measures would be required to reduce potential impacts to a less than significant level. Therefore, impacts to tribal cultural resources from the Reduced Project Site Alternative would consistent with those associated with the proposed Project.
Utilities and Service Systems
Under the Reduced Project Site Alternative, Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 would be developed with 2,439 multifamily residential units. Similar to the proposed Project, additional configurations or connections to existing domestic water, wastewater, stormwater drainage, electric power, natural gas, and telecommunication facilities could be needed with future residential development under this alternative.
Additionally, this alternative would result in increased demand for solid waste collection and disposal and electricity, natural gas and telecommunication services. Therefore, the Reduced Project Site Alternative would result in similar impacts as the proposed Project.
Wildfire
The level of development onsite would be decreased under this alternative as compared to the proposed Project as buildout of Site 24 would not occur. Both the Project and this alternative would be required to comply with the California Building Code and California Fire Code requirements. Development under the Reduced Project Site Alternative would reduce the number of units developed and would also reduce the number of occupants onsite. Sites 2, 7, 8 11, 12, and 16 would remain undeveloped and would not expose any additional occupants to fire hazards. Overall, this alternative would also result in less-than-significant impacts related to wildfires and would result in similar impacts in comparison to the proposed Project.
6.8.2 Conclusion
Ability to Reduce Impacts
The Reduced Project Site Alternative would not eliminate the significant and unavoidable impacts related to agricultural resources, air quality, GHG emissions, and VMT that would occur from implementation of the proposed Project, as buildout under this alternative would be only slightly reduced in comparison to that allowed under the proposed Project. In addition, this alternative would require most of the same mitigation to ensure less than significant impacts related to historical resources, biological resources, cultural resources, paleontological resources, and noise.
Overall, although the volume of impacts would be less under the Reduced Project Site Alternative, the Reduced Project Site Alternative would not eliminate any of the significant and unavoidable impacts that would result from buildout of the proposed Project.
Ability to Achieve Project Objectives
Implementation of the Reduced Project Site Alternative would achieve Objectives 1, 2, and 4 as it would introduce additional residential units in the City to help reach the City’s RHNA goals. The Reduced Project Site Alternative would not meet Objective 3, to minimize potential land use compatibility conflicts associated with the proposed change to existing land use designations and zoning as Site 24 would not be rezoned to Public/Institutional uses to allow for less intense development more similar to its surrounding proposed residential uses.
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City of Redlands 6-26
Draft Subsequent EIR
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6.9 ALTERNATIVE 4: REDUCED PROJECT DEVELOPMENT ALTERNATIVE The Reduced Project Development Alternative would redesignate the Rezone sites to allow for development of future residential and additional square footage of nonresidential development, similar to the proposed Project. However, Project buildout would be reduced by 55 percent; thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF of nonresidential uses. This alternative would still require approval of the GPA, adoption of a zone change, and adoption of an SPA to the EVCSP. Furthermore, under this alternative, only 1,096 dwelling units would be allowed to be constructed and the City would have a 1,315 dwelling unit deficit in meeting their State mandated RHNA fair share.
6.9.1 Environmental Impacts
Aesthetics
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF of nonresidential uses. This alternative would lead to decreased density within the proposed Rezone sites which would result in an increase in landscaping and setbacks. This alternative would introduce new sources of light and glare but would be similarly subject to the requirements of the Redlands Municipal Code. Therefore, aesthetic impacts would be neutral compared to the proposed Project.
Agriculture and Forestry
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Development under the Reduced Project Site Alternative would result in the same loss of Prime Farmland as with the proposed Project and would not avoid the significant and unavoidable impact of converting Farmland to non-agricultural uses. Overall, this alternative would result in significant and unavoidable impacts related to agriculture resources similar to the proposed Project.
Air Quality
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Therefore, a reduced overall volume of construction activities and the related emissions would occur. Under the Reduced Project Development Alternative, it is possible that a combination of developments could occur, such that daily construction emissions would still exceed this threshold. Thus, construction air quality impacts would remain significant and unavoidable.
In addition, the reduced amount of development by this alternative would result in less stationary source emissions from equipment and less traffic associated air emissions than the proposed Project. Therefore, overall air quality impacts would be reduced in comparison to the proposed Project. The volume of VOC, NOx, and CO emissions from operational vehicular emissions generated by the Reduced Project Development Alternative would be reduced to a less-than-significant level due to the 55 percent decrease in volume of vehicular trips that would occur from operation of the alternative. As described in Section 5.2, Air Quality, operations from implementing projects under the proposed Project would generate up to 121.01 lbs/day of VOC emissions, which is substantially above the threshold of 55 lbs/day; 89.74 lbs/day of NOx, which is above the threshold of 55 lbs/day; and 608.04 lbs/day of CO, which is above the threshold of 550 lbs/day during peak summer operations. Under the Reduced Project Development Alternative, the maximum daily VOC, NOx, and CO emissions related to residential operations would similarly be reduced Redlands Regular Meeting of 06-03-25
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by 55 percent, resulting in 54 lbs/day of VOC emissions, 41 lbs/day of NOx emissions, and 274 lbs/day of CO emissions. Therefore, although significant and unavoidable construction impacts may still occur with this Alternative, impacts related to operational emissions would be reduced to a less-than-significant level.
Biological Resources
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Development of this alternative would require removal of existing vegetation in open areas and vacant lots and could potentially impact special status plants, animals, or sensitive vegetation communities. As such, the impacts to biological resources on the Project site would be similar to the Project and require the same mitigation measures. These mitigation measures would also reduce potential impacts from this alternative to a less than significant level. This alternative would result in less- than-significant impacts to biological resources, and therefore, would be consistent with the Project’s impact.
Cultural Resources
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses As such, the Reduced Project Development Alternative would result in the same potential to adversely affect any historic or undiscovered archeological resources as the proposed Project as this alternative would redevelop the same area as the proposed Project, just with less density and would require the implementation of Mitigation Measures CUL-3 and CUL-4. This alternative would have a similar impact on historic structures within the Project site. Similar to the proposed Project, Mitigation Measures CUL-1 and CUL-2 would be implemented and compliance with applicable City of Redlands Municipal Code provisions, including Redlands Historic Architectural Design Guidelines, would be required to reduce potential impacts to a less-than-significant level. Therefore, impacts to cultural resources from the Reduced Project Development Alternative would be the same as those associated with the proposed Project.
Energy
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Under this alternative, a slightly reduced overall volume of construction activities and the related energy demand would occur, which was determined to be less than significant.
Implementing projects under this alternative would be compliant with Title 24 requirements. Therefore, impacts to energy from the Reduced Project Site Alternative would be slightly less than those associated with the proposed Project, but still less than significant.
Geology and Soils
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Potential impacts related to the potential for additional workers, building, and structures to experience seismic ground shaking, liquefaction, lateral spreading, subsidence, or collapse within the Project site would be similar to the Project, however fewer people would be exposed. Soil erosion impacts would also be less than significant due to compliance with water quality standards, and new development would be required to comply with regulatory requirements regarding geologic considerations such as seismic hazards from ground shaking. The same mitigation regarding paleontological resources would be required for this alternative. This alternative would result in less than significant impacts to geology and soils, and therefore, would be consistent with the Project’s impact.
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City of Redlands 6-28
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Greenhouse Gas Emissions
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Therefore, a slightly reduced volume of construction activities and related production of GHG emissions would occur. In addition, the slightly reduced amount of development by this alternative would result in less stationary source emissions from equipment onsite, and less traffic-associated GHG emissions than the proposed Project with the exclusion of the Public/Institutional uses on Site 24.
However, because the Draft EIR utilizes a total CO
2 per service population threshold, the reduction in
development would equal the reduction in population resulting from the alternative and result in similar emissions per service population as the proposed Project. Thus, the Reduced Project Development Alternative would require the implementation of the same mitigation measures that are required for the proposed Project and impacts would remain significant and unavoidable.
Hazards and Hazardous Materials
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Like the proposed Project, construction of this alternative would be required to comply with existing regulations regarding the transport, use, and disposal of hazardous materials. In addition, this alternative would likely require the same utilization of hazardous materials during operation as the proposed Project. Like the proposed Project, this alternative would not require mitigation.
In addition, as this alternative would result in a decrease in building square footage and residents onsite, the alternative would not pose a safety hazard to the people working in the area. This alternative would result in less than significant impacts to hazards and hazardous materials, and therefore, would be consistent with the Project’s impact.
Hydrology and Water Quality
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Due to the decrease in units and parking spaces needed, it is likely that development of this alternative would result in a decrease in impermeable surfaces compared to those required for development of the Project. Construction of the alternative would still be required to implement drainage infrastructure improvements. In addition, preparation of a SWPPP and WQMP would be required for future development under this alternative. Therefore, this alternative would result in similar less-than- significant impacts as the Project, and therefore, would be consistent with the Project’s impact.
Land Use and Planning
Under the Reduced Project Development Alternative, a GPA, SPA and Zone Change would still be required to accommodate residential uses within the Alternative site. This alternative would be similar in that it would be consistent with all applicable plans and policies and would result in similar development as the Project and meet all applicable Project initiatives. The Reduced Project Development Alternative would be subject to the same goals, policies, programs, and regulations as the Project. Therefore, the Reduced Project Development Alternative would result in similar less-than-significant impacts as the proposed Project.
Noise
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of Redlands Regular Meeting of 06-03-25
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67,971.81 SF nonresidential uses. The construction of this alternative would require site clearing, grading, and construction activities similar to the proposed Project at similar intensity. Construction noise impacts would remain less than significant, similar to the proposed Project and would also be required to implement the same mitigation measures due to the proximity to nearby sensitive receptors.
Operational noise would be slightly reduced under this alternative due to the decrease in residents and associated traffic. Similar to the proposed Project, impacts would be reduced to a less-than-significant impact with the implementation of mitigation measures.
Population and Housing
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. This would reduce the number of residents at buildout from 6,456 to 2,905. The decrease in population that would be generated by this alternative would be consistent with SCAG forecasts and would not induce substantial population growth in the Project area. The Reduced Project Development Alternative and the proposed Project would result in similar less-than-significant impacts related to population and housing.
Public Services
The Reduced Project Development Alternative would result in a 55 percent decrease of development over the same area as the Project. As such, the Reduced Project Development Alternative would result in fewer residents at full buildout of the Alterative compared to the proposed Project. Thus, demand for public services, including fire protection, police protection, school services, and library services would be slightly reduced compared to the proposed Project. The Reduced Project Development Alternative would result in a less-than-significant impact and would be similar to those associated with the proposed Project.
Recreation
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Construction of this alternative would result in generally similar impacts, if not a slightly decreased demand for park and recreation facilities. In addition, this alternative would also require the payment of development impact fees imposed by the City of Redlands. Through implementation of regulatory requirements, impacts would be less than significant. Therefore, this alternative would result in similar less-than-significant impacts as the Project.
Transportation
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. As discussed in Section 5.10, Transportation, all TAZs within the Project site satisfy the City’s screening criteria, except for TAZ 53835402 and TAZ 53835101 which include sites 20, 21, and 23. As such, under the Reduced Project Development Alternative, the same sites would not screen out from further VMT analysis. Because Sites 20 and 21 are more than 80 percent over the threshold for the proposed Project, it is expected that even with the Reduced Development Alternative, impacts would remain significant and unavoidable. Thus, the alternative would be required to include the mitigation included for the proposed Project. As such, impacts would be similar in comparison to the proposed Project under the Reduced Project Development Alternative, and impacts would be significant and unavoidable.
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Redlands RHNA Rezone Project 6. Alternatives
City of Redlands 6-30
Draft Subsequent EIR
January 2025
Tribal Cultural Resources
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. As such, the Reduced Project Development Alternative would result in a similar potential to adversely affect any historic or undiscovered archeological resources as the proposed Project. However, like the proposed Project, similar mitigation to the Project’s mitigation measures would be required to reduce potential impacts to a less than significant level. Therefore, impacts to tribal cultural resources from the Reduced Project Site Alternative would be consistent with those associated with the proposed Project.
Utilities and Service Systems
Under the Reduced Project Development Alternative, Project buildout would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. Similar to the proposed Project, under this alternative, additional configurations or connections to existing domestic water, wastewater, stormwater drainage, electric power, natural gas, and telecommunication facilities could be needed with future residential development.
Additionally, this alternative would result in increased demand for solid waste collection and disposal and electricity, natural gas and telecommunication services. Therefore, the Reduced Project Development Alternative would result in similar impacts as the proposed Project.
Wildfire
The level of development onsite would be decreased under this alternative as compared to the proposed Project. Both the Project and this alternative would be required to comply with the California Building Code and California Fire Code requirements. Development under the Reduced Project Development Alternative would reduce the number of units developed and would also reduce the number of occupants onsite. Overall, this alternative would also result in less-than-significant impacts related to wildfires and would result in similar impacts in comparison to the proposed Project.
6.9.2 Conclusion
Ability to Reduce Impacts
The Reduced Project Development Alternative would not eliminate the significant and unavoidable impacts related to agricultural resources, construction air quality emissions, GHG emissions, and VMT that would occur from implementation of the proposed Project. In addition, this alternative would require most of the same mitigation to ensure less than significant impacts related to historical resources, biological resources, cultural resources, paleontological resources, and noise. However, this alternative would avoid the significant and unavoidable impact related to operation air quality emissions.
Overall, although the volume of impacts would be less under the Reduced Project Development Alternative, the Reduced Project Development Alternative would not eliminate most of the significant and unavoidable impacts that would result from buildout of the proposed Project.
Ability to Achieve Project Objectives
The Reduced Project Development Alternative would meet Objective 4, to minimize potential land use compatibility conflicts associated with the proposed change to existing land use designations and zoning as Site 24 would be rezoned to Public/Institutional uses to allow for less intense development more similar to Redlands Regular Meeting of 06-03-25
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its surrounding proposed residential uses. The Alternative would not meet Objectives 1, 2, or 3 as the amount of housing proposed by this Alternative would not be enough for the City to meet their RHNA goals as discussed in the certified Housing Element for the 2021-2029 housing cycle and would not provide enough housing to accommodate all income groups as allocated by RHNA.
6.10 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires a lead agency to identify the “environmentally superior alternative” when significant environmental impacts result from a proposed Project. The Environmentally Superior Alternative for this Project would be Alternative 1, No Project/No Development. The No Project/No Development Alternative would avoid the implementation of the mitigation measures that are identified in Section 5.0 of this Draft Subsequent EIR that are related to air quality, biological resources, cultural resources, geology and soils, greenhouse gas emissions, transportation, and tribal cultural resources.
Additionally, State CEQA Guidelines Section 15126.6(3)(1) states:
The “no project” analysis shall discuss the existing conditions at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.
If the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. (Emphasis added.) Therefore, pursuant to CEQA, because the No Project/No Development Alternative has been identified as the Environmentally Superior Alternative, the Environmentally Superior Alternative among the other alternatives would be Alternative 3, Reduced Project Site Alternative, which would involve rezoning Sites 1, 3, 4, 5, 6, 9, 10, 13, 14, 15, 15A, and 17-23 to be developed with 2,439 multifamily residential units. This alternative would result in lessened impacts on five of the environmental topics. However, this alternative would be required to implement applicable mitigation measures regarding air quality, biological resources, cultural resources, greenhouse gas emissions, paleontological resources, noise, transportation, and tribal cultural resources, similar to the Project. Moreover, implementation of the Reduced Project Site Alternative would achieve Objectives 1, 2, and 4, but would not meet Objective 3, to minimize potential land use compatibility conflicts associated with the proposed change to existing land use designations and zoning as Site 24 would not be rezoned to Public/Institutional uses from Commercial/Industrial to allow for less intense development more similar to its surrounding proposed residential uses.
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Redlands RHNA Rezone Project 6. Alternatives
City of Redlands 6-32
Draft Subsequent EIR
January 2025
Table 6-3: Impact Comparison of the Proposed Project and Alternatives Proposed
Project
Alternative 1:
No Project/No
Development
Alternative 2:
No
Project/Building
out of General
Plan Land Use
Alternative 3:
Reduced Project
Site
Alternative 4:
Reduced Project
Development
Aesthetics Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project; less
than significant
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
less than
significant
Agricultural
Resources
Significant
and
Unavoidable
Less than
proposed
Project,
no impact
Same as
proposed
Project,
significant and
unavoidable
Same as
proposed Project,
significant and
unavoidable
Same as
proposed Project,
significant and
unavoidable
Air Quality Significant
and
Unavoidable
Less than
proposed
Project,
no impact
More than
proposed
Project,
Significant and
Unavoidable
Less than
proposed Project,
significant and
unavoidable
Less than
proposed Project,
significant and
unavoidable
Biological
Resources
Less than
significant
with mitigation
Less than
proposed
Project,
no impact
Same as
proposed
Project,
less than
significant with
mitigation
Same as
proposed Project,
less than
significant with
mitigation
Same as
proposed Project,
less than
significant with
mitigation
Cultural
Resources
Less than
significant
with mitigation
Less than
proposed
Project,
no impact
Same as
proposed
Project,
less than
significant with
mitigation
Less than
proposed Project,
less than
significant with
mitigation
Same as
proposed Project,
less than
significant with
mitigation
Energy Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project;
less than
significant
Less than
proposed Project,
less than
significant
Less than
proposed Project,
less than
significant
Geology and
Soils
Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project;
less than
significant
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
less than
significant
Greenhouse
Gas Emissions
Significant
and
Unavoidable
Less than
proposed
Project,
no impact
More than
proposed
Project,
Significant and
Unavoidable
Less than
proposed Project,
significant and
unavoidable
Less than Project,
significant and
unavoidable
Hazards and
Hazardous
Materials
Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project;
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
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Proposed
Project
Alternative 1:
No Project/No
Development
Alternative 2:
No
Project/Building
out of General
Plan Land Use
Alternative 3:
Reduced Project
Site
Alternative 4:
Reduced Project
Development
less than
significant
less than
significant
Hydrology and
Water Quality
Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project;
less than
significant
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
less than
significant
Land Use and
Planning
Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project;
less than
significant
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
less than
significant
Noise Less than
significant
with mitigation
Less than
proposed
Project,
no impact
More than
proposed
Project,
less than
significant with
mitigation
Same as
proposed Project,
less than
significant with
mitigation
Same as
proposed Project,
less than
significant with
mitigation
Population and
Housing
Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project, less than
significant
Same as
proposed Project,
less than
significant
Same as
proposed Project,
less than
significant
Public Services Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project, less than
significant
Same as
proposed Project,
less than
significant
Same as
proposed Project,
less than
significant
Recreation Less than
significant
Less than
proposed
Project, no
impact
Same as
proposed
Project, less than
significant
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
less than
significant
Transportation Significant
and
Unavoidable
Less than
proposed
Project,
no impact
More than
proposed
Project,
Significant and
Unavoidable
Same as
proposed Project,
significant and
unavoidable
Same as
proposed Project,
significant and
unavoidable
Tribal Cultural
Resources
Less than
significant
with mitigation
Less than
proposed
Project,
no impact
Same as
proposed
Project,
less than
significant with
mitigation
Less than
proposed Project;
less than
significant with
mitigation
Same as
proposed
Project;
less than
significant with
mitigation
Utilities and
Service Systems
Less than
significant
with mitigation
Less than
proposed
Project,
no impact
Same as
proposed
Project;
less than
significant
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
less than
significant
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Proposed
Project
Alternative 1:
No Project/No
Development
Alternative 2:
No
Project/Building
out of General
Plan Land Use
Alternative 3:
Reduced Project
Site
Alternative 4:
Reduced Project
Development
Wildfire Less than
significant
Less than
proposed
Project,
no impact
Same as
proposed
Project;
less than
significant
Same as
proposed Project;
less than
significant
Same as
proposed
Project;
less than
significant
Reduce Impacts of the Project? Yes No Yes Yes
Areas of Reduced Impacts
Compared to the Project 19 0 5 3
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Table 6-4: Comparison of the Proposed Project and Alternatives Ability to Meet Objectives Proposed
Project
Alternative 1:
No Project/
No
Development
Alternative 2:
No
Project/Building
out of General
Plan Land Use
Alternative 3:
Reduced
Project Site
Alternative 4:
Reduced
Project
Development
1. Implement Program
1.1-1 of the 6th Cycle
2021-2029 Housing
Element to provide
adequate capacity
for at least 4,219
units on suitable sites.
Yes No No Yes No
2. Maintain adequate
housing sites for all
income groups
throughout the eight-
year planning period.
Yes No No Yes No
3. Minimize potential
land use compatibility
conflicts associated
with the proposed
change to existing
land use designations
and zoning.
Yes No No No Yes
4. Increase the City’s
overall housing
capacity and
capability to
accommodate housing
as required per the
certified Housing
Element for the 2021-
2029 housing cycle.
Yes No No Yes No
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7. EIR Preparers and Persons Contacted
7.1 EIR PREPARERS
City of Redlands
Kevin Beery, Senior Planner
Brian Foote, AICP, Planning Manager
Brian Desatnik, Development Services Department Director EPD Solutions, Inc.
Jeremy Krout, AICP
Konnie Dobreva, JD
Meghan Macias, TE
Alex Garber
Renee Escario
Meaghan Truman
Brady Connolly
Lauren Battle
Fuscoe Engineering, Water Supply Assessment and Water & Sewer Demand Study Ian Adam, QSD/QSP
Danielle Adili
Urban Crossroads, Air Quality, Energy, and Greenhouse Gas Analyses Haseeb Qureshi
Alyssa Barnett
Ali Dadabhoy
7.2 ORGANIZATIONS AND PERSONS CONTACTED
City of Redlands Fire Department
City of Redlands Police Department
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1 I:\cmo\Resolutions\8687 EIR 2021-2029 Housing Element Rezoning Project.docx-ms
RESOLUTION NO. 8687
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS
ADOPTING FINDINGS OF FACT, A STATEMENT OF OVERRIDING
CONSIDERATIONS, A MITIGATION MONITORING & REPORTING
PROGRAM, AND CERTIFYING THE FINAL SUBSEQUENT
ENVIRONMENTAL IMPACT REPORT PREPARED FOR THE 2021–2029
HOUSING ELEMENT REZONING PROJECT.
WHEREAS, the City of Redlands (“City”) has initiated General Plan Amendment No. 149, Amendment No. 1 to Concept Plan No. 4, Amendment No. 54 to Specific Plan No. 40 (East Valley Corridor Specific Plan), and Zone Change No. 479, to amend the General Plan and Specific Plan land use maps as well as the City Zoning Map to rezone 27 parcels for the regional housing needs allocation (“RHNA”) rezoning project (collectively herein referred to as “Project”) as required by the City’s certified 2021–2029 Housing Element; and
WHEREAS, on June 27, 2024, the City, acting as the Lead Agency under the California Environmental Quality Act (“CEQA”), published a notice of preparation and initiated work on a Draft Subsequent Environmental Impact Report (“Draft SEIR”) for the Project; and WHEREAS, on July 18, 2024, a public scoping meeting was conducted to receive input on the preparation of the Draft SEIR; and
WHEREAS, on January 21, 2025, the Draft SEIR was circulated for public review with a 45-day public review and comment period beginning on January 22, 2025, and ending on March 7, 2025; and
WHEREAS, on April 9, 2025, the City prepared the Final Subsequent Environmental Impact Report (“Final SEIR”) for the Project by incorporating therein the Draft SEIR; comments received about the Draft SEIR and responses to those comments; and changes, clarifications, and corrections to the Draft SEIR; and
WHEREAS, on April 9, 2025, the Final SEIR was made available to those public agencies that commented on the Draft SEIR as well as all other commenters; and WHEREAS, the Environmental Impact Report, comprising the Draft SEIR and the Final SEIR, is a program EIR that examines the potential effects resulting from implementing the Project; and
WHEREAS, on April 22, 2025, the Planning Commission reviewed the Final SEIR comprising the Draft SEIR dated January 2025, comments received on the Draft SEIR, and the Response to Comments Document dated April 2025 (collectively, the “CEQA Documentation”); and reviewed the Findings of Fact and Statement of Overriding Considerations; and Redlands Regular Meeting of 06-03-25
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WHEREAS, April 22 , 2025, the Planning Commission held a public hearing and considered the City staff’s verbal and written reports, and the written and verbal testimony submitted by members of the general public; and
WHEREAS, on April 22, 2025, the Planning Commission recommended that the City Council adopts the Findings of Fact, Statement of Overriding Considerations, and Mitigation Monitoring and Reporting Program, and certifies the Final SEIR prepared for the Project; and WHEREAS, on June 3, 2025, the City Council reviewed the CEQA Documentation for the Project; and
WHEREAS, on June 3, 2025, the City Council considered the recommendation of the Planning Commission, City staff’s verbal and written reports, and the written and verbal testimony submitted by members of the general public.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS AS FOLLOWS:
Section 1. California Environmental Quality Act. The City Council has received, reviewed and considered the CEQA Documentation and other substantive and procedural components of CEQA compliance for the Project. The CEQA Documentation prepared for the Project has been completed, and review procedures as required by CEQA for a Lead Agency have been completed in conformance with CEQA as set forth in the recitals to this resolution.
Pursuant to CEQA, including without limitation, CEQA Guidelines section 15090, the City Council further finds and determines that: the City has complied with its duties as Lead Agency for the Project, the CEQA Documentation was presented to the City Council, and the City Council has reviewed and considered the information contained therein. Further, the City Council finds that the CEQA Documentation was prepared in compliance with CEQA, specifically:
1. That a Notice of Preparation was published on June 27, 2024, giving public agencies and members of the public until thirty (30) days after their receipt of the Notice of Preparation to review and respond to the proposed scope of the Project; a copy of such notice was mailed to interested parties, all affected property owners of record for the 27 subject parcels, all property owners within a 300-foot radius of the 27 subject parcels, surrounding cities and other public agencies; and a duly noticed public scoping meeting was held on July 18, 2024.
2. That the Draft SEIR was prepared in compliance with CEQA Guidelines sections 15120 through 15132.
3. That the Draft SEIR was published on January 21, 2025, and circulated for public review and comment from January 22, 2025, through March 7, 2025, thus complying with the 45- day review period; and as part of this review period, a Notice of Availability was posted and mailed to interested parties, all affected property owners of record for the 27 subject Redlands Regular Meeting of 06-03-25
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parcels, all property owners within a 300-foot radius of the 27 subject parcels, surrounding cities and other public agencies.
4. That the Final SEIR has been prepared consisting of: the Draft SEIR, the comments and recommendations received on the Draft SEIR, and the response of the City to the written comments received.
5. That the CEQA Documentation (incorporated herein by reference) was prepared in accordance with the applicable provisions of the CEQA Guidelines.
Section 2. Certification of Subsequent Environmental Impact Report . The City Council finds that the Final SEIR reflects the independent judgment and analysis of the City. The City Council specifically finds that the Final SEIR for the Project accurately and completely presents adequate information upon about the broad effects of implementing the Project. The City Council finds that the proposed Project may result in significant environmental effects (e.g., agricultural resources, air quality, greenhouse gases, and transportation) and such effects were analyzed in the Draft SEIR and disclosed during the public comment period as required by CEQA . The City Council also finds that the Findings of Facts and Statement of Overriding Considerations provide sufficient justification for approving the proposed Project, even though there may be significant environmental effects to agricultural resources, air quality, greenhouse gases, or transportation.
The City Council hereby adopts the Findings of Facts and Statement of Overriding Considerations, as well as the Mitigation Monitoring & Reporting Program (attached hereto as Exhibits “A” and “B,” respectively), and certifies the Final SEIR pursuant to section 15090 of the CEQA Guidelines.
Section 3. Custodian of Records . The custodian of documents and other materials which constitute the record of proceedings upon which this determination is based is the Development Services Director or designee, and all records are located in the City Development Services Department.
Section 4. Effective Date. This Resolution shall become effective upon adoption.
ADOPTED, SIGNED AND APPROVED this 3rd day of June, 2025.
Mario Saucedo, Mayor
ATTEST:
____________________________
Jeanne Donaldson, City Clerk
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I, Jeanne Donaldson, City Clerk of the City of Redlands, hereby certify that the foregoing Resolution was duly adopted by the City Council at a regular meeting thereof, held on the 3rd day of June, 2025, by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
__________________________________
Jeanne Donaldson, City Clerk
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EXHIBIT A
FINDINGS OF FACT AND
STATEMENT OF OVERRIDING CONSIDERATIONS
[Attached]
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EXHIBIT B
MITIGATION MONITORING & REPORTING PROGRAM
[Attached]
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CEQA FINDINGS OF FACT
FOR THE
REDLANDS RHNA REZONE PROJECT
CITY OF REDLANDS, CALIFORNIA
STATE CLEARINGHOUSE NO. 2016081041
Public Resources Code Section 21002 states that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” Section 21002 further states that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which would avoid or substantially lessen such significant effects.”
Agencies demonstrate compliance with Section 21002’s mandate by adopting findings before approving projects for which EIRs are required. (See Pub. Resources Code, § 21081, subd. (a); State CEQA Guidelines § 15091, subd. (a).) The approving agency must make written findings for each significant enviro nmental effect identified in an EIR for a proposed project and must reach at least one of three permissible conclusions. • The first possible finding is that “[c]hanges or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR.” (State CEQA Guidelines § 15091, subd. (a)(1).) • The second permissible finding is that “[s]uch changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding” and that “[s]uch changes have been adopted by such other agency or can and should be adopted by such other agency.” (State CEQA Guidelines § 15091, subd. (a)(2).)
• The third potential conclusion is that “[s]pecific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.” (State CEQA Guidelines § 15091, subd. (a)(3).)
Agencies must not approve a project with significant environmental impacts if feasible alternatives or mitigation measures would substantially lessen the significant impacts. Public Resources Code Section 21061.1 defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social and technological factors.” State CEQA Guidelines Section 15364 adds “legal” considerations as another indicium of feasibility (Se e also Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565). Project objectives also inform the determination of “feasibility.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417.) Further, “‘feasibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” (Id.; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) An agency need not, however, adopt infeasible mitigation measures or alternatives (State CEQA Guidelines § 15091, subds. (a), (b). Further, environmental impacts that are less than significant do not require the imposition of mitigation measures (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347).
Notably, Section 21002 requires an agency to “substantially lessen or avoid” significant adverse environmental impacts. Thus, mitigation measures that “substantially lessen” significant environmental impacts, even if not completely avoid them, satisfy Section 21002’s mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 (“CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level ”); Las Virgenes Homeowners Federation, Inc. v. County of Los Angeles (1986) 177 Cal.App.3d 300, 309 (“[t]here is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance . . . if such would render the project unfeasible”).
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CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to substantially lessen or avoid significant environmental impacts that would otherwise occur. Project modification or alternatives are not required , however, where such changes are infeasible or where the responsibility for modifying the project lies with some other agency. (State CEQA Guidelines § 15091, subds. (a), (b). The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced.” (Citizens of Goleta Valley v. Board of Supervisors, supra, 52 Cal.3d at p. 576).
The City of Redlands has determined that based on all the evidence presented, including, but not limited to, the Final EIR, written and oral testimony given at meetings and hearings on the Project, and submission of testimony from the public, organizations and regulatory agenc ies, the following environmental impacts associated with the Project are either:
(1) Less than significant and do not require mitigation; or (2) Potentially significant and each of these impacts would be avoided or reduced to a level of insignificance through the identified mitigation measures.
(3) Significant and cannot be fully mitigated to a level of less than significant but will be substantially lessened to the extent feasible by the identified mitigation measures.
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SECTION I
ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION
The Final EIR includes the Draft Subsequent Environmental Impact Report (EIR) dated January 2025, written comments on the Draft Subsequent EIR that were received during the public review period, written responses to those comments , changes to the Draft Subsequent EIR, and the Mitigation Monitoring and Reporting Program (MMRP). In conformance with CEQA and the State CEQA Guidelines, the City of Redlands conducted an extensive environmental review of the Redlands RHNA Rezone Project that includes the following:
• Completion of an Initial Study (IS) by the City of Redland s, which concluded that a n EIR should be prepared, and the Notice of Preparation (NOP) released for a 30-day public review period. The NOP was posted on the City’s website www.cityofredlands.org on July 1, 2024. The NOP was posted to the State Clearinghouse’s ceqanet.opr.ca.gov for public review from July 1, 2024, through July 31, 2024.
The NOP was also published in the Redlands Daily Facts newspaper on July 1, 2024. Copies of the NOP were mailed to neighbors within a 300- foot radius of the Project site. Copies of the IS were made available for public review and download via the City’s website at:
https://www.cityofredlands.org/post/environmental-documents • Completion of a scoping process, in which agencies and the public were invited by the City of Redlands to participate. The public scoping meeting for the EIR was held on July 18, 2024, at 4:30 p.m. via Zoom.
The notice of the public scoping meeting was included in the NOP distributed on July 1, 2024. • Preparation of a Draft EIR by the City of Redlands was made available for a 4 5-day public review period (January 22, 2025, through March 7, 2025). The Notice of Availability (NOA) for the Draft Subsequent EIR was sent to all persons, agencies and organizations on the interested persons list, all neighbors within 300-feet of the Project site, published on the City’s website, and filed with the County Clerk. The NOA was also published in the Redlands Daily Facts newspaper on January 22, 2025. • The NOA of the Draft Subsequent EIR was posted to the State Clearinghouse’s ceqanet.opr.ca.gov for public review from January 22, 2025, through March 7, 2025. Copies of the NOA and EIR were posted at the City of Red lands Development Service Department at 35 Cajon Street, Redlands, CA 92 373 throughout the public review period. Copies of the Draft Subsequent EIR were made available for public review and download via the City’s website at: https://www.cityofredlands.org/post/environmental- documents
• The Final EIR contains comments on the Draft Subsequent EIR, responses to those comments, revisions to the Draft Subsequent EIR if any, the Mitigation Monitoring and Reporting Program, and appended documents. The Final EIR was released more than 10 days prior to certification of the Final EIR. • After considering the EIR and in conjunction with making these findings, the City of Redlands hereby finds that pursuant to Section 15092 of the CEQA Guidelines that approval of the Project will result in significant effects on the environment, however, the significant effects will be eliminated or substantially lessened where feasible and has dete rmined that remaining significant effects are found to be acceptable under Section 15093.
• The Mitigation Monitoring and Reporting Program is hereby adopted to ensure implementation of feasible mitigation measures identified in the EIR. The City of Redlands finds that these mitigation measures are fully enforceable and shall be binding upon the City and affected parties. • The City of Redlands finds that the Project is in the public interest and is necessary for the public health, safety, and welfare.
• The City of Redlands hereby certifies the Final EIR in accordance with the requirements of CEQA. • Pursuant to CEQA Guidelines Section 15095, staff is directed as follows: a) copy of the Final EIR and CEQA Findings of Fact shall be retained in the Project files; b) copy of the Final EIR and CEQA Findings of Fact shall be provided to all CEQA "responsible" agencies.
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SECTION II
ENVIRONMENTAL IMPACTS NOT REQUIRING MITIGATION
The City prepared an Initial Study that determined that potentially significant environmental effects could occur and that a Subsequent EIR should be prepared for the Project. The scope of the Subsequent EIR was determined based upon the Initial Study. Based upon the Initial Study, the City determined that the Project would have no impacts or a less than significant impact related to the following environmental topic areas and that no further analysis of these topics was required in the Subsequent EIR:
• Aesthetics
• Geology and Soils
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Mineral Resources
• Recreation
• Wildfire
Section 15091 of the State CEQA Guidelines does not require specific findings to address environmental effects that an EIR identifies as “less than significant” where no mitigation is required. These findings will nevertheless fully account for all such ef fects identified in the Initial Study and Draft Subsequent EIR in this Section II. Thus, the City hereby finds that the following potential environmental impacts of the Project are less than significant and do not require the imposition of mitigation measures:
A. Aesthetics
Impact AE-1 Finding: The Project would not have a substantial adverse effect on a scenic vista (Initial Study at p. 39). Impacts would be less than significant.
Facts in Support of Finding: Scenic vistas in the City consist of the scenic corridors and views to and from the open spaces, canyonlands, hillsides, groves, and the San Bernardino Mountains. Scenic views are also found in the urbanized part of the city, including along scenic and historic drives. The Project area (Sites 1- 24) consists of an urbanized environment that does not include or provide scenic vistas. Land use changes that would occur under the Project are in or near already developed areas of the City and coincide with areas designated for development under the current General Plan land use designations. Additionally, structures resulting from the Project would be generally within the heights of the existing developed areas and within the development guidelines set forth in the Municipal Code to ensure they would not block views of or from these scenic vistas as the structures would be consistent with views presently found in the area.
Future individual development projects would still be subject to development and planning review and must therefore conform to zoning and other ordinances regarding aesthetic qualities such as lighting, signage, landscaping, and building setbacks. Due to t he siting and nature of the proposed land use changes, and General Plan policies that ensure that new development will have minimal impact on scenic corridors and other scenic resources, the proposed Project will have a less than significant impact on the City’s scenic vistas.
Impact AE-2 Finding: The Project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway (Initial Study at p. 4 0).
Impacts would be less than significant.
Facts in Support of Finding: There are currently no designated State scenic highways within the vicinity of the Project site. However, State Route (SR) 38 is an eligible, however not officially designated, State scenic highway. SR 38 traverses between the two project areas, however neither is within the viewshed of the highway, as sites 1 through 16A and 24 are located approximately 1 mile southeast and sites 17 through Redlands Regular Meeting of 06-03-25
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23 are located approximately one half to one mile north of the eligible highway, with various commercial and residential developments between the highway and the proposed Project site. The proposed Project site is not located adjacent to or within the viewshed of any of the City designated scenic/historical streets. As such, the Project would not result in the potential to damage scenic resources within a State or City-designated scenic highway or roadway.
Impact AE-3 Finding: The Project would not conflict with applicable zoning and other regulations governing scenic quality (Initial Study at p. 40). Impacts would be less than significant.
Facts in Support of Finding: Full buildout of the Project area would result in the development of 2,436 dwelling units and 151,048.46 SF of Public/Institutional space. 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. Implementing projects pursuant to the proposed Project would undergo development review in order to ensure that the Project would meet all applicable development standards pursuant to the Redlands General Plan and Redlands Municipal Code. Overall, the proposed Project area is located within an urbanized area and would not conflict with applicable zoning and other regulations governing scenic quality. Hence, the proposed Project would not degrade the visual character of the surrounding area; and impacts would be less than significant.
Impact AE-4 Finding: The Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area (Initial Study at p. 41) Impacts would be less than significant.
Facts in Support of Finding:
Construction: Limited, if any, nighttime lighting would be needed during future construction projects allowed by the proposed Project because Redlands Municipal Section 8.06.120 limits construction activities to the hours of 7:00 a.m. and 6:00 p.m. on weekdays and Saturdays. Thus, most construction activity would occur during daytime hours, and construction-related low-level illumination would be used for safety and security purposes only. In addition, construction activities do not include any materials or machinery that woul d generate offsite glare. Therefore, impacts related to lighting and glare during construction activities would be less than significant.
Operation: All future projects would be required to comply with the applicable development standards for the site. Glare is not expected to result from the increase in pavement or from any future structures as non- reflective materials and architectural coatings would be utilized in the project design in accordance with Redlands Municipal Code Section 18.12.170(B)(7). Future projects would include specific setbacks, lighting standards, and building materials that would ensure the avoidance of potential lighting impacts. Therefore, the Project would result in a less than significant impact.
Aesthetics Cumulative Finding: The Project would not have a cumulative adverse impact related to aesthetics.
Facts in Support of Finding: Implementation of the Project would result in a coordinated development from implementation of the design guidelines and development standards that would be ensured through the City’s development permitting process. Therefore, cumulative impacts would be less than significant.
The cumulative aesthetics study area for the Project includes the viewshed from public areas that can view the Project site as well as locations that can view the Project site. The Project area (Sites 1-24) consists of an urbanized environment that does not include or provide scenic vistas . Land use changes that would occur under the Project are in or near already developed areas of the City and coincide with areas designated for development under the current General Plan land use designations. Additionally, structures resulting from the Project would be generally within the heights of the existing developed areas and within the development Redlands Regular Meeting of 06-03-25
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guidelines set forth in the Municipal Code to ensure they would not block views of or from these scenic vistas as the structures would be consistent with views presently found in the area.
Implementing projects pursuant to the proposed Project would undergo development review in order to ensure that the Project would meet all applicable development standards pursuant to the Redlands General Plan and Redlands Municipal Code. Overall, the proposed Project area is located within an urbanized area and would not conflict with applicable zoning and other regulations governing scenic quality. Furthermore, the Project would comply with Municipal Code Section 18.12.170(B)(7) regarding outdoor lighting. Nearby projects would also be built in compliance with the Municipal Code and would therefore not result in a cumulative impact related to outdoor lighting. Thus, the Project would not result in an impact that could be cumulatively considerable related to scenic quality.
B. Agriculture and Forestry Resources
Impact AG-2 Finding: The Project would not conflict with existing zoning for agriculture use, or a Williamson Act contract (Initial Study at p. 44). Impacts would be less than significant.
Fact in Support of Finding: The Project site is not under an active Williamson Act contract. Therefore, the development of the Project would not result in the cancellation of the contract and impacts related to a Williamson Act contract would not occur. There is one site, Site 20, which is zoned for agricultural uses.
However, the Site 20 has not been used for agricultural purposes since at least 1994 and since then the site has remained vacant. In addition, the site has an existing General Plan designation of Medium Density Residential. Therefore, impacts would be less than significant.
Impact AG-3 Finding: The Project would not conflict with existing zoning, or cause rezoning of, forest land (as defined in Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)) (Initial Study at p. 44). No impact would occur.
Facts in Support of Finding: The proposed Project area is an urbanized environment. None of the parcels within the proposed Project are currently zoned as forest land, timberland, or Timberland Production.
Therefore, no impact would occur.
Impact AG-4 Finding: The Project would not result in the loss of forest land or conversion of forest land to non-forest use (Initial Study on p. 44). No impact would occur.
Facts in Support of Finding: No forest land exists in the Project area, and implementation will not result in the loss of forest land or the conversion of forest land to non-forest use. Therefore, no impact would occur.
C. Air Quality
Impact AQ -4 Finding: The Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people (Initial Study at p. 47) . Impacts would be less than significant.
Facts in Support of Finding: During construction of future development allowed under the Project, some odors may be present due to diesel exhaust. However, these odors would be temporary and limited to the construction period. The Project would allow for the development of future residential and public/institutional uses and would not include any activities or operations that would generate objectionable odors once operational. Therefore, the proposed Project would not result in other emissions (such as those leading to odors) affecting a substantial number of people, and impacts would be less than significant.
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D. Biological Resources
Impact BIO-4 Finding: The Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites (Initial Study at p. 51). Impacts would be less than significant.
Facts in Support of Finding: No wildlife corridors, native wildlife nursery sites, or bodies of water in which fish are present are located within the Project site or in the surrounding area. The Migratory Bird Treaty Act of 1918 (MBTA) implements the United States’ commitment to four treaties with Canada, Japan, Mexico, and Russia for the protection of shared migratory bird resources. The MBTA governs the taking, killing, possession, transportation, and importation of migratory birds, their eggs, parts, an d nests. The U.S. Fish and Wildlife Service (USFWS) administers permits to take migratory birds in accordance with the MBTA. The City requires that all projects comply with the MBTA by either avoiding grading activities during the nesting season (February 15 to August 15) or conducting a site survey for nesting birds prior to commencing grading activities. Projects implemented under the Project would be required to comply with the provisions of the MBTA. Adherence to the MBTA regulations would ensure that if construction occurs during the breeding season, appropriate measures would be taken to avoid impacts to any nesting birds if found. With adherence to the MBTA requirements, less than significant impacts would occur.
Impact BIO -5 Finding: The Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance (Initial Study at p. 51). Impacts would be less than significant.
Facts in Support of Finding: The Project would not conflict with any local policies or ordinances protecting biological resources. The City has a Street Tree Policy and Protection Guidelines Manual (adopted January 2013) and a tree protection ordinance codified as Redlands Municipal Chapter 12.52 for street trees and trees in public places. Future development and/or redevelopment activities that would be permitted under the Project would be required to be reviewed by the City for consistency with the existing tree policies and guidelines. Therefore, the Project would not conflict with any local policies or ordinances protecting biological resources, and no impacts would occur.
Impact BIO-6 Finding: The Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan (Initial Study at p. 51). No impact would occur.
Facts in Support of Finding: The Project is within an urbanized area, and there are no adopted regional conservation plans in the City. The Upper Santa Ana Wash Land Management and Habitat Conservation Plan, known also as the Wash Plan is the culmination of over a decade of coordination to develop an integrated approach to permit and mitigate all construction and maintenance activities within the Santa Ana River wash area, including water conservation, wells and water infrastructure, aggregate mining, transportation, flood control, agriculture, trails, and habitat enhancement. The Wash Plan was adopted in 2020. The Project area is located approximately 0.75 miles southwest of the nearest Wash Plan boundaries, with residential and commercial development in between the Project and the Wash Plan boundaries.
Implementation of the Project would not conflict or otherwise impact the Wash Plan policies or objectives.
Therefore, the Project would not conflict with the provisions of an adopted habitat conservation plan or natural community conservation plan and no impacts would occur.
E. Cultural Resources
Impact CUL-3 Finding: The Project would not disturb any human remains, including those interred outside of formal cemeteries (Initial Study at p. 55). Impacts would be less than significant.
Facts in Support of Finding: There are no known human remains on or near the Project area, including formal cemeteries. Additionally, the sites are located within an urbanized environment. Because the area has Redlands Regular Meeting of 06-03-25
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already been previously disturbed and developed, it has been subject to construction and ground-disturbing activities. The likelihood that human remains may be discovered during further site clearing and grading activities is considered extremely low. However, ground -disturbing activities have the potential to disturb previously undiscovered subsurface human remains. In the unlikely event that human remains are uncovered during ground-disturbing activities, California Health and Safety Code Section 7050.5 states that if human remains are discovered, no further disturbance shall occur until the County Coroner has made a determination of origin and disposition. This regulation is applicable to any project where ground disturbance would occur.
Section 7052 of the California Health and Safety Code makes the willful mutilation, disinterment, or removal of human remains a felony. Therefore, compliance with existing l aw regarding the discovery of human remains would reduce potential impacts to human remains to less than significant levels F. Energy
Impact E -1 Finding: The Project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during Project construction or operation (Draft Subsequent EIR at p. 5.4-7). Impacts would be less than significant.
Facts in Support of Finding:
Construction: Construction activities related to the Project and the associated infrastructure are not expected to result in demand for fuel greater on a per-unit-of-development basis than other development projects in Southern California. Also, California Code of Regulations (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. Thus, impacts related to construction energy usage would be less than significant.
Operation: Once operational, the Project would generate demand for electricity, natural gas, as well as gasoline or diesel 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. As shown in Draft Subsequent EIR Tables 5.4-2 and 5.4-3, the Project would result in a total of 11,493,948 kWh/year of electricity, 2,081,210 gallons of vehicle fuel, and 30,522,697 kBTU/year of natural gas. This would result in a decrease in energy uses compared to the existing approved General Plan buildout, which would result in 19,869.824 kWh/year of electricity, 4,330,815 gallons of vehicle fuel, and 31,062,419 kBTU/year of natural gas.
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 Finding: The Project would not conflict with or obstruct a S tate or local plan for renewable energy or energy efficiency (Draft Subsequent EIR at p. 5.4-9). No impact would occur.
Facts in Support of Finding: 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 Redlands Regular Meeting of 06-03-25
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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.
Energy Cumulative Finding: The Project would not result in cumulative energy consumption which would be cumulatively wasteful, inefficient, or unnecessary (Draft Subsequent EIR at p. 5.4-9). Impacts would be less than significant.
Facts in Support of Finding: 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 t hroughout the southern California region.
All development projects throughout the region would be required to comply with the energy efficiency standards in the Title 24 requirements. Additionally, some of the developments could provide for additional reductions in energy consumption by use of sol ar panels, sky lights, or othe r types of energy efficiency infrastructure. With implementation of the existing energy conservation regulations, cumulative electricity and natural gas consumption would not be cumulatively wasteful, inefficient, or unnecessary.
Petroleum consumption associated with the proposed 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.
G. Geology and Soils
Impact GEO-1i Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault (Initial Study at p. 60). No impact would occur.
Facts in Support of Finding: The closest fault is the Redlands Fault of the Crafton Hills Fault Zone, located south of Highland Avenue/Fifth Avenue (approximately 2.25 miles from Site 24). Therefore, future development projects constructed under the proposed Project would not expose people or structures to potential substantial adverse effects from rupture of a known earthquake fault that is delineated on an Alquist-Priolo Earthquake Fault Zoning Map. No impact would occur.
Impact GEO-1ii Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking (Initial Study at p. 60). Impacts would be less than significant.
Facts in Support of Finding: A major earthquake along the Redlands Fault of the Crafton Hills Fault Zone could cause substantial seismic ground shaking at the site. However, structures built in the City are required to be built in compliance with the CBC (California Code of Regulations, Title 24, Part 2) that provides provisions for earthquake safety based on factors including building occupancy type, the types of soils on- site, and the probable strength of ground motion. Compliance with the CBC would require the incorporation of: (1) seismic safety features to minimize the potential for significant effects as a result of earthquakes; (2) proper building footings and foundations; and ( 3) construction of the building structure so that it would withstand the effects of strong ground shaking. The City’s permitting process would ensure that all required CBC seismic safety measures are incorporated into the building. Compliance with the CBC as verified by the City’s review process, would reduce impacts related to strong seismic ground shaking to a less than significant level.
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Impact GEO-1iii Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic -related ground failure, including liquefaction (Initial Study at p. 61). Impacts would be less than significant.
Facts in Support of Finding: The proposed Project would increase the potential residential buildout within the City; however, the Project site and the immediate surrounding areas are not located in an area that is susceptible to liquefaction. Furthermore, the Project would be developed in compliance with construction requirements under CBC and building designs as a condition of construction permit approval. Therefore, potential impacts related to hazards from seismic-related ground failure would be less than significant.
Impact GEO-1iv Finding: The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides (Initial Study at p. 61). Impacts would be less than significant.
Facts in Support of Finding: The Project site is located in a seismically active region subject to strong ground shaking. However, the Project site is located in a flat area that does not contain or is adjacent to large slopes, and the Project would not create large slopes. Additionally, the sites are not located in an area susceptible to landslides, as mapped in Figure 3.6-3 of the General Plan EIR, and are not in the path of any potential landslides. As a result, implementation of the Project would not expose people or structures to substantial adverse effects involving landslides, and potential impacts related to landslides would not occur.
Thus, there would be no impact.
Impact GEO-2 Finding: The Project would not result in soil erosion or the loss of topsoil (Initial Study at p. 61). Impacts would be less than significant.
Facts in Support of Finding: Construction of the Project has the potential to contribute to soil erosion and the loss of topsoil. Grading and excavation activities would be required that would expose and loosen topsoil, which could be eroded by wind or water. However, to reduce the potential for soil erosion and the loss of topsoil, a Stormwater Pollution Prevention Plan (SWPPP) is required by the Regional Water Quality Control Board (RWQCB) regulations to be developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address site-specific conditions related to specific grading and construction activities. The SWPPP is required to identify potential sources of erosion and sedimentation loss of topsoil during construction, identify erosion control BMPs to reduce or eliminate the erosion and loss of topsoil. With implementation of the SWPPP, construction impacts related to erosion and loss of topsoil would be less than significant.
Generally, once construction is complete and exposed areas are revegetated or covered by buildings, asphalt, or concrete, the erosion hazard is substantially eliminated or reduced. Therefore, the potential for adverse soil erosion and topsoil loss would be less than significant.
Impact GEO-3 Finding: The Project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on - or off-site landslide, lateral spreading, subsidence, liquefaction or collapse (Initial Study at p. 62). Impacts would be less than significant.
Facts in Support of Finding: The proposed Project would increase the potential residential buildout within the City; however, the proposed sites are within a generally flat area that is not subject to landslides, and due to the flat topography, the potential for lateral spreading is also considered very low. The proposed Project area is not identified as being located on a geologic unit or soil that is unstable, or that would become unstable because of development activities. Project construction would be developed in compliance with the CBC and the recommendations of the Geotechnical Investigation related to construction on soils of varying strengths. Therefore, potential impacts would be less than significant.
Impact GEO-4 Finding: The Project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property (Initial Study at p. 62). Impacts would be less than significant.
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Facts in Support of Finding: The Geotechnical Investigation (Appendix A of the Initial Study) described that the soils within the Project site have a low potential for expansion. Any potential hazards related to unstable soils would be addressed through the integration of geotechnical information and design recommendations in the design and construction process for future individual development projects in accordance with the CBC requirements which minimize the risk associated with soils hazards. Therefore, less than significant impacts related to expansive soils would occur.
Impact GEO-5 Finding: The Project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater (Initial Study at p. 63). No impact would occur.
Facts in Support of Finding: The development of the Project site would not involve use of septic tanks or alternative methods for disposal of wastewater into subsurface soils. Future development projects would include connection to existing wastewater infrastructure. Therefore, the Project would not result in any impacts related to septic tanks or alternative wastewater disposal methods.
Plans, Policies and Programs (PPP)
PPP HYD-1: SWPPP. As listed in Section II, Subsection I, Hydrology and Water Quality.
H. Hazards and Hazardous Materials
Impact HAZ-1 Finding: The Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials (Initial Study at p. 67). Impacts would be less than significant.
Facts in Support of Finding:
Construction: The construction activities that would occur by the Project would involve transport, use, and disposal of hazardous materials such as paints, solvents, oils, grease, and caulking. In addition, hazardous materials would be needed for fueling and servicing c onstruction equipment on the site. These types of materials are not acutely hazardous, and all storage, handling, use, and disposal of these materials are regulated by county, State , and federal regulations, which construction activities are required to st rictly adhere to. As a result, the routine transport, use or disposal of hazardous materials during construction activities for the Project would be less than significant.
Operation: The types of materials customarily used by residential and public/institutional uses are not acutely hazardous and would only be used and stored in limited quantities. The normal routine use of these products pursuant to existing regulations would not result in a significant hazard to people or the environment in the vicinity of the Project site. Therefore, buildout pursuant to the Project would not result in a significant hazard to the public or to the environment through the routine transport, use, or disposal of hazardous waste, and impacts would be less than significant.
Impact HAZ-2 Finding: The Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment (Initial Study p. 68). Impacts would be less than significant.
Facts in Support of Finding:
Construction: Construction of the Project would involve the limited use and disposal of hazardous materials.
Equipment that would be used in construction of the P roject has the potential to release gas, oils, greases, solvents; and spills of paint and other finishing substances. However, the amount of hazardous materials on- site would be limited, and construction activities would be required to adhere to all applicable regulations Redlands Regular Meeting of 06-03-25
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regarding hazardous materials storage and handling, as well as to implement construction best management practices (through implementation of a required SWPPP implemented by City conditions of approval) to prevent a hazardous materials release and to promptly contain and clean up any spills, which would minimize the potential for harmful exposures. With compliance to existing laws and regulations, which is mandated by the City through construction permitting, the Project’s potential construction-related impacts would be less than significant.
Operation: Future operation of up to 2,436 residential units and 237,619.5 SF of public/institutional use would include use of limited hazardous materials, such as solvents, cleaning agents, paints, pesticides, batteries, fertilizers, and aerosol cans. Normal routine use of typical residential products pursuant to existing regulations would not result in a significant hazard to the environment, residents, or workers in the vicinity of the Project. Further, the Project would result in an overall decrease in nonresidential development. As a result, operation of the proposed Project would not create a reasonably foreseeable upset and accident condition involving the release of hazardous materials into the environment, and impacts would be less than significant.
Impact HAZ-3 Finding: The Project would not emit hazardous emissions or handle hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school (Initial Study at p. 69). Impacts would be less than significant.
Facts in Support of Finding: There are eight schools located within a quarter mile of the proposed Project site. Prior to construction, a SWPPP would need to be prepared and implemented, which would ensure hazardous materials are properly handled during construction and BMPs would be in place to avoid potential contaminated runoff from leaving the future development sites (PPP HYD -1). During operation, these hazardous materials would be limited and used and disposed of in compliance with federal, State, and local regulations, which would reduce the potential for accidental release into the environment near a school.
Therefore, buildout pursuant to the proposed Project would not emit or handle acutely hazardous materials, substances, or waste near a school, and impacts would be less than significant.
Impact HAZ-4 Finding: The Project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment. (Initial Study at p. 70). No impacts would occur.
Facts in Support of Finding: According to the California Department of Toxic Substances Control (DTSC) EnviroStor database, the area are located on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Therefore, the Project would not be located on a hazardous materials site pursuant to Government Code Section 65965.5.
Impact HAZ-5 Finding: The Project would not result in a safety hazard or excessive noise for people residing or working in the Project area for a project located within an airport land use plan or, where such a plan has not been adopted, be within two miles of a public airport or public use airport ( Initial Study at p. 70).
Impacts would be less than significant.
Facts in Support of Finding: The nearest airports to the proposed Project area are Redlands Municipal Airport (approximately 1.75 miles to the northeast of Sites 17-23) and San Bernardino International Airport (approximately 2.33 miles northwest of Sites 17-23). Only Site 23 is within the airport compatibility Zone D for the Redlands Municipal Airport, and none of the proposed sites are within the modeled noise contours for the Redlands Municipal Airport or San Bernardino International Airport. According to the Redlands Airport Land Use Compatibility Plan (ALUCP), Zone D does not have any development restrictions.
Additionally, future development pursuant to the proposed Project would be developed pursuant to the City’s and applicable Airport Land Use Compatibility Plan development guidelines to ensure that future development would not pose a hazard to airport operations, flight patterns, or otherwise result in substantial aviation-related safety risks. Therefore, impacts would be less than significant.
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Impact HAZ-6 Finding: The Project would not impair implementation of an adopted emergency response plan or emergency evacuation plan (Initial Study at p. 70). Impacts would be less than significant.
Facts in Support of Finding: The Project would not physically interfere with an adopted emergency response plan or emergency evacuation plan. Physical development pursuant to the proposed Project, including roadway improvements, is not expected to create obstacles to the implementation of emergency response or evacuation plans adopted for the City. Emergency access and circulation during construction and operation of individual development projects under the proposed Project would be part of each project’s review and approval by the City. Therefore, as existing City development standards would require new development within the proposed Project to be designed so as to not interfere with an adopted emergency response plan or emergency evacuation plan, impacts from implementation of the proposed Project would be less than significant.
Impact HAZ-7 Finding: The Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires (Initial Study at p. 70). Impacts would be less than significant.
Facts in Support of Finding: The proposed Project site, as with most of the City, is characterized as having a moderate fire threat level. Further, the proposed sites are located in an urbanized environment that does not contain wildlands. In addition, the sites are already designated for urban development pursuant to the current General Plan land use designations for each site. Chapter 15.04 of the Redlands Municipal Code requires all development to adhere to safety standards provided in the CBC and Chapter 15.20 adopts the California Fire Code, including construction and design methods that effectively reduce the risk of structure fires. The City’s close coordination of the Redlands Fire Department with the fire services of neighboring jurisdictions ensures the safety of new development from wildland fires. Therefore, impacts related to exposure of people or structures to wildland fire hazards would not occur.
Hazards and Hazardous Materials Cumulative Finding: The Project would not result in cumulative impacts related to hazards or hazardous materials.
Facts in Support of Finding: The cumulative hazards materials impact assessment considers the development of the Project in conjunction with other development projects, as listed in Section 5.0 of the Draft Subsequent EIR. Cumulative development within the City would have the potential to expose residents, employees, and visitors to chemical hazards through redevelopment of sites and structures that may contain hazardous materials. The severity of potential hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. All hazardous materials users and transporters, as well as hazardous waste generators and disposers are subject to regulations that require proper transport, handling, use, storage, and disposal of such materials to ensure public safety. Thus, if hazardous materials are found to be present on future project sites, appropriate remediation activities would be required pursuant to standard federal, State , and regional regulations. Compliance with the relevant federal, State, and local regulations during operation and construction throughout the Project site, as well as during the construction and operation of related projects would ensure that cumulative impacts from hazardous materials would be less than significant.
Plans, Policies and Programs (PPP)
PPP HYD-1: SWPPP. As listed in Section II, Subsection I, Hydrology and Water Quality.
I. Hydrology and Water Quality
Impact HYD-1 Finding: The Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality ( Initial Study at p. 72 ).
Impacts would be less than significant.
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Facts in Support of Finding:
Construction: Construction of the Project would be required through City permitting to implement of a grading and erosion control plan that is compliant with the Construction Activities General Permit, which requires preparation of a SWPPP by a Qualified SWPPP Developer. Adherence to the existing requirements and implementation of the appropriate BMPs per the permitting process would ensure that activities associated with construction would not violate any water quality standards. As a result, impacts relat ed to the degradation of water quality during construction activities would be less than significant.
Operation: Potential pollutants associated with the proposed uses include various chemicals from cleaners, pathogens from pet wastes, nutrients from fertilizer, pesticides and sediment from landscaping, trash and debris, and oil and grease from vehicles. These pollutants could potentially discharge into surface waters and result in degradation of water quality. However, in accordance with State Water Resources Board Order R8-2010-0036, NPDES No. CAS618033, each development would be required to incorporate a WQMP with post-construction (or permanent) Low Impact Development (LID) site design, source control, and treatment control BMPs. The LID site design would minimize impervious surfaces and provide infiltration of runoff into landscaped areas.
Implementation of practices required by the NPDES permit would reduce the volume of runoff from impervious surfaces and increase the amount of natural filtration of pollutants from stormwater occurring on- site for the development projects, which would improve the quality of stormwater before it enters the City’s stormwater system. Compliance with federal, State, and local water quality regulations will ensure that water quality is protected to the maximum extent practicable. Therefore, impacts would be less than significant.
Impact HYD-2 Finding: The Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin (Initial Study at p. 74). Impacts would be less than significant.
Facts in Support of Finding: The proposed Project would result in 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. Future residential development associated with the proposed Project would result in similar permeable surface areas as what is considered in the General Plan. Similar to Projects that would be implemented under the approved General Plan, future implementing projects under the proposed Project would be required to implement the policies and regulations within the General Plan that would help conserve groundwater in the area. In addition, none of the proposed Project sites are currently zoned for open space or other land uses that would preserve any permeable surfaces. Many of the sites are planned to be developed with Commercial/Industrial uses and would similarly introduce impervious surfaces to the Project area. However, as discussed in the General Plan EIR, any future projects would be required to implement the policies of the General Plan which would reduce any impacts to the groundwater supply to a less than significant level. Thus, impacts would be less than significant.
Impact HYD-3i Finding: The Project would not substantially alter the existing drainage pattern of the area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in a substantial erosion or siltation on- or off-site (Initial Study at p. 74). Impacts would be less than significant.
Facts in Support of Finding:
Construction: Construction of the Project has the potential to contribute to soil erosion and siltation. Grading and excavation activities would be required that would expose and loosen topsoil, which could be eroded by wind or water. However, the NDPES Storm Water Perm it that all projects in the City are required to conform to. To reduce the potential for soil erosion and the loss of topsoil, a SWPPP is required by the RWQCB regulations to be developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address site-specific conditions related to specific grading and construction activities. The SWPPP is required Redlands Regular Meeting of 06-03-25
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to identify potential sources of erosion and siltation during construction, identify erosion control BMPs to reduce or eliminate the erosion and siltation. With implementation of the SWPPP, construction impacts related to erosion and siltation would be less than significant.
Operation: As the Project site is already slated for urban development, buildout pursuant to the Project would not result in an 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. The on-site drainage features that would be installed by future projects would be designed to slow, filter, and infiltrate stormwater, which would also reduce the potential for storm water to erode soil.
Furthermore, implementation of the Project requires City approval of a site -specific WQMP, which would ensure that appropriate operational BMPs would be implemented to minimize or eliminate the potential for soil erosion and sedimentation to occur. As a result, potential impacts related to substantial soil erosion or sedimentation would be less than significant.
Impact HYD-3ii Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site (Initial Study at p. 76). Impacts would be less than significant.
Facts in Support of Finding:
Construction: Construction of the Project has the potential to temporarily alter the existing drainage pattern of the site and could result in flooding on- or off-site. Grading and excavation activities would be required that would expose and loosen topsoil, which could be eroded by wind or water. However, the NDPES Storm Water Permit that all projects in the City are required to conform to. To reduce the potential for soil erosion and the loss of topsoil, a SWPPP is required by the RWQCB regulations to be developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address site-specific conditions related to specific grading and construction activities. The SWPPP is required to identify potential sources of erosion and siltation during construction, identify erosion control BMPs to reduce or eliminate erosion and siltation. With implementation of the SWPPP, construction impacts related to erosion and siltation would be less than significant.
Operation: In addition, As the Project site is already slated for urban development, buildout pursuant to the Project would not result in an 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. The Project area contains areas of flood risk. Sites 1, 2, 6, 7, 8, 11, 12, 14, 15, 16, and 24 are all located within FEMA flood zones. Per the Redlands Flood Damage Prevention Measures (Chapter
15.32 of the Redlands Municipal Code), in a FEMA Flood zone any new “occupiable” finished floor must be at least two feet above the one percent (100-year) base flood elevation. As part of the permitting approval process, the proposed drainage design and engineering plans for future development projects would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, adherence to the existing NPDES permit regulations and Municipal Code would ensure that impacts related to alteration of a drainage pattern or flooding from operational activities related to future developments would be less than significant.
Impact HYD-3iii Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provid e substantial additional sources of polluted runoff (Initial Study at p. 77). Impacts would be less than significant.
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Facts in Support of Finding:
Construction: C onstruction of future developments pursuant to the Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff and polluted runoff if drainage is not properly controlled. Implementation of future developments would require a SWPPP (included as PPP HYD -1) that would address site -specific pollutant and drainage issues related to construction of future developments pursuant to the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities.
Operation: As the Project site is 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. Projects proposed pursuant to the proposed Project would be required to manage any increases of on-site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows. Overall, adherence to the existing NPDES permit regulations and Municipal Code would ensure that impacts related to exceeding the capacity of existing or planned stormwater drainage systems or creating additional sources of polluted runoff from operationa l activities related to future developments would be less than significant.
Impact HYD-3iv Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows (Initial Study at p. 77). Impacts would be less than significant.
Facts in Support of Finding:
Construction: C onstruction of future developments pursuant to the Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff and polluted runoff if drainage is not properly controlled. Implementation of future developments would require a SWPPP (included as PPP HYD -1) that would address site specific pollutant and drainage issues related to construction of future developments pursuant to the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities.
Operation: The Project site contains areas of flood risk. Sites 1, 2, 6, 7, 8, 11, 12, 14, 15, 16, and 24 are all located within FEMA flood zones. Per the Redlands Flood Damage Prevention Measures (Chapter 15.32 of the Redlands Municipal Code), in a FEMA Flood zone any new “occupiable” finished floor must be at least two feet above the one percent (100-year) base flood elevation. As part of the permitting approval process, the proposed drainage design and engineering plans for future development projects would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, adherence to the existing NPDES permit regulations and Municipal Code would ensure that impacts related to alteration of a drainage pattern or flooding from operational activities related to future developments would be less than significant.
Impact WQ-4 Finding: The Project would not risk release of pollutants due to Project inundation within a flood hazard zone (Initial Study at p. 78). Impacts would be less than significant.
Facts in Support of Finding:
Construction: C onstruction of future developments pursuant to the Project could require demolition and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff and polluted runoff if drainage is not properly controlled. Implementation of future developments would require a SWPPP (included as PPP HYD -1) that would address site specific pollutant Redlands Regular Meeting of 06-03-25
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and drainage issues related to construction of future developments pursuant to the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities.
Operation: As the Project site is 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. Projects proposed in implementation of the RHNA Rezone would be required to be consistent with the City’s drainage plans and the Redlands Flood Damage Prevention Measures (Chapter 15.32 of the Redlands Municipal Code) . Projects proposed pursuant to the proposed Project would be required to manage any increases of on -site runoff flows through either direct storm drain improvements, provided through direct modifications to storm drain facilities, or via payment of a storm drain development impact fee that will go towards funding storm drain projects to meet increased flows.
The City is approximately 50 miles inland from the Pacific Ocean. Therefore, the proposed Project area is not at risk of inundation from a tsunami and the proposed Project area is not located adjacent to any water retention facilities, lakes, or other bodies of water. Therefore, the proposed Project is not at risk of inundation from seiching.
Impact WQ-5 Finding: The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan ( Initial Study at p. 79). Impacts would be less than significant.
Facts in Support of Finding: Construction activity within the City is required to comply with the NPDES Stormwater Discharge Permit. The City’s Pretreatment and Regulation of Wastes Ordinance and its Storm Drains Ordinance further protect water quality in the City and would be applicable to development projects under the RHNA Rezone. Implementation of practices required by the NPDES permit and verified through City construction and operational permitting would reduce the volume of runoff from impervious surfaces and increase the amount of natural filtration of pollutants from stormwater occurring on -site for the development projects, generally improving the quality of stormwater before it infiltrates into the groundwater basin. Project specific WQMPs required for development pursuant to the Project would address quality and quantity of stormwater runoff and provide BMPs for construction and operation to ensure compliance with the current General Stormwater Permit. Therefore, buildout pursuant to the Project would not conflict with a water quality control plan or sustainable groundwater management plan, impacts would be less than significant.
Hydrology and Water Quality Cumulative Finding: The Project would not result in cumulative impacts related to hydrology and water quality.
Facts in Support of Finding:
Water Quality: The cumulative water quality impact assessment considers the development of the Project in conjunction with other development projects in the context of the Santa Ana River watershed. The geographic scope for cumulative impacts related to hydrology and water quality includes the Santa Ana River watershed because cumulative projects and developments could incrementally exacerbate the existing impaired condition and could result in pollutant related impairments. However, related developments wi thin the watershed would be required to implement water quality control measures pursuant to the same NPDES General Construction Permit that requires implementation of a SWPPP (for construction), a Low Impact Development plan (for operation) and BMPs to eliminate or reduce the discharge of pollutants in stormwater discharges, reduce runoff, reduce erosion and sedimentation, and increase filtration and infiltration, in areas permitted. Therefore, overall potential impacts to water quality associated with present and future development in the watershed would not be cumulatively considerable with compliance with all applicable laws, permits, ordinances and plans. As detailed previously, the Project would be implemented in compliance with all regulations, as would be verified by the City during the development permitting process. Therefore, cumulative impacts related to water quality would be less than significant.
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Drainage: 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. As described above, with i mplementation of the Project the on -site pervious surfaces would increase, and stormwater runoff would be accommodated by the stormwater drainage basin infrastructure. As a result, the Project would not generate runoff that could combine with additional runoff from cumulative projects that could cumulatively impact drainage. Thus, cumulative impacts related to drainage would be less than significant.
Plans, Policies and Programs (PPP)
PPP HYD-1: SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the City Building Division evidence of compliance with the NPDES (National Pollutant Discharge Elimination System) requirement to obtain a construction permit from the State Water Resource Control Board (SWRCB).
The permit requirement applies to grading and construction sites of one acre or larger. The Project applicant/proponent shall comply by submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the construction site.
PPP HYD-2: WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a completed Water Quality Management Plan (WQMP) shall be prepared by the Project applicant and submitted to and approved by the City Public Works Department. The WQMP shall identify all Post -Construction, Site Design. Source Control, and Treatment Control Best Management Practices (BMPs) that will be incorporated into the development Project in order to minimize the adverse effects on receiving waters.
J. Land Use and Planning
Impact LU-1 Finding: The Project would not physically divide an established community (Initial Study at p. 81). Impacts would be less than significant.
Facts in Support of Finding: The potential displacement of persons residing on an infill or redevelopment parcel (if any) would be short-term, and the proposed Project would result in a greater number of residential units to house residents of the area. The proposed Project would not require the extension of any roads that could potentially divide an established community, only roads necessary for internal circulation. Therefore, impacts related to displacement of housing or persons that would physically divide an established community would less than significant.
Impact LU-2 Finding: The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect (Draft Subsequent EIR at p. 5.6-4). Impacts would be less than significant.
Facts in Support of Finding: The Project would not conflict with the adopted Connect SoCal 2020 policies nor the 2024 SCAG RTP/SCS. The Project would meet both criteria for compliance with the SCAQMD AQMP.
The Regional MS4 permit would be obtained which requires compliance with NPDES standards for stormwater management and pollution prevention measures.
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 C ode. 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. Furthermore, as shown in Table 5.6-3 of the Draft Subsequent EIR, the proposed Project would be consistent with the applicable City General Plan Policies adopted to avoid or mitigate an environmental effect. The proposed Project would not cause a significant environmental impact Redlands Regular Meeting of 06-03-25
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due to a conflict with any land use plan, policy, or regulation adopted to avoid or mitigate an environmental effect, and impacts would be less than significant.
Land Use and Planning Cumulative Finding: The Project would not result in cumulative impacts related to land use and planning (Draft Subsequent EIR at p. 5.6-20). Impacts would be less than significant.
Facts in Support of Finding: Cumulative projects in the City of Redlands would have the potential to result in a cumulative impact if they would, in combination, conflict with existing land use plans, policies, and regulations adopted for the purpose of avoiding or mitigating an environmental impact. Cumulative projects in the City of Redlands would utilize regional planning documents such as Connect SoCal 202 4 during entitlement planning, and the City’s General Plan would be consistent with the regional plans, to the extent that they are applicable. Cumulative projects in th e City would be required to comply with the applicable land use plan or they would not be approved without a General Plan Amendment. 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.
K. Mineral Resources
Impact MIN-1 Finding: The Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state (Initial Study at p. 82). Impacts would be less than significant.
Facts in Support of Finding: Sites 17 through 23 of the RHNA rezone area are within MRZ- 2. Portions of Sites 1 through 16A and 24 of the RHNA Rezone area are within MRZ-1. The Project site is currently designated for urban development under the current General Plan land use designations and has not historically included mineral extraction, nor does the proposed Project area currently support mineral extraction or confirmed the identification mineral resources on the sites. Thus, implementation of the proposed Project would not result in the loss of availability of a known mineral resource of value to the region and state.
Impact MIN-2 Finding: The Project would not result in the loss of availability of a locally-important mineral resource recovery site delineated on the General Plan, specific plan or other land use plan (Initial Study at p. 83). No impacts would occur.
Facts in Support of Finding: The proposed Project area does not include areas designated for mining in any land use plan. Also, as described previously, implementation of the proposed Project would not result in the loss of availability of a known mineral resource recovery site. Therefore, there would be no impact from implementation of the proposed Project.
Mineral Resources Cumulative Finding: The Project would not result in cumulative impacts related to mineral resources.
Facts in Support of Finding: The Project area has not historically included mineral extraction, nor does the Project area currently support mineral extraction . Thus, implementation of the Project would not result in significant impacts to mineral resources and impacts would not be cumulatively considerable.
L. Noise
Impact N -3 Finding: The Project would not expose people residing or working in the P roject area to excessive noise levels, for a project located within the vicinity of a private airstrip or an airport land use Redlands Regular Meeting of 06-03-25
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plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport (Initial Study at p. 85). Impacts would be less than significant.
Facts in Support of Finding: 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, but none of the proposed Project sites are within the modeled noise contours for the Redlands Municipal Airport or San Bernardino International Airport . Thus, individual development projects under the proposed Project would not expose people residing or working in the area to excessive noise levels from airport operations and impacts would be less than significant.
M. Population and Housing
Impact POP-1 Finding: The Project would not induce substantial unplanned population growth in an area, either directly or indirectly (Draft Subsequent EIR at p. 5.8-9). Impacts would be less than significant.
Facts in Support of Finding: 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. The site is located in a developed area of the City adjacent to existing roads and in close proximity to infrastructure and utilities.
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 would result in a generation of 550 jobs. 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.
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. 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.
Employment Growth : 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: 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.
Construction: 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. In addition, buildout of the propo sed 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.
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Infrastructure: 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 Impact POP-2 Finding: The Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere (Initial Study at p.86). Impact would be less than significant.
Facts in Support of Finding: The proposed Project provides for infill development and redevelopment and would provide up to 2,325 additional residential dwelling units (that provides for approximately 6,162 additional residents) within the City compared to the General Plan. Individual development projects pursuant to the proposed Project may result in temporary displacement of residents during construction activities.
However, development projects would occur at a parcel-by-parcel project level. The potential displacement of persons residing on an infill or redevelopment parcel (if any) would be short -term, and the proposed Project would result in a greater number of residential units to house residents of the area. Therefore, impacts related to displacement of housing or persons that would require replacement housing elsewhere would not occur.
Population and Housing Cumulative Finding: The Project would not result in cumulative impacts related to population and housing (Draft Subsequent EIR at p. 5.8-11).
Facts in Support of Finding: 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 sig nificant and not cumulatively considerable.
N. Publ ic Services
Impact PS-1 Finding: The Project would not result in substantial adverse physical impacts associated with fire protection services or the provision of new or physically altered fire station facilities (Draft Subsequent EIR at p. 5.9-69). Impacts would be less than significant.
Facts in Support of Finding: Construction and operation of the Project would increase the demand for fire protection and emergency medical services. The threshold is whether the Project would result in inadequate staffing levels or require additional equipment, response times, and/or increase the demand for services that would then require the construction or expansion of fire station facilities that would have an adverse physical effect on the environment.
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. In addition, the Project would be required to adhere to the California Fire Code which would minimize the demand on fire stations, personnel, and equipment. Additionally, site access would be subject to plan check review by the City Building Division and the Redlands Fire Department (RFD) to ensure compliance with fire protection standards. The buildings would be equipped with fire extinguishers, wet and dry sprinkler systems, pre -action sprinkler systems, fire alarm systems, fire pumps, backflow devices, and clean agent waterless fire suppression systems pursuant to the California Fire Code, California Building Code, and other existing regulations regarding fire safety.
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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 Draft Subsequent EIR Section 5.9.8, would serve to ensure the maintenance of existing facilit ies and the timely provision of new facilities as needed. Development impact fees collected would ensure the level of fire protection services are maintained and response times are improved and can be applied to the purchase of equipment, maintenance of existing facilities, and the construction of new facilities . Therefore, with the payment of development fees included as PPP PS-1 , Project impacts to fire services would be less than significant.
Impact PS-2 Finding: The Project would not result in substantial adverse physical impacts associated with police services or the provision of new or physically altered police facilities. ( Draft Subsequent EIR p. 5.9- 10). Impacts would be less than significant.
Facts in Support of Finding: The increased residential population from the buildout of the proposed Project could increase the frequency of emergency and non -emergency calls to the Redlands Police Department (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.
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, se parate 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.
Impact PS-3 Finding: The Project would not result in substantial adverse physical impacts associated with schools. (Draft Subsequent EIR p. 5.9-11). Impacts would be less than significant.
Facts in Support of Finding: 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 Redlands Unified School District (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. 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 b ased 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 school facilities. Therefore, impacts to school facilities would be less than significant.
Impact PS-4 Finding: The Project would not result in substantial adverse physical impacts associated with parks (Initial Study p. 89). Impacts would be less than significant.
Facts in Support of Finding: The City of Redlands has 424.2 acres of parkland, or a ratio of 5.9 acres of parkland per 1,000 residents which exceeds the State law requirement of 5.0 acres per 1,000 residents. As such, buildout of the proposed Project would result in a demand for 32.26 acres of parkland. The addition Redlands Regular Meeting of 06-03-25
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of 6,162 new residents would increase the use of recreational facilities and would require approximately
30.81 acres of new parkland based on the parkland/recreational space standard of 5.0 acres per 1,000 residents. However, with a total of 79,152 residen ts, the City of Redlands would need 392.93 acres of parkland to meet the City’s requirement which would be exceeded by the already existing 424.2 acres.
Furthermore, the City’s mechanism for addressing parkland needs are its development impact fees as set forth in Municipal Code Chapter 3.32 included as PPP PS-2. Based on the existing parkland within the Project area and the incremental population increase resulting from buildout of the proposed Project, the Project would not result in overuse of existing parks and facilities that would result in substantial deter ioration of existing facilities.
Impact PS-5 Finding: The Project would not result in substantial adverse physical impacts associated with other public facilities (Initial Study p. 90). Impacts would be less than significant.
Facts in Support of Finding: The policies set forth by the Redlands General Plan ensure that within the City these public services are improved and expanded to meet demand as development occurs. Future development of new public facilities would require project- level environmental review and site -specific mitigation measures as appropriate, ensuring that adverse environmental effects are avoided or mitigated.
Additionally, the Project would generate new tax revenues that would contribute to and supplement existing revenue sources for the maintenance and enhancement of these facilities. Therefore, Project implementation would not adversely affect public facilities or require the construction of new or modified public facilities that are not already addressed in this document.
Public Services Cumulative Finding: The Project would result in less than significant cumulative impacts related to public services (Draft Subsequent EIR at p. 5.9-11).
Facts in Support of Finding: T he Project applicant would pay the required City development 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.
Plans, Policies and Programs (PPP)
PPP PS -1: Development Impact Fees. As a standard requirement for implementing projects within the proposed Project, and prior to issuance of any building permits for the implementing project, the project applicants/developers shall pay all applicable City of Redlands Development Impact Fees (DIF) pursuant to the Redlands Municipal Code and/or adopted fee schedules.
PPP PS-2: As a Condition of Approval for implementing projects within the proposed Project, the project applicants/developers shall pay applicable park related fees pursuant to Redlands Municipal Code Chapter 3.32.
O. Recreation
Impact REC-1 Finding: The Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that physical deterioration of the facility would be accelerated (Initial Study p. 91). Impacts would be less than significant.
Facts in Support of Finding: At the estimated 2023 population of 72,696 residents, the ratio of existing parkland acres per 1,000 residents is 5.9, which exceeds the GP’s parkland/recreational space standard of 5.0 acres per 1,000 residents. The General Plan designates areas for parkland, recreational facilities, and trails to serve the City’s population as it grows. The City’s mechanism for addressing parkland and Redlands Regular Meeting of 06-03-25
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recreational facility needs is its development impact fees , as set forth in the Redlands Municipal Code Chapter 3.32, included as PPP PS-2. Development impact fees are charged by local governments to defray all or a portion of the cost of public facilities related to development projects. Fees are used for the acquisition, construction, and improvement of public facilities demanded by new development. Individual future development projects under the proposed Project would be subject to the payment of these development impact fees to the City. Thus, the Project would not significantly increase the use of existing parks or recreational facilities such that substantial physical deterioration would occur or be accelerated.
Impact REC-2 Finding: The Project will include employee recreational facilities but will not require the construction or expansion of recreational facilities in a manner which will have an adverse physical effect on the environment (Initial Study p. 92). Impacts would be less than significant.
Facts in Support of Finding: The precise timing of open space or other public improvements associated with buildout of the Project are not known with certainty, as improvements would likely depend on the timing of future developments, buildout of private development projects, future availability and amounts of public grant funding or other public funds, and other factors. The development of future parkland and recreational facilities would be subject to existing building and construction regulations and env ironmental review that would ensure that future construction activities have a minimal effect on the surrounding environment.
Adherence to existing regulations and mitigation measures included in the Subsequent EIR would ensure that the Project would not result in construction or expansion of recreational facilities which might have an adverse impact on the environment, and impacts would be less than significant.
Recreation Cumulative Finding: The Project would result in less than significant cumulative impacts related to recreation.
Facts in Support of Finding: The cumulative area of recreation impacts for the proposed Project includes the City of Redlands . Based on 5 acres of public park and/or recreational space per 1,000 residents, buildout of the proposed Project results in a need for approximately 30.81 acres of parkland to serve the 6,162 residents of the Project site, which would be provided through on -site recreation facilities and/or payment of in-lieu fees. Implementation of future development projects would also be required to provide adequate park facilities or pay in lieu fees, in accordance with Redlands Municipal Code Chapter 3.32 .
Therefore, the proposed Project’s impacts related to the amount of parkland within the City would not result in a cumulatively considerable impact related to parks and recreational facilities.
Plans, Policies and Programs (PPP)
PPP PS-2: As listed in Section II, Subsection N, Public Services.
P. Transportation
Impact TR-1 Finding: The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities (Draft Subsequent EIR at p. 5.10-8). Impacts would be less than significant.
Facts in Support of Finding:
Project Trip Generation: 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 t rips in the City of Redlands compared to buildout pursuant to the existing General Plan.
Roadway Facilities: 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.
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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.
Transit Facilities: 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. As a result, the Project would not result in any conflicts with the existing and planned pedestrian network and impacts related to pedestrian facilities would not occur.
Bicycle Facilities: 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. 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.
Pedestrian Facilities: The Project does not propose a specific infrastructure improvements; however, future development facilitated by the Project may be required to include sidewalk improvements. Specific sidewalk 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 provi sion of adequate sidewalk, as ensured and verified by the city during the plan check and permitting process, prior to obtaining building permits. Therefore, the proposed Project would not conflict with pedestrian facilities.
Policies: As discussed in Section 5. 10, Transportation, of the Draft Subsequent EIR , 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 less than significant.
Impact TR-3 Finding: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) (Initial Study at p. 94). Impacts would be less than significant.
Facts in Support of Finding: T he proposed Project would not alter the design of current roadways and streetscapes. Most of the development pursuant to the proposed Project would result in infill development and would not create hazards from incompatible uses in the Project site or within the surrounding area. Future development projects under the proposed Project would be subject to the typical development review process, which includes Planning and Engineering review, and compliance with standard engineering design requirements would ensure no hazardous design conditions. Thus, no impacts related to vehicular circulation design features would occur from the Project.
Impact TR-4 Finding: The Project would not result in inadequate emergency access (Initial Study at p. 94).
Impacts would be less than significant.
Facts in Support of Finding: Development pursuant to the proposed Project would not alter the design of current roadways or streetscapes in a manner which would result in inadequate emergency access.
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Construction of development projects under the proposed Project may require the presence of construction equipment and materials adjacent to roadways. Construction activities and future development designs would be required to ensure emergency access in accordance with California Fire Code Section 503 (CCR Title 24, Part 9), which would be confirmed and approved through the City’s standard development review and permitting process. As such, the Project would not result in inadequate access, and impacts would be less than significant.
Transportation Cumulative Finding: Impacts related to transportation would be less than significant with compliance with existing regulations and mitigation measures (Draft Subsequent EIR at p. 5.10-19).
Facts in Support of Finding:
Roadway, Transit, Bicycle, and Pedestrian Networks : Cumulative development in the City and surrounding jurisdictions, as shown on Draft Subsequent EIR 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: As shown in Draft Subsequent EIR 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 /SP 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.
Q. Utilities and Service Systems
Impact UT-1 Finding: The Project would not require or result in the relocation or construction of new water or wastewater facilities, or expansion of existing facilities, the construction of which could cause significant environmental effects (Draft Subsequent EIR at p. 5.12-9). Impacts would be less than significant.
Facts in Support of Finding:
Water: 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 off -site utility improvements are not anticipated to be required for buildout pursuant to the proposed Project. 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.
Wastewater: As compared to the existing General Plan buildout, the proposed development of the proposed Project would result in minor increases in the wastewater to the City’s existing sewer systems. Based on the sewer systems standards, sewer pipes larger than 12 -inches in diameter are designed to flow up to 75 percent full. Therefore, since most of the existing sewer systems are flowing at or less than 50 percent full, there is additional capacity to handle an increase in wastewater ( Draft Subsequent EIR Appendix H). 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 Redlands Regular Meeting of 06-03-25
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Subsequent EIR mitigation measures throughout this document. These requirements would ensure that construction related impacts remain less than significant.
Stormwater: 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 la nd uses within the City, and future site - specific development projects would install on-site stormwater drainage infrastructure and new connections to the existing stormwater drainage system. 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 WQMP. Additionally, future 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.
Impact UT -2 Finding: Sufficient water supplies are available to serve the Project and reasonably foreseeable development during normal, dry, and multiple dry years (Draft Subsequent EIR at p. 5.12-11).
Impacts would be less than significant.
Facts in Support of Finding: 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. The Integrated Regional Water Management Plan (IRUWMP) assessed the projected water demand and supply in the service area and concluded that the City of Redlands Municipal Utilities and Engineering Department (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 Draft Subsequent EIR 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. Thus, impacts related to the need for new or expanded water supplies and entitlements would be less than significant.
Impact UT-3 Finding: The Project would not result in a determination by the wastewater treatment provider that would serve the Project that it has inadequate capacity to serve the projects projected demand in addition to the providers existing commitments (Draft Subsequent EIR at p. 5.12-12). Impacts would be less than significant.
Facts in Support of Finding: As shown in Draft Subsequent EIR Table 5.12 -3, Net Change in Wastewater Generation for Project Site, 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. In 2020, the City’s Wastewater Treatment Plant (WWTP) collected 6,620 AF (5.8 mgd) for treatment. 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 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.
Impact UT-4 Finding: The Project would not generate solid waste in excess of State or local standards or in excess of the capacity of local infrastructure or otherwise impair the attainment of solid waste reduction goals (Initial Study at p. 98). Impacts would be less than significant.
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Facts in Support of Finding:
Construction: The majority of waste generated during demolition and construction activities by implementing projects would be building materials (e.g., concrete, dirt, and waste generated by construction workers). As stated in Draft Subsequent EIR Section 13.66.040 of the City’s Municipal Code, Construction and Demolition Recycling Requirements, no demolition permit or building permit shall be issued for any development activity subject to this chapter unless the construction and demolition recycling plan has been approved by the municipal utilities director. Thus, implementing projects pursuant to the proposed Project would be required to meet the City’s waste diversion requirements as they pertain to project construction.
Operation: Buildout pursuant to the proposed Project would result in a decrease of 2,057,992.20 SF of nonresidential development. Thus, implementation of the proposed Project is expected to decrease waste generation. As the California Street Landfill has the capacity to process an additional 527.31 tons of solid waste per day and the San Timoteo Sanitary Landfill has the capacity to process an additional 337.1 tons per day, the solid waste generated by the Project woul d be within the capacity of the landfil l. The solid waste generated by full buildout of the proposed Project would represent approximately 0.6 percent of the excess capacity of the California Street Landfill and 0.9 percent of the excess capacity at the San Timoteo Sanitary Landfill each day. Construction and operational impacts related to solid waste would be less than significant.
Impact UT-5 Finding: The Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals (Initial Study at p. 99). Impacts would be less than significant.
Facts in Support of Finding: Future developments pursuant to the proposed Project would be required comply with Redlands Municipal Code Section 13.66.040, Construction and Demolition Recycling Requirements, which requires that no demolition permit or building permit shall be issued for any development activity unless the construction and demolition recycling plan has been approved by the Municipal Utilities Director. In addition, individual development projects under the proposed Project would be required to comply with all federal, State, and local regulations related to solid waste, and toward that end, future developments would comply with all applicable standards related to solid waste diversion, reduction, and recycling during construction and operation. Therefore, implementation of t he proposed Project would result in less than significant impacts related to potential conflicts with federal, State, and local management and reduction statutes and regulations pertaining to solid waste.
Utilities and Service Systems Cumulative Finding: The Project would not result in cumulative impacts related to utilities and service systems (Draft Subsequent EIR at p. 5.12-13).
Facts in Support of Finding:
Water: 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: 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.
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Stormwater: 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.
R. Wildfires
Impact WF-1 Finding: The Project is not located in or near State responsibility areas or lands classified as very high fire hazard severity zones and would not substantially impair an adopted emergency response plan or emergency evacuation plan (Initial Study at p. 100). Impacts would be less than significant.
Facts in Support of Finding: The Rezone sites are classified as being in a moderate fire threat area per the High Fire Hazard Area Redland s GIS map. The sites are also not located in a S tate responsibility area.
Moreover, future development pursuant to the proposed Project would not impair the implementation of an adopted emergency response plan or emergency evacuation plan. Therefore, impacts from proposed Project implementation would be less than significant
Impact WF-2 Finding: The Project is not located in or near State responsibility areas or lands classified as very high fire hazard severity zones, and would not involve slope, prevailing winds, and other factors, that could exacerbate wildfire risks, and thereby expose P roject occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire (Initial Study at p. 100). No impacts would occur.
Facts in Support of Finding: The sites are located within an urbanized environment with moderate fire threat level and do not include, nor are they around, wildlands or areas of high fire hazard terrain or vegetation.
Implementation of the proposed Project would neither exacerbate wildfire risks nor expose occupants to risk of pollutant concentrations from a wildfire or uncontrolled spread of a wildfire. Therefore, no impact would occur.
Impact WF-3 Finding: The Project is not located in or near State responsibility areas or lands classified as very high fire hazard severity zones and would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that m ay exacerbate fire risk or that may result in temporary or ongoing impacts to the environment (Initial Study at p. 101). No impacts would occur.
Facts in Support of Finding: The sites are within an urbanized environment with a moderate fire threat level and do not include wildlands or areas of high fire hazard terrain or vegetation. Implementation of the proposed Project would include the introduction of new residential developments and may require individual projects to connect to existing infrastructure within roadways. However, these new developments within an existing urbanized environment, and future utility upgrades, if needed, would not exacerbate fire risk or result in temporary or ongoing impacts to the environment in regard to wildfires. Thus, no impacts would result.
Impact WF-4 Finding: The Project is not located in or near State responsibility areas or lands classified as very high fire hazard severity zones and would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes (Initial Study at p. 101). Impacts would be less than significant.
Facts in Support of Finding: The proposed sites are generally flat and are not located near hillside areas or in the downslope pathway of a potential landslide. While a few of the sites are within a special flood hazard area, implementation of the proposed Project would improve the existing drainage. Therefore, post- fire risks related to downstream flooding or landslides would be less than significant.
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Wildfires Cumulative Finding: The Project would not result in cumulative impacts related to wildfires.
Facts in Support of Finding: The Project is not located in or near State responsibility areas or lands classified as very high fire hazard severity zones; and therefore, would not result in impacts related to wildfires and no potential of cumulative impacts would occur.
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SECTION III
IMPACTS MITIGATED TO A LEVEL OF LESS THAN SIGNIFICANT
The City hereby finds that mitigation measures have been identified in the Initial Study and Draft Subsequent EIR that would avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts and the mitigation measures that would reduce them to a less than significant level are summarized below. • Biological Resources
• Cultural Resources
• Geology and Soils
• Noise
• Tribal Cultural Resources
A. Biological Resources
Impact BIO-1 Finding: The Project would not h ave a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service (Initial Study at p. 49). Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding: The Project area is urbanized and developed and is currently slated for urban development pursuant to the current General Plan land use designations analyzed under the General Plan EIR. Implementation of the Project would result in infill development within an already highly disturbed urban environment and would not result in any direct impacts to special status species, nor involve or result in any existing habitat modifications that could indirectly result in a substantial adverse effect on any special status species. While it is not expected that the Project site would support suitable habitat for rare plant and animal species, General Biological Surveys would be performed for future development projects within the proposed Project site to confirm whether suitable habitat exists, as outlined in Mitigation Measure BIO-1. If suitable habitat is identified, rare plant/wildlife surveys should be conducted to determine presence of species, in accordance with California Department of Fish and Wildlife (CDFW) and the U.S. Fish and Wildlife Service (USFWS) and during the appropriate time of year. Therefore, the Project would not result in impacts on species identified as candidate, sensitive, or special status with implementation of Mitigation Measure BIO-1.
Impact BIO-2 Finding: The Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service (Initial Study at p. 50). Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding: Existing vegetation communities on- site consist of agricultural land, annual grassland, and developed/ruderal land. However, several sites are located near the Morey Arroyo riverine, which is a riparian habitat according to the USFWS National Wetland Inventory. Therefore, future developments related to the proposed Project within the Rezone sites shall require a biological survey for jurisdictional features prior to the approval of any development applications, as outlined in Mi tigation Measure BIO-2. If jurisdictional waters are identified on a site, avoidance is preferred. Where avoidance is not feasible, project-specific impacts to jurisdictional resources shall be addressed and mitigated by federal and State regulators via applicable consulting and permitting process. Thus, with implementation of Mitigation Measure BIO-2, impacts to riparian habitat would be less than significant.
Impact BIO -3 Finding: The Project would not have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means (Initial Study at p. 50). Impacts would be less than significant with mitigation incorporated.
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Facts in Support of Finding: Several sites are located near the Morey Arroyo riverine, which is a riparian habitat according to the USFWS National Wetland Inventory. These sites are already slated for urban development pursuant to their respective current General Plan land use designations, as analyzed under the General Plan EIR. Nevertheless, Mitigation Measure BIO -2 has been included to require jurisdictional assessments for individual development projects within the Project site prior to approval of any development applications. With implementation of Mitigation Measure BIO -2, impacts to federally protected wetlands would be less than significant.
Biological Resources Cumulative Finding: The Project would not result in cumulatively considerable impacts to biological resources. Impacts would be less than significant with mitigation.
Facts in Support of Finding: With implementation of the mitigation measures identified in the Initial Study and Draft Subsequent EIR, the Project would not result in significant impacts related to special-status species, jurisdictional waters, wildlife movement, local ordinances or regulations protecting biological resources, habitat conservation plans, plant communities, and habitat fragmentation. Since the Project would implement existing requirements and mitigation measures and would result in less than significant impacts to biological resources, the Project could not combine with other projects within the City in a manner that would result in cumulative impacts. Cumulative projects would be required to comply with applicable survey requirements and mitigation for biologica l resources. Further, there are no projects that would, in combination with the Project, produce a significant impact to biological resources.
Mitigation Measures
MM BIO-1 Biological Assessment : Future projects proposed within the proposed Project site shall be surveyed by a qualified biologist to determine if any special -status plant or wildlife species have the potential to occur or if any riparian habitats, jurisdictional drainages, or wetlands are present onsite. If suitable habitat is present, a qualified biologist shall survey for special-status species during the appropriate time of year (i.e., when the species is readily identifiable, such as during its bloom ing period) prior to initiating any ground disturbing activities in a given area. The focused surveys shall be conducted in accordance with CDFW guidelines. If special- status species are identified and cannot be avoided, the project-level biological survey report would justify why species-specific mitigation is necessary and propose mitigation to reduce project impacts to a less than significant level.
MM BIO-2 Jurisdictional Resources: If potential jurisdictional waters are determined to be present onsite through the biological assessment require by MM BIO-1 above, a jurisdictional assessment shall be conducted for future projects within Sites 1 through 24. Jurisdictional resources shall be avoided when feasible. Where avoidance is not feasible, project- specific impacts to jurisdictional resources shall be addressed and mitigated by federal and State regulators via applicable consulting and permitting pr ocess. The types of mitigation required may include onsite or offsite preservation, enhancement, creation, and/or restoration.
Mitigation is typically required at a 1:1 ratio or higher and to be accomplished in close proximity to the impacts or at least in the same watershed. Final requirements and locations are, however, subject to change during applicable consultation/permit processes required by the USACE, RWQCB, and CDFW.
Best Management Practices (BMPs) to minimize and avoid impacts to jurisdictional resources during and after construction are subject to approval by permitting agencies and shall include, but are not limited to, the following:
• Construction-related equipment shall be stored in developed areas, outside of the drainage. No equipment maintenance shall be done within or adjacent to the drainage. • Source control and treatment control BMPs shall be implemented to minimize the potential contaminants that are generated during and after construction. Water quality BMPs shall be implemented throughout the project to capture and treat potential contaminants.
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• Substances harmful to aquatic life shall not be discharged into the drainage. All hazardous substances shall be properly handled and stored.
• A Storm Water Pollution Prevention Plan shall be prepared to prevent sediment from entering the drainage during construction.
• To avoid attracting predators during construction, the project shall be kept clean of debris to the extent possible. All food-related trash items shall be enclosed in sealed containers and regularly removed from site.
• Construction personnel shall strictly limit their activities, vehicles, equipment and construction material to the proposed project footprint, staging areas, and designated routes of travel. • Exclusion fencing shall be installed to demarcate the limits of disturbance. The exclusion fencing should be maintained until the completion of construction activities.
B. Cultural Resources
Impact CUL-1 Finding: The Project would not cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5 (Initial Study at p. 54). Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding: Implementation of site-specific development projects pursuant to the proposed Project could cause a substantial adverse change in the significance of a historical resource by altering a historical resource’s physical characteristics, which convey its histo rical significance. While there are no designated historical resources on the Project site, some structures may be older than 45 years and may Adherence to Redlands Municipal Code Section 2.62.200 (included as PPP CUL -1) and Ce rtificate of Appropriateness procedures would address unidentified, potential historical resources (buildings, structures, and features aged 45 years and older) and would ensure preservation of known historic resources as new development within the Project area occurs. Furthermore, Mitigation Measure CUL-1 is included to require evaluation of potential historic resources for implementing projects that could potentially impact a building or structure in excess of 45 years of age. Mitigation Measure CUL -2 req uires any identified historical resources to meet the Secretary of the Interior’s Professional Qualifications Standards to ensure project compliance with the Standards for Rehabilitation. Therefore, with implementation of Mitigation Measure CUL-1 and CUL-2, and Redlands Municipal Code Section 2.62.200 (provided as PPP CUL-1), impacts related to a substantial adverse change in the significance of a historic resource would be less than significant.
Impact CUL-2 Finding: The Project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5 (Draft Subsequent EIR at p. 5.3-12).
Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding: 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 prop osed 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.
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 high ly sensitive for Redlands Regular Meeting of 06-03-25
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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 bu ildout pursuant to the Redlands RHNA Rezone Project would be less than significant.
Cultural Resources Cumulative Finding: Impacts related to historic and archaeological resources and human remains would be less than significant with compliance with existing regulations and mitigation measures (Draft Subsequent EIR at p. 5.3-12).
Facts in Support of Finding: 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 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. There i s 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. 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.
Plans, Policies and Programs (PPP)
PPP CUL-1: Municipal Code Chapter 2.62. The City of Redlands Historic Architectural Design Guidelines shall apply to all future projects within the proposed Project . The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings may also be applicable to properties or projects that may affect historic buildings and resources.
Mitigation Measures
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.
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 Redlands Regular Meeting of 06-03-25
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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.
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: Archeological 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 resourc es to a level that is less than significant as well as address potential impacts to undiscovered buried archaeological resources associated with implementing projects. The plan shall include a scope of work, project grading and development scheduling, 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:
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o 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. o 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.
If human remains or funerary/burial objects are encountered during any activities associated with the project, work in the immediate vicinity (within a 100 -foot buffer) shall cease and the County Coroner shall be contacted pursuant to State Health and Safe ty 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 certifi cate of occupancy. The report will include DPR Primary and Archaeological Site Forms if any are required.
o 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 experien ce 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:
o 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. o 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.
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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.
If human remains or funerary/burial objects are encountered during any activities associated with the project, work in the immediate vicinity (within a 100 -foot buffer) shall cease and the County Coroner shall be contacted pursuant to State Health and Safe ty 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 certifi cate of occupancy. The report will include DPR Primary and Archaeological Site Forms if any are required.
C. Geology and Soil
Impact GEO-6 Finding: The Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature (Initial Study at p. 63). Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding: Future development pursuant to the proposed Project could involve grading and excavation to greater depths than previously undertaken and could inadvertently uncover unknown paleontological resources buried in site soils. Therefore, future projects would be required to adhere to Mitigation Measure PAL -1, which would require future project applicants to provide an assessment of whether grading would impact any underlying soil units or geologic formations that have potential to yield fossiliferous materials. Mitigation Measure PAL -2 would establish a procedure for the management of paleontological materials on sites with potential to yield paleontological resources. Therefore, with implementation of Mitigation Measures PAL-1 and PAL-2, impacts related to paleontological resources would be less than significant.
Geology and Soil Cumulative Finding: The Project would result in less than significant cumulative impacts related to geology and soils.
Facts in Support of Finding: A cumulative impact could occur if development projects incrementally result in the loss of the same types of unique paleontological resources. As detailed previously, the Redlands area , including the Project site, is underlain by deep sediments that are sensitive to paleontological resources.
However, with incorporation of mitigation measure PAL-1, ground excavation that could impact paleontological resources would be monitored to reduce potential significant impacts that could become cumulatively considerable. Thus, with incorporation of mitigation measures the potential for cumulatively considerable impacts would be less than significant.
Mitigation Measures
MM PAL-1: Paleontological Resources. Future project applicants within the Project sites shall provide a paleontological assessment by a qualified paleontologist meeting the standards of the Society of Vertebrate Paleontology (SVP) to determine whether grading for the project could impact underlying soil units or geologic formations that have a low to high potential to yield fossiliferous materials, prior to project approval. The qualified paleontologist will determine the degree of paleontological resource sensitivity, as outlined below, and shall recommend a project-specific paleontological resources monitoring and mitigation plan (PRMMP), if warranted, based on paleontological sensitivity. This plan will address specifics of monitoring and mitigation for the development project, and will take into account updated geologic Redlands Regular Meeting of 06-03-25
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mapping, geotechnical data, updated paleontological records searches, and any changes to the regulatory framework. This PRMMP must meet the standards of the SVP. The following provisions would be typical for units mapped with the different levels of paleontological sensitivity:
• High- All projects involving ground disturbances in previously undisturbed areas sediments mapped as having high paleontological sensitivity shall require preparation of a PRMMP by a qualified paleontologist and shall be monitored by a qualified paleontological monitor on a full-time basis under the supervision of the Qualified Paleontologist. Undisturbed sediments may be present at the surface, or present in the subsurface, beneath earlier developments. This monitoring will include inspection of exposed sedimentary units during active excavations within sensitive geologic sediments. The monitor will have authority to temporarily divert activity away from exposed fossils to evaluate the significance of the find and, should the fossils be determined to be of scientific significance, professionally and efficiently recover the fossil specimens and collect associated data pursuant to the guidelines of the Society of Vertebrate Paleontology. Paleontological monitors will use field data forms to record pertinent location and geologic data, will measure stratigraphic sections (if applicable), and collect appropriate sediment samples from any fossil localities. • Low to High- All projects involving ground disturbance in previously undisturbed areas mapped with low- to-high paleontological sensitivity shall require preparation of a PRMMP by a qualified paleontologist.
The PRMMP shall specify that monitoring shall only be required when construction activity will exceed the depth of the low sensitivity surficial sediments. The underlying sediments may have high paleontological sensitivity, and therefore work in those units shall require paleontological monitoring, as designated by the Qualified Paleontologist in the PRMMP. When determining the depth at which the transition to high sensitivity occurs and monitoring becomes necessary, the Qualified Paleontologist should take into account: a) the most recent local geologic mapping, b) depths at which fossils have been found in the vicinity of the project area, as revealed by the museum records search, and c) geotechnical studies of the project area, if available.
• Low- All projects involving ground disturbance in previously undisturbed areas mapped as having low paleontological sensitivity should incorporate worker training to make construction workers aware that while paleontological sensitivity is low, fossils mig ht still be encountered. The Qualified Paleontologist should oversee this training as well as remain on -call in the event fossils are found. Paleontological monitoring is usually not required for sediments with low paleontological sensitivity. • None- Projects determined by the Qualified Paleontologist to involve ground -disturbing activities in areas mapped as having no paleontological sensitivity (i.e., plutonic igneous or high-grade metamorphic rocks) will not require further paleontological mit igation measures, but shall implement MM PAL -2, if incidental discoveries occur.
MM PAL-2: Fossil Discovery. In the event of any fossil discovery, regardless of depth or geologic formation, construction work will halt within a 50 foot radius of the find until its significance can be determined by a Qualified Paleontologist. Scientifically significant fossils shall be recovered, prepared to the point of curation, identified by qualified experts, listed in a database to facilitate analysis, and deposited in a designated paleontological curation facility in accordance with the standards of the SVP. A repository shall be identified and a curatorial arrangement will be signed prior to collection of the fossils. Any accredited institution may serve as a repository.
D. Noise
Impact NOI-1 Finding: The Project would not generate a substantial temporary or permanent increase in ambient noise levels in excess of standards established in the local General Plan or noise ordinance, or applicable standards of other agencies ( Draft Subsequent EIR at p. 5.7 -13). Impacts would be less than significant with mitigation incorporated.
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Facts in Support of Finding:
Construction: 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.
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 were 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.
Operation:
Increase in Roadway Noise. As detailed in Section 5.10, Transportation, of the Draft Subsequent EIR, 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. 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: 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 Plan and Municipal Code regulations that would be verified through the City’s development review and permitting process, impacts would be less than significant.
Impact NOI-2 Finding: The Project would not generate excessive ground -borne vibration or groundborne noise levels (Draft Subsequent EIR at p. 5.7 -16). Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding:
Construction: 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 Redlands Regular Meeting of 06-03-25
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vibration could occur. Also, Municipal Code Section 8.06.020 identifies the vibration threshold as 0.01 in/sec root mean squared (RMS). 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 buildings within 25 feet of construct ion to ensure that construction vibration from implementation of the proposed Project would not damage any historic structures.
Operation: The operation of residential and public/institutional land uses would not include the operation of any vibration sources other than typical on- site 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.
Noise Cumulative Finding: The Project would result in less than significant cumulative impacts related to noise and vibration (Draft Subsequent EIR 5.7-17). Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding: 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. 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. 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. However, implementation of construction noise Mitigation Measures NOI -1 and NOI -2 and construction 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.
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.
Mitigation Measures
MM 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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MM 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 L eq 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.
MM 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.
MM 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.
E. Tribal Cultural Resources
Impact TCR-1 Finding: The Project would not 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 listed or eligible for listing in the California Register of Historic Resources, or in a local register of historical resources as defined in Public Resource Code Section 5020.1(K). ( Draft Subsequent EIR p. 5.11-6). Impacts less than significant with mitigation incorporated.
Facts in Support of Finding: The 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. Thus, the City has agreed to implement Mitigation Measure TCR- 1 in the event of any inadvertent discovery of Tribal Cultural Resources (TCRs). 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 Draft Subsequent EIR 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 Redlands Regular Meeting of 06-03-25
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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.
Impact TCR-2 Finding: The Project would not 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 that is a resource determine d 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. ( Draft Subsequent EIR at p. 5.1 1-6).
Impacts would be less than significant with mitigation incorporated.
Facts in Support of Finding: 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 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.
Tribal Cultural Resources Cumulative Finding: The Project would result in less than significant cumulative impacts related to tribal cultural resources (Draft Subsequent EIR 5.11-7).
Facts in Support of Finding: 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. 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.
Mitigation Measures
MM CUL-3: Listed previously in Section III, Subsection B, Cultural Resources.
MM CUL-4: Listed previously in Section III, Subsection B, Cultural Resources.
MM TCR-1: Inadvertent Discovery of Tribal Cultural Resources. In the event that previously unidentified tribal cultural resources are unearthed during construction, the Qualified Archaeologist shall have the authority to temporarily divert and/or temporarily halt ground -disturbance operations in the area of discovery to allow for the evaluation of potentially significant cultural resources. Isolates and clearly non - significant deposits shall be minimally documented in the field and collected so the monitore d 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 cons ulting 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 Redlands Regular Meeting of 06-03-25
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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.
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.
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SECTION IV
RESOLUTION REGARDING SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS Public Resources Code Section §21002 states that “it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effec ts of such projects. The Legislature further finds and declares that in the event specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof.”
Section §15364 of the State CEQA Guidelines defines “feasible” as “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.”
The City Council hereby finds that, despite the incorporation of feasible measures outlined in the Final EIR, the following impacts cannot be fully mitigated to a less-than-significant level. Despite these significant and unavoidable impacts, the City nevertheless approves the Project because of the benefits described in the Statement of Overriding Considerations included herein.
A. Agriculture and Forestry
Impact Finding AG -1: The Project would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program (FMMP) of the California Resources Agency, to non -agricultural use (Draft Subsequent EIR at p. 5.1-8). Impacts are significant and unavoidable.
Facts in Support of Findings: According to the FMMP, Project implementation would cause the conversion of
44.67 acres of farmland designated as Prime Farmland to non -agricultural uses and would result in a reduction in overall acreage of agricultural lands within the City . The site received a LESA score of 67.0 (Land Evaluation Score of 40.75 and a Site Assessment Score of 26.25) out of a 100-point scale. According to the LESA Model significance thresholds, sites receiving a score of between 60 and 70 points are considered significant unless either the Land Evaluation or Site Assessment weighted factor subscore is less than 20 points.
Both the Land Evaluation and Site Assessment subscores exceed 20 points. Therefore, the Project’s conversion of the site’s Farmlands to non-agricultural uses is considered significant.
There are no feasible mitigation measures to reduce impacts associated with the Project’s conversion of Prime Farmland to non- agricultural uses. Retention of on -site agricultural uses would be infeasible as it would prevent the development of future residential buildings, which would inhibit implementation of the Project as a whole. Replacement of agricultural resources off -site would be infeasible as creation of new farmland - status properties within the City is outside of the City and future applicants’ control. Additional off -site mitigation would be infeasible as it would require the future applicant to purchase replacement acreage for farmland currently not in use elsewhere in California and restore it as viable farmland; however, distant mitigation would not reduce impacts as the Project parcels have no relationship to the loss of agricultural lands within the City or County. There is no available replacement acreage of lower quality farmland within the City or County that could be mitigated to Prime Farmland. Farmland within the City or County is either planned for future development of non- agricultural uses or already designated by the Department of Conservation as Unique Farmland, Farmland of Statewide Importance, or Prime Farmland. Overall, no feasible mitigation measures exist which would substantially lessen the Project’s significant impacts related to the conversion of Prime Farmland and Farmland of Statewide Importance to non -agricultural use.
Therefore, impacts would be significant and unavoidable.
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Impact Finding AG-5: The Project would involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of Forest land to non-forest use (Draft Subsequent EIR at p. 5.1-9). Impacts are significant and unavoidable.
Facts in Support of Findings: According to the LESA Model significance thresholds, sites receiving a score of between 60 and 70 points are considered significant unless either the Land Evaluation or Site Assessment weighted factor subscore is less than 20 points. Both the Land Evaluati on and Site Assessment subscores exceed 20 points. Therefore, the Project’s conversion of the site’s Farmlands to non -agricultural uses is considered significant.
There are no feasible mitigation measures to reduce impacts associated with the Project’s conversion of Prime Farmland to non- agricultural uses. Retention of on -site agricultural uses would be infeasible as it would prevent the development of future residential buildings, which would inhibit implementation of the Project as a whole. Replacement of agricultural resources off -site would be infeasible as creation of new farmland - status properties within the City is outside of the City and future applicants’ co ntrol. Additional off -site mitigation would be infeasible as it would require the future applicant to purchase replacement acreage for farmland currently not in use elsewhere in California and restore it as viable farmland; however, distant mitigation would not reduce impacts a s the Project parcels have no relationship to the loss of agricultural lands within the City or County. Overall, no feasible mitigation measures exist which would substantially lessen the Project’s significant impacts related to the c onversion of Prime Farmland and Farmland of Statewide Importance to non-agricultural use. Therefore, impacts would be significant and unavoidable.
Agriculture and Forestry Cumulative Finding: The Project would have a cumulatively adverse impact related to agriculture. A significant impact would occur (Draft EIR at p. 5.1-10).
Facts in Support of Findings: Continued conversion of agricultural lands to urban uses would substantially reduce overall agricultural productivity in the City and the County region. According to the City of Redlands General Plan EIR, approximately 200 acres of Prime, Important, or Unique Farmland could potentially be converted under buildout of the General Plan. The overall decrease in farmland within the City was identified as a significant cumulative impact in the General Plan EIR. Although the site is designated for non-agricultural uses by the General Plan, implementation of the Project would contribute to the reduction of agricultural uses and Farmland within the region and would cumulatively contribute to the loss of agricultural resources within the County. Although the proposed conversion is consistent with the projected decline in agricultural uses by the General Plan EIR, the Project would result in cumulatively considerable impacts to agricultural resources.
Impacts would therefore be cumulatively significant and unavoidable.
B. Air Quality
Impact AQ-1 Finding: The Project would conflict with obstruct implementation of an applicable air quality plan (Draft Subsequent EIR at p. 5.2-20). Impacts would be significant and unavoidable.
Facts in Support of Finding: 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. 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.
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As detailed below under Impact AQ-2 within the Draft Subsequent EIR, 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.
Impact AQ -2 Finding: The Project would result in a cumulatively considerable net increase of criteria pollutants for which the Project region is non-attainment under an applicable federal or State ambient air quality standard (Draft Subsequent EIR at p. 5.2-22). Impacts would be significant and unavoidable.
Facts in Support of Finding:
Construction: 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. 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, SOX, PM10,
and PM2.5. Thus, Mitigation Measure AQ -1 has been included to require that fu ture 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.
Operation: As shown in Draft Subsequent EIR Table 5.2-7, 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. 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.
Impact AQ-3 Finding: The Project would expose sensitive receptors to substantial pollutant concentrations (Draft Subsequent EIR at p. 5.2-26). Impacts would be significant and unavoidable.
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Facts in Support of Finding:
Construction: A Localized Significan ce Threshold (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 loc alized 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.
Operational: 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.
CO Hotspots: 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 throu ghout 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: 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.
Air Quality Cumulative Finding: The Project would have a cumulatively adverse impact related to air quality. A significant impact would occur (Draft Subsequent EIR at p. 5.2-27).
Facts in Support of Finding: I f an individual project would result in air emissions of criteria pollutants that exceed the SCAQMD’s thresholds for project -specific impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants. As described under Impact AQ -2 in the Draft Subsequent EIR, emissions from construction of the proposed Project could exceed the SCAQMD’s thresholds after implementation of SCAQMD rules and mitigation measures. Also, emissions from operat ion 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.
Mitigation Measures
MM 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 Redlands Regular Meeting of 06-03-25
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(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. • 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 main tained as per the manufacturer’s specification. Maintenance records shall be available at the construction site for City verification.
MM 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; Redlands Regular Meeting of 06-03-25
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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.
MM 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/m 3), 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).
C. Greenhouse Gas Emissions
Impact GHG-1 Finding: The Project would generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment (Draft Subsequent EIR at p. 5.5-14). Impacts would be significant and unavoidable.
Facts in Support of Findings:
Construction: 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, Mitigation Measure AQ-1 has been 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.
Operation: As shown on Draft Subsequent EIR Table 5.5 -2, operation of the Project at buildout and full occupancy would generate 23,660.41 MTCO2e 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. Because buildout of the proposed land uses would result in exceedance of the SP Redlands Regular Meeting of 06-03-25
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screening threshold, Mitigation Measures AQ -1 and AQ-2 would be implemented to require development projects to prepare a project-specific 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 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.
Impact GHG-2 Finding: The Project could conflict with an applicable plan, policy or regulation adopted for the purpose of reducing emissions of greenhouse gases (Draft Subsequent EIR at p. 5.5-17). Impacts would be significant and unavoidable.
Facts in Support of Finding: 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 Pl an policies and the City’s Climate Action Plan. However, as detailed in Draft Subsequent EIR Table 5.5-5, the proposed Project would have the potential to be inconsistent with the 2022 Scoping Plan Appendix D, Local Actions. 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.
Greenhouse Gas Cumulative Finding: The Project would have a cumulatively adverse impact related to greenhouse gas emissions. A significant impact would occur (Draft Subsequent EIR at p. 5.5-25).
Facts in Support of Finding: 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, 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.
Mitigation Measures
MM AQ-1: Construction Emissions. Listed previously in Section IV, Subsection B, Air Quality.
MM AQ-2: Operational Emissions. Listed previously in Section IV, Subsection B, Air Quality.
D. Transportation
Impact TR-2 Finding: The Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (B) regarding vehicle miles traveled (Draft Subsequent EIR at p. 5.10-11).
Facts in Support of Finding: 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 Draft Subsequent EIR 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. As shown in Draft Subsequent EIR 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 c onditions. 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 Redlands Regular Meeting of 06-03-25
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impact. As shown in Draft Subsequent EIR 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 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. As shown in Draft Subsequent EIR 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. As shown in Draft Subsequent EIR 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 thre shold 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.
As shown in Draft Subsequent EIR 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. and the Project VMT/SP for TAZ 53835101 (Site 23) would be 8.1 percent ab ove the threshold under Project Baseline 2024 conditions. 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, 2 1, 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 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.
Mitigation Measures
MM 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. F or 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 metho dology 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.
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• 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 time and inconvenience is added to trips made by private auto. The reduction i n 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.
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• 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.
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SECTION V
GROWTH-INDUCING IMPACTS AND COMMITMENT OF RESOURCES
Section 15126.2(d) of the State CEQA Guidelines requires the EIR address the growth -inducing impact of the Project. Draft Subsequent EIR Section 5.13, Mandatory Findings, evaluates the potential for the proposed Project to affect the environment from employment or population growth, or the construction of additional housing, either directly or indirectly.
Impact Growth-1 Finding: The Project would not establish substantial permanent employment opportunities or otherwise stimulate activity such that it would result in the need for additional housing, businesses, and services to support increased economic opportunities (Draft Subsequent EIR at p. 5.13-3). Impacts would be less than significant.
Facts in Support of Finding: SCAG estimates that employment in the City will increase from 49,900 jobs in 2019 to 60,100 in 2050, which is an increase of over 21 percent. The employment anticipated by the proposed Project would generate approximately 550 new employees (see Section 5.8, Population and Housing), which represents about 5 percent of the estimated job growth by 2050. The 550 jobs expected in the Project area are included in SCAG projections because the employment-generating land uses within the Project area is existing pursuant to current General Plan land use designations and is decreasing with implementation of the Project. Thus, the employment that would occur within the Project area would be less than significant.
Buildout of the proposed Project would contribute to approximately 49.4 percent of the projected population growth, approximately 79.96 percent of the projected housing stock growth, and approximately 5 percent of the projected employment growth in the City. 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 projec tions for the City. Additionally, the projected employment growth that would occur from buildout of the Project would not exceed employment growth projections for the City. Additionally, the proposed Project implements goals and policies of the Redlands Housing Element that support a variety of housing types and densities.
Therefore, the economic effects of the proposed Project would not result in the need for additional development to support the proposed Project and would not result in a substantial impact on the environment.
Impact Growth-2 Finding: The Project would not remove obstacles to growth through the construction or extension of major infrastructure facilities that do not presently exist in the Pr oject area or would add substantial capacity that could accommodate additional unplanned growth (Draft Subsequent EIR at p. 5.13- 4). Impacts would be less than significant.
Facts in Support of Finding: The RHNA Rezone area is a developed urban area that is connected to the City’s existing infrastructure system. Water, sewer, drainage, and roadway infrastructure currently provides service to all of the areas within the Project. As described in Section 5.12, Utilities and Service Systems, of the Draft Subsequent EIR, development projects pursuant to the RHNA Rezone would include potential installation of on-site infrastructure and new connections to the existing infrastructure systems, which include improvements to existing aged infrastructure such as increasing the size of water and sewer lines. However, these improvements would be sized to accommodate individual developments and would not provide excess capacity. Furthermore, buildout pursuant to the Project would not result in the extension of any roadways into undeveloped areas as the rezone sites are surrounded by existing roadways. Therefore, the infrastructure improvements implemented by the Project would not result in unplanned growth.
Impact Growth-3 Finding: The Project would not remove obstacles to growth through changes in existing regulations pertaining to land development (Draft Subsequent EIR at p. 5.13-5). Impacts would be less than significant.
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Facts in Support of Finding: The proposed Project includes amending the City of Redlands General Plan to change the land use designations of 23 sites to allow for additional residential development and a Specific Plan Amendment to remove 15 of the Rezone sites out of the East Valley Corridor Specific Plan (EVCSP).
However, pursuant to the RHNA prepared by the California Department of Housing and Community Development (HCD), the City of Redlands must increase their residential zoning capacity to accommodate their 0.26 percent share that is 3,516 units of the RHNA. Assuming that the maximum number of residential units allowed by the proposed Project are developed and occupied (no vacancy), the 2,325 additional housing units in the Project area would consist of a 9.1 percent increase of housing units citywide, which i s within the SCAG anticipated growth of both the City and the County. Therefore, impacts related to growth from changes in existing regulations pertaining to land development would not occur.
Impact Growth-4 Finding: The Project would not result in the need to expand one or more public service facilities to maintain desired levels of service (Draft Subsequent EIR at p. 5.13-5). Impacts would be less than significant.
Facts in Support of Finding : as detailed in Section 5.9, Public Services , of the Draft Subsequent EIR, the proposed Project would not require development of additional facilities or expansion of existing facilities to maintain existing levels of service. Based on service ratios and buildout projections, the proposed Project would not create a demand for services beyond the capacity of existing facilities or plans. Therefore, an indirect growth inducing impact as a result of expanded or new public facilities that could support other development in addition to the proposed Project would not occur.
Impact Growth -4 Finding: The Project would not involve some other action that could encourage and facilitate other activities that could significantly affect eh environment (Draft Subsequent EIR at p. 5.13-5).
Impacts would be less than significant.
Facts in Support of Finding: The development implemented pursuant to the proposed Project would be required to comply with all applicable City plans, policies, and ordinances. In addition, mitigation measures have been identified within th e Draft Subsequent EIR to ensure that the Project minimizes environmental impacts. The Project would not involve any precedent-setting action that could encourage and facilitate other activities that significantly affect the environment. All physical environmental effects from construction of buildout pursuant to the proposed Project have been analyzed in the technical sections of th e Draft Subsequent EIR and the Initial Study prepared for th e Project (included as Appendix A to the Draft Subsequent EIR). For example, activities such as excavation, grading, and construction as required for the buildout of the Project have been evaluated herein. Also, all operational aspects of future development pursuant to the Project have been analyzed in the Draft Subsequent EIR and throug h implementation of existing regulations, including the General Plan and zoning ordinance, would not create an environmental impact of induced growth.
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SECTION VI
SIGNIFICANT IRREVERSIBLE EFFECTS
Section 15126.2(c) of the CEQA Guidelines requires that an EIR discuss “any significant irreversible environmental changes which would be involved in the proposed action should it be implemented.” Generally, a project would result in significant irreversible environmental changes if:
• The project would involve a large commitment of nonrenewable resources; • The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project; or • The proposed irretrievable commitments of nonrenewable resources is not justified (e.g., the project involves the wasteful use of energy).
The proposed Project would result in or contribute to the following irreversible environmental changes:
• Lands in the Project site would be committed to residential uses once the proposed building s are constructed. Secondary effects associated with this irreversible commitment of land resources include:
o Changes in views associated with construction of the new building and associated development (Section 5.1, Aesthetics, of the Initial Study (included as Appendix A to the Draft Subsequent EIR)) o Increased vehicle trips on surrounding roadways during operation of future projects under the proposed Project (see Section 5.10 of the Draft Subsequent EIR, Transportation). o Emissions of air pollutants associated with Project construction and operation of future projects under the proposed Project (see Section 5.2 of the Draft Subsequent EIR, Air Quality). o Consumption of non-renewable energy associated with construction and operation of future projects under the proposed Project due to the use of automobiles, lighting, heating and cooling systems, appliances, and the like (see Section 5.4 of the Draft Subsequent EIR, Energy). o Increased ambient noise associated with an increase in activities and traffic from future projects under the proposed Project (see Section 5.7 of the Draft Subsequent EIR, Noise). o Construction of the proposed Project as described in Section 3.0 of the Draft Subsequent EIR, Project Description, would require the use of energy produced from non -renewable resources and construction materials.
The Project site contains approximately 44.67 acres of Prime Farmland. The Project could result in conversion of the Prime Farmland to non -agricultural uses with buildout pursuant to the proposed rezoning. There are no feasible mitigation measures to reduce impacts associated with the Project’s conversion of this farmland to nonagricultural uses. Therefore, impacts would be significant and unavoidable. Project implementation would result in the conversion of existing 44.67 acres of Farmland at the Project s ite to nonagricultural use and could facilitate the conversion of Farmland within the vicinity to nonagricultural use. Development of the Project site could result in increased development pressure on the surrounding agricultural sites. Therefore, the Project could indirectly cause changes in the environment that could convert other farmland 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.
In regard to energy usage from the proposed Project, as demonstrated in the analyses contained in Draft Subsequent EIR Section 5.4, Energy, the proposed Project would not involve wasteful or unjustifiable use of non-renewable resources, and conservation efforts would be enforced during construction and operation of proposed development. The proposed development would incorporate energy- generating and conserving Project design features, including those required by the California Building Code, California Energy Code Title 24, which specify green building standards for new developments. Project specific information related to energy consumption is provided in Section 5.4, Energy, of the Draft Subsequent EIR.
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SECTION VII
ALTERNATIVES
The City of Redlands hereby declares that it has considered and rejected as infeasible the alternatives identified in the Draft Subsequent EIR and described below. Section 15126.6 of the State CEQA Guidelines requires an EIR to describe a range of reasonable alternatives to the Project, or to the location of the Project, which could feasibly achieve most of its basic objectives, but would avoid or substantially lessen any of the significant effects identified in the EIR analysis. An EIR is not required to c onsider every conceivable alternative to a proposed project. Rather, an EIR must consider a reasonable range of alternatives that are potentially feasible; an EIR is not required to consider alternatives that are infeasible. In addition, an EIR should evaluate the comparative merits of the alternatives. Therefore, this section sets forth the potential alternatives to the Project analyzed in the EIR and evaluates them in light of the objectives of the Project, as required by CEQA.
Objectives
The following objectives have been identified in order to aid decision makers in their review of the proposed Project and its associated environmental impacts. (Draft Subsequent EIR at p. 6-4) • Implement Program 1.1-1 of the 6th Cycle 2021-2029 Housing Element to provide adequate capacity for at least 4,219 units on suitable sites.
• Maintain adequate housing sites for all income groups throughout the eight-year planning period. • Increase the City’s overall housing capacity and capability to accommodate housing as required per the certified Housing Element for the 2021-2029 housing cycle. • Minimize potential land use conflicts associated with the proposed change to existing land use designations and zoning.
Alternatives
Key provisions of the State CEQA Guidelines relating to the alternatives analysis (Section 15126.6 et seq.) are summarized below:
• The discussion of alternatives shall focus on alternatives to the Project or its location that are capable of avoiding or substantially lessening any significant effects of the Project, even if these alternatives would impede to some degree the attainment of the Project objectives or would be more-costly. • The “No Project” alternative shall be evaluated along with its impact. The “No Project” analysis shall discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable future if the Project is not approved.
• The range of alternatives required in an EIR is governed by a “rule of reason ;” therefore, the EIR must evaluate only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the Project. • For alternative locations, only locations that would avoid or substantially lessen any of the significant effects of the Project need be considered for inclusion in the EIR. • An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative.
Rationale for Selecting Potentially Feasible Alternatives The alternatives must include a no-project alternative and a range of reasonable alternatives to the Project if those reasonable alternatives would attain most of the Project objectives while substantially lessening the Redlands Regular Meeting of 06-03-25
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potentially significant Project impacts. The range of alternatives discussed in an EIR is governed by a “rule of reason,” which the State CEQA Guidelines Section 15126.6(f)(3) defines as:
. . . set[ting] forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the Project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision-making.
Among the factors that may be taken into account when addressing the feasibility of alternatives (as described in the State CEQA Guidelines Section 15126.6(f)([1]) are environmental impacts, site suitability, economic viability, availability of infrastruct ure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the P roject proponent could reasonably acquire, control, or otherwise have access to an alternative site. An EIR need not consider an alternative whose effects could not be reasonably identified, and whose implementation is remote or speculative.
For purposes of this analysis, the Project alternatives are evaluated to determine the extent to which they attain the basic Project objectives, while significantly lessening the significant effects of the Project.
Alternatives Not Selected for Analysis
Alternate Site Alternative
An alternative site alternative was considered and eliminated from further consideration. CEQA specifies that the key question regarding alternative site consideration is “whether any of the significant effects of the Project would be avoided or substantially lessened by putting the Project at another location.” In addition, an alternative site need not be considered when implementation is “remote and speculative,” such as when the alternative site is beyond the control of a Project applicant.
An alternate site for the Project was eliminated from further consideration. Any alternate site would need to occur within the City of Redlands. The City is required by State law to rezone housing shortfall sites according to what has been approved under the certified Housing Element (Government Code § 65583.2, Senate Bill 197). The site s identified within the City’s 2021 -2029 Housing Element include the Rezone sites , and an alternate site would fail to meet most of the Project objectives, would be infeasib le, and would not be compliant with State law regarding rezoning pursuant to the City’s Housing Element. Additionally, if the Project were to occur on an alternate site and rezoning were conducted within different parcels in the City, similar impacts would result and comparable mitigation would be required; therefore, impacts would not be reduced under this alternative. Therefore, this alternative has been determined infeasible. (Draft Subsequent EIR at p. 6-4)
Finding: The City of Redlands rejects the Alternative Site Alternative, on the following ground, which provides sufficient justification for rejection of this alternative: the Project is location specific as the sites were identified in the City’s 2021 -209 Housing Element . I f the Project were to be relocated it would require similar, potentially additional, mitigations and would not reduce impacts compared to the proposed Project .
Therefore, this alternative is eliminated from further consideration.
Alternatives Selected for Further Analysis
Alternative 1: No Project/No Development Alternative
This alternative consists of the Project not being approved, and the Project site would remain in the conditions that existed at the time the Notice of Preparation was published (July 1, 2024) with no additional development occurring within the Rezone sites. (Draft Subsequent EIR at p. 6-4) Redlands Regular Meeting of 06-03-25
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Alternative 2: No Project/Buildout of Existing Land Use Alternative Under this alternative, buildout of the residential and nonresidential uses would occur as permitted under the existing General Plan land use designations, and the Project site would not be rezoned to allow for additional residential uses. Buildout of this Alternative would result in up to 2,209,040.26 square feet of non-residential uses and 111 units of residential development. (Draft Subsequent EIR at p. 6-4) Alternative 3: Reduced Project Site Alternative
The Reduced Project Site Alternative would allow for a similar future development to occur as proposed by the Project, but the allowed area where the future rezone and potential development would be allowed to occur would be limited to only a portion of the existing Project site. Under this alternative, the parcels which are located on the Morrey Arroyo Creek (Sites 2, 7, 8, 11,12, 16, 16A, and 24) would not be rezoned. All parcels under this alternative (1, 3, 4, 5, 6, 9, 10, 10A, 13, 14, 15, 15A, and 17-23) would be rezoned the R-3 zoning designat ion, with a maximum density of 30 dwelling units/acre. The Reduced Project Site Alternative would allow for the potential future development of 2,439 residential units but would limit the potential future development to just 81.32 acres. This alternative would still require an SPA to the EVCSP, a GPA, and zone change. (Draft Subsequent EIR at p. 6-5)
Alternative 4: Reduced Project Development Intensity Alternative The Reduced Project Development Intensity Alternative would redesignate the Rezone sites to allow for development of future residential and additional square footage of nonresidential development, similar to the proposed Project. However, potential buildou t would be reduced by 55 percent, thereby limiting the overall future buildout to a maximum of 1,096 residential units and a buildout of 67,971.81 SF nonresidential uses. This alternative would still require approval of the GPA, adoption of a zone change, and adoption of an SPA to the EVCSP. Furthermore, under this alternative, only 1,948 dwelling units would be allowed to be constructed and the City would have a 1,315 dwelling -unit deficit in meeting their State mandated RHNA fair share. (Draft Subsequent EIR at p. 6-5) Findings for Alternatives
Alternative 1: No Project/No Development Alternative
The No Project/No Development Alternative would result in continuation of the existing uses within the Rezone sites, and the potential buildout of additional residential units based on the proposed rezoning would not occur. As a result, this alternative would avoid the need for mitigation measures that are identified in Section
5.0 of this Draft Subsequent EIR, which include measures related to air quality, biological resources, cultural resources, greenhouse gas emissions, paleontological res ources, noise, transportation, and tribal cultural resources. This alternative would also avoid the significant and unavoidable impacts to air quality, agriculture, greenhouse gas emissions, and VMT.
Implementation of the No Project/No Development Alternative would not meet any of the Project objectives.
The No Project/No Development Alternative would not introduce any additional housing within the City and the City would not be able to meet their RHNA per the 2021-2029 Housing Element. Additionally, under this alternative the City would not be able to address land use conflicts within the City. (Draft Subsequent EIR at p. 6-9)
Finding: The City of Redlands finds that the No Project/No Development Alternative would not necessitate mitigation measures related to air quality, biological resources, cultural resources, greenhouse gas emissions, paleontological resources, noise, transportation, and tribal cultural resources. However, the potential benefits of the proposed Project would also not be realized including providing housing that would result in a better jobs-housing balance in Redlands, which is currently considered jobs rich. In addition, the City of Redlands Redlands Regular Meeting of 06-03-25
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would not be compliant with State Housing Element Law under this alternative. Each of these reasons, separately and independently, is a sufficient basis upon which to reject this alternative.
Alternative 2: No Project/Buildout of Existing Land Use Alternative The No Project/Buildout of Existing Land Use Alternative would not eliminate the significant and unavoidable impacts related to agricultural resources, air quality emissions, GHG emissions, and VMT that would occur from implementation of the proposed Project. In addition, this alternative would require the same mitigation to ensure less than significant impacts related to historical resources, biological resources, cultural resources, paleontological resources, noise, and tribal cultural resources . This alternative would not result in lessened impacts to any of the 19 environmental topics analyzed in the Draft Subsequent EIR and Initial Study (Draft Subsequent EIR Table 6-3).
As shown in Draft Subsequent EIR Table 6-4, the No Project/Buildout of Existing Land Use Alternative would not meet any of the Project objectives. The No Project/Buildout of Existing Land Use Alternative would not introduce enough additional housing within the City to able to meet their RHNA per the 2021-2029 Housing Element. Additionally, under this alternative the City would not be able to address land use conflicts within the City.
Finding: The City of Redlands finds that the No Project/Buildout of Existing Land Use Alternative would not result in any lessened impact compared to the proposed Project and would require the same mitigation measures as the proposed Project. This alternative would not meet the Project objectives to bring housing to the City of Redlands. In addition, the City of Redlands would not be compliant with State Housing Element Law under this alternative. These reasons, separately and independently, is a sufficient basis upon which to reject this alternative.
Alternative 3: Reduced Project Site Alternative
The Reduced Project Site Alternative would not eliminate the significant and unavoidable impacts related to agricultural resources, air quality, GHG emissions, and VMT that would occur from implementation of the proposed Project, as buildout under this alternative would be only slightly reduced in comparison to that allowed under the proposed Project. In addition, this alternative would require most of the same mitigation to ensure less than significant impacts related to historical resources, biological resources, cultural resources, paleontological resources, and noise. Overall, although the volume of impacts would be less under the Reduced Project Site Alternative, the Reduced Project Site Alternative would not eliminate any of the significant and unavoidable impacts that would result from buildout of the proposed Project.
As shown in Table 6-4 of the Draft Subsequent EIR, implementation of the Reduced Project Site Alternative would achieve Objectives 1, 2, and 4 as it would introduce additional residential units in the City to help reach the City’s RHNA goals. The Reduced Project Site Alternative would not meet Objective 3, to minimize potential land use compatibility conflicts associated with the proposed change to existing land use designations and zoning as Site 24 would not be rezoned to Public/Institutional uses to be consistent with the existing school uses and proposed residences surrounding the site.
Finding: The City of Redlands finds that the Reduced Project Site Alternative would not eliminate the significant and unavoidable impacts from the Project and would not eliminate the need for mitigation. The Reduced Project Site Alternative would meet the majority of P roject objective s. However, it would not minimize potential land use conflicts associated with the proposed zone change. These reasons, separately and independently, are a sufficient basis upon which to reject this alternative.
Alternative 4: Reduced Project Development Alternative
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from implementation of the proposed Project. In addition, this alternative would require most of the same mitigation to ensure less than significant impacts related to historical resources, biological resources, cultural resources, paleontological resources, and noise. However, this alternative would avoid the significant and unavoidable impact related to operational air quality emissions.
The Reduced Project Development Alternative would meet Objective 4, to minimize potential land use compatibility conflicts associated with the proposed change to existing land use designations and zoning as Site 24 would be rezoned to Public/Institutional uses to allow for less intense development more similar to its surrounding proposed residential uses. The Alternative would not meet Objectives 1, 2, or 3 as the amount of housing proposed by this Alternative would not be enough for the City to meet their RHNA goals as discussed in the certified Housing Element for the 2021-2029 housing cycle and would not provide enough housing to accommodate all income groups as allocated by RHNA.
Finding: The City of Redlands finds that the Reduced Project Development Alternative would not provide enough housing to reach their RHNA goals as discussed in the certified Housing Element for the 2021-2029 housing cycle, which is a main objective of the proposed Project. Because this alternative would not meet the City’s legal obligation to rezone the site to meet the necessary residential capacity consistent with the City’s certified Housing Element Update, this alternative is eliminated from further consideration.
Environmentally Superior Alternative
Section 15126.6(e)(2) of the CEQA Guidelines indicates that an analysis of alternatives to a proposed project shall identify an environmentally superior alternative among the alternatives evaluated in an EIR. The Environmentally Superior Alternative for the Project would be the No Project/No Development Alternative.
Pursuant to CEQA Guidelines Section 15126.6(3)(1) an additional alternative need to be selected alongside the No Project/Development Alternative. The second Environmentally Superior Alternative for the Project is the Reduced Project Site Alternative.
The No Project/No Development Alternative would avoid the implementation of the mitigation measures that are identified in Section 5.0 of the Draft Subsequent EIR that are related to air quality, biological resources, cultural resources, greenhouse gas emissions, paleontological resources, noise, transportation, and tribal cultural resources. The Reduced Project Site Alternative would result in lessened impact to 5 of the 16 environmental topics analyzed in the Draft Subsequent EIR. Implementation of the Reduced Project Site Alternative would achieve Objectives 1, 2, and 4, but would not meet Objective 3, to minimize potential land use compatibility conflicts associated with the proposed change to existing land use designations and zoning. This alternative would be required to implement applicable mitigation measures regarding air quality, biological resources, cultural resources, greenhouse gas emissions, paleontological resources, noi se, transportation, and tribal cultural resources, similar to the Project. Thus, although environmentally superior, mitigation measures would continue to be required. (Draft Subsequent EIR at p. 7-18) CEQA does not require the lead agency (the City of Redlands ) to choose the environmentally superior alternative. Instead, CEQA requires the City to consider environmentally superior alternatives, weigh those considerations against the environmental impacts of the proposed Project, and make findings that the benefits of those considerations outweigh the harm. Based on the considerations described herein, the City of Redland finds that the No Project/No Development Alternative and Reduced Project Site Alternative are infeasible based on these environmental, economic, and social factors.
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SECTION VII
STATEMENT OF OVERRIDING CONSIDERATIONS
Introduction
The City of Redlands is the Lead Agency under CEQA for preparation, review , and certification of the Subsequent EIR for the Redlands RHNA Project (Project). As the Lead Agency, the City is also responsible for determining the potential environmental impacts of the proposed action and which of those impacts are significant, and which can be mitigated through imposition of mitigation measures to avoid or minimize those impacts to a level of less than significant. CEQA then requires the Lead Agency to balance the benefits of a proposed action against its significant unavoidable adver se environmental impacts in determining whether or not to approve the proposed Project. In making this determination the City is guided by CEQA Guidelines Section § 15093, Statement of Overriding Considerations, which states:
(a) CEQA requires the decision -making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposal (sic) project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.” (b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the Final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the Final EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record.
(c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to CEQA Guidelines Section 15091.
In addition, Public Resources Code Section § 21081(b) requires that where a public agency finds that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in an EIR and thereby leave significant unavoidable effects, the public agency must also find that overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects of the project.
Pursuant to Public Resources Code Section § 21081(b) and the State CEQA Guidelines Section § 15093, the City has balanced the benefits of the proposed Project against the unavoidable adverse impacts associated with the Project and has adopted all feasible mitigation measures with respect to these impacts. The City also has examined alternatives to the proposed Project, none of which both meet the Project objectives and is environmentally preferable to the proposed Project for the reasons discussed in the Findings and Facts in Support of Findings.
The City of Redlands, as the Lead Agency for this Project, and having reviewed the Subsequent EIR for the Redlands RHNA Rezone Project, and reviewed all written materials within the City’s public record and heard all oral testimony presented at public hearings, adopts this Statement of Overriding Considerations, which has balanced the benefits of the Project against its significant unavoidable adverse environmental impacts in reaching its decision to approve the Project.
Overriding Considerations
The City, after balancing the specific economic, legal, social, technological, and other benefits of the Project, has determined that the unavoidable adverse environmental impacts identified above may be considered Redlands Regular Meeting of 06-03-25
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acceptable due to the following specific considerations which outweigh the unavoidable, adverse environmental impacts of the Project, each of which standing alone is sufficient to support approval of the Project, in accordance with CEQA Guideline Section § 21081(b) and CEQA Guideline Section § 15093. The specific economic, legal, social, technological, or other benefits of the Project are as follows:
• The Project would allow the City to meet their State mandated RHNA fair share and would ensure that the City remains consists with State Housing Element Law. • The Project would implement and be consistent with the City’s Housing Element. • The Project provides additional housing and the necessary residential capacity consistent with the City’s certified Housing Element Update.
• The Project would provide housing that would result in a better jobs-housing balance in Redlands, which is currently considered jobs rich.
• The Project would promote a diverse housing stock with a wide range of sizes and affordability within the City of Redlands.
• The Project would increase the development potential of underutilized parcels of the City of Redlands, allowing for increased residential development and development impact fees within the City. • The Project would locate new higher -density housing developments within close proximity to nearby retail stores, personal service uses, medical and dental offices, schools, parks, transportation corridors, and employment centers in Redlands.
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SECTION VIII
CERTIFICATION OF THE EIR
The City of Redlands finds that it has reviewed and considered the Final EIR in evaluating the proposed Project, that the Final EIR is an accurate and objective statement that fully complies with CEQA, State CEQA Guidelines and that the Final EIR reflects the independent judgment of the City.
The City of Redlands declares that no new significant information as defined by State CEQA Guidelines, Section 15088.5 has been received by the City after circulation of the Draft Subsequent EIR that would require recirculation.
The City of Redlands certifies the Subsequent EIR based on the entirety of the record of proceedings, including but not limited to the following findings and conclusions.
Findings
The following significant environmental impacts have been identified in the Subsequent EIR and would require mitigation as set forth in Section IV of this Resolution but cannot be mitigated to a level of insignificance:
• Agriculture and Forestry (Project-related and cumulative), • Air Quality(Project-related and cumulative),
• Greenhouse Gas Emissions (Project-related and cumulative), and • Transportation (Project-level).
Conclusions
1. All significant environmental impacts from the implementation of the proposed Project have been identified in the Subsequent EIR and, with implementation of existing regulations and the mitigation measures from the Subsequent EIR, will be mitigated to a level of insignificance.
2. Other alternatives to the proposed Project, which could potentially achieve the basic objectives of the proposed Project, have been considered and rejected in favor of the proposed Project.
3. Environmental, economic, social, and other considerations and benefits derived from the proposed Project override and make infeasible any alternatives to the proposed Project or further mitigation measures beyond those incorporated into the proposed Project.
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SECTION IX
MITIGATION MONITORING AND REPORTING PLAN
Pursuant to Public Resources Code Section 21081.6, the City of Redlands adopts the Mitigation Monitoring and Reporting Plan (MMRP) attached to this Resolution as Exhibit A. In the event of any inconsistencies between the mitigation measures as set forth herein and the Mitigation Monitoring and Reporting Plan, the Mitigation Monitoring and Reporting Plan shall control.
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SECTION X
CONTENTS AND CUSTODIAN OF RECORDS
The documents and materials that constitute the record of proceedings on which these findings have been based are located at the City of Redlands Planning Division. The custodian for these records is the City of Redlands. This information is provided in compliance with Public Resources Code Section 21081.6.
The record of proceedings for the City’s decision on the Project consists of the following documents, at a minimum:
1. The Initial Study for the Redlands RHNA Rezone Project;
2. The NOP, NOA, NOC, and all other public notices issued by the City in conjunction with the Project;
3. All comments submitted by agencies or members of the public during the 45-day comment period on the Draft Subsequent EIR;
4. The Final EIR for the Redlands RHNA Rezone Project, including comments timely received on the Draft Subsequent EIR, responses to those comments, and technical appendices;
5. The Mitigation Monitoring and Reporting Plan for the Project;
6. All findings, resolutions and ordinances adopted by the City in connection with the Redlands RHNA Rezone Project, and all documents cited or referred to therein;
7. All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the Project prepared by the City, consultants to the City, or responsible or trustee agencies with respect to the City’s compliance with the requirements of CEQA and with respect to the City’s action on the Redlands RHNA Rezone Project;
8. All documents submitted to the City by other public agencies or members of the public in connection with the Redlands RHNA Rezone Project up through Project approval.
9. Matters of common knowledge to the City, including, but not limited to f ederal, State, and local laws and regulations;
10. Any documents expressly cited or referenced in these findings, in addition to those cited above; and
11. Any other materials required for the record of proceedings by Public Resources Code Section 21167.6, subdivision (e).
The following location is where review of the record may be performed:
City of Redlands
Planning Division
35 Cajon Street
Redlands, CA 92373
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Table 3-1: Mitigation Monitoring and Reporting Program
Redlands RHNA Rezone Project
Plan, Program, Policy / Mitigation Measure Timing Responsible for Ensuring Compliance / Verification
Date Completed
and Initials
AIR QUALITY
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 Ai r 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 int
o 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 coul d 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 bui lding 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.
Prior to grading permit
and building permit
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Plan, Program, Policy / Mitigation Measure Timing Responsible for Ensuring Compliance / Verification
Date Completed
and Initials
• 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 main
tained 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; Prior to issuance of
certificates of occupancy
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Plan, Program, Policy / Mitigation Measure Timing Responsible for Ensuring Compliance / Verification
Date Completed
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• 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);
• 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/m3, or the appropriate noncancer hazard index exceeds 1.0, the applicant will be required to identify and demonstrate that mitigation measures are capable of reducing potential cancer and non-cancer risks to an acceptable level (i.e., below ten in one millio n or a hazard index of 1.0), including appropriate enforcement mechanisms. Measures to reduce risk may include but are not limited to:
Prior to issuance of
development permits
City of Redlands Planning
Division
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• 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).
BIOLOGICAL RESOURCES
Mitigation Measure BIO -1: Biological Assessment. Future projects proposed within the proposed Project site shall be surveyed by a qualified biologist to determine if any special -status plant or wildlife species have the potential to occur or if any riparian habitats, jurisdictional drainages, or wetlands are present onsite. If suitable habitat is present, a qualified biologist shall survey for special-status species during the appropriate time of year (i.e., when the species is readily identifiable, such as during its blooming period) prior to initiating any ground disturbing activities in a given area. The focused surveys shall be conducted in accordance with CDFW guidelines. If special -status species are identified and c annot be avoided, the project -level biological survey report would justify why species-specific mitigation is necessary and propose mitigation to reduce project impacts to a less than significant level.
Prior to the issuance of
grading permits
City of Redlands Planning
Division
Mitigation Measure BIO-2: Jurisdictional Resources: If potential jurisdictional waters are determined to be present onsite through the biological assessment require by MM BIO-1 above, a jurisdictional assessment shall be conducted for future projects within Sites 1 through 24. Jurisdictional resources shall be avoided when feasible. Where avoidance is not feasible, project -specific impacts to jurisdictional resources shall be addressed and mitigated by federal and state regulators via applicable consulting and permitting process. The types of mitigation required may include onsite or offsite preservation, enhancement, creation, and/or restoration. Mitigation is typically required at a 1:1 ratio or higher and to be accomplished in close proximity to the impacts or at least in the same watershed. Final requirements and locations are, however, subject to change during applicable consultation/permit processes required by the USACE, RWQCB, and CDFW.
Best Management Practices (BMPs) to minimize and avoid impacts to jurisdictional resources during and after construction are subject to approval by permitting agencies and shall include, but are not limited to, the following:
Prior to the issuance of
grading permits
City of Redlands Planning
Division
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• Construction-related equipment shall be stored in developed areas, outside of the drainage. No equipment maintenance shall be done within or adjacent to the drainage.
• Source control and treatment control BMPs shall be implemented to minimize the potential contaminants that are generated during and after construction.
Water quality BMPs shall be implemented throughout the project to capture and treat potential contaminants.
• Substances harmful to aquatic life shall not be discharged into the drainage.
All hazardous substances shall be properly handled and stored. • A Storm Water Pollution Prevention Plan shall be prepared to prevent sediment from entering the drainage during construction. • To avoid attracting predators during construction, the project shall be kept clean of debris to the extent possible. All food -related trash items shall be enclosed in sealed containers and regularly removed from site. • Construction personnel shall strictly limit their activities, vehicles, equipment and construction material to the proposed project footprint, staging areas, and designated routes of travel.
• Exclusion fencing shall be installed to demarcate the limits of disturbance.
The exclusion fencing should be maintained until the completion of construction activities.
CULTURAL RESOURCES
PPP CUL -1: Municipal Code Chapter 2.62. The City of Redlands Historic Architectural Design Guidelines shall apply to all future projects within the proposed Project. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings may also be applicable to properties or projects that may affect historic buildings and resources.
Prior to issuance of
demolition permits
City of Redlands Building &
Safety Division
Mitigation Measure 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 Prior to issuance of
demolition permits
City of Redlands Planning
Division
Redlands Regular Meeting of 06-03-25
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Final Subsequent EIR
April 2025
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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.
Mitigation Measure CUL-2. For renovations involving historical resources identified through the process described in the architectural history evaluation mitigation measure (MM CUL-2), 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.
Prior to issuance of
building permits
City of Redlands Planning
Division
Mitigation Measure 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.
Prior to the issuance of
grading permits
City of Redlands Planning
Division
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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 as sessment 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.
Mitigation Measure 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 resource s 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. The plan shall include a scope of work, project grading and development scheduling, 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 Prior to the issuance of
grading permits
City of Redlands Planning
Division
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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 satisf
action 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 Redlands Regular Meeting of 06-03-25
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archaeologist disagree on preferred treatment, the ultimate authority shall be the City of Redlands Director of Development Services.
If human remains or funerary/burial objects are encountered during any activities associated with the project, work in the immediate vicinity (within a 100-foot buffer) 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 archaeolo
gical 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.
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• 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.
If human remains or funerary/burial objects are encountered during any activities associated with the project, work in the immediate vicinity (within a 100-foot buffer) 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.
GEOLOGY AND SOILS
Mitigation Measure PAL -1: Paleontological Resources. Future project applicants within the Project sites shall provide a paleontological assessment by a qualified paleontologist meeting the standards of the Society of Vertebrate Paleontology (SVP) to determine whether grading for the project could impact underlying soil units or geologic formations that have a low to high potential to yield fossiliferous materials, prior to project approval.
The qualified
paleontologist will determine the degree of paleontological resource sensitivity, as outlined below, and s hall recommend a project -
specific paleontological
Prior to issuance of
grading permits
City of Redlands Planning
Division
Redlands Regular Meeting of 06-03-25
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Final Subsequent EIR
April 2025
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and Initials
resources monitoring and mitigation plan (PRMMP), if warranted, based on paleontological sensitivity. This plan will address specifics of monitoring and mitigation for the development project, and will take into account updated geologic mapping, geotechnic
al data, updated paleontological records
searches, and any changes to the regulatory framework. This PRMMP must meet the standards of the SVP. The following provisions would be typical for units mapped with the different levels of paleontological sensitivity:
• High- All projects involving ground disturbances in previously undisturbed areas sediments mapped as having high paleontological sensitivity shall require preparation of a PRMMP by a qualified paleontologist and shall be monitored by a qualified paleontological monitor on a full-time basis under the supervision of the Qualified Paleontologist. Undisturbed sediments may be present at the surface, or present in the subsurface, beneath earlier developments. This monitoring will include inspection of exposed sedimentary units during active excavations within sensitive geologic sediments. The monitor will have authority to temporarily divert activity away from exposed fossils to evaluate the significance of the find and, should the fossils be determined to be of scientific significance, professionally and efficiently recover the fossil specimens and collect associated data pursuant to the guidelines of the Society of Vertebrate Paleontology (SVP, 2010). Paleontological monitors will use field data forms to record pertinent location and geologic data, will measure stratigraphic sections (if applicable), and collect appropriate sediment samples from any fossil localities.
• Low to High - All projects involving ground disturbance in previously undisturbed areas mapped with low-to-high paleontological sensitivity shall require preparation of a PRMMP by a qualified paleontologist. The PRMMP shall specify that monitoring shall only be required when construction activity will exceed the depth of the low sensitivity surficial sediments. The underlying sediments may have high paleontological sensitivity, and therefore work in those units shall require paleontological monitoring, as designated by the Qualified Paleontologist in the PRMMP. When determining the depth at which the transition to high sensitivity occurs and monitoring becomes necessary, the Qualified Paleontologist should take into account: a) the most recent local geologic mapping, b) depths at which fossils have been found Redlands Regular Meeting of 06-03-25
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in the vicinity of the project area, as revealed by the museum records search, and c) geotechnical studies of the project area, if available. • Low- All projects involving ground disturbance in previously undisturbed areas mapped as having low paleontological sensitivity should incorporate worker training to make construction workers aware that while paleontological sensitivity is low, fossils mig ht still be encountered. The Qualified Paleontologist should oversee this training as well as remain on - call in the event fossils are found. Paleontological monitoring is usually not required for sediments with low paleontological sensitivity. • None- Projects determined by the Qualified Paleontologist to involve ground-disturbing activities in areas mapped as having no paleontological sensitivity (i.e., plutonic igneous or high -grade metamorphic rocks) will not require further paleontological mitigation measures, but shall implement MM PAL-2, if incidental discoveries occur.
Mitigation Measure PAL -2: Fossil Discovery. In the event of any fossil discovery, regardless of depth or geologic formation, construction work will halt within a 50 foot radius of the find until its significance can be determined by a Qualified Paleontologist. Scientifically significant fossils shall be recovered, prepared to the point of curation, identified by qualified experts, listed in a database to facilitate analysis, and deposited in a designated paleontological curation facility in accordance with the standards of the SVP. A repository shall be identified and a curatorial arrangement will be signed prior to collection of the fossils. Any accredited institution may serve as a repository.
During grading activities City of Redlands Planning
Division
GREENHOUSE GAS EMISSIONS
Mitigation Measure AQ-1: Construction Emissions. As listed previously. Prior to grading permit and building permit
City of Redlands Planning
Division
Mitigation Measure AQ-2: Operational Emissions. As listed previously. Prior to issuance of certificates of occupancy
City of Redlands Planning
Division
HAZARDS AND HAZARDOUS MATERIALS
Plan, Program, or Policy PPP HYD-1: SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the City Building Division evidence of compliance with the NPDES (National Pollutant Discharge Elimination System) requirement to obtain a construction permit from the Sta te Water Prior to issuance of a
grading permit
City of Redlands Building &
Safety Division
Redlands Regular Meeting of 06-03-25
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Resource Control Board (SWRCB). The permit requirement applies to grading and construction sites of one acre or larger. The Project applicant/proponent shall comply by submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the construction site.
HYDROLOGY AND WATER QUALITY
Plan, Program, or Policy PPP HYD-1: SWPPP. As listed previously. Prior to issuance of a grading permit
City of Redlands Building &
Safety Division
Plan, Program, or Policy PPP HYD -2: WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a completed Water Quality Management Plan (WQMP) shall be prepared by the Project applicant and submitted to and approved by the City Public Works Department. The WQMP shall identify all Post -Construction, Site Design. Source Control, and T reatment Control Best Management Practices (BMPs) that will be incorporated into the development Project in order to minimize the adverse effects on receiving waters.
Prior to issuance of a
grading permit
City of Redlands Building &
Safety Division
NOISE
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.
Prior to issuance of
demolition and/or
grading permits
City of Redlands Planning
Division
Redlands Regular Meeting of 06-03-25
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Final Subsequent EIR
April 2025
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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.
Prior to issuance of
demolition and/or
grading permits
City of Redlands Planning
Division
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 with in 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.
Prior to issuance of
demolition and/or
grading permits
City of Redlands Planning
Division
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 r esult in structural damage to the adjacent Prior to issuance of
demolition and/or
grading permits
City of Redlands Planning
Division
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historic building(s). If recommended by the pre -construction assessment, groundborne vibration monitoring of nearby historic structures shall be required.
PUBLIC SERVICES
Plans, Program, or Policy 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.
Prior to issuance of
certificates of occupancy
City of Redlands Planning
Division
Plans, Program, or Policy PPP PS -2: As a Condition of Approval for implementing projects within the proposed Project, the project applicants/developers shall pay applicable park related fees pursuant to Redlands Municipal Code Chapter 3.32.
Prior to issuance of
certificates of occupancy
City of Redlands Planning
Division
RECREATION
Plans, Program, or Policy PPP PS-2: As listed previously. Prior to issuance of certificates of occupancy
City of Redlands Planning
Division
TRANSPORTATION
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 Prior to issuance of
building permits
City of Redlands Building &
Safety Division
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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 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, Redlands Regular Meeting of 06-03-25
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Redlands RHNA Rezone Project 4. Mitigation Monitoring and Reporting Program City of Redlands 3-19
Final Subsequent EIR
April 2025
Plan, Program, Policy / Mitigation Measure Timing Responsible for Ensuring Compliance / Verification
Date Completed
and Initials
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 Redlands Regular Meeting of 06-03-25
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Redlands RHNA Rezone Project 4. Mitigation Monitoring and Reporting Program City of Redlands 3-20
Final Subsequent EIR
April 2025
Plan, Program, Policy / Mitigation Measure Timing Responsible for Ensuring Compliance / Verification
Date Completed
and Initials
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.
TRIBAL CULTURAL RESOURCES
Mitigation Measure TCR -1: Inadvertent Discovery of Tribal Cultural Resources. In the event that previously unidentified tribal cultural resources are unearthed during construction, the Qualified Archaeologist shall have the authority to temporarily divert and/or temporarily halt ground -disturbance operations in the area of discovery to allow for the evaluation of potentially significant cultural resources. Isolates and clearly non -significant deposits shall be minimally documented in the field and collected so the monitored grading can proceed.
If a potentially significant 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 t he 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 Prior to issuance of
grading permit
City of Redlands Planning
Division
Redlands Regular Meeting of 06-03-25
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Redlands RHNA Rezone Project 4. Mitigation Monitoring and Reporting Program City of Redlands 3-21
Final Subsequent EIR
April 2025
Plan, Program, Policy / Mitigation Measure Timing Responsible for Ensuring Compliance / Verification
Date Completed
and Initials
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)
Mitigation Measure CUL-3: Archeological Resources Assessment. As listed previously.
Prior to the issuance of
grading permits
City of Redlands Planning
Division
Mitigation Measure CUL-4 : Archaeological Monitoring/Preservation. As listed previously.
Prior to the issuance of
grading permits
City of Redlands Planning
Division
Redlands Regular Meeting of 06-03-25
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1 I:\cmo\Resolutions\8688 Amending 20235 General Plan Land Use Map.docx-ms
RESOLUTION NO. 8688
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS AMENDING THE 2035 GENERAL PLAN LAND USE MAP IN
ACCORDANCE WI TH PROGRAM 1.1 -1 (‘RHNA REZONING’) OF THE SIXTH CYCLE 2021–2029 HOUSING ELEMENT.
WHEREAS, the City of Redlands (“City”) has initiated General Plan Amendment No. 149, Amendment No. 1 to Concept Plan No. 4, Amendment No. 54 to Specific Plan No. 40 (East Valley Corridor Specific Plan), and Zone Change No. 479, to amend the General Plan and Specific Plan land use maps and the City Zoning Map to rezone twenty-seven (27) parcels for the regional housing needs allocation (“RHNA”) rezoning project (collectively herein referred to as “Project”) as required by the City’s certified 2021–2029 Housing Element (“Housing Element”); and WHEREAS, the Planning Division conducted an extensive public outreach effort during preparation of the Housing Element and, furthermore, the Project actions are identified in the Housing Element work program, particularly Program 1.1-1 entitled, “RHNA Rezoning”; and WHEREAS, the City and the Southern California region faces a serious housing shortage, and a lack of access to housing directly affects the health, safety and welfare of City residents; and WHEREAS, the state legislature has consistently recognized the continuing need for affordable housing in California and, in Government Code section 65580, states, "the availability of housing is of vital statewide importance, and the early attainment of decent housing… is a priority of the highest order" and, further, that, "local… governments have a responsibility to use the powers vested in them to facilitate the improvement and development of housing to make adequate provision for the housing needs of all economic segments of the community"; and WHEREAS, affordable housing is regulated by a variety of state and local laws, ordinances, and policies, and the RHNA requires the City to provide for the development of a specified number of housing units ; the City’s housing production allocation for the current cycle calls for 2,234 new affordable housing units as follows: 652 units are needed for moderate-income households, 615 units are needed for low -income households and 967 units are needed for very low- and extremely low-income households; and
WHEREAS, the City desires to explore and, to the extent feasible, use all available tools to meet its assigned regional housing production target; and WHEREAS, state law requires each city to develop a general plan establishing policies for future development. As specified in the Government Code, the general plan must, among other objectives: (i) encourage the development of a variety of housing types for all income levels ; and (ii) assist in the development of adequate housing to meet the needs of low and moderate -income households; and
WHEREAS, according to City Council Resolution No. 5473, the provision in Measure “U” requiring preparation of a socio-economic cost/benefit study does not apply to City-initiated Redlands Regular Meeting of 06-03-25
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general plan, specific plan or zoning amendments that are not associated with a specific development project; and
WHEREAS, in accordance with the California Environmental Quality Act (“CEQA”), a Draft Subsequent Environmental Impact Report ( “Draft SEIR”) for the Project was published on January 21, 2025, and circulated for a 45 -day public review and comment period beginning on January 22, 2025, and ending on March 7, 2025; and
WHEREAS, a Final Subsequent Environmental Impact Report ( “Final SEIR ”) was published on April 9, 2025, including a response to comments received on the Draft SEIR; and WHEREAS on April 2, 2025, notice of the Planning Commission’s public hearing for the Project was caused to be published by a display ad in a newspaper of general circulation by the Secretary to the Planning Commission; and
WHEREAS, on April 22, 2025, the Planning Commission held a noticed public hearing on the Project and considered the staff written and oral reports, written public comments, and testimony from members of the public; and
WHEREAS, on April 22, 2025, the Planning Commission recommended that the City Council approves the Project; and
WHEREAS, on May 13, 2025, notice of the City Council’s public hearing for the Project was published in a newspaper of general circulation by the City Clerk; and WHEREAS, on June 3, 2025, the City Council held a public hearing and considered the staff written and oral reports, the recommendation of the Planning Commission, written public comments, and testimony by members of the public; and
WHEREAS, following the public hearing on the proposed General Plan amendment and the Project, the City Council determined that adoption of the amendment is in the best interests of the public health, safety and general welfare.
NOW, THEREFORE, RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS THAT:
Section 1. General Plan Consistency and Validity. General Plan Amendment No. 149 is necessary to make the 2035 General Plan internally consistent and compatible by integrating its land use and housing policies which identify and mandate specific parcels of land to be rezoned for medium- and high-density residential use. The proposed amendment is consistent with several 2035 General Plan policies and programs, and the amendment would not otherwise result in inconsistencies with the 2035 General Plan.
Section 2. California Environmental Quality Act. As adopted and certified by City Council Resolution No. 8687, the Final SEIR prepared for the Project has been prepared in compliance with CEQA in accordance with the applicable sections under Articles 7, 8, 9 and 10 of the CEQA Guidelines.
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Section 3. Adoption of Amendment. Amendment to the Land Use Map (Figure 4-1) included in the adopted 2035 General Plan is necessary to accommodate the rezoning actions required by Program 1.1-1 (RHNA Rezoning) as listed in the City’s certified 2021-2029 Housing Element. General Plan Amendment No. 149 is hereby adopted, as described below and as shown in Exhibit “A” attached hereto, and, with regard to Sites 1, 2, 3, 6, 7, 8, 13, 14, 15, 16, 18, 19 and 21, based on the following findings in accordance with Measure U Policy 4.40s.
1. There are substantial and overriding economic or social benefits to the City and its residents and taxpayers from the proposed density increase.
There are substantial and overriding economic or social benefits to the City and its residents and taxpayers from the proposed density increase because the increased residential density would help meet housing demand, improve housing affordability and generate property tax revenue, all of which support economic resilience and social well- being.
2. The proposed density increase will not cause adverse environmental impacts, either individually or cumulatively, directly or indirectly.
The proposed density increase would not cause adverse environmental impacts, either individually or cumulatively, directly or indirectly, that were not previously accounted for as part of the certified Environmental Impact Report prepared for the 2035 General Plan.
Implementation of the General Plan as amended would continue to cause potentially significant adverse environmental impacts on agricultural resources, air quality, greenhouse gas emissions, and transportation impacts within the planning area. However, because the project sites are located within already infill areas, where development can take advantage of existing infrastructure, the redesignation would reduce the need for new construction in undeveloped areas and avoid the loss of open space and resource lands. While the redesignation may allow the future conversion of existing farmland resources to residential development, the land is presently designated for urban use, including commercial and residential. The conversion of this land to medium- and high- density residential use would not result in substantially worse direct environmental impacts beyond the types of urban development that are consistent with the current land use classifications designated by the general plan.
3. The proposed density increase will not convert viable agricultural land to non- agricultural uses.
The proposed density increase would not convert viable agricultural land to non- agricultural uses because, although some of the sites are currently being used for farming, the sites are presently designated and zoned for commercial and residential uses and are planned for urban development. Redesignation of the sites to residential use does not change the status of the site as designated for urban uses and, therefore, this finding does not apply.
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4. The proposed density increase will not have a growth-inducing effect on other property.
The proposed density increase would not have a growth-inducing effect on other property because it is limited to specific in-fill sites, thereby containing growth within existing developed areas and reducing pressure to develop surrounding or undeveloped areas.
5. The resulting uses will be compatible with uses on adjacent land.
The future resulting residential uses will be compatible with uses on adjacent land because the proposed residential parcels are located in an urbanized area that already includes a mix of uses, including residential, commercial and industrial. Buffer zones, development standards, and appropriate land use planning will ensure that future residential uses can coexist with nearby uses without conflict. No existing or reasonably foreseeable inharmonious uses are located in the vicinity of the subject parcels.
6. The proposed density increase will not require substantial expansion of public infrastructure, facilities or services.
The proposed density increase would not require substantial expansion of public infrastructure, facilities or services because the sites are already zoned for commercial and residential uses within largely developed in-fill areas which are served by and are readily accessible to infrastructure and services. Infill development on the project site would avoid the pressure to develop new housing in outer areas, which would necessitate higher expenditure for capital improvements. The cost of serving new development with public services, including police and fire, would be offset by the payment of development impact fees.
General Plan Amendment No. 149
Change the land use designations of the following twenty-two (22) parcels:
APN Existing Designation Proposed Designation
0292-163-02-0000 Commercial/Industrial Medium Density Residential 0292-163-03-0000 Commercial/Industrial Medium Density Residential 0292-165-05-0000 Commercial/Industrial High Density Residential 0292-165-06-0000 Commercial/Industrial High Density Residential 0292-165-07-0000 Commercial/Industrial High Density Residential 0292-165-08-0000 Commercial/Industrial High Density Residential 0292-165-09-0000 Commercial/Industrial High Density Residential 0292-165-16-0000 Commercial/Industrial High Density Residential 0292-165-17-0000 Commercial/Industrial High Density Residential 0292-165-04-0000 Commercial/Industrial High Density Residential 0292-167-02-0000 Commercial/Industrial Medium Density Residential 0292-167-07-0000 Commercial/Industrial Medium Density Residential 0292-167-28-0000 Commercial/Industrial High Density Residential 0292-167-29-0000 Commercial/Industrial High Density Residential 0292-167-30-0000 Commercial/Industrial High Density Residential Redlands Regular Meeting of 06-03-25
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0292-167-17-0000 Commercial/Industrial High Density Residential 0292-201-20-0000 Commercial/Industrial Medium Density Residential 0292-201-14-0000 Commercial/Industrial Medium Density Residential 0167-141-04-0000 Commercial Medium Density Residential 0167-141-05-0000 Commercial Medium Density High Density Residential 0167-141-06-0000 Commercial Medium Density High Density Residential 0292-165-15-0000* Commercial/Industrial Public/Institutional *area north of Morrey Arroyo only
Section 4. Effective Date. This Resolution shall take effect upon adoption.
ADOPTED, SIGNED AND APPROVED this 3rd day of June, 2025
Mario Saucedo, Mayor
ATTEST:
______________________________
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 06-03-25
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I, Jeanne Donaldson, City Clerk of the City of Redlands, hereby certify that the foregoing ordinance was duly adopted by the City Council at a regular meeting thereof held on the 3rd day of June, 2025.
AYES:
NOES:
ABSTAIN:
ABSENT:
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 06-03-25
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GENERAL PLAN AMENDMENT No. 149 – EXHIBIT A-1.1
GENERAL PLAN FIGURE 4-1, EXISTING LAND USE MAP (EAST)
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GENERAL PLAN AMENDMENT No. 149 – EXHIBIT A-1.2
GENERAL PLAN FIGURE 4-1, EXISTING LAND USE MAP (WEST)
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GENERAL PLAN AMENDMENT No. 149 – EXHIBIT A-2.1
GENERAL PLAN FIGURE 4-1, PROPOSED LAND USE MAP (EAST)
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GENERAL PLAN AMENDMENT No. 149 – EXHIBIT A-2.2
GENERAL PLAN FIGURE 4-1, PROPOSED LAND USE MAP (WEST)
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1 I:\cmo\Resolutions\8689 Amending CP No. 4.docx-ms
RESOLUTION NO. 8689
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
REDLANDS AMENDING CONCEPT PLAN NO. 4 (THE CITIES
PA VILLION CONCEPT PLAN).
WHEREAS, the City of Redlands (“City”) has initiated General Plan Amendment No. 149, Amendment No. 1 to Concept Plan No. 4, Amendment No. 54 to Specific Plan No. 40 (East Valley Corridor Specific Plan) , and Zone Change No. 479 , to amend the General Plan and Specific Plan land use maps and the City Zoning Map to rezone twenty- seven (27) parcels for the regional housing needs allocation (“RHNA”) rezoning project (collectively herein referred to as “Project”) as required by the City’s certified 2021–2029 Housing Element (“Housing Element”); and
WHEREAS, the Planning Division conducted an extensive public outreach effort during preparation of the Housing Element and, furthermore, the Project actions are identified in the Housing Element work program, particularly Program 1.1 -1 entitled, “RHNA Rezoning”; and
WHEREAS, the City and the Southern California region faces a serious housing shortage, and a lack of access to housing directly affects the health, safety and welfare of City residents; and
WHEREAS, the state legislature has consistently recognized the continuing need for affordable housing in California and, in Government Code section 65580, states, "the availability of housing is of vital statewide importance, and the early attainment of decent housing… is a priority of the highest order" and, further, that, "local… governments have a responsibility to use the powers vested in them to facilitate the improvement and development of housing to make adequate provision for the housing needs of all economic segments of the community"; and
WHEREAS, affordable housing is regulated by a variety of state and local laws, ordinances, and policies, and the RHNA requires the City to provide for the development of a specified number of housing units ; the City’s housing production allocation for the current cycle calls for 2,234 new affordable housing units as follows: 652 units are needed for moderate-income households, 615 units are needed for low-income households and 967 units are needed for very low- and extremely low-income households; and WHEREAS, the City desires to explore and, to the extent feasible, use all available tools to meet its assigned regional housing production target; and WHEREAS, state law requires each city to develop a general plan establishing policies for future development. As specified in the Government Code, the general plan must, among other objectives: (i) encourage the development of a variety of housing types for all income levels ; and (ii) assist in the development of adequate housing to meet the needs of low and moderate-income households; and
Redlands Regular Meeting of 06-03-25
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WHEREAS, according to City Council Resolution No. 5473, the provision in Measure “U” requiring preparation of a socio-economic cost/benefit study does not apply to City-initiated general plan, specific plan or zoning amendments that are not associated with a specific development project; and
WHEREAS, in accordance with the California Environmental Quality Act (“CEQA”), a Draft Subsequent Environmental Impact Report ( “Draft SEIR ”) for the Project was published on January 21, 2025, and circulated for a 45 -day public review and comment period beginning on January 22, 2025, and ending on March 7, 2025; and WHEREAS, a Final Subsequent Environmental Impact Report (“Final SEIR”) was published on April 9, 2025, including a response to comments received on the Draft SEIR; and
WHEREAS on April 2, 2025, notice of the Planning Commission’s public hearing for the Project was caused to be published by a display ad in a newspaper of general circulation by the Secretary to the Planning Commission; and WHEREAS, on April 22, 2025, the Planning Commission held a noticed public hearing on the Project and considered the staff written and oral reports, written public comments, and testimony from members of the public; and WHEREAS, on April 22, 2025, the Planning Commission recommended that the City Council approves the Project; and
WHEREAS, on May 13, 2025, notice of the City Council’s public hearing for the Project was published in a newspaper of general circulation by the City Clerk; and WHEREAS, on June 3, 2025, the City Council held a public hearing and considered the staff written and oral reports, the recommendation of the Planning Commission, written public comments, and testimony by members of the public; and WHEREAS, following the public hearing on the proposed Concept Plan No. 4 amendment and the Project, the City Council determined that adoption of the amendment is in the best interests of the public health, safety and general welfare.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS THAT:
Section 1. California Environmental Quality Act. As adopted and certified by City Council Resolution No. 8687, the Final SEIR prepared for the Project has been prepared in compliance with CEQA in accordance with the applicable sections under Articles 7, 8, 9 and 10 of the CEQA Guidelines.
Section 2. Amendment to Concept Plan. Concept Plan No. 4 is hereby amended to remove three (3) parcels, APNs: 0167-141-04-0000, 0167-141-05-0000, and 0167-141- 06-0000, from the concept plan boundaries as shown in Exhibit “A” attached hereto.
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Section 3. Effective Date. This Resolution shall take effect upon adoption.
ADOPTED, SIGNED AND APPROVED this 3rd day of June, 2025
Mario Saucedo, Mayor
ATTEST:
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 06-03-25
1038 of 1245
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I, Jeanne Donaldson, City Clerk of the City of Redlands, hereby certify that the foregoing resolution was duly adopted by the City Council at a regular meeting thereof held on the 3rd day of June, 2025.
AYES:
NOES:
ABSTAIN:
ABSENT:
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 06-03-25
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CONCEPT PLAN 4, AMENDMENT No. 1 – EXHIBIT A
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1 I:\cmo\Resolutions\8690 Amending Specific Plan No. 40.docx-ms RESOLUTION NO. 8690
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
REDLANDS AMENDING SPECIFIC PLAN NO. 40 (EAST V ALLEY
CORRIDOR SPECIFIC PLAN)
WHEREAS, the City of Redlands (“City”) has initiated General Plan Amendment No. 149, Amendment No. 1 to Concept Plan No. 4, Amendment No. 54 to Specific Plan No. 40 (East Valley Corridor Specific Plan), and Zone Change No. 479, to amend the General Plan and Specific Plan land use maps and the City Zoning Map to rezone twenty- seven (27) parcels for the regional housing needs allocation (“RHNA”) rezoning project (collectively herein referred to as “Project”) as required by the City’s certified 2021–2029 Housing Element (“Housing Element”); and
WHEREAS, the Planning Division conducted an extensive public outreach effort during preparation of the Housing Element and, furthermore, the Project actions are identified in the Housing Element work program, particularly Program 1.1-1 entitled, “RHNA Rezoning”; and
WHEREAS, the City and the Southern California region faces a serious housing shortage, and a lack of access to housing directly affects the health, safety and welfare of City residents; and
WHEREAS, the state legislature has consistently recognized the continuing need for affordable housing in California and, in Government Code section 65580, states, "the availability of housing is of vital statewide importance, and the early attainment of decent housing… is a priority of the highest order" and, further, that, "local… governments have a responsibility to use the powers vested in them to facilitate the improvement and development of housing to make adequate provision for the housing needs of all economic segments of the community"; and
WHEREAS, affordable housing is regulated by a variety of state and local laws, ordinances, and policies, and the RHNA requires the City to provide for the development of a specified number of housing units; the City’s housing production allocation for the current cycle calls for 2,234 new affordable housing units as follows: 652 units are needed for moderate-income households, 615 units are needed for low-income households and 967 units are needed for very low- and extremely low-income households; and
WHEREAS, the City desires to explore and, to the extent feasible, use all available tools to meet its assigned regional housing production target; and WHEREAS, state law requires each city to develop a general plan establishing policies for future development. As specified in the Government Code, the general plan must, among other objectives: (i) encourage the development of a variety of housing types for all income levels; and (ii) assist in the development of adequate housing to meet the needs of low and moderate-income households; and
Redlands Regular Meeting of 06-03-25
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2 I:\cmo\Resolutions\8690 Amending Specific Plan No. 40.docx-ms WHEREAS, according to City Council Resolution No. 5473, the provision in Measure “U” requiring preparation of a socio-economic cost/benefit study does not apply to City-initiated general plan, specific plan or zoning amendments that are not associated with a specific development project; and
WHEREAS, in accordance with the California Environmental Quality Act (“CEQA”), a Draft Subsequent Environmental Impact Report (“Draft SEIR”) for the Project was published on January 21, 2025, and circulated for a 45-day public review and comment period beginning on January 22, 2025, and ending on March 7, 2025; and WHEREAS, a Final Subsequent Environmental Impact Report (“Final SEIR”) was published on April 9, 2025, including a response to comments received on the Draft SEIR; and
WHEREAS on April 2, 2025, notice of the Planning Commission’s public hearing for the Project was caused to be published by a display ad in a newspaper of general circulation by the Secretary to the Planning Commission; and WHEREAS, on April 22, 2025, the Planning Commission held a noticed public hearing on the Project and considered the staff written and oral reports, written public comments, and testimony from members of the public; and WHEREAS, on April 22, 2025, the Planning Commission recommended that the City Council approves the Project; and
WHEREAS, on May 13, 2025, notice of the City Council’s public hearing for the Project was published in a newspaper of general circulation by the City Clerk; and WHEREAS, on June 3, 2025, the City Council held a public hearing and considered the staff written and oral reports, the recommendation of the Planning Commission, written public comments, and testimony by members of the public; and WHEREAS, following the public hearing on the proposed Specific Plan No. 40 amendment and the Project, the City Council determined that adoption of the amendment is in the best interests of the public health, safety and general welfare.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS THAT:
Section 1. California Environmental Quality Act. As adopted and certified by City Council Resolution No. 8687, the Final SEIR prepared for the Project has been prepared in compliance with CEQA in accordance with the applicable sections under Articles 7, 8, 9 and 10 of the CEQA Guidelines.
Section 2. Amendment to Specific Plan. Amendment No. 54 to Specific Plan No. 40 (East Valley Corridor Specific Plan) is hereby adopted, as described below and as shown in Exhibits “A” and “B” attached hereto.
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3 I:\cmo\Resolutions\8690 Amending Specific Plan No. 40.docx-ms Specific Plan No. 40 Amendment No. 54
Remove the following twenty-one (21) parcels from the specific plan boundaries as shown in Exhibit “A”.
APNs:
0292-163-02-0000 0292-163-03-0000 0292-165-05-0000
0292-165-06-0000 0292-165-07-0000 0292-165-08-0000
0292-165-09-0000 0292-165-16-0000 0292-165-17-0000
0292-165-04-0000 0292-167-02-0000 0292-167-07-0000
0292-167-28-0000 0292-167-29-0000 0292-167-30-0000
0292-167-17-0000 0292-201-20-0000 0292-201-14-0000
0167-141-04-0000 0167-141-05-0000 0167-141-06-0000
Change the specific plan district designations of the following two (2) parcels as shown in Exhibit “B”:
APN Existing Designation Proposed Designation
0292-165-10-0000 EV/3000RM EV/2500RM
0292-165-15-0000* EV/IC EV/PI
*area north of Morrey Arroyo only
Section 3. Effective Date. This resolution shall take effect upon adoption.
ADOPTED, SIGNED AND APPROVED this 3rd day of June, 2025.
Mario Saucedo, Mayor
ATTEST:
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 06-03-25
1043 of 1245
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I, Jeanne Donaldson, City Clerk of the City of Redlands, hereby certify that the foregoing resolution was duly adopted by the City Council at a regular meeting thereof held on the 3rd day of June, 2025.
AYES:
NOES:
ABSTAIN:
ABSENT:
Jeanne Donaldson, City Clerk
Redlands Regular Meeting of 06-03-25
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5 I:\cmo\Resolutions\8690 Amending Specific Plan No. 40.docx-ms AMENDMENT No. 54 to SPECIFIC PLAN 40 – EXHIBIT A
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6 I:\cmo\Resolutions\8690 Amending Specific Plan No. 40.docx-ms AMENDMENT No. 54 to SPECIFIC PLAN 40 – EXHIBIT B-1
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1 I:\cmo\Ordinances\2983 Adopting Revised Land Use Zoning Map.docx-ms ORDINANCE NO. 2983
AN ORDINANCE OF THE CITY OF REDLANDS AMENDING TITLE
18 OF THE REDLANDS MUNICIPAL CODE BY ADOPTING A
REVISED LAND USE ZONING MAP IN ACCORDANCE WITH
PROGRAM 1.1-1 (‘RHNA REZONING’) OF THE SIXTH CYCLE 2021– 2029 HOUSING ELEMENT
WHEREAS, the City of Redlands (“City”) has initiated General Plan Amendment No. 149, Amendment No. 1 to Concept Plan No. 4, Amendment No. 54 to Specific Plan No. 40 (East Valley Corridor Specific Plan) , and Zone Change No. 479 , to amend the General Plan and Specific Plan land use maps and the City Zoning Map to rezone twenty- seven (27) parcels for the regional housing needs allocation (“RHNA”) rezoning project (collectively herein referred to as “Project”) as required by the City’s certified 2021–2029 Housing Element (“Housing Element”); and
WHEREAS, the Planning Division conducted an extensive public outreach effort during preparation of the Housing Element and, furthermore, the Project actions are identified in the Housing Element work program, particularly Program 1.1 -1 entitled, “RHNA Rezoning”; and
WHEREAS, the City and the Southern California region faces a serious housing shortage, and a lack of access to housing directly affects the health, safety and welfare of City residents; and
WHEREAS, the state legislature has consistently recognized the continuing need for affordable housing in California and, in Government Code section 65580, states, "the availability of housing is of vital statewide importance, and the early attainment of decent housing… is a priority of the highest order" and, further, that, "local… governments have a responsibility to use the powers vested in them to facilitate the improvement and development of housing to make adequate provision for the housing needs of all economic segments of the community"; and
WHEREAS, affordable housing is regulated by a variety of state and local laws, ordinances, and policies, and the RHNA requires the City to provide for the development of a specified number of housing units ; the City’s housing production allocation for the current cycle calls for 2,234 new affordable housing units as follows: 652 units are needed for moderate-income households, 615 units are needed for low-income households and 967 units are needed for very low- and extremely low-income households; and WHEREAS, the City desires to explore and, to the extent feasible, use all available tools to meet its assigned regional housing production target; and WHEREAS, state law requires each city to develop a general plan establishing policies for future development. As specified in the Government Code, the general plan Redlands Regular Meeting of 06-03-25
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2 I:\cmo\Ordinances\2983 Adopting Revised Land Use Zoning Map.docx-ms must, among other objectives: (i) encourage the development of a variety of housing types for all income levels; and (ii) assist in the development of adequate housing to meet the needs of low and moderate-income households; and
WHEREAS, according to City Council Resolution No. 5473, the provision in Measure “U” requiring preparation of a socio-economic cost/benefit study does not apply to City-initiated general plan, specific plan or zoning amendments that are not associated with a specific development project; and
WHEREAS, in accordance with the California Environmental Quality Act (“CEQA”), a Draft Subsequent Environmental Impact Report ( “Draft SEIR ”) for the Project was published on January 21, 2025, and circulated for a 45 -day public review and comment period beginning on January 22, 2025, and ending on March 7, 2025; and WHEREAS, a Final Subsequent Environmental Impact Report (“Final SEIR”) was published on April 9, 2025, including a response to comments received on the Draft SEIR; and
WHEREAS on April 2, 2025, notice of the Planning Commission’s public hearing for the Project was caused to be published by a display ad in a newspaper of general circulation by the Secretary to the Planning Commission; and WHEREAS, on April 22, 2025, the Planning Commission held a noticed public hearing on the Project and considered the staff written and oral reports, written public comments, and testimony from members of the public; and WHEREAS, on April 22, 2025, the Planning Commission recommended that the City Council approves the Project; and
WHEREAS, on May 13, 2025, notice of the City Council’s public hearing for the Project was published in a newspaper of general circulation by the City Clerk; and WHEREAS, on June 3, 2025, the City Council held a public hearing and considered the staff written and oral reports, the recommendation of the Planning Commission, written public comments, and testimony by members of the public; and WHEREAS, on June 3, 2025, the City Council adopted Resolution No. 8687 adopting Findings of Fact, a Statement of Overriding Considerations and a Mitigation Monitoring and Reporting Program, and certifying the Final SEIR prepared for the Project; and
WHEREAS, following the public hearing on the proposed General Plan amendment and the Project, the City Council determined that adoption of the amendment is in the best interests of the public health, safety and general welfare.
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NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF REDLANDS ORDAINS AS FOLLOWS:
Section 1. The zoning district boundaries on the City’s Zoning Map are hereby amended for the properties listed below and shown in Exhibit “A.” Ref.
No.
Assessor’ s Parcel Number
(A.P .N.)
Zoning Designation
(New)
1 0292-163-02-0000 R-2, Multiple Family Residential
2 0292-163-03-0000 R-2, Multiple Family Residential
3 0292-165-05-0000 R-3, Multiple Family Residential
4 0292-165-06-0000 R-3, Multiple Family Residential
5 0292-165-07-0000 R-3, Multiple Family Residential
6 0292-165-08-0000 R-3, Multiple Family Residential
7 0292-165-09-0000 R-3, Multiple Family Residential
8 0292-165-10-0000 EV/2500RM (in SP No. 40)
9 0292-165-16-0000 R-3, Multiple Family Residential
10 0292-165-17-0000 R-3, Multiple Family Residential
10A 0292-165-04-0000 R-3, Multiple Family Residential
11 0292-167-02-0000 R-2, Multiple Family Residential
12 0292-167-07-0000 R-2, Multiple Family Residential
13 0292-167-28-0000 R-3, Multiple Family Residential
14 0292-167-29-0000 R-3, Multiple Family Residential
15 0292-167-30-0000 R-3, Multiple Family Residential
15A 0292-167-17-0000 R-3, Multiple Family Residential
16 0292-201-20-0000 R-2, Multiple Family Residential
16A 0292-201-14-0000 R-2, Multiple Family Residential
17 0167-141-04-0000 R-2, Multiple Family Residential
18 0167-141-05-0000 R-3, Multiple Family Residential
19 0167-141-06-0000 R-3, Multiple Family Residential
20 0169-021-02-0000 R-2, Multiple Family Residential
21 0169-021-11-0000 R-2, Multiple Family Residential
22 0167-151-23-0000 R-3, Multiple Family Residential
23 0167-161-10-0000 R-3, Multiple Family Residential
24 0292-165-15-0000
*area north of Morrey Arroyo only
EV/PI (in SP No. 40)
Section 2. The Mayor shall sign this ordinance and the City Clerk shall certify to the adoption of this ordinance and shall cause it, or a summary of it, to be published once in the Redlands Daily Facts, a newspaper of general circulation within the City, and thereafter, this ordinance shall take effect in accordance with law.
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Mario Saucedo, Mayor
ATTEST:
Jeanne Donaldson, City Clerk
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I, Jeanne Donaldson, City Clerk of the City of Redlands, hereby certify that the foregoing ordinance was duly introduced by the City Council at a regular meeting thereof held on the 3rd day of June, 2025.
AYES:
NOES:
ABSTAIN:
ABSENT:
Jeanne Donaldson, City Clerk
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6 I:\cmo\Ordinances\2983 Adopting Revised Land Use Zoning Map.docx-ms ZONE CHANGE NO. 479 – EXHIBIT A-1.1
EXISTING ZONING MAP (WEST)
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7 I:\cmo\Ordinances\2983 Adopting Revised Land Use Zoning Map.docx-ms ZONE CHANGE NO. 479 – EXHIBIT A-1.2
EXISTING ZONING MAP (EAST)
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8 I:\cmo\Ordinances\2983 Adopting Revised Land Use Zoning Map.docx-ms ZONE CHANGE NO. 479 – EXHIBIT A-2.1
PROPOSED ZONING MAP (WEST)
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9 I:\cmo\Ordinances\2983 Adopting Revised Land Use Zoning Map.docx-ms ZONE CHANGE NO. 479 – EXHIBIT A-2.2
PROPOSED ZONING MAP (EAST)
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City Council Meeting K. 2.
DATE: 06/03/2025
TO: Honorable Mayor and City Council Members
SUBJECT: Public Hearing to consider Resolution No. 8685 - Approving the Issuance of the California Municipal Finance Authority Revenue Bonds, Series 2025 (HumanGood)
(Mayor to declare meeting open as a public hearing)
(Management Services/Finance Director Garcia)
PROCEDURE FOR PUBLIC HEARING:
Mayor to declare TEFRA (Tax Equity and Fiscal Responsibility Act) Hearing open as a public hearing and calls upon Department Head for report.
1. Mayor calls for questions/comments from members of the City Council.2.
Mayor calls for comments/questions/testimony from members of the public (3 minutes per speaker).
3. Mayor calls upon City Clerk to note any written comments received.4.
Mayor closes the public hearing.5.
City Council considers the motion and votes.6.
MOTION(S):
I move to adopt Resolution No. 8685.
RECOMMENDATION:
Not Applicable.
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DISCUSSION:
The HumanGood affiliated group of companies (the "Borrower") owns and operates various continuing care communities throughout the region. As such, they have requested that the California Municipal Finance Authority (“CMFA”) serve as the municipal issuer of an aggregate principal amount of tax-exempt revenue bonds not to exceed $205,000,000 (the "Bonds"). The proceeds of the Bonds will be used to finance expenditures for various renovations to existing infrastructure and upgrades to housing units and amenities at continuing care communities throughout the state of California owned and operated by HumanGood ("the Project"), one of which is located in the City of Redlands: Plymouth Village, 900 Salem Drive, Redlands, California, 92373. This is the same property site as was included in the California Municipal Finance Authority Revenue Bonds, Series 2019 and Series 2021 (HumanGood).
In order for all or a portion of the Bonds to qualify as tax-exempt bonds, the City of Redlands must conduct a public hearing (the “TEFRA Hearing”) providing members of the community with an opportunity to speak in favor of or against the use of tax-exempt bonds for the financing of the Project. Prior to such TEFRA Hearing, reasonable notice must be provided to the members of the community. The City shall publish a notice of this public hearing at least seven (7) days prior to the hearing. Notice of this hearing was published on May 23, 2025. Following the close of the TEFRA Hearing, an “applicable elected representative” of the governmental unit hosting the Project must provide its approval of the issuance of the Bonds for the financing of the Project.
The CMFA was created on January 1, 2004 pursuant to a joint exercise of powers agreement (JPA). It was formed to assist local governments, non-profit organizations and businesses with the issuance of taxable and tax-exempt bonds aimed financing economic development and charitable activities. The City signed onto this JPA in 2019.
The Joint Exercise of Powers Agreement provides that the CMFA is a public entity, separate and apart from each member executing such agreement. The debts, liabilities and obligations of the CMFA do not constitute debts, liabilities or obligations of the members - in this case, the City.
The Bonds to be issued by the CMFA for the Project will be the sole responsibility of the Borrower, and the City will have no financial, legal, moral obligation, liability or responsibility for the Project or the repayment of the Bonds for the financing of the Project. All financing documents with respect to the issuance of the Bonds will contain clear disclaimers that the Bonds are not obligations of the City or the State of California but are to be paid for solely from funds provided by the Borrower.
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Outside of holding the TEFRA hearing, no other participation or activity of the City or the City Council with respect to the issuance of the Bonds will be required.
In order to satisfy the requirements of the Agreement and of the Internal Revenue Code, the City must (1) hold a public hearing and (2) adopt the TEFRA Resolution approving the financing to be undertaken through CMFA.
Each financing completed by CMFA is structured so the local agency completing the TEFRA hearing process has no liability with respect to the issuance of bonds or the repayment of any debt service relating to such bonds. In addition, the local agency completing the TEFRA hearing process is not a party to any of the financing documents relating to the issuance of the bonds nor is it named in any of the disclosure documents describing the bonds or the proposed financing.
ALTERNATIVES:
The City Council may elect to deny its approval for the issuance of tax-exempt bonds by the California Municipal Finance Authority (CMFA).
STRATEGIC PLAN:
Not Applicable
SUBMITTED BY:
Danielle Garcia, Management Services /Finance Director
RECOMMENDED BY:
Charles M. Duggan, Jr., City Manager
REVIEWED BY:
Yvette M. Abich Garcia, City Attorney
Janice McConnell, Assistant City Manager
Fiscal Impact
Discussion:
No expenditure of financial or staff resources is anticipated as a result of approving Resolution No. 8258. Further, as a matter of policy, the CMFA will grant a portion of the issuance fees that it assesses HumanGood to the City's general fund. This amount is estimated to be $2,000. This will offset the staff time involved for this hearing and cover the costs of the public hearing notice.
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Attachments
Joint Powers Authority - Agmt. with CMFA dated July 22, 2019 HumanGood 2025 - TEFRA Resolution No. 8685
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JOINT EXERCISE OF POWERS AGREEMENT
RELATING TO THE CALIFORNIA MUNICIPAL FINANCE AUTHORITY
THISAGREEMENT, datedasof January1, 2004, amongthe partiesexecutingthis Agreement (all suchparties, exceptthosewhichhavewithdrawnasprovidedherein, arereferred to asthe "Members" andthosepartiesinitially executingthis Agreementarereferredto asthe Initial Members"):
WITNESSETH
WHEREAS, pursuantto Title 1, Division 7, Chapter 5 of the California Government Code (in effect as of the datehereof andas the samemay from time to time be amendedor supplemented, the " Joint Exercise of Powers Act"), two or more public agencies may by agreementjointly exerciseanypowercommonto thecontractingparties; and WHEREAS, eachof theMembersis a "public agency" asthattermis definedin Section 6500 of the Joint Exercise of Powers Act; and
WHEREAS, eachof theMembersis empoweredby lawto promoteeconomic, cultural andcommunitydevelopment, including, withoutlimitation, thepromotionof opportunitiesfor thecreationor retentionof employment, thestimulationof economicactivity, the increaseof the taxbase, andthepromotionof opportunitiesfor education, culturalimprovementandpublic health, safety and generalwelfare; and
WHEREAS, eachof theMembersmayaccomplishthepurposesandobjectivesdescribed in the preceding preamble by various means, including through making grants, loans or providing otherfinancial assistanceto governmentaland nonprofit organizations; and WHEREAS, each Member is also empoweredby law to acquire and dispose of real propertyfor apublic purpose; and
WHEREAS, theJointExerciseof PowersAct authorizestheMembersto createajoint exerciseof powersentitywith theauthorityto exerciseanypowerscommonto theMembers, as specifiedin this Agreementand to exercisethe additionalpowersgrantedto it in the Joint Exerciseof PowersAct andanyotherapplicableprovisionsof thelawsof the Stateof California; and
WHEREAS, a publicentityestablishedpursuantto the JointExerciseof PowersAct is empoweredto issueor execute bonds, notes, commercialpaperor any otherevidencesof indebtedness, includingleasesor installmentsaleagreementsor certificatesof participation therein ( herein " Bonds"), and to otherwiseundertakefinancing programsunder the Joint Exerciseof PowersAct or other applicableprovisionsof the laws of the Stateof California to accomplish its public purposes; and
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WHEREAS, theMembershavedeterminedto specificallyauthorizea publicentity authorizedpursuant totheJointExerciseof PowersAct to issueBonds pursuantto theJoint Exerciseof PowersAct or otherapplicableprovisionsof the lawsof the Stateof California; and WHEREAS, it isthe desireoftheMembers touseapublicentityestablished pursuantto theJointExerciseofPowersActtoundertakethefinancingand/orrefinancingofprojectsof any nature, including, butnotlimitedto, capital orworkingcapitalprojects, insurance, liabilityor retirementprogramsor facilitating Membersuse of existing or new financial instrumentsand mechanisms; and
WHEREAS, it is furtherthe intentionof the Membersthat theprojects undertakenwill resultin significantpublicbenefitstothe inhabitantsof thejurisdictionsof theMembers; and WHEREAS, by this Agreement, each Member desires to create and establish the CaliforniaMunicipalFinanceAuthority" for thepurposessetforth hereinand toexercisethe powers provided herein;
NOW, THEREFORE, theMembers, for andin considerationof themutualpromisesand agreements herein, contained, do agree as follows:
Section 1. Purpose.
This Agreementis madepursuantto the provisionsof the Joint Exerciseof PowersAct.
Thepurposeof thisAgreementis to establishapublicentityfor thejoint exerciseof powers commonto theMembersandfor theexerciseof additionalpowersgivento ajoint powersentity underthe Joint PowersAct or any other applicablelaw, including, butnot limited to, the issuanceof Bondsfor any purposeor activity permittedunderthe JointExerciseof PowersAct orany otherapplicablelaw. Suchpurposewill beaccomplishedandsaidpowerexercised in the manner hereinafter set forth.
Section 2. Term.
This Agreement shall become effective in accordancewith Section 17 as of the date hereofandshallcontinuein full forceandeffectuntilsuchtimeasit isterminatedinwritingby all the Members; provided, however, that this Agreementshallnot terminateor be terminated until all Bondsissuedor causedto be issuedby theAuthority (definedbelow) shall nolongerbe outstandingunderthe termsof the indenture, trustagreementor otherinstrumentpursuantto which such Bonds are issued, or unlessa successorto the Authority assumesall of the Authority' s debts, liabilities andobligastions.
Section 3. Authority.
A. CREATION AND POWERS OF AUTHORITY.
Pursuantto theJointExerciseof PowersAct, thereis herebycreateda public entity to be known as the " California Municipal Finance Authority" ( the " Authority"), and said Authority shall be a public entity separate and apart from the Members. Its Redlands Regular Meeting of 06-03-25
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debts, liabilitiesandobligationsdonotconstitutedebts, liabilitiesorobligationsof any Members.
The Authority shall be administered by the Board of Directors ( the " Board," or the " Directors" and each a " Director") of the California Foundation for Stronger Communities, a nonprofit public benefit corporationorganized underthe laws of the State of California ( the " Foundation"), with eachsuch Director serving in his or her individual capacity as a Director of the Board. TheBoardshallbe the administering agencyof thisAgreementand, assuch, shallbevestedwith thepowerssetforthherein, and shall administerthis Agreementin accordancewith the purposesandfunctions provided herein. The number of Directors, the appointment of Directors, alternates and successors, their respectivetermsof office, and all otherprovisions relatingto the qualificationandoffice of the Directorsshallbe asprovidedin the ArticlesandBylaws of the Foundation, orby resolutionof the Boardadoptedin accordancewith theBylaws of the Foundation.
All referencesin this Agreementto any Director shallbe deemedto refer to and includetheapplicablealternateDirector, if any, whensoactingin placeof a regularly appointed Director.
Directorsmayreceivereasonablecompensationfor servingassuch, andshallbe entitledtoreimbursementforanyexpensesactuallyincurredin connectionwithserving as a Director, if the Board shall determinethat such expensesshall be reimbursedand thereareunencumberedfundsavailablefor suchpurpose.
TheFoundation maybe removedasadministeringagenthereunderandreplaced at any time by amendmentof this Agreementapprovedas providedin Section16; providedthat a successoradministeringagentof this Agreementhasbeenappointedand accepted its duties and responsibilities under this Agreement.
C. OFFICERS; DUTIES; OFFICIAL BONDS.
Theofficersof the Authorityshallbe the Chair, Vice -Chair, Secretaryand Treasurer ( defined below). The Board, in its capacityas administeringagentof this Agreement, shallelecta Chair, a Vice -Chair, anda Secretaryof theAuthorityfrom among Directors to serveuntil such officer is re-electedor a successorto such office is electedby the Board. The Board shall appointoneor moreof its officers or employeesto serve as treasurer, auditor, and controller of the Authority ( the " Treasurer") pursuant to Section6505.6 of the Joint Exerciseof PowersAct to serveuntil suchofficer is re-elected or a successorto suchoffice is electedby the Board.
Subject totheapplicableprovisionsof anyresolution, indenture, trustagreement or otherinstrumentor proceedingauthorizingor securing Bonds (eachsuchresolution, indenture, trust agreement, instrumentandproceedingbeing herein referredto as an Indenture") providing for a trustee or other fiscal agent, and except as may otherwise be Redlands Regular Meeting of 06-03-25
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specifiedby resolutionof theBoard, theTreasureris designatedasthedepositaryof the Authority to havecustodyof all moneyof the Authority, from whateversourcederived andshallhavethe powers, dutiesandresponsibilitiesspecifiedin Sections6505, 6505.5 and 6509. 5 of the Joint Exercise of Powers Act.
TheTreasurerof theAuthorityis designatedasthepublicofficeror personwho haschargeof, handles, or hasaccessto anypropertyof theAuthority, andsuchofficer shallfile anofficialbondwiththeSecretaryof theAuthorityin theamountspecifiedby resolution of the Board but in no event less than $ 1,000.
TheBoardshallhavethepowerto appointsuchotherofficersand employeesasit may deemnecessaryandto retain independent counsel, consultantsand accountants.
TheBoardshallhavethepower, byresolution, to theextentpermittedby theJoint Exerciseof PowerAct or anyotherapplicablelaw, to delegateanyof its functionsto one ormoreof theDirectorsor officers, employeesor agentsof theAuthorityandto cause anyof saidDirectors, officers, employeesoragentsto takeanyactionsandexecuteany documents or instruments for and in the name and on behalf of the Board or the Authority.
D. MEETINGS OF THE BOARD.
1) Ralph M. Brown Act.
All meetingsof the Board, including, without limitation, regular, adjourned regular, special, and adjourned special meetings shall be called, noticed, held andconductedin accordancewith the provisionsof the Ralph M. Brown Act ( commencing with Section 54950 of the Government Code of the State of California), or any successor legislation hereinafter enacted (the " Brown Act").
2) RegularMeeting.
The Board shall provide for its regular meetings; provided, however, it shall hold at least one regular meeting each year. The date, hourandplaceof theholdingof theregularmeetingsshallbe fixedby resolution of the Board. To theextentpermittedby the Brown Act, such meetingsmay beheldby telephone conference.
3) SpecialMeetings.
Special meetingsof the Board maybe called in accordancewith the provisions of Section 54956 of the Government Code of the State of California. TotheextentpermittedbytheBrownAct, suchmeetingsmay be held by telephone conference.
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4) Minutes.
The Secretaryof the Authority shall causeto be kept minutesof the regular, adjourned regular, special, and adjourned special meetings of theBoardandshall, assoonaspossibleaftereachmeeting, causea copy of the minutes to be forwarded to each Director.
5) Quorum.
A majority of the Board shall constitutea quorum for the transactionof business. No actionmaybetakenby the Board exceptupon theaffirmativevoteof amajorityof theDirectors constitutinga quorum, exceptthatlessthana quorum may adjournameetingto anothertime and place.
E. RULES AND REGULATIONS.
TheAuthority mayadopt, from timeto time, by resolutionof theBoardsuchrules andregulationsfortheconductof itsmeetingsandaffairsasmayberequired.
Section 4. Powers.
TheAuthorityshallhave thepower, in its ownname, toexercise thecommonpowersof theMembersandtoexercisealladditionalpowersgiventoajointpowersentityunderanyofthe lawsof theStateof California, including, but not limitedto, theJointExerciseof PowersAct, for any purpose authorized under this Agreement. Suchpowersshall includethe commonpowers specified inthis Agreementandmaybeexercisedin themannerandaccording tothemethod providedin thisAgreement. TheAuthorityis herebyauthorized todoall actsnecessaryfor the exerciseof suchpower, including, butnot limitedto, anyof all of thefollowing; to makeand enter into contracts; to employ agents and employees; to acquire, construct, provide for maintenanceandoperationof, or maintainandoperate, anybuildings, worksor improvements; to acquire, hold or disposeof property whereverlocated; toincur debts, liabilities or obligations; to receive gifts, contributions and donations of property, funds, services, and other forms of assistancefromperson, firms, corporationsandanygovernmentalentity; tosueandbesuedin its own name; to makegrants, loansor provide otherfinancialassistance togovernmentaland nonprofitorganizations (e.g., theMembersor theFoundation) to accomplishanyof itspurposes; andgenerallytodoanyandallthingsnecessaryor convenienttoaccomplishitspurposes.
Withoutlimitingthegeneralityof theforegoing, theAuthoritymayissueor causeto be issuedBonds, andpledgeanypropertyorrevenuesassecuritytotheextentpermittedunderthe JointExerciseof PowersAct, or anyotherapplicableprovisionof law; provided, however, the AuthorityshallnotissueBondswith respectto anyprojectlocatedin thejurisdictionof oneor moreMembersunlessthe governingbody of any suchMember, or its duly authorized representative, shallapprove, conditionallyorunconditionally, theproject, includingtheissuance of Bonds therefor. Suchapprovalmay be evidencedby resolution, certificate, order, report or suchothermeansof writtenapprovalof suchprojectasmaybeselectedbytheMember (orits authorized representative) whose approval is required. No such approval shall be required in Redlands Regular Meeting of 06-03-25
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connectionwith BondsthatrefundBondspreviouslyissuedbytheAuthorityandapprovedby the governing board of a Member.
Themannerin whichtheAuthorityshallexerciseits powersandperformits dutiesis and shallbesubjecttotherestrictionsuponthemannerin whichaCaliforniagenerallawcitycould exercisesuchpowersandperformsuchduties. Themannerin whichtheAuthorityshallexercise its powersandperformits dutiesshallnot besubjectto anyrestrictionsapplicableto themanner in whichanyotherpublicagencycouldexercise suchpowersor performsuchduties, whether suchagencyis apartyto this Agreementor not.
Section 5. Fiscal Year.
Forthepurposesof this Agreement, theterm " FiscalYear" shallmean thefiscalyearas establishedfromtimetotimeby resolutionof theBoard, being, atthedateof thisAgreement, the periodfromJuly 1to andincludingthefollowingJune30, exceptfor thefirst FiscalYearwhich shall be theperiod from the dateof this Agreementto June 30, 2004, Section 6. Disposition of Assets.
At the end of the term hereof or upon the earlier termination of this Agreement as set forthin Section2, afterpaymentof all expensesandliabilitiesof theAuthority, allpropertyof the Authority both real andpersonalshall automaticallyvest in theMembersin the mannerand amount determined by the Board in its sole discretion and shall thereafter remain, the sole propertyof theMembers; provided, however, thatany surplusmoneyonhand shallbereturned in proportionto the contributionsmadeby theMembers.
Section 7. Bonds.
From timetotimetheAuthorityshallissueBonds, in oneormoreseries, forthepurpose of exercisingits powersandraisingthefundsnecessaryto carryoutits purposesunderthis Agreement.
The servicesof bond counsel, financing consultantsand other consultantsand advisors working on the projects and/ or their financing shall be used by the Authority. The expenses of the Boardshallbepaidfrom theproceedsof theBondsor anyotherunencumbered fundsof the Authority availablefor suchpurpose.
Section 8. Bonds Onlv Limited and Special hObligationsof Authority. The Bonds, togetherwith the interestand premium, if any, thereon, shall not be deemedto constitutea debtof anyMemberor pledgeof thefaithand creditof theMembersor theAuthority.
The Bondsshall be onlyspecialobligationsof theAuthority, and the Authorityshall under no circumstancesbe obligatedto paythe Bondsexcept from revenuesand otherfundspledged therefor. Neither the Membersnor theAuthorityshall be obligatedto paythe principalof, premium, if any, or intereston theBonds, or othercostsincidentalthereto, except from the revenues and fundspledgedtherefor, and neitherthe faithand creditnor thetaxingpowerof theMembers nor the faith and credit of the Authorityshall be pledgedto the paymentof the Redlands Regular Meeting of 06-03-25
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principalof, premium, if any, orinterestontheBondsnorshalltheMembers ortheAuthority in anymannerbeobligatedto makeanyappropriationfor suchpayment.
No covenantor agreementcontainedin anyBondor relateddocument shallbe deemedto beacovenantoragreementofanyDirector, oranyofficer, employeeoragentoftheAuthorityin hisor herindividualcapacityandneithertheBoardof theAuthoritynoranyDirectororofficer thereofexecutingtheBonds shallbeliablepersonallyonanyBondorbesubjectto anypersonal liability or accountability byreasonof theissuanceof any Bonds.
Section 9. Accounts and Reports.
All funds of the Authority shall be strictly accounted for. The Authority shall establish andmaintainsuchfundsandaccountsasmayberequiredbygoodaccountingpracticeandby any provision of any Indenture (to the extent such duties arenot assignedto a trusteeof Bonds).
Thebooksandrecordsof theAuthorityshallbeopento inspectionat all reasonabletimesby each Member.
The Treasurerof the Authority shall causeanindependentaudit to be madeof thebooks of accountsandfinancialrecordsof theAuthorityby a certifiedpublicaccountantor public accountantin compliancewith the provisions of Section 6505 of the Joint Exerciseof Powers Act. In eachcasetheminimumrequirementsof theauditshallbethoseprescribedbytheState Controller for special districts under Section 26909 of the Government Code of the State of California and shall conform to generally accepted auditing standards. When such an audit of accounts andrecordsis madeby a certified publicaccountantor publicaccountant, a report thereofshallbefiled asa publicrecordwith eachMemberandalsowith thecountyauditorof eachcountyin whicha Memberis located; provided, however, thatto the extentpermittedby law, theAuthoritymay, insteadof filing suchreportwitheachMemberand ,suchcountyauditor, electto postsuchreportasa publicrecordelectronicallyon a websitedesignatedby the Authority. Such report if made shall be filed within 12 months of the end of the Fiscal Year or Years under examination.
TheTreasureris hereby directedto reportin writingonthefirst dayof July, October, January, and April of eachyear to the Board and the Memberswhich report shall describethe amountof moneyheldby theTreasurerfor theAuthority, theamountof receiptssincethelast suchreport, andtheamountpaidoutsincethelastsuchreport (whichmayexcludeamountsheld by a trusteeor otherfiduciaryin connectionwith anyBonds tothe extentthatsuchtrusteeor otherfiduciary providedregularreportscoveringsuch amounts.) Any costsof the audit, includingcontractswith, or employmentof, certifiedpublic accountantsor publicaccountantsin makinganauditpursuantto this Section, shallbeborneby theAuthorityandshallbeachargeagainstanyunencumberedfundsof theAuthorityavailable for that purpose.
In anyFiscalYearthe Boardmay, by resolutionadoptedby unanimousvote, replacethe annual special audit with an audit covering a two- year period.
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Section 10. Funds.
Subjectto theapplicableprovisionsof anyIndenture, which mayprovidefor atrusteeor otherfiduciary to receive, havecustodyof and disburseAuthority funds, the Treasurerof the Authority shall receive, have the custody of and disburseAuthority funds pursuantto the accounting procedures developed under Sections3.0 and 9, and shall make the disbursements requiredby this Agreementor otherwisenecessaryto carryoutanyoftheprovisionsof purposes of this Agreement.
Section 11. Notices.
Notices and other communications hereunder to the Members shall be sufficient if deliveredto the clerk of the governingbody of eachMember•, provided, however, that to the extent permitted by law, the Authority may, provide notices and other communications and postingselectronically (including, without limitation, through emailor by postingto awebsite).
Section 12. Additional MemberslWithdrawal of Members.
Qualifying public agenciesmay be addedas parties to this Agreementand become Members upon: ( 1) the filing by such public agency with the Authority of an executed counterpartof this Agreement, togetherwith a copyof theresolutionof thegoverningbodyof suchpublic agencyapprovingthis Agreementand the executionand delivery hereof, and (2) adoptionof a resolutionof the Boardapprovingthe additionof suchpublic agencyasaMember.
Upon satisfaction of such conditions, the Board shall file such executed counterpart of this Agreementasanamendmenthereto, effectiveuponsuchfiling.
A Member may withdraw from this Agreement upon written notice to the Board; provided, however, that no suchwithdrawal shall result in the dissolutionof the Authority so long asany Bondsremainoutstanding. Any suchwithdrawalshallbeeffectiveonly upon receipt of the notice of withdrawal by the Board which shall acknowledgereceipt of such notice of withdrawal in writing and shall file such notice as an amendmentto this Agreement effective upon suchfiling.
Section 13. Indemnification.
To the full extentpermittedby law, the Board mayauthorizeindemnificationby the Authority of any person who is or was a Director or an officer, employeeof other agent of the Authority, andwho wasor is a party oris threatenedto be madea partyto a proceedingby reasonof the fact that such person is or was such a Director or an officer, employeeor other agentof the Authority, againstexpenses, includingattorneysfees, judgments, fines, settlements andotheramountsactuallyandreasonablyincurredin connectionwith suchproceeding, if such personactedin goodfaith in a mannersuchpersonreasonablybelieved tobe in the bestinterests of the Authority and, in the caseof a criminalproceeding, hadno reasonablecauseto believethe conductof such personwas unlawful and, in the caseof an action by or in the right of the Authority, actedwith suchcare, includingreasonableinquiry, asanordinarilyprudentpersonin a like position would use under similar circumstances.
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Section 14. Contributions and Advances.
Contributionsor advancesof publicfundsandof theuseof personnel, equipmentor propertymaybe madeto the Authorityby the Membersfor anyof the purposesof this Agreement. Paymentof publicfundsmaybe madeto defraythecostof anysuchcontributionor advance. Any suchadvancemay be madesubject torepayment, andin suchcaseshall be repaid, in themanneragreeduponbytheAuthorityandtheMember makingsuch advanceatthetimeof such advance.
It is mutuallyunderstoodandagreedto that noMemberhasanyobligationto make advancesor contributions to the Authority to provide for the costs and expensesof administration of the Authority, even though any Member may do so. The Members understand andagreethata portionof thefundsof theAuthoritythatotherwisemaybe allocatedor distributedtotheMembersmayinsteadbe used tomakegrants, loansorprovideotherfinancial assistance to governmental units and nonprofit organizations ( e. g., the Foundation) to accomplishanyofthegovernmentalunit'sornonprofitorganization'spurposes.
Section 15. Immunities.
All of the privileges and immunities from liabilities, exemptionsfrom laws, ordinances andrules, andotherbenefitswhich apply to the activity of officers, agentsor employeesof Members when performing their respective functions within the territorial limits of their respective public agencies, shall apply to the same degree andextent to the Directors, officers, employees, agentsor otherrepresentativesof theAuthoritywhile engagedin theperformanceof anyof theirfunctionsor dutiesundertheprovisionsof this Agreement.
Section 16. Amendments.
Except asprovided in Section 12 above, this Agreement shall not be amended, modified, or altered, unless the negative consent of each of the Members is obtained. To obtain the negativeconsentof eachof theMembers, thefollowingnegativeconsentprocedure shallbe followed: ( a) theAuthority shallprovideeachMemberwith a noticeat leastsixty (60) days priorto thedatesuchproposed amendmentis to becomeeffectiveexplainingthe natureof such proposed amendment and this negative consent procedure; ( b) theAuthority shallprovideeach Member whodidnotrespondaremindernoticewithanoticeatleastthirty (30) dayspriortothe date such proposed amendmentis to become effective; and (c) if no Member objects to the proposed amendmentin writingwithin sixty (60) daysaftertheinitial notice, theproposed amendment shall become effective with respect to all Members.
Section 17. Effectiveness.
This Agreement shall become effective and be in full force and effect and a legal, valid andbinding obligationof eachof the Memberson the datethat the Board shallhavereceived from two of the Initial Members an executed counterpart of this Agreement, together with a certifiedcopyof aresolutionofthegoverningbodyof eachsuchInitialMemberapprovingthis Agreement and the execution and delivery hereof.
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Section 18. Partial Invaliditv.
If any oneor moreof the terms, provisions, promises, covenantsor conditionsof this Agreementshallto anyextentbe adjudgedinvalid, unenforceable, void or voidablefor any reasonwhatsoeverby a courtof competentjurisdiction, each andall of the remainingterms, provisions, promises, covenantsandconditionsof thisAgreementshallnotbeaffected thereby, andshallbevalidandenforceabletothefullestextentpermittedby law.
Section 19. Successors.
This Agreementshallbe binding uponandshall inureto thebenefit of the successorsof the parties hereto. Exceptto theextentexpresslyprovidedherein, no Membermayassignany right or obligation hereunder without the consent of the other Members.
Section 20. Miscellaneous.
This Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument.
The sectionheadingsherein are for convenienceonly and are not to be construedas modifying or governing the language in the section referred to.
Whereverin. this Agreementany consentor approvalis required, the sameshall not be unreasonably withheld.
This Agreementshall be governed underthe laws of the Stateof California.
This Agreementis the completeandexclusivestatementof the agreementamongthe Members, which supersedes and merges all prior proposals, understandings, and other agreements, whether oral, written, or impliedin conduct, betweenandamongthe Members relating to the subject matter of this Agreement.
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IN WITNESS WHEREOF, the City of Redlands has causedthis Agreement to be executed and attested by its duly authorized representatives as of the Z 1 day of ' T' UUy , 2019.
Member:
CITY OF LANDS
By U/),/]
Nam Janjce McConnell
Title: Assistant City Manager
AT>-
eanne
By
Na Donaldson
Title: City Clerk
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RESOLUTION NO. 7988
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS
APPROVING, AUTHORIZING AND DIRECTING EXECUTION OF A JOINT
EXERCISE OF POWERS AGREEMENT RELATING TO THE CALIFORNIA hTURTICIPAL FINANCE AUTHORITY AND APPROVING THE ISSUANCE OF THE
CALIFORNIA MUNICIPAL FINANCE AUTHORITY REVENUE BONDS,
SERIES 2019 ( HU11 ZGOOD) IN AN AGGREGATE PRINCIPAL AMOUNT NOT TO EXCEED $ 180, 000, 000 FOR THE PURPOSE OF FINANCING AND
REFINANCING THE ACQUISITION, CONSTRUCTION, FURNISHING AND
EQUIPPING OF PLYMOUTH VILLAGE AND CERTAIN OTHER MATTERS
RELATING THERETO
WHEREAS, pursuant to Chapter 5 of Division 7 of Title 1 of the Government Code of the State of California ( the " Act"), certain public agencies ( the " Members") have entered into a Joint Exercise of PowersAgreementRelatingto the California Municipal FinanceAuthority, datedasof January1, 2004 the " Agreement") in order to form the California Municipal Finance Authority ( the " Authority"), for the purposeof promoting economic, cultural andcotnrnunity development, and in order to exerciseany powers common to the Members, including the issuance of bonds, notes or other evidences of indebtedness; and
WHEREAS, the City of Redlands, California ( the " City") hasdeterminedthat it is in the public interest andfor the public benefit that the City becomea Member of theAuthority in order to facilitate the promotion of economic, cultural and community development activities in the City, including the financing of projects therefor by the Authority; and
WHEREAS, there is now before this City Council of the City ( the " Council") the form of the Agreement; and
WHEREAS, the Agreement hasbeen filed with the City, and the membersof the Council, with the assistance of its staff, have reviewed said dooturnent; and WHEREAS, the Authority is authorizedto issueandsellrevenuebondsfor thepurpose, among others, of fmanciangor refinancingthe constructionof capital projects; and WHEREAS, HumanGood, HumanGood NorCal ( formerly known asAmerican Baptist Homes of the Nest), Hu>nanGood SoCal (formerly known as Southern California Presbyterian Homes), HumanGoodFresno (formerly known asThe Terracesat SanJoaquinGardens), RedwoodSeniorHomes and Services and Westminster Gardens, each a Califorriia nonprofit public benefit corporation collectively, the " Corporation "), has requestedthat the Authority issuebondsin oneor more seriesin an aggregate principal amount not to exceed $ 180, 000, 000 ( the ` Bonds "), the proceedsof which will be used, amongotherthings, (a) in aprincipalamountnotto exceed $65,000,000, to refundall or aportion of the outstanding $ 77,805,000 original principal arriount California Statewide Communities Development Authority Senior Living Revenue Bonds, Series 2009 ( Southern California Presbyterian Homes) ( the " Series 2009 Bonds"), ( b) in aprincipal amountnot to exceed $95,000,000, to refund all or aportion of the outstanding $106,580,000 original principal amount California StatewideCommunities Development Authority Revenue Bonds, Series 2010 ( American Baptist Homes ofthe West) ( the " Series 2010 Bonds"), ( c) in a principal amount not to exceed $35,000,000, to finance or reimbursethe cost of remodeling, renovating, furnishing and equipping certain of the Corporation' s continuing care I: 3Resolutiom' aes 7900- 7999\ 7998 I vmmnGood 2019 - TEFRA Resolution. domin Redlands Regular Meeting of 06-03-25
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Section 4. The issuanceof the Bonds shall be subject to the approval of the Authority of all financing documents relating thereto to which the Authority is a party. The City shall have no responsibility or liability whatsoever with respect to the Bonds.
Section 5. The adoption of this Resolution shall not obligate the City or any department thereofto (i) provideanyfinancingto acquireor construct theProjector anyrefinancingof theProject; ii) approve any application or request for or take any other action in colrinectionwith any planning approval, pen -nit or other actionnecessaryfor the acquisition, construction, rehabilitation or operation of the project; (iii) makeany contribution or advanceanyfunds whatsoeverto theAuthority; or (iv) take any further action with respectto the Authority or its membership therein.
Section 6. The officers and employees of the City are hereby authorized and directed, jointly and severally, to do any and all things and to executeand deliver any andall documentswhich they deem necessary or advisable in order to carry out, give effect to and comply with the terns and intent of this Resolution andthe financing transaction approved hereby.
Section 7. The Council expressly conditions its approval of this Resolution on its understanding that the City shall have no obligation whatsoever to pay any principal, interest, fees or other costs associatedwith the Authority' s issuanceof the Bonds.
Section 8. The Clerk shall forward a certified copy of this Resolution and an originally executedAgreement to the Authority in care of its counsel:
Ronald E. Lee, Esq.
Jones Hall, APLC
475 Sansome Street, Suite 1700
San Francisco, CA 94111
Section 9. This Resolution shalltake effect immediatelyupon its adoption.
ADOPTED, SIGNED AND APPROVED this 2nd day of July, 2019.
Paul W. Foster, Mayor
Attest:
Lnz
nne Donaldson, City Clerk
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1 I:\cmo\Resolutions\8685 Approving Issuance of CMFA Bonds - HumanGood 2025.docx-ms
RESOLUTION NO. 8685
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS
APPROVING THE ISSUANCE OF THE CALIFORNIA MUNICIPAL
FINANCE AUTHORITY REVENUE AND REFUNDING BONDS, SERIES
2025 (HUMANGOOD – CALIFORNIA OBLIGATED GROUP) IN AN
AGGREGATE PRINCIPAL AMOUNT NOT TO EXCEED $205,000,000 FOR
THE PURPOSE OF FINANCING OR REFINANCING THE
CONSTRUCTION, FURNISHING AND EQUIPPING OF PLYMOUTH
VILLAGE AND CERTAIN OTHER MATTERS RELATING THERETO
WHEREAS, HumanGood, HumanGood NorCal, HumanGood SoCal or HumanGood Fresno, each a California nonprofit public benefit corporation (collectively, the “Corporation”), has requested that the California Municipal Finance Authority (the “Authority”) participate in the issuance of one or more series of revenue bonds in an aggregate principal amount not to exceed $205,000,000 (the “Bonds”), the proceeds of which will be used, among other things, (a) in a principal amount not to exceed $35,000,000, to refund all or a port ion of the outstanding $52,080,000 original principal amount California Statewide Communities Development Authority Revenue Bonds, Series 2015 (American Baptist Homes of the West) (the “Series 2015 NorCal Bonds”), (b) in a principal amount not to exceed $40,000,000, to refund all or a portion of the outstanding $47,900,000 original principal amount California Municipal Finance Authority Senior Living Revenue Bonds (Southern California Presbyterian Homes) Series 2015 (the “Series 2015 SoCal Bonds”), (c) in a principal amount not to exceed $15,000,000, to refund all or a portion of the outstanding $15,480,000 original principal amount California Municipal Finance Authority Revenue and Refunding Bonds, Series 2020A (HumanGood – California Obligated Group) (the “Series 2020A Bonds”), (d) in a principal amount not to exceed $60,000,000, to refund all or a portion of the outstanding $64,765,000 original principal amount California Municipal Finance Authority Revenue and Refunding Bonds, Series 2020B (HumanGood – California Obligated Group) (the “Series 2020B Bonds”), (e) in a principal amount not to exceed $55,000,000, to finance or reimburse the cost of constructing, building, remodeling, renovating, rehabilitating, upgrading, furnishing and equipping certain of th e Corporation’s continuing care retirement communities located in several jurisdictions throughout the state of California, including in the City of Redlands, (f) to pay a portion of the interest on the Bonds, if deemed necessary or advisable by the Author ity or the Corporation, (g) to provide working capital to the Corporation, if deemed necessary or advisable by the Authority or the Corporation, (h) to fund a debt service reserve fund, if deemed necessary or advisable by the Authority or the Corporation, and (i) to pay certain expenses incurred in connection with the issuance of the Bonds (collectively, the “Project”); and
WHEREAS, a portion of the proceeds of the Bonds in a principal amount not to exceed $20,000,000 will be used to finance expenditures for various renovations to existing infrastructure and upgrades to housing units and amenities at the following continuing care community owned and operated by the Corporation and located in the City of Redlands (the “City”): Plymouth Village located at 900 Salem Drive, Redlands, California, 92373 (the Redlands Regular Meeting of 06-03-25
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“Community”); and
WHEREAS, the proceeds of the Series 2015 NorCal Bonds were used, among other things, to (1) refund all or a portion of the $50,000,000 original principal amount California Statewide Communities Development Authority Variable Rate Demand Revenue Bonds, Series 2006 (American Baptist Homes of the West) (the “Series 2006 Bonds”), (2) finance or reimburse the cost of the remodeling, renovation, furnishing and equipping of the Corporation’s continuing care facilities located in several jurisdictions, including at the Community in the City, (3) pay a portion of the intere st on the Series 2015 NorCal Bonds, (4) provide working capital to the Corporation, (5) fund a debt service reserve fund, and (6) pay certain expenses incurred in connection with the issuance of the Series 2015 NorCal Bonds; and WHEREAS, pursuant to Section 147(f) of the Internal Revenue Code of 1986 (the “Code”), in order for the interest on the Bonds to be tax-exempt, the issuance of the Bonds by the Authority must be approved by the City because the Community is located within the territorial limits of the City; and
WHEREAS, the Council is the elected legislative body of the City and is one of the applicable elected representatives required to approve the issuance of the Bonds under Section 147(f) of the Code; and
WHEREAS, the Council understands that its actions in holding the public hearing and in adopting this Resolution do not obligate the City in any manner for payment of the principal, interest, fees or any other costs associated with the issuance of the Bonds, and the Council expressly conditions its approval of the issuance of the Bonds by the Authority by the adoption of this Resolution on this understanding; and
WHEREAS, the Authority has requested that the Council approve the issuance of the Bonds by the Authority in order to satisfy the public approval requirement of Section 147(f) of the Code and the requirements of Section 4 of the Joint Exercise of Powers Agreement relating to the California Municipal Finance Authority, dated as of January 1, 2004 (the “Agreement”), among certain local agencies, including the City; and WHEREAS, pursuant to Section 147(f) of the Code, the Council has, following notice duly given, held a public hearing regarding the issuance of the Bonds, and now desires to approve the issuance of the Bonds by the Authority;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS AS FOLLOWS:
Section 1. The Council accepts the above recitals as true and correct.
Section 2. The Council hereby approves the issuance of the Bonds by the Authority. It is the purpose and intent of the Council that this Resolution constitute approval of the issuance of the Bonds by the Authority for the purposes of (a) Section 147(f) of the Code by the applicable elected Redlands Regular Meeting of 06-03-25
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representative of the governmental unit having jurisdiction over the area in which the Community is located, in accordance with said Section 147(f) and (b) Section 4 of the Agreement.
Section 3. The issuance of the Bonds shall be subject to the approval of the Authority of all financing documents relating thereto to which the Authority is a party. The City shall have no responsibility or liability whatsoever with respect to the Bonds.
Section 4. The adoption of this Resolution shall not obligate the City or any department thereof to (i) provide any financing to acquire or construct the Project or any refinancing of the Project; (ii) approve any application or request for or take any other action in connection with any planning approval, permit or other action necessary for the acquisition, construction, rehabilitation or operation of the Project; (iii) make any contribution or advance any funds whatsoever to the Authority; or (iv) take any further action with respect to the Authority or its membership therein.
Section 5. The officers and employees of the City are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents which they deem necessary or advisable in order to carry out, give effect to and c omply with the terms and intent of this Resolution and the financing transaction approved hereby.
Section 6. The Council expressly conditions its approval of this Resolution on its understanding that the City shall have no obligation whatsoever to pay any principal, interest, fees or other costs associated with the Authority’s issuance of the Bonds.
Section 7. This Resolution shall take effect immediately upon its adoption.
ADOPTED, SIGNED AND APPROVED this 3rd day of June, 2025.
Mario Saucedo, Mayor
ATTEST:
Jeanne Donaldson, City Clerk
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I, Jeanne Donaldson, City Clerk of the City of Redlands, hereby certify that the foregoing resolution was duly adopted by the City Council at a regular meeting thereof held on the 3rd day of June 2025, by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
Jeanne Donaldson, City Clerk
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City Council Meeting L. 1.
DATE: 06/03/2025
TO: Honorable Mayor and City Council Members
SUBJECT: Consideration of Resolution No. 8692 authorizing the City Manager, or designee, to execute the Subrecipient Agreements, any amendments and all other related documents associated with the Encampment Resolution Funding (ERF-3-R) Program for an amount not-to-exceed $4,155,600 (Assistant City Manager Boatman)
MOTION(S):
If the City Council determines that staff’s recommendation is appropriate, the following motions are provided:
I move that the City Council adopt Resolution No. 8692; and 1.
I further move that the City Council approve the subrecipients as further detailed in the staff report as single/sole source providers for the ERF-3-R Program.
2. RECOMMENDATION:
Staff recommends that City Council adopt Resolution No. 8692 authorizing the City Manager, or designee, to execute subrecipient agreements, any amendments and all other related documents associated with the Encampment Resolution Funding (ERF-3-R) Program for an amount not-to-exceed $4,155,600.
DISCUSSION:
On November 27, 2023, the California Interagency Council on Homelessness announced a Notice of Funding Availability (NOFA) for the Encampment Resolution Funding Round Three (ERF-3-R) Program, which seeks to fund actionable, person-centered local proposals that resolve the experience of unsheltered homelessness for individuals residing in encampments.
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On April 30, 2024, the Homeless Solutions Division Program Manager of the Facilities and Community Services Department submitted an ERF-3-R Program grant application in response to the Notice of Funding Availibilty for a comprehensive plan to implement a multi-faceted approach addressing ongoing homelessness challenges in the City.
On September 27, 2024, the City received confirmation from the State of California Department of Housing and Community Development (HCD) of their intent to award a grant to the City for the ERF-3-R Program. On December 17, 2024 (Item No. L.4.), City Council accepted the HCD ERF-3-R grant for the amount of $5,341,800.
On February 25, 2025, the City received the funds from the HCD for the ERF-3-R Program and of that amount, $4,155,600 will be allocated to local non-profit service providers (subrecipients) in order to meet the project's proposed outcomes. Funding for the Homeless Resource Services Program Agreements will be for a 24-month period beginning June 4, 2025.
The subrecipients will provide a range of supportive services through a multi-faceted approach geared towards the specific needs of the homeless populations in Redlands, including temporary and transitional housing as well as securing housing for up to 100 individuals. Additional services include mental and substance-use treatment, employment assistance, and specialized care for those with chronic health and physical disabilities.
The City of Redlands has existing partnerships with key community organizations to facilitate these services and were selected as subrecipients as part of the grant application process. Key partnerships include several nonprofit organizations leveraging their unique areas of expertise and resources. Step Up on Second Street, Inc., with over 35 years of experience, will provide outreach services and connect individuals to available resources, including permanent housing at the Step Up in Redlands site. Youth Hope focuses on unhoused youth, offering outreach, case management, and supportive services.
Family Service Association, Building a Generation, and the Salvation Army have over 10 years of experience and will leverage their community relationships to support permanent housing placements. Rehabilitation Services, Salvation Army, and Central for Spiritual Living each have over 5 years of experience serving diverse populations and will provide interim shelter beds. The Super 8 motel currently works with the city and will provide emergency shelter.
Leveraging over 5 years of experience in career development and job search assistance, Building a Generation, Goodwill Career Services, and Redlands Chamber of Commerce will provide job placement assistance. Each partner’s prior experience in managing complex homelessness projects informs this proposal, ensuring that the roles assigned are backed by a proven track record of success. While no formal procurement process was required by the ERF-3-R Redlands Regular Meeting of 06-03-25
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grant application, the Single/Sole Source providers listed below have met City Procurement requirements as well as the qualifications and experience required as part of the grant application process. Additionally, the Program subrecipients have assisted the City with housing 350 homeless individuals exceeding the expected target of 200.
Subrecipient funding awards are outlined as follows:
Subrecipients Services Amount
Center for Spiritual Living Temporary Shelter Beds $337,500 Rehabilitation Services Temporary Shelter Beds $337,500 Salvation Army Temporary Shelter Beds $337,500
SB Express Temporary Hotel Rooms $264,000
Step Up Outreach $306,250
Youth Hope Outreach $100,000
Salvation Army Outreach $306,250
Salvation Army Outreach and Mobile
Shelter
$300,000
Building a Generation Rapid Rehousing $456,200
Family Service Association
of Redlands
Rapid Rehousing $456,200
Salvation Army Rapid Rehousing $456,200
Building a Generation Employment Services $150,000
The Goodwill Employment Services $150,000
The Redlands Chamber of
Commerce
Employment Services $150,000
StepUp Project Homekey
Operating Support
$ 48,000
Resolution No. 8692 authorizes the City Manager, or designee, to execute the Subrecipient Agreements, any amendments and all other related documents associated with the subrecipient services related to the Encampment Resolution Funding (ERF-3-R) Program Grant for an amount not-to-exceed $4,155,600.
ALTERNATIVES:
City Council may elect not to approve Resolution No. 8692 and provide alternative direction to staff. However, electing not to approve this item could result in the loss of grant funding by not meeting the expenditure deadline.
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STRATEGIC PLAN:
Supports Priority B: Public Health and Safety, Objective 4: Homelessness SUBMITTED BY:
Christopher Boatman, Assistant City Manager
RECOMMENDED BY:
Charles M. Duggan Jr., City Manager
REVIEWED BY:
Yvette M. Abich Garcia, City Attorney
Janice McConnell, Assistant City Manager
Danielle Garcia, Management Services/Finance Director
PREPARED BY:
Tricia Munoz, Development Services Management Analyst
Fiscal Impact
Fiscal Year: FY2025-26
Revenue Generating: N
Appropriation Required Y/N: N
Amount: $4,155,600
Budgeted Y/N: Y
Account No.: various
Discussion:
There will be no impact on the General Fund as sufficient appropriation exists in the Facilities & Community Services Department Budget under Project Ledger S120006 and was approved by Council on December 17, 2024, (Item.
No. L.4.). Funds for the ERF-3 Grant Award Agreement No. 24-ERF-3-R-100029-RFF#1 were received on February 21, 2025, for the services outlined in the staff report.
Attachments
ERF-3-R Resolution
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1 I:\CMO\RESOLUTIONS\8692 ERF-3R GRANT SIGNING AUTHORITY.DOCX-MS
RESOLUTION NO. 8692
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS
AUTHORIZING THE CITY MANAGER, OR DESIGNEE, TO EXECUTE
SUBRECEIPIENT AGREEMENTS FOR THE ENCAMPMENT RESOLUTION
FUNDING ROUND THREE GRANT AWARD FROM THE STATE OF
CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY
DEVELOPMENT TO FUND UNSHELTERED HOMELESSNESS OUTREACH
AND HOUSING OPTIONS AND TO NEGOTIATE AND EXECUTE RELATED
DOCUMENTS ASSOCIATED WITH THE SUBRECEIPIENT AGREEMENTS
WHEREAS, on November 27, 2023, the California Interagency Council on Homelessness announced a Notice of Funding Availability for the Encampment Resolution Funding Round Three (“ERF-3-R”) Program, which seeks to fund actionable, person -centered local proposals that resolve the experience of unsheltered homelessness for individuals residing in encampments; and
WHEREAS, on April 30, 2024, the Homeless Solutions Division Program Manager of the Facilities and Community Services Department submitted an ERF -3-R Program grant application; and
WHEREAS, on September 27, 2024, the Homeless Solutions Division of the Facilities and Community Services Department received confirmation from the State of California Department of Housing and Community Development (“HCD”) of their intent to award the City’s proposed ERF-3- R Program in the amount of $5,341,800; and
WHEREAS, on December 17, 2024, City Council accepted the ERF-3-R grant funding award and funds were received by the City on February 25, 2025, in the amount of $5,341,800 of which $4,155,600 is allocated to subrecipient agreements; and
WHEREAS, the subrecipients will provide a range of supportive services through a multi - faceted approach geared towards the specific needs of the homeless populations in Redlands, including temporary and transitional housing as well as securing housing for up to 100 individuals.
Additional services include mental and substance -use treatment, employment assistance, and specialized care for those with chronic health and physical disabilities; and WHEREAS, the City Council has considered all information related to this matter, as presented at the public meetings of the City Council identified herein, including any supporting reports by City Staff, and any information provided during public meetings.
NOW, THEREFORE, BE IT RESOLVED by the City of Redlands, as follows:
Section 1. The City Council hereby finds that the facts set forth in the recitals to this Resolution are true and correct and establish the factual basis for the City Council’s adoption of this Resolution.
Section 2. The City Manager of the City of Redlands, or designee , is hereby authorized and directed to execute ERF-3-R Program subrecipient agreements and any subrecipient agreement amendments thereto.
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Section 3. This Resolution shall become effective immediately.
ADOPTED, SIGNED AND APPROVED this 3rd day of June 2025.
________________________
Mario Saucedo, Mayor
ATTEST:
___________________________
Jeanne Donaldson, City Clerk
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I, Jeanne Donaldson, City Clerk of the City of Redlands, hereby certify that the foregoing Resolution No. 8692 was duly adopted by the City Council at a regular meeting thereof held on the 3rd day of June 2025, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
_________________________________
Jeanne Donaldson, City Clerk
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City Council Meeting L. 2.
DATE: 06/03/2025
TO: Honorable Mayor and City Council Members
SUBJECT: A Public Hearing regarding a report on city vacancies and the status of recruitment and retention efforts as required by Assembly Bill 2561 (Government Code Section 3502.3) (Human
Resources/Risk Management Director Meteau)
(Mayor to declare meeting open as a public hearing)
PROCEDURE FOR PUBLIC HEARING:
Mayor declares the meeting open as a public hearing.1.
Mayor calls upon Department Director for report.2.
Mayor calls for questions/comments from members of the City Council.3.
Mayor calls for comments/questions/testimony from the labor group that made a request to speak.
4. Mayor calls on members of the public (3 minutes per speaker).5.
Mayor calls upon City Clerk to note any written comments received.6.
Mayor closes the public hearing.7.
City Council considers the motion and votes.8.
MOTION(S):
I move to receive and file the vacancy report and status of recruitment and retention efforts as required by Assembly Bill 2561 (Government Code Section 3502.3).
DISCUSSION:
In September 2024, Assembly Bill (AB) 2561 (Gov. Code 3502.3) was signed by the Governor of California. AB 2561 requires a public agency to present the status of vacancies and recruitment and retention efforts at a public hearing at least once per fiscal year, allowing recognized employee organizations to present at the hearing. This report outlines the City of Redlands’ legal obligation under the new law, effective January 1, 2025.
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under the new law, effective January 1, 2025.
In compliance with AB 2561, the City of Redlands is required to undertake the following actions:
Hold a Public Hearing: At least once each fiscal year, at a public hearing before the City Council, the City shall present information regarding the status of vacancies and recruitment and retention efforts (Gov. Code § 3502.3(a)(1)) and identify any necessary changes to policies, procedures, and recruitment activities that may lead to obstacles in the hiring process (Gov. Code § 3502.3(a)(3)).
1. Hearing Before Final Budget: If the City Council adopts an annual budget during the fiscal year, the presentation must occur before the adoption of the final budget. (Gov. Code § 3502.3(a)(2)).
2. Employee Organization Participation: Allow the recognized employee organization for each bargaining unit at the City to make presentations during the public hearing concerning vacancies and recruitment and retention efforts. (Gov. Code § 3502.3(b)).
3. POSITION DATA:
The passage of AB 2561 recognizes the following challenges in local government employment:
Job vacancies in local government are widespread and significantly impact public sector service delivery.
1. High vacancy rates contribute to increased workloads for existing employees, leading to burnout and higher turnover.
2. There is a statewide interest in ensuring that public agencies are adequately staffed to support public service functions.
3. In 2024, the City of Redlands was budgeted for 595 full-time employees who are represented by a bargaining unit.
96 full-time employees separated from employment.
110 full-time employees were hired.
In 2024, the City enhanced recruitment efforts, including:
Social media: Leveraged LinkedIn Recruiting and other platforms to promote the City, broaden candidate outreach, and support direct sourcing efforts.
Career Fairs: Attended career fairs to connect with a diverse pool of candidates, promote the City, and identify potential talent for current and future job opportunities.
Reduce Time to Fill: Streamlined the hiring process through effective collaboration with department heads on the recruitment timeline.
Hiring incentives: Utilized hiring incentives for hard-to-fill positions and Redlands Regular Meeting of 06-03-25
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prominently featured them in job postings to attract candidates.
Continuous recruitment efforts for hard-to-fill positions.
Competitive benefits: Developed a benefits guide to highlight benefit offerings to candidates.
The City also implemented strategies to improve retention, including:
Enhanced onboarding: Strengthened the onboarding experience to better integrate new hires and align them with organizational values, and launched an onboarding video showcasing the City, its workforce, culture, mission, and values.
Wellness initiatives: Promoted a positive work environment and helped reduce burnout through programs like fitness challenges, mental health resources, and wellness and financial workshops.
Employee engagement: Strengthened employee engagement by cultivating a culture of connection and involvement through targeted employee engagement initiatives.
Training and Development: Launched Management and Leadership Workshops to equip current and emerging leaders with key skills in communication, decision-making, team building, and strategic thinking, fostering organizational success and a culture of continuous growth.
By enhancing recruitment and retention efforts and ensuring transparent reporting, the City is committed to maintaining a strong and effective workforce.
VACANCY RATE:
All bargaining units maintained vacancy rates below 20% as follows:
The Redlands Association of Department Directors (RADD) had a 0% vacancy rate.
The Redlands Association of Management Employees (RAME) had a 5.3% vacancy rate.
The Redlands Association of Mid-Management Employees (RAMME) had a 6.4% vacancy rate.
The Redlands Association of Safety Management Employees (RASME) had a 0% vacancy rate.
The Redlands Association of Fire Management Employees (RAFME) had a 0% vacancy rate.
The Redlands Association of Civilian Safety Employees (RCSEA) had a12.7% vacancy rate.
The Redlands Profession Firefighters Association (RPFA) had a 7.4% vacancy rate.
The Redlands Police Officers Association (RPOA) had a 19.8% vacancy rate.
The TEAMSTERS Local #1932 had an 8.6% vacancy rate.
As permitted under Government Code Section 3502.3(b) and city policy, Redlands Regular Meeting of 06-03-25
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As permitted under Government Code Section 3502.3(b) and city policy, recognized employee organizations shall have the right to present information, concerns, and recommendations at the public hearing. The Redlands Police Officers Association (RPOA) has requested to make a presentation to the City Council.