Agenda packet — Redlands City Council, April 7, 2026 (part 3 of 7)

The developed land cover type is not considered a sensitive natural community in local or regional plans, policies, and regulations, or by CDFW and USFWS. The plants within this land cover type are not considered rare by the CNDDB. The Developed land cover type is dominated by non-native species; it is widespread in the project vicinity; it is considered common and not to be of concern; and/or it exhibits a moderate level of disturbance rendering this land cover type less valuable as habitat to support wildlife diversity or special-status species.

Developed lands are either non-vegetated features that are occupied by man-made structures or other impermeable surfaces that cannot support vegetation (e.g., streets and buildings), or are vegetated by ornamental or landscape vegetation. These developed areas provide virtually no habitat for wildlife species; however, birds could use the ornamental vegetation for foraging and nesting.

Developed lands and ornamental vegetation do not have a global or state rank and are not considered sensitive communities.

Disturbed/Ruderal
The project site includes a total of 7.15 acres of disturbed/ruderal land cover type. These areas of the project site include several detention basins and areas utilized as staging areas in support of past agricultural activities. Dominant plants documented within this vegetation community include ruderal non-native species as well as native species common in disturbed areas including but not  SECTION 4.3 – BIOLOGICAL RESOURCES 
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limited to horseweed (Erigeron canadensis), Russian thistle, prostate knotweed, red-stemmed filaree (Erodium cicutarium), prickly lettuce (Lactuca serriola), golden crown beard (Verbesina encelioides), tumbling pigweed (Amaranthus albus), salt cedar (Tamarisk ramosissima), tree tobacco (Nicotiana glauca), black mustard, brittlebush (Encelia farinosa), telegraph weed (Heterotheca grandiflora), annual bursage (Ambrosia acanthicarpa), turkey-mullein (Croton setiger), desert croton (Croton californicus), tocalote (Centaurea melitensis), London rocket (Sisymbrium irio), stinknet, Australian saltbush, annual beard-grass (Polypogon monspeliensis), California cottonrose (Logfia filaginoides), common sandaster (Corethrogyne filaginifolia), bedstraw (Galium sp.) common sow thistle (Sonchus oleraceus), scarlet pimpernel (Lysimachia arvensis), henbit (Lamium amplexicaule), dwarf nettle (Urtica urens), umbrella plant (Cyperus involucratus), bull thistle (Cirsium vulgare), annual yellow sweetclover (Melilotus indicus), shepherd’s purse (Capsella bursa-pastoris), and Mexican fan palm (Washingtonia robusta) (Cadre Environmental, 2025, p. 7).

Disturbed
A total of 1.43 acres of disturbed land cover type was documented on the project site. These regions of the project site include those areas generally devoid of vegetation, including dirt roads (Cadre Environmental, 2025, p. 7).

Mule Fat Scrub
A total of 0.51 acre of mule fat scrub vegetation was documented onsite. Specifically, several small patches of mule fat scrub are located within the existing detention basin located in the northwest corner of the project site. This vegetation community is dominated by mule fat (Baccharis salicifolia) with an understory of ruderal and native species commonly occurring within disturbed habitats, as described above (Cadre Environmental, 2025, p. 7).

California Buckwheat Scrub
A single small 0.18-acre-patch of California buckwheat scrub is located within the existing detention basin located in the northwest corner of the project site. This vegetation community is dominated by California buckwheat (Eriogonum fasciculatum) with an understory of ruderal and native species commonly occurring within disturbed habitats, as described above (Cadre Environmental, 2025, p. 7).

Ornamental
A single mature chinaberry tree (Melia azedarach) with a 0.10-acre (74.47-foot-diameter) canopy is located in the northeast corner of the project site (Cadre Environmental, 2025, p. 7).

4.3.4.2 Sensitive Species
Based on a review of the CNDDB (CDFW, 2025), Redlands General Plan and existing conditions within and adjacent to the project site, a total of 18 sensitive plant species have potential to occur within the vicinity of the project site. See Table 2, Sensitive Plant Species Assessment, in the BRTR in Appendix D2 (Cadre Environmental, 2025, p. 27). No suitable habitat for sensitive plant species, including those listed as federal or state threatened/endangered, was documented within the project site. No sensitive plant species listed in the BRTR, or undisturbed habitats or soils were documented or expected to occur within the project site. The project site is primarily characterized as heavily disturbed agricultural field, detention basins, and development (Cadre Environmental, 2025, p. 30).  SECTION 4.3 – BIOLOGICAL RESOURCES 
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Based on a review of the CNDDB, Redlands General Plan and existing site conditions, a total of 46 sensitive invertebrate and wildlife species have the potential of occurring within the vicinity of the project site. See Table 3, Sensitive Wildlife Species Assessment.in the BRTR in Appendix D2 (Cadre Environmental, 2025, p. 30). None of the sensitive wildlife species listed in the BRTR were identified during surveys. Based on the habitats documented within the project site, there is only one species with a high potential to occur, five species with a moderate potential to occur, and seven species with a low potential to occur. These species are listed below. • Crotch’s bumble bee (Bombus crotchii)/State Candidate Endangered (SCE) - foraging and nesting, low potential
• Burrowing owl (Athene cunicularia)/State Species of Special Concern (SSC) - foraging, refugia and nesting, moderate potential.
• Loggerhead shrike (Lanius ludovicianus)/SSC – foraging, moderate potential • White-tailed kite (Elanus leucurus)/State Fully Protected (SFP) – foraging, moderate potential
• Golden eagle (Aquila chrysaetos)/ California Watch List (CWL), SFP – foraging, low potential • Cooper's hawk (Accipiter cooperii)/SSC – foraging, low potential • Sharp-shinned hawk (Accipiter striatus)/CWL – foraging, high potential • Northern harrier (Circus cyaneus)/SSC – foraging, low potential • California horned lark (Eremophila alpestris actia)/CWL- foraging and nesting, moderate potential
• Merlin (Falco columbarius)/CWL – foraging, low potential • Prairie falcon (Falco mexicanus)/CWL – foraging, low potential • Long-eared owl (Asio otus)/SCC – foraging, low potential • Western yellow bat (Lasiurus xanthinus)/SSC - foraging and roosting (palm trees), moderate potential
The project site does not occur within or adjacent to a USFWS-designated critical habitat for any federally listed threatened or endangered species (Cadre Environmental, 2025, p. 41).

4.3.4.3 Potential Jurisdictional Areas
The project site was assessed for the potential presence/absence of areas under the jurisdiction of USACE, CDFW, and RWQCB. Figure 4.3-2, Jurisdictional Resources Assessment, shows potential jurisdictional resources identified during the field survey. To ensure that potential adverse effects to jurisdictional resources are reduced to a less than significant level, a formal jurisdictional delineation and regulatory permit(s) will be required for the entire project site for each phase prior to development approval.
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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Figure 4.3-2

JURISDICTIONAL RESOURCES ASSESSMENT
Land Cover/Potential Jurisdictional Areas
I AGF I Agriculture - Fallow Land
Developed
Disturbed/Ruderal
Mule Fat Scrub
California Buckwheat Scrub
,~._~, Flow Pattern
D Potential CDFW/RWQCB Jurisdictional Resources
Sources.: Cadre Errvfronmental 2025
Disclaimer: Illustration provided by Cadre Environmental, who has indicated that the information is true and correct. No other warranties are expressed or implied.

Source: Cadre Environmental, 2025.

Ultra Syst em s env,ronmenta I• manage men I• pl.a nn 1n9 ~ Uni •
~----... -,""~-----
l
n' '-,-
Kaiser Permanente
Redlands Medical Center
Potential Jurisdictional Areas
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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4.3.5 Environmental Impact Analysis

4.3.5.1 Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, the project would have a significant impact related to biological resources if it would:

A. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; or
B. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; or C. 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; or
D. 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; or
E. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or
F. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

For this analysis, the CEQA Appendix G Thresholds listed above are relied upon. Section 4.4 of the Initial Study prepared for this project determined that the project would have a less than significant impact under Threshold D because the project site does not contain native wildlife nursery sites or wildlife corridors and would not impede established ones. There would also be no impact under Threshold F because the project site is not within adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan (UltraSystems, 2025). The Initial Study also stated that these thresholds will not be discussed further in the PEIR. However, Threshold D was analyzed and mitigation included for it in the BRTR in Appendix D2. Therefore, Threshold D is included in this analysis with measures to ensure impacts will be less than significant under this threshold.

4.3.5.2 Analysis of Project Impacts
Threshold A: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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Less Than Significant with Mitigation
Development of the proposed project would not have a substantial adverse effect, either directly or through habitat modifications, on any plant species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by CDFW or USFWS. No native undisturbed suitable habitat, soils or sensitive plant species were observed or expected to occur within the project site. Therefore, no mitigation is required for sensitive plant species or habitats (Cadre Environmental, 2025, p. 44).

The proposed project may result in an adverse impact, either directly or through habitat modifications, on wildlife species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. The habitats documented within the project site have a low to high likelihood of occurrence for the 13 species listed above (Cadre Environmental, 2025, p. 44).

The 0.18-acre patch of California buckwheat scrub documented in the northwest detention basin is suitable foraging habitat for the Crotch’s bumble bee. Suitable nesting habitat was also documented in the region of this food source. To ensure that potential adverse effects to Crotch’s bumble bee are reduced to a less than significant level, focused assessments and surveys, as warranted will be required during phases 1 and 2 of the project including impact analysis prior to approval of development within each area, as described in mitigation measure (MM) BIO-1 presented in Section

4.3.7 below (Cadre Environmental, 2025, p. 44).14
Burrows suitable for burrowing owl potentially utilized for refugia and/or nesting and foraging habitat were documented throughout the undeveloped areas of the project site. To ensure that potential adverse effects to burrowing owl are reduced to a less than significant level, focused assessments and surveys and impact analysis, as warranted, will be required during phases 1 and 2 of the project prior to approval of development within each respective area, as detailed in MM BIO2 in Section 4.3.7 below (Cadre Environmental, 2025, p. 44).

Suitable foraging habitat for nine sensitive species including loggerhead shrike, white-tailed kite, golden eagle, Cooper's hawk, sharp-shinned hawk, northern harrier, merlin, prairie falcon, and longeared owl was documented within the project site. However, it was determined that development of the proposed project is not expected to result in a significant impact to regional foraging resources for these species and thus no mitigation is proposed for these species (Cadre Environmental, 2025, p. 44).

Suitable foraging and nesting habitat for one sensitive species, California horned lark, was identified within the project site. To ensure that potential impacts to California horned lark are reduced to a less than significant level, a focused nesting survey and impact analysis will be required during phases 1 and 2 of the project prior to approval of development within each phase area to be developed, as summarized in MM BIO-3 in Section 4.3.7 below (Cadre Environmental, 2025, p. 44).

The project site also contains suitable foraging and roosting habitat (palms) for the yellow bat. To ensure that potential impacts to yellow bat are reduced to a less than significant level, preconstruction surveys will be required during each of the four phases of the project prior to 14 Grading for phases 2, 3, and 4 of the project will be done in Phase 2.  SECTION 4.3 – BIOLOGICAL RESOURCES 
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approval of development within reach respective region, as summarized in MM BIO-4 presented in Section 4.3.7 below (Cadre Environmental, 2025, p. 45).

Threshold B: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Less than Significant with Mitigation
A total of 26.91-acres of developed and natural vegetation communities within the project site would be directly and permanently impacted as a result of project development (Phases 1 to 4), as summarized in Table 4.3-1 above.15 No sensitive habitat identified in local or regional plans, policies, regulations, or by CDFW or USFWS will be impacted as a result of project implementation. A total of

0.51-acre of mule fat scrub (riparian habitat) was documented within Basin 2. To ensure that potential impacts to jurisdictional resources including riparian habitat are reduced to less than significant, MM BIO-5 will require a formal jurisdictional delineation and impact analysis to be conducted for the entire project site for all project phases prior to approval of Phase 1. If present, and prior to issuance of a grading permit, the project applicant may be required to obtain a 1602 LSAA from CDFW for impacts to regulated features including riparian habitat, as warranted in MM BIO-5 and presented in Section 4.3.7 below (Cadre Environmental, 2025, p. 45).

Threshold C: Would the Project 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? Less Than Significant with Mitigation
The project site was assessed for the potential presence or absence of resources under the jurisdiction of USACE, CDFW, and RWQCB. The assessment identified potentially jurisdictional areas shown in Figure 4.3-2. Impacts to potentially jurisdictional areas would be significant. To ensure that potential impacts to jurisdictional resources are reduced to a less than significant level, MM BIO5 requires a formal jurisdictional delineation and impacts analysis be conducted for the entire project site covering all project phases prior to approval of Phase I development. If present, and prior to issuance of a grading permit, the project applicant may be required to obtain a CWA Section 404 permit from the USACE, a 1602 LSAA from CDFW, and a CWA Section 401 or Waste Discharge Requirements (WDR) permit from the RWQCB pursuant to the California Water Code Section 13260, as described in MM BIO-5 and presented in Section 4.3.7 below (Cadre Environmental, 2025, p. 47).

Threshold D: Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less than Significant with Mitigation
The Initial Study had determined that the project would result in a less than significant impact under this threshold. The project site does not contain native wildlife nursery sites. The project would not interfere substantially with or impede: (1) the movement of any resident or migratory fish or wildlife 15 Table 4.3-1 describes a total of 36.60 acres including 9.69 acres developed with the existing medical office building; thus, the acreage of impacts for this project is 26.91 acres.  SECTION 4.3 – BIOLOGICAL RESOURCES 
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species; (2) established resident or migratory wildlife corridors; or (3) the use of wildlife nursery sites. However, this threshold was analyzed in the BRTR (Appendix D2) and mitigation included to ensure impacts would be less than significant, and thus it is discussed below.

The project site has vegetation including trees and shrubs that could provide nesting habitat for raptors and migratory birds protected under the MBTA and the California Fish and Game Code §§ 3503, 3503.5, and 3513. In order to avoid violation of the MBTA and the California Fish and Game Codes, site preparation activities (ground disturbance, construction activities, staging equipment, and/or removal of trees and vegetation) for the project shall be avoided, to the greatest extent possible, during the nesting season of potentially occurring native and migratory bird species (generally September 15 to February 15 for songbirds; September 1 to January 14 for raptors, although the nesting season may be extended due to weather and drought conditions) (Cadre Environmental, 2025, p. 47).

Construction outside the raptor nesting season (between September 15 and January 14) does not require preconstruction nesting bird surveys. However, if construction is proposed between January 14 and September 15, a qualified biologist will conduct a preconstruction nesting bird and raptor survey(s) no more than three days prior to initiation of grading to document the presence or absence of nesting birds or raptors within or directly adjacent to the project site. Loss of an active nest would be considered a potentially significant impact. Impacts to raptor foraging and potential nesting bird habitat would be reduced to less than significant with the implementation of MM BIO-3, presented in Section 4.3.7 below (Cadre Environmental, 2025, p. 47).

The project site is surrounded by high-traffic roads and commercial/industrial development and does not serve as a local or regional wildlife movement corridor. Therefore, no impacts would occur with regards to wildlife movement corridors, and no mitigation is required (Cadre Environmental, 2025, p. 47).

Threshold E: Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? No Impact
City of Redlands General Plan
The City of Redlands General Plan 2035, Chapter 6, Vital Environment, includes policies and actions for the protection and preservation of biological resources and open space conservation (City of Redlands, 2017a). Below in Table 4.3-2 is a list of these policies and actions and discussions addressing each one with regard to the proposed project.

Table 4.3-2
GENERAL PLAN CHAPTER 6 CONSISTENCY ANALYSIS
General Plan Policy or Action Consistency Analysis
General Plan Open Space for Conservation – Section 6.1 (City of Redlands, 2017a, p. 6-3) Section 6.1 Policies - Principles
6-P.1 Develop a balanced and integrated open space
system that reflects a variety of considerations,
including resource conservation, production of
agriculture, recreation, aesthetics, and community
identity.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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General Plan Policy or Action Consistency Analysis
commercial/industrial development and does not
contribute to recreation, aesthetics or community
identity. The proposed project would not conflict
with Principle 6-P.1.
6-P.2 Designate and develop the Emerald Necklace
around the city, consisting of open spaces and
conserved lands, that showcase and link unique
resources both within and surrounding the Planning
Area and serve as a distinct boundary for urban
development within Redlands.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite and the project
would not include, add, or remove areas in the
Emerald Necklace. The project site is completely
surrounded by high traffic roads and
commercial/industrial development and does not
possess or contribute to unique resources. The
proposed project would not conflict with Principle
6-P.2.
6-P.3 Seek to link the various elements of the Emerald
Necklace through a system of open spaces,
waterways, parks, and trails.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space
conservation is proposed onsite and would not
provide or remove a link to the Emerald Necklace.

The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not contribute to open
spaces, waterways, parks, and trails. The proposed
project would not conflict with Principle 6-P.3.
6-P.4 Preserve and enhance open space and
agricultural land to define the Mentone and Crafton
areas as distinct from Redlands.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
contribute to the Mentone and Crafton regions. The
proposed project would not conflict with Principle
6-P.4.
6-P.5 Encourage the preservation of natural habitat
areas as open space.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
contribute to regional open space conservation. The
proposed project would not conflict with Principle
6-P.5.
6-P.6 Promote access to and views of conservation
areas in a manner consistent with good land resource
stewardship.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
contribute to regional open space conservation. The
proposed project would not conflict with Principle
6-P.6.
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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General Plan Policy or Action Consistency Analysis
Section 6.1 Polices - Actions
6-A.1 Preserve as open space those areas that contain
unique habitats, natural resources, and visual
amenities such as citrus groves, hillsides, canyons,
and waterways. These areas provide natural contrast
with the urban cityscape.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and would not
include, add, or remove unique habitats, natural
resources, or visual amenities such as citrus groves,
hillsides, canyons, and waterways. The proposed
project would not conflict with Action 6-A.1.
6-A.2 Identify gaps in the Emerald Necklace and work
with San Bernardino County and neighboring cities,
conservation organizations, and willing landowners
to prioritize land acquisition or other resource
preservation strategies in those areas.

The site is not appropriate for open space or
conservation/preservation for the Emerald
Necklace because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
include or result in removal of areas in the Emerald
Necklace. The proposed project would not conflict
with Action 6-A.2.
6-A.3 Identify portions of the Emerald Necklace that
are not in public ownership and work with
conservation organizations and landowners to ensure
that the land is dedicated or otherwise conserved.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
include, add, or remove areas in the Emerald
Necklace. The proposed project would not conflict
with Action 6-A.3.
6-A.4 Develop standards for planning, design,
management, and maintenance of trails and pathways
within parks, preserves, open space, and rights-ofway.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
contribute to trails and pathways within parks,
preserves, and open space. The proposed project
would not conflict with Action 6-A.4.
6-A.5 Develop a long-term plan for the maintenance
of open space areas held by the City which may
include non-profits, public-private partnerships, and
volunteer organizations.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. Therefore, the
proposed project would not conflict with Action 6-
A.5.
6-A.6 Designate and map open space, recreation
areas, and trails contained in the Emerald Necklace.

The site is not appropriate for open space,
recreation areas, or trails because of the
surrounding roads and commercial/industrial uses.

No open space, recreation areas, or trails are
proposed onsite. The project site is completely
surrounded by high traffic roads and
commercial/industrial development and would not
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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General Plan Policy or Action Consistency Analysis
add to or remove areas in the Emerald Necklace.

The proposed project would not conflict with
Action 6-A.6.
6-A.7 Work with San Bernardino County, neighboring
cities, conservation organizations, and landowners to
maintain and enhance the trails, roadways, and lands
within the Emerald Necklace, and to ensure that
sensitive resources in these areas are not disturbed or degraded.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
include or result in removal of areas in the Emerald
Necklace. The proposed project would not conflict
with Action 6-A.7.
6-A.8 Provide sufficient resources for the
maintenance of trails and conservation areas through
both volunteer and City mechanisms.

The site is not appropriate for open space, trails, or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite and thus the
applicant would not be responsible for providing
trail maintenance resources. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
contribute trails or conservation areas. The
proposed project would not conflict with Action 6-
A.8.
6-A.9 Develop and implement a wayfinding program
along the Emerald Necklace to identify sites of
interest and provide directions along trails and
roadways. Ensure that any signs are consistently
designed and visually compatible with the
surroundings.

The site is not appropriate for open space or
conservation because of the surrounding roads and
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
include or result in removal of areas in the Emerald
Necklace. The proposed project would not conflict
with Action 6-A.6.
6-A.10 Maintain and enhance Redlands’ network of
urban forest and street trees.

No trees regulated by the City of Redland’s Trees
and Tree Protection Along Street and Public Places
Ordinance (Chapter 12.52) were documented
onsite. No Impact. The proposed project would not
conflict with Action 6-A.10.

General Plan Biological Resources – Section 6.2 (City of Redlands, 2017a, p. 6-12) Section 6.2 Policies - Principles
6-P.7 Protect environmentally sensitive lands,
wildlife habitats, and rare, threatened, or endangered
plant and animal communities.

To ensure that potential adverse effects to sensitive
species and resources are reduced to a less than
significant level, focused biological resources
assessments will be required during each of the four
phases of the project including impact analysis prior
to approval of development within reach respective
region. In addition to completing CEQA review, any
focused surveys and required conservation
measures shall be implemented prior to project
approval and initiation of construction, as warranted
and summarized in MM BIO-1 to MM BIO-5.
6-P.8 Minimize disruption of wildlife and valued
habitat throughout the Planning Area and emphasize
The site is not appropriate for open space or
conservation because of the surrounding roads and
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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General Plan Policy or Action Consistency Analysis
that open space is for more than just human use, but
also serves as habitat for biological resources.
commercial/industrial uses. No open space or
conservation is proposed onsite. The project site is
completely surrounded by high traffic roads and
commercial/industrial development and does not
contribute to regional open space conservation. The
proposed project would not conflict with Principle
6-P.8.
6-P.9 Preserve, protect, and enhance wildlife
corridors, including natural watercourses, connecting
the San Bernardino National Forest, Santa Ana River
Wash, Crafton Hills, San Timoteo and Live Oak
Canyons, the Badlands, and other open space areas.

The site is not appropriate for open space,
corridors, or conservation because of the
surrounding roads and commercial/industrial uses.

No open space or conservation is proposed onsite.

The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not include or result in
removal of areas in the San Bernardino National
Forest, Santa Ana River Wash, Crafton Hills, San
Timoteo and Live Oak Canyons, the Badlands, and
other open space areas. The proposed project would
not conflict with Principle 6-P.9.
6-P.10 Landscape public areas using native
vegetation where practical.

The site is not appropriate for open space or public
areas because of the surrounding roads and
commercial/industrial uses. No public areas are
proposed onsite. The proposed project would not
conflict with Principle 6-P.10.

Section 6.2 Policies - Actions
6-A.11 Require a biological assessment of any
proposed project site within the Planning Area where
species that are State or federally listed as rare,
threatened, or endangered are identified as
potentially present.

No open space or conservation easements are
proposed onsite. The project site is completely
surrounded by high traffic roads and
commercial/industrial development and would not
add to or remove areas in the San Bernardino
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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General Plan Policy or Action Consistency Analysis
National Forest, Santa Ana River Wash, Crafton
Hills, San Timoteo and Live Oak Canyons, the
Badlands, and other open space areas. The
proposed project would not conflict with Action 6-
A.13.
6-A.14 Construct freeway and arterial street
undercrossing or overpasses where necessary to
establish and preserve identified wildlife corridors.

No undercrossing or overpasses are proposed. The
project site is completely surrounded by high traffic
roads and commercial/industrial development and
does represent a local or regional wildlife
movement corridor. The proposed project would
not conflict with Action 6-A.14.
6-A.15 Enhance the Mill Creek Zanja and Morey
Arroyo and tributary drainages as riparian corridors,
where feasible, to provide habitat as well as
recreational and aesthetic value consistent with an
overall master plan for habitat preservation.

The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not include or result in
removal of areas in Mill Creek Zanja and Morey
Arroyo and tributary drainages. The proposed
project would not conflict with Action 6-A.15.
6-A.16 Work with the Crafton Hills Open Space
Conservancy to preserve, enhance, and maintain the
Crafton Hills as an ecosystem.

The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not include or result in
removal of areas in the Crafton Hills Open Space
Conservancy. The proposed project would not
conflict with Action 6-A.16.
6-A.17 Coordinate open space and habitat
preservation in the Crafton Hills with the City of
Yucaipa.

The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not include or result in
removal of areas in Crafton Hills Open Space
Conservancy. The proposed project would not
conflict with Action 6-A.17.
6-A.18 Coordinate open space and habitat
preservation in San Timoteo and Live Oak canyons
with Riverside County.

The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not include or result in
removal of areas in the San Timoteo or Live Oak
Canyons. The proposed project would not conflict
with Action 6-A.18.
6-A.19 Continue participation in regional planning
efforts to protect habitat and environmentally
sensitive species, including efforts by the City of
Yucaipa on habitat preservation along Yucaipa Creek
and in Live Oak Canyon throughout its length.

The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not include or result in
removal of areas in Yucaipa Creek and Live Oak
Canyons. The proposed project would not conflict
with Action 6-A.19.
6-A.20 Work with State and County agencies in
developing recovery and restoration plans after natural or manmade disasters to restore natural landscapes,
habitats, and functioning ecosystems. As part of the
recovery and restoration plans, include evaluation
processes and implementation actions. Where
appropriate, incorporate the use of native species.

No recovery or restoration plans are proposed or
warranted. The proposed project would not conflict
with Action 6-A.20.
6-A.21 Ensure that future activities in the Santa Ana
River Wash are consistent with the habitat
conservation policies of the Upper Santa Ana River
The project site is completely surrounded by high
traffic roads and commercial/industrial
development and does not include or result in
removal of areas in the Santa Ana River Wash or
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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General Plan Policy or Action Consistency Analysis
Land Management Habitat Conservation Plan (Wash
Plan).

Upper Santa Ana River Land Management Habitat
Conservation Plan. The proposed project would not
conflict with Action 6-A.21.

Sources: City of Redlands, 2017a. Cadre Environmental, 2025.

Redlands Municipal Code - Regulated Trees
All public trees meeting the definition of native or specimen trees in § 12.52.020 of Chapter 12.52 (City Tree Ordinance) are subject to the protections of the Chapter. Code of Ordinances, Chapter

12.52.020 § 12.52.020 Definitions defines landmark treesin the City Tree Ordinance (City of Redlands, 2004) as:
“a public tree designated as a historic resource under chapter 2.62 of this code as a tree of historic or cultural significance and of importance to the community due to any of the following factors: it is one of the largest or oldest public trees of the species located in the city, it has historical significance due to an association with a historic building, site, street, person or event, or it is a significant outstanding feature of a neighborhood. “ Native tree is defined as:

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

Specimen tree is defined as:
“Any tree, identified by a certified arborist as native to the local area, with a trunk more than eight inches (8") in diameter at a height of four and one-half feet (4 ½ ‘) above natural grade that is identified on a list of native trees approved by the city council.” No trees regulated by the City of Redland’s Trees and Tree Protection Along Street and Public Places Ordinance (Chapter 12.52) were documented onsite during the biological surveys. Therefore, no impact on trees regulated by the City of Redlands would occur (Cadre Environmental, 2025, p. 48).

Based on the analysis above, the project would not conflict with any local policies or ordinances protecting biological resources, such as the City’s General Plan and City Tree Ordinance, thus no impacts would occur.

4.3.6 Cumulative Impacts
The project site is already partially developed as a medical facility. It is surrounded by high traffic roads and warehouse/industrial buildings on all sides, including one currently under construction to the south. The direct and/or indirect impacts of the project would not result in significant cumulative impacts (CEQA § 15310) to environmental resources within the region of the project site. Cumulative impacts refer to incremental effects of an individual project when assessed with the effects of past, current, and proposed projects. The project represents the development of 36.60 acres of primarily agricultural, developed, disturbed and disturbed/ruderal habitat surrounded by commercial, high traffic roads, and therefore will not result in an adverse cumulative impact to sensitive resources.

Impacts related to buildout of the City of Redlands are anticipated to be less than significant if  SECTION 4.3 – BIOLOGICAL RESOURCES 
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projects comply with the City of Redlands General Plan 2035 policies principles/actions. With implementation of the following mitigation measures, the proposed project would not conflict with the general plan policies for the protection of sensitive resources (Cadre Environmental, 2025, p. 49).

4.3.7 Mitigation Measures
To ensure that potential adverse effects to sensitive species and resources are reduced to a less than significant level, focused biological surveys and impacts analyses of the project site will be required prior to approval of Phase I development and each subsequent development phase. In addition to completing CEQA review, focused surveys and required mitigation measures shall be implemented prior to project approval and initiation of construction at each phase of the project, as described in MM BIO-1 through MM BIO-5. The measures presented below are based on the measures in the BRTR (Cadre Environmental, 2025) in Appendix D2.

MM BIO-1: Crotch’s Bumble Bee Surveys
To ensure the proposed project does not result in direct or indirect impacts to the Crotch’s bumble bee, focused presence/absence surveys shall be conducted based on the CDFW Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species Guidelines (June 6th, 2023), (CDFW, 2023). Focused surveys shall be started during the colony active period and when floral resources are present for the species by a qualified entomologist. Specifically, three surveys shall be conducted with at least two weeks between surveys from April to June. All regions within the project site where suitable floral resources are present shall be surveyed by walking meandering transects at least one hour after sunrise and/or at least two hours before sunset (ideally between 9am and 1pm) on warm sunny days with winds below eight miles per hour.

Focused surveys shall be conducted for a minimum of one person-hour of searching per three acres of suitable habitat. Bumble bees shall be captured with a net from blooms, avoiding destruction of the flower when possible. Each bee shall be carefully transferred into a sterile vial and moved to a cooler with only one bee per vial to avoid disease spread. The bee shall be kept in the vial for no more than 10 minutes in ambient temperature before being placed in a cooler as they have a tendency to over-heat (the amount of time will be decreased on hotter days). The vial shall be placed in a cooler at a temperature above 25 degrees Fahrenheit, as lower temperatures could freeze and kill the bee.

The results of the focused surveys shall be summarized in a letter report including graphics and recommendations. At a minimum, the survey letter report shall provide the following:

1. A description and map of the survey area, focusing on areas that could provide suitable habitat for Crotch’s bumble bee.

2. Field survey conditions that shall include name(s) of qualified entomologist(s) and brief qualifications; date and time of survey; survey duration; general weather conditions; survey goals, and species searched.

3. Map(s) showing the location of nests/colonies; and,

4. A description of physical (e.g., soil, moisture, slope) and biological (e.g., plant composition) conditions where each nest/colony is found. A sufficient description of biological conditions, primarily impacted habitat, shall include native plant composition (e.g., density, cover, and abundance) within impacted habitat (e.g., species list separated by vegetation class; density, cover, and abundance of each species).  SECTION 4.3 – BIOLOGICAL RESOURCES 
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If the species is detected onsite, the CDFW shall be contacted to determine appropriate conservation measures to prevent direct/indirect impacts to the species, or acquisition of an Incidental Take Permit (ITP). To initiate the ITP process, the applicant or representative shall contact the appropriate CDFW Regional Office and submit a completed ITP application.

MM BIO-2: Focused and Preconstruction Burrowing Owl Surveys To ensure the proposed project does not result in direct or indirect impacts to the burrowing owl, focused surveys shall be conducted in accordance with the March 7, 2012, Staff Report on Burrowing Owl Mitigation (CDFG, 2012) which recommends both a breeding and non-breeding season survey.

Specifically, a total of four surveys shall be conducted by a qualified avian biologist during the breeding season: 1) at least one site visit between February 15 and April 15, and 2) a minimum of three surveys, at least three weeks apart, between April 15 and July 15, with at least one visit after June 15. Non-breeding season surveys shall include four surveys spread out evenly from July 15 to February 15. A report of the findings prepared by a qualified biologist shall be submitted to the City of Redlands prior to any permit or approval for ground disturbing activities.

Regardless of the findings of the focused surveys, a burrowing owl preconstruction survey shall be conducted no less than 14 days prior to the initiation of ground-disturbing activities to ensure protection for this species including a survey conducted with 24 hours of start of work. The preconstruction surveys shall be conducted in compliance with CDFW guidelines (CDFG, 2012). A report of the findings prepared by a qualified biologist shall be submitted to the City of Redlands prior to any permit or approval for ground disturbing activities. If burrowing owls are not detected onsite, the proposed project may proceed. However, if project initiation is delayed more than 14 days, updated preconstruction surveys may be required.

If burrowing owls are detected onsite during the focused or preconstruction surveys, a burrowing owl monitoring and/or relocation plan shall be developed and approved by the City of Redlands, CDFW and USFWS prior to any permit or approval for ground disturbing activities. At a minimum, the plan shall include the following:

1. Burrowing owl status, distribution and habitat utilization within and adjacent to the project site.

2. Conservation objectives and goals developed in cooperation with CDFW and USFWS.

3. Results of burrowing owl monitoring activities.
a. 350-foot minimum protective (no work) zone shall be designated around each of the occupied burrow sites and delineated by orange silt fencing. The installation of the fencing shall be monitored by a qualified biologist to ensure owls are not directly or indirectly impacted as a result of fence installation. The monitoring biologist will also be responsible for directing where the fencing shall be installed. b. A qualified monitoring biologist shall monitor the owls weekly during the nonbreeding season to determine if the 350-foot protective zone is adequate for their protection. The weekly monitoring events will also provide critical information regarding the status of the species onsite for purposes of developing a relocation plan. c. A qualified monitoring biologist shall conduct an initial environmental briefing with any contractors which will be working onsite. The briefing shall include a discussion  SECTION 4.3 – BIOLOGICAL RESOURCES 
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of burrowing owl natural history, identification of burrowing owl non-breeding season protection zones, and summary of penalties for directly and/or indirectly impacting the species.
d. A qualified monitoring biologist shall be authorized to stop all work activities in the event potential direct and/or indirect impacts to burrowing owl may occur as a result of proposed staging activities.
e. Monthly updates on the monitoring efforts including recommendations, as warranted, shall be submitted to the City of Redlands, CDFW and USFWS.

4. Passive and/or active relocation activities.

5. Burrowing owl management activities for active relocation sites.

Based on the candidacy or listing status of the species at the time of surveys, if detected, acquisition of an Incidental Take Permit may also be required.

MM BIO-3: Pre-Construction Breeding Bird Survey
To maintain compliance with the MBTA and California Fish and Game Code §§ 3503, 3503.5, and 3513, and to avoid impacts or take of migratory non-game breeding birds and other native birds, their nests, young, and eggs, the following measures shall be implemented.

Site preparation activities (ground disturbance, construction activities, staging equipment, and/or removal of trees and vegetation) for the project shall be avoided, to the greatest extent possible, during the nesting season of potentially occurring native and migratory bird species (generally September 15 to February 15 for songbirds; September 1 to January 14 for raptors, although the nesting season may be extended due to weather and drought conditions).

If site preparation activities are proposed during the nesting/breeding season, the project proponent shall retain a qualified avian biologist to conduct a pre-activity field survey prior to the issuance of grading permits for the project to determine if active nests of species protected by the MBTA or the California Fish and Game Codes are present in the construction zone. The nest surveys shall include the project site where project activities have the potential to cause nest failure. The survey results shall be provided to the City of Redlands for review and approval. The project applicant shall adhere to the following:

1. The project applicant shall retain a qualified biologist experienced in: identifying local and migratory bird species of special concern; conducting bird surveys using appropriate survey methodology; nesting surveying techniques, recognizing breeding and nesting behaviors, locating nests and breeding territories, and identifying nesting stages and nest success; determining/establishing appropriate avoidance and minimization measures; and monitoring the efficacy of implemented avoidance and minimization measures.

2. Pre-activity field surveys shall be conducted at the appropriate time of day/night, during appropriate weather conditions, no more than three days prior to the initiation of project activities.

Surveys shall encompass all suitable areas including trees, shrubs, bare ground, burrows, cavities, and structures. Survey duration shall take into consideration the size of the property; density, and complexity of the habitat; number of survey participants; survey techniques employed; and shall be sufficient to ensure the data collected is complete and accurate.  SECTION 4.3 – BIOLOGICAL RESOURCES 
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If no nesting birds are observed during the survey, site preparation and construction activities may begin.

However, if active nests (including nesting raptors) are located, then avoidance or minimization measures shall be undertaken in consultation with the City of Redlands, CDFW and USFW, as warranted.

Measures shall include immediate establishment of an appropriate buffer zone to be established by a qualified biologist based on their best professional judgement and experience. The buffer around the nest shall be delineated and flagged, and no construction activity shall occur within the buffer area until a qualified biologist determines nesting species have fledged and the nest is no longer active, or the nest has failed. The biologist shall monitor the nest at the onset of project activities and at the onset of any changes in such project activities (e.g., increase in number or type of equipment, change in equipment usage, etc.) to determine the efficacy of the buffer. If the biologist determines that such project activities may be causing an adverse reaction, the biologist shall adjust the buffer accordingly or implement alternative avoidance and minimization measures, such as redirecting or rescheduling construction or erecting sound barriers. All work within these buffers will be halted until the nesting effort is finished (i.e., the juveniles are surviving independent from the nest). The onsite biologist shall review and verify compliance with these nesting avoidance buffers and shall verify the nesting effort has finished. Work can resume within these avoidance areas when no other active nests are found.

Birds or their active nests will not be disturbed, captured, handled or moved. Active nests cannot be removed or disturbed; however, nests can be removed or disturbed if determined inactive by a qualified biologist.

If listed bird species are observed within a project site during the preconstruction survey, the biologist will immediately map the area and notify the appropriate resource agency to determine suitable protection measures and/or mitigation measures and to determine if additional mitigation is necessary. Project activities may begin within the area only when concurrence is received from the appropriate resource agency.

Upon completion of the survey and nesting bird monitoring, a report shall be prepared and submitted to City of Redlands for review and approval prior to initiation of construction activities.

MM BIO-4: Preconstruction Bat Survey
Prior to implementation of project activities, a qualified bat biologist shall be retained to determine whether potential roosting sites for yellow bats may be affected. For large ornamental trees and palms suitable for bat roosting/nursery, exit counts and acoustic surveys shall be performed prior to initial ground disturbance, vegetation or structure removal to determine whether the project site and a 300-foot buffer supports a nursery or roost. This work will occur between late -spring and late summer and/or in the fall (generally mid-March through late October).

If the results of the bat survey find a total of a single roosting individual of a special status bat species or 25 or more individuals of a non-special status bat species with potential to be present in the project site, a Bat Management Plan shall be developed by a qualified bat biologist to ensure mortality to bats does not occur. For each location confirmed to be occupied by bats, the Bat Management Plan must provide details both in text and graphically where exclusion devices/and or staged tree/palm removal will need to occur, the timing for exclusion work and the timeline and methodology needed to exclude the bats. The plan will need to be reviewed and approved by the City of Redlands and CDFW prior to disturbance of the roosts. The Bat Management Plan shall include:

1. Bat status, distribution and habitat information within and adjacent to the project site.  SECTION 4.3 – BIOLOGICAL RESOURCES 
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2. Results of the bat surveys.

3. Project-specific measures for noise attenuation devices, acoustic and visual monitoring during high-vibration and sound activities (such as saw cutting, jackhammering, and pile driving), visual disturbance buffers, and the installation of bat exclusion devices to safely and humanely evict bats outside of the maternity season, in the event they are needed.

4. Exclusion methods may include use of one-way doors at roost entrances (bats may leave, but not re enter), or sealing roost entrances when the site can be confirmed to contain no bats. Exclusion efforts may be restricted during periods of sensitive activity (e.g., during hibernation or while females in maternity colonies are nursing young).

5. If roosts cannot be avoided or it is determined that construction activities may cause roost abandonment, such activities may not commence until permanent, elevated bat houses have been installed outside of, but near the construction area. Placement and height will be determined by a qualified wildlife biologist, but the height of bat house will be at least 15 feet. Bat houses will be multi-chambered and be purchased or constructed in accordance with CDFW standards. The number of bat houses required will be dependent upon the size and number of colonies found, but at least one bat house will be installed for each pair of bats (if occurring individually), or of sufficient number to accommodate each colony of bats to be relocated.

6. Consultation with the California Department of Fish and Wildlife would occur to finalize preparation of the Bat Management Plan for inclusion in other permits that are required from the CDFW, such as a Lake or Streambed Alteration Agreement (LSAA) under Section 1600-1616 of the Fish and Game Code. Each LSAA usually contains a section titled Measures to Protect Fish and Wildlife Resources, for which this plan would be incorporated.

7. A description of incidental monitoring and reporting that will take place during construction.

8. Details for post-construction monitoring.

9. Note that the Bat Management Plan is triggered only if the project requires high-vibration and sound activities causing shaking or vibration, generally resulting from saw cutting, jackhammering, pile driving, or similar activities (within 150 feet of a bat colony).

MM BIO-5: Jurisdictional Delineation and Permitting
Prior to approval of grading permits and initiation of project activities, a qualified biologist shall conduct a formal jurisdictional delineation on the project site to determine the presence/absence of jurisdictional resources, extent of jurisdictional areas, and impacts to resources regulated by the USACE, RWQCB, and CDFW. The delineation shall be conducted using the current USACE methods and definition of “waters of the U.S.” (most current as of this writing is March 2025 notice and data sheets) and the methods and wetland definitions specified in the California State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (Procedures)(SWRCB, 2019) to delineate waters of the state.
 SECTION 4.3 – BIOLOGICAL RESOURCES 
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Upon completion of the jurisdictional delineation survey, a jurisdictional delineation report shall be prepared according to the Minimum Standards for Acceptance of Aquatic Resources Delineation Reports for the USACE, Los Angeles Regulatory District (USACE-LA, 2017). This report shall be submitted to City of Redlands for review and approval.

If jurisdictional areas are present on the project site, the project applicant shall obtain a Clean Water Act Section 404 permit, California Fish and Game Code Section 1602 Lake or Streambed Alteration Agreement from CDFW and a CWA 401 or WDR permit issued by the RWQCB (Santa Ana RWQCBRegion 8) pursuant to the California Water Code § 13260, as warranted. If required, these permits shall be obtained prior to issuance of a grading permit. Construction activities (including but not limited to fencing, staging, and clearing) will not commence unless all requirements of the USACE, CDFW, RWQCB have been met and the RWQCB has issued a WDR permit, letter of permission, or other project-specific approval. All conditions of these permits shall be adhered to during project development.

4.3.8 Level of Significance After Mitigation
Impacts would be less than significant with mitigation.  SECTION 4.4 – CULTURAL RESOURCES 
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4.4 Cultural Resources

4.4.1 Introduction
This section provides an overview of cultural resources that may be present within the study area.

Cultural resources are artifacts of human activity, occupation, or use (see Appendix D1 for UltraSystems’ Cultural Resources Inventory report). They include expressions of human culture and history in the physical environment, such as archaeological sites, historic buildings and structures, or other culturally significant places. This section also provides an analysis of the project’s potential impacts on historic resources that could result from development of the proposed project. The analysis is based on investigations of the project site by cultural resources and historical resources specialists. This section is based on record searches and other investigation methods provided in Appendix D1.

Historic buildings and structures generally must be 50 years or older and are typically identified through archival and library research, followed by field reconnaissance and recordation. Historic buildings and structures are architecturally, historically, or artistically important individual and groups of residential, commercial, industrial, and transportation properties.

Archaeological resources refer to surface or buried material remains, buried structures, or other items used or modified by people. Prehistoric archaeological resources predate European presence in the Riverside County region, and can include villages or campsites, food remains, basketry fragments, shell and stone tools and tool-making debris. Ethnohistoric or protohistoric archaeological resources are those that can be attributed to native cultures, but include evidence of European contact, such as trade beads or other goods in a site that otherwise appears to be prehistoric. Historic archaeological sites are those deposits that post-date European contact.

Traditional cultural properties (TCPs) are places associated with the cultural practices or beliefs of a living community. The significance of these places is derived from the role the property plays in a community’s cultural identity, as defined by its beliefs, practices, history, and social institutions.

Examples include natural landscape features, plant gathering places, sacred sites, and Native American burial locations.

4.4.2 Regulatory Framework
The treatment of cultural resources is governed by federal, state, and local laws and guidelines. There are specific criteria for determining whether prehistoric sites or objects are significant and thus protected by law. Federal and state significance criteria generally focus on the integrity and uniqueness of the resource, its relationship to similar resources, and its potential to contribute information that is important to scholarly research. Some resources that do not meet federal significance criteria may be considered significant by state criteria. The laws and regulations seek to mitigate project impacts on significant prehistoric and historical-period resources.

Federal
National Historic Preservation Act (NHPA) of 1966
The NHPA of 1966 authorized the National Register of Historic Places (NRHP) and coordinates public and private efforts to identify, evaluate, and protect the Nation’s historic and archaeological resources. The NRHP includes districts, sites, buildings, structures, and objects that are significant in  SECTION 4.4 – CULTURAL RESOURCES 
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American history, architecture, archaeology, engineering, and culture. Section 106 (Protection of Historic Properties) of the NHPA requires federal agencies to take into account the effects of projects on historic properties.

National Register of Historic Places
The National Register is “an authoritative guide to be used by Federal, State, and local governments, private groups and citizens to identify the Nation’s cultural resources and to indicate what properties should be considered for protection from destruction or impairment.” (Title 36 Code of Federal Regulations, Part 60.2)
Criteria
The National Historic Preservation Act, enacted in 1966, established the National Register of Historic Places program under the Secretary of the Interior. The National Register established four criteria to evaluate significance and eligibility for listing. They are:

1. Property is associated with events that have made a significant contribution to the broad patterns of our history.

2. Property is associated with the lives of persons significant in our past.

3. Property embodies the distinctive characteristics of a type, period, or method of construction or represents the work of a master, or possesses high artistic values, or represents a significant and distinguishable entity whose components lack individual distinction.

4. Property has yielded, or is likely to yield, information important in prehistory or history. (NPS 1997).

Context
To qualify for the National Register, “a property must be significant; that is, it must represent a significant part of the history, architecture, archaeology, engineering, or culture of an area, and it must have the characteristics that make it a good representative of properties associated with that aspect of the past.”(NPS 1997:7). Additionally, National Register Bulletin #15 states that the significance of a historic property can be judged and explained only when it is evaluated within its historic context. The Bulletin defines Historic contexts as:
“…historical patterns that can be identified through consideration of the history of the property and the history of the surrounding area” (NPS 1997:7). a) Integrity
In addition to context, a property must have integrity, which is defined as: “…the ability of a property to convey its significance” (NPS 1997:44). The seven aspects of integrity include; location, design, setting, materials, workmanship, feeling, and association. “To retain historic integrity a property will always possess several, and usually most, of the aspects” (NPS 1997:44).
 SECTION 4.4 – CULTURAL RESOURCES 
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b) Historic Districts
A Historic District “…possesses a significant concentration, linkage, or continuity of sites, buildings, structures, or objects united historically or aesthetically by plan or physical development. A district derives its importance from being a unified entity, even though it is often composed of a wide variety of resources. The identity of a district results from the interrelationship of its resources, which can convey a visual sense of the overall historic environment or be an arrangement of historically or functionally related properties” (NPS 1997:5).

As detailed in Title 36 of the Code of Federal Regulations Part 60.3(d): A District is a geographically definable area, urban or rural, possessing a significant concentration, linkage, or continuity of sites, buildings, structures, or objects united by past events or aesthetically by plan or physical development. A district may also comprise individual elements separated geographically but linked by association or history.

The Secretary of the Interior's Standards for the Treatment of Historic Properties (36 CFR Part 68)
The Secretary of the Interior’s Standards for the Treatment of Historic Properties (Standards) apply to all grants-in-aid projects assisted through the Historic Preservation Fund (authorized by the NHPA) and are meant to be applied to a range of resource types, including buildings, sites, structures, objects, and districts. These Standards address four treatments: preservation, rehabilitation, restoration, and reconstruction. The purpose of Standards is to provide guidance to historic building owners and building managers, preservation consultants, architects, contractors, and project reviewers prior to beginning work. These regulations focus on “certified historic structures” as defined by the IRS Code of 1986 and are used in the Preservation Tax Incentives Program. Guidelines, were developed to assist with applying the Standards to specific types of historic resources including historic buildings, cultural landscapes, historic lighthouses, historic vessels, historic furnished interiors, and historic bridges. The guidelines focus on four treatment Standards: Preservation, Rehabilitation, Restoration, and Reconstruction. Each section includes one set of Standards with accompanying Guidelines that are to be used throughout the course of a project (Grimmer, Anne E., 2017).

State
California Register of Historical Resources (Public Resource Code § 5024.10 et seq.) State law protects cultural resources by requiring evaluations of the significance of historical resources in CEQA documents. A cultural resource is an important historical resource if it meets any of the criteria found in § 15064.5(a) of the State CEQA Guidelines. These criteria are similar to those used in federal law. The California Register of Historical Resources (CRHR) is maintained by the state Office of Historic Preservation. Properties listed, or formally designated eligible for listing, on the NRHP are automatically listed on the CRHR, as are state historical landmarks and points of interest.

The CRHR also includes properties designated under local ordinances or identified through local historical resource surveys.

As detailed in Public Resources Code § 5024.1, the California Register is an authoritative guide in California to be used by state and local agencies, private groups, and citizens to identify the state’s  SECTION 4.4 – CULTURAL RESOURCES 
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historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change.

For purposes of CEQA, a historical resource is any object, building, structure, site, area, place, record, or manuscript listed in or eligible for listing in the CRHR (PRC § 21084.1). A resource is eligible for listing in the CRHR if it meets any of the following criteria:

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

2. Is associated with the lives of persons important in our past;

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

4. Has yielded, or may be likely to yield, information important in prehistory or history.

Properties formally determined eligible for the NRHP are automatically listed in the CRHR.

The California Code of Regulations (CCR) further provides that cultural resources of local significance are CRHR-eligible (Title 14 CCR, § 4852).

California Environmental Quality Act (CEQA)
CEQA requires the lead agency to consider whether the Project will have a significant effect on unique archaeological resources and to avoid unique archaeological resources when feasible or mitigate any effects to less-than-significant levels per California Public Resources Code (PRC) § 21083.2. CEQA (PRC § 21083.2(g)) defines a unique archaeological resource as an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:

5. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information.

6. Has a special and particular quality such as being the oldest of its type or the best available example of its type.

7. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

CEQA Guidelines (Title 14 of the California Code of Regulations § 15064.5) states that historical resources include:

8. A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Public Resources Code § 5024.1, Title 14 CCR, Section 4850 et seq.);

9. A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code or identified as significant in an historical  SECTION 4.4 – CULTURAL RESOURCES 
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resource survey meeting the requirements of section 5024.1(g) of the Public Resources Code; and

10. Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historic resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record.

The fact that a resource is not listed in or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources, or identified in an historical resources survey does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code §§ 5020.12(j) or 5024.1.

A significant impact would occur under CEQA if the project results in a substantial adverse change in the significance of a historical resource as defined in § 15064.5(a). A substantial adverse change in the significance of a historical resource, per CEQA Guidelines, means: “…physical demolition, destruction, relocation, or alternation of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired. “ The significance of an historical resource is materially impaired when a project:
(A) Demolishes or materially alters in an adverse manner those physical characteristics of an historical resources that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources; or (B) Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the Public Resources Code or its identification in an historical resources survey meeting the requirements of section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or (C) Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA
Section 15064.5(b)(3) of CEQA states that: “Generally, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer, shall be considered as mitigated to a level of less than a significant impact on the historical resource.”
Human Remains
According to § 15064.5 of the State CEQA Guidelines, all human remains are a significant resource. § 15064.5 of the State CEQA Guidelines also assigns special importance to human remains and  SECTION 4.4 – CULTURAL RESOURCES 
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specifies procedures to be used when Native American remains are discovered. These procedures are discussed within PRC § 5097. Per PRC § 5.97.98(a): Whenever the commission receives notification of a discovery of Native American human remains from a county coroner pursuant to subdivision (c) of § 7050.5 of the Health and Safety Code, it shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The decedents may, with the permission of the owner of the land, or his or her authorized representative, inspect the site of the discovery of the Native American remains and may recommend to the owner or the person responsible for the excavation work means for treating or disposing, with appropriate dignity, the human remains and any associated grave goods. The descendants shall complete their inspection and make their recommendation within 24 hours of their notification by the Native American Heritage Commission. The recommendation may include the scientific removal and nondestructive analysis of human remains and items associated with Native American burials.

California Public Resources Code § 5097.98
California Senate Bill 297 (1982) addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American skeletal remains are discovered during construction of a project; and establishes the Native American Heritage Commission to resolve disputes regarding the disposition of such remains. It has been incorporated into § 15064.5(e) of the State CEQA Guidelines.

California Health and Safety Code
The California Health and Safety Code § 7050.5 states that if human remains are discovered during construction on a project’s site, no further disturbance shall occur until a county coroner makes a determination of origin and disposition of the remains. If the county coroner determines the remains are not subject to his or her authority and recognizes the remains to be those of Native American, the county coroner must contact the Native American Heritage Commission within 24 hours.

Local
City of Redlands Historical Resources
The City of Redlands has taken an active interest in preserving its historic resources. The Historic and Scenic Preservation Commission, established in 1976, advises the City Council regarding designation and protection of historic resources. Resources are designated through a nomination process in which a nominated resource is reviewed by the Historic and Scenic Preservation Commission and approved by the Redlands City Council. City-designated historic resources are identified in the City of Redlands Development Services Department List of Historic Resources. Local, State, and national historic resources mapped in the city include the area surrounding Downtown and Colony, where the city’s historic resources are more highly concentrated.

Historic and Scenic Preservation Ordinance
The City of Redlands adopted a Historic and Scenic Preservation Ordinance in 1986 to strengthen historic resource protection in Redlands. The ordinance is included as Chapter 2.62 of the Municipal Code. The ordinance gives authority to the Historic and Scenic Preservation Commission to make recommendations, decisions, and determinations regarding the designation, preservation, protection, and enhancement of historic resources. The Commission also has the authority to deny  SECTION 4.4 – CULTURAL RESOURCES 
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demolition, except in cases of proven hardship, and to designate without owner consent. In addition, the provisions of Redlands’ design guidelines apply to any kind of alteration, enhancement, or demolition to historic landmarks, historic properties, and historic and/or scenic districts and are subject to the review of the City in accordance with the ordinance.

Scenic Corridors
The City Council has designated a number of streets within the city as scenic highways, drives, and historic streets. Special development standards have been adopted by resolution for these streets.

4.4.3 Methodology
UltraSystems searched for the presence of historic properties within the Area of Potential Effects (APE) through background research, desktop visual inspections of the APE, pedestrian survey and tribal consultation. Specific identification efforts for this undertaking are discussed below. The APE (Figure 4.4-1) includes the project footprint. Ground disturbance would occur in areas that were previously disturbed by farming and related activities.

The Cultural Resources Inventory Report for the City of Redlands Kaiser Permanente Medical Center Project site includes background information gathered from the CHRIS records and literature search at the SCCIC located at the California University Fullerton that includes the APE encompassing the project boundary, as well as a 0.5-mile buffer surrounding the APE.

A request was made to the Native American Heritage Commission (NAHC) on June 8, 2023 to conduct a search of their Sacred Lands File (SLF) for potential traditional cultural properties as well as to provide a list of local Native American tribal organizations to contact, following which outreach letters were sent to the listed tribes. The NAHC replied on July 13, 2023 noting a positive response to the SLF search and with a list of 38 Tribes and Native American contacts to contact. Outreach letters were sent to the tribes on October 3, 2023. None of the tribal responses indicated the presence of known cultural resources at or near the project site or provided information on the SLF site. Three of the tribes did express concerns regarding potential nearby traditional cultural resources. The San Manuel Band of Serrano Indians stated that they consider the project site to be sensitive to the tribe due to its proximity to the footprint of the Mill Creek Zanja, an historic waterway listed on the NRHP which had been built using Serrano labor; also, the Soboba Band of Luiseño Indians noted they had concerns for the project area. The Gabrielino-Tongva San Gabriel Band of Mission Indians stated that there are known prehistoric archaeological sites in the project area and that the I-10 freeway (one mile to the south) stems from a traditional transportation route. The Morongo Band of Mission Indians consider the project area to be highly sensitive for cultural resources and will be requesting government-to-government AB 52 consultation. Also, the Gabrielino Tongva Indians of California Tribal Council recommended the presence of a Native American monitor during ground disturbing construction activities. (See Section 4.2 and Attachment C in Appendix D1).

A pedestrian survey was conducted on November 6, 2023. The survey consisted of walking, visually inspecting, and photographing the exposed ground surface and landscaped areas throughout the project site using standard archaeological procedures and techniques.

 SECTION 4.4 – CULTURAL RESOURCES 
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Figure 4.4-1

USGS TOPOGRAPHIC MAP OF THE STUDY AREA
Disclaimer: Representations on this map or Illustration are Intended only to Indicate locations of pro}ect parameters reported in the legend. Project parameter Information supptied by others (see layer credits) may not have been independently verified for accuracy by UltraSystems Environmental, Inc. This map or illustration should not be used for, and does not replace, final grading plans or other documents that shouk1 be professionally certified for development purposes.

Path: \\Glssvl'\gls\Pro}ecls\7214_Redlands_Kaiser_MedCenter_EIR\MXOs\77214_Kalser_ 4_5_ Topo_2022_05_25.mKd May 25, 2023 Service Layer Credits: Sources: Esri, HERE, Garmin, USGS. lntermap. INCREMENT P, NRCan, Esri Japan, METI , Esri China (Hong Kong), Esn Korea, Esri (Thailand~ NGCC , (c) OpenStre:etMap contributors . and the GIS User Community. Sources: Esri, HERE, Garmin, lnlermap, increment P Corp., GEBCO, USGS, FAQ, NPS, NRCAN , GeoBase, IGN , Kadaster NL Ordnance Survey, Esri Japan , METI, Esri China (Hong Kong), (c) OpenStreetMap contriiutors , and the GIS User Community. CopyrightO 2013 National Geographic Society, kubed; CA Dept. of Conservation, May 2019: UllraSystems Environmental, Inc ., 2022 Kaiser Permanente
Medical Center
Scale : 1 :24,000 N
0 1,000 2,000 Feet
0 250 500 Meters
Legend
D Project Boundary
Half-Mile Radius
~ Quadrangle Boundary
c-------:, Township Boundary
~ Section Boundary
Topographic Map
USGS Quadrangle: Redlands
Township: 1S Range : 3W
Section: 19
 SECTION 4.4 – CULTURAL RESOURCES 
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The vacant portion of the project parcel is L-shaped and consists of open flat land except for a water retention basin approximately 10 feet deep in the northwest corner. A current Kaiser Medical Center building occupies the southeast corner of the larger lot surrounded by the L-shaped parcel to the north and west. The parcel is bordered by Almond Avenue along the north edge, California Street along the east, West Lugonia Avenue along the south boundary, and a warehouse building to the west.

The survey consisted of walking north/south transects at 15-meter intervals. In the north half the transects started in the northeast corner and progressed to the west. In the south half of the parcel the transects started in the southeast corner and progressed to the west. The basin in the northwest corner was observed by walking the semi-circular periphery.

The northern half of the parcel was covered by dense vegetation consisting of tumble weeds, aka Russian thistle (Salsola tragus), along the north and east edges and in large patches scattered throughout, as well as large areas covered by both dead and living black and tansy mustard (Brassica nigra and Desurainia pinnata), cheeseweed (Malva parviflora), various Chenopod family and other ground-cover plants as well as various shrubs, consisting predominantly of non-native invasive species. Also, there were areas that had been covered by chipped wood. It is estimated that the visible ground surface in this north half is approximately 15 percent. It was observed that the entire area had been disked within the past year or so along the east/west axis for managing the vegetation.

The southern half of the parcel was also covered by dense vegetation consisting of tumble weeds along the east, south and west edges that covered up to one-third of the surface, as well as large areas covered by mustard, various Chenopod plants, portulaca (Portulaca oleracea) and other non-native groundcover, and various shrubs. It is estimated that the visible ground surface in the southern half is approximately five percent. It was observed that the entire area had been disked within the past year or so along the north/south axis for managing vegetation.

Along with the herbaceous plants, the shrubs here consisted of scattered mule fat (Baccharis salicifolia), tree tobacco (Nicotiana glauca), tamarisk (Tamarix sp.), and a single willow (Salix sp.).

Numerous signs of coyote (Canis latrans) were observed throughout the parcel; there was, however, no direct sign of rabbits or hares. The soil was observed to be of silty greyish-tan consistency with little or no gravel or rocks. This is consistent with the known local geology (see Section2.1 in Appendix D1).

No prehistoric or historic features or isolate artifacts were observed. Given the extremely poor surface visibility it cannot be ruled out that cultural resources may be present. However, the features of the Marigold Farms complex, recorded in 1991 and 2012 (see Section 4.1.1 in Appendix D1) were located in what is now Almond Avenue and parcel to the north west of California Street (Section 2.2.3 in Appendix D1), and so would have been demolished when Almond Avenue and the intersection was expanded between 2002 and 2005 and when the warehouse was built on the lot to the north.

Nonetheless it is believed that any building foundations, if remaining, would have been apparent during the survey and none were observed. A large, apparently old Chinaberry tree (Melia aszedarach) (aka white cedar), an ornamental, is present in the northeast corner along Almond Avenue; this tree can be seen in aerial photos at the south edge of the Marigold Farms complex from at least 1938 onward (Section 2.2.3.3 in Appendix D1).

It is recommended that the parcel be resurveyed when brush is removed from this portion of the construction area for construction and the ground surface is made visible.  SECTION 4.4 – CULTURAL RESOURCES 
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4.4.4 Existing Conditions

4.4.4.1 Natural Setting
The City of Redlands is located in the southwest portion of the San Bernardino Valley. This is a broad inland valley defined by the San Gabriel and San Bernardino Mountain Ranges to the north and is ringed by a series of low rocky hills to the south. The region’s environment is characterized by a temperate Mediterranean climate, with the average maximum temperature in July reaching 89 degrees Fahrenheit (°F) and the average minimum temperature in January at around 42°F. Rainfall is typically less than 15 inches annually, most of which occurs between November and March.

The project site boundary is underlain by Surficial Sediments (Qa) (Dibblee, 2004), consisting of Alluvial and clay in valley areas covered with grey soil, including alluvia pebbly sand adjacent to mountain terrain. These soils date to the Holocene (11,650 years before present [ybp]) (Dibblee, 2004). The project site is at an elevation ranging from approximately 1,145 to 1,160 feet above mean sea level (AMSL) with a gentle slope to the west.

The city of Redlands encompasses 36.24 square miles. It is bordered by the cities of Highland to the north, San Bernardino to the northwest, Loma Linda to the southwest, Yucaipa to the east, and unincorporated San Bernardino County lands to the north and northeast, as well as by Riverside County to the south. At the 2020 census the population was 73,170; by mid-2022 the population had grown to an estimated 73,849 (U.S. Census 2023). (See Section 2.1 in Appendix D1 for references.)

4.4.4.2 Archaeological Setting
Prehistoric Overview
The earliest evidence of human occupation in the Inland Empire region (consisting of the southwestern corner of San Bernardino and western Riverside counties) was discovered below the surface of an alluvial fan in the northern portion of the Lakeview Mountains, overlooking the San Jacinto Valley, dating to around 9,500 radiocarbon years (rcy) before present (B.P.) (before present = A.D. 1950) (Horne and McDougall, 2008). Another prehistoric archaeological site found near the shoreline of Lake Elsinore, close to the confluence of Temescal Wash and the San Jacinto River, dates between 8,000 and 9,000 B.P. (Grenda, 1997). Additional sites with isolated Archaic dart points, bifaces, and other associated flaked stone artifacts are considered to be from the same age range and have been found in the Cajon Pass area, typically atop knolls with good viewsheds (Basgall and True, 1985; Goodman, 2002; Goodman and McDonald, 2001). (See Section 2.2.1 in Appendix D1 for references.)
The regional prehistory of Southern California has been characterized by various cultural chronologies, including those developed by Chartkoff and Chartkoff (1984), Warren (1984), and others. Specifically, the prehistory of the Inland Empire region has been addressed by O’Connell et al., (1974), Keller et al., (1989), Grenda (1993), and Horne and McDougall (2008). Although the beginning and ending dates of different cultural periods vary, the regional framework can be generally broken into four primary periods:

Paleoindian and Lake Mojave (Terminal Pleistocene and Early Holocene) (ca. 11000 to 6000 calibrated years [cal] B.C.). This time period is characterized by highly mobile foraging strategies and a broad spectrum of subsistence pursuits. These earliest expressions of aboriginal occupation in America were marked by the use of large projectile points (Fluted  SECTION 4.4 – CULTURAL RESOURCES 
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and Concave Base Points) that are an element of the Western Clovis expression. Following the earliest portions of this time span there was a change in climate coincident with the retreat of glaciers. Large bodies of water existed, and lakeside aboriginal adaptations were common. Large, stemmed points (Western Stemmed – Lake Mojave and Silver Lake) accompanied by a wide variety of formalized stone tools were employed with the aid of atlatls (dart throwers) and are representative of an adaptation that was in part focused on lacustrine environments.

Millingstone Horizon (ca. 6000 cal B.C. to cal A.D. 1000), during which time mobile hunter-gatherers became more sedentary and plant foods and small game animals came into more use. This prehistoric cultural expression is often characterized by a large number of millingstones (especially well-made, deep basin metates) and formalized, portable handstones (manos). Additionally, the cultural assemblage is dominated by an abundance of scraping tools (including scraper planes and pounding/pulping implements), and only a slight representation of dart-tipped projectile points (Pinto, Elko and Gypsum types).

Late Prehistoric Period (ca. cal A.D. 1000 to 1500), during which a more complex social organization, more diversified subsistence base and an extensive use of the bow and arrow is evidenced. Small, light arrow points, expedient millingstones and, later, pottery mark this period along with the full development of regional Native cultures and tribal territories.

Protohistoric Period (ca. cal A.D. 1500 to 1700s) ushered in long-distance contacts with Europeans, and thereby led to the Historic Period (ca. cal A.D. 1700 to contemporary times).

Small arrow points are recognized as a hallmark of this time period.

Geospatial analyses of known prehistoric sites in inland Southern California suggest that longer-term residential settlements of the Native population were more likely to occur in sheltered areas. Such locations were near the base of hills and/or on elevated terraces, hills, and finger ridges. Further, these favored locations were near permanent or reliable sources of water. These were areas that were largely level encampments situated on the unprotected valley floor. The residential sites were used for resource procurement and travel. The use of such geographical settings is supported by the ethnographic literature. These reports identify the foothills as preferred areas for settlement (Bean and Smith, 1978a; 1978b).

4.4.4.3 Ethnohistoric Overview
Prior to European contact, the indigenous peoples who resided in modern-day San Bernardino County were the Tongva (Gabrielino), and Taaqtam (Serrano) peoples who lived in the San Bernardino Valley and the San Bernardino Mountains. Bean and Smith (1978a:538; 1978b:570) and Johnston (1962) indicate that “…the historic-era border between the Gabrielino and Serrano at San Bernardino [town]. It is likely that both groups used the territories within the project area during the sixteenth to nineteenth centuries…” (Foster et al. 1991:11). (See Section 2.2.2 in Appendix D1 for references.)
Gabrielino/Tongva
The project lies within the territory of the Gabrielino (Tongva) ethnolinguistic group (Bean and Smith, 1978a:538), who speak a language classified as a member of the Uto-Aztecan language family.

This language is further affiliated as an element of the Northern Takic Branch of that linguistic group (Golla, 2011).
 SECTION 4.4 – CULTURAL RESOURCES 
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The Gabrielino, with the Chumash, were considered the most populous, wealthiest, and therefore most powerful ethnic nationalities in aboriginal Southern California (Bean and Smith, 1978a:538).

Unfortunately, most Gabrielino cultural practices had declined before systematic ethnographic studies were instituted. Today, the leading sources on Gabrielino culture are Bean and Smith (1978a), Johnston (1962), and McCawley (1996).

According to recent research, Takic groups were not the first inhabitants of the region. Archeologists suggest that a Takic in-migration may have occurred as early as 2,000 years ago, resulting in the Takic groups replacing or intermarrying with a more ancient indigenous people represented by speakers of a Hokan language (Howard and Raab, 1993; Porcasi, 1998). By the time of European contact, the Gabrielino territory included the southern Channel Islands and the entire Los Angeles Basin. Their territory reached to the west along the Pacific Coast to Malibu, north and east to the foothills of the San Gabriel Mountains, to the southeast into the present-day San Bernardino-Riverside area and south to the San Joaquin Hills in central Orange County.

Different groups of Gabrielino adopted several subsistence strategies, based on gathering, hunting, and fishing. Because of the similarities to other Southern California tribes in economic activities, inland Gabrielino groups' industrial arts, exemplified by basket weaving, exhibited an affinity with those of their neighbors (Kroeber, 1925). Coastal Gabrielino material culture, on the other hand, reflected an elaborately developed artisanship most recognized through the medium of steatite, which was rivaled by few other groups in Southern California.

Occasionally several villages were allied under the leadership of a single chief. The villages frequently engaged in warfare against one another, resulting in what some consider to be a state of constant enmity between coastal and inland groups.

The City of Redlands is situated within the eastern periphery of the Tongva culture area. The central Tongva land was the Los Angeles Basin; however, it extended east to include portions of the San Bernardino Valley. In the San Bernardino Valley, the Tongva’s neighbors were the Serrano on the north and the Cahuilla farther east. Away from the Santa Ana River this area was not well watered.

Therefore, this portion of the territory was not as densely populated as the coastal territory.

The San Bernardino Valley contains the northeastern region of Gabrielino territory, with upwards of eight major communities located throughout (McCawley 1996:48). The village of Wa’aachnga, also spelled Kaawchama, was somewhat west of Redlands (McCawley, 1996:50). It is also the site of the San Bernardino Asistencia of Mission San Gabriel built in 1820 (Engelhardt 1931) in what was later called Old San Bernardino. Somewhat to the southwest of Redlands, ”southeast of Colton between the southerly bank of the Santa Ana River and the base of the foothills” (Shinn 1941, cited in McCawley 1996:50) was the native community of Homhoa. Both of these villages were located either along the Santa Ana River (Wa’aachnga) or a tributary to it (Homhoa). In the late Mission Period or just thereafter, much of the region was populated by the Serrano (Bean and Smith, 1978b), who migrated into the area following the removal of the Gabrielino to Mission San Gabriel.  SECTION 4.4 – CULTURAL RESOURCES 
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The first Franciscan establishment in Gabrielino territory and the broader region was Mission San Gabriel, founded in A.D. 1772. Priests from the mission proselytized the Tongva throughout the Los Angeles Basin. As early as 1542, however, the Gabrielino were in peripheral contact with the Spanish even during the historic expedition of Juan Rodríguez Cabrillo. However, it was not until 1769 that the Spaniards took steps to colonize the territory of aboriginal Californians. Within a few decades, most of the Gabrielino were incorporated into Mission San Gabriel and other missions in Southern California (Engelhardt, 1931). Due to introduced diseases, dietary deficiencies, and forceful reducción (removal of non-agrarian Native populations to the mission compound), Gabrielino population dwindled rapidly from these impacts. By 1900, the Gabrielino community had almost ceased to exist as a culturally identifiable group. In the late 20th century, however, a renaissance of Native American activism and cultural revitalization of Gabrielino descendants took place. Among the results of this movement has been a return to a traditional name for the tribe, the Tongva, which is employed by several of the bands and organizations representing tribal members. Many of the Tongva bands focus on maintaining and teaching traditional knowledge, with special emphasis on language, place names and natural resources, and preservation of ancestral sites.

Serrano
The City of Redlands is also situated within the southeastern periphery of the Serrano culture area.

Research by Earle (1990, 1997, 2004a, 2004b, 2005a, 2005b), King (2003), and Johnson and Lorenz (2006) have helped to clarify the ethnic identification of the San Gabriel / San Bernardino mountains and Mojave Desert Native American groups. Their work with the John Peabody Harrington notes, combined with analysis of the Franciscan sacramental registries, confirm ethnographic records (Benedict 1924, Kroeber 1925, Strong 1929) that the inhabitants of the project area were speakers of a dialect of Serrano. It has been determined that Native groups occupying villages in the San Bernardino Mountains and adjacent Moreno Valley region maintained marriage ties to surrounding region and the foothills extending into the San Bernardino and San Jacinto Valleys inhabited by Cahuilla and Luiseno were also Serrano in ethnic and linguistic affiliation.

Earle (1990, 1997) supports King’s revisions of earlier territorial boundaries asserting that Serrano territory included the San Bernardino Mountains and the northern slopes of the San Gabriel Mountains, the Mojave River, and Antelope Valley. It also appears from their research that both the south and north slopes of the San Gabriel Mountains were “owned” and occupied by Serrano speakers.

Early 20th century ethnographic fieldwork among the Serrano was conducted by Kroeber (1925), Gifford (1918), Strong (1929), Benedict (1924), and Harrington (1986). More recent research by Bean (1972), Bean and Smith (1978b), and Bean, et al. (1981) has helped to focus attention on key research questions in an attempt to clarify the relationship of Serrano land use patterns, territorial attributions, subsistence-settlement patterns, and social, ceremonial, and political organization.

The economic resource base of the Serrano was determined in part by the seasonal availability of key animals and plants exploited for basic subsistence (Earle 1992). Hunting activities supplemented a diet mainly emphasizing plants. Hunting excursions were usually an individual affair but also sometimes incorporated communal drives, and trap lines to snare small animals (e.g., rabbits, squirrels and rodents). Some desert hunting areas to the north in the Mojave Desert and in the vicinity of the Mojave River may have been shared with adjacent groups (e.g., Chemehuevi and/or Mojave).
 SECTION 4.4 – CULTURAL RESOURCES 
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Mule deer were available in the San Gabriel Mountains. Deer would migrate to lower elevations during the winter and would be available in the lower foothill region at that time. Pronghorn frequented the valley floors year-round but were not consistently abundant and were hunted only occasionally using communal surrounds and group drives. The latter communal drive technique was also used to ensnare large numbers of jackrabbits during the fall when the rabbits were especially abundant. Mountain sheep were available in the higher mountains but would only have been rarely procured. Waterfowl could be captured using bows and arrows and special nets. Ducks, quail, geese, and grebes would have been available in considerable numbers during their breeding seasons and in association with riparian settings.

Abundant stands of acorns, juniper, mesquite, and piñon were available to extended gathering expeditions into the mountains. These might involve several lineages collaborating under one leader’s authority and would have entailed accessing the resource base of surrounding groups (Bean and Smith 1978; Benedict 1924:391-392; Drucker 1937). Cattail / bulrush seeds (Typha spp. and Scirpus spp.), various roots, shoots, bulbs, and other hard seeds were all principal plant foods. The most likely plant resources that were of significant economic importance that have been identified paleobotantically or noted in the immediate vicinity of the Project were grasses (Poa ssp.), chia (Salvia columbariae), and goosefoot (Chenopodium spp.).

Various groundstone tools, including manos and metates, mortars and pestles used for grinding food were made by grinding granite, quartzite and other suitable rocks. Flaked tools including knives, spear and arrow points, and scarpers were made from crystalline lithics. Bone and antler were used to fashion other tools. Baskets were woven for use in gathering, storing and preparing foods, as well as hats for women. Other plant material was woven into bags, storage pouches, mats, nets and sandals.

Serrano houses were circular domes made of brush that had a central fire pit. Ramadas and ceremonial enclosures were also built. Granaries were woven, often of willow. Houses of several families tended to be clustered in small communities and located near springs or creeks, and often were centrally located at the nexus of several environments.

Edward W. Gifford conducted a detailed study of the marriage practices and sociopolitical organization of native southern California Native Americans during from 1916 through 1917 (Gifford 1918). Based on these studies, he developed a model of Serrano social organization (Earle 2004a, 2004b). William Duncan Strong (1929: 5-35) conducted additional extensive social organization studies among the Serrano, Cahuilla, Luiseño, and Cupeño in 1925. Strong indicated that the Serrano were an unusual California group in that they possessed true patrilineal clans. Patrilineal clans are patterned such that all males, their descendants, and their wives were part of a single group. Clans may be segmented into subclans or lineages. A woman retained her own lineage name but upon marriage was incorporated into the clan of her husband. The transfer of women from one ceremonial affiliation with one clan to another, upon marriage, was characteristic of all southern California Takic (a linguistic subfamily of Northern Uto-Aztecan) groups. The Serrano maintained an active moiety system -- their society was divided into two parts identified with either Coyote or Wildcat. The Coyote moiety had the most important political leaders. Moiety out-marriage excluded partners from half the neighboring Serrano settlements. Hence, only settlements of opposing moieties were interrelated through marriage.

Serrano villages in the mountain settings were generally less dispersed than in the desert. This nearer pattern resulted in marriages linking together very large areas. Many of the settlements had marriage ties with villages 10 - 20 miles away and counter intuitive was the fact that the closest relationships  SECTION 4.4 – CULTURAL RESOURCES 
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were not with the nearest villages – but rather with settlements affiliated with opposing moieties further distant.

King’s study of the Franciscan mission registers indicates that there were numerous important hereditary positions among the Serrano. Each village contained a chief, a ceremonial manager, two messengers, as well as various shamans, diviners, and other ritual specialists. Each of these leaders oversaw different elements of Serrano life involving festivals, dances, and warfare.

Ethnographic data attests that a major native trade and travel corridor facilitated a long-distance exchange system. Recent research has supported the importance of long-distance trade linking coastal southern Californian Tongva clans/villages with inland groups including the coastal Tongva and Luiseño/Acjachemen tribes in a route along the Santa Ana River (Earle 2005a, Strong 1929).

Shell bead trade was one of the mediums of exchange and was used as a kind of currency or money.

This system was significant since it involved trade, travel, and exchange covering hundreds of miles and was a system of exchange of native goods that linked various ethnic groups politically and economically.

Their primary trading partners were the Mojaves to the east and the Tongva to the west, but they also traded with their close neighbors, the Cahuilla and Chemehuevi. The Serrano were, in fact, a major nexus in a trade and exchange network that brought goods from the Southwest to the coast.

This trade and travel route ran from the American Southwest (principally the Hopi territory in Arizona), along the Colorado River to the Mojave River thence through the central Mojave Desert into the Antelope Valley and west to the Pacific Coast (Davis 1961; Farmer 1935; Sample 1950). These circuits of exchange cut across political and cultural boundaries. A number of researchers have argued that such an exchange system may have been an influential factor in facilitating semisedentary settlement and complex sociopolitical organization for the Serrano (Earle 2005a; Robinson 1977; Sutton 1980).

The Maringa (Mariña) Serrano, who occupied the south-easternmost area of their tribe’s territory, were the most visible of Serrano groups in the later historical period after many Serrano who lived in the valleys were removed to Mission San Gabriel in in1811.

Nearby Serrano habitations in the foothills above the San Jacinto Valley, are recorded by Strong at yūhavetam, above Highland and upwards from there into the San Bernardino Mountains’ foothills, wa’atcem, in the mountains foothills between the Santa Ana River and Mill Creek, yucaipaīem, Yucaipa Valley, and the Marina clan at yumisēval, along upper Mission Creek above the San Gorgonio Pass (Strong 1929: Map1 page 7, and Table 1 page 11). These are all noted as occupied by members of Coyote moiety clans.

In 1770, the Gaspar de Portolá Expedition passed along the Southern California coast to the west through Luiseño territory, while the de Anza expeditions of 1774 and 1776 took a route through the San Jacinto Valley bordering Serrano territory. During the next two decades several missions were established in the region and made contact with the Serrano. Natives were recruited to these missions that included San Gabriel, San Luis Rey, and San Fernando. Kroeber (1925:617) estimated only 1,500 people for the total population; Bean and Smith (1978), however, did not speculate on the population. Upon contact, European interactions and introduced diseases led to dramatic population declines.

Eventually, a reservation system was developed, and members of the Serrano tribe are currently enrolled in the San Manuel Band of Mission Indians (now the Yahaaviatam of San Manuel) (located  SECTION 4.4 – CULTURAL RESOURCES 
7214/Redlands – Kaiser Permanente Medical Center Page 4.4-16 Program Environmental Impact Report November 2025
adjacent to the town of Highland; 5.5 miles to the northwest of the project), and with members of the Cahuilla tribe at Morongo Band of Mission Indians (adjacent to and east of Banning, 28 miles to the east of the project). These two groups are federally recognized. There is also one non-federally recognized Serrano band, the Serrano Nation of Mission Indians.

4.4.4.4 Historic-Period Overview
Spanish/Mexican Era
Spanish Missionaries from Mission San Gabriel Arcángel established an asistencia and ranch near the village of Guachama in 1810 near Lytle Creek just west of the current city of San Bernardino, naming the new Gabrielino and Serrano neophyte Politana. Father Francisco Dumetz named the asistencia San Bernardino on May 20, 1810, after the feast day of St. Bernardino of Siena. In 1819, they established the San Bernardino de Siena Estancia, a mission farm in what is now Redlands. (Sparkman 1908). (See Section 2.2.3 in Appendix D1 for references.) By the early 1820s California came under Mexico's rule, and in 1834 the missions were secularized.

Since the primary purpose of the Missions was Indian control, this secularization led to an increase in the number of natives participating in the reservation system. Many were kept forcefully and assimilated into Hispanic society if they had been converted to Catholicism.

Following Mexican independence from Spain in 1821, select Mexican citizens were awarded land grants to establish ranchos in the area of the county. Rancho Jurupa in 1838, Rancho Cucamonga and El Rincon in 1839, Rancho Santa Ana del Chino in 1841, Rancho San Bernardino in 1842 and Rancho Muscupiabe in 1844. Agua Mansa was the first town in what became San Bernardino County, settled by immigrants from New Mexico in the 1830s on land donated from the Rancho Jurupa in 1841 near what is now Colton. (Van De Grift Sanchez, 1914.) In 1842, several years after the secularization of the missions by Mexico, Governor Juan Bautista Alvarado, made a large land grant to Don Antonio Maria Lugo and his three sons. The Lugo family’s Rancho San Bernardino encompassed land in both the San Bernardino and Yucaipa valleys, extending from present-day Colton to Calimesa.

Wartime alliances developed among three groups, the Mexicans, Anglos, and Indians, and the turmoil, or war, had a profound effect on Native Americans resulting in the Cahuilla massacre of Luiseno near Temecula. The signing of the Treaty of Guadalupe Hidalgo on February 2, 1848, ended the MexicanAmerican War and marked the beginning of the American Period when California became a territory of the United States, and a state in 1850.

The American Period
The discovery of gold the same year as the treaty initiated the 1848 Gold Rush, bringing thousands of miners and settlers to California. Gold was discovered in San Bernardino County by William Francis "Bill" Holcomb in the Holcomb and Bear Valleys in 1860. The boomtown of Belleville briefly threatened to take the county seat away from San Bernardino. San Bernardino won by one vote.

However, for those settlers who chose to come to Southern California, their fortunes were more closely tied to cattle and farming than gold. (Cleland 1941) When severe drought and flooding came to southern California and the 1860’s, many ranchos were put into bankruptcy. The Great Flood of 1862 largely destroyed the earlier settlement of Agua Mansa.

The Catholic Church there was rebuilt in downtown San Bernardino in 1865. The flood caused severe  SECTION 4.4 – CULTURAL RESOURCES 
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damage along the Santa Ana River's tributaries, particularly Lytle Creek. (Castillo 1978; Cleland 1941.)
While California remained in the Union during the Civil War, there were many Confederate sympathizers in the area. A brief skirmish between Unionists and Confederate sympathizers erupted in the local mountains (Kupfer 1979).

The stagecoaches of Phineas Banning had a stop in downtown San Bernardino during the 1860s. A young Wyatt Earp and his family traveled to San Bernardino by wagon train, arriving in 1864. Virgil Earp later settled in Colton, California, where he became town marshal. Late in life, in the 1920s, Wyatt became a ceremonial San Bernardino County Deputy Sheriff (Hinckley 1956).

San Bernardino County
At the beginning of California statehood in 1850, what is now San Bernardino was part of Los Angeles County. In the spring of 1851, 437 Mormon settlers, who had come in wagons from Salt Lake City, settled in the San Bernardino Valley. Amasa Lyman and Charles C. Rich, acting as representatives of the Latter-Day Saints, bought a large portion of Rancho San Bernardino from the Lugos and established what would become the city of San Bernardino.

San Bernardino County was formed in 1853 from parts of Los Angeles County. Some of the southern portions of the county's territory were used in part to form Riverside County in 1893 (Van De Grift Sanchez 1914).

Agriculture and ranching played a prominent role in the socioeconomic development of San Bernardino County from the latter half of the nineteenth century. The earliest agricultural activity in the San Gorgonio Pass-San Timoteo Canyon area was cattle ranching, with Mission San Gabriel creating the Rancho San Bernardino as a cattle ranch to support the Mission. Following the increased population in the project area of Anglo-American settlement, grain production (including barley, oats, and wheat) emerged as a primary crop for many farmers.

The California Gold Rush and concomitant increase in population created a large market for dairy products. Due to the limits of early transportation systems, most dairy production was located close to cities. Construction of railroads in the 1870s allowed the dairies to function farther from population centers, which was desirable due to the lower cost of land in more remote locations.

During the railroad boom of the 1880s and beyond, the dairy business in the San Bernardino Valley region was an important early industry that provided milk products to the growing cities of Redlands and San Bernardino.

The presence of the railroad also allowed for transport of hay, grain, and cattle. Fruit trees were first grown in the project vicinity in the late 1840s, ushering in the emphasis on citriculture in southern California. By the 1880s, grain farming was surpassed by citriculture as the dominant agricultural pursuit in western San Bernardino County. In the 1900s, citrus farming was promoted locally and resulted in a second “Gold [orange] Rush”. Agricultural enterprises, which had served the area well for over 100 years, were to change forever with the advent of World War II. The overwhelming need for housing engendered by the GI Bill and the postwar building boom initiated the transition into residential development that continues to this day.
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City of Redlands
In 1881, the development firm of Judson and Brown, (E.C. Judson and Frank E. Brown), purchased 4,000 acres along the southern edge of the alluvial plains of the San Bernardino Valley. Their intent was to subdivide the land into 5- and 10-acre parcels which would then be sold to “working class” investors of moderate means. The Judson and Brown partnership was also instrumental in bringing water into the area. Water for domestic and agricultural purposes was brought in by construction of an irrigation canal which was dug to the Santa Ana River, some five miles distant. The introduction of a reliable water supply paved the way for successful farming as well as the continuing development of residential tracts. Soon it was discovered that the soil could support a variety of profitable crops.

However, it was only a short time before citrus became the preferred crop. “Agriculture included grapes, peaches, apricot orchards and a number of fruit drying operations... Backers of early Redlands townsite were actively promoting citrus cultivation in the area. Planters were encouraged to border their groves with Mexican fan palm trees to make them more attractive to prospective citrus investors from the east. By the end of the 1880’s people were uprooting their other fruit orchards in favor of oranges. The navel orange soon became Redlands main economic source (Moore 1983).” (URS Consultants, Inc. 1988).

The City of Redlands was incorporated on November 26, 1888 (Burgess 1981; Hinckley 1951).

Establishing itself as the business center of the region with a thriving community at Orange and State Streets, the community grew to encompass several thousand acres. By 1889 the boom decade had passed. That same year the brothers Alfred H. and Albert K Smiley move into the Redlands area. The Smiley brothers, who were land development investors, bought Canyon Crest Park and developed it into one of this region’s botanical show spots--Smiley Heights (Robinson 1958:59).

In the 1890’s, the Santa Fe Railroad constructed a loop rail service line through the entire citrus belt of the San Bernardino Valley. This loop was referred to as the “Redlands loop” and was a digression from the Old Kite Route which was in service from the 1890s-1930s (Donovan and Horton 1943:16).

In 1891, the Atchison Topeka and Santa Fe Railway completed the loop line which connected Redlands, East Highlands, Highland, and West Highlands with San Bernardino - a major railroad shipping point. This loop facilitated the shipping and marketing of fruit and also resulted in the construction of a number of stations and packing houses along the railway route. Most notable of these was the Drew Ranch packing house which was later sold to Vice President Fairbanks (Theodore Roosevelt administration). Other houses included the Allen Break, the Randolph house, the M.H.

Whittier house, the A.P. Dallas house, and the Nevada Street Packing Company (Anderson 1979). At the height of its citrus industry, Redlands had 32 packing houses. Of that number, only two remain in operation.

In 1903, Henry Huntington, nephew of Collis Huntington (President of the Southern Pacific), formed a new traction company called the Los Angeles Inter-Urban Railway as a result of an attempted takeover of the Pacific Electric by the Southern Pacific (Crump 1965:74). Huntington expanded his Los Angeles Inter-Urban line into San Bernardino and Riverside counties where he acquired major interests in existing traction companies. One such company was the San Bernardino Valley Traction Company (SBVT). However, by 1910, Huntington, seeking a more esoteric lifestyle, had turned control of both the Pacific Electric and Los Angeles Inter-Urban railways over to the Southern Pacific.

The onset of World War II brought about considerable change in the Redlands economy, particularly with the citrus industry. In the late 1940s, large grove properties became more valuable as  SECTION 4.4 – CULTURAL RESOURCES 
7214/Redlands – Kaiser Permanente Medical Center Page 4.4-19 Program Environmental Impact Report November 2025
subdivisions for housing developments than for the growing of citrus. As a result, most of the packing houses were forced to relocate or close (Moore 1983). Southern Pacific continued to serve the citrus packing houses in the Redlands/Lugonia area until sometime following the end of WW II. By the close of the war, trucks had become the choice in the transportation of fruit to market. They were more flexible in load hauling capability and could be more directly routed (Moore 1987:185).

The nearby community of Gladysta was platted by businessman Henry L. Williams in 1887 when he attempted to predict the route of the San Bernardino-Redlands Railroad. Williams named it after his daughter Gladys (Redland Daily Facts 2011). See mention below of its presence approximately 0.5 mile to the southeast of the project site on the 1901 USGS topo map.

Since the 1950s, many thousands of acres of orange trees have given way to residential and commercial development. As its citrus agriculture gradually fades into history, Redlands continues to prosper while maintaining its downtown core and surrounding neighborhoods reminiscent of a small early twentieth century city.

4.4.4.5 History of the Project Site
Aerial Photographs
Historic aerial photographs are available for this area of Redlands, the earliest dating to 1938 (NETROnline, 2023). This photo shows that the project area is predominantly orchards. The project parcel itself is open land apparently used for hay fields, while to the north and east across California Street and to the south all is in orchards – likely citrus. There is a large farm complex on the northeast corner of the parcel and extending north of the California/Almond streets intersection consisting of five buildings to the north of the first rod extension west from Almond, possibly a barn and a residence, while to the south (on the project parcel) are five smaller out-buildings with a reservoir, all surrounded by trees. This can be associated with the Marigold Farms dairy.

The next available aerial photo comes from 1959 (NETROnline, 2023), when the general land use remained the same throughout the area; the farm complex is reduced in size with only two structures north of the “Almond” dirt road; the south side remains the same. In 1966 (NETROnline, 2023) there is now just one structure north of the first road while the buildings to the south are unchanged from 1959 as is the agricultural use of the surrounding land. The land use and number of buildings remain unchanged in the 1968 and 1980 aerial photos (NETROnline, 2023) of this location.

The only apparent alterations in the 1984 aerial view are that by now Lugonia Avenue is paved, as is California Street from south of Lugonia, northward to Almond Avenue. This then remains unchanged in the 1985 and 1994 (NETROnline, 2023) aerial views. Three years later (NETROnline, 2023) the basin in the northwest corner of the parcel is now present, and the parcel is still open field. At this time, Almond Avenue has been pushed through past California Street, and the remaining aspects of the farm complex are gone, though an orchard still remains east of California Street.

The Kaiser Medical Center occupies the southwest quarter of the project parcel by 2009, with the remaining space possibly agricultural fields; the surrounding parcels remain the same. There are no further changes visible in 2010 and 2012 (NETROnline, 2023). In 2014 (NETROnline, 2023) the open land around the medical center remains open and while the southern half appears fallow, the northern portion may still be in active agricultural use; there is now a warehouse north of Almond, and to the east of California the orchard is gone, and the land is fallow. Within two years, however, (NETROnline, 2023) the land on all four sides of the project parcel has been built up with commercial  SECTION 4.4 – CULTURAL RESOURCES 
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and warehouse structures. The aerial photos from 2018 and 2020 (NETROnline, 2023) are the same, though in 2020 it can be seen there is now a large ditch running east/west between the north and south field in the parcel (the situation found during the present field survey).

USGS Topo Maps
The available U.S. Geological Survey (USGS) topographic maps for this area start with 1901. Maps from 1901 through 1951 (USGS, 1901, 1905, 1909, 1913, 1924, 1929, 1939, 1946 and 1951) are the same, showing the presence of the current main roads of California Street bordering the east edge of the project site, Lugonia Avenue along the south and Almond Avenue to the north, all dirt roads. There is a rail line approximately 0.5 mile to the south (this is the Atchison Topeka and Santa Fe [AT&SF] rail line which is still present) with a small community at the siding; roads are present in the surrounding area. A label on the map approximately 0.5 mile to the east indicates that the area is called Gladysta, though no structures are present. The land is shown as open with no agriculture present, though orchards were likely already present but simply not yet shown on the map. There is a wash indicated flowing from the northwest of the project site 0.5 to 0.75 mile to the southwest; this parallels the rail line east/west for about 0.5 mile directly south of the project site, and then turns south. The 1955 (USGS, 1955) map now shows Lugonia Avenue as a paved primary road and the other surrounding streets of California and Almond as smaller paved roads. There are orchards stretching out east of California and south of Lugonia from the project site, which is still open land; there is a water reservoir and four structures indicated in the north corner, across from the Almond intersection – this would be the Mayfair Dairy farm. These are all located immediately west of the intersection of California and Almond streets. The rail line 0.25 mile to the south is now identified as the AT&SF and there is now another rail line also going east/west 0.25 mile to the north identified as the San Bernardino Electric line.

The 1960 topo map shows the region as essentially the same as in 1955 but now only three structures are shown in the northeast corner (the Dairy), while the reservoir remains (USGS, 1960). The 1963 USGS map is the same as the 1955 version, while the 1964 map is the same as the 1960 version (USGS, 1963 and 1964).

The I-10 Freeway is not present in the 1964 USGS topo map, but is shown in the 1969 version, 0.25 mile to the south following the rail line, with an on/off ramp at California Street. At that time there is still agriculture (orchards) to the north of the freeway and to the south of the AT&SF Rail line with the land between, including the project site, “vacant” (though the site was occupied by the dairy farm which would have been growing hay). In 1969 the USGS topo (USGS, 1969) map still shows little change in the immediate project area from the 1955 version – orchards remain to the east across California Street and south across Lugonia Avenue with the project site as open space, though the orchard along the southwest edge has been reduced in size. The dairy complex also continues to be reduced in size and is now shown as one structure, and the reservoir is now gone. The 1973 map (USGS, 1973) shows the same configuration as in 1960. By the time of the 1979 topo map (USGS, 1979), while the general setting and structures remain the same as in 1969, in the 1980 version (USGS, 1980) the surrounding area is the same as seen in 1969, but the dairy farm presence has been expanded to now include a large long building situated on the west side of the intersection of California and Almond, at the extreme northeast corner of the project parcel. The 1986 USGS map shows much the same situation as in 1980 except the orchards to the south of Lugonia are now nearly gone. The 1988 and 1999 USGS topo maps show the same configuration as in 1986 (USGS, 1986, 1988 and 1999).
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The 2012, 2015, 2018 and 2021 topo maps (USGS, 2012, 2015, 2018 and 2021) use the new standard of only showing roadways, with the except that on the 2015 map the waterway to the south is now named “The Mission Zanja.” The 2018 map shows a “Nevada” label immediately southeast of the project area, in the same location as “Gladysta” appeared in 1901. Nevada is identified as a “populated place located within the City of Redlands” (HomeTownLocator.com, n.d.).

4.4.4.6 Identified Cultural Resources
Recorded Archaeological Sites
Based on the cultural resources records search conducted at the South Central Coastal Information Center (SCCIC) (see Table 4.4-1 below and Section 4.1 in Appendix D1), it was determined that two historic era cultural resources have been previously recorded within the project site boundary.

Within the 0.5-mile buffer zone there are an additional six recorded historic era cultural resources.

There have been no prehistoric resources recorded within the project boundary or the buffer area.

The Marigold Farms historic site, CA-SBr-7139H, was a dairy, farming, and ranching operation dating from 1915 through approximately 1991 (Swope, Slatter and Cardoza 1991). This farm complex occupied the block from Lugonia Avenue on the south to San Bernardino Avenue on the north, and California Stret on the east to Mountain View Avenue on the west (which includes the Kaiser Medical Center property in the southeast corner of the farm). As described by Swope, et al. (1991:1) from their survey of the farm complex, on the southern portion of the site there was a historic milking barn (recorded previously as CA-SBr-6857H; see below) and a presumed modern equipment storage shed.

Other historical features associated with Marigold Farms (domestic structure, hammer mill, silos, etc.) were located north of San Bernardino Avenue, outside the boundaries of the property under investigation, and were not formally recorded during this research. A historic resources inventory record of the north portion of the site was prepared. A cluster of residences was once located west of the barn. Wooden structures located at the south-central portion of the property are thought to postdate the historical period. A red fired-brick standpipe was located approximately 10 meters southwest of the southwest corner of the barn. Reservoirs were once present on the property. The Marigold railroad siding was located near the north central portion of the property.

All of these Marigold Farms features were located north of the current project site, around the intersection of Almond Avenue and California Street. The area of the current project site was open land used for cultivating alfalfa and is not shown to have contained any structures (Swope et al. 1991:1, 7). The survey report of the project that the site record derived from concluded that the site record produced mitigated potential impacts of development to the farm (Swope and Lerch 1992:ii).

The barn associated with the Marigold Farms complex was recorded separately as CA-SBr-6857H by Romani, Head and Webb (1990). This was described at the time as an abandoned barn of concrete and wood plank, rectangular in configuration. It was also noted at the time that there were alfalfa fields to the south of the structure which would have encompassed the current project site (Romani, et al. 1990:4). It was located at the southwest corner of California Street and Almond Avenue, which is the northeast corner of the current project site. At the time of the Marigold Farms operations, Almond Avenue ended at California Street; the road has since been extended west of California and this road work would have demolished the barn and any subsurface components.

There were six other historic resources outside of the project APE but within a 0.5-mile radius of it.

There was a set of four large metal tanks (P-36-009992, CA-SBr-9992H) located on the northwest corner of Olive Avenue and California Street, approximately 3,000 feet to the north of the project site.  SECTION 4.4 – CULTURAL RESOURCES 
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Once used for the storage of smudge oil, one was on a platform with the other three situated directly on the ground (Tang 2000:1). No construction date is suggested, though it is known that at least three of the tanks were present by1938 (Tang 2000:2).

There are three utility-related properties recorded within the project buffer zone. The Southern California Edison’s Mira Loma-Vista 220kV transmission line, also known as the Hayfield-Chino 220kV (line) (P-36-026051) runs east/west to the north of the project site along San Bernardino Avenue. This was recorded in 2018 by Cunningham, O’Conner and Wintergerst as CA-SBr-17229H.

There is also the San Bernardino-Redlands-Timoteo and San Bernardino-Redlands-Tennessee Subtransmission Lines (P-36-026224). Southern California Edison constructed these lines between 1966 and 1967, running east/west through San Bernardino County. They were “historically constructed on lattice poles, single wood poles, or in an H-frame wood pole configuration” (Williams 2014:2); the line in the current project area runs north/south approximately 2,500 feet to the west of the project site. Site P-36-26219 is the San Bernardino Substation, an historic-age electrical substation built in the 1940s, located 2,750 feet to the northwest of the current project site. “It consists of the typical components of a substation, including circuit switches, regulators and reclosers. There is one small concrete control structure located near the center of the substation” (LSA Associates 2013:1).

There is one transportation-associated historic site in the 0.5-mile zone, an abandoned line of the Southern California Railroad (P-36-02619) (ICF 2018). This was constructed in 1882 to provide a direct rail line between San Diego and Colton in San Bernardino County. The remaining abandoned grade is 12 feet across and is associated with six scatters of historic artifacts (ICF 2018:2). It is located approximately 2,100 feet southwest of the current project site.

The San Bernardino County Museum located at 2024 Orange Tree Lane is recorded as P-36-015135 and is noted as a California Department of Parks and Recreation Point of Historic Interest (Anonymous 1969). It is located approximately 1,000 feet southwest of the current project site.

Originally dedicated in 1957, the original structures have since been replaced.

Table 4.4-1
KNOWN CULTURAL RESOURCES WITHIN A 0.5 MILE RADIUS OF THE PROJECT BOUNDARY Site Number Author(s) Date Type Description
P-36-06847 ICF 2018 Historic The resource consists of a segment of the historic alignment of The
Southern California Railroad, a
consolidation of California Southern
Railroad Company, the California
Central Railway Company, and the
Redondo Beach Railway Company.
“The California Southern Railroad
was built in 1882 to provide the first
direct route from San Diego to
Colton. In November, 1885, the
[California Southern Railroad] was
officially opened between San
Bernardino and Barstow. Only the

0.54-mile-long segment within the
current project area is recorded. The
grade has been affected by blading,
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Site Number Author(s) Date Type Description
flood, and removal of ties and rail
after an apparent flood even in the
mid-1980s.

P-36-06857 Roman, Gwendolyn,
Genevieve Head, and
Tricia Webb
1990 Historic Historical structure. Abandoned
barn of concrete and wood plank;
rectangular in configuration. Time
period unknown. There were alfalfa
fields to north, west, and south, and a
citrus orchard across California
street to east.

P-36-007139
CA-SBr-7139H
Fulton, P. (LSA);
Swope, K., K. Slater
and B. Cardoza
2012;
1991
Historic The Marigold Farms was a dairy,
farming, and ranching operation
dating from 1915 through
approximately 1991. A dirt road once
extended into the property from the
east. This road may have been an
extension of Almond Avenue, or
Hugo Avenue, parallel to and south of
Almond. Bryn Mawr Avenue, another
dirt road, bisected the center of the
property from north to south. A
railroad siding named Marigold was
located at the north center of the
property on the San Bernardino
Valley Traction Company line. On the
southern portion of the site are a
historic milking barn and a
presumed modern equipment
storage shed. Other historical
features associated with Marigold
Farms (domestic structure, hammer
mill, silos, etc.) were located north of
San Bernardino Avenue, outside the
boundaries of the property under
investigation, and were not formally
recorded during this research. A
historic resources inventory record
of the north portion of the site was
prepared. A cluster of residences was
once located west of the barn.

Wooden structures located at the
south-central portion of the property
are thought to postdate the historical
period. A red fired-brick standpipe
was located approximately 10
meters southwest of the southwest
corner of the barn. Reservoirs were
once present on the property. The
Marigold railroad siding was located
near the north central portion of the
property.
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Site Number Author(s) Date Type Description
P-36-09992
CA-SBr-9992H
Tang, Bai “Tom” 2000 Historic Consists of four large metal tanks once used for storage of smudge oil,
and the largest with a capacity of
25,000 gallons. Cylindrical in shape,
made of galvanized corrugated steel
sheets. One on a wooden platform,
the other three on the ground
surface. Unknown date, but three of
the tanks were known to be present
in 1938. On the northeast corner of
Olive Avenue and California Street.

P-36-0015135 Anon. 1975 Historic The San Bernardino County Museum recorded as a Point of Historic
Interest by the California
Department of Parks and Recreation
in 1969 and was recommended in
1975. A 1953 Progress Report
indicate several buildings present for
storage of collections. Museum
dedicated in 1957. (No further
information is provided in the record
but it is known to have been greatly
expanded into modern facilities as a
comprehensive natural history
museum.) Located on Orange Tree
Lane, in the City of Redlands.

P-36-026051
CA-SBr-17229H
Cunningham,
Robert, John
O’Connor, and Steve
Wintergerst
2018 Historic The resource is a segment of the
Chino-Hayfield 220kV transmission
line. The Chino-Hayfield
transmission line was originally
recorded by Davidson, Goodwin, and
Smith in 2012. It was described as an
approximately 43-mile-long
transmission line associated with the
development of the San Bernardino
to Desert Hot Springs corridor
through San Gorgonio Pass and San
Timoteo Canyon. The transmission
line was evaluated for NRHP/CRHR
eligibility by Wendy L. Tinsley
Becker in 2014 and was
recommended as not eligible. A
segment of the resource crossing
Reche Canyon was revisited by
ECORP archaeologists in 2018 as
part of a cultural resources survey.

The condition of the segment was
found to be consistent with previous
site records.

P-36-026219 Williams, Audry
LSA
2014
2013
Historic The San Bernardino Substation
recorded as a historical resource.

The San Bernardino Substation is an
 SECTION 4.4 – CULTURAL RESOURCES 
7214/Redlands – Kaiser Permanente Medical Center Page 4.4-25 Program Environmental Impact Report November 2025
Site Number Author(s) Date Type Description
existing 220/66/12kV substation
location north of San Bernardino
Avenue and east of Mountain view
Avenue in the City of Redlands. The
San Bernardino Substation was built
in the 1960s by SCE to support the
San Bernardino Steam Plant.

P-36-026224 Williams, Audry 2014 Historic The resource recorded consists of portions of the San BernardinoRedlands-Timoteo and San Bernardino-Redlands-Tennessee
66kV Subtransmission Lines. SCE
constructed the San BernardinoRedlands-Timoteo 66kV and the San Bernardino-Redlands-Tennessee
66kV subtransmission lines between
1966 and 1967. The lines run parallel
to the Devers-San Bernardino No. 1
220kV transmission line from the
San Bernardino Substation to Barton
Road. The lines consist of lattice steel
towers from San Bernardino
Substation to Redland Boulevard,
and transitions to wood poles to its
terminus at Barton Road. The
construction of the San BernardinoRedlands-Timoteo 66kV and the San Bernardino-Redlands-Tennessee
66kV subtransmission lines is
associated with post-World War II
housing developments expanding
into Loma Linda area and the
concurrent need for more power.

Previous Archaeological Investigations
Records at the SCCIC indicate there have been 17 previous cultural resource studies within portions of the 0.5-mile buffer of the project. Two of the surveys included the project site (SB-2625 and SB4809), while four other surveys touched upon the boundaries of the project site (SB-2853, - 4600, - 8038, and -8199). The remaining 11 prior studies are located outside of the project boundary. Four of these 11 surveys identified cultural resources, but none were in the 0.5-mile radius of this project. (See Table 4.4-2, and Attachment D in Appendix D1.)
The current project parcel was originally surveyed by Michael K. Lerch & Associates in 1992 consisting of 35 acres for the approved Kaiser Medical Center, part of a larger planned development of the Barton Center of Redlands, a 306-acre subdivision (SB-2625). No prehistoric resources and a single historical resource, being the Marigold Farms buildings, were discovered during this investigation. They recorded the Marigold Farms complex and its milking barn (CA-SBR-7139H) – see description in Recorded Archaeological Sites above. The report concluded that the site record produced mitigated potential impacts of development to the farm (Swope and Lerch 1992:ii).  SECTION 4.4 – CULTURAL RESOURCES 
7214/Redlands – Kaiser Permanente Medical Center Page 4.4-26 Program Environmental Impact Report November 2025
In 2006, W&S Consultants undertook an archaeological survey of the Kaiser Redlands medical office building project site that encompasses the same footprint as the current project (SB-4809). At that time, the archival research showed the prior presence of two historic sites related to the Marigold Farms that had been present in the northeast corner of the project parcel and that they had subsequently been demolished (W&S Consultants 2006:7). These were the concrete milk barn (CASBR-6857) and a portion of the Marigold Farms complex (CA-SBR-7139H) (see Recorded Archaeological Sites above for a description of these resources).

Adjacent surveys consisted of the Inland Feeder project for the Metropolitan Water District of Southern California (SB-2853) that surveyed a water utility line along California Street; a cultural resources survey for a development (SB-4600) across the northeast corner from the project suite at California Street and Almond Avenue; SB-8038, a paleontological assessment of a parcel that would be developed for the Hillwood Commercial Center on the east side of California Street from the project area; and finally there is a report documenting monitoring during ground disturbing activities for the construction of the Redlands Commercial Center buildings (SB-8199) immediately south of the project site on the south side of Lugonia Avenue.

An archaeological investigation may have taken place at the project site as indicated by the notation of “SB-06633” on the Redlands, California USGS map at the SCCIC. The SCCIC staff indicated that this report was no longer in their system and was likely removed by staff. Its potential appearance between reports dating to 2007 and 2015 indicates it may be associated with the site record P-36- 007139 recorded by P. Fulton in 2012 at this location.

Table 4.4-2
KNOWN CULTURAL RESOURCE STUDIES WITHIN A 0.5-MILE RADIUS

OF THE PROJECT BOUNDARY
Report
Number Author(s) Date Title Resources
SB-00557 Hearn, Joseph E. 1977
Archaeological - historical
resources assessment of
project site located on the
north side of Redlands
Boulevard and west of
California street in the Bryn
Mawr area
N/A
SB-00600 Hearn, Joseph E. 1978
Archaeological - historical
resources assessment of
approximately eight acres at
the northeast corner of
Redlands Boulevard and Bryn
Mawr avenue; Loma Linda area
N/A
SB-00647 Hearn, Joseph E. 1978
Archaeological - historical
resources assessment of 63
acre parcel of land located on
the north side of Redlands
Boulevard between Mountain
View Avenue and Bryn Mawr
Avenue, Loma Linda-Redlands
area
N/A
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7214/Redlands – Kaiser Permanente Medical Center Page 4.4-27 Program Environmental Impact Report November 2025
Report
Number Author(s) Date Title Resources
SB-00931 Smith, Gerald A. 1980
Cultural resources assessment
of the west portion of
assessor's parcel number 292-
061-11, Redlands area
N/A
SB-02486
Hathaway, Roger G.,
John Romani, and
Joanne SanFelippo
1991
An architectural determination
of eligibility/significance
report and an archaeological
survey for the Marigold
Business Park
N/A
SB-02625 Swope, Karen K., and
Michael K. Lerch 1992
Cultural resources assessment
of the Barton Center of
Redlands, Narigold Farms, city
of Redlands, San Bernardino
County, California
36-006857,
36-007139
SB-02853
Foster, John M.,
James J. Schmidt,
Carmen A. Weber,
Gwendolyn R.

Romani, and Roberta
S. Greenwood
1991
Cultural resource
investigation: Inland Feeder
Project, MWD of Southern Ca
36-006086, 36-
006354, 36-006847,
36-006848, 36-
006849, 36-006850,
36-006851, 36-
006852, 36-006853,
36-006854, 36-
006855, 36-006856,
36-006857, 36-
006858, 36-006859,
36-006860, 36-
006861, 36-006862,
36-006863, 36-
006864, 36-006865,
36-006866, 36-
006867, 36-006868,
36-006869, 36-
006870, 36-006871,
36-006872, 36-
006940, 36-007021,
36-007050, 36-
007051, 36-007053,
36-007054, 36-
007055, 36-007702
SB-03750 Love, Bruce 2000 Westside Landfill expansion
project. 29pp
36-009990, 36-
009991, 36-009992
SB-04048 Love, Bruce 2001
Identification and evaluation of
historic properties: city of
Redlands recycled water
project in the city of Redlands,
San Bernardino County, Ca.
27pp
36-007139, 36-
009991, 36-009992
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Report
Number Author(s) Date Title Resources
SB-04600 Dice, Michael 2004
Phase I Cultural Resources
Survey of a 73.45 Acre Property
in Unincorporated San
Bernardino County, APN:
0292-052-01, -03, - 04, -06, -08,
-10, -11, -12, -16 near Nevada
Street/Almond Avenue, Section
13 of Township 1 North Range
6 West, County of San
Bernardino, California.

N/A
SB-04809 W & S Consultants 2006
Phase 1 archaeological survey
of the Kaiser Redlands mob
study area, Redlands, San
Bernardino County, California
N/A
SB-04812 Dice, Michael 2004
Records Search Results and
Site Visit for Sprint
Telecommunications Facility
SB38XC919E (City Grove),
California Street and I-10,
Redlands, San Bernardino
County, California.

N/A
SB-05805 Crull, Scott 2007
An Archaeological and
Paleontological MitigationMonitoring Report for
Tentative Parcel Map 17815,
with APHs: 167-401-02, 03;
167-511-08 and 167-451-05,
06, 07- a 40 Acre Parcel
Located in the City of Redlands,
San Bernardino County,
California.

N/A
SB-06633 [unknown] [unkno
wn] [unknown] [unknown]
SB-07964
DeCarlo, Matthew M.
and Diane L.

Winslow
2015
Cultural Resources Impact
Assessment and Evaluation
Status Report for Southern
California Edison Company's
West of Devers Upgrade
Project, Riverside and San
Bernardino Counties,
California
36-002311, 36-
006847, 36-006855,
36-026030
SB-08038 Brunzell, David 2013
Cultural Resources Assessment
Hillwood Commerce Center
Project, City of Redlands, San
Bernardino County, California
36-009991
SB-08199
Abdo-Hintzman,
Kholood, and Josh
Smallwood
2015
Cultural resources monitoring
report for the Redlands
Commerce Center buildings 1
and 2 project City of Redlands,
San Bernardino County,
California
36-028815
 SECTION 4.4 – CULTURAL RESOURCES 
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Pedestrian Survey
A pedestrian field survey to look for the presence of cultural resources was conducted November 6, 2023. Survey transects were conducted in an opportunistic manner in conformity with the available exposed ground surface and layout of the landscaping.

The result of the pedestrian survey was negative for both prehistoric and historic archaeological sites, features and isolates.

Native American Outreach
On June 8, 2023, Ms. Doukakis contacted the NAHC via email notifying them of the project, requesting a search of their SLF and asking for a list of local tribal organizations and individuals to contact for project outreach. The results of the search request were received from Cameron Vela, Cultural Resources Analyst, on July 13, 2023. The NAHC letter stated that “A record search of the Native American Heritage Commission (NAHC) Sacred Lands File (SLF) was completed for the information you have submitted for the above referenced project. The results were positive [emphasis in the original]. Please contact the San Manuel Band of Mission Indians on the attached list for information.” (See Attachment C in Appendix D1.)
UEI prepared letters to each of the 38 tribal contacts representing 21 tribal organizations describing the project and included a map showing the project's location, asking if they have knowledge of cultural resources in the area, as well as if they had any questions or concerns regarding the project.

On October 3, 2023, Ms. Doukakis mailed these letters with accompanying maps to all 38 tribal contacts, and also emailed identical letters and maps to each of the 37 tribal contacts for which email addresses were known.

Eight email responses were received.
• The Gabrieleno Band of Mission Indians – Kizh Nation Administration responded on behalf of Chairperson Andrew Salas and Christina Swindell Martinez, Secretary on October 3, 2023 requesting the lead agency’s contact information. That information was provided by Ms.

Doukakis on October 4, 2023.
• Christina Conley, Cultural Resource Administrator for the Gabrielino Tongva Indians of California Tribal Council on behalf of Chairperson Robert Dorame responded on October 3, 2023, indicating that the project would need to have a Native American monitor and suggested calling Sandonne Goad, Chairperson of the Gabrielino/Tongva Nation for this area. • Chairperson Charles Alvarez of the Gabrielino-Tongva Tribe on behalf of San Dunlap, Cultural Resources Director, responded on October 4, 2023, stating that the tribe would look into this matter and respond accordingly. No further response has been received to date. • Paul Macarro, Cultural Resources Coordinator for the Pechanga Band of Indians on behalf of Chairperson Mark Macarro responded on October 3, 2023 indicating that the project area is outside the ancestral lands of their tribe and the tribe will defer to the appropriate tribes. • Xitaley Madrigal, Cultural Resources Analyst for the Agua Caliente Band of Cahuilla Indians (ACBCI) on behalf of Chairperson Reid Milanovich and Director Patricia Garcia-Plotkin responded on October 11, 2023 indicating that the project area is not located within the  SECTION 4.4 – CULTURAL RESOURCES 
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boundaries of the ACBCI reservation but it is within the Tribe’s Traditional Use Area and recommends a cultural resources inventory of the project area, documentation of CHRIS cultural resources, a copy of the records received on the project, the presence of cultural resource monitors if any ground disturbance takes place, including a Secretary of the Interior-qualified archeologist. Mr. O’Neil responded to Ms. Madrigal, stating that a cultural resources inventory report would be completed and could be requested from the City of Redlands when completed. As for the other requests recommended, Mr. O’Neil stated that they are best made to the City of Redlands during AB 52 consultation. • Ana Rios, Administrative Assistant for the Augustine Band of Cahuilla Mission Indians sent an email response on October 9, 2023 on behalf of Chairperson Amanda Vance; an attached letter from Tribal Secretary Geramy Martin indicated that the tribe is unaware of specific cultural resources that may be affected by the proposed project; however, in the event that resources are encountered during the development of this project the tribe asks to be contacted. Mr. O’Neil responded to Ms. Rios, stating that a cultural resources inventory report would be completed and could be requested from the City of Redlands when completed as part of the outreach process; Mr. O’Neil also stated that the City of Redlands, per AB 52, would conduct consultation and the tribe could make any recommendations then. • Alexandra McCleary, Cultural Lands Manager for the San Manuel Band of Mission Indians, responded on November 2, 2023 indicating that the proposed project site is considered sensitive by the Tribe, as it is close to the historic footprint of the Mill Creek Zanja, a historic waterway listed on the National Register which had been built using Serrano labor; there was no specific mention of a Sacred Lands File site. The tribe would like to engage in governmentto-government consultation pursuant to AB 52 with the Lead Agency for the project; Mr.

O’Neil indicated on the same day that the Lead Agency is the City of Redland’s Planning Department and UEI will let them know that the tribe wishes to engage in AB 52 consultation. • Laura Chatterton, Cultural Resource Specialist for the Morongo Band of Mission Indians on behalf of Chairperson Robert Martin and Tribal Historic Preservation Officer Ann Brierty provided a response on November 14, 2023 indicating that the tribe considers the project area to be highly sensitive for cultural resources and will be requesting government-togovernment AB 52 consultation; Mr. O’Neil indicated on the same day that the Lead Agency is the City of Redlands and UEI will let them know that the Band wishes to participate in consultation.

Following up on the initial letter and email contacts, telephone calls were conducted by Ms. Doukakis on November 3, 2023 and November 6, 2023, to complete the outreach process. These calls were to the 20 tribal contacts (representing eight additional tribes) who had not already responded to UEI’s mailings and emails. Nine telephone calls were placed with no answer and messages were left describing the project and requesting a response. These were to Doug Welmas, Chairperson of the Cabazon Band of Mission Indians; Sandonne Goad, Chairperson of the Gabrielino-Tongva Nation; Robert Martin, Chairperson of the Morongo Band of Mission Indians; Ann Brierty, Tribal Historic Preservation Officer of the Morongo Band of Mission Indians; Shasta Gaughen, THPO of the Pala Band of Mission Indians; Alexis Wallick, Assistant Tribal Historic Preservation Officer of the Pala Band of Mission Indians; Wayne Walker, Co-Chairperson of the Serrano Nation of Mission Indians; the Cultural Committee for the Torres-Martinez Desert Cahuilla Indians; and BobbyRay Esparza, Cultural Director of the Cahuilla Band of Indians.
 SECTION 4.4 – CULTURAL RESOURCES 
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• In the call to Chairperson Daniel Salgado, and Tribal Historic Preservation Officer Anthony Madrigal, of the Cahuilla Band of Indians the tribal receptionist indicated that Chairperson Salgado and Mr. Madrigal were not in the office and to leave a message on Mr. Esparza’s voicemail, which was done.
• In the call to John Gomez, Environmental Coordinator for the Ramona Band of Cahuilla Indians on behalf of Chairperson Joseph Hamilton, the tribal receptionist indicated that Mr.

Gomez was in the field and provided his cell phone number; that number was called -- there was no answer and a message was left.
• In the call to Lovina Redner, Tribal Chair for the Santa Rosa Band of Cahuilla Indians, the tribal receptionist indicated that Ms. Redner was not in the office at the time and asked that UEI leave our call back number which was done.
• In the call to Mark Cochrane, Co-Chairperson of the Serrano Nation of Mission Indians, the phone line was disconnected, and no message could be left. There has been no response to date for any of these calls.
• During the call to Anthony Morales, Chairperson of the Gabrieleno-Tongva San Gabriel Band of Missions Indians, he indicated that he does not have any specific concerns but there are known archaeological sites in the area and freeways like the I-10 that would have been used for traditional transportation routes. Chairperson Morales recommended Native American and archaeological monitoring and would like his tribe to be involved. • In the call to Manfred Scott, Acting Chairman for the Quechan Tribe of the Fort Yuma Reservation on behalf of President Jordan Joaquin, and Jill McCormick, Historic Preservation Officer indicated that the tribe will defer to more local tribes. • In the call to Joseph Ontiveros, Cultural Resource Department for the Soboba Band of Luiseño Indians on behalf of Chairperson Isaiah Vivanco indicated that this area is of moderate concern for the tribe and further information will be provided to the lead agency during AB 52 consultation.
• In the call to Dorothy Willis with the EPA Department for the Los Coyotes Band of Cahuilla and Cupeño Indians on behalf of Chairperson Ray Chapparosa, indicated that she was on the other line and to email her our question. This email was sent November 6, 2023. • In the call to Cheryl Madrigal, Tribal Historic Preservation Officer of the Rincon Band of Luiseño Indians representing Tribal Council Member Joseph Linton, Tribal Council Member Laurie Gonzalez, and Attorney General Denise Turner Walsh, Ms. Madrigal indicated that she will take a look at our email and get back to us with a response. • A phone call was received from Deneen Pelton, Cultural Resources Coordinator with the Rincon Band, on the same day indicating that they sent an email response for this project on October 27, 2023. Ms. Pelton provided the email response, and it indicated that the project location is not within the Band’s specific Area of Historic Interest (AHI) and the tribe has no additional information to provide; Ms. Pelton recommended that we directly contact a Tribe that is closer to the project and may have pertinent information. (See Attachment C.) There have been no further responses from these tribes to date.  SECTION 4.4 – CULTURAL RESOURCES 
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4.4.5 Environmental Impact Analysis

4.4.5.1 Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, the project would have a significant impact related to cultural resources if it would:
• Threshold A. Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5; or
• Threshold B. Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5; or
• Threshold C. Disturb human remains, including those interred outside of dedicated cemeteries.

4.4.5.2 Analysis of Project Impacts
Threshold A: Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5?
Less than Significant Impact with Mitigation Incorporated A historical resource is defined in § 15064.5(a)(3) of the CEQA Guidelines as any object, building, structure, site, area, place, record, or manuscript determined to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California. Historical resources are further defined as being associated with significant events, important persons, or distinctive characteristics of a type, period or method of construction; representing the work of an important creative individual; or possessing high artistic values. Resources listed in or determined eligible for the California Register, included in a local register, or identified as significant in a historic resource survey are also considered as historical resources under CEQA.

Similarly, the National Register criteria (contained in Code of Federal Regulations Title 36 Section 60.4) are used to evaluate resources when complying with Section 106 of the National Historic Preservation Act. Specifically, the National Register criteria state that eligible resources comprise districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and that (a) are associated with events that have made a significant contribution to the broad patterns of our history; or (b) that are associated with the lives of persons significant in our past; or (c) that embody the distinctive characteristics of a type, period, or method of construction, or that possess high artistic values, or that represent a significant distinguishable entity whose components may lack individual distinction; or (d) that have yielded or may be likely to yield, information important to history or prehistory.

A substantial adverse change in the significance of a historical resource, as a result of a project or development, is considered a significant impact on the environment. Substantial adverse change is defined as physical demolition, relocation, or alteration of a resource or its immediate surroundings such that the significance of the historical resource would be materially impaired. Direct impacts are those that cause substantial adverse physical change to a historic property. Indirect impacts are those  SECTION 4.4 – CULTURAL RESOURCES 
7214/Redlands – Kaiser Permanente Medical Center Page 4.4-33 Program Environmental Impact Report November 2025
that cause substantial adverse change to the immediate surroundings of a historic property, such that the significance of a historical resource would be materially impaired.

It was determined that the Kaiser Permanente Medical Center Project site had two historic era cultural resources that were previously recorded within the project site boundary. Within the

0.5-mile buffer zone there are an additional five recorded historic-era cultural resources.

The two historic sites, both related to the Mayfair Dairy farm, were situated in the northeast area of the project site. These were recorded as the Mayfair Dairy farm complex (CA-BSR-7139H) and an associated barn (P-36-6875). The related report stated that the site recording would be sufficient documentation of the resource (Swope and Lerch 1992 cited in Section 4.1.1 and 4.1.2 in Appendix D1), and both structures were subsequently demolished. However, because of the obscured ground surface during the pedestrian survey there is the potential for the presence of historic artifacts and/or features to be present. Also, grading activities associated with project construction would cause subsurface disturbance and could result in the unanticipated discovery of unique archaeological resources.

Therefore, mitigation measures CUL-1 and CUL-2, described in Section 4.6, will be implemented to reduce potential impacts to less than significant. Mitigation measure CUL-1 requires the project applicant to retain an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archaeology to conduct monitoring of subsurface ground disturbance during construction activities. Mitigation measure CUL-2 requires an Archaeological Resources Treatment Plan (ARTP) to be prepared if historical or unique archaeological resources are discovered during construction activities.

Threshold B: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
Less than Significant Impact with Mitigation Incorporated An archaeological resource is defined in § 15064.5(c) of the CEQA Guidelines as a site, area or place determined to be historically significant as defined in § 15064(a) of the CEQA Guidelines, or as a unique archaeological resource defined in § 21083.2 of the Public Resources Code as an artifact, object, or site that contains information needed to answer important scientific research questions of public interest or that has a special and particular quality such as being the oldest or best example of its type, or that is directly associated with a scientifically-recognized important prehistoric or historic event or person.

Based on the cultural resources records search conducted by the Eastern Information Center, it was determined there have been no prehistoric resources recorded within the project boundary or the half mile-buffer area.

Results of the NAHC SLF were positive. Letters and emails were sent to the 38 contacts representing 21 tribes on October 2, 2023; follow up telephone calls were made November 6, 2023 (see above for detailed description of Outreach responses). There was no response to inquiries concerning the unidentified potential SLF site. However, the San Manuel Band of Mission Indians did note the nearby presence of the Mill Creek Zanja, significant to the Serrano due to their association with its construction. This historic site, however, is not in the immediate vicinity of the project parcel and would not be affected by the project.
 SECTION 4.4 – CULTURAL RESOURCES 
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The cultural resources study findings suggest that there is a low potential for the presence of prehistoric cultural resources. The project site is disturbed by several decades of agricultural use. A prior survey of the property also resulted in negative findings for prehistoric resources.

Grading and other ground disturbing activities associated with development of the project would cause new subsurface disturbance and could result in the unanticipated discovery of unique archaeological resources. Therefore, mitigation measures CUL-1 and CUL-2 that are listed in Section

4.4.6 are recommended.

Threshold C: Would the Project disturb human remains, including those interred outside of dedicated cemeteries?
Less than Significant Impact with Mitigation Incorporated Previous ground disturbing activities on the project site have not encountered human remains. The SCCIC records search did not show the presence of archaeological sites or prior studies of surveys or construction monitoring that reported the presence of prehistoric sites or human remains in the 0.5- mile zone surrounding the APE.

California Health and Safety Code § 7050.5 identifies procedures for the unlikely discovery of human remains. CEQA § 15064.5 indicates the process for determining the significance of impacts to archeological and historical resources. California Public Resources Code § 5097.98 stipulates the notification process during the discovery of Native American human remains, descendants, disposition of human remains, and associated artifacts.

The potential for encountering human remains during ground disturbance is low. However, in the case that human remains are encountered, mitigation measure CUL-3, listed in Section 4.4.7, would require contacting the coroner and contacting the Native American Heritage Commission (NAHC) to make recommendations for removal and nondestructive analysis. CUL-3 would reduce impacts to human remains to less than significant.

No human remains have been previously identified or recorded on the Kaiser Permanente Medical Center Project site.

Grading and trenching activities would be associated with installation of infrastructure including water, sewer, and utility lines and construction of proposed buildings of the project. Grading would involve new subsurface disturbance and could result in the unanticipated discovery of unknown human remains, including those interred outside of formal cemeteries.

4.4.6 Cumulative Impacts
No prehistoric or historic archaeological resources were observed during the pedestrian field survey.

The previous cultural resources surveys within the 0.5-mile buffer zone resulted in no prehistoric archaeological sites or isolates being recorded at the project site or within the 0.5-mile buffer zone.

There were two historic properties recorded in the northeast corner of the project APE which have subsequently been recorded and demolished.

Grading operations could uncover subsurface cultural resources and would have a potentially significant impact to Cultural Resources and mitigation measures have been developed to reduce impacts to less than significant. Impacts to potential archaeological resources and human remains  SECTION 4.4 – CULTURAL RESOURCES 
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that may be discovered during subsurface construction activities within the project site with implementation of mitigation measures CUL-1, CUL-2, and CUL-3 would reduce these impacts to a less than significant level. Implementation of the proposed project would not create or contribute to a cumulative impact on cultural resources.

Additional projects in the area would also involve grading and excavation activities and could significantly impact historical or archaeological resources that may be on or buried in soil under those project sites. Each project would be evaluated under CEQA for potential impacts to cultural resources.

If warranted, each project would be required to implement mitigation measures to reduce potential impacts. Therefore, in combination with past, present, and reasonably foreseeable projects, the project would result in a less than significant cumulative impact with respect to cultural resources.

4.4.7 Mitigation Measures
MM CUL-1: The project applicant shall retain an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archaeology to conduct monitoring of subsurface ground disturbance during construction activities. The archaeologist shall also take the opportunity to re-survey the parcel’s ground surface as the vegetation is cleared for construction work. If unanticipated cultural resource discoveries are made the archaeologist will be afforded the necessary time to recover, analyze, and curate the find(s). The qualified archaeologist will recommend the extent of archaeological monitoring necessary to ensure the protection of any other resources that may be in the area. Any identified cultural resources shall be recorded on the appropriate DPR 523 (A-L) form and filed with the Eastern Information Center.

MM CUL-2: If historical or unique archaeological resources are discovered during construction activities, the contractor shall halt construction activities in a 50-foot radius and notify the project proponent and the City of Redlands. A Secretary of the Interior qualified archaeologist (Principal Archaeologist) shall be notified and afforded the necessary time to recover, analyze, and curate the find(s). The Principal Archaeologist shall recommend the extent of archaeological monitoring necessary to ensure the protection of any other resources that may be in the area. Construction activities may continue on other parts of the project site while evaluation and treatment of historical or unique archaeological resources takes place.

The Principal Archaeologist, depending on the type and extent of the finds, may prepare an Archaeological Resources Treatment Plan (ARTP) to guide future monitoring, the recovery of cultural resources, analysis and reporting of the finds, and curation of the finds. The ARTP shall be submitted to the City and the project proponent for approval.

The ARTP shall include the following:

1. Results of the Cultural Resources Inventory: archaeological resources and their condition and threats on the project site.

2. Impact assessment.

3. Mitigation strategies, which may include:
a. Potential avoidance measures.
 SECTION 4.4 – CULTURAL RESOURCES 
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b. Data recovery steps such as excavation and analysis of an archaeological site to collect information before it is destroyed.
c. Conservation measures such as cleaning, conserving, studying, cataloging, and storing recovered archaeological materials and associated records.

4. Procedures for archaeological monitoring during construction to record exposed resources.

5. Protocols for unanticipated discoveries: what construction workers should do if they find cultural resources unexpectedly, including ceasing work and contacting a qualified archaeologist.

6. Consultation with relevant groups, such as Native American tribes, historians, and regulatory agencies, to determine the value of resources and appropriate treatment measures.

7. Documenting and reporting format and procedures.

MM CUL-3: If human remains are encountered during excavations associated with this project, all work shall stop within a 30-foot radius of the discovery, and the San Bernardino County Coroner will be notified (§ 5097.98 of the Public Resources Code). The Coroner will determine whether the remains are recent human origin or older Native American ancestry. If the coroner, with the aid of the supervising archaeologist, determines that the remains are prehistoric, they will contact the Native American Heritage Commission (NAHC). The NAHC will be responsible for designating the Most Likely Descendant (MLD). The MLDS (either an individual or sometimes a committee) will be responsible for the ultimate disposition of the remains, as required by § 7050.5 of the California Health and Safety Code. The MLD will make recommendations within 24 hours of their notification by the NAHC. These recommendations may include scientific removal and nondestructive analysis of human remains and items associated with Native American burials (§ 7050.5 of the Health and Safety Code).

4.4.8 Level of Significance after Mitigation
Historical Resources
Implementation of mitigation measure CUL-1 would reduce potential impacts to historical and archeological resources to less than significant.

Archaeological Resources
Implementation of mitigation measures CUL-1 and CUL-2 would reduce potential impacts to historical and archeological resources to less than significant.

Human Remains
Implementation of mitigation measure CUL-3 and adherence to all applicable laws and regulations would reduce potential impacts regarding human remains to less than significant.  SECTION 4.5 – ENERGY 
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4.5 Energy

4.5.1 Introduction
The following discussion focuses on the project’s energy use impacts. The information in this section is based partially upon the air quality and greenhouse gas emissions analyses discussed in Section

4.2 and Section 4.7, respectively.

4.5.2 Regulatory Framework
Federal
Corporate Average Fuel Economy (CAFE) Standards
Enacted in 1975, the Corporate Average Fuel Economy (CAFE) Standards aim to reduce energy consumption by improving the fuel economy of cars and light trucks. CAFE standards are regulated by the Department of Transportation’s National Highway Traffic and Safety Administration (NHTSA).

NHTSA sets and enforces CAFE standards under the Energy Policy and Conservation Act (EPCA), and the U.S. Environmental Protection Agency (USEPA) calculates average fuel economy levels and sets GHG standards under the Clean Air Act (US Department of Transportation, 2020). The latest CAFE standards were proposed by the NHTSA in July 2023 and finalized in June 2024 (NHTSA, 2024).

Effective August 23, 2024, passenger cars and light trucks will see an increase of two percent annually for passenger cars in model years 2027–31. For light trucks, the increase will be zero percent per year for model years 2027–28 and two percent per year for model years 2029–31. Additionally, NHTSA is setting final fuel efficiency standards for heavy-duty pickup trucks and vans (HDPUVs) with a 10 percent annual increase for model years 2030–32 and further increases for model years 2033–

35. Energy Independence and Security Act
Enacted in 2007, the Energy Independence and Security Act (EISA) reinforces energy reduction goals by aiming to increase the production of clean renewable fuels, improve efficiency of products, and promote research on GHG capture options. Additionally, the EISA aims to protect American consumers by moving the United States toward increased energy independence and security. Three primary provisions of the EISA are (1) the CAFE standards, (2) the Renewable Fuel Standard, and (3) the appliance/lighting efficiency standards (USEPA, 2020).

State
California Code of Regulations (CCR) Title 24, Part 6
CCR Title 24, Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24) were first established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. The Title 24 standards are updated on a three-year schedule.

The 2022 Title 24 standards, which went into effect on January 1, 2023, require the installation of insulated hot water pipes, improved window performance, improved wall insulation, and mandatory duct sealing. It also requires roofs to be constructed to be solar ready, with cool roofing shingles, a  SECTION 4.5 – ENERGY 
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minimum one-inch air space between roof material and roof deck, and a minimum of R-22 roof/ceiling insulation. All lighting is required to be high efficiency, and daylight sensors and motion sensors are required for outdoor lighting, bathrooms, utility rooms and other spaces. The forced air systems are required to limit leakage to five percent or less and all heat pump systems must be equipped with liquid line filter driers. Compared to the 2019 version of Title 24, nonresidential buildings will use about 30 percent less energy due mainly to lighting upgrades.

California Code of Regulations (CCR) Title 24, Part 11
CCR Title 24, Part 11: California Green Building Standards (Title 24) was developed in response to continued efforts to reduce energy, water, and material consumption. The Title 24 standards are updated on a three-year schedule. The standards that are currently effective are 2022 standards which were adopted in August 2021, but 2025 standards have been adopted by the California Energy Commission (CEC) in September 2024 and will become effective on January 1, 2026.

In December 2021, the 2022 standards were approved by the California Building Standards Commission for inclusion into the California Building Standards Code. The Building Energy Efficiency Standards (Energy Code) apply to newly constructed buildings, additions, and alterations. They are a vital pillar of California’s climate action plan. The 2022 Energy Code will produce benefits to support the state’s public health, climate, and clean energy goals. The 2022 Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Buildings with permit applications applied for on or after January 1, 2023 must comply with the 2022 Energy Code. Public Resources Code §§ 25402 subdivisions (a)-(b) and § 25402.1 emphasize the importance of building design and construction flexibility by requiring the CEC to establish performance standards, in the form of an “energy budget” in terms of the energy consumption per square foot of floor space (CEC, 2022b). The 2025 standards will continue to build upon the 2022 standards and incorporate additional measures that will further reduce energy use and greenhouse gas emissions in a cost-effective manner.

The provisions of Title 24, Part 6 apply to all buildings for which an application for a building permit or renewal of an existing permit is required by law. They regulate design and construction of the building envelope, space-conditioning and water-heating systems, indoor and outdoor lighting systems of buildings, and signs located either indoors or outdoors. Title 24, Part 6 specifies mandatory, prescriptive and performance measures, all designed to optimize energy use in buildings and decrease overall consumption of energy to construct and operate residential and nonresidential buildings. Mandatory measures establish requirements for manufacturing, construction, and installation of certain systems, equipment, and building components that are installed in buildings.

California Renewable Portfolio Standard
Senate Bill 1078 (SB 1078), enacted in 2002, required retail sellers of electricity, including investor-owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017. In 2006, Senate Bill 107 (SB 107) changed the target date to 2010. Executive Order S-14-08, signed on November 2008, changed the State’s Renewable Energy Standard to 33 percent renewable energy by 2020. The executive order was codified by Senate Bill X1-2. Finally, Executive Order S-21-09 directed the ARB to adopt regulations by July 31, 2010 to enforce S-14-08.
 SECTION 4.5 – ENERGY 
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Senate Bill 350
Senate Bill 350 (SB 350), the Clean Energy and Pollution Reduction Act, was enacted in 2015 and includes aggressive clean energy goals in an effort to address climate change. The law creates new clean energy, clean air, and GHG reduction goals for 2030. SB 350 adopts a GHG reduction target of 40 percent below 1990 levels by setting targets for efficiency and renewable electricity, primarily in the energy and transportation sectors. The Act is part of a larger effort to reduce GHG emissions to 80 percent below 1990 levels by 2050. To implement SB 350, the Energy Commission is working closely alongside the California Public Utilities Commission (CPUC) and the ARB. Additionally, SB 350 tasks states agencies with studying and identifying barriers to, and opportunities for, utilizing clean, renewable energy in low-income communities (California Energy Commission, 2020a).

Senate Bill 100
Senate Bill 100 (SB 100), officially known as “The 100 Percent Clean Energy Act of 2018,” requires that public utilities, including electric corporations, must design renewable energy portfolios so that all retail sales by 2045 are generated from renewable and zero-carbon energy sources. SB 100 updates the state’s Renewables Portfolio Standard to ensure that by 2030 at least 60 percent of California’s electricity is renewable (CEC, 2021).

Assembly Bill 32
In 2006, the California State Legislature adopted Assembly Bill 32 (AB 32), the California Global Warming Solutions Act of 2006. AB 32 requires ARB to adopt rules and regulations that would achieve GHG emissions equivalent to statewide levels in 1990 by 2020 through an enforceable statewide emission cap which will be phased in starting in 2012. Emission reductions shall include carbon sequestration projects that would remove carbon from the atmosphere and best management practices that are technologically feasible and cost effective.

ARB’s AB 32 Scoping Plan, which was adopted in 2009, proposes a variety of measures including strengthening energy efficiency and building standards; targeted fees on water and energy use; a market-based cap-and-trade system; achieving a 33-percent renewable energy mix; and a fee regulation to fund the program. The 2014 update to the Scoping Plan identifies strategies moving beyond the 2020 targets to 2050. The cap-and-trade program established under Scoping Plan sets a statewide limit on sources responsible for 85 percent of California’s GHG emissions and has established a market for long-term investment in energy efficiency and cleaner fuels since 2012.

Low Carbon Fuel Standard
The Low Carbon Fuel Standard (LCFS), adopted and administered by the ARB in 2009 and implemented in 2011, is designed pursuant to California AB 32 and Executive Order S-01-07. The LCFS is one of nine action measures to reduce California’s GHG emissions and emissions that cause climate change and smog-forming pollutants by improving vehicle technology, improving fuel efficiency, and increasing alternative transportation options. The LCFSs encourage production and use of clean low-carbon fuels across the state and establish a ten-percent reduction in carbon intensity (CI) of fuel products by 2020. Moreover, providers of transportation fuels in the state must meet LCFS carbon intensity standards for each annual compliance period. In 2018, the CI benchmarks were updated to be consistent with the state’s 2030 GHG target enacted through SB 32 (California Air Resources Board, 2025a).
 SECTION 4.5 – ENERGY 
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California Air Resources Board (ARB) Advanced Clean Cars Regulation I & II The Advanced Clean Cars program considers multiple regulations into a single framework, including Low-Emission Vehicle (LEV) standards, greenhouse gas (GHG) emissions requirements and the ZeroEmission Vehicle (ZEV) mandate. The first phase, Advanced Clean Cars I, was adopted by ARB in 2012 followed by Advanced Clean Cars II in 2022. These regulations are designed to significantly reduce emissions from light-duty passenger vehicles, pickup trucks and SUVs while increasing the number of zero-emission vehicles to reach air quality and GHG emission goals. In October 2023, ARB introduced a new initiative to explore potential amendments to the Advanced Clean Cars II regulations including updates to tailpipe GHG standards and targeted revisions to the LEV and ZEV regulations (ARB, 2023a).

ARB - Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling The ARB Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling was adopted to reduce public exposure to particulate matter and associated toxic air contaminants by establishing restrictions, emissions standards, and other requirements for heavy-duty diesel engines. The regulation applies to any person, business, or agency that operates diesel-fueled vehicles within the State of California. A primary requirement is that drivers may not idle diesel engines for greater than five minutes at any location (California Code of Regulations Title 13 § 2485).

Sustainable Communities and Climate Protection Act of 2008- SB 375 SB 375 promotes the State’s climate goals by helping reduce GHG emissions through coordinated transportation, housing, and land use planning. Under SB 375, the ARB creates regional targets for GHG reductions from passenger vehicles for 2020 and 2035 for the 18 metropolitan planning regions.

The targets were last updated in 2018. In accordance with SB 375, each MPO must develop a Sustainable Communities Strategy (SCS) that would allow the region to meet the ARB’s targets.

Additionally, SB 375 provides incentives to encourage sustainable development, including CEQA exemptions (California Air Resources Board, 2020d).

Assembly Bill 758
Assembly Bill 758 (AB 758), adopted in 2009, requires the California Energy Commission (CEC) to develop a comprehensive program to achieve greater energy savings in the state’s residential and nonresidential buildings. AB 758 requires publicly-owned electric utilities to implement energy efficiency programs that encourage energy savings in GHG reductions and report its implementation status to the state. Programs may include, but are not limited to, upgrading infrastructure or providing consumers with information on energy usage (California Legislative Information, 2020c).

Senate Bill 1389
Senate Bill 1389 (SB 1389), adopted in 2002, required the CEC to develop an integrated energy policy report on or before November 2003, and every two years thereafter. The bill requires the Commission to conduct assessments and forecasts to evaluate energy supply, production, distribution, demand and price (California Legislative Information, 2020d). The scope in the most recent report, 2025 Integrated Energy Policy Report (IEPR), consists of advancing clean energy development, updating electricity and natural gas forecasts, and revising load-shift goals, with adoption of the final report anticipated in March 2026 (CEC, 2025).  SECTION 4.5 – ENERGY 
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California Environmental Quality Act
Appendix F of the CEQA Guidelines, titled Energy Conservation, identifies the state’s goals of conserving energy and presents means of achieving the goal, including decreased per capita energy consumption, decreased reliance on natural gas, and increasing reliance on renewable energy. To ensure that energy implications are considered when assessing proposed projects, CEQA requires that EIRs discuss potential energy impacts with an emphasis on reducing inefficient consumption of energy. Appendix F details the manner in which impacts to energy must be addressed in various parts of an EIR, including, but not limited to, the project description, mitigation measures, and alternatives.

Assembly Bill 1109
California Assembly Bill 1109 (AB 1109), also known as the Lighting Efficiency and Toxics Reduction Act, requires reductions in energy usage for lighting and is structured to reduce lighting electrical consumption by (1) at least 50 percent from 2007 levels for indoor residential lighting, and (2) at least 25 percent from 2007 levels for indoor commercial and all outdoor lighting by 2018.

Senate Bill 1339 (2018)
Senate Bill 1339 (SB 1339), enacted in 2018, requires the CPUC, in consultation with the CEC and California Independent System Operator (CAISO), to set forth actions and policies to facilitate the commercialization of microgrids for customers of large electrical corporations. CAISO and CPUC opened an Order Instituting Rulemaking (OIR), R.19-09-009, to implement key components of SB 1339 which include: (1) the development of appropriate rates, tariffs, and rules; (2) the removal of barriers to deploying microgrids within the service territories of large investor-owned utilities (IOUs); (3) safeguards to prevent cost shifts onto customers who do not benefit; and (4) a strong emphasis on protecting worker safety, public safety, and overall electric system reliability (CPUC, 2024). Electric Rule 21 is a California statewide tariff that governs the interconnection of distributed energy resources (DERs) to the electric grid. As part of CPUC R.19-09-009, Electric Rule 21 was revised to reduce interconnection barriers for microgrids and critical resiliency projects.

Regional
Southern California Edison Rule 21
SCE Rule 21 is the IOU’s version of the statewide Electric Rule 21 tariff that governs how DERs, such as solar panels, batteries, and microgrids, connect to the SCE electric grid (SCE, 2025a). Microgrids within SCE jurisdiction are subject to SCE Rule 21 technical, procedural, and safety requirements.

This includes submitting an interconnection application, undergoing grid impact screenings or studies, meeting smart inverter standards, and potentially paying for any necessary system upgrades.

Whether the microgrid exports power to the grid or operates solely behind-the-meter, it must comply with Rule 21 to ensure it does not compromise grid safety, reliability, or fairness to other ratepayers (SCE, 2025b).

SCAG 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (Connect SoCal 2024)
In compliance with SB 375, the Southern California Association of Governments (SCAG) adopted its Connect SoCal 2024 (2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS)) in April 2024. Connect SoCal 2024 Amendment #1 was adopted in September 2024. A  SECTION 4.5 – ENERGY 
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primary goal of the plan is to promote mobility and transportation services across the SCAG region, and in turn, meet goals set by the ARB. The RTP/SCS applies to six counties under SCAG’s jurisdiction; Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura. The plan charts a path toward a more mobile, sustainable, and prosperous region by making key connections between transportation networks, between planning strategies and between the people whose collaboration can make plans a reality. The goals of Connect SoCal fall into four core categories: economy, mobility, environment and healthy/complete communities. The plan explicitly lays out goals related to housing, transportation technologies, equity and resilience to adequately reflect the increasing importance of these topics in the region (SCAG, 2025).

Local
City of Redlands Climate Action Plan
The City of Redlands initially approved and adopted its Climate Action Plan (CAP) on December 5, 2017 alongside the city’s 2035 General Plan (Dyett & Bhatia, 2017). The latest CAP update, CAP 2050, was approved by the city on July 1, 2025. The CAP supports the City of Redlands’ commitment to lowering communitywide GHG emissions and demonstrates how the City will meet California's GHG reduction targets. The CAP will also serve as a guide to a more efficient environmental review process for future development projects in accordance with CEQA. The CAP lists policies and strategies included in the General Plan to promote energy efficiency, waste reduction, and resource conservation and recycling.

Redlands 2035 General Plan
The City of Redlands General Plan 2035, approved in May 2018, includes policies that will guide future development through the Plan’s 2035 planning horizon. Within the document’s “Sustainable Community” theme are policies for energy and water conservation, and GHG reduction. Section 4.7.2 lists General Plan emission reduction strategies which include energy conservation and increased communitywide renewable energy.

Additional optional measures and actions detailed in the CAP that would lead to further energy efficiency and are relevant to the proposed project include (Dyett & Bhatia, 2017):

B-1: Adopt a commercial energy conservation ordinance mandating all new nonresidential developments with more than 50 cars parked on open lots or on roofs of parking structures to use Photovoltaic (PV) panels for half or more of the cars (over and above other requirements) (Shortterm).

B-2: Adopt an ordinance requiring existing and new nonresidential developments to install PV panels to offset a portion of their energy use (Mid-term).

C-2: Create a citywide “Energy Challenge,” to promote cost-effective energy improvements, while having residents and building owners commit to reducing energy consumption (Short-term).

D-1: Promote incentive and rebate programs on the City’s website and by other means (Short-term).

D-2: Adopt a commercial and industrial energy conservation ordinance which requires buildings to meet specified energy efficiency measures such as requisite heating, ventilation, and air conditioning  SECTION 4.5 – ENERGY 
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improvements, service water system requirements, and improved refrigeration equipment, during development (as defined by the ordinance) (Short-term).

E-1: Promote commissioning programs on the City of Redlands website for commercial and industrial buildings (Short-term).

I-2: Promote the use of LED or other energy efficient lamps by publicizing rebate programs and information from SCE on the benefits of the use of LED or other energy efficient lighting on the City’s webpage (Short-term).

I-3: Evaluate the feasibility of adopting a minimum natural lighting and ventilation standard, developed based on local conditions. Demonstrate natural lighting and ventilation features in future renovations or new construction (Mid-term).

G-5: Adopt requirements for Zero-Emission Vehicle (ZEV) parking for new developments (Shortterm).

City of Redlands Municipal Code
City of Redlands Municipal Code Chapter 15.18 designates the California Energy Code, 2022 edition as the city’s adopted energy code. All required regulations, provisions, conditions, amendments and terms of the 2022 Energy Code are referred to and are adopted into the city’s municipal code.

4.5.3 Methodology
To assess whether the proposed project would result in the inefficient, wasteful, or unnecessary use of energy resources, CEQA Guidelines Appendix F were taken into consideration. Although CEQA Appendix F does not establish specific thresholds of significance, it emphasizes the importance of minimizing energy consumption and promoting efficiency. Its stated goals include reducing per capita energy use, decreasing reliance on fossil fuels and increasing the use of renewable energy sources. In accordance with recommendations included in CEQA Appendix F, the following factors were evaluated for environmental impacts:

1. The anticipated energy demand and efficiency, by fuel type and usage amount, during the project’s construction and operational phase. Analysis of the project’s construction phase considers offroad equipment fuel use, transportation fuel use, and electricity use. Analysis of the project’s operational and maintenance phase considers electricity use, natural gas use, and vehicle fuel use.

2. Potential impacts on local and regional energy supplies, including the need for additional generation or distribution capacity.

3. The project’s influence on peak and base period energy demand.

4. Compliance with applicable energy efficiency regulations and standards.

5. Impacts on the availability and sustainability of energy resources.

6. Projected transportation-related energy use and the extent to which the project supports efficient transportation options.
 SECTION 4.5 – ENERGY 
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This approach ensures a comprehensive evaluation of the project’s energy impacts, consistent with CEQA’s intent to promote energy conservation and long-term sustainability.

The California Emissions Estimator Model (CalEEMod) was used to calculate natural gas and electricity and vehicle miles traveled after project buildout. Electricity and natural gas was only calculated for Phase 1 project operations since it was assumed that the photovoltaic solar arrays and fuel cell microgrid central utility plant (CUP) built during Phase 2 will enable the project to operate independently of the electrical grid. The CUP is not anticipated to generate natural gas or electricityrelated emissions. Calculations are shown in Appendix D.

For mobile sources, CalEEMod calculated VMT and vehicle fleet mix for conditions at project buildout.

Conversion of results to energy values is shown in Appendix D.

4.5.4 Existing Conditions
Electricity
Southern California Edison (SCE) provides electricity to residents and businesses in Redlands.

Baseline self-generation energy in SCE’s planning area is forecast to be 16,532 GWh in 2030 and 19,994 GWh in 2040 (CEC, 2024); one GWH is equivalent to one million kilowatt-hours. Sources of SCE electricity in 2022, the latest year for which data are available, were 33 percent renewable, including 17 percent solar and 9.8 percent wind; 3.4 percent large hydroelectric; 24.7 percent natural gas; 8.3 percent nuclear; and 30.3 percent unspecified16 (SCE, 2022). SCE will provide electricity to the project site from existing electrical service lines.

Natural Gas
More than 90 percent of the natural gas used in California is produced from basins in Texas and New Mexico. Southern California Gas Company (SoCalGas) has a “network of transmission pipelines and four interconnected storage fields to deliver natural gas to nearly six million residential and business customers. The gas transmission system extends from the Colorado River on the east of SoCalGas’ approximately 20,000 square mile service territory, to the Pacific Coast on the west, and from Tulare County to the north, to the United States/Mexico border to the south supporting 21 million consumers in Southern California. SoCalGas operates four storage facilities that interconnect with its gas transmission system. These storage facilities – Aliso Canyon, Honor Rancho, La Goleta, and Playa del Rey – are located near the primary load centers of the SoCalGas system” (SoCalGas, 2019). In 2022, total natural gas consumption by the non-residential sector of San Bernardino County was approximately 295 million therms, equal to approximately 29.5 billion cubic feet of natural gas (CEC, 2023a).

Transportation Energy
According to the CEC, transportation accounted for over 42 percent of California’s total energy consumption in 2022 (EIA, 2022). In 2023, motor vehicles in San Bernardino County consumed 795 million gallons of gasoline and 245 million gallons of diesel fuel (CEC, 2023b). The transportation sector uses about 85 percent of the petroleum consumed in the state. However, as discussed in previous sections of this PEIR, the state has been working for over a decade on developing strategies 16 “Unspecified power is electricity that has been purchased through open market transactions and is not traceable to a specific generation source” (SCE,2022).
 SECTION 4.5 – ENERGY 
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and regulations for reducing petroleum use for transportation, such as use of alternative fuels and reducing vehicle miles traveled (VMT). The CEC predicts that the demand for gasoline will continue to decline over the next ten years, and that there will be an increase in the use of alternative fuels.

4.5.5 Environmental Impact Analysis

4.5.5.1 Thresholds of Significance
Appendix G of the CEQA Guidelines specifies two criteria for evaluating the significance of impacts on energy resources; a project would result in impacts related to energy resources if it would:

A. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or B. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

4.5.5.2 Analysis of Project Impacts
Threshold A: Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
or
Threshold B: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant Impact
Project construction and operation would consume energy. Sources of energy for these activities would include electricity, natural gas, and transportation fuels, such as diesel and gasoline. During project construction, minimal amounts of energy would be consumed in the form of electricity associated with the conveyance of water used for dust control and, on a limited basis, powering lights, electronic equipment, or other construction activities necessitating electrical power. Construction activities, including the construction of new buildings and facilities, typically do not involve the consumption of natural gas. Project construction would also consume fuels for transportation (delivery and haul truck trips and construction worker commute trips) for off-road construction vehicles and equipment on the project site. During operation of the project, energy use would include, but not be limited to, heating, ventilating, and air conditioning (HVAC); lighting; and the use of appliances and electronics. Energy would also be consumed during project operations related to water usage, solid waste disposal, and vehicle trips. In addition, the project could result in a significant impact to state or local plans for renewable energy or energy efficiency if it failed to meet energy efficiency standards or prevented energy suppliers from meeting renewable energy source targets.

Construction
The following forms of energy (and units of measurement) would be expended during construction:
• Diesel fuel for offroad equipment (gallons).
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• Motor vehicle fuel for worker commuting, vendor materials delivery and hauled waste disposal (gallons).

Natural gas is not typically consumed during project construction. It was therefore omitted from the construction energy analysis.

Offroad Equipment Fuel Use
The number of horsepower-hours of each offroad equipment type was calculated using equipment characteristics and scheduling generated by CalEEMod for the air quality and greenhouse gas emissions analyses (see Section 4.2). An estimated energy consumption factor for all construction equipment of

18.5 hp-hr/gal was obtained from the California Air Resources Board (ARB, 2005). As shown in Table

4.5-1, off-road equipment is estimated to use approximately 258,096 gallons of diesel fuel.

Table 4.5-1

CONSTRUCTION ENERGY USE
Category Gasoline (Gallons) Diesel (Gallons) Total (Gallons) Off-road Equipment - 258,096 258,096
Workers 187,643 270 187,913
Vendors 7,238 186,947 194,185
Haulers - 141 141
Total 194,881 445,454 640,335
Source: On-road Motor Vehicle Fuel Consumption (Workers, Vendors and Haulers) calculated by UltraSystems using EMFAC2021(v1.0.2) emissions inventory web platform tool (ARB, 2022) and CalEEMod (2022.1.1.26) (CAPCOA, 2022); see Appendix B1.

Transportation Fuel Use
During construction, petroleum-based fuels (i.e., gasoline and diesel fuel) would be consumed by offroad construction vehicles/equipment; by construction workers’ vehicles traveling to and from the project site, as well as by hauling of equipment and building materials to the site. Onroad vehicle miles traveled (VMT) for each construction subphase and each of the three trip types were calculated from results of the CalEEMod modeling. It was assumed that worker commuter trips will consist of light duty passenger vehicles, vendor trips will consist of medium and heavy duty vehicles and hauling trips will consist of only heavy-duty vehicles. Fuel efficiencies (in gallons per year) for gasoline and diesel vehicles in the San Bernardino portion of the South Coast Air Basin were calculated with the EMFAC2021 model, Version 1.0.2. Finally, VMT values were divided by fuel efficiencies to obtain fuel volumes used for construction. Transportation fuel use for workers, vendors, and haulers is shown above in Table 4.5-1.

During project construction, trucks and construction equipment would be required to comply with the ARB’s anti-idling regulations. The ARB’s In-Use Off-Road Diesel-Fueled Fleets regulation would also apply. Vehicles driven to or from the project site (delivery trucks, construction employee vehicles, etc.) are subject to fuel efficiency standards requirements established by the Federal Government (ARB, 2025d). Therefore, project construction activities regarding fuel use would not result in wasteful, inefficient, or unnecessary use of energy.  SECTION 4.5 – ENERGY 
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Electricity Use
During project construction, energy would be consumed in the form of electricity associated with the conveyance and treatment of water used for dust control and, on a limited basis, powering lights, electronic equipment, or other construction activities needing electrical power. Due to the fact that quantity of electricity associated with lighting and construction equipment that utilizes electricity is not easily quantifiable or readily available, the estimated electricity usage during project construction is speculative. Lighting used during project construction would comply with Title 24 standards/ requirements (such as wattage limitations). This compliance would ensure that electricity use during project construction would not result in the wasteful, inefficient, or unnecessary use of energy.

Operations
The following forms of energy would be expended during project operation:
• Electricity for the proposed medical offices and hospital buildings, street lighting, space and water heating, and conveyance and treatment of water.
• Gasoline for onroad motor vehicles.

Note that the proposed project includes photovoltaic solar arrays and a fuel cell microgrid central utility plant (CUP) that will enable the project to operate independently of the electric grid. The project is expected to include a connection to the Southern California Edison electrical grid for backup electric power. The CUP will be built in Phase 2, so energy usage was only calculated for Phase 1 operations.

Energy would be consumed during project operation for lighting, electric appliance use, space and water heating, water conveyance, landscaping maintenance, solid waste disposal, and vehicle trips from visitors, delivery vehicles and employees. Estimated project operational electricity and natural gas use, vehicle miles traveled per year, and fuel use are estimated below in Table 4.5-2 and Table 4.5-3, respectively.

The project’s operational electricity use after the development of Phase 1 is approximately 0.02 percent of the projected electricity demand in SCE’s planning area in 2030. The project’s anticipated increases in gasoline and diesel fuel consumption are less than 1 percent of San Bernardino County’s 2023 fuel consumption. The project is not expected to place a substantial demand on regional energy supplies, necessitate significant additional energy infrastructure, or cause a considerable increase in electricity demand during peak or off-peak periods.

Table 4.5-2
PHASE 1 PROJECT OPERATIONAL ELECTRICITY USE
Land Use Electricity Use (kWh/yr) Natural Gas (kBTU/yr) Medical Office Building 2,879,561 4,527,603
Parking Lot 283,327 -
Total 3,162,889 4,527,603
Source: Electricity and Natural Gas use calculated by UltraSystems with CalEEMod (2022.1.1.29).

Table 4.5-3

PROJECT OPERATIONAL VEHICLE MILES TRAVELED PER YEAR
Phase Vehicle Miles
Traveled per Year
Gasoline
(gallons/yr)
Diesel
(gallons/yr)
Total
(gallons/yr)
Phase 1 10,024,528 296,989 53,528 350,517
 SECTION 4.5 – ENERGY 
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Phase Vehicle Miles
Traveled per Year
Gasoline
(gallons/yr)
Diesel
(gallons/yr)
Total
(gallons/yr)
Phase 2 13,419,687 395,398 78,848 474,246
Phase 3 7,879,360 231,072 50,214 281,286
Phase 4 6,804,348 198,544 47,036 245,580
Total at Full Buildout 38,127,923 1,122,003 229,626 1,351,629 Source: On-road Motor Vehicle Fuel Consumption calculated by UltraSystems using EMFAC2021(v1.0.2) emissions inventory web platform tool (ARB, 2022) and CalEEMod (2022.1.1.29) (CAPCOA, 2022).

The project would comply with all applicable regulations and codes that require achievement of various levels of energy efficiency in building operation. These include (1) CCR Title 24, Part 6:

California’s Energy Efficiency Standards for Nonresidential Buildings (Title 24); (2) the 2022 California Green Building Standards Code (CalGreen; California Code of Regulations Title 24 Part 11); and (3) City of Redlands Municipal Code Chapter 15.18, California Energy Code (CENC).

Continued use of energy resources is consistent with the anticipated growth within the city and the general vicinity and would not result in energy consumption requiring a significant increase in energy production for the energy provider. Therefore, the energy demand by project operation would be less than significant.

Based on the information provided above, the proposed project would have a less than significant impact regarding wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. The project would also have a less than significant impact regarding conflict with or obstruction of a state or local plan for renewable energy or energy efficiency.

4.5.6 Cumulative Impacts
The area considered for cumulative impacts is the City of Redlands. Energy use in the study area is considered to be proportional to service population (that is, residents plus workers); however, energy use is actually expected to increase less than service population as energy efficiency regulations will grow more stringent in future years. (See the regulatory discussion in Section 4.5.2.) Other projects would be required to comply with federal, state, and local energy efficiency laws and regulations. Energy efficiency requirements grow more stringent with the passing of time; for example, see the descriptions of CCR Title 24 Part 11 (CALGreen) and SB 100 in Section 4.5.2 above.

Other projects would comply with energy conservation requirements in City of Redlands Municipal Code Chapter 15.18 which apply to commercial and public-use buildings.

Therefore, other projects in the City of Redlands combined with the proposed project would not involve wasteful, inefficient, or unnecessary consumption of energy and would not conflict with a state or local plan for energy efficiency or renewable energy. Cumulative impacts would be less than significant, and project impacts would not be cumulatively considerable.

4.5.7 Mitigation Measures
Project-level and cumulative impacts related to energy use have been determined to be less than significant. Therefore, no mitigation measures are required.

4.5.8 Level of Significance after Mitigation
Impacts related to energy use would be less than significant without mitigation.  SECTION 4.6 – GEOLOGY AND SOILS 
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4.6 Geology and Soils

4.6.1 Introduction
The following discussion addresses existing environmental conditions related to the stability of soils associated with seismic hazards and erosion within the project area. Compliance with existing laws, regulations, and standards would serve to reduce or avoid geology and soils impacts that could occur with implementation of the proposed project.

The information presented in this section and used for this analysis is based on the Geotechnical Investigation Report for the proposed project, prepared by Twining on March 31, 2023; a complete copy of the report is included as Appendix D7. As discussed in Section 2.0, Project Description, the project would consist of the following two elements: (1) Amendment No. 8 to Concept Plan 1; and (2) Planned Development No. 6. Planned Development No. 6 would consist of:
• Phase 1: Ambulatory Services Center/Medical Office Building No. 2 • Phase 2: Hospital with various support buildings, including a Central Utility Plant • Phase 3: Medical Office Building No. 3
• Phase 4: Possible expansion of the hospital
The Geotechnical Investigation Report outlines various geotechnical engineering recommendations focused on geological hazards and seismic design considerations applicable to the project. All project activities shall conform to the guidelines and recommendations described in the report, ensuring compliance with the specified geotechnical standards.

4.6.2 Regulatory Framework
Federal Regulations
Earthquake Hazards Reduction Act of 1977 (Public Law [PL] 95 – 124), as amended.

The Earthquake Hazards Reduction Act was passed by Congress in 1977 to “…reduce the risks of life and property from future earthquakes in the United States through the establishment and maintenance of an effective earthquake hazards reduction program.” This Act led to the establishment of the National Earthquake Hazard Reduction Program (NEHRP). In establishing the NEHRP, Congress recognized that earthquake-related losses could be reduced through improved design and construction methods and practices, land use controls and redevelopment, prediction techniques and early warning systems, coordinated emergency preparedness plans, and public education and participation programs. Congress reviewed and updated the Act in 2004, resulting in the NEHRP Reauthorization Act of 2004, PL 108–360, which was signed into law the same year. The four primary agencies involved in the NEHRP are:
• Federal Emergency Management Agency (FEMA) of the Department of Homeland Security. • The National Institute of Standards & Technology (NIST) of the U.S. Department of Commerce. • National Science Foundation (NSF).
• United States Geological Survey (USGS).
 SECTION 4.6 – GEOLOGY AND SOILS 
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U.S. Geological Survey Landslide Hazard Program
The USGS created the Landslide Hazard Program in the mid-1970s; the primary objective of the program is to reduce long-term losses from landslide hazards by improving our understanding of the causes of ground failure and suggesting mitigation strategies. The federal government plays the lead role in funding and conducting this research, while the reduction of losses due to geologic hazards is primarily a state and local responsibility. The City of Redlands Local Hazard Mitigation Plan (LHMP) outlines a mitigation strategy to help reduce and/or eliminate impacts from landslides within the city (City of Redlands, 2021).

Disaster Mitigation Act of 2000
The Disaster Mitigation Act of 2000 (DMA2K) (Public Law 106-390) amended the Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988 to establish a Pre-Disaster Mitigation (PDM) program and new requirements for the federal post-disaster Hazard Mitigation Grant Program (HMGP). DMA2K encourages and rewards local and state pre-disaster planning. Promote sustainability and seek to integrate state and local planning with the overall goal of strengthening statewide hazard mitigation. This enhanced planning approach enables local, tribal and state governments to identify specific strategies to reduce the probable impacts of natural hazards such as floods, fires, and earthquakes. To be eligible for hazard mitigation funding after November 1, 2004, local governments must develop a Hazard Mitigation Plan that incorporates specific program elements of the DMA2K law. The City of Redlands Local Hazard Mitigation Plan (LHMP) outlines the disaster mitigation strategies for the city (City of Redlands, 2021).

State Regulations
Alquist Priolo Earthquake Fault Zoning Act (Public Resources Code 2, Division 2, Chapter 7.5 §§ 2625 2630)
The Alquist-Priolo Earthquake Fault Zoning Act was enacted in 1972 to mitigate the hazard of surface faulting to structures for human occupancy. The main purpose of Alquist-Priolo is to prevent the construction of buildings used for human occupancy on the surface trace of active faults. Before a new project is permitted, cities and counties require a geological investigation to demonstrate that proposed buildings will not be constructed on active faults. The act addresses only the hazard of surface fault rupture and is not directed at other earthquake hazards, such as liquefaction or seismically induced landslides. The law requires the State of California geologist to establish regulatory zones around the surface traces of active faults and to issue appropriate maps. Maps are distributed to all affected cities, counties, and state agencies for use in planning and controlling new or renovated construction. Local agencies must regulate most development projects within zones. Projects regulated by the AlquistPriolo Act generally include new structures for human occupancy and subdivisions of land that will eventually include structures for human occupancy (CGS 2018a, p. 24).

California Multi-Hazard Mitigation Plan
The California State Multi-Hazard Mitigation Plan, also known as the State Hazard Mitigation Plan (SHMP), was approved by FEMA in 2013. The SHMP describes the current and planned activities to address natural hazards. Adopting the SHMP qualifies the State of California for federal funds in the event of a disaster. The State is required, under the Disaster Mitigation Act of 2000, described above, to review and update its SHMP and resubmit to FEMA approval at least once every five years to ensure continued eligibility for federal funding. SHMP provides goals and strategies to minimize risks  SECTION 4.6 – GEOLOGY AND SOILS 
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associated with natural hazards and respond to disaster situations. The SHMP notes that the primary sources of losses in the State of California are fire and flooding.

Hospital Facilities Seismic Safety Act of 1973
The Alfred E. Alquist Hospital Facilities Seismic Safety Act (HSSA) was passed in 1973 to ensure that hospitals in California comply with high construction standards and are reasonably capable of providing services to the public after a disaster. HSSA requires the establishment of seismic design regulations for hospital buildings and requires that new hospitals and additions to hospitals have the capacity, as far as is practical, to remain functional after a major earthquake. State law requires that all existing hospital buildings that provide general acute care licensed under the provisions of § 1250 of the California Health and Safety Code comply with the intention of the HSSA by 2030.

Seismic Safety Act of 1975
The Seismic Safety Act (CCR §§ 8870 – 8870.95) created a Seismic Safety Commission whose purpose was to report annually to the Governor on the findings, progress, and recommendations of the Commission related to the reduction of earthquake hazards. The Commission was to include individuals intended to represent the professions of architecture, planning, fire protection, public utilities, electrical engineering, mechanical engineering, structural engineering, soil engineering, geology, seismology, local government, insurance, social services, emergency services, and the state legislature. In 2006, the name of the Seismic Safety Commission was changed to the Alfred E. Alquist Safety Commission. Much of the Commission’s work is carried out by special committees, including:
• Planning & Budget Committee: Provides guidance to the executive director regarding planning, administrative, policy, and fiscal issues, and makes recommendations to the full commission. • Strong Motion Instrumentation Advisory Committee: Established by law to advise the CGS in the long-term operation and goals of the strong motion instrumentation program, including:
• Modification and upgrading of existing instrumentation and addition of new recording devices • General use and dissemination of data collected by the Strong Motion Instrumentation Program • Cooperative efforts with other strong motion programs including the USGS • Direct application of data for use by engineers in the design of structures and modification of building codes (SSC, 2021).

California Earthquake Hazard Reduction Act of 1986
The California Earthquake Hazards Reduction Act (CCR Title 2 § 8871.1 - 8871.5 et seq.; 1986 Act) is similar in purpose to the federal Earthquake Hazards Reduction Act of 1977 and was enacted by the State of California with the goal of reducing the earthquake hazard within California to “acceptable levels” through a significant reduction in the number of hazardous buildings and the expansion of scientific and engineering studies. The 1986 Act established a coordinated program that was assigned the task of specifying priorities, funding sources and amounts, schedules, and other resources needed to significantly reduce earthquake hazards across the state by January 1, 2000. As part of this program, the State Office of Emergency Services was to:
• Establish an interim state operations center in southern California to coordinate response to a major earthquake. The office shall also develop an operational communications plan for the center based on an inventory of current communication capabilities and an assessment of  SECTION 4.6 – GEOLOGY AND SOILS 
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structural vulnerabilities (7 CCR § 8871.3 [a]).
• Undertake a design analysis for the construction of a permanent state operations center in southern California, including an evaluation of telecommunication and information technology systems for emergency management functions (7 CCR § 8871.3[b]); and • Integrate and coordinate the California Emergency Services Act (Chapter 7 [commencing with § 8550]), the Disaster Assistance Act (Chapter 7.5 [commencing with § 8680]), the Economic Disaster Act of 1984 (Chapter 7.6 [commencing with § 8695]), the Planning and Zoning Law (Title 7 [commencing with § 65000]), the Community Redevelopment Law (Part 1 [commencing with § 33000] of Division 24 of the Health and Safety Code), and the Community Development Financial Assistance and Disaster Project Law (Part 1.5 [commencing with § 34000] of Division 24 of the Health and Safety Code) (7 CCR § 8871.5[e]).

Seismic Hazards Mapping Act of 1990
The Seismic Hazards Mapping Act of 1990 (Public Resources Code, Chapter 7.8, §§ 2690 2699.6) directs the California Department of Conservation (DOC), CGS, to identify and map areas prone to earthquake hazards of liquefaction, earthquake-induced landslides, and amplified ground shaking.

The purpose of the Seismic Hazards Mapping Act is to reduce the threat to public safety and minimize the loss of life and property by identifying and mitigating these seismic hazards.

The geologists of the Seismic Hazard Mapping Program collect geological, geophysical, and geotechnical data from numerous sources to compile the Seismic Hazard Zone Maps. They integrate and interpret these data regionally to assess the severity of seismic hazards and designate required investigation zones for areas prone to liquefaction and earthquake–induced landslides. Cities and counties are required to use seismic hazards zone maps in land use planning and building permit processes.

Zones of Required Investigation include, in addition to Alquist-Priolo Earthquake Fault Zones, areas of liquefaction and earthquake-induced landslides (CGS, 2021).

California State Building Code
The California Building Code (CBC; 24 CCR) contains the regulations that govern the construction of buildings in California. The CBC contains general building design and construction requirements related to fire and life safety, structural safety, and access compliance. The CBC provides minimum standards to protect life or limb, health, property, and public welfare by regulating and controlling the design, construction, quality of materials, use and occupancy, location, and maintenance of all buildings and structures, and certain equipment. Part 2 is pre-assembled with the International Building Code with the necessary California amendments. The 2022 CBC, Title 24 Part 2, Volume 2, Chapter 16 § 1613 contains specific seismic design criteria required for “Every structure, and portion thereof, including nonstructural components that are permanently attached to structures and their supports and attachments, shall be designed and constructed to resist the effects of earthquake motions according to ASCE 7 “(American Society of Civil Engineers "Minimum Design Loads and Associated Criteria for Buildings and Other Structures") with few exceptions (California Building Standards Commission [CBSC], 2022).

The 2022 CBC, Part 2, Volume 2, Chapter 18 §§ 1801 – 1803.7 specifically requires soil investigations, geotechnical reports, and geohazard reports conducted on soils that can be classified as questionable, critically expansive subjected to seismic hazards, including expansive soils, or prone to other seismic  SECTION 4.6 – GEOLOGY AND SOILS 
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hazards. The purpose of the subsequent geological technical report is to identify geological and seismic conditions that may require project mitigations. The reports shall contain data that assess the nature of the site and the potential for earthquake damage based on appropriate investigations of the geology of the region and site, the foundation conditions of the project and the potential seismic shaking at the site (CBC § 1803.7).

Local Regulations
City of Redlands Municipal Code
In accordance with § 50022.1 to § 50022.8 and § 50022.10 of the California Government Code, the City of Redlands, adopted the Redlands Municipal Code. This code has been updated and includes all ordinances up to and including Ordinance 2986, which was enacted on July 15, 2025.

City of Redlands General Plan
The current General Plan of the City is a policy document, or “blueprint” for future development, adopted by the City Council to guide future growth in Redlands. The 2035 General Plan is organized around chapters that include policies and actions to guide future development. The seven themes of the 2035 General Plan are as follows.

1. Distinctive City 5. Vital Environment

2. Prosperous Economy 6. Healthy Community

3. Livable Community 7. Sustainable Community

4. Connected City
The State-mandated elements of Land Use, Circulation, Open Space, Conservation, Health & Safety, Noise, and Housing are all integrated within the chapters noted above.

City of Redlands Local Hazards Mitigation Plan
In the year 2000, the Federal Emergency Management Agency (FEMA) implemented significant revisions to Title 44 of the Code of Federal Regulations (44 CFR). This set of amendments is officially recognized as the "Disaster Mitigation Act (DMA) 2000." In particular, § 322 (a-d) of the DMA 2000 stipulates that local governments must possess an approved and adopted Hazard Mitigation Plan (HMP) in order to qualify for federal disaster mitigation funding.

The Hazard Mitigation Plan must comprehensively outline the methodology for assessing potential hazards, evaluating risks and vulnerabilities, identifying and prioritizing mitigation strategies, and actively engaging the community - including the public, key stakeholders, and neighboring authorities or agencies - throughout the process.

In compliance with these requirements, the City of Redlands has updated its Local Hazard Mitigation Plan (LHMP), which was reviewed and subsequently adopted by the City Council on November 16, 2021, through Resolution 8268.

East Valley Corridor Specific Plan
The East Valley Corridor is the main gateway to the communities of the East San Bernardino Valley, including Redlands, Loma Linda, and San Bernardino. The area is largely undeveloped, and more than  SECTION 4.6 – GEOLOGY AND SOILS 
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half of the planning area is agricultural production. The proposed project is located within the East Valley Corridor Specific Plan area.

The purpose of this effort was to plan for the large areas of undeveloped land located along Interstate 10 in the Redlands-Loma Linda area to facilitate future industrial, commercial and residential development in an orderly and aesthetic way. The objectives of the plan are to provide a well-planned community that will attract major businesses to the area to provide a job base for the East Valley and strengthen the local economy, while ensuring high quality development through design guidelines and standards.

Paleontological Resources
A search of paleontological resource records by the Western Science Center for the Kaiser Permanente Medical Center Project located in the City of Redlands (included as Appendix D8) determined that the presence of any fossil material is unlikely at the project site.

The geological formations underlying the proposed project site are characterized by an assemblage of alluvial sand and gravel deposits from the Holocene epoch. These Holocene alluvial units are recognized for their high preservation value; however, the likelihood of encountering fossilized materials is minimal, attributed to the relatively recent geological age of these deposits.

If the development process requires significant excavation or disturbance at greater depths, the probability of encountering Pleistocene alluvial sediments increases. These sediments, being older, are more likely to contain fossil material. However, the Western Science Center has no recorded localities within the project area or within a radius of one mile, suggesting a lower probability of encountering significant paleontological resources in the vicinity (Western Science Center, 2023).

Methodology
The Geotechnical Investigation Report comprised a detailed analysis that involves the drilling, testing, sampling and logging of 13 exploration hollow stem auger bores, designated as B-1 through B-13. The holes that extended beyond five feet below ground surface (bgs) were executed using a CME-75 truck mounted drill rig, fitted with an 8-inch diameter hollow stem auger. Specifically, holes B-1 through B-4 were advanced to a depth of approximately five feet bgs, located within the boundaries of the proposed parking lot areas. On the contrary, wells B-5 through B-13 reached depths ranging from approximately 31.5 to 51.5 feet bgs, located within the intended footprint of the proposed building structure.

In the initial phase, all the holes were advanced to a depth of five feet bgs using a 5-inch diameter hand auger. This approach was implemented to mitigate the risk of inadvertently damaging existing underground utilities. The approximate locations of each boring are detailed in Figure 2 of the Geotechnical Investigation Report (Twinning, 2023, p. 2).

Geotechnical Engineering Recommendations
Based on the results of the literature review and field exploration, laboratory testing, and engineering analyses, the Geotechnical Investigation Report concluded that the proposed construction is feasible from a geotechnical point of view, provided that the recommendations in the report are incorporated into the design plans and are implemented during construction.

Project Design Features
 SECTION 4.6 – GEOLOGY AND SOILS 
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PDF-GEO-1: The project would implement all geotechnical recommendations for the development of the site, including earthwork, seismic design, retaining walls, shoring, and foundation design as specified in the Geotechnical Engineering Investigation prepared for the project; completed by Twining on March 31, 2023, and provided in Appendix D7 of this PEIR.

4.6.3 Existing Conditions
The project site encompasses an approximate 37-acre campus located at 1301 California Street (APN 0167-441-07-000) and is located within Concept Plan No. 1 of the East Valley Corridor Specific Plan.

Presently, the site features a 120,000 square foot building that serves as the Kaiser Permanente Redlands Medical Offices, along with associated parking facilities. A substantial portion of the site remains undeveloped and vacant.

Geology and Soils
The City of Redlands, in which the project site is located, is located north of the geomorphic province of the Peninsular Range, which features mountains and valleys in the northwest that are composed of granite and older metamorphic rock. The City of Redlands is located within the Redlands Valley, directly south of the Redlands Mountains, which serve as the eastern extension of the Transverse Ranges.

Topographically, the land generally descends toward the southwest (City of Redlands, 2017b, p. 3.6-1).

The surrounding area features a variety of surficial deposits categorized by age: very young, young, old, and very old. Very young deposits consist of recently transported sediments located in channels, washes, alluvial fans, plains, and hill slopes, incorporating very young wash deposits, alluvial-fan deposits, axial-valley deposits, and landslide deposits. Young deposits exhibit slight to moderate consolidation and are minimally dissected, consisting of young alluvial fan, axial valley, and landslide deposits. The old deposits are moderately consolidated and show slight to moderate dissection, including old alluvial fans, axial valley, and landslide deposits. Very old deposits demonstrate moderate to well consolidation or lithification along with moderate to well dissection; these include very old alluvial fan and axial valley deposits (City of Redlands, 2017b, pp. 3.6-2).

The predominant soil series within the project site is the Hanford soil series. This series is prevalent in the East Valley Corridor Specific Plan area and along the Zanja and San Timoteo creeks. Hanford soils are characterized by deep and well-drained profiles formed in moderately coarse alluvium, mainly derived from granite. These soils typically develop on streambeds, floodplains, and alluvial fans, prevailing in areas with lower slopes (City of Redlands, 2017b, pp. 3.6-5).

The current surface elevation of the site is approximately 1,148 feet above mean sea level (AMSL). Within the site, several notable elevation points correspond to existing basins. Specifically, the bottom of the large basin located in the northwest corner of the site is recorded at approximately 1,132 feet AMSL. Adjacent to this, the elevation at the base of the basin located in the northwest corner of the existing building measures approximately 1,140 feet AMSL. Furthermore, the basin that extends north-south to the west of the existing medical office building has a bottom elevation of approximately 1,143 feet AMSL (Twining, 2023).

According to the Geotechnical Investigation Report for the project site, it is underlain by Holoceneaged alluvial deposits consisting of “alluvial sand and clay of valley areas” (Twining, 2023, p. 4).

Artificial Fill
The subsurface conditions encountered in the Geotechnical Investigation Report and previous other borings consisted of approximately five feet of artificial fill on the eastern edge of the building to approximately three feet of artificial fill on the western edge of the building. The fill in the proposed  SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-8 Program Environmental Impact Report November 2025
building area and other areas consisted of silty sand with some sandy silt. The fill is generally dark brown to reddish brown, slightly moist, and consists mainly of fine sand.

It appears that the fill was associated with previous grading operations performed at the site; however, no documentation was available for the placement and compaction of the fill was available. It is recommended in the Geotechnical Investigation Report that any compact reports related to the fill placement be provided for an evaluation; if no documents are available, the fill materials will require removal and replacement as part of the grading for the Medical Office Building pad (Twining, 2023,p. 4).

Alluvial Fan Deposits
Holocene-aged old alluvial deposits underlie the site to the maximum depth of exploration. The deposits in the proposed building area and most other areas consist predominantly of medium-tovery-dense silty sand with some sandy silt that varied primarily from stiff to very stiff.

The subsurface is characterized by alluvial deposits from the Holocene epoch, which extend down to the maximum depth reached during exploration. The geological composition of the project site is mainly medium dense to very dense silty sand, indicating a stable substrate that has the structural integrity for construction applications (Twining, 2023, p. 4).

4.6.3.1 Corrosive Soils
The potential for near-surface on-site materials to corrode buried steel and concrete improvements was evaluated in the Geotechnical Investigation Report. Laboratory tests were performed on a selected near-surface soil sample to evaluate pH and electrical resistivity, as well as chloride and sulfate contents. pH and electrical resistivity tests were performed according to California Test 643, and sulfate and chloride tests were performed according to California Tests 417 and 422. Laboratory test results are presented in Appendix B of the Geotechnical Investigation Report (Twining, 2023, p. 13).

The Geotechnical Investigation Report recommends that Type II cement and a water cement ratio of no more than 0.50 be used in the project. The test results indicate that the potential for chloride attack of reinforcing steel is low in concrete structures and pipes in contact with subsurface materials. However, if necessary, a corrosion specialist may be consulted for protection against chloride attack. After such compliance, project development would not cause substantial hazards to people or structures arising from corrosive soils (Twining, 2023, p. 13).

A factor to evaluate the corrosivity of buried metal is electrical resistivity. The electrical resistivity of a soil is a measure of resistance to electrical current. The corrosion of the buried metal is directly proportional to the flow of electrical current from the metal into the soil. As the resistivity of the soil decreases, the corrosivity generally increases. The test results indicate that the site soils have a minimum electrical resistivity value of 2,200-ohm centimeters. Soil is not considered to be corrosive to buried metals. Corrosion correlations between resistivity and corrosion potential published by the National Association of Corrosion Engineers indicate that soils are mildly corrosive to buried metals. On the basis of that, corrosion protection should be considered for metals in contact with soils at the site. Corrosion protection may include the use of epoxy or asphalt coatings. A corrosion specialist should be consulted on appropriate protection for buried metals and suitable types of piping (Twining, 2023, p. 14).  SECTION 4.6 – GEOLOGY AND SOILS 
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4.6.3.2 Faults and Seismic Hazards
Earthquake Faults
The City of Redlands is delineated by the San Andreas fault zone in the northeast and the San Jacinto fault zone in the southwest. In addition, it is traversed by the Crafton Hills fault zone, which extends through southern Redlands, Crafton, and Mentone. Portions of these fault zones are designated as Alquist-Priolo Earthquake Fault Zone (EFZ) (City of Redlands, 2017b, p. 3.6-2).).

The project site is not located within an Alquist-Priolo EFZ or within any regional fault zones as mapped by the City of Redlands. The nearest Alquist-Priolo EFZ is located approximately two miles northeast of the site (see Figure 4.6-1). The closest known active fault is the San Jacinto fault system, which includes the Redlands South fault system and is about 2.5 miles to the northeast (see Figure 4.6-2).

The San Andreas and San Jacinto faults are classified as right-lateral strike-slip faults, exhibiting a northwest-southeast trend. In contrast, the Crafton Hills fault zone is characterized by a system of normal dip-slip faults. The San Andreas Redlands fault has the potential to generate an earthquake with a maximum moment magnitude (Mw) of 7.5, while the San Jacinto Redlands fault is capable of producing an earthquake with a maximum moment magnitude of 6.7.

Although the Crafton Hills fault zone is recognized as an active fault (i.e., it experienced movement since the Holocene epoch), the California Geological Survey currently refrains from offering a maximum potential magnitude prediction for this fault system (City of Redlands, 2017b, p. 3.6-2).

Additional faults close to the City of Redlands include the San Gorgonio Pass fault zone, located three miles away with estimated magnitudes ranging from Mw 6.0 to 7.0; the Banning fault zone, 14 miles away with probable magnitudes of Mw 6.0 to 7.2; and the Cucamonga fault zone, located 26 miles away with expected magnitudes from Mw 6.0 to 7.0 (City of Redlands, 2017b, p. 3.6-2).

The Geotechnical Investigation Report reviewed active or potentially active faults within 62 miles of the site from the 2008 USGS fault database. Faults within 31 miles of the site are considered to represent the closest and most significant potential hazard to the site with respect to potential ground surface rupture and generate strong ground motion in the event of a moderate to large earthquake. Based on the review of geologic and seismologic literature and site evaluation, the Geotechnical Investigation Report argues that the likelihood of surface fault rupture at the site during the life of the proposed improvements is remote (Twining, 2023, p. 7).

Ground Shaking
The shaking of the ground during an earthquake is influenced by various factors, including the magnitude of the earthquake, the distance from the fault line, the focus of the release of seismic energy, and the characteristics of the geological materials present. Furthermore, the composition of the underlying soils plays a critical role in amplifying the shaking of the ground. Areas with unconsolidated alluvium typically experience more significant ground motion, as these materials are effective in transmitting intense seismic vibrations to the surface. Given that a substantial portion of the project site is composed of alluvial deposits, there exists a greater risk of severe ground shaking during seismic events (City of Redlands, 2017b, p. 3.6-3).

Landslides and Erosion
Slope failure or landslides can be triggered by seismic activity, even in areas considered to have only moderate or low susceptibility to such events. The probability of landslides increases during the wet  SECTION 4.6 – GEOLOGY AND SOILS 
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season and in regions characterized by elevated groundwater levels and saturated soils. Data from the United States Geological Survey identify certain areas of southern Redlands, as well as smaller portions on the eastern side of the city, as having moderate to high potential for landslides (City of Redlands, 2017b, p. 3.6-3).

However, the Flood Hazards Map outlined in the General Plan of the City of Redlands indicates that the site in question is not located within a landslide-prone area. Currently, there are no known landslides that affect the site, nor are they located within the trajectory of any recognized or potential landslide events. In addition, the site is not close to significant slopes. Consequently, the potential for earthquake-induced landslides occurring at this site is assessed to be low (Twining, 2023, p. 10).  SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-11 Program Environmental Impact Report November 2025
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 SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-12 Program Environmental Impact Report November 2025
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 SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-13 Program Environmental Impact Report November 2025
Liquefaction occurs when vibrations or increased water pressure within the soil cause particles to lose contact with one another and behave like a liquid. Younger soils or recent deposits, such as unconsolidated alluvium, are more susceptible to liquefaction than older, more compacted materials; saturated soils are also especially prone to this hazard. Areas located along waterways tend to have the highest susceptibility to liquefaction as a result of their recent alluvial deposits and high groundwater levels. Liquefaction hazards are delineated in the General Plan EIR. The only portions of the City of Redlands mapped with susceptibility to liquefaction are along the Santa Ana River Wash and in Mentone.

Because most of the City of Redlands is located in alluvial fan deposits, there may be potential impacts related to liquefaction as the result of severe seismic shaking (City of Redlands, 2017b, p. 3.6-4).

However, the project site is not located within areas susceptible to liquefaction, as mapped by the City of Redlands (see Figure 4.6-3). Furthermore, it is expected that the groundwater level is expected to be deeper than 50 feet. Therefore, it is concluded that the potential for liquefaction at this site is negligible.

Additionally, the potential for related liquefaction effects (i.e., liquefaction-induced bearing capacity failure, surface manifestation, and lateral spread) at the site is considered minor because the site has negligible liquefaction potential (Twining, 2023, p. 10).

4.6.3.3 Groundwater
The Geotechnical Investigation Report indicates two water wells within 1,300 feet of the site.

Historically, groundwater levels have exhibited significant fluctuations, reaching a minimum depth of 33 feet below ground surface (bgs) in the 1930s and 1940s, and a maximum depth of 210 feet bgs observed during the 1960s. In 1986, one well recorded a groundwater level at approximately 74 feet bgs. A geotechnical report executed by Woodward-Clyde in 1989 for a larger parcel, which encompasses the current site, identified groundwater at a depth of 50 feet bgs in one of its boreholes.

Twining's findings in 2023 confirmed that no groundwater was encountered in any borings reaching depths of up to 60 feet bgs (Twining, 2023, p. 5).

According to the California Department of Water Resources Water Data Library, there are two wells in close proximity to the site:
• State Well Number 01S03W19L001S
- Site Code: 340686N1172353W001
- Ground Surface Elevation: 1,130.53’ AMSL
- Location: Approximately 2,200’ southwest
• State Well Number 01S03W19G002S
- Site Code: 340739N1172334W001
- Ground Surface Elevation: 1,137.52’ AMSL
- Location: Approximately 1,500’ northwest
The first well groundwater elevation measurements ranged from 944 feet (AMSL) to 981 feet from 2005 to 2008, corresponding to a groundwater depth of 166 feet bgs to 203 feet bgs. The second well reported groundwater elevations from a peak of 1,122 feet in 1945 to a low of 912 feet in 1966. After a decline from the late 1940s to 1966, groundwater levels began to rise and peak in 1987 at 1,061 feet. From 1991 to 2000 (when monitoring ceased) levels remained relatively stable around1,018 feet, which translates to approximately 129 feet bgs at the current site (Twining, 2023, p. 5).

During recent drilling operations for the Geotechnical Investigation Report, three borings were carried out at a depth of 51.5 feet bgs. No groundwater was encountered in any of these wells. Based on the data provided by Crandall, the California Water Data Library, and recent borings, it is prudent  SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-14 Program Environmental Impact Report November 2025
to assume that the depth to groundwater is greater than 50 feet bgs for design considerations (Twining, 2023, p. 5).

It was noted in the Geotechnical Investigation Report that groundwater conditions may vary across the site due to various stratigraphic and hydrologic factors. In addition, these conditions are subject to temporal changes arising from seasonal and meteorological variations, as well as human activities in the vicinity. Therefore, continuous monitoring and evaluation are recommended to ensure an accurate understanding of groundwater dynamics at the site (Twining, 2023, p. 5).

4.6.3.4 Flooding, Inundation, Tsunami, and Seiche
Tsunamis are generated by substantial landslides that occur in or near marine environments.

Seiches are characterized by the oscillation of standing waves within a confined or partially confined water body, such as a lake, reservoir, or bay, after the initial driving force has subsided. These oscillations can produce waves that reach several heights, potentially causing significant damage along coastal areas. The greatest impact of a seiche can manifest itself as the overtopping and subsequent failure of a dam.

The project site is located inland from coastal regions and does not encompass any enclosed or semi-enclosed water bodies. Based on the flood hazards map outlined in the General Plan of the City of Redlands, the location of the project does not fall within the 100-year or 500- year floodplain, nor does it lie within a dam inundation zone. Consequently, the risks associated with floods, inundations, tsunamis, and seiches at this site are classified as low (Twining, 2023, pp. 10-11).

4.6.4 Environmental Impact Analysis

4.6.4.1 Thresholds of Significance
CEQA Guidelines Appendix G, Environmental Checklist, sets forth the following significance thresholds criteria; a project would result in impacts related to geology and soils if it would:

A. Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) 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? Refer to Division of Mines and Geology Special Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including liquefaction? iv) Landslides?
 SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-15 Program Environmental Impact Report November 2025
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 SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-16 Program Environmental Impact Report November 2025
B. Result in substantial soil erosion or the loss of topsoil? C. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
D. 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? E. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? F. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The Initial Study, included as Appendix A1 to this PEIR, determined that impacts related to Significance Threshold E would result in no impacts because the proposed project would connect to the existing local sewer system and would not rely on septic tanks or alternative wastewater disposal systems.. Therefore, Threshold E will not be analyzed in this EIR.

The information in this section is based on the following technical reports. • Geotechnical Investigation Report, Medical Office Building 2 (MOB 2) project at the Kaiser Redlands site located at 1301 California Street in Redlands, California, Assessor’s Parcel Number (APN): 0167-441-07-000. Prepared by Twining, dated March 31, 2023. A complete copy of this report is included in Appendix D7.
• Paleontological Records Search for the Kaiser Permanente Medical Center Project located in the City of Redlands. Prepared by the Western Science Center on October 31, 2023. A complete copy of this report is included in Appendix D8.

4.6.4.2 Analysis of Project Impacts
Threshold A: Would the Project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) 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? Refer to Special Publication 42 of the Division of Mines and Geology.

Less Than Significant Impact
The Alquist-Priolo Zones Special Studies Act defines active faults as those that have experienced surface displacement or movement during the last 11,000 years. As discussed above, there are no mapped Alquist-Priolo earthquake fault zones, or fault zones mapped by the City of Redlands, that pass through or near the proposed project site. Therefore, there would be a less than significant impact.  SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-17 Program Environmental Impact Report November 2025
ii) Strong seismic ground shaking?
Less Than Significant Impact
Earthquakes in and near the proposed project have the potential to cause significant shaking of the ground. Development consistent with the General Plan may occur in locations where seismic ground shaking is a potential concern. However, the project would be constructed in accordance with the California Building Code (CBC); § 1613 of the CBC requires that all structures be designed and constructed to withstand the effects of earthquake motions according to the minimum design loads for buildings and other structures established by the American Society of Civil Engineers. Therefore, in compliance with the CBC, the proposed project would result in less than significant impacts. iii) Seismic‐related ground failure, including liquefaction? Less Than Significant Impact
Liquefaction is the phenomenon in which loosely deposited granular soils with silt and clay contents generally less than approximately 35 percent, and non-plastic silts located below the water table undergo rapid loss of shear strength when subjected to strong earthquake-induced ground shaking.

Shaking of the ground for a sufficient duration results in loss of grain-to-grain contact due to a rapid rise in the pressure of the pore water and causes the soil to behave as a fluid for a short period of time.

As noted above, the site is not within an area susceptible to liquefaction mapped by the City of Redlands. Furthermore, the groundwater is likely deeper than 50 feet. As discussed above and in Section 5.3 of the Geotechnical Investigation Report (Appendix D7), liquefaction occurs when vibrations or increased water pressure within the soil cause particles to lose contact with one another and behave like a liquid. Therefore, the liquefaction potential is less than significant. iv) Landslides?
Less Than Significant Impact
As shown above, the site is not located within an area susceptible to landslides. There are no known landslides at the site or the site in the path of any known or potential landslides. Furthermore, the site is not adjacent to significant slopes. The potential for earthquake-induced landslides to occur at the site is considered low. Therefore, the impacts would be less than significant.

Threshold B: Would the Project result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact
The project site is particularly susceptible to erosion during the construction phase due to exposure of the soil. To mitigate the risks associated with erosion, the project will adopt best management practices (BMP) in accordance with the 2022 General Construction Permit (GCP) issued by the State Water Resources Control Board.

The 2022 GCP refers to the current permit issued by the California State Water Board, which regulates stormwater runoff from construction sites throughout the state, meaning that most construction projects exceeding a certain land disturbance threshold must comply with its  SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-18 Program Environmental Impact Report November 2025
requirements to discharge stormwater legally and mandates the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP) to manage stormwater runoff during construction activities (SWRCB, 2024).

Compliance with the 2022 GCP and the implementation of BMPs would ensure that the project would not result in substantial soil erosion or the loss of topsoil. The project will not result in substantial soil erosion or loss of topsoil and therefore, impacts would be less than significant.

Threshold C: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on or offsite landslide, lateral spreading, subsidence, liquefaction, or collapse? Less Than Significant Impact
As discussed in detail above, the project site is not located within an Alquist-Priolo Earthquake Fault Zone or other designated area of known geologic instability, and the potential for landslide, lateral spreading, subsidence, liquefaction, or collapse is considered negligible based on site-specific investigations. In addition, compliance with the recommendations of the Geotechnical Investigation Report is a condition of issuance of a grading permit by the City of Redlands, ensuring that any standard design and construction measures are implemented. For these reasons, 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. No mitigation is required, and impacts would be less than significant.

Threshold D: Would the Project 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?
Less Than Significant Impact
Expansive soil shrinks and expands with changes in soil moisture. Soil moisture can change from landscape irrigation, rainfall, and utility leakage. According to the Geotechnical Investigation Report, consolidation test results show that the subsurface materials of the site have negligible collapse. One sample (boring B-12 at 5 feet bgs) exhibited 8.3 percent collapse potential when wet, but this result is not considered reliable because of the obvious relatively large sample disturbance observed (Twining, 2023, p. 13).

Based on the results of laboratory potential expansion index tests, surficial soils have a very low expansion potential and would have a less than significant impact.

Threshold F: Would the Project directly or indirectly destroy a unique paleontological resource or site or a unique geologic feature?
Less Than Significant Impact with Mitigation Incorporated The likelihood of encountering fossil material is minimal; however, if excavation activities disrupt deeper sediment layers that correspond to the early Holocene or Late Pleistocene epochs, such findings could have considerable scientific importance. If excavation activity disturbs deeper sediment dating to the earliest parts of the Holocene or Late Pleistocene periods, the material would be scientifically significant. The project would implement PDF-GEO-1, ensuring that all geotechnical recommendations contained in the Geotechnical Investigation Report (Twining, March 31, 2023;  SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-19 Program Environmental Impact Report November 2025
Appendix D7) are incorporated into site development, including earthwork, seismic design, retaining walls, shoring, and foundation design. Therefore, impacts related to geology and soils would be less than significant with implementation of PDF-GEO-1.

4.6.5 Cumulative Impacts
Geology and soils impacts are site specific and generally do not combine to result in cumulative impacts. Similar to the proposed project, future development projects would be required to comply with applicable state and local building regulations including the CBC and City of Redlands Municipal Code Title 15, Buildings and Construction. Site-specific geologic hazards would be addressed in each project’s geotechnical investigation. Therefore, no significant cumulative impact would occur.

4.6.6 Mitigation Measures
MM-GEO-1: A qualified paleontologist, approved by the City of Redlands and the Western Science Center, must be retained prior to excavation and grading activities at the project site.

1. Prior to the earth-moving activities, the paleontologist shall develop a site-specific Paleontological Resources Impact Mitigation Program (PRIMP) to be implemented in support of the Project in order to mitigate potential adverse impacts to paleontological resources. The PRIMP shall follow guidelines developed by the Society for Vertebrate Paleontology and include monitoring of ground disturbance activities in sediments that are likely to include paleontological resources, specimen recovery, and screen washing; preparation of any collected specimens to the point of identification; curation of any collected specimens to a museum repository with permanent, retrievable storage; and preparation of a final paleontological survey report that would provide details of monitoring, fossil identification, and repository arrangements. The Project Applicant shall then comply with the recommendations of the Project Paleontologist and requirements of the PRIMP. At a minimum, the PRIMP shall include the following:

1. Project and location

2. Regulatory setting

3. Geology of the site

4. Paleontological resources and survey results

5. Paleontological sensitivity of the site

6. Paleontological resources mitigation and monitoring measures such as:
a. Coordination with construction personnel and training b. Details of training and materials
c. Frequency and location of inspections
d. When and how grading/excavation activities will be diverted e. Procedures of fossil recovery, removal, treatment, transport, and deposition facility
f. Recording, documentation, and reporting procedures

2. Before the mitigation program begins, the paleontologist or monitor must coordinate with the appropriate construction contractor personnel to provide information regarding the requirements of the City or Redlands, as applicable, for the protection of paleontological resources. Contractor personnel shall be briefed on the procedures to follow in the event that fossil remains, and a previously unrecorded fossil site are encountered by earth-moving activities, particularly when the monitor is not on site.

3. The qualified paleontologist shall perform periodic inspections of excavation and grading  SECTION 4.6 – GEOLOGY AND SOILS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.6-20 Program Environmental Impact Report November 2025
activities at the project site to determine the presence of fossiliferous soils. The frequency and location of inspections shall be specified in the PRIMP and will depend on the depth of excavation and grading activities and the materials being excavated. If paleontological materials are encountered, the paleontologist must temporarily divert or redirect the grading and excavation activities in the area of the exposed material to facilitate evaluation and, if necessary, salvage. The authority of the paleontologist to temporarily halt construction in part of the project site must be included in the project grading and construction plans. A copy of the report of the paleontological survey is submitted to the Western Science Center. Any fossils recovered during mitigation shall be deposited in an accredited and permanent scientific institution for the benefit of current and future generations.

4.6.7 Level of Significance after Mitigation
The Geotechnical Investigation Report outlines site-specific geotechnical engineering recommendations focused on geological hazards and seismic design considerations applicable to the project. In accordance with PDF-GEO-1, all project activities must comply with the guidelines and recommendations delineated in the Geotechnical Investigation Report to ensure adherence to applicable geotechnical standards. Additionally, implementation of MM-GEO-1 would reduce the potential impacts on paleontological resources to less than significant.

At the federal level, the U.S. Environmental Protection Agency (USEPA) administers climate change and energy efficiency programs intended to reduce greenhouse gas (GHG) emissions. These include voluntary initiatives such as Energy Star, which encourages energy efficiency in building design, appliances, and equipment. In addition, the federal Mandatory Greenhouse Gas Reporting Rule— updated on September 22, 2022—requires certain large sources and suppliers of GHGs to report emissions data to the USEPA, thereby supporting federal climate policy and emission reduction tracking.

The project is also informed by national energy policy. The Energy Policy Act of 1992 introduced measures to promote alternative fuels, energy efficiency, and renewable energy, while the Energy Policy Act of 2005 expanded these initiatives by providing tax incentives, loan guarantees, and regulatory support for cleaner energy technologies and conservation practices. Together, these policies establish a framework under which projects are expected to incorporate energy-efficient practices and contribute to the broader reduction of GHG emissions.

Accordingly, through compliance with applicable geotechnical recommendations (PDF-GEO-1), mitigation measures (MM-GEO-1), federal Clean Air Act standards, USEPA climate change and energy efficiency programs, and federal energy policy requirements, the project would reduce potential geotechnical, paleontological, and climate-related impacts to less than significant levels.  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.7-1 Program Environmental Impact Report November 2025

4.7 Greenhouse Gas Emissions

4.7.1 Introduction
Gases that trap heat in the atmosphere are called greenhouse gases (GHGs), since they have effects that are analogous to the way in which a greenhouse retains heat. GHGs are emitted by both natural processes and human activities. The accumulation of GHGs in the atmosphere regulates the earth’s temperature. The State of California has undertaken initiatives designed to address the effects of GHG emissions, and to establish targets and emission reduction strategies for GHG emissions in California.

Activities associated with the project, including construction and operational activities, would have the potential to generate GHG emissions.

This section discusses the main GHG species of interest, regulations pertaining to climate change, the project’s consistency with plans for reducing GHG emissions, existing and predicted future GHG emissions from the project site, and their significance under CEQA.

4.7.2 Regulatory Framework
Federal
The U.S. Environmental Protection Agency (USEPA) collects several types of GHG emissions data.

These data help policy makers, businesses, and the USEPA track GHG emissions trends and identify opportunities for reducing emissions and increasing efficiency. The USEPA has been maintaining a national inventory of GHG emissions since 1990 and in 2009 established mandatory reporting of GHG emissions from large GHG emissions sources.

Clean Air Act
Before January 20, 2017, the USEPA was implementing regulatory initiatives such as mobile source GHG emission standards and the Clean Power Plan; partnering with the private sector through voluntary energy and climate programs; and reducing USEPA's carbon footprint with the federal GHG requirements and USEPA's Strategic Sustainability Performance Plan. The first Trump administration had a different strategy in relation to climate change and took the USEPA in a new direction (USEPA, 2017). Executive Order on Energy Independence (Federal Register, 2017) (Executive Order 13783) specifically addressed revisions in the Clean Power Plan and standards of performance for GHGs for new stationary sources; CH4 standards for the oil and gas sector; and lightduty vehicle GHG standards. On January 20, 2021, former President Biden issued Executive Order 13990 (White House, 2021), which rescinded the Executive Order on Energy Independence, along with several other executive orders concerning energy, climate, and environmental protection.

Among the stated goals of Executive Order 13990 are “to reduce greenhouse gas emissions” and “to bolster resilience to the impacts of climate change.” On January 20, 2025, the current Trump administration issued Executive Order 14154, Unleashing American Energy, which aims to increase domestic energy production by removing regulatory barriers to reduce energy costs for consumers.

It revokes Executive Order 11991, directing the Council on Environmental Quality (CEQ) to rescind its National Environmental Policy Act (NEPA) regulations (Federal Register, 2025).

State
Through several pieces of legislation, gubernatorial executive orders, and administrative regulations that relate to GHG emissions and climate change, California has set aggressive goals for GHG  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.7-2 Program Environmental Impact Report November 2025
reductions within the state. Per Senate Bill (SB) 97, the California Natural Resources Agency adopted amendments to the CEQA Guidelines which address the specific obligations of public agencies when analyzing GHG emissions under CEQA to determine a project’s effects on the environment. However, neither a threshold of significance nor any specific mitigation measures are included or provided in these CEQA Guidelines amendments. The major state provisions for reducing GHG emissions are as follows
Assembly Bill 32 (AB 32)
The California Global Warming Solutions Act of 2006, widely known as AB 32, requires the California Air Resources Board (ARB) to develop and enforce regulations for the reporting and verification of statewide GHG emissions. The ARB is directed to set a statewide GHG emission limit, based on 1990 levels, to be achieved by 2020. The bill set a timeline for adopting a scoping plan for achieving GHG reductions in a technologically and economically feasible manner. The heart of the bill was the requirement that statewide GHG emissions be reduced to 1990 levels by 2020.

The AB 32 Scoping Plan (ARB, 2008) contained the main strategies to achieve the 2020 emissions cap. The plan was developed by the ARB with input from the Climate Action Team and proposes a comprehensive set of actions designed to reduce overall carbon emissions in California, improve the environment, reduce oil dependency, diversify energy sources, and enhance public health while creating new jobs and improving the state’s economy. The GHG reduction strategies contained in the AB 32 Scoping Plan include direct regulations, alternative compliance mechanisms, monetary and non-monetary incentives, voluntary actions, and market-based mechanisms such as a cap-and-trade system.

In May 2014, the ARB adopted the First Update to the AB 32 Scoping Plan (ARB, 2014). This update identified the next steps for California’s leadership on climate change. The first update to the initial AB 32 Scoping Plan described progress made to meet the near-term objectives of AB 32 and defined California’s climate change priorities and activities for the next several years. It also framed activities and issues facing the state as it develops an integrated framework for achieving both air quality and climate goals in California beyond 2020.

In the original AB 32 Scoping Plan, the ARB approved a total statewide GHG 1990 emissions level and 2020 emissions limit of 427 million metric tons (MT) of CO2e. As part of the update, the ARB revised the 2020 Statewide limit to 431 million MT of CO2e, an approximately 1 percent increase from the original estimate. The 2020 business-as-usual forecast in the update is 509 million MT of CO2e. The state would need to reduce those emissions by 15.3 percent to meet the 431 million MT of CO2e 2020 limit.

In November 2017, the ARB published the 2017 AB 32 Scoping Plan (ARB, 2017), which built upon the former AB 32 Scoping Plan and Update by outlining priorities and recommendations for the state to achieve its 2030 GHG target of a 40 percent reduction in GHGs by 2030, compared to 1990 levels.

The major elements of the framework proposed were enhancement of the Renewables Portfolio Standard (RPS) and the Low Carbon Fuel Standard (LCFS); a Mobile Source Strategy, Sustainable Freight Action Plan, Short-Lived Climate Pollutant Reduction Strategy, Sustainable Communities Strategies, and a Post-2020 Cap-and-Trade Program; a 20 percent reduction in GHG emissions from the refinery sector and an Integrated Natural and Working Lands Action Plan.

On November 16, 2022, the ARB circulated its Final 2022 Scoping Plan for Achieving Carbon Neutrality (ARB, 2022). It identifies a technologically feasible, cost-effective path to achieve carbon  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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neutrality by 2045 or earlier. Through the lens of carbon neutrality, the plan expands the scope to more meaningfully consider how our natural and working lands (NWL) contribute to our long-term climate goal.

Executive Order B-30-15
On April 29, 2015, Governor Edmund G. Brown Jr. issued an executive order to establish a California GHG reduction target of 40 percent below 1990 levels by 2030. This new emission reduction target is a step toward the ultimate goal of reducing emissions by 80 percent below 1990 levels by 2050.

The executive order also specifically addresses the need for climate adaptation and directs state government to:
• Incorporate climate change impacts into the state’s Five-Year Infrastructure Plan. • Update the Safeguarding California Plan – the state climate adaption strategy – to identify how climate change will affect California infrastructure and industry, and what actions the state can take to reduce the risks posed by climate change. • Factor climate change into state agencies' planning and investment decisions. • Implement measures under existing agency and departmental authority to reduce GHG emissions.

California Senate Bill 32
This bill codifies Executive Order B-30-15 by adding § 38566 to the Health and Safety Code; it mandates the ARB to ensure that statewide greenhouse gas emissions are reduced to at least 40 percent below the statewide greenhouse gas emissions limit no later than December 31, 2030.

California Senate Bills 1078, 107, 2, and 350; Renewables Portfolio Standard Established in 2002 under California SB 1078 and accelerated in 2006 under California SB 107, California’s RPS requires retail suppliers of electric services to increase procurement from eligible renewable energy resources by at least one percent of their retail sales annually, until they reach 20 percent by 2010.

On April 2, 2011, Governor Brown signed California SB 2 to increase California’s RPS to 33 percent by 2020. This new standard also requires regulated sellers of electricity to procure 25 percent of their energy supply from certified renewable resources by 2016. In October 2015, Governor Brown signed into legislation SB 350, which requires retail sellers and publicly owned utilities to procure 50 percent of their electricity from eligible renewable energy resources by 2030. Under SB 100, signed by Governor Brown on September 10, 2018, the renewables requirement was increased to 60 percent.

Low Carbon Fuel Standard (LCFS)
California Executive Order S-01-07 (January 18, 2007) requires a 10 percent or greater reduction in the average carbon intensity for transportation fuels in California regulated by the ARB. The ARB identified the LCFS as a Discrete Early Action item under AB 32, and the final resolution (09-31) was  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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issued on April 23, 2009. The latest amendments to the LCFS were effective July 1, 2020 and further aim to decarbonize the transportation sector (ARB, 2025a).

Sustainable Communities and Climate Protection Act (SB 375) California’s Sustainable Communities and Climate Protection Act, also referred to as SB 375, became effective January 1, 2009. The goal of SB 375 is to help achieve AB 32’s GHG emissions reduction goals by aligning the planning processes for regional transportation, housing, and land use. SB 375 requires the ARB to develop regional reduction targets for GHGs and prompts the creation of regional plans to reduce emissions from vehicle use throughout the state. California’s 18 metropolitan planning organizations (MPOs) have been tasked with creating sustainable community strategies (SCS) in an effort to reduce the region’s vehicle miles traveled (VMT) in order to help meet AB 32 targets through integrated transportation, land use, housing and environmental planning. Pursuant to SB 375, the ARB set per-capita GHG emissions reduction targets from passenger vehicles for each of the state’s 18 MPOs. In March 2018, the ARB issued a regional eight percent per capita reduction target for the planning year 2020, and a target of 19 percent for 2035 in the jurisdiction of the Southern California Association of Governments (ARB, 2018).

California Green Building Standards (CALGreen) Code
Although not originally intended to reduce GHGs, California Code of Regulations Title 24 Part 6:

California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24), was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption.

Since then, Title 24 has been amended with recognition that energy-efficient buildings that require less electricity reduce fuel consumption, which in turn decreases GHG emissions. The current 2022 Title 24 standards (effective as of January 1, 2023) make new development projects constructed within California after January 1, 2023 subject to the mandatory planning and design, energy efficiency, water efficiency and conservation, material conservation and resources efficiency, and environmental quality measures of the California Green Building Standards (CALGreen) Code (California Code of Regulations, Title 24, Part 11).

Regional
South Coast Air Quality Management District
The South Coast Air Quality Management District (SCAQMD) is responsible for regional planning to achieve attainment of ambient air quality standards in the South Coast Air Basin, in which the project is located.17 It also enforces federal and state emission regulations through a system of sourcespecific rules and by requiring permits for building and operating facilities that emit criteria pollutants and toxic air contaminants. The SCAQMD does not have rules limiting GHG emissions, nor does it issue permits specifically for emissions of GHG species. However, some of its rules and permit conditions, by limiting fossil fuel combustion, have a side benefit of reducing GHG emissions.

In 2008, the SCAQMD proposed GHG emission thresholds to be used for evaluating significance under CEQA (SCAQMD, 2008). Under the proposal, commercial and/or residential projects that emit less than 3,000 metric tons of CO2e (MTCO2e) per year would be assumed to have a less than significant impact on climate change. Although this threshold has never been formally adopted, it is widely used 17 For more detailed information on the SCAQMD, refer to Section 4.2.  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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in CEQA evaluations.

Southern California Association of Governments
The Southern California Association of Governments (SCAG) is the federally-designated metropolitan planning agency for Ventura, Los Angeles, Orange, Riverside, San Bernardino and Imperial Counties.

It works together with the SCAQMD to prepare the triennial Air Quality Management Plan (AQMP).

It is also responsible for quadrennial updates of the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also known as Connect SoCal, the latest of which guides transportation developments between 2024 and 2050 (SCAG, 2025). Connect SoCal 2024 outlines strategies to reach its goal of reducing GHG emissions from passenger vehicles by 19 percent by 2025.

Local
The City of Redlands has taken several actions to address climate change.

City of Redlands Climate Action Plan
The City of Redlands approved its Climate Action Plan (CAP) in 2017, alongside the city’s 2035 General Plan (Dyett & Bhatia, 2017). The CAP, originally adopted on December 5, 2017, and updated on July 1, 2025 (CAP Update), supports the City of Redlands commitment to lowering communitywide GHG emissions and outlines how the City will meet California's GHG reduction targets. The 2017 CAP and the 2025 update will also facilitate a more efficient environmental review process for future development projects in accordance with CEQA.

City of Redlands General Plan 2035
The City of Redlands General Plan 2035, approved in May 2018, includes policies that will guide future development through the Plan’s 2035 planning horizon. Within the document’s “Sustainable Community” theme are policies for energy and water conservation, and GHG reduction Greenhouse Gas Emission Sources
The CAP reflects guidelines set forth in the 2017 AB 32 Scoping Plan. These guidelines recommend that local government implement achieving GHG reduction targets of 6 MTCO2e per capita per year by 2030 and 2 MTCO2e per capita per year in 2050, as established by Executive Order S-3-15 and Senate Bill 32. The CAP has established a goal of 6 MTCO2e per capita per year by 2030 and 5 MTCO2e per capita per year by 2035. To achieve these targets, communitywide GHG emissions must be reduced to approximately 359,358 MTCO2e per year by 2035 (Dyett & Bhatia, 2017, p. 2035). As part of a CAP update, a GHG inventory and progress report was carried out for the year 2022 for the City of Redlands. According to an adjusted business-as-usual forecast,18 communitywide GHG emissions are anticipated to decrease from 2015 levels by 3 percent by 2030 and by 20 percent in 2050. The City is not anticipated to meet its 2030 goal, but it is forecasted to meet the goal for 2035. A summary of Redlands’ communitywide 2015, 2022, 2030, and 2050 actual and forecasted emissions is provided in Table 4.7‐1.
18 An adjusted business-as-usual forecast takes into account State GHG reduction actions in addition to GHG reduction measures in the Redlands CAP. These State actions include Renewable Portfolio Standards (RPS), Renewable Gas Standards (RGS), and Title 24 Building Energy Efficiency Standards.  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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Table 4.7-1

REDLANDS BASELINE AND PROJECTED GHG EMISSIONS WITH STATE ACTION Emissions Sector 2015
MTCO2e
2022
MTCO2e
2030
MTCO2e
2050
MTCO2e
Built Environment 190,861 163,753 137,957 65,468
Transportation 274,086 369,041 326,467 399,791
Solid Waste 24,933 7,412 7,718 8,435
Potable Water 3,189 2,975 2,175 0
Wastewater 6,088 13,129 11,159 10,176
Total 499,157 556,310 485,476 399,791
Percent Change from 2015 - 11 (3) (20)
Per capita emissions 7.1 7.7 6.5 4.9
Notes: CO2e = carbon dioxide equivalent; MT= metric tons; Source: Dyett & Bhatia, 2024, p.29 Emission Reduction Strategies
City of Redlands General Plan
The General Plan lists principles and actions that make up policies aimed at achieving the city’s GHG reduction targets established in the CAP (City of Redlands, 2018). The policies are summarized below:

Greenhouse Gas (GHG) Reduction:
8-P.9: Enhance sustainability through GHG reducing initiative. 8-P.10: Reduce energy and fossil fuel consumption in municipal operations. 8-A.45: Create a Climate Action Plan that complies with State-mandated GHG emissions. 8-A.46: Monitor the city’s compliance with state GHG targets per the CAP and adjust policies, as necessary.
8-A.47: Incentivize climate-friendly purchasing.
8-A.48: Explore programs such as Community Choice Aggregation (CCA) that increase the renewable energy supply and maintain the reliability and sustainability of the electrical grid.

4.7.3 Existing Conditions
Greenhouse Gases
The principal GHGs are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride, perfluorocarbons, hydrofluorocarbons, and water vapor. CO2 is the reference gas for climate change because it is the predominant GHG emitted. To account for the varying warming potential of different GHGs, GHG emissions are often quantified and reported as CO2 equivalent (CO2e). CO2e emissions are calculated as the sum of the products of each compound’s emissions and its global warming potential (GWP). The GWP is based upon the heat-absorbing ability of a GHG compound relative to that of CO2, as well as the persistence in the atmosphere relative to that of CO2. The higher its GWP, the more a given species heats the atmosphere, over a given time.  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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The 100-year GWP values for CO2, CH4 and N2O were assumed in this evaluation to be 1, 25 and 298, respectively (Forster et al., 2017).

4.7.4 Emission Calculation Methodology
CalEEMod, Version 2022.1.1.29, the same software that was used for the criteria air pollutant analysis, was used to estimate carbon dioxide, methane, and nitrous oxide emissions for project construction and operation. Modeling inputs and results are provided in Appendix D. The model calculates the CO2e emissions from the emissions and global warming potentials of the three aforementioned compounds. In accordance with SCAQMD guidance, total construction emissions were “amortized” over 30 years and added to the operational emissions. Further information about the analytical approach is presented in Section 4.7.5 and Appendix D.

Project Design Features
The Project would comply with the 2022 California Green Building Standards Code (CalGreen) (Part 11 of Title 24, California Code of Regulations). The following are proposed energy conservation measures that are beyond the minimum requirements of CalGreen. Please note that only GHG-PDF-1 and GHG-PDF-9 were taken into account in the emission calculations.

Energy Conservation and Efficiency
GHG-PDF-1: Project design will provide energy efficiency exceeding Title 24, Part 6, California Energy Code baseline standard requirements by 10 percent, based on the 2022 Building Energy Efficiency Standards requirements
GHG-PDF-2: Use of natural heating and cooling features.

GHG-PDF-3: Use of improved insulation.

GHG-PDF-4: Installation of PV panels.

GHG-PDF-5: Use of efficient and durable roofing materials and exterior finishes.

GHG-PDF-6: Use of efficient interior finishes.

Water Conservation
GHG-PDF-7: Water-efficient plumbing fixtures (17 to 31 percent of GHG emissions associated with non-residential indoor water use).

Solid Waste Conservation
GHG-PDF-8: Use of recycled foundation materials.

Other
GHG-PDF-9: No combustion of natural gas (100 percent reduction in emissions from natural gas use).
 SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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4.7.5 Environmental Impact Analysis

4.7.5.1 Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, the project would have a significant impact related to GHGs if it would:

A. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
B. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

According to the CEQA Guidelines, a lead agency shall have the discretion to determine, for a specific project, whether to quantify GHG emissions and/or to rely on a qualitative analysis or performancebased standards.19 A lead agency should consider the following factors, among others, when determining the significance of GHG emissions on the environment:20 • The extent to which the project would increase or decrease GHG emission with reference to existing environmental conditions.
• Whether the project’s GHG emissions would exceed a numeric threshold of significance that the lead agency determines to apply to the project.
• The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional or local plan for reducing or mitigating GHG emissions.

Neither the State of California, the City of Redlands, nor the SCAQMD has a formally adopted numeric, “bright line” threshold that distinguishes between significant and less than significant GHG emission levels for development projects such as the proposed project. As discussed in Section 4.7.2, the SCAQMD has proposed a threshold of 3,000 metric tons per year but has not adopted it as a rule or guideline. Nevertheless, this threshold is in common use for proposed projects in the South Coast Air Basin and was used in the present analysis.

In addition, the project’s significance was evaluated by considering the extent to which it complies with regulations or requirements adopted to implement a statewide, regional or local plan for reducing or mitigating GHG emissions. The project was compared with the City of Redlands Climate Action Plan and 2035 General Plan for its consistency therewith.

4.7.5.2 Analysis of Project Impacts
Threshold A: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? 19 CEQA Guidelines § 15064.4(a).
20 Op. cit., § 15064.4(b).
 SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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Significant and Unavoidable Impact
Direct greenhouse gas emissions (GHG) emissions include emissions from construction activities, stationary sources, and mobile (vehicle) sources. Typically, mobile sources make up the majority of direct emissions. Indirect GHG emissions are generated by incremental electricity consumption and waste generation. Project implementation would increase GHG emissions from mobile sources, electricity usage, natural gas consumption, solid waste generation, and water use.

The estimates for this analysis include the following sources of annual direct and indirect GHG emissions: (1) area sources (e.g., landscaping-related fuel combustion sources); (2) energy use associated with office and restaurant uses; (3) water and wastewater; (4) solid waste; (5) mobile sources (e.g., passenger vehicles and trucks); and (6) construction activity. The ongoing operational emissions consist of the first five categories, while emissions associated with construction are generated only during construction.

Construction emissions are from offroad equipment and onroad vehicles such as worker and vendor commuting and trucks for soil and material hauling. CalEEMod defaults were used for construction activity and equipment usage, except for phase lengths that were supplied by the project proponent.

To assess the temporary construction effect on the project’s overall lifetime GHG emissions, the SCAQMD developed an Interim Guidance (SCAQMD, 2008) recommending that construction emissions should be amortized over the life of the project, defined in the Guidance as 30 years, which is then added to the operational emissions and compared to the applicable GHG significance threshold.

GHG emissions would also continue to occur every year after buildout. Combustion of any type of fossil fuel emits CO2 and other GHGs directly into the atmosphere; these emissions are considered direct emissions when associated with buildings. GHGs are also emitted during the generation of electricity from fossil fuels; these emissions are indirect emissions as they occur elsewhere but are attributed to power usage onsite. Indirect GHG emissions also result from the production of electricity used to convey, treat, and distribute water and wastewater. In addition, CalEEMod calculates the indirect GHG emissions associated with waste that is disposed of at a landfill using waste disposal rates by land use and overall composition.

An initial emissions calculation without mitigation measures was performed and the operational phase is shown in Table 4.7-3. Construction emissions were the same with and without the selected measures. An emissions calculation with the following measures selected was also performed.

Mitigated operational emissions are shown in Table 4.7-4. Implementation of these measures removed operational area sources and added slight energy usage in all phases. The net difference is a 0.14 percent decrease. Note that only quantitative measures have an impact on the reported results since qualitative measures are not easily quantifiable:
• One quantitative measure was considered for area sources, to replace gas powered landscape equipment with zero-emission landscape equipment (LL-1). • Two qualitative CalEEMod transportation mitigation measures were considered: providing an employer-sponsored vanpool (T-11) and providing electric vehicle charging infrastructure (T-14).

The construction and operational emissions presented in Table 4.7-2 and Table 4.7-4 are the results of the following model conditions. CalEEMod defaults were used throughout, with the following major exceptions:
 SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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• Because the project will not require natural gas service, natural gas-based GHG emissions were subtracted from the CalEEMod results.
• Because the project will be constructing a fuel cell micro-grid central utility plant (CUP) in Phase 2 that will enable the project to operate independently of the electric grid, onsite electricity usage was removed from CalEEMod following Phase 1 operations. Any energy usage from Phases 2 through 4 is not from generation of building electricity. • Daily trip rates were modified based on the project’s traffic study (Fehr & Peers, 2025). • The three measures listed above, LL-1, T-11 and T-14.

Table 4.7-2 shows the predicted GHG emissions during each construction year. Phase 2 would result in the most construction GHG construction emissions of any project phase: 3,492.8 metric tons.

Consistent with SCAQMD recommendations (SCAQMD, 2008, p. 3-10) and to ensure that construction emissions are assessed quantitatively, construction GHG emissions have been amortized over a 30-year period. The maximum value of amortized constructions emissions for the proposed project’s construction emissions is 179 MTCO2e. This amortized value is included in the analysis of operational emissions for the proposed project. Modeling results are in Appendix D. Carbon dioxide equivalent emissions from annual operation of the project are shown in Table 4.7-4.

Table 4.7-2

PROJECT CONSTRUCTION GHG EMISSIONS
Construction Year Annual CO2e Emissions (metric tons)
CO2 CH4 N2O CO2e
Phase 1
2027 77.6 0.00 0.00 78.0
2028 451.5 0.02 0.02 457.8
2029 119.2 0.00 0.00 120.3
Phase 1 Totals 648.3 0.02 0.02 656.1
Phase 2
2035 108.5 0.00 0.00 108.9
2036 750.4 0.03 0.03 760.9
2037 1144.8 0.03 0.07 1165.6
2038 1129.1 0.03 0.07 1149.9
2039 304.1 0.01 0.01 307.5
Phase 2 Totals 3,436.9 0.1 0.18 3,492.8
Phase 3
2043 55.0 0.00 0.00 55.2
2044 316.2 0.01 0.01 318.3
2045 76.5 0.00 0.00 76.9
Phase 3 Totals 447.7 0.01 0.01 450.4
Phase 4
2047 55.2 0.00 0.00 55.4
2048 337.8 0.01 0.01 341.0
2049 347.2 0.01 0.01 350.7
2050 28.2 0.00 0.00 28.3
Phase 4 Totals 768.4 0.02 0.02 775.4
Maximum 30-Year Amortized Emissions 179
 SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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Table 4.7-3

PROJECT OPERATIONAL GHG EMISSIONS PRIOR TO MITIGATION
Emissions Source
Annual Increment in CO2e Emissions(metric tons)
Phase 1 Phase 2 Phase 3 Phase 4 Source
Totals
Mobile (Motor Vehicles) 3,461 4,020 2,288 1,962 1,731
Area Sources 3.36 19.34 1.69 3.66 28
Energy 1,007 - - - 1,007
Water Demand 70.80 88.73 43.59 40.82 244
Solid Waste Generation 556.3 204.3 279.8 98.4 1,139
Maximum Amortized Construction 179
Total Project Operational GHG Emissions 14,327
Source: CAPCOA, 2022.

Table 4.7-4

PROJECT OPERATIONAL GHG EMISSIONS AFTER MITIGATION
Emissions Source
Annual Increment in CO2e Emissions (metric tons)
Phase 1 Phase 2 Phase 3 Phase 4 Source
Totals
Mobile (Motor Vehicles) 3,461 4,020 2,288 1,962 11,731
Energy 1,008 4.42 0.39 0.84 1,014
Water Demand 70.8 88.7 43.6 40.8 244
Solid Waste Generation 556 204 280 98.4 1,138
Maximum Amortized Construction 179
Total Project Operational GHG Emissions 14,306
Source: CAPCOA, 2022.

Mitigated GHG emissions from the project’s operational phase are estimated to be 14,306 metric tons per year. This will exceed the SCAQMD significance threshold of 3,000 MTCO2e per year. Since most of these emissions will come from mobile sources, the traffic study provides mitigation measures targeted at project employees and commuter vehicle miles travelled (VMT) which can be implemented to reduce GHG emissions in addition to the measures already considered. These mitigation measures are discussed in Section 4.2.7 and Section 4.7.7.

Therefore, for Threshold A, the project’s impacts would be significant and unavoidable even with mitigation measures.

Threshold B: Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Less Than Significant Impact with Mitigation Incorporated The City of Redlands General Plan 2035 was concurrently prepared with the 2017 Climate Action Plan (CAP). An updated CAP, Climate Action Plan 2050, was recently adopted on July 1, 2025. The goal for the updated CAP is to reduce city-wide GHG emissions to 6.0 MTCO2e per capita per year and sets forth strategies for working toward that goal (Dyett & Bhatia, 2017). The City of Redlands 2035 General Plan provides principles and actions that make up policies aimed at achieving the city’s GHG reduction targets established in the CAP (City of Redlands, 2018). The CAP projects that citywide business-as-usual GHG emissions would be 6.4 MTCO2e per capita per year in 2030. Implementation of quantifiable GHG reduction measures would allow the City to achieve its GHG reduction targets for both 2030 and 2050.
 SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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The proposed project would be consistent with the transportation goal of the CAP by incorporating measures such as implementing EV charging stations and requiring electric landscaping equipment when feasible. The proposed project would be consistent with the CAP’s energy efficiency goals by complying with the latest California Building Code (Title 24), including the latest CALGreen Code standards, and incorporating energy efficient design features, such as the construction of the CUP.

As described above, the CAP projects that GHG emissions in 2030 will reach 6.4 MTCO2e per capita per year without GHG reduction measures. Implementation of feasible GHG reduction measures have the potential to decrease emissions to 6.0 MTCO2e per capita per year and achieve the reduction target. Since the project’s operational GHG emissions exceed the SCAQMD significance threshold, it must incorporate GHG reduction mitigation measures in attempt to avoid conflicting with the city’s CAP and General Plan. These mitigation measures are listed below in Section 4.7.7. If the project implements all GHG reducing mitigation measures listed below and in the General Plan, then it will not conflict with the CAP or General Plan. The project will therefore have a less than significant impact with mitigation measures.

4.7.6 Cumulative Impacts
It is widely recognized that no single project could generate enough GHG emissions to noticeably change the global climate. However, the combination of GHG emissions from past, present, and future projects could contribute substantially to global climate change. Thus, project specific GHG emissions should be evaluated in terms of whether they would result in a cumulatively significant impact on global climate change. Climate change impacts may include an increase in extreme heat days, higher concentrations of air pollutants, sea level rise, impacts on water supply and water quality, public health impacts, impacts on ecosystems, impacts on agriculture, and other environmental impacts.

As shown in Section 4.7.5, the project must incorporate GHG reduction measures to be consistent with state and local plans and programs that aim to reduce state and regional GHG emissions, including the City of Redland’s Climate Action Plan and 2035 General Plan. The project’s incremental contribution to GHG emissions and their effects on climate change is estimated to be cumulatively considerable. For these reasons, the project’s cumulative contribution to global climate change would be significant and unavoidable.

4.7.7 Mitigation Measures
Impacts associated with significance threshold A would be significant and unavoidable even with mitigation measures. Impacts associated with significance threshold B would be less than significant with mitigation. Regardless of the significant and unavoidable determination for threshold A, the following mitigation measures would be required to minimize impacts related to greenhouse gas emissions.

As discussed in Section 4.7.5, the project must incorporate mitigation measures during the construction and operational phases. CAPCOA has developed a method of quantifying GHG reducing measures that may be incorporated into potentially significant projects. These quantifiable construction mitigation measures and range of potential GHG reductions in parentheses are listed below (CAPCOA, 2010, P. 410-488):

MM GHG-1 Using alternative fuels for construction equipment (0 to 22 percent).  SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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MM GHG-2 Using electric or hybrid construction equipment (2.5 to 80 percent of GHG emissions from equipment that is electric or hybrid if used 100 percent of the time).

MM GHG-3 Limiting construction equipment idling beyond regulation requirements, which is typically 5 minutes as regulated by the ARB’s Heavy-Duty Vehicle Idling Emission Reduction Program (percent reduced is equal to (1 − 𝑡𝑡𝑚𝑚 𝑡𝑡𝑏𝑏
)100, where 𝑡𝑡𝑚𝑚 is the
mitigated idling period and 𝑡𝑡𝑏𝑏 is the baseline idling period) (CAPCOA, 2010, p. 429).

MM GHG-4 Instituting a heavy-duty offroad vehicle plan (range of effectiveness is not applicable because it only ensures compliances with other mitigation measures). At a minimum, the heavy-duty offroad vehicle plan shall include the following:

1. Fleet reporting and labeling: diesel-fueled vehicles operating in California, with engines 25 horsepower or greater, must be reported to the ARB through the online DOORS system and labeled appropriately.

2. Emission reduction strategies: how you will meet emission reduction requirements by:
a. Retiring/Replacing Vehicles: Phase out older, dirtier engines by replacing them with new, cleaner ones or equipment that meets the latest emission standards.
b. Engine repowering: plan/schedule to replace older off-road diesel engines with newer, cleaner ones.
c. Verified Diesel Emission Control Strategies (VDECS): Install verified diesel emission control strategies (e.g., exhaust retrofits) on existing engines.

3. Fuel acquisition: fleets must begin (2024) using renewable diesel (R99 or R100).

4. Idling restrictions: limit idling to five minutes and apply a written idling policy.

5. Fleet average goals: fleet average emission level standards/balancing emissions from vehicles.

MM GHG-5 Implementing a construction vehicle inventory tracking system (range of effectiveness does not reduce GHG emissions in and of itself; it only ensures compliance with other mitigation measures).

During the project’s operational phase, the majority of GHG emissions will result from mobile sources such as employee and visitor trips. The traffic study provides the most effective GHG reduction measures that can be implemented to reduce VMT. MM TRANS-4, MM AQ-1 and MM AQ-2 below were taken into account in emissions calculations and must be considered by the project. The Kaiser Permanente Medical Facility may incorporate these measures by reference in any sustainability plan or corporate social responsibility policy regarding energy efficiency or carbon footprint reduction. These measures and their estimated potential VMT reductions are detailed in Appendix D13 and are summarized below.
 SECTION 4.7 – GREENHOUSE GAS EMISSIONS 
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MM TRANS-1 Implement Commute Trip Reduction Marketing (4 percent of Home-Based Work (HBW) VMT).

MM TRANS-2 Provide Employee Rideshare Program (4 percent of HBW VMT).

MM TRANS-3 Provide End-of-Trip Bicycle Facilities (0.3 percent of HBW VMT).

MM TRANS-4 Provide Employer-Sponsored Vanpool, (1.6 percent of HBW VMT) (listed as T-11 in CalEEMod).

MM AQ-1 Replace Gas Powered Landscape Equipment with Zero-Emission Landscape Equipment (listed as LL-1 in CalEEMod).

MM AQ-2 Provide Electric Vehicle Charging Infrastructure (listed as T-14 in CalEEMod).

4.7.8 Level of Significance After Mitigation
As shown above, significant impacts related to GHG emissions during construction and operation of the proposed project are anticipated to occur. The construction mitigation measures would not be effective in reducing annual project emissions because their amortized value is a small fraction of the total.

Compliance with state mandates, other applicable regulatory requirements and mitigation measures mentioned in Section 4.7.7 would reduce annual GHG emissions, but not enough to meet the 3,000 MTCO2e per year significance threshold. In conclusion, GHG emissions impacts from the project will be significant and unavoidable. Pursuant to Section 15093 of the State CEQA Guidelines, a Statement of Overriding Consideration will need to be adopted prior to approval of the proposed project.  SECTION 4.8 – HAZARDS AND HAZARDOUS MATERIALS 
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4.8 Hazards and Hazardous Materials

4.8.1 Introduction
The following discussion focuses on project impacts respecting hazardous materials. The initial study for the proposed project, included as Appendix A to this DEIR, concluded that impacts related to Threshold C21: hazards within one quarter mile of a school, Threshold E22: within an airport land use plan, Threshold F23: impair an emergency response plan, or Threshold G24: risk of wildfires would have no impact or be less than significant and not further discussed in the report.

4.8.2 Regulatory Framework
Federal
The Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) establishes the programs and processes for the federal government to provide disaster and emergency assistance to states, local governments, tribal nations, individuals, and qualified private nonprofit organizations.

The provisions of the Stafford Act cover all hazards including natural disasters and terrorist events.

Section 203 of the Stafford Act, 42 USC, required all state, tribal nations, and local governments (including special districts) to develop comprehensive mitigation plans as a condition of eligibility for future post-disaster mitigation grants (LACCEO, 2014, p. 1).

Medical Wastes Regulation
Federal agencies governing the storage, transport, and disposal of medical wastes include:
• Occupational Safety and Health Administration
• Centers for Disease Control and Prevention
Regulations for packaging of medical wastes for transportation are set forth in Code of Federal Regulations Title 49 §§ 173.197 et seq. (NARA, 2025).

Environmental Protection Agency
The Federal Toxic Substances Control Act (1976) and the Resource Conservation and Recovery Act of 1976 (RCRA) established a program administered by the EPA for the regulation of the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA was amended in 1984 by the Hazardous and Solid Waste Act (HSWA), which affirmed and extended the “cradle to grave” system of regulating hazardous wastes. The use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by the HSWA. 21 Threshold C had no impact because the project site was not within one quarter mile of a school. 22 Threshold D has no impact because it is not located within a hazard zone of the San Bernardino International Airport (SBIA). 23 Threshold F has less than significant impacts because construction and operation of the project would be developed accordingly to development regulations to ensure adequate emergency circulation. 24 Threshold G has less than significant impacts because the project site is not within or adjacent to a Very High Fire Hazard Severity Zone (VHFHSZ).
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The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, was enacted by Congress on December 11, 1980. This law provided broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA established requirements concerning closed and abandoned hazardous waste sites; provided for liability of persons responsible for releases of hazardous waste at these sites; and established a trust fund to provide for clean up when no responsible party could be identified. CERCLA also enabled the revision of the National Contingency Plan (NCP). The NCP provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The NCP also established the National Priorities List, which is a list of contaminated sites warranting further investigation by the EPA. CERCLA was amended by the Superfund Amendments and Reauthorization Act (SARA) on October 17, 1986.

United States Department of Transportation (USDOT)
The USDOT Office of Hazardous Materials Safety prescribes strict regulations for the safe transportation of hazardous materials, as described in Title 40, 42, 45, and 49 of the Code of Federal Regulations, and implemented by Title 17, 19, and 27 of the CCR. The USDOT Hazardous Materials Regulations (HMR) apply to persons who undertake transportation of hazardous materials. The Pipeline and Hazardous Materials Safety Administration (PHMSA) issues the HMR. PHMSA has also issued procedural regulations, including provisions on registration and public sector training and planning grants (49 CFR Parts 105, 106, 107, and 110). PHMSA's regulatory functions include issuing rules and regulations governing the safe transportation of hazardous materials and representing USDOT in international organizations and working to assure the compatibility of domestic regulations with the regulations of bodies such as the Federal Motor Carrier Safety Administration (FMCSA). The FMCSA issues regulations concerning highway routing of hazardous materials, the hazardous materials endorsement for a commercial driver's license, highway hazardous material safety permits, and financial responsibility requirements for motor carriers of hazardous materials.

Federal Emergency Management Agency
The primary mission of the Federal Emergency Management Agency is to reduce the loss of life and property and to protect the nation from all hazards, including natural disasters, acts of terrorism, and other man-made disasters, by leading and supporting a risk-based, comprehensive emergency management system of preparedness, protection, response, recovery, and mitigation.

Disaster Mitigation Act
The Disaster Mitigation Act of 2000 requires a state mitigation plan as a condition of disaster assistance, adding incentives for increased coordination and integration of mitigation activities at the state level through the establishment of requirements for two different levels of state plans:
“Standard” and “Enhanced.” States that develop an approved Enhanced State Plan can increase the amount of funding available through the Hazard Mitigation Grant Program. The Disaster Mitigation Act also established a new requirement for local mitigation plans.

Emergency Planning and Community Right-To-Know Act
The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 was included under the Superfund Amendments and Reauthorization Act (SARA) law and is commonly referred to as SARA Title III. EPCRA was passed in response to concerns regarding the environmental and safety  SECTION 4.8 – HAZARDS AND HAZARDOUS MATERIALS 
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hazards proposed by the storage and handling of toxic chemicals. EPCRA establishes requirements for federal, state, and local governments, Indian Tribes, and industry regarding emergency planning and Community Right-to-know reporting on hazardous and toxic chemicals. SARA Title III requires states and local emergency planning groups to develop community emergency response plans for protection from a list of Extremely Hazardous Substances (40 CFR Appendix B). The Community Right-to-Know provisions help increase the public’s knowledge of and access to information on chemicals at individual facilities, their uses, and their release into the environment.

Hazardous Materials Transportation Act
The Hazardous Materials Transportation Act (HMTA) of 1975 was created to provide adequate protection from the risks to life and property related to the transportation of hazardous materials in commerce by improving regulatory enforcement authority of the Secretary of Transportation.

Occupational Safety and Health Administration (OSHA)
With the Occupational Safety and Health Act of 1970, Congress created the Occupational Safety and Health Administration (OSHA) to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.

State
Governor’s Office of Emergency Services (OES)
The Governor’s Office of Emergency Services (OES) is responsible for the coordination of overall state agency response to disasters; and assuring the state's readiness to respond to, recover from all hazards and assisting local governments in their emergency preparedness, response, recovery and mitigation.

The State of California Emergency Plan, issued by the Governor’s Office of Emergency Services (OES) in 2017, describes the methods for conducting emergency operations, the process for rendering mutual aid, the emergency services of governmental agencies, how resources are mobilized, how the public will be informed, and the process to ensure continuity of government during an emergency or disaster.

The State emergency management system is divided into Operational Areas, each one consisting of a county and all the jurisdictions within that county including cities and special districts.

The State Hazard Mitigation Plan, issued by OES in 2018, contains risk assessments and sets forth mitigation strategies for a wide variety of natural and human-caused hazards. Hazard mitigation is any sustained action taken to reduce or eliminate long-term risk to people and property from natural or human-caused hazards and their effects (CalOES, 2018, p. 1.1-5).

OES divides the state into six Fire and Rescue Mutual Aid regions. San Bernardino County is in Region 6, which extends from San Diego and Imperial counties on the south to Mono County on the north (OES, 2023).
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Medical Wastes Regulation
The Medical Waste Management Act (California Health and Safety Code §§ 117600 et seq.) regulates storage, transportation, and treatment of medical wastes. Medical waste generators producing 200 pounds or more of medical waste per month are classified as Large Quantity Generators (LQGs). State regulations governing medical waste are also issued and enforced by the California Division of Occupational Safety and Health (DOSH) and Caltrans.

San Bernardino County
The City of Redlands is the San Bernardino County Operational Area. The existing emergency response plan in San Bernardino County is the San Bernardino County Operational Area Emergency Response Plan (“ERP”) revised in 2018. The ERP identifies County agencies and other agencies that would be involved in emergency responses; threat summaries and assessments; and procedures for responding agencies as well as County agencies that would be involved in coordinating and managing responses. The ERP is focused on emergencies beyond the scope of the daily functions of public safety agencies, such as emergencies requiring multi-agency and/or multi-jurisdictional responses.

Further assessments of potential hazards and County resources available for responding to hazards are contained in the County of San Bernardino Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) updated in 2022. The MJHMP includes a vulnerability analysis for many types of hazards including earthquakes, floods, fires, and manmade hazards including terrorism and civil unrest; goals and objectives for strategies for mitigating hazards; proposed strategies and actions for reducing vulnerability to identified hazards; and lists of facilities and equipment available for responding to disasters.

Medical Wastes Regulation
The San Bernardino County Department of Public Health, Division of Environmental Health Services (EHS) regulates medical waste generators, transporters, transfer stations, and treatment facilities within the County under the authority of the Medical Waste Management Act (California Health and Safety Code §§ 117600 et seq.). Medical waste generators producing 200 pounds or more of medical waste per month are classified as Large Quantity Generators (LQGs), who must obtain a permit from EHS. It is expected that the proposed project would be an LQG by the time the medical office building proposed in Phase 1 (165,000 square feet) was completed and operating. The Medical Waste Management Act sets forth requirements governing containment and storage, transport, and treatment of medical wastes. LQGs, medical waste haulers, and treatment facilities are required to register or obtain permits from EHS (EHS, 2023). Eight medical waste transporters located in San Bernardino County are currently registered with the California Department of Public Health (CDPH, 2023a). The CDPH lists one medical waste transfer station, and one medical waste treatment facility, in San Bernardino County (CDPH, 2023b).

City of Redlands
The City of Redlands adopted its Local Hazard Mitigation Plan (LHMP) in 2021. The LHMP includes assessments of hazards and risks in the city, assesses hazard mitigation capacity in the city, and sets forth mitigation strategies. These strategies include measures such as strengthening critical infrastructure, improving emergency response systems, protecting vulnerable populations, and reducing risks from hazards like flooding, wildfires, and earthquakes (City of Redlands, 2021).  SECTION 4.8 – HAZARDS AND HAZARDOUS MATERIALS 
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California Code of Regulations Title 22
Hazardous substances are regulated by state and federal agencies to protect public health and the environment. Hazardous materials have certain chemical, physical, or infectious properties that threaten life, health, property, or the environment. The California Code of Regulations (CCR) Title 22 Division 4.5, Environmental Health Standards for the Management of Hazardous Waste, provides the following definition: A hazardous material is a substance or combination of substances which, because of its quantity, concentration or physical, chemical, or infectious characteristics, may either (1) cause or significantly contribute to an increase in mortality or an increase in serious, irreversible or incapacitating irreversible illness; or (2) pose a substantial present or potential hazard to human health and safety, or the environment when improperly treated, stored, transported or disposed of.

Hazardous materials include waste that has been abandoned, discarded, or recycled on the property and as a result represents a continuing hazard as the development is proposed. Hazardous materials also include any contaminated soil or groundwater.

4.8.3 Existing Conditions
Hazardous Materials
Three hazardous materials sites were identified within 0.5 mile of the project site and are described below in Table 4.8-1.

Table 4.8-1
HAZARDOUS MATERIALS SITES ON AND WITHIN 0.5 MILE OF THE PROJECT SITE Site Name
Address
Distance and Direction from Permanent TMF Site
Additional information
GeoTracker
California Shell
941 California St
2,250 feet south
Leaking Underground Storage Tank
Gasoline release affected drinking water aquifer
and soil; case closed 2008
Resource Conservation and Recovery Act Information (RCRAInfo) Kaiser Permanente Redlands medical Center
1301 California St
Onsite
Large Quantity Generator of hazardous wastes
(LGQ)
Splash Kingdom Waterpark
1101 California St
980 feet south
Other hazardous waste activities
Sources: SWRCB, 2023; NETROnline.com

4.8.4 Environmental Impact Analysis

4.8.4.1 Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, the project would have a significant impact regarding hazards and hazardous materials if it would:

A. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
 SECTION 4.8 – HAZARDS AND HAZARDOUS MATERIALS 
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B. 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; or
C. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school; or D. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code § 65962.5 and, as a result, would it create a significant hazard to the public or the environment; or
E. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area; or F. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; or
G. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

Thresholds of Significance from CEQA Appendix G were used to evaluate the potential level of initial impact and the potential level of impact after implementation of mitigation measures. The Initial Study, included as Appendix A, substantiates that impacts respecting Significance Thresholds C, E, F, and G would be no impact or less than significant. Under Threshold C, no schools are within 0.25 mile of the project site and no impact would occur. Regarding Threshold E, project development would not cause airport-related hazards, or excessive noise, to people occupying the project site thus no impacts would occur Threshold F results determined compliance with City requirements for traffic management during construction in the public right-of-way would ensure that the project would have a less than significant impact with regards to implementation of an adopted emergency response plan or emergency evacuation plan. Threshold G analysis resulted in less than significant impacts regarding death and injury involving wildland fires because the project site is surrounded by built-out urban uses and project development would not exacerbate wildfire risks, Therefore, this section focuses only on impacts related to hazardous materials (Significance Thresholds A, B and D).

4.8.4.2 Analysis of Project Impacts
Threshold A: Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Less than Significant Impact
Construction
Project construction would involve use of hazardous materials such as fuels, oils and other lubricants, degreasers, paints, pesticides, and fertilizers. Use and disposal of hazardous materials would be in compliance with existing regulations of several agencies including the US Environmental Protection Agency, Department of Toxic Substances Control, US Department of Transportation, and San  SECTION 4.8 – HAZARDS AND HAZARDOUS MATERIALS 
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Bernardino County Environmental Health Services. Impacts arising from routine use of hazardous materials during project construction would be less than significant upon compliance with existing regulations.

Operation
Project operation would generate medical waste. The San Bernardino County Department of Public Health, Division of Environmental Health Services (EHS) regulates medical waste generators, transporters, transfer stations, and treatment facilities within the County under the authority of the Medical Waste Management Act (California Health and Safety Code §§ 117600 et seq.). Medical waste generators producing 200 pounds or more of medical waste per month are classified as Large Quantity Generators (LQGs), who must obtain a permit from EHS. It is expected that the proposed project would be an LQG by the time the medical office building proposed in Phase 1 (165,000 square feet) is completed and operating. The Medical Waste Management Act sets forth requirements governing containment and storage, transport, and treatment of medical wastes. LQGs, medical waste haulers, and treatment facilities are required to register or obtain permits from EHS (EHS, 2023).

Eight medical waste transporters located in San Bernardino County are currently registered with the California Department of Public Health (CDPH, 2023a). The CDPH lists one medical waste transfer station, and one medical waste treatment facility, in San Bernardino County (CDPH, 2023b).

State regulations governing medical waste are also issued and enforced by the California Division of Occupational Safety and Health (DOSH) and Caltrans. Federal regulations governing medical waste are also issued and enforced by Occupational Safety and Health Administration and the Centers for Disease Control and Prevention. Operational impacts arising from routine transport, use, or disposal of hazardous materials would be less than significant after adherence to federal, state, and county regulations.

Threshold B: Would the project create a significant hazard to the public or the environmental through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less than Significant Impact
Construction
Project construction would involve transport, storage, and use of chemical agents, solvents, paints, and other hazardous materials commonly associated with construction activities. Chemical transport, storage, and use would comply with Resource Conservation and Recovery Act (RCRA); Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Occupational Safety and Health Administration (OSHA); California Hazardous Waste Control Law (California Health and Safety Code, Division 20, Chapter 6.5, Hazardous Waste Control); California Division of Safety and Health (DOSH); South Coast Air Quality Management District (SCAQMD); and San Bernardino County Fire Department (SBCFD) requirements.25 The SBCFD provides emergency responses for hazardous materials releases. The construction contractor would maintain equipment and supplies onsite for containing and cleaning up small spills of hazardous materials, and in the event of a release of hazardous materials of quantity and/or toxicity that onsite workers could not 25 San Bernardino County Fire Department (SBCFD) is the Certified Unified Program Agency (CUPA) for San Bernardino County; the Certified Unified Program coordinates and makes consistent enforcement of several state and federal regulations governing hazardous materials.
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safely contain and clean up, would notify the SBCFD immediately. Therefore, compliance with applicable laws and regulations during project construction would reduce the potential for accidental releases of hazardous materials, and construction hazards impacts would be less than significant.

Operation
Project operation would generate hazardous materials such as medical wastes. Medical waste would be stored, transported, treated, and disposed of in accordance with regulations enforced by the Occupational Safety and Health Administration; the Centers for Disease Control and Prevention; the San Bernardino County Division of Environmental Health Services (Medical Waste Management Act, California Health and Safety Code Sections 117600 et seq.); the California Division of Occupational Safety and Health (DOSH) and Caltrans. See Regulatory Framework, Section 4.8.2 above, for further discussion of regulatory requirements pertaining to medical wastes.

Project operation would also involve use of cleansers, disinfectants, paints, fertilizers, herbicides, and pesticides for cleaning and maintenance purposes. Hazardous materials used for such purposes would be stored, used, transported, and disposed of in compliance with the regulations identified in the discussion of construction impacts above. As with project construction, the managers and operators of the proposed hospital and medical office building would train staff on safe containment and cleanup of small spills of hazardous materials and would contact the SBCFD immediately in the event of a release of hazardous materials that onsite staff were unable to safely contain and clean up.

Impacts would be less than significant.

Threshold D: Would the project 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 it create a significant hazard to the public or the environment? Less than Significant Impact
Government Code § 65962.5 requires the Department of Toxic Substances Control (DTSC) to compile and update, at least annually, lists of the following:
• Hazardous waste and substances sites from the DTSC EnviroStor database. • Leaking Underground Storage Tank (LUST) sites by county and fiscal year in the State Water Resources Control Board (SWRCB) GeoTracker database.
• Solid waste disposal sites identified by SWRCB with waste constituents above hazardous waste levels outside waste management units.
• SWRCB Cease and Desist Orders (CDOs), and Cleanup and Abatement Orders (CAOs). • Hazardous waste facilities subject to corrective action pursuant to § 25187.5 of the Health and Safety Code, identified by DTSC.

These lists are collectively referred to as the “Cortese List.” A radius search was conducted for the project site by National Environmental Title Research, Inc. (NETR) on December 20, 2023.
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The medical office building onsite is listed as a large-quantity generator of hazardous waste on the Resource Conservation and Recovery Act Information (RCRAInfo) database. California Shell, at 941 California Street about 2,250 feet south of the project site, is listed as a Leaking Underground Storage Tank site; the case was closed in 2008. The former Splash Kingdom Waterpark site at 1101 California Street, 980 feet south of the project site, is listed for other hazardous waste activities on the RCRAInfo database, which include the generation and storage of hazardous wastes requiring ongoing monitoring and compliance with DTSC and U.S. EPA requirements. No open cases requiring active remediation were identified for these sites.

None of the listed sites is an environmental concern for the project site, as only one of the sites is listed for a known release of hazardous materials, and that case (California Shell) was closed in 2008.

All three sites are known to regulatory agencies and being managed by the appropriate regulatory agency. Impacts would, therefore, be less than significant and no mitigation is required.

As each phase is developed, construction impacts would remain the same as discussed under Threshold B. Compliance with applicable laws and regulations during project construction would reduce the potential for accidental releases of hazardous materials, and construction hazards impacts to less than significant. During operation of each new phase, the facility and staff would still be required to comply with regulations discussed under Threshold B. Impacts from each phase would remain less than significant and no mitigation is required.

4.8.5 Cumulative Impacts
Project construction would involve transport, storage, and use of chemical agents, solvents, paints, and other hazardous materials commonly associated with construction activities. Impacts relating to use, containment, transport and disposal of hazardous materials from routine use of hazardous materials during project construction would be less than significant after compliance with existing regulations.

Project operation would generate medical waste. Operational impacts respecting hazardous materials would be less than significant after adherence to federal, state, and county regulations. The managers and operators of the proposed hospital and medical office building would train staff on safe containment and cleanup of small spills of hazardous materials and would contact the SBCFD immediately in the event of a release of hazardous materials that onsite staff were unable to safely contain and clean up. Impacts would be less than significant.

Construction and operation of related projects would also be required to comply with laws and regulations governing the use, transport, storage, and disposal of hazardous materials; therefore, such use, transport, storage, and disposal would not cause substantial hazards to the public or the environment. Cumulative impacts respecting hazardous materials would be less than significant.

4.8.6 Mitigation Measures
Impacts would be less than significant, and no mitigation measures are required.

4.8.7 Level of Significance after Mitigation
Impacts would be less than significant without mitigation.  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
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4.9 Hydrology and Water Quality

4.9.1 Introduction
Impacts to water quality, surface hydrology and drainage, and flooding hazards were determined to be less than significant in the Initial Study included as Appendix A to this PEIR. This determination was based on the fact that the project would comply with federal, state, and local water quality regulations, including the Clean Water Act, the Porter-Cologne Water Quality Control Act, and the City’s MS4 Permit requirements. The project also incorporates a site-specific Water Quality Management Plan with low-impact development (LID) best management practices to capture, treat, and infiltrate stormwater onsite, thereby preventing significant erosion, siltation, or polluted runoff.

In addition, the project site is not located within a flood hazard zone, nor would development alter local drainage patterns in a manner that would increase flooding risks. Because these issues were determined to be less than significant, this section focuses on the potential impacts to groundwater supply and groundwater recharge.

4.9.2 Regulatory Framework
Federal
Clean Water Act
The Clean Water Act (CWA) was first introduced in 1948 as the Water Pollution Control Act. The CWA authorizes federal, state, and local entities to cooperatively create comprehensive programs for eliminating or reducing the pollution of state waters and tributaries. The primary goals of the CWA are to restore and maintain the chemical, physical, and biological integrity of the nation's waters and to make all surface waters fishable and swimmable. The CWA forms the basic national framework for the management of water quality and the control of pollutant discharges. The CWA sets forth several objectives to achieve the abovementioned goals. These objectives include: regulating pollutant and toxic pollutant discharges; providing for water quality that protects and fosters the propagation of fish, shellfish and wildlife; developing waste treatment management plans; and developing and implementing programs for the control of non-point sources of pollution. The State Water Resources Control Board (SWRCB) and the nine Regional Water Quality Control Boards (RWQCBs) are the primary state agencies responsible for implementing the CWA and regulating the activities and factors that affect or have the potential to affect water quality in the state.

The CWA provides the legal framework for several water quality regulations including the National Pollutant Discharge Elimination System (NPDES), effluent limitations, water quality standards, pretreatment standards, anti-degradation policy, non-point source discharge programs, and wetlands protection. An NPDES permit is required for all discharges of pollutants to waters of the United States from any point source.

In addition to regulating non-stormwater discharges, the CWA sets forth water quality standards based on a water body's designated beneficial uses (e.g., wildlife habitat, domestic water supply, recreation, etc.), along with water quality criteria necessary to support those uses. Water quality criteria are either prescribed concentrations or levels of constituents such as lead, suspended sediment, and fecal coliform bacteria, or narrative statements which represent the quality of water that support a particular use.
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Pursuant to Clean Water Act §§ 303(d) and 305(b) (33 U.S.C. §§ 1313[d], 1315[b]), each state is required to report to the USEPA on the overall quality of the waters within its boundaries. When designated beneficial uses of a particular receiving water body are being compromised by water quality, § 303(d) of the CWA requires identifying and listing that water body as impaired. Once a water body has been deemed impaired, a Total Maximum Daily Load (TMDL) must be established for the pollutant(s) or flows causing the impairment. A Total Maximum Daily Load is an estimate of the total load of pollutants from point, non-point, and natural sources that a water body may receive without exceeding applicable water quality standards. Those facilities and activities that are discharging into the water body, collectively, must not exceed the Total Maximum Daily Load. The USEPA developed guidance to states recommending that the 305(b) report and the 303(d) list be integrated into a single report. For California, this combined report is called the California Integrated Report, and it satisfies both the CWA § 305(b) and § 303(d) requirements. In California, the SWRCB oversees § 305(b) and § 303(d); Upon approval of the 303(d) list portion of the California Integrated Report by the SWRCB, the California Integrated Report is submitted to USEPA, which may make changes to the 303(d) list before it approves the final 303(d) list for California.

In addition to trash and debris, common pollutants of concern that have the potential to affect water quality generally fall into one of the following seven categories: sediments; nutrients; bacteria and viruses; oil and grease; metals; organic compounds; and pesticides.

Section 401 Clean Water Act
Although the Clean Water Act is a federal law, the Environmental Protection Agency (EPA) has authorized some states, including California, to have the primary authority and responsibility for setting surface- and groundwater water quality standards.

Section 401 is implemented through the Water Quality Certification (WQC) process. In the State of California, the State Water Quality Resources Board (SWRCB) has given the responsibility for issuing § 401 WQCs to its nine Regional Water Quality Control Boards (RWQCBs), unless a discharge of dredged or fill material is proposed within more than one region. In the event that a project proposes discharges of dredged or fill material in more than one region, responsibility for issuance of a § 401 WQC will lie either with the SWRCB, or, upon agreement of the RWQCBs for the affected regions, with the RWQCB chosen in the discretion of the RWQCBs (California Water Code, § 13160; California Code of Regulations., Title 23, § 3838). Certification must be based on a finding that the proposed discharge will comply with water quality standards, which include numeric and narrative water quality objectives applicable to identified surface waters in the Water Quality Control Plan for the region (Basin Plan) in which a discharge of fill is proposed.

If a project does not contain federal waters (i.e., waters of the U.S.), the project must still comply with water quality-related permits required by the SRWCB and the RWQCB. The project is within the jurisdiction of the Santa Ana RWQCB (Region 8).

State
Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Control Act (Porter-Cologne) (California Water Code, Division 7, §§ 13000–14958) defines water quality objectives as the allowable limits or levels of water quality constituents or characteristics which are established for the reasonable protection of beneficial uses of water or the prevention of nuisances within a specific area. Thus, water quality objectives are intended  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
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to protect the public health and welfare, and to maintain or enhance water quality in relation to the existing and/or potential beneficial uses of the water. Water quality objectives apply to both waters of the U.S. and waters of the State. In the State of California, the Porter-Cologne Water Quality Control Act is administered in concurrence with the § 401 CWA Water Quality Certification. As with § 401 CWA, the Santa Ana RWQCB would provide project review pursuant to Porter-Cologne.

Construction Stormwater Program
Stormwater is defined by USEPA as the runoff generated when precipitation from rain and snowmelt events flows over land or impervious surfaces without percolating into the ground. Stormwater is often considered a nuisance because it mobilizes pollutants such as motor oil and trash. In most cases, stormwater flows directly to water bodies through sewer systems, contributing a major source of pollution to rivers, lakes, and the ocean. Stormwater discharges in California are regulated by the SWRCB and RWQCBs through National Pollutant Discharge Elimination System (NPDES) permits.

However, storm water may also act as a resource and recharge to groundwater when properly managed (SWRCB 2025a). The SWRCB regulates stormwater discharges from construction sites because of its potential to mobilize pollutants and discharge into waterbodies or watersheds (SWRCB 2025b).

Construction activity subject to this permit includes clearing, grading and disturbances to the ground such as stockpiling or excavation but does not include regular maintenance activities performed to restore the original line, grade, or capacity of the facility. Dischargers whose projects disturb one or more acres of soil or whose projects disturb less than one acre but are part of a larger common plan of development that in total disturbs one or more acres, are required to obtain coverage under the NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit; NPDES No. CAS000002). The SWRCB and its nine RWQCBs also implement water quality regulations under the California Porter Cologne Water Quality Control Act; therefore, the NPDES was adopted by the SWRCB as Order No. 2022-0057-DWQ on September 8, 2022.

The Construction General Permit requires potential dischargers of pollutants into waters of the U.S. and State file a Notice of Intent (NOI) with the SWRCB through the SWRCBs Stormwater Multiple Application and Report Tracking System (SMARTS); the NOI requires the preparation and implementation of a site-specific Stormwater Pollution Prevention Plan (SWPPP), which establishes enforceable limits on discharges, requires effluent monitoring, designates reporting requirements, and requires construction best management practices (BMPs) to reduce or eliminate point and non-point source discharges of pollutants, including sediment resulting from wind or water erosion.

Basin Plans
The SWRCB requires its nine RWQCBs to develop water quality control plans (Basin Plans) designed to preserve and enhance water quality and protect the beneficial uses of all Regional waters.

Specifically, Basin Plans designate beneficial uses for surface waters and groundwater, set narrative and numerical objectives that must be attained or maintained to protect the designated beneficial uses and conform to the State antidegradation policy, and describe implementation programs to protect all waters in the Regions. In addition, Basin Plans incorporate by reference all applicable State and Regional Board plans and policies, and other pertinent water quality policies and regulations.

This project is under the jurisdiction of the Santa Ana RWQCB (Region 8).  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
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Regional and Local
Municipal Stormwater Program
The USEPA defines municipal separate storm sewer systems (MS4s, or storm drains) as a conveyance or system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains) owned or operated by a State (40 CFR 122.26[b][8]).

Pursuant to CWA § 402(p), storm water permits are required for discharges from an MS4 serving municipalities. Most of these permits are issued to a group of co-permittees encompassing an entire metropolitan area. Phase I MS4 permits require the discharger to develop and implement a Storm Water Management Plan or Program with the goal of reducing the discharge of pollutants to the maximum extent practicable. Through the Municipal Stormwater program, RWQCBs have adopted NPDES permits to regulate storm water for municipalities. Most of these permits are issued to a group of co-permittees encompassing an entire metropolitan area. These permits require the discharger to develop and implement a Storm Water Management Plan or Program with the goal of reducing the discharge of pollutants to the maximum extent practicable (SWRCB 2025c). In this context, the NPDES Permit is also referred to as an MS4 Permit.

The National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for the San Bernardino County Flood Control District, the County of San Bernardino, and the Incorporated Cities of San Bernardino County within the Santa Ana Region, Area-Wide Urban Storm Water Runoff Management Program regulates, through Order No. R8-2010-0036 and NPDES No. CAS618036, the discharge of pollutants into waters of the U.S. and State into MS4s, through which stormwater and urban runoff are discharged into waters of the U.S. and State located within the Santa Ana Region. Some of the natural channels, streambeds and other drainage facilities that are generally considered as waters of the U.S. and State have been converted to flood control facilities. In such cases, where a natural streambed is modified to convey storm water flows, the conveyance system becomes both a conveyance system and a water of the U.S. (RWQCB, 2010) The Santa Ana Region Area-Wide Urban Storm Water Runoff Management Program regulates the discharge of pollutants in urban runoff from anthropogenic (generated from nonagricultural human activities) sources from MS4s that are either under the jurisdiction of the Permittees (the City of Redlands is a Co-Permittee), and/or where Permittees have MS4 maintenance responsibility, or have authority to approve modifications of the MS4s. Urban runoff includes those discharges from residential, commercial, industrial and construction areas within the permitted area but excludes discharges from feedlots, dairies, and farms or other agricultural activities. The Permittees have jurisdiction over and/or maintenance responsibility for storm water conveyance systems within San Bernardino County (RWQCB, 2010).

As new development and redevelopment occurs, it can significantly increase pollutant loads in stormwater and urban runoff, because increased population density results in proportionately higher levels of vehicle emissions, vehicle maintenance wastes, municipal sewage wastes, household hazardous wastes, fertilizers, pet waste, trash, and other anthropogenic pollutants. The MS4 Permit requires new development and significant redevelopment projects to incorporate post-construction low-impact development (LID) BMPs into project design to reduce or eliminate the quantity, and improve the quality of, stormwater being discharged from the project site.  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
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To comply with the requirements of the MS4 Permit, project proponents must prepare a site-specific Water Quality Management Plan (WQMP) and submit it to the Permittee (i.e., the City of Redlands) for approval. The WQMP must include site design (including, where feasible, the CALGreen Code), source control and treatment control LID BMPs to reduce the quantity of rainfall runoff and improve the quality of water that leaves a site. LID is a leading stormwater management strategy that seeks to mitigate the impacts of runoff and stormwater pollution as close to its source as possible. LID comprises a set of site design approaches and BMPs. These LID practices can effectively remove nutrients, bacteria, and metals while reducing the volume and intensity of stormwater flows.

4.9.3 Existing Conditions
Groundwater
The project site is over the Upper Santa Ana Valley Groundwater Basin, Bunker Hill Subbasin (see Figure 4.9-1). In 1969, Bunker Hill Subbasin was included as part of the “San Bernardino Basin” (SBB) by the Western-San Bernardino Judgment (Western Judgment; WSC, 2021, p. 3-20). The Bunker Hill Subbasin spans a surface area of 120 square miles within the SBB, and consists of the alluvial materials that underlay the San Bernardino Valley. Recharge to the Bunker Hill Subbasin historically has resulted from infiltration of runoff from the San Gabriel and San Bernardino Mountains. The Santa Ana River, Mill Creek, and Lytle Creek contribute more than 60 percent of the total recharge to the groundwater system. Lesser contributors include Cajon Creek, San Timoteo Creek, and most of the creeks flowing southward out of the San Bernardino Mountains. The subbasin is also replenished by deep percolation of water from precipitation and resulting runoff, percolation from delivered water, and water spread in streambeds and spreading grounds (DWR, 2004).

Groundwater Supplies
Groundwater extractions from the SBB are regulated under a court judgment. The Western Judgement determined the natural safe yield for groundwater extractions from the SBB is 232,100 acre-feet per year26 (afy), with 167,238 afy of that allocated to several water agencies in San Bernardino County and 64,862 afy allocated to a group of water purveyors in Riverside County (WSC, 2021, p. 3-20).

The City of Redlands Municipal Utilities & Engineering Department (MUED) provides water to the project site. MUED extracts groundwater from the Bunker Hill and the Yucaipa Subbasins. Between 2016 and 2020, MUED extracted between 11,442 af and 14,466 af from the Bunker Hill Subbasin, and between 16 af and 297 af from the Yucaipa Subbasin (WSC 2021, p. 4-13).

Groundwater Recharge
The SBB is intentionally recharged with stormwater; with water imported from northern California via the State Water Project (SWP); and recycled water. The San Bernardino Valley Municipal Water District, a SWP contractor, purchases SWP water for recharge into to the Upper Santa Ana Valley Groundwater Basin (WSC, 2021, p. 3-7). Total intentional groundwater recharge in the SBB in 2025 is forecast as 38,072 afy consisting of 9,112 afy imported water, 16,430 afy recycled water, and 12,530 afy local surface water (WSC, 2021, p. 4-7).
26 One acre-foot is the volume of water required to cover 1 acre with 1 foot of water, or approximately 325,851 gallons.  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
7214/Redlands – Kaiser Permanente Medical Center Page 4.9-6 Program Environmental Impact Report November 2025
Figure 4.9-1

GROUNDWATER BASINS, SUBBASINS AND RECHARGE AREAS
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Legend
c:]Project Boundary
Notembs 17. 2023
Kaiser Permanente
Medical Center
A • Groundwater Recharge Basins
CDWR Bulletin 11 8 Groundwater Basins (2021 ):
1" ■-■ R SANTAANA VALLEY
Gro undwater Basi ns, Subbasins
and Recharge Basins
Scale: 1 :63 ,360
0 0.5 1 Miles
0 0.5 1 Kilorreters
CDWR Bulletin 11 8 Groundwater Subbas ins (2021 ):
- RIALTO-COL TON
- RIVERSIDE-ARLI NGTON
- SAN BERNARDINO
- UPPER SANTAANA VALLEY - SAN TIMOTEO
- UPPER SANTAANA VALLEY - YUCAIPA
LI 1 tra.S?· stems
 SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
7214/Redlands – Kaiser Permanente Medical Center Page 4.9-7 Program Environmental Impact Report November 2025
As of 2021, there were 10 active recharge projects along tributaries of the Santa Ana River and 10 proposed or additional recharge projects (WSC 2021, pp. 3-47 – 3-48).

MUED contributes to regional efforts to recharge the SBB with SWP water and local surface water in wet years when available, so that storage is available for use in dry years when other supplies may be limited (WSC 2021, p. 4-13).

4.9.4 Environmental Impact Analysis
Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, the project would have a significant impact regarding hydrology and water quality if it would:

A. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality; or B. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; or
C. 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:
i. result in substantial erosion or siltation on- or off-site; ii. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
iii. create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
iv. impede or redirect flood flows; or
D. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation; or
E. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

The following provides a brief summary of the conclusions for each applicable CEQA threshold related to hydrology and water quality. These summaries highlight the significance determinations, the primary reasons for those determinations, and the regulatory or design features that ensure compliance. As documented in the Initial Study (Appendix A), impacts under Thresholds A, C.i, C.ii, C.iii, C.iv, D, and E were determined to be less than significant or to have no impact. Because these issues were adequately addressed at the Initial Study level and do not require further evaluation or mitigation, they are omitted from detailed analysis in this PEIR. Instead, this section focuses on  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
7214/Redlands – Kaiser Permanente Medical Center Page 4.9-8 Program Environmental Impact Report November 2025
groundwater supply and recharge (threshold B), which may result in potentially significant impacts and therefore warrants additional analysis.

Threshold A) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Less Than Significant Impact. The project could generate pollutants during construction (e.g., sediment, fuels, solvents) and operation (e.g., urban runoff). However, compliance with the NPDES Construction General Permit, implementation of a project-specific SWPPP, and incorporation of LID BMPs under the WQMP would ensure runoff is captured, treated, and managed onsite. Therefore, the project would not violate water quality standards, and impacts would be less than significant.

Threshold C.i) Result in substantial erosion or siltation on- or off-site? Less Than Significant Impact. Construction activities would disturb soils, but erosion would be minimized through SWPPP-required BMPs and incorporation of LID features into design. These measures would control runoff and stabilize soils, reducing erosion and siltation impacts to less than significant levels.

Threshold C.ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
Less Than Significant Impact. Project drainage improvements, including infiltration and bioretention basins, are designed to capture and infiltrate stormwater onsite. These BMPs would prevent increases in runoff that could cause on- or off-site flooding.

Threshold C.iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
Less Than Significant Impact. Onsite stormwater facilities are sized to retain and treat runoff before discharge. Compliance with NPDES and MS4 Permit requirements would prevent exceedance of drainage system capacity and minimize pollutant discharges.

Threshold C.iv) Impede or redirect flood flows?
No Impact. FEMA mapping identifies the site within Zone X, outside the 100-year and 500-year floodplains. The project would not impede or redirect flood flows.

Threshold D) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
No Impact. The site is not within mapped dam inundation zones, is more than 40 miles inland from the Pacific Ocean (thus not at risk from tsunamis) and is not adjacent to any waterbody capable of producing a seiche. Therefore, there would be no impact.

Threshold E) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
 SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
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Less Than Significant Impact. The project would comply with the Santa Ana Basin Water Quality Control Plan by incorporating BMPs required under the SWPPP and WQMP. The Bunker Hill Subbasin has no adopted groundwater sustainability plan; therefore, no conflict would occur, and impacts would be less than significant.

Analysis of Project Impacts
Threshold B: Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant Impact
Groundwater Supplies
The proposed project is estimated to use approximately 107,594 gallons of water per day (0.33 af), as shown below in Table 4.9-1. MUED forecasts that it will have adequate water supplies to meet demands in its service area over the 2025-2045 period in normal, single-dry-year, and multiple-dryyear conditions (WSC 2021, pp. 4-19 – 4-23; MUED total water supplies and demands are discussed further in Section 4.19, Utilities and Service Systems). Water demand forecasts are based on population estimates from the Southern California Association of Governments (SCAG) and General Plan land use buildout projections. SCAG population projections are based in part on general plan buildout projections (WSC 2021, pp. 4-19 – 4-23).

Table 4.9-1

ESTIMATED PROJECT WATER DEMAND
Phase Land Use Square
Feet/Beds
Water Demand, Gallons per Day
Per unit Total
1 Medical Office/Ambulatory
Surgery 165,000 sf 312.5 per 1,000 sf 51,563
2 Acute Care Hospital 213 beds 93.75 per bed 19,969
3 Medical Office 83,000 sf 312.5 per 1,000 sf 25,938
4 Hospital 108 beds 93.75 per bed 10,125
Total Not applicable Not applicable Not applicable 107,5941

1. 107,594 gallons = 0.33 acre-feet
Source: Michael Baker International, 2025: Water Supply Assessment for Kaiser Permanente Redlands Medical Center MUED forecasts that its groundwater supplies will increase from approximately 13,973 afy in 2025 to 16,677 afy in 2045 (WSC 2021, p. 4-19). Groundwater would comprise between 45 percent and 48 percent of the city’s projected water supply, with the remainder supplied by surface water, recycled water, and water purchased from the SWP (WSC 2021, p. 4-19). The proposed project would require an estimated annual water demand of 120.5 afy.

The General Plan designation for the project site is Commercial Industrial. The proposed project, therefore, is accounted for in MUED water demand forecasts. Thus, water use by project operation would not substantially decrease groundwater supplies, and impacts would be less than significant.  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
7214/Redlands – Kaiser Permanente Medical Center Page 4.9-10 Program Environmental Impact Report November 2025
Groundwater Recharge
Runoff generated on the project site would be captured by existing and proposed inlets and conveyed via new storm drains (similar to the LID-BMPs of Phase I) to the existing infiltration basin and to new bioretention basins, which would replace those used during the construction phase. Runoff generated in the area that previously discharged directly to Almond Avenue would also be captured by proposed inlets and conveyed via new onsite storm drains and conveyed to a new bioretention basin. Filtered water from this bioretention basin would be discharged to the existing infiltration basin; only treated overflow would discharge into the public storm drain on Almond Avenue (MBI, 2024a, p. 3).

The project includes four LID BMPs that would infiltrate stormwater into the soil: an infiltration basin under the proposed parking lot in the northwest part of the site; and three bioretention basins—one in the north-central part of the site and two in the central part of the site. The infiltration basins and bioretention basins combined would have capacity to infiltrate or retain runoff from the site from a six-hour, 2-year storm; that is, 125,534 cubic feet, as shown below in Table 4.9-2 (MBI, 2024b, sheet C5.03).

Table 4.9-2

INFILTRATION BASIN AND BIORETENTION BASINS CAPACITIES
BMP ID Capacity (cubic feet)
Infiltration Basin 92,438
Bioretention Basin 1-C 9,300
Bioretention Basin 1-B 9,765
Bioretention Basin 2-A2 14,031
Total 125,534
Source: Michael Baker International. 2024
As currently designed, LID BMPs (e.g., infiltration basin and bioretention basins) would retain most stormwater generated on the project site, remove trash and other contaminants specified in the project-specific Water Quality Management Plan, and allow stormwater to infiltrate the soil and contribute to groundwater recharge. Project development would not interfere with groundwater recharge, and impacts would be less than significant.

4.9.5 Cumulative Impacts
The area considered for cumulative impacts to groundwater is the San Bernardino Basin of the Upper Santa Ana Valley Groundwater Basin. The SBB spans a surface area of 141 square miles in the northeast part of the Upper Santa Ana River Valley.

The SBB is an adjudicated basin, pumping of groundwater is restricted, and the MUED may not extract more than its allocated volume of groundwater. The MUED also draws upon local surface water and the State Water Project to provide water to its service area. The proposed project would not require MUED to extract more groundwater than is allowed by the Western Judgement, nor would the project significantly deplete the SBB.

Other projects in the area would increase impervious areas, which could reduce groundwater recharge and would increase water demands, which could increase groundwater use. However, other projects would also be required to install LID BMPs as part of project design, minimize impervious areas, retain and treat most stormwater generated onsite, and allow treated stormwater to either  SECTION 4.9 – HYDROLOGY AND WATER QUALITY 
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infiltrate or allow only treated stormwater into storm drains (and downstream infiltration basins) as required by the MS4 Permit. Implementation of LID BMPs pursuant to the requirements of the MS4 Permit would result in most stormwater runoff generated by new construction within the SBB area being treated and allowed to infiltrate into the Bunker Hill Subbasin. Impacts would be less than significant after compliance with the MS4 permit, and project impacts would not be cumulatively considerable.

4.9.6 Mitigation Measures
Impacts would be less than significant, and no mitigation measures are required.

4.9.7 Level of Significance after Mitigation
Impacts would be less than significant without mitigation.  SECTION 4.10 – NOISE 
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4.10 Noise
This section analyzes the potential impacts from noise and vibration that would result from project construction and operation. It includes a discussion of the characteristics of sound and groundborne vibration. Regulations, standards, and plans for controlling noise exposures are then described. The section identifies sensitive noise receptors surrounding the project site and presents the results of noise exposure calculations during construction at the nearest sensitive receptor (the existing medical facility). Both short-term (construction) noise and vibration exposure estimates are quantified. Finally, cumulative noise impacts are discussed.

4.10.1 Noise and Vibration Fundamentals
Noise
Characteristics of Sound
Sound is a pressure wave transmitted through the air. It is described in terms of loudness or amplitude (measured in decibels), frequency or pitch (measured in hertz [Hz] or cycles per second), and duration (measured in seconds or minutes). The decibel (dB) scale is a logarithmic scale that describes the physical intensity of the pressure vibrations that make up any sound. The pitch of the sound is related to the frequency of the pressure vibration. Because the human ear is not equally sensitive to all frequencies, a special frequency dependent rating scale is used to relate noise to human sensitivity. The A weighted decibel scale (dBA) provides this compensation by discriminating against upper and lower frequencies in a manner approximating the sensitivity of the human ear. The scale is based on a reference pressure level of 20 micropascals (zero dBA). The scale ranges from zero (for the average least perceptible sound) to about 130 (for the average human pain level).

Noise Measurement Scales
Several rating scales have been developed to analyze adverse effects of community noise on people.

Since environmental noise fluctuates over time, these scales consider that the effect of noise on people depends largely upon the total acoustical energy content of the noise, as well as the time of day when the noise occurs. Those that are applicable to this analysis are as follows:
• Leq, the equivalent noise level, is an average of sound level over a defined time interval (such as one minute, 15 minutes, one hour, or 24 hours). Thus, the Leq of a time varying- noise and that of a steady noise are the same if they deliver the same acoustic energy to the ear during exposure.
• L90 is a noise level that is exceeded 90 percent of the time at a given location; it is often used as a measure of “background” noise.
• Lmax is the root mean square (RMS) maximum noise level during the measurement interval.

This measurement is calculated by taking the RMS of all peak noise levels within the sampling interval. Lmax is distinct from the peak noise level, which only includes the single highest measurement within a measurement interval.
• CNEL, the Community Noise Equivalent Level, is a 24-hour average Leq with a 4.77 A-- weighted decibel (dBA) “penalty” added to noise during the hours of 7:00 p.m. to 10:00 p.m., and a 10---dBA penalty added to noise during the hours of 10:00 p.m. to 7:00 a.m. to account for noise sensitivity in the evening and nighttime (ICF Jones & Stokes, 2009). The logarithmic  SECTION 4.10 – NOISE 
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effect of these additions is that a 60-dBA 24---hour Leq would result in a calculation of

66.7 dBA CNEL.
• Ldn, the day-night average noise, is a 24--hour average Leq with an additional 10d--BA “penalty” added to noise that occurs between 10:00 p.m. and 7:00 a.m. The Ldn metric yields values within 1 dBA of the CNEL metric. As a matter of practice, Ldn and CNEL values are considered to be equivalent and are treated as such in this assessment.

Ground-Borne Vibration
Vibration is sound radiated through the ground. Ground-borne noise is the rumbling sound caused by the vibration of building interior surfaces. The ground motion caused by vibration is measured in two ways: the peak particle velocity (PPV) and the root-mean-square (RMS) average, expressed as vibration decibels (VdB). The PPV, which is the maximum vibration in inches per second, is an indicator of the potential for damage to structures. The RMS average is the square root of the average of the squares of the measured particle velocities. It is an indicator of the potential for human annoyance. Typical outdoor sources of perceptible ground-borne vibration are construction equipment and traffic on rough roads.

4.10.2 Regulatory Framework
Federal
The United States Environmental Protection Agency, under the authority of the Noise Control Act of 1972, has established noise emission criteria, as detailed in Title 40 of the Code of Federal Regulations (CFR). Title 40 of the CFR, Parts 201 through 205 pertain to various transportation equipment (such as motor carries engaged in interstate commerce) and Part 204, which provides noise emission standards for construction equipment.

State
The California Department of Health Services (DHS) Office of Noise Control has studied the correlation of noise levels with effects on various land uses. (The Office of Noise Control no longer exists). The most current guidelines prepared by the state noise officer are contained in the “General Plan Guidelines” issued by the Governor’s Office of Planning and Research in 2017 (OPR, 2017) and are shown in Table 4.10-1.
 SECTION 4.10 – NOISE 
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Table 4.10-1

LAND USE COMPATIBILITY FOR COMMUNITY NOISE SOURCES
Land Use Category Community Noise Exposure (Ldn or CNEL) 50 55 60 65 70 75 80
Residential
Transient Lodging – Motel, Hotel
Schools, Libraries, Churches, Hospitals, Nursing Homes
Auditoriums, Concert Halls, Amphitheaters
Sports Arena, Outdoor Spectator Sports
Playgrounds, Parks
Golf Courses, Riding Stables, Water Recreation, Cemeteries Office Buildings, Business Commercial and Professional
Industrial, Manufacturing, Utilities, Agriculture
ZONE A - Normally Acceptable: Specified land use is satisfactory, based upon the assumption that any buildings involved meet conventional Title 24 construction standards. No special noise insulation requirements.

ZONE B - Conditionally Acceptable: New construction or development shall be undertaken only after a detailed noise analysis is made and noise reduction measures are identified and included in the project design.

ZONE C - Normally Unacceptable: New construction or development is discouraged. If new construction is proposed, a detailed analysis is required, noise reduction measures must be identified, and noise insulation features included in the design.

ZONE D - Clearly Unacceptable: New construction or development should not be undertaken.

Source: OPR, 2017
 SECTION 4.10 – NOISE 
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The City of Redlands General Plan 2035
The City of Redlands General Plan Noise Element establishes policies to minimize noise impacts, ensure compatibility between land uses, and protect noise-sensitive receptors. The following goals and policies are applicable to the proposed project and will guide the assessment and mitigation of noise impacts:

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

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

To enforce these policies, the City has established specific implementation actions:

Action 7-A.136: Require a noise analysis for all development proposals located where projected noise exposure exceeds compatibility thresholds.

Action 7-A.137: For projects exceeding the noise exposure standards in Table 7-10, require site planning and architectural design to incorporate noise-attenuating features. Mitigation must ensure compliance with allowable outdoor and indoor noise exposure standards in Table 7-11.

These policies and actions provide the regulatory framework for noise assessment and mitigation within the City of Redlands. The proposed project will be evaluated in accordance with these guidelines to ensure compliance with local standards and minimize noise-related impacts on surrounding land uses.

East Valley Corridor Specific Plan EV.4.0225 (b) (1-2)
The East Valley Corridor Specific Plan regulates operational impacts by requiring that all land uses comply with performance standards for vibration and noise. Every use of land or building shall operate in conformity with the following performance standards:
(1) Vibrations: Every use shall be so operated that maximum ground vibration generated is not perceptible without instruments at any point in the boundary of the district in which the use is located.
(2) Noise: Every use shall be so operated that the maximum volume of sound or noise generated does not exceed sixty-five (65) decibels from 7:00 a.m. to 10:00 p.m. and forty-five (45) decibels from 10:00 p.m. to 7:00 a.m. in areas which abut residential land uses. Measurement of maximum sound or noise volume can be taken at any point on the lot line of the lot on which the use is located.

City of Redlands Municipal Code
The City of Redlands Municipal Code (City of Redlands, 2004) Title 8, Chapter 8.06 specifies the noise control provisions to be implemented in the City of Redlands. Sections that are applicable to the proposed project include the following:
 SECTION 4.10 – NOISE 
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8.06.070: EXTERIOR NOISE LIMITS
“A. The noise standards for the categories of land uses identified in Table 4.10-2 of this section shall, unless otherwise specifically indicated, apply to all such property within a designated zone.

Table 4.10-2

MAXIMUM PERMISSIBLE SOUND LEVELS BY RECEIVING LAND USE
Receiving Land Use Category Time Period Noise Level - dBA Single-family residential districts 10:00 p.m. – 7:00 a.m. 7:00 a.m. – 10:00 p.m.
50 60
Multi-family residential districts; public space; institutional 10:00 p.m. – 7:00 a.m. 7:00 a.m. – 10:00 p.m.
50 60
Commercial 10:00 p.m. – 7:00 a.m.
7:00 a.m. – 10:00 p.m.
60 65
Industrial Any time 75

B. No person shall operate, or cause to be operated, any source of sound at any location within the city or allow the creation of any noise on property owned, leased, occupied or otherwise controlled by such person which causes the noise level when measured on any other property to exceed:

1. The noise standard for that land use specified in table 127 of this section for a cumulative period of more than thirty (30) minutes in any hour; or

2. The noise standard specified in table 1 of this section plus five (5) dB for a cumulative period of more than fifteen (15) minutes in any hour; or

3. The noise standard specified in table 1 of this section plus ten (10) dB for a cumulative period of more than five (5) minutes in any hour; or

4. The noise standard specified in table 1 of this section plus fifteen (15) dB for a cumulative period of more than one minute in any hour; or

5. The noise standard specified in table 1 of this section plus twenty (20) dB or the maximum measured ambient level, for any period of time.”

8.06.090: NOISE DISTURBANCES PROHIBITED
The following acts, and the causing or permitting thereof, are declared to be in violation of this chapter:
“F. Construction and/or Demolition: Operating or causing the operation of any tools or equipment used in construction, drilling, repair, alteration or demolition work between weekday hours of six o'clock (6:00) P.M. and seven o'clock (7:00) A.M., including Saturdays, or at any time on Sundays or holidays, such that the sound therefrom creates a noise disturbance across a residential or commercial real property line, except for emergency work by public service utilities, the city or another governmental entity. All mobile or stationary internal combustion engine powered equipment or machinery shall be equipped 27 Table numbering here refers to the cited Municipal Code section. “Table 1” of the Municipal Code is shown as Table

4.10-2 in this section of the PEIR.
 SECTION 4.10 – NOISE 
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with exhaust and air intake silencers in proper working order, or suitable to meet the standards set forth herein.28
G. Vibration: Operating or permitting the operation of any device that creates a vibration which is above the vibration perception threshold of an individual at or beyond the property boundary of the source if on private property or at one hundred fifty feet (150') from the source if on a public space or public right of way.”

8.06.120: EXEMPTIONS
“G. Construction Activity: This chapter shall not apply to noise sources associated with new construction, remodeling, rehabilitation or grading of any property provided such activities take place between the hours of seven o'clock (7:00) A.M. and six o'clock (6:00) P.M. on weekdays, including Saturdays, with no activities taking place at any time on Sundays or federal holidays. All motorized equipment used in such activity shall be equipped with functioning mufflers.”

4.10.3 Methodology
Noise impacts from construction activities are a function of the noise generated by the operation of construction equipment and onroad delivery and worker commuter vehicles, the location of equipment, and the timing and duration of the noise generating activities. For this analysis, it was estimated that project construction would start in early September 2027 and end in January 2050.

The project will be constructed in four phases, with several years between the end of one phase and the start of the next. Construction noise analyses have been conducted separately for each phase to accurately assess noise impacts and develop phase-specific mitigation measures if required.

Using preliminary design and scheduling information, UltraSystems used the air pollutant emissions estimation model CalEEMod29 to estimate the number of days to execute the following construction subphases:
• Demolition.
• Site preparation.
• Grading.
• New building construction.
• Paving.
• Architectural coating.
• Utilities and trenching.

The types and numbers of pieces of equipment anticipated in each phase of construction and development were estimated using CalEEMod and UltraSystems’ experience with similar projects.

Table 4.10-3 through Table 4.10-7 list the equipment expected to be used in each of the four phases.

For each equipment type, the table shows a maximum noise emission level (in dBA at 50 feet, unless 28 See the construction exemption in §8.06.120 below. 29 Described in Section 4.2.  SECTION 4.10 – NOISE 
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otherwise specified) and a “usage factor,” which is an estimated percentage of operating time that the equipment would be producing noise at the stated level.30 Table 4.10-3
PHASE 1 CONSTRUCTION EQUIPMENT NOISE CHARACTERISTICS
Subphase Equipment Type No. of Pieces of
Equipment
HorsepowerUsage
Factor
dBA
@
50 Feet
Demolition
Concrete Saw 1 1 0.7 90
Tractor/Loader/Backhoes 1 97 0.37 85
Rubber Tired Loaders 1 225 0.20 74
Site Preparation
Rubber Tired Loaders 3 225 0.40 74
Tractor/Loader/Backhoes 4 97 0.37 85
Grading
Excavators 1 158 0.14 88
Tractor/Loader/Backhoes 3 97 0.37 85
Rubber Tired Loaders 1 150 0.40 74
Graders 1 148 0.41 85
Building Construction
Welders 1 80 0.10 74
Generator Sets 1 14 0.50 73
Cranes 1 231 0.29 83
Tractor/Loader/Backhoes 3 97 0.37 85
Forklift 3 0.20 0.40 82
Paving
Pavers 2 81 0.42 77
Paving Equipment 2 132 0.5 85
Rollers 2 80 0.10 74
Architectural Coating Air Compressor 1 37 0.48 77
Utilities Trenching and
Installation Trenchers 1 231 0.27 83
30 Equipment noise emissions and usage factors are from Knauer, H. et al., 2006. FHWA Highway Construction Noise Handbook. U.S. Department of Transportation, Research and Innovative Technology, Administration, Cambridge, Massachusetts, FHWA-HEP-06-015 (August 2006), except where otherwise noted.  SECTION 4.10 – NOISE 
7214/Redlands – Kaiser Permanente Medical Center Page 4.10-8 Program Environmental Impact Report November 2025
Table 4.10-4
PHASE 2 CONSTRUCTION EQUIPMENT NOISE CHARACTERISTICS
Subphase Equipment Type
No. of Pieces of
Equipment HorsepowerUsage
Factor
dBA
@
50 Feet
Site Preparation
Rubber Tired Loaders 3 225 0.40 74
Tractor/Loader/Backhoes 4 97 0.37 85
Pad Grading
Excavators 2 158 0.14 88
Tractor/Loader/Backhoes 2 97 0.37 85
Rubber Tired Loaders 1 150 0.40 74
Graders 1 148 0.41 85
Building Construction
Welders 1 80 0.10 74
Generator Sets 1 14 0.50 73
Cranes 1 231 0.29 83
Tractor/Loader/Backhoes 3 97 0.37 85
Forklift 3 0.20 0.40 82
Paving and
Landscaping
Pavers 2 81 0.42 77
Paving Equipment 2 132 0.5 85
Rollers 2 80 0.10 74
Architectural Coating Air Compressor 1 37 0.48 77
Utilities Trenching and
Installation Trenchers 1 231 0.27 83
Table 4.10-5
PHASE 3 CONSTRUCTION EQUIPMENT NOISE CHARACTERISTICS
Subphase Equipment Type
No. of Pices of
Equipment HorsepowerUsage
Factor
dBA
@
50 Feet
Site Preparation
Rubber Tired Loaders 3 225 0.40 74
Tractor/Loader/Backhoes 4 97 0.37 85
 SECTION 4.10 – NOISE 
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Subphase Equipment Type
No. of Pices of
Equipment HorsepowerUsage
Factor
dBA
@
50 Feet
Fine Grading
Excavators 2 158 0.14 88
Tractor/Loader/Backhoes 3 97 0.37 85
Rubber Tired Loaders 1 150 0.40 74
Graders 1 148 0.41 85
Building Construction
Welders 1 80 0.10 74
Generator Sets 1 14 0.50 73
Cranes 1 231 0.29 83
Tractor/Loader/Backhoes 3 97 0.37 85
Forklift 3 0.20 0.40 82
Paving and
Landscaping
Pavers 1 81 0.42 77
Paving Equipment 2 132 0.5 85
Cement and Mortar Mixers 2 9 0.56 67
Rollers 2 80 0.10 74
Architectural Coating Air Compressor 1 37 0.48 77
Utilities Trenching and
Installation Trenchers 1 231 0.27 83
Table 4.10-6
PHASE 4 CONSTRUCTION EQUIPMENT NOISE CHARACTERISTICS
Subphase Equipment Type
No. of Pices of
Equipment HorsepowerUsage
Factor
dBA
@
50 Feet
Site Preparation
Scrapers 1 225 0.40 74
Graders 1 148 0.41 85
Tractor/Loader/Backhoes 1 97 0.37 85
Fine Grading
Scrapers 2 158 0.14 88
Tractor/Loader/Backhoes 2 97 0.37 85
Rubber Tired Loaders 1 150 0.40 74
 SECTION 4.10 – NOISE 
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Subphase Equipment Type
No. of Pices of
Equipment HorsepowerUsage
Factor
dBA
@
50 Feet
Graders 1 148 0.41 85
Building Construction
Welders 1 80 0.10 74
Generator Sets 1 14 0.50 73
Cranes 1 231 0.29 83
Tractor/Loader/Backhoes 1 97 0.37 85
Forklift 2 0.20 0.40 82
Paving and
Landscaping
Pavers 1 81 0.42 77
Paving Equipment 2 132 0.5 85
Cement and Mortar Mixers 1 9 0.56 67
Graders 1 148 0.41 85
Rollers 2 80 0.10 74
Architectural Coating Air Compressor 1 37 0.48 77
Utilities Trenching and
Installation Trenchers 1 231 0.27 83
For the noise exposure calculations, the distances used were, for each subphase, the shortest distance between source and receiver. Because the construction equipment is used throughout the project site, the noise sources were assumed to be roughly in the middle of the construction activity.

4.10.4 Existing Conditions
The primary noise source in the City of Redlands is vehicular traffic along major arterials, including Interstate 10, State Route 210, and major city streets such as Redlands Boulevard and Orange Street.

Typical urban noise contributors include commercial and industrial activities, construction operations, landscape maintenance equipment, and emergency vehicle sirens. Given the city's proximity to San Bernardino International Airport, aircraft overflights contribute to the ambient noise environment, particularly in areas closer to the airport.

Noise-Sensitive Receptors
The City of Redlands General Plan 2035 identifies the following land uses as noise-sensitive receptors:
 SECTION 4.10 – NOISE 
7214/Redlands – Kaiser Permanente Medical Center Page 4.10-11 Program Environmental Impact Report November 2025
• Residences
• Schools
• Hospitals
• Religious facilities
• Libraries
• Parks
For this analysis, medical office buildings (MOBs) such as the existing Kaiser facility east of the project, were considered to be short-term noise-sensitive receptors. The MOB is the nearest noisesensitive receiver. Table 4.10-7 shows the nearest receptors by category.

Table 4.10-7

NEAREST NOISE-SENSITIVE RECEPTORS
Category Name Address Distance
(feet)a
Medical Office Building Kaiser Redlands Medical Offices 1301 California St Redlands, CA 92374 150
Residence Rosewood Apartments 26232 Redlands Blvd,
Redlands, CA 92373 2,371
School Packinghouse Christian Academy 27165 San Bernardino Ave, Redlands, CA 92374 5,280
Hospital Loma Linda University Children’s
Hospital
11234 Anderson St,
Loma Linda, CA 92354 13,200
Religious Facility Packinghouse Christian Academy 27165 San Bernardino Ave, Redlands, CA 92374 5,280
Library Loma Linda Public Library 25581 Barton Rd,
Loma Linda, CA 92354 9,504
Park Heritage Park 1885 Orange Ave,
Redlands, CA 92373 8,606
aThis is not the distance used in construction emission calculations. See text.

Note: The sensitive receptors in the medical office building are the nearest during Phase 1 construction. Each subsequent phase was analyzed to determine the nearest sensitive receptor for each phase.

Ambient Noise
The proposed project site falls within the projected 60 dBA CNEL noise contours for the year 2035, as identified in the City of Redlands General Plan 2035. The 60 dBA CNEL contour represents a level of noise typically considered acceptable for most residential and commercial land uses with conventional construction practices. According to the Noise Element of the General Plan, this noise level is characterized as “quiet,” a noise level considered acceptable for commercial land uses without requiring mitigation measures. The General Plan emphasizes the importance of noise compatibility and specifies measures to ensure that development within these contours maintains compatibility with surrounding uses and complies with established noise standards.

4.10.5 Environmental Impact Analysis

4.10.5.1 Thresholds of Significance
In accordance with CEQA Guidelines Appendix G, the project would have a significant impact related to noise if it would result in the:
 SECTION 4.10 – NOISE 
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A. Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; or B. Generation of excessive groundborne vibration or groundborne noise levels; or C. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels.

The Initial Study (refer to Appendix A1) determined that there would be no impact for Threshold C. Under Threshold C, project development would not cause airport-related hazards, or excessive noise, to persons at the project site and thus no impacts would occur. This analysis therefore evaluated impacts only for Appendix G Thresholds A and B.

Because Municipal Code § 8.06.120 exempts construction activities (within specified time-of-day limits) from the Code’s quantitative exposure limits, the City, as Lead Agency, used the following criteria for determining the significance under CEQA for project-generated construction and operational noise:

The proposed project would have a significant noise impact if it would:
• Expose persons to or generate noise levels in excess of standards prescribed by the City of Redlands Municipal Code; or
• Include construction activities within the hours prohibited by the Municipal Code; or • Result in noise exposures at sensitive receivers during construction exceeding 80 dBA Leq (FTA, 2018, p. 179); or
• Contribute, with other local construction projects, to a significant cumulative noise impact; or • Increase operational exposures at sensitive receivers (mainly because of an increase in traffic flow) by 5 dBA CNEL or more.

4.10.5.2 Analysis of Project Impacts
Threshold A: Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Less Than Significant Impact
Construction Impacts
Project construction would be temporary but could result in significant short-term increases in noise levels at the nearest sensitive receiver. Operational noise impacts, by contrast, would be longterm and would include both on-site stationary sources and off-site transportation-related sources.  SECTION 4.10 – NOISE 
7214/Redlands – Kaiser Permanente Medical Center Page 4.10-13 Program Environmental Impact Report November 2025
Table 4.10-8 shows the maximum exposures for each construction phase’s nearest sensitive receiver. During phase 1, the nearest sensitive receiver is the existing MOB. During phases 2 and 3, the nearest sensitive receiver would be the patients and users of the facilities built during phase 1.

During phase 4, the nearest sensitive receiver would be the patients and users of the facilities built during phase 2. For all construction, the highest exposure would be 80.0 dBA Leq. This corresponds to the fine grading subphase and is equivalent to the FTA significance threshold of 80 dBA Leq.

Construction noise during each phase would not exceed the FTA 80 dBA criteria (FTA Assessment Manual Page 179 Option B: Detailed Analysis).31 No mitigation measures would be required.

However, since during fine grading for Phase 3, construction noise exposure may reach the FTA threshold of 80 dBA Leq, Best Management Practices (BMPs) BMP NOISE-1 would be implemented during construction of Phase 3 to ensure that noise levels during construction would not exceed the 80 dBA Leq FTA threshold.

Table 4.10-8

MAXIMUM CONSTRUCTION NOISE EXPOSURES AT NEAREST SENSITIVE RECEIVER Construction Phase
and Subphase
Distancea
(feet)
Construction
Exposure (dBA Leq)
1 – Site Preparation 245 73.7
2 – Site Preparation 100 76.5
3 – Fine Grading 135 80. 0
4 – Fine Grading 120 73.5 a For construction phases 2-4, the nearest affected sensitive receiver includes those phases already in operation.

Operational Impacts
Onsite noise sources associated with the proposed project would include rooftop mechanical equipment such as HVAC systems, emergency generators, and ventilation units, as well as noise from trash collection, parking lot activity, and vehicle movements within the campus. Rooftop equipment typically generates 50 to 55 dBA at 50 feet, which is unlikely to be perceptible above ambient traffic noise levels in the surrounding area. Trash collection may generate brief, elevated noise events; however, given the short duration of these activities, they would not contribute significantly to overall hourly Leq values. The existing site is within a commercial and medical office setting, where similar noise sources, including parking lot activity and mechanical systems, are already present. Given the existing ambient noise environment and the nature of the proposed project, on-site stationary noise sources would not result in a substantial increase in exposure, and impacts would be less than significant.

The project will generate new traffic in the project area, including staff commuting trips, patient and visitor trips, trips by delivery vehicles and sirens from ambulances induced by development of a new emergency room. The new traffic has the potential for generating noise throughout the day and night, which could have an adverse impact on sensitive noise receptors. The majority of the roadways surrounding the project site are in industrial or commercial areas, which lack these types of sensitive receptors. In the spirit of full disclosure, the following analysis of operational noise impacts was performed. To exceed the operational noise exposure threshold of an increase of 5 dBA CNEL, average daily traffic would have to be more than double. Therefore, projected traffic was compared 31 Transit Noise and Vibration Impact Assessment Manual(FTA, 2018). Office of Planning and Environment, Washington, DC. FTA Report No. 0123. September 2018. Available at
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibrationimpact-assessment-manual-fta-report-no-0123_0.pdf  SECTION 4.10 – NOISE 
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with existing traffic on the same road segments.32
The CalEEMod modeling predicted that project operations (after completion of Task 4 construction in 2050) would generate a total annual average daily traffic (ADT) of 16,368. (See Appendix D2). The traffic study (Fehr & Peers, 2025) derived the same value and estimated the percentages of this future traffic that would travel on most of the local roadways. This information was used to distribute project-generated traffic by road segment. Because the traffic distributions did not include every relevant street segment, only 15,059 ADT of the projected traffic was accounted for. However, this includes 92 percent of project-generated traffic. “Existing” traffic data for local road segments were obtained from a traffic inventory maintained by the City of Redlands and accessible online (City of Redlands, 2025). The data displayed by this online tool are from about two to 12 years old.

Table 4.10-9 shows the road segments for which both “existing” and distributed future traffic data were available. Table 4.10-10 shows the percent increase in traffic after Phase 4 construction. In no case would traffic double. The maximum increase, by 52.4 percent, would be on Almond Avenue, west of the project site. Traffic noise would increase by about 1.8 dBA, which most people would not perceive. Onroad operational noise impacts would therefore be less than significant.

Table 4.10-9

EXISTING TRAFFIC ON ROAD SEGMENTS ANALYZED
Segment Roadway From To ADT
A Mountain View Avenue W. San Bernardino Ave Redlands Boulevard 11,096 B W. San Bernardino Avenue Entire project area, west of project site 9,789 C W. San Bernardino Avenue Entire project area, east of project site 9,789 S Almond Avenue Entire project area, west of project site 2,500 E Almond Avenue Entire project area, east of project site 2,500 F W. Lugonia Avenue Mountain View Avenue California Street 2,695 G W. Lugonia Avenue California Street Alabama Street 7,400 H Orange Tree Lane California Street Alabama Street 3,920 I Redlands Boulevard Entire project area, west of project site 7,427 O Redlands Boulevard Entire project area, east of project site 7,427 K Interstate-10 East of California Street 170,500
L Interstate-10 West of California Street 191,000
Table 4.10-10

ESTIMATED INCREASE IN LOCAL TRAFFIC AT FULL PROJECT BUILDOUT Segment Roadway ADT Pct of
Projected New Pct
Existing Increase
A Mountain View Avenue 11,096 2 327 2.95
B W. San Bernardino Avenue 9,789 4 655 6.69
C W. San Bernardino Avenue 9,789 6 1,309 13.4
S Almond Avenue 2,500 6 1,309 52.4
E Almond Avenue 2,500 2 327 13.1
F W. Lugonia Avenue 2,695 4 655 24.3
G W. Lugonia Avenue 7,400 4 655 8.85
H Orange Tree Lane 3,920 4 655 16.7
32 This approach is highly conservative, because project traffic should be compared with traffic that would occur in the buildout year or later. At a modest annual growth rate of one percent, the “existing” ADT would be about 28 percent higher than current values.
 SECTION 4.10 – NOISE 
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I Redlands Boulevard 7,427 12 1,964 26.5
O Redlands Boulevard 7,427 12 1,964 26.5
K Interstate-10 170,500 15 2,455 1.44
L Interstate-10 191,000 17 2,783 1.46
Threshold B: Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Less Than Significant Impact
Vibration is sound radiated through the ground. Vibration can result from a source (e.g., subway operations, vehicles, machinery equipment, etc.) causing the adjacent ground to move, thereby creating vibration waves that propagate through the soil to the foundations of nearby buildings. This effect is referred to as groundborne vibration. CEQA addresses two types of impacts of groundborne vibration: architectural vibration and human annoyance.

Construction Vibration
It is expected that ground-borne vibration from project construction activities would cause only intermittent, localized intrusion. The project’s construction activities most likely to cause vibration impacts are:
• Heavy Construction Equipment: Although all heavy, mobile construction equipment has the potential of causing at least some perceptible vibration while operating close to buildings, the vibration is usually short term and is not of sufficient magnitude to cause building damage. For each construction phase, vibration exposures were calculated for the nearest building to the construction activity, whether it be the existing Kaiser facility or a building constructed in a previous phase of the proposed project. All vibration exposures in all construction phases would be less than significant. It is not expected that heavy equipment such as large bulldozers would operate closely enough to any sensitive receivers to cause vibration impact.
• Trucks: Trucks hauling building materials to construction sites can be sources of vibration intrusion if the haul routes pass through residential neighborhoods on streets with bumps or potholes. Repairing the bumps and potholes almost always eliminates the problem.

The FTA (2018) has published standard vibration levels for construction equipment operations, at a reference distance of 25 feet. The calculated vibration levels expressed in VdB and PPV for typical construction equipment at their distances during construction are listed in Table 4.10-11. The nearest sensitive receiver for onsite construction vibration would be the existing medical office building and the completed buildings after each phase. The distance shown in Table 4.10-11 is from the center of construction activity in Phase 1 to the center of the MOB. For loaded trucks, the distance is from the center of the MOB to the centerline of the nearest traffic lane on California Street.

Table 4.10-11

VIBRATION LEVELS OF TYPICAL CONSTRUCTION EQUIPMENT
Equipment
PPV
at 25 feet
(in/sec)
Vibration
Decibels
at 25 feet
(VdB)
PPV
at 342 feet
(in/sec)
Vibration
Decibels
at 342 feet
(VdB)
PPV
at 409 feet
(in/sec)
Vibration
Decibels
at 409 feet
(VdB)
Loaded trucks 0.076 86 0.004 50
Jack hammer 0.035 79 0.002 45
 SECTION 4.10 – NOISE 
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Equipment
PPV
at 25 feet
(in/sec)
Vibration
Decibels
at 25 feet
(VdB)
PPV
at 342 feet
(in/sec)
Vibration
Decibels
at 342 feet
(VdB)
PPV
at 409 feet
(in/sec)
Vibration
Decibels
at 409 feet
(VdB)
Small bulldozer 0.003 58 0.0002 26
Large bulldozer 0.089 87 0.005 53
As shown in Table 4.10-9, the PPV of construction equipment at the nearest sensitive receiver (342 feet) is at most 0.005 inch per second (and after each subsequent phase), which is less than the FTA damage threshold of 0.12 inch per second PPV for fragile historic buildings. The maximum VdB are 53 VdB, which are below the FTA threshold for human annoyance of 80 VdB. Unmitigated vibration impacts would therefore be less than significant.

4.10.6 Cumulative Impacts
Cumulative construction impacts could occur if other construction projects were active concurrently with development of the proposed project, and near enough so that noise from two or more projects were perceived by the same sensitive receivers. However, the area surrounding the project site is almost completely built out, and there is limited space for new development. Currently, there are no planned or reasonably foreseeable future projects that would be under construction at the same time as the proposed project and could generate additional construction noise in the immediate project vicinity. Therefore, cumulative construction noise impacts would be less than significant.

4.10.7 Mitigation Measures
Impacts would be less than significant for both noise and vibration. However, since during fine grading for Phase 3, construction noise exposure may reach the FTA threshold of 80 dBA Leq. a supplemental noise study (BMP NOISE-1) would be undertaken during the Lead Agency’s approval of Phase 3 to ensure that noise levels during construction would not exceed that threshold.

BMP NOISE-1 Noise Study for Phase 3. A new noise study shall be conducted after completion of Phase 2 construction and prior to the start of Phase 3 construction to determine potential noise impacts of Phase 3 construction activities. The information in this study will be used in support of the Lead Agency’s approval of Phase 3 and potential preparation of a Noise Mitigation Plan for Phase 3 construction if necessary.

4.10.8 Level of Significance after Mitigation
Noise impacts are expected to be less than significant without mitigation. Implementation of BMP NOISE-1 will reconfirm that noise levels during construction of Phase 3 would not exceed the 80 dBA Leq FTA threshold and that reasonably foreseeable noise impacts would remain less than significant.  SECTION 4.11 – PUBLIC SERVICES 
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4.11 Public Services

4.11.1 Introduction
This section discusses the proposed project’s potential impact to public services. The Initial Study, included as Appendix A to this PEIR, determined that Threshold C (Schools), Threshold D (Parks) and Threshold E (Libraries/Hospitals) would be less than significant.33 Therefore, those impacts are not addressed in this section.

4.11.2 Regulatory Framework
Fire Protection Services
Federal
Occupational Safety and Health Act
The Occupational Safety and Health Act of 1970 led to establishment of the Occupational Safety and Health Administration to assure safe and healthful working conditions for all workers by setting and enforcing standards and by providing training and education. The required safety and health regulations for construction sites are included in the Code of Federal Regulations, Title 29, Part 1926.

Safety requirements related to fire protection and prevention for construction sites are provided in Part 1926, Subpart F, and generally include provision of fire suppression and fire-fighting equipment on construction sites, sufficient water supply, and requirement for keeping storage sites free from accumulation of unnecessary combustible materials. In California, the Division of Occupational Safety and Health, also known as Cal/OSHA, is responsible for administering these safety and health requirements.

State
California Code of Regulations, Title 24, Part 2, California Building Code Current law states that every local agency enforcing building regulations, such as cities and counties, must adopt the provisions of the California Building Code (CBC) within 180 days of its publication date, which is established by the California Building Standards Commission. The most recent building standard adopted by the legislature and used throughout the state is the 2022 version of the CBC, often with local, more restrictive amendments that are based on local geographic, topographic, or climatic conditions. The CBC is updated on a three-year cycle, and the 2022 CBC took effect on January 1, 2023. The building standards in the California Building Code apply to all locations in California, except where more stringent standards have been adopted by state agencies and local governing bodies.

Requirements for structures in Fire Hazard Severity Zones are provided in Chapter 7A of the CBC, “Materials and Construction Methods for Exterior Wildfire Exposure,” and Chapter 49 of the California Fire Code, “Requirements for Wildland-Urban Interface Fire Areas.” Requirements in these 33 Public service impacts related to schools, parks, libraries and hospitals were found to have no impact because the proposed project is not a land use that would increase the population in the area.  SECTION 4.11 – PUBLIC SERVICES 
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two chapters cover roofing, attic ventilation, exterior walls, exterior windows and glazing, exterior doors, decking, protection of underfloor, appendages and floor projections, and ancillary structures.

California Code of Regulations, Title 24, Part 9, California Fire Code Requirements in the California Fire Code (CFC) are for: building and equipment design, such as firerated construction, alarm systems, sprinkler systems, and means of egress; requirements for specific land uses, including airports, dry cleaners, gas stations, and automotive service businesses; hazardous materials; fire flow requirements; and fire hydrant spacing. Other fire safety requirements of the CFC are related to the provision of fire resistance standards for doors, building materials, and particular types of construction, and clearance of debris within a prescribed distance from occupied structures within wildfire hazard areas. The CFC is updated on a three-year cycle, and the 2022 CFC took effect on January 1, 2023.

Local
Chapter 15.20, City of Redlands Fire Code
The Fire Code is Chapter 15.20 of the Redlands Municipal Code. It adopts an amended version of the California Fire Code. The Redlands Fire Code amends several provisions of the California Fire Code in order to address local needs pertaining to high fire hazard areas, water supplies, fire extinguishing and sprinkler systems, and flammable and combustible materials (City of Redlands Fire Prevention Bureau, 2012). Modifications to the California Fire Code include water supply and sprinkler requirements for areas without City water service; the delineation of a Local Responsibility Area for the city’s wildland-urban interface area; vegetation management (fuel modification) requirements for buildings and structures in or adjoining hazardous fire areas; defensible space requirements for properties in the designated very high fire hazards severity zone; and requirements for a fire protection plan for new development in the wildland-urban interface area.

Police Protection Services
Local
City of Redlands Municipal Code § 2.14: Police Protection The chief of police shall establish rules and regulations for the governance of the police department of the city. Such rules and regulations shall be reviewed annually by the chief of police, with the city attorney office's assistance, for compliance with applicable law. The chief of police, when establishing such rules and regulations, may utilize a service or agency that provides model rules and regulations for California police departments.

A police reserve force is established in the city as a voluntary organization, and which is excluded from the civil service or personnel system of the city; the members of which may receive compensation in the form of a stipend as established by resolution of the city council. The chief of police is empowered to deputize and appoint persons as reserve city police officers pursuant to Penal Code § 832.6. Those persons appointed by the chief of police who are qualified as "designated" level 1 reserve officers have the full powers and duties of a peace officer as provided in Penal Code § 830.1; the authority of "nondesignated" level 1 reserve officers extends only for the duration of assignment to specific police functions, as determined by the chief of police. All appointments of  SECTION 4.11 – PUBLIC SERVICES 
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persons to the police reserve force are made without regard to race, sex, creed, religion or political affiliation.

4.11.3 Existing Conditions
Fire Protection Services
Fire protection services are provided to the project site by Redlands Fire Department (City of Redlands, 2017b, p. 3.13-14). The nearest fire station to the project site is the Redlands Fire Station 264 at 1270 W Park Avenue, 2.3 miles southeast (Google Earth Pro, 2025).

Police Protection Services
Police protection services are provided to the project site by Redlands Police Department (City of Redlands, 2017b, p. 3.13-13). The nearest police station to the project site is the Redlands Police Department, at 1270 W Park Avenue, is 2.3 miles southeast (Google Earth Pro, 2025).

4.11.4 Environmental Impact Analysis

4.11.4.1 Thresholds of Significance
In accordance with CEQA Guidelines Appendix G, the project would have a significant impact related to public services if it would result in the:

A. substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the need for new or physically altered governmental facilities, construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection?
b) Police protection?
c) Schools?
d) Parks?
e) Other public facilities?
In the Initial Study (refer to Appendix A1), it was determined that there would be no impact for Thresholds A-c) schools, A-d) parks, and A-e).other public facilities. Construction and operational workers are expected to reside in or near the project area and would not contribute to an increase in population. Therefore, there would be no impact to schools, parks, and other public facilities such as libraries. Regarding hospitals. the project would be a benefit to hospital service availability. This analysis therefore evaluated impacts only for Appendix G sub-Thresholds a) and b).
 SECTION 4.11 – PUBLIC SERVICES 
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4.11.4.2 Analysis of Project Impacts
Threshold A: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the need for new or physically altered governmental facilities, construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) and b) Fire Protection, and Police Protection.

Less than Significant Impact
The proposed project site is located in an existing fire and police service department area.

Development of the proposed hospital could increase the demands for services from the City’s fire and police departments. However, the project would adhere to City of Redlands Municipal Ordinance No. 2968, which authorizes Fire Protection Facilities Fees for industrial and healthcare uses of $551 per 1,000 square feet; and Police Facilities Fee of $636 per 1,000 square feet for the same land uses (City of Redlands, 2024). Payment of development fees would ensure that there would be adequate fire and police services to serve the project. Additionally, the project would be developed to the latest City standards, which would ensure adequate ingress and egress. Therefore, with adequate service fees and circulation for emergency personnel, there would be less than significant impacts related to fire and police services.

4.11.5 Cumulative Impacts
As discussed above, the proposed project would be adequately served by public services through development fees. As detailed in Section 3.0, there are related projects in the area that could potentially impact public services in the area. However, each project would be required to ensure there are adequate public services that can serve the project (i.e., development fees). Therefore, there would be no cumulative or cumulatively considerable impacts to public services.

4.11.6 Mitigation Measures
Upon compliance with regulatory requirements, impacts related to Thresholds A (fire protection) and B (police protection) would be less than significant. No mitigation measures are required.

4.11.7 Level of Significance after Mitigation
Impacts would be less than significant, and no mitigation measures are required.  SECTION 4.12 – TRANSPORTATION 
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4.12 Transportation

4.12.1 Introduction
This section evaluates the potential transportation impacts of the proposed project. The analysis relies on the Kaiser Redlands Expansion Transportation Study prepared by Fehr & Peers (February 2025), provided in Appendix D13. The traffic study examined both Vehicle Miles Traveled (VMT) impacts, in accordance with Senate Bill (SB) 743 and the City of Redlands VMT Analysis Guidelines (2020), and the operational performance of 10 existing intersections and five proposed project driveway intersections.

Under SB 743, VMT replaced the traditional Level of Service (LOS) approach as the primary metric for evaluating transportation impacts under CEQA. LOS measures intersection delay (for example, whether a road is congested), while VMT measures the total amount of driving a project generates, expressed as the number of miles driven by all vehicles associated with the project. The shift to VMT emphasizes reducing greenhouse gas emissions and promoting sustainable land use and transportation patterns. This transition became mandatory statewide on July 1, 2020.

For the proposed project, the Initial Study (Appendix A1) determined that transportation impacts related to circulation system policies, roadway design hazards, and emergency access would be less than significant. These issues are not carried forward for detailed analysis in this PEIR. Instead, this section focuses on VMT impacts, as VMT is the sole area where the project may result in a potentially significant effect with respect to transportation.

In other words, it has been demonstrated that the project would fit safely into the surrounding road network—with adequate driveways, sidewalks, and emergency access—but, under CEQA, the project requires further review to determine whether the project would result in increased vehicle usage greater than what state and local standards consider acceptable. The purpose of the following analysis is to determine whether the project would cause more driving than is consistent with Redlands’ transportation and sustainability goals, and to identify any mitigation measures that may be needed to reduce VMT impacts.

4.12.2 Regulatory Framework
The regulatory framework applicable to the proposed project is addressed in Appendix A1, Initial Study.

4.12.3 Existing Conditions
Roadways
The project traffic study area consists of segments of California Street, Lugonia Avenue, Almond Avenue, and Mountain View Avenue, as well as Interstate 10 (I-10) and State Route 210 (SR-210) freeways.
• California Street is a four-to-six lane north-south roadway • Lugonia Avenue is a three-to-four lane east-west roadway • Almond Avenue is a four-to-six lane roadway
• Mountain View Avenue is a four-to-six lane east-west roadway • I-10 in the study area is an eight-to-10 lane freeway  SECTION 4.12 – TRANSPORTATION 
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• SR-210 in the study area is a six-to-eight lane freeway (Fehr & Peers, 2025, p. 18).

Intersections
The project traffic study analyzed the operation of 10 intersections, all signalized and all in the jurisdiction of the city of Redlands:
• California Street and San Bernardino Avenue
• California Street and Almond Avenue
• California Street and Lugonia Avenue
• California Street and Orange Tree Lane
• California Street and I-10 WB Ramps
• California Street and I-10 EB Ramps
• California Street and Redlands Boulevard
• Mountain View Avenue and Almond Avenue
• Mountain View Avenue and I-10 WB Ramps
• Mountain View Avenue and I-10 EB Ramps (Fehr & Peers, 2025, p. 23).

Bicycle and Pedestrian Facilities
A Class 1 (off-road) bicycle path is present on California Avenue.

Within the study area, sidewalks are provided along California Street, Lugonia Avenue, and sections of Almond Avenue (though not Almond Avenue fronting the project site) (Fehr & Peers, 2025, p. 21).

Public Transit
Omnitrans operates public transit bus service in Redlands. Three Omnitrans routes operate in the study area:
• Route 8 extends east-west between Yucaipa and San Bernardino and operates on Redlands Boulevard in the study area.
• Route 15 extends east-west between Redlands and Fontana and operates on Alabama Street near the study area.
• Route 19 extends east-west between Yucaipa and Fontana and operates on Barton Road near the study area (Fehr & Peers ,2025, p. 22).

4.12.4 Environmental Impact Analysis

4.12.4.1 Thresholds of Significance
In accordance with the CEQA Guidelines Appendix G, the project would have a significant impact related to transportation if it would:

A. Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities; or B. Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b); or  SECTION 4.12 – TRANSPORTATION 
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C. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or D. Result in inadequate emergency access.

The Initial Study (Appendix A1) determined that impacts would be less than significant for Thresholds A, C and D. This analysis therefore evaluates impacts only for Appendix G Threshold B.

The proposed project would not conflict with applicable transportation plans or policies, as surrounding arterial roadways (Lugonia Avenue, California Street, Almond Avenue) provide adequate access and sidewalks, and Omnitrans Route 8 provides nearby transit service (Omnitrans, 2023a, 2023b). The project is not a transportation facility and would not conflict with the Statewide Transportation Improvement Program, the San Bernardino County Congestion Management Program, or the City of Redlands General Plan and mobility plans (Caltrans, 2023; SBAG, 2016; City of Redlands, 2014; 2017; 2021a). A Vehicle Miles Traveled (VMT) analysis is in preparation, and impacts are considered potentially significant pending its findings (CEQA Guidelines §15064.3, 2019). Driveways and access points would comply with City standards and Fire Code requirements (Amlegal.com, 2023; City of Redlands, 2021b), and encroachment permit requirements would ensure emergency access is maintained during construction (City of Redlands, 2021c). Therefore, impacts would be less than significant, except for VMT, which requires further analysis in this PEIR.

4.12.4.2 Analysis of Project Impacts
Threshold B: Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Significant and Unavoidable Impact
CEQA Guidelines § 15064.3(b) pertains to the use of Vehicle Miles Traveled (VMT) as a method of determining the significance of transportation impacts.

Section 15064.3, Determining the Significance of Transportation Impacts, of the CEQA Guidelines describes specific considerations for evaluating a project’s transportation impacts. Section 15064.3, subdivision (b) includes criteria for analyzing transportation impacts. For land use projects, “Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact.

Generally, projects within 0.5 miles of either an existing major transit stop or a stop along an existing high-quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact” (CEQA Guidelines § 15064.3).

Project Trip Generation
Project operation is estimated to generate 16,093 trips per day, as shown below in Table 4.12-1.  SECTION 4.12 – TRANSPORTATION 
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Table 4.12-1

ESTIMATED PROJECT TRIP GENERATION
Phase Land Use Trip Generation
Type Quantity Units Per unit Total
1 Medical Office Building 165 1,000 square feet 36 5,940 2 Hospital1 213 Beds 22.32 4,754
3 Medical Office Building 83 1,000 square feet 36 2,988 4 Hospital 108 Beds 22.32 2,411
Total Not applicable N/A N/A N/A 16,093 1 Phase 2 also includes a Central Utility Plant that would house hospital equipment and devices but would not generate trips additional to those estimated for other project land uses (Fehr & Peers, 2025, Appendix A, p. 6).

Source: Fehr & Peers 2025, Appendix A, p. 6
Travel Demand Model
VMT in the study area was modeled using the latest version of the San Bernardino Transportation Analysis Model, SBTAM+. SBTAM+ is a regional travel demand model that uses land use (such as employment, households) and roadway network information (such as number of lanes, speed limits, congestion) to predict vehicle travel patterns. The model was used to estimate future projections of vehicle travel, including traffic forecasts on roadways and estimates of Vehicle Miles Traveled (VMT).

The SBTAM+ Base Year model is validated to 2019 with a Future Year model of 2050 and is considered the most appropriate tool for testing changes in land use and roadway network in San Bernardino County. The project site was isolated into its own Traffic Analysis Zone (TAZ) so that the project VMT could be estimated while accounting for demographic characteristics consistent with the full buildout of the Kaiser expansion (Fehr & Peers, 2025, p. 29).

VMT Results
VMT was estimated in two scenarios: future year 2050 no project, and future year 2050 plus project.

VMT was estimated using the home-based work method that focuses on commute trips. Home-basedwork VMT is commute VMT, or home-to-work VMT. This is the travel between a person's home and workplace. This is used as it is consistent with the City's guidelines Project employment at Master Plan buildout is estimated at 1,900 (Fehr & Peers, 2025, p. 29). The City’s threshold for project VMT impacts is per capita VMT greater than 15 percent below the San Bernardino County Baseline VMT.

As shown below in Table 4.12-2, estimated project VMT per employee in 2050 is 22.7, that is, 12 percent higher than the City’s threshold.

Table 4.12-2

PROJECT-GENERATED VMT ESTIMATES
VMT Metrics for Non-Residential Projects Home-Based Work VMT per Employee Project VMT Estimates (2050) 22.8
San Bernardino County Baseline VMT (2050) 23.8
Threshold: 15% Below San Bernardino County Baseline VMT 20.2 Percent Higher than VMT Threshold 12%
VMT Exceeds Threshold? Yes
Source: Fehr & Peers, 2025
 SECTION 4.12 – TRANSPORTATION 
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Trip Length Reductions
Kaiser provided information showing that trip lengths for most Kaiser patients and employees would be reduced by use of the proposed Redlands facilities compared to trips to existing Kaiser facilities in the cities of Fontana and Ontario. Trip lengths would be reduced for 164,156 Kaiser members and would be lengthened for 69,788 members. For employees and physicians, average trip lengths to the expanded Redlands Campus would be shorter than current distances traveled to Fontana and Ontario Kaiser facilities (Fehr & Peers, 2025, p. 31).

4.12.5 Cumulative Impacts
The VMT analysis summarized above applies to cumulative as well as direct impacts (Fehr & Peers, 2025, p. 16).

Intersections of Proposed Driveways with Existing Roadways The Traffic Study also modeled the operation of intersections of proposed project site driveways with existing roadways. Intersection A, of the main project site entrance driveway with California Street, was modeled as being severely congested during both the a.m. and p.m. peak hours using cross-street stop control. Figure 2.3-5 in Section 2, Project Description, shows the main entrance driveway. The average delay per vehicle was modeled as over 100 seconds in each peak hour period. The Traffic Study recommends installation of a traffic signal; with a traffic signal, operation of that intersection would meet City of Redlands standards (Fehr & Peers, 2025, p. 41). The project includes installation of a traffic signal at that intersection. This content is informational, as intersection operation is no longer considered an impact under CEQA.

Project plans include a total of five access driveways into the project site, including two existing driveways; site access is described further in Section 2, Project Description.

4.12.6 Mitigation Measures
Impacts associated with significance threshold B would be potentially significant without mitigation.

Therefore, the following mitigation measures would be required to minimize potential impacts related to traffic and transportation.

MM TRANS-1 Prior to issuance of a certificate of occupancy for each phase of the project, the project proponent will implement a commute trip reduction program consisting of information sharing and marketing to promote and educate employees about their travel choices to the project site beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG emissions.

MM TRANS-2 Prior to issuance of a certificate of occupancy for each phase of the project, the project proponent will implement a ridesharing program for employees with similar commutes with funding requirements for employers. Ridesharing encourages carpooled vehicle trips in place of single-occupied vehicle trips, thereby reducing the number of trips, VMT, and GHG emissions. Existing programs including IE Commuter can be leveraged for this measure.

MM TRANS-3 Prior to issuance of a certificate of occupancy for each phase of the project, the project proponent will install and maintain end-of-trip facilities for employee use. End-of-trip facilities include bike parking, bike lockers, showers, and personal lockers. The  SECTION 4.12 – TRANSPORTATION 
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provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions.

MM TRANS-4 Prior to issuance of a certificate of occupancy for each phase of the project, the project proponent will implement an employer-sponsored vanpool service. Vanpooling is a flexible form of public transportation that provides groups of 5 to 15 people with a cost-effective and convenient rideshare option for commuting. The mode shift from long-distance, single-occupied vehicles to shared vehicles reduces overall commute VMT, thereby reducing GHG emissions. It was assumed that up to 2% of employees would participate in the vanpool program.

Estimate of Effectiveness of Mitigation Measures
The effectiveness of the mitigation measures was estimated as part of the project transportation study and is summarized below in Table 4.12-2.

Table 4.12-3

ESTIMATE OF EFFECTIVENESS OF MITIGATION MEASURES
Mitigation Measure Maximum VMT Reduction
TRANS-1: Commute Trip Reduction Marketing 4.0%
TRANS-2: Employee Rideshare Program 4.0%
TRANS-3: End-of-Trip Bicycle Facilities 0.3%
TRANS-4: Employer-Sponsored Vanpool 1.6%
Multiplicative Dampening: Adjustment to overall VMT reduction to account for overlap between measures
-0.6%
Total 9.9%
Source: Fehr & Peers, 2025

4.12.7 Level of Significance After Mitigation
Project VMT per employee is estimated to be 12 percent higher than the City of Redlands threshold.

The four mitigation measures for the VMT impact combined are estimated to reduce project VMT by

9.9 percent. Therefore, impacts associated with significance threshold B would be significant and unavoidable after implementation of mitigation measures TRANS-1 through TRANS-4. As a result, the City of Redlands will have to adopt a Statement of Overriding Considerations, pursuant to CEQA Guidelines Section 15093 prior to approving this project.  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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4.13 Tribal Cultural Resources

4.13.1 Introduction
This section addresses potential impacts to tribal cultural resources (TCRs). The evaluation of potential impacts to TCRs is based on both consultation and coordination with Native American tribes traditionally and culturally affiliated with the proposed project site as well as a Sacred Lands Files (SLF) records search conducted by the Native American Heritage Commission (NAHC).

Information in this section is also based in part on the Phase I Cultural Resources Inventory for the Kaiser Permanente Medical Center Project, City of Redlands, San Bernardino County, California, prepared by UltraSystems Environmental Inc. (UltraSystems, 2024), included as Appendix D1.

Tribal cultural resources are defined by the Public Resources Code (PRC) § 21074 as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either included or determined to be eligible for inclusion in the California Register of Historical Resources (CRHR) or included in a local register of historical resources, or a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant. A cultural landscape that meets these criteria is a TCR to the extent that the landscape is geographically defined in terms of the size and scope of the landscape. Historical resources, unique archaeological resources, or non-unique archaeological resources may also be TCRs if they meet these criteria.

4.13.2 Regulatory Framework
The treatment of TCRs is governed by state laws and guidelines. There are specific criteria for determining whether prehistoric sites or objects associated with TCRs are significant and thus protected by law. Some resources that do not meet archaeological cultural significance criteria may be considered significant by state criteria for TCRs. The laws and regulations seek to mitigate project impacts on significant TCRs.

Federal
National Native American Graves Protection and Reparation Act The Native American Graves Protection and Repatriation Act (NAGPRA) was passed in 1990 to provide for the protection of Native American graves. The act conveys to Native Americans of demonstrated lineal decent, the human remains, including the funerary or religious items, that are held by federal agencies and federally supported museums, or that have been recovered from federal lands. NAGPRA makes the sale or purchase of Native American remains illegal, whether or not they were derived from federal or Native American lands.

State
Unique Archaeological Resources under CEQA
CEQA requires the lead agency to consider whether the project will have a significant effect on unique archaeological resources and to avoid unique archaeological resources when feasible or mitigate any effects to less than significant levels per California Public Resources Code (PRC) § 21083.2. CEQA (PRC § 21083.2(g)) defines a unique archaeological resource as an archaeological artifact, object, or  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
1) Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information; 2) Has a special and particular quality such as being the oldest of its type or the best available example of its type;
3) Is directly associated with a scientifically recognized important prehistoric or historic event or person.

California Senate Bill 18 (Traditional Tribal Cultural Places) SB 18 requires local (city and county) governments to consult with California Native American tribes to aid in the protection of traditional tribal cultural places (“cultural places”) through local land use planning. SB 18 requires local governments to consult with tribes prior to making certain planning decisions and to provide notice to tribes at certain key points in the planning process. These consultation and notice requirements apply to adoption and amendment of both general plans (defined in Government Code §65300 et seq.) and specific plans (defined in Government Code §65450 et seq.). If a lead agency determines that a project may cause a substantial adverse change to tribal cultural resources, the lead agency must consider measures to mitigate that impact. Pub. Res.

Code § 20184.3 (b)(2) provides examples of mitigation measures that lead agencies may consider to avoid or minimize impacts to tribal cultural resources. These examples include avoidance and preservation of the resources in place, treating the resource with culturally appropriate dignity, or permanent conservation easements or other interests in real property.

Human Remains
Section 15064.5 of the State CEQA Guidelines specifies procedures to be used when Native American remains are discovered. These procedures are discussed within PRC § 5097, as well as in the California Health and Safety Code § 7050.5.

California Public Resources Code 5097.98
Public Resources Code § 5097.98 addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American skeletal remains are discovered during construction of a project; and establishes the NAHC to resolve disputes regarding the disposition of such remains. It has been incorporated into § 15064.5(e) of the State CEQA Guidelines.

California Health and Safety Code
The California Health and Safety Code § 7050.5 states that if human remains are discovered during construction on a project site, no further disturbance shall occur until a county coroner makes a determination of origin and disposition of the remains. If the county coroner determines the remains are not subject to his or her authority and recognizes the remains to be those of Native American, the county coroner must contact the NAHC within 24 hours.
 SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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Local
There are no local regulations that pertain to the issue of Native American involvement.

4.13.3 Methodology

4.13.3.1 Ethnographic Record Review
This material presented below is the result of ethnographic research prepared for the Phase I Cultural Resources Inventory conducted for the proposed project (refer to Appendix D1 to this PEIR).

Gabrielino/Tongva
Prior to European contact, the indigenous peoples who resided in modern-day San Bernardino County were the Tongva (Gabrielino), and Taaqtam (Serrano) peoples who lived in the San Bernardino Valley and the San Bernardino Mountains. Bean and Smith and Johnston indicate that “…the historic-era border between the Gabrielino and Serrano at San Bernardino [town]. It is likely that both groups used the territories within the project area during the sixteenth to nineteenth centuries….”
The project lies within the territory of the Gabrielino (Tongva) ethnolinguistic group (Bean and Smith, 1978a:538), who speak a language classified as a member of the Uto-Aztecan language family.

This language is further affiliated as an element of the Northern Takic Branch of that linguistic group.

The Gabrielino, with the Chumash, were considered the most populous, wealthiest, and therefore most powerful ethnic nationalities in aboriginal Southern California. Unfortunately, most Gabrielino cultural practices had declined before systematic ethnographic studies were instituted. Today, the leading sources on Gabrielino culture are Bean and Smith, Johnston, and McCawley.

By the time of European contact, the Gabrielino territory included the southern Channel Islands and the entire Los Angeles Basin. Their territory reached to the west along the Pacific Coast to Malibu, north and east to the foothills of the San Gabriel Mountains, to the southeast into the present-day San Bernardino-Riverside area and south to the San Joaquin Hills in central Orange County.

Different groups of Gabrielino adopted several subsistence strategies, based on gathering, hunting, and fishing. Because of the similarities to other Southern California tribes in economic activities, inland Gabrielino groups' industrial arts, exemplified by basket weaving, exhibited an affinity with those of their neighbors. Coastal Gabrielino material culture, on the other hand, reflected an elaborately developed artisanship most recognized through the medium of steatite, which was rivaled by few other groups in Southern California.

The intricacies of Gabrielino social organization are not well known. There appeared to have been at least three hierarchically ordered social classes, topped with an elite consisting of the chiefs, their immediate families, and other ceremonial specialists. Clans owned land, and property boundaries were marked by the clan's personalized symbol. Villages were politically autonomous, composed of non-localized lineages, each with its own leader. The dominant lineage's leader was usually the  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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village chief, whose office was generally hereditary through the male line. Occasionally several villages were allied under the leadership of a single chief. The villages frequently engaged in warfare against one another, resulting in what some consider to be a state of constant enmity between coastal and inland groups.

Therefore, this portion of the territory was not as densely populated as the coastal territory.

The San Bernardino Valley contains the northeastern region of Gabrielino territory, with upwards of eight major communities located throughout. The village of Wa’aachnga, also spelled Kaawchama, was somewhat west of Redlands. It is also the site of the San Bernardino Asistencia of Mission San Gabriel built in 1820 in what was later called Old San Bernardino. Somewhat to the southwest of Redlands, southeast of Colton between the southerly bank of the Santa Ana River and the base of the foothills” was the native community of Homhoa. Both of these villages were located either along the Santa Ana River (Wa’aachnga) or a tributary to it (Homhoa). In the late Mission Period or just thereafter, much of the region was populated by the Serrano, who migrated into the area following the removal of the Gabrielino to Mission San Gabriel.

The first Franciscan establishment in Gabrielino territory and the broader region was Mission San Gabriel, founded in A.D. 1772. Priests from the mission proselytized the Tongva throughout the Los Angeles Basin. As early as 1542, however, the Gabrielino were in peripheral contact with the Spanish even during the historic expedition of Juan Rodríguez Cabrillo. However, it was not until 1769 that the Spaniards took steps to colonize the territory of aboriginal Californians. Within a few decades, most of the Gabrielino were incorporated into Mission San Gabriel and other missions in Southern California. Due to introduced diseases, dietary deficiencies, and forceful reducción (removal of non-agrarian Native populations to the mission compound), Gabrielino population dwindled rapidly from these impacts. By 1900, the Gabrielino community had almost ceased to exist as a culturally identifiable group. In the late 20th century, however, a renaissance of Native American activism and cultural revitalization of Gabrielino descendants took place. Among the results of this movement has been a return to a traditional name for the tribe, the Tongva, which is employed by several of the bands and organizations representing tribal members. Many of the Tongva bands focus on maintaining and teaching traditional knowledge, with special emphasis on language, place names and natural resources, and preservation of ancestral sites.

Serrano
The City of Redlands is situated within the southeastern periphery of the Serrano culture area. The Recent research by Earle, King, and Johnson and Lorenz have helped to clarify the ethnic identification of the San Gabriel/San Bernardino mountains and Mojave Desert Native American groups. Their work with the John Peabody Harrington notes, combined with analysis of the Franciscan sacramental registries, confirm ethnographic records that the inhabitants of the project area were speakers of a dialect of Serrano. It has been determined that Native groups occupying villages in the San Bernardino Mountains and adjacent Moreno Valley region maintained marriage ties to surrounding region and the foothills extending into the San Bernardino and San Jacinto Valleys inhabited by Cahuilla and Luiseno were also Serrano in ethnic and linguistic affiliation.  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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Earle supports King’s revisions of earlier territorial boundaries asserting that Serrano territory included the San Bernardino Mountains and the northern slopes of the San Gabriel Mountains, the Mojave River, and Antelope Valley. It also appears from their research that both the south and north slopes of the San Gabriel Mountains were “owned” and occupied by Serrano speakers.

Early 20th century ethnographic fieldwork among the Serrano was conducted by Kroeber, Gifford, Strong, Benedict, and Harrington. More recent research by Bean, Bean and Smith, and Bean, et al. has helped to focus attention on key research questions in an attempt to clarify the relationship of Serrano land use patterns, territorial attributions, subsistence-settlement patterns, and social, ceremonial, and political organization.

The economic resource base of the Serrano was determined in part by the seasonal availability of key animals and plants exploited for basic subsistence. Hunting activities supplemented a diet mainly emphasizing plants. Hunting excursions were usually an individual affair but also sometimes incorporated communal drives, and trap lines to snare small animals (e.g., rabbits, squirrels and rodents). Some desert hunting areas to the north in the Mojave Desert and in the vicinity of the Mojave River may have been shared with adjacent groups (e.g., Chemehuevi and/or Mojave).

Mule deer were available in the San Gabriel Mountains. Deer would migrate to lower elevations during the winter and would be available in the lower foothill region at that time. Pronghorn frequented the valley floors year-round but were not consistently abundant and were hunted only occasionally using communal surrounds and group drives. The latter communal drive technique was also used to ensnare large numbers of jackrabbits during the fall when the rabbits were especially abundant. Mountain sheep were available in the higher mountains but would only have been rarely procured. Waterfowl could be captured using bows and arrows and special nets. Ducks, quail, geese, and grebes would have been available in considerable numbers during their breeding seasons and in association with riparian settings.

Abundant stands of acorns, juniper, mesquite, and piñon were available to extended gathering expeditions into the mountains. These might involve several lineages collaborating under one leader’s authority and would have entailed accessing the resource base of surrounding groups. Cattail / bulrush seeds (Typha spp. and Scirpus spp.), various roots, shoots, bulbs, and other hard seeds were all principal plant foods. The most likely plant resources that were of significant economic importance that have been identified paleobotantically or noted in the immediate vicinity of the Project were grasses (Poa ssp.), chia (Salvia columbariae), and goosefoot (Chenopodium spp.).

Edward W. Gifford conducted a detailed study of the marriage practices and sociopolitical organization of native southern California Native Americans during from 1916 through 1917. Based  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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on these studies, he developed a model of Serrano social organization. William Duncan Strong conducted additional extensive social organization studies among the Serrano, Cahuilla, Luiseño, and Cupeño in 1925. Strong indicated that the Serrano were an unusual California group in that they possessed true patrilineal clans. Patrilineal clans are patterned such that all males, their descendants, and their wives were part of a single group. Clans may be segmented into subclans or lineages. A woman retained her own lineage name but upon marriage was incorporated into the clan of her husband. The transfer of women from one ceremonial affiliation with one clan to another, upon marriage, was characteristic of all southern California Takic (a linguistic subfamily of Northern UtoAztecan) groups. The Serrano maintained an active moiety system -- their society was divided into two parts identified with either Coyote or Wildcat. The Coyote moiety had the most important political leaders. Moiety out-marriage excluded partners from half the neighboring Serrano settlements. Hence, only settlements of opposing moieties were interrelated through marriage.

Serrano villages in the mountain settings were generally less dispersed than in the desert. This nearer pattern resulted in marriages linking together very large areas. Many of the settlements had marriage ties with villages 10 - 20 miles away and counter intuitive was the fact that the closest relationships were not with the nearest villages – but rather with settlements affiliated with opposing moieties further distant.

Ethnographic data attests that a major native trade and travel corridor facilitated a long-distance exchange system. Recent research has supported the importance of long distance trade linking coastal southern Californian Tongva clans/villages with inland groups including the coastal Tongva and Luiseño/Acjachemen tribes in a route along the Santa Ana River. Shell bead trade was one of the mediums of exchange and was used as a kind of currency or money. This system was significant since it involved trade, travel, and exchange covering hundreds of miles and was a system of exchange of native goods that linked various ethnic groups politically and economically.

This trade and travel route ran from the American Southwest (principally the Hopi territory in Arizona), along the Colorado River to the Mojave River thence through the central Mojave Desert into the Antelope Valley and west to the Pacific Coast. These circuits of exchange cut across political and cultural boundaries. A number of researchers have argued that such an exchange system may have been an influential factor in facilitating semi-sedentary settlement and complex sociopolitical organization for the Serrano.

Nearby Serrano habitations in the foothills above the San Jacinto Valley, are recorded by Strong at yūhavetam, above Highland and upwards from there into the San Bernardino Mountains’ foothills, wa’atcem, in the mountains foothills between the Santa Ana River and Mill Creek, yucaipaīem,  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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Yucaipa Valley, and the Marina clan at yumisēval, along upper Mission Creek above the San Gorgonio Pass. These are all noted as occupied by members of Coyote moiety clans.

In 1770, the Gaspar de Portolá Expedition passed along the Southern California coast to the west through Luiseño territory, while the de Anza expeditions of 1774 and 1776 took a route through the San Jacinto Valley bordering Serrano territory. During the next two decades several missions were established in the region and made contact with the Serrano. Natives were recruited to these missions that included San Gabriel, San Luis Rey, and San Fernando. Kroeber estimated only 1,500 people for the total population; Bean and Smith, however, did not speculate on the population. Upon contact, European interactions and introduced diseases led to dramatic population declines.

Eventually, a reservation system was developed, and members of the Serrano tribe are currently enrolled in the San Manuel Band of Mission Indians (now the Yahaaviatam of San Manuel) located adjacent to the town of Highland; 5.5 miles to the northwest of the project, and with members of the Cahuilla tribe at Morongo Band of Mission Indians (adjacent to and east of Banning 28 miles to the east of the project). These two groups are federally recognized. There is also one non-federally recognized Serrano band, the Serrano Nation of Mission Indians.

Phase I Cultural Resources Inventory for Project
Information in this section is drawn from the Phase I Cultural Resources Inventory conducted for the proposed project (refer to Appendix D1 to this Draft PEIR). The cultural resources survey and related archival research included a background archaeological records check (archival research) at the local California Historic Resources Information System (CHRIS) facility, the South Central Coastal Information Center (SCCIC) at California State University, Fullerton, a SLF search request to the NAHC, and the list of local Native American entities to contact from the NAHC. The field survey conducted for this project observed no prehistoric or historic artifacts or features. The potential for subsurface cultural and or historical deposits is minimal based on the findings from these sources.

Records Review
Sacred Lands File Review
The NAHC maintains a confidential SLF that contains sites of traditional, cultural, or religious value to the Native American community. On July 8, 2023, Megan Doukakis, Assistant Project Archaeologist, submitted a request to the NAHC via email for a SLF search within the 0.5-mile project buffer. The results of the search request were received July 13, 2024, at the office of UltraSystems from Ms.

Cameron Vela, Cultural Resources Analyst. The NAHC letter stated that “A record search of the NAHC Sacred Lands File was completed for the area of potential effect (APE) referenced above with positive results [emphasis in the original].” None of the Tribal Outreach responding tribes noted this SLF site.

California Historical Resources Information System Review The cultural resources records search was conducted on June 22, 2023 by Ms. Doukakis (refer to Attachment D in Appendix D1). The purpose of the records search was to identify previously recorded cultural resources (prehistoric and historic archaeological sites, historic buildings, structures, objects, or districts) within the project area and a half-mile radius. The records search included a review of previously recorded prehistoric and historic archaeological sites within the project area and a 0.5-mile buffer, and a review of prior cultural resource surveys and/or excavation reports within that same geographical area. (See Section 4.1.1 in Appendix D1 for references.)  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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The CHRIS record search indicated that there were no prehistoric archaeological sites identified within the project boundary or within the 0.5-mile buffer zone. Two historic era cultural resources have been previously recorded within the project site boundary. Within the 0.5-mile buffer zone there are an additional six recorded historic era cultural resources.

Previously Conducted Cultural Resources Studies
Seventeen previous cultural resources surveys identified in the CHRIS records search included a portion of the half-mile buffer zone. Two of these included the project boundary.

The current project parcel was originally surveyed by Michael K. Lerch & Associates in 1992 consisting of 35 acres for the approved Kaiser Medical Center, part of a larger planned development of the Barton Center of Redlands, a 306-acre subdivision (SB-2625). No prehistoric resources and a single historical resource were discovered during this investigation, being the Marigold Farms buildings. They recorded the Marigold Farms complex and its milking barn (CA-SBR-7139H). The report concluded that the site record produced mitigated potential impacts of development to the farm.

In 2006, W&S Consultants undertook an archaeological survey of the Kaiser Redlands medical office building project site that encompasses the same footprint as the current project (SB-4809). At that time, the archival research showed the prior presence of two historic sites related to the Marigold Farms that had been present in the northeast corner of the project parcel and that they had subsequently been demolished. These were the concrete milk barn (CA-SBR-6857) and a portion of the Marigold Farms complex (CA-SBR-7139H).

Marigold Farms (CA-SBr-7139H) and its associated barn (CA-SBr-6857H) were located adjacent to the current project site and possibly had features within the extreme northeast corner of the current project at the intersection of Almond Avenue and California Street. However, all related structures have been demolished through construction of commercial development and road construction.

Adjacent surveys consisted of the Inland Feeder project for the Metropolitan Water District of Southern California (SB-2853) that surveyed a water utility line along California Street; a cultural resources survey for a development (SB-4600) across the northeast corner from the project suite at California Street and Almond Avenue; SB-8038, a paleontological assessment of a parcel that would be developed for the Hillwood Commercial Center on the east side of California Street from the project area, and finally there is a report documenting monitoring during ground disturbing activities for the construction of the Redlands Commercial Center buildings (SB-8199) immediately south of the project site on the south side of Lugonia Avenue.

Pedestrian Survey
On November 6, 2024, an intensive pedestrian cultural resources survey was undertaken by Stephen O’Neil, M.A., RPA, who qualifies as a Principal Prehistoric Archaeologist and Historic Archaeologist per United States Secretary of the Interior Standards, with Mr. Rodrigo Jacobo M.A.  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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Survey transects were conducted by walking north/south transects at 15 meter intervals. The pedestrian survey observed no prehistoric or historic artifacts or features.

Native American Outreach
In relation to the Phase I Cultural Resources Inventory Report, June 8, 2023, Ms. Doukakis contacted the NAHC via email notifying them of the project, requesting a search of their SLF and asking for a list of local tribal organizations and individuals to contact for project outreach. The results of the search request were received July 13, 2023 from Mr. Cameron Vela, Cultural Resources Analyst with tribal contacts for outreach purposes (refer to Attachment C in Appendix F) On October 3, 2023, UEI sent letters and emails to each of the 38 tribal contacts describing the project and a map showing the project's location, requesting a reply if they have knowledge of cultural resources in the area, and asking if they had any questions or concerns regarding the project.

Eight email responses were received:
• The Gabrieleno Band of Mission Indians – Kizh Nation Administration responded on behalf of Chairperson Andrew Salas and Christina Swindell Martinez, Secretary on October 3, 2023 requesting the lead agency’s contact information. That information was provided by Ms.

Doukakis on October 4, 2023.
• Christina Conley, Cultural Resource Administrator for the Gabrielino Tongva Indians of California Tribal Council on behalf of Chairperson Robert Dorame responded on October 3, 2023, indicating that the project would need to have a Native American monitor and suggested calling Sandonne Goad, Chairperson of the Gabrielino/Tongva Nation for this area. • Chairperson Charles Alvarez of the Gabrielino-Tongva Tribe on behalf of San Dunlap, Cultural Resources Director, responded on October 4, 2023, stating that the tribe would look into this matter and respond accordingly. Consultation was concluded and no further tribal responses were received.
• Paul Macarro, Cultural Resources Coordinator for the Pechanga Band of Indians on behalf of Chairperson Mark Macarro responded on October 3, 2023 indicating that the project area is outside the ancestral lands of their tribe and the tribe will defer to the appropriate tribes. • Xitaley Madrigal, Cultural Resources Analyst for the Agua Caliente Band of Cahuilla Indians (ACBCI) on behalf of Chairperson Reid Milanovich and Director Patricia Garcia-Plotkin responded on October 11, 2023 indicating that the project area is not located within the boundaries of the ACBCI reservation but it is within the Tribe’s Traditional Use Area and recommends a cultural resources inventory of the project area, documentation of CHRIS cultural resources, a copy of the records received on the project, the presence of cultural resource monitors if any ground disturbance takes place, including a Secretary of the Interior-qualified archeologist. Mr. O’Neil responded to Ms. Madrigal, stating that a cultural resources inventory report would be completed and could be requested from the City of Redlands when completed. As for the other requests recommended, Mr. O’Neil stated that they are best made to the City of Redlands during AB 52 consultation. • Ana Rios, Administrative Assistant for the Augustine Band of Cahuilla Mission Indians sent an email response on October 9, 2023 on behalf of Chairperson Amanda Vance; an attached  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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letter from Tribal Secretary Geramy Martin indicated that the tribe is unaware of specific cultural resources that may be affected by the proposed project; however, in the event that resources are encountered during the development of this project the tribe asks to be contacted. Mr. O’Neil responded to Ms. Rios, stating that a cultural resources inventory report would be completed and could be requested from the City of Redlands when completed as part of the outreach process; Mr. O’Neil also stated that the City of Redlands, per AB 52, would conduct consultation and the tribe could make any recommendations then. • Alexandra McCleary, Cultural Lands Manager for the San Manuel Band of Mission Indians responded on November 2, 2023 indicating that the proposed project site is considered sensitive by the Tribe, as it is close to the historic footprint of the Mill Creek Zanja, a historic waterway listed on the National Register which had been built using Serrano labor; there was no specific mention of a Sacred Lands File site. The tribe would like to engage in governmentto-government consultation pursuant to AB 52 with the Lead Agency for the project; Mr.

Following up on the initial letter and email contacts, telephone calls were conducted by Ms. Doukakis on November 3, 2023 and November 6, 2023, to complete the outreach process. These calls were to the 20 tribal contacts (representing eight additional tribes) who had not already responded to UEI’s mailings and emails. Nine telephone calls were placed with no answer and messages were left describing the project and requesting a response. These were to Doug Welmas, Chairperson of the Cabazon Band of Mission Indians; Sandonne Goad, Chairperson of the Gabrielino-Tongva Nation; Robert Martin, Chairperson of the Morongo Band of Mission Indians, to Ann Brierty, Tribal Historic Preservation Officer of the Morongo Band of Mission Indians; Shasta Gaughen, THPO of the Pala Band of Mission Indians, to Alexis Wallick, Assistant Tribal Historic Preservation Officer of the Pala Band of Mission Indians; Wayne Walker, Co-Chairperson of the Serrano Nation of Mission Indians; the Cultural Committee for the Torres-Martinez Desert Cahuilla Indians; and to BobbyRay Esparza, Cultural Director of the Cahuilla Band of Indians.
• In the call to Chairperson Daniel Salgado, and Tribal Historic Preservation Officer Anthony Madrigal, of the Cahuilla Band of Indians the tribal receptionist indicated that Chairperson Salgado and Mr. Madrigal were not in the office and to leave a message on Mr. Esparza’s voicemail which was done.
• In the call to John Gomez, Environmental Coordinator for the Ramona Band of Cahuilla Indians on behalf of Chairperson Joseph Hamilton, the tribal receptionist indicated that Mr.

Gomez was in the field and provided his cell phone number; that number was called -- there was no answer and a message was left.
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• In the call to Lovina Redner, Tribal Chair for the Santa Rosa Band of Cahuilla Indians, the tribal receptionist indicated that Ms. Redner was not in the office at the time and asked that UEI leave our call back number which was done.
• In the call to Mark Cochrane, Co-Chairperson of the Serrano Nation of Mission Indians, the phone line was disconnected, and no message could be left. There has been no response to date for any of these calls.
• During the call to Anthony Morales, Chairperson of the Gabrieleno-Tongva San Gabriel Band of Missions Indians, he indicated that he does not have any specific concerns but there are known archaeological sites in the area and freeways like the I-10 that would have been used for traditional transportation routes. Chairperson Morales recommended Native American and archaeological monitoring and would like his tribe to be involved. • In the call to Manfred Scott, Acting Chairman for the Quechan Tribe of the Fort Yuma Reservation on behalf of President Jordan Joaquin, and Jill McCormick, Historic Preservation Officer indicated that the tribe will defer to more local tribes. • In the call to Joseph Ontiveros, Cultural Resource Department for the Soboba Band of Luiseño Indians on behalf of Chairperson Isaiah Vivanco indicated that this area is of moderate concern for the tribe and further information will be provided to the lead agency during AB 52 consultation.
• In the call to Dorothy Willis with the EPA Department for the Los Coyotes Band of Cahuilla and Cupeño Indians on behalf of Chairperson Ray Chapparosa, indicated that she was on the other line and to email her our question. This email was sent November 6, 2023. • In the call to Cheryl Madrigal, Tribal Historic Preservation Officer of the Rincon Band of Luiseño Indians representing Tribal Council Member Joseph Linton, Tribal Council Member Laurie Gonzalez, and Attorney General Denise Turner Walsh, Ms. Madrigal indicated that she will take a look at our email and get back to us with a response.

A phone call was received from Deneen Pelton, Cultural Resources Coordinator with the Rincon Band, on the same day indicating that they sent an email response for this project on October 27, 2023. Ms.

Pelton provided the email response, and it indicated that the project location is not within the Band’s specific Area of Historic Interest (AHI) and the tribe has no additional information to provide; Ms.

Pelton recommended that we directly contact a Tribe that is closer to the project and may have pertinent information. (See Attachment C.) There have been no further responses from these tribes to date.

Tribal Consultation under SB 18
In compliance with SB 18, the City of Redlands (the lead agency) has initiated outreach to local tribes for the Kaiser Permanente Medical Center Project. Consultation invitations were sent to the participating tribes through email and certified mail informing them of the project on February 23, 2023 and March 8, 2023. In accordance with SB 18, the tribe has 90 days in which to respond and request opening consultation, unless a shorter timeframe has been agreed to by the tribe.

The tribes contacted on February 23, 2023 included:
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• Agua Caliente Band of Cahuilla
• Augustine Band of Cahuilla Mission
Indians
• Cabazon Band of Mission Indians
• Cahuilla Band of Indians
• Gabrieleño Band of Mission Indians –
Kizh Nation
• Los Coyotes Band of Cahuilla and
Cupeño Indians
• Morongo Band of Mission
• Pala Band of Mission Indians
• Pechenga Band of Indians
• Quechan Tribe of Ft. Yuma Reservation
• Ramona Band of Cahuilla
• Rincon Band of Luiseño Indians
• Rincon Band of Luiseño Indians
• San Manuel Band of Mission
• Santa Rosa Band of Cahuilla
• Serrano Nation of Mission
• Soboba Band of Luiseño
• Torres Martinez Desert Cahuilla
The tribes contacted on March 8, 2023 included:
• Chemehuevi Indian Tribe
• Colorado River Indian Tribes
• Fernandeño Tataviam Band of Mission
Indians
• Fort Mojave Indian Tribe
• Gabrieleno/Tongva San Gabriel Band of
Mission Indians
• Gabrielino/Tongva Nation
• Gabrielino Tongva Indians of California
Tribal Council
• Gabrielino-Tongva Tribe
• Juaneno Band of Mission Indians
• Acjachemen Nation - Belardes
• Juaneno Band of Mission Indians
• Acjachemen Nation 84A
• Kern Valley Indian Community
• Pechanga Band of Indians
• Quechan Tribe of the Fort Yuma
Reservation
• Ramona Band of Cahuilla
• Twenty-Nine Palms Band of Mission
Six responses have been received to date. Five of these responses indicated that the tribes were not concerned about the project and not interested in participating in consultation. These tribes included the Agua Caliente Band of Cahuilla Indians, Augustine Band of Cahuilla Indians, Fernandeño Tataviam Band of Mission Indians. Rincon Band of Luiseño Indians, and Yuhaaviatam of San Manuel Nation.

The Yuhaaviatam of San Manuel Nation also provided a set of recommended Mitigation Measures.

The first measure describes that the tribe would like to be contacted if any pre-contact and/or historic-era cultural resources are discovered during the project. The second requests that all archaeological/cultural documents be provided to the tribe. No formal consultation request was received from the Yuhaaviatam of San Manuel Nation, so no agreement was made to include their proposed Mitigation Measures.

Consultation with Gabrieleño Band of Mission Indians –Kizh Nation In a response received from the Gabrieleño Band of Mission Indians – Kizh Nation, the tribe indicated that the proposed project location is within the tribe’s Ancestral Tribal Territory and requests consultation with the lead agency. Consultation took place over the phone on June 15, 2023. A follow up email was sent  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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by Mr. Beery to Mr. Salas providing grading plans for the project. The Admin Specialist for the tribe indicated through email that the tribe will review the grading plan and get back to Mr. Beery. Brandy Salas, Admin Specialist indicated through email that the tribe would like to consult on the project and set up a meeting time. Mr. Beery responded with multiple meeting dates and times in which he is available.

Ms. Salas responded that the Chairman’s schedule is fully booked until December 12, 2023 at 1pm. (K.

Beery to S. O’Neil, personal communication; November 7, 2023.) The Admin Specialist for the tribe provided an email response in lieu of an in person meeting on October 16, 2023. Six documents from William McCawley’s The First Angelinos (1996) text involving descriptions of the area of Redlands and the Gabrieleno community of Kaawchama were provided. A passage from California's Gabrielino Indians by Bernice Eastman Johnston (1962) was provided concerning villages in Redlands. Two maps were provided, one is a 1938 map with a current map overlayed showing the project area and Native American villages, travel routes and waterways. The village of Kaawchama is shown to be located a short distance to the north of the project area. The second map is a current map with Mexican Rancho boundaries outlined. The project area sits within the Rancho San Bernardino. Lastly, a set of Mitigation Measures were provided. Consultation with the Gabrieleño Band of Mission Indians – Kizh Nation was concluded on April 10, 2025 and the City agreed to recommend inclusion of their proposed mitigation measures in the Draft PEIR. These measures are included below.

4.13.4 Existing Conditions
Redlands is located in the southwest portion of the San Bernardino Valley. This is a broad inland valley defined by the San Gabriel and San Bernardino Mountain Ranges to the north and is ringed by a series of low rocky hills to the south. The region’s environment is characterized by a temperate Mediterranean climate, with the average maximum temperature in July reaching 89 degrees Fahrenheit (°F) and the average minimum temperature in January at around 42°F. Rainfall is typically less than 15 inches annually, most of which occurs between November and March.

The project area is specifically located at 1301 California Street at the northwest corner of California Street and Lugonia Avenue and 0.25 mile north of the I-10 Freeway in the city of Redlands. This may be seen on the Redlands, Calif., USGS topographical quadrangle, Range 03 West, Township 01 South, in the SE ¼ of the NE ¼ of Section 19. The project area is surrounded by industrial uses to the east, north, and west, and by industrial and the former site of a water park, now under construction with a warehouse structure, to the south.

4.13.5 Environmental Impact Analysis

4.13.5.1 Thresholds of Significance
Pursuant to State CEQA Guidelines Appendix G, the project is assessed under the following significance thresholds:

A. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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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:
(iii) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code § 5020.1(k); or
(iv) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resource Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

4.13.5.2 Analysis of Project Impacts
Threshold A: Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape 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:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code § 5020.1(k); or
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resource Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

Less Than Significant with Mitigation Incorporated
Previous cultural resources surveys within the 0.5-mile buffer zone resulted in two historic archaeological sites that have been previously recorded within the project site boundary and an additional eight archaeological sites within the surrounding 0.5-mile buffer. No prehistoric resources were recorded within the project boundary or the 0.5-mile buffer area. (refer to Sections 4.1 and 4.3 in Appendix D1). The NAHC’s SLF search had a positive response for a traditional resource in the project area. A pedestrian survey conducted resulted in no prehistoric or historic features or isolate artifacts being observed, although given the extremely poor surface visibility it cannot be ruled out that cultural resources may be present.

A prior survey of the property resulted in negative findings for prehistoric resources. However given that the prior agricultural use within the project might have masked archaeological deposits, the close proximity of fresh water source (the Santa Ana River) which would have been attractive to Native American use, that one of the contacted tribes did recommend tribal and archaeological monitoring based on the historic presence of local indigenous people along the nearby Santa Ana River, the presence of an adjacent associated farm complex dating back to approximately 1915, and that the present vegetation coverage did not allow for full observation of the project area ground  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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surface, there is the potential that buried archaeological deposits may be present within the project boundary. Therefore, it is recommended that an archaeological monitor be present during grounddisturbing activities as presented in MM TCR-1. If prehistoric and/or historic items are observed during subsurface activities, work should be stopped in that area and a qualified archaeologist and Native American monitor be retained to assess the finding(s) and retrieve the material. See MMs TCR-2 and TCR-3.

Based on the Phase I Cultural Resources Inventory report (Appendix D1) which includes a records search at the SCCIC of survey reports and site records, the results of an SLF search by the NAHC, and outreach to locally affiliated bands suggested by the NAHC, it was determined that the probability for significant impacts to TCRs is high at the project site.

4.13.6 Cumulative Impacts
TCRs have not been identified within the project site and within the vicinity of the project site.

However, each related project would be required to comply with the applicable laws and regulations regarding TCRs, as detailed in the Regulatory Framework in Section 4.4.2. Additionally, related projects would be required to comply with the consultation requirements of SB 18 and AB 52 to determine and mitigate any potential impacts to TCRs. Thus, cumulative impacts to tribal cultural resources would be less than significant and impacts of the proposed project would not be cumulatively considerable.

4.13.7 Mitigation Measures
Although no information or evidence has been presented to the City demonstrating any potentially significant impacts to any known or likely TCRs on the project site or in close proximity to the project site, the City has agreed to implement the following mitigation measures in the event of any inadvertent discoveries of TCRs.

MM-TCR-1: Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities

1. The project applicant shall retain a Native American Monitor(s) from one or more Consulting Tribe(s). Monitors from more than one tribe may coordinate and utilize a rotating schedule at their discretion.. The monitor(s) shall be retained prior to the commencement of any “ground-disturbing activity” for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Grounddisturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

2. A copy of the executed monitoring agreement with each monitoring Consulting Tribe(s) shall be submitted to the lead agency prior to the earlier of the commencement of any grounddisturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

3. The monitor(s) will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and  SECTION 4.13 – TRIBAL CULTURAL RESOURCES 
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describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency upon written request to the Tribe.

4. On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Consulting Tribe(s) from a designated point of contact for the project applicant that all ground-disturbing activities and phases that may involve ground-disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Consulting Tribe(s)to the project applicant and lead agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact TCRs.

MM-TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/NonCeremonial) A. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e. not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Consulting Tribe(s)’ monitor(s) and/or archaeologist(s).

MM-TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects
A. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.

B. If Native American human remains and/or grave goods are discovered or recognized on the project site, then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed.

C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

D. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

E. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

4.13.8 Level of Significance after Mitigation
Compliance with MM-TCR-1, MM-TCR-2 and MM-TCR-3 would ensure that previously unknown tribal cultural resources and archaeological or historical artifacts are protected, evaluated, and recovered as determined by the appropriately qualified Native American representative and cultural resources expert. Implementation of these mitigation measures, in addition to adherence with applicable federal, state, and county regulations would reduce potential project impacts on tribal cultural resources to less than significant level after mitigation.  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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4.14 Utilities and Service Systems

4.14.1 Introduction
This section of the PEIR is focused on water supplies, water infrastructure, and wastewater treatment facilities, because the Initial Study identified those issues (thresholds a and b under CEQA Guidelines Appendix G for Utilities and Service Systems) as having the potential for significant impacts requiring further analysis. In contrast, the Initial Study determined that impacts related to telecommunications, drainage, and solid waste disposal would be less than significant.

Regarding solid waste, the Initial Study mistakenly described all City of Redlands waste as disposed of at the California Street Landfill. Updated CalRecycle (2023) disposal data show that approximately 93 percent of the City’s waste is disposed of at two facilities—the California Street Landfill and the San Timoteo Sanitary Landfill. This correction does not alter the Initial Study’s conclusion that adequate landfill capacity exists and that project impacts on solid waste disposal would remain less than significant.

The existing setting for solid waste disposal is described in Section 4.14.3, Existing Conditions. The significance conclusion of the impact is not changed from the less than significant finding identified in the Initial Study. Therefore, this impact is not analyzed in this DEIR.

Because the Initial Study provided a sufficient evidentiary basis to conclude that impacts on telecommunications, drainage, and solid waste would be less than significant, these topics do not require further analysis in this PEIR. Instead, the PEIR appropriately focuses on water supply, water infrastructure, and wastewater treatment capacity, which warrants detailed study. The impacts on electricity and natural gas supplies and consumption are addressed in Section 4.5 of this DEIR.

4.14.2 Regulatory Framework
Water Supplies
State
Senate Bill 610 (California Water Code §§ 10910 et seq.) Senate Bill (SB) 610, codified in the California Water Code, §§ 10910 et seq., became effective January 1, 2002. SB 610 requires counties and cities to consider the availability of adequate water supplies for certain new large development projects as part of the California Environmental Quality Act (CEQA) process.

Specifically, SB 610 requires that for certain projects subject to CEQA, the urban water supplier prepares a Water Supply Assessment (WSA) that determines whether the projected water demand associated with a project is included as part of the most recently adopted Urban Water Management Plan (UWMP).

Specifically, a WSA shall identify existing water supply entitlements, water rights, or water service contracts held by the public water system and prior years' water deliveries received by the public water system. In addition, it must address water supplies over a 20-year future period and consider average, single-dry, and multiple-dry years. In accordance with § 10912 of the California Water Code, projects subject to CEQA requiring submittal of a WSA include the following:
• Residential developments of more than 500 dwelling units; • Shopping center or business establishment employing more than 1,000 persons or having  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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more than 500,000 square feet of floor space;
• Commercial office buildings employing more than 1,000 persons or having more than 250,000 square feet of floor space;
• Hotels and motels, or both, having more than 500 rooms; • Industrial, manufacturing, or processing plant, or industrial park of more than 40 acres of land, more than 650,000 square feet of floor area, or employing more than 1,000 persons; • Mixed-use projects that include one or more of the above-identified categories; or • A project that would require an amount of water equivalent to or greater than the amount of water required by a 500-unit project.

The WSA must be approved by the public water system at a regular or special meeting and must be incorporated into the CEQA document. The lead agency must then make certain findings related to water supply based on the WSA. For this project, the City is both the water agency and the lead agency.

Senate Bill X7-7 (Water Conservation Act of 2009)
Senate Bill X7-7 (Water Conservation Act of 2009), codified in California Water Code §10608, requires all water suppliers to increase water use efficiency. Enacted in 2009, this legislation sets an overall goal of reducing per capita urban water use, compared to 2009 use, by 20 percent by December 31, 2020. The State was required to make incremental progress toward this goal by reducing per capita water use by at least 10 percent on or before December 31, 2015. Monthly domestic water savings in the state reached 14.9 percent in September 2017 compared to production in September 2013. Cumulative statewide savings from June 2015 to February 2017 resulted in a 22.5 percent decrease in per capita urban water use.

California Urban Water Management Plan Act (California Water Code §§ 10610-10656) The California Urban Water Management Planning Act (California Water Code, §§ 10610-10656) addresses several State policies regarding water conservation and development of water management plans to ensure efficient use of available supplies. The California Urban Water Management Planning Act also requires water suppliers to develop water management plans every five years to identify shortand long-term demand management measures to meet growing water demand during normal, singledry, and multiple-dry years. Specifically, municipal water suppliers serving more than 3,000 customers or providing more than 3,000 acres per year of water must adopt an UWMP.

Several recent requirements have been added to the Urban Water Management Planning Act. These additional requirements include: (i) a narrative description of water demand measures implemented over the past five years and future measures planned to meet 20 percent demand reduction targets by 2020; (ii) a standard methodology for calculating system water loss; (iii) voluntary reporting of passive conservation savings, energy intensity, and climate change; and (iv) an analysis of water features that are artificially supplied with water.

Sustainable Groundwater Management Act of 2014
The Sustainable Groundwater Management Act of 2014, passed in September 2014, is a comprehensive three-bill package that provides a framework for the sustainable management of groundwater supplies by local authorities. The Sustainable Groundwater Management Act requires the formation of local groundwater sustainability agencies to assess local water basin conditions and  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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adopt locally based management plans. Local groundwater sustainability agencies were required to be formed by June 30, 2017. The Sustainable Groundwater Management Act provides 20 years for groundwater sustainability agencies to implement plans and achieve long-term groundwater sustainability and protect existing surface water and groundwater rights. The Sustainable Groundwater Management Act provides local groundwater sustainability agencies with the authority to require the registration of groundwater wells, measure and manage extractions, require reports and assess fees, and request revisions of basin boundaries, including establishing new subbasins. As required by the Sustainable Groundwater Management Act, in December 2016, the California Department of Water Resources published on its website the best management practices (BMP):
• BMP 1. Monitoring Protocols, Standards, and Sites;
• BMP 2. Monitoring Networks and Identification of Data Gaps; • BMP 3. Hydrogeologic Conceptual Model;
• BMP 4. Water Budget; and
• BMP 5. Modeling
In November 2017, BMP 6 for Sustainable Management Criteria was released for public comments to be received by January 8, 2018. Furthermore, under §10720.7 of the Sustainable Groundwater Management Act, groundwater sustainability agencies responsible for high- and medium-priority basins must adopt groundwater sustainability plans by January 31, 2020, or January 31, 2022, depending on whether the basin is in critical overdraft.

Article 22.5 - Drought Emergency Water Conservation, California Code of Regulations (Emergency Declaration and Executive Orders B-29-15, B 36-15, B-37-16, and B-40-17) Due to improved hydrologic conditions throughout California, on April 7, 2017, Governor Brown issued Executive Order B-40-17 that lifted the drought emergency declared via previous executive orders in 2014 through 2016 in all but four California counties. Executive Order B-40-17 also rescinds the Drought Emergency Proclamations issued in January and April 2014 as well as four drought-related Executive Orders issued in 2014 and 2015. However, Executive Order B-40-17 also directs the State Water Resources Control Board to maintain urban water use reporting requirements and prohibitions on wasteful practices. Water agencies will continue to strengthen drought readiness and water use efficiency. The regulatory requirements resulting from existing Executive Orders have been codified in Article 22.5, Drought Emergency Water Conservation, of the California Code of Regulations.

California Water Plan 2023
Required by the California Water Code § 10005(a), the California Water Plan (Water Plan) is the State's strategic plan for managing and developing water resources statewide for current and future generations. The Water Plan provides a collaborative planning framework for elected officials, agencies, tribes, water and resource managers, businesses, academia, stakeholders, and the public to develop findings and recommendations and make informed decisions for California's water future.

The Water Plan, updated every five years, presents the status and trends of California's water-dependent natural resources, water supplies, and agricultural, urban, and environmental water demands for a range of plausible future scenarios. The Water Plan also evaluates different combinations of regional and statewide resource management strategies to reduce water demand, increase water supply, reduce flood risk, improve water quality, and improve environmental and resource stewardship. Evaluations and assessments performed for the Water Plan help identify effective actions and policies to meet  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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California's resource management objectives in the near term and for several decades to come. Although the California Water Plan cannot mandate actions or authorize itemized spending, policymakers and lawmakers can authorize specific actions and appropriate necessary funding.

Regional
San Bernardino Valley Regional Urban Water Management Plan 2020 (UWMP) The San Bernardino Valley Regional UWMP 2020 is a tool that provides a summary of anticipated supplies and demand for the years 2020-2045. It was prepared for the following agencies within the San Bernardino Valley Municipal Water District service area:
• City of Redlands
• San Bernardino Valley Municipal Water District (wholesale water agency) • East Valley Water District
• City of Loma Linda
• City of San Bernardino Municipal Water Department
• West Valley Water District
• Yucaipa Valley Water District
• City of Colton
• City of Rialto
• Riverside Highland Water Company
The Plan was prepared in accordance with the Urban Water Management Plan Act, the 2009 Water Conservation Act (SB X7-7) and the DWR Guidebook for Urban Water Suppliers. The City of Redlands participated in the UWMP. The UWMP also serves as the Integrated Regional Water Management Plan for the San Bernardino Valley region.

City of Redlands Water Systems Master Plan (WSMP)
The 2022 WSMP includes the three water systems of the city: Non-Potable Water, Potable Water, and Recycled Water Systems. The most critical outcome of the 2022 WSMP is the development of comprehensive five-year and twenty-year capital improvement program recommendations to improve distribution efficiency, reduce nonrevenue water, and accommodate growth within the City water service areas.

Wastewater
State
The California Green Building Standards Code, commonly referred to as the CALGreen Code, is established in the California Code of Regulations, Title 24, Part 11, and establishes voluntary and mandatory standards pertaining to the planning and design of sustainable site development and water conservation, among other issues. According to the CALGreen Code, all water closets (i.e., flush toilets) are limited to 1.28 gallons per flush, and urinals are limited to 0.5 gallons per flush. In addition, maximum flow rates for faucets are established at 2.0 gallons per minute (gpm) at 80 pounds per square inch (psi) for showerheads; 1.2 gpm at 60 psi for residential lavatory faucets; and 1.8 gpm at 60 psi for kitchen faucets.

City of Redlands Water Efficient Landscape Requirements  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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Chapter 15.54 of the Redlands Municipal Code establishes the City’s Water Efficient Landscape Requirements to promote the benefits provided by landscapes while recognizing the need to use water as efficiently as possible. The chapter requires that applicable landscaping projects submit a landscape documentation package that contains project information, hydrozone information table, water budget calculations, soil management report, and landscape, irrigation, and grading design plans. The chapter establishes requirements for irrigation scheduling, maintenance, and audits to ensure efficient use of water. The requirements also include provisions for recycled water irrigation systems and encourage best-strategy practices in stormwater to increase retention and infiltration on site.

California Plumbing Code (2022)
The City of Redlands has adopted the 2022 California Building Standards Code with July 2024 Supplement, including the California Plumbing Code (California Code of Regulations, Title 24, Part 5). The code includes provisions for the design, materials, and installation of water supply and distribution fixtures, sanitary drainage, indirect waste, storm drainage, and non-potable water sources for individual projects.

4.14.3 Existing Conditions
Water Supplies
The City of Redlands Municipal Utilities & Engineering Department (MUED) supplies water to nearly all of the city of Redlands, including the project site, and most of the unincorporated community of Mentone east of Redlands. Redlands receives its water from the following:
• Mill Creek Watershed: The water from the Mill Creek watershed is treated at the Henry Tate (Tate) Water Treatment Plant (WTP) located on Highway 38 east of Mentone. • Santa Ana River Watershed: The water from the Santa Ana River watershed is treated at the Hinckley WTP located north of Mentone.
• Local Groundwater: Local groundwater is pumped from wells in Redlands, Mentone, and Yucaipa. • California State Water Project (SWP) Water: SWP water is treated at Hinckley WTP and Tate WTP.

Metropolitan Water District of Southern California (MWD) MWD wholesales water imported from northern California through the SWP, which is operated by the California Department of Water Resources, and from the Colorado River via the Colorado River Aqueduct.

Recycled Water
The City of Redlands Water Reclamation Plant (WRP) is a facility that treats raw wastewater, converting it into recycled water for various uses. Originally a secondary treatment facility, it has been expanded to include advanced wastewater treatment processes. The plant is operated by the City of Redlands. The City of Redlands produces its recycled water internally in its WRP, treating municipal wastewater to tertiary standards in accordance with California Title 22 regulations. Uses of recycled water include industrial cooling and landscape irrigation. The City’s WRP treats approximately 5.9 mgd and has 9 mgd capacity including tertiary treatment capacity of 7.2 mgd.34 In 2020, approximately 1.6 34 Sanitary wastewater is treated in the following three phases: Primary Treatment: removal of solids using settling tanks; Secondary Treatment: reduction of organic matter using bacteria and oxygen; followed by further removal of solids;  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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mgd were used as recycled water for customers, and 3.4 mgd were used for groundwater recharge in the Bunker Hill Basin (City of Redlands, 2024). The projected water supplies during the 2025–2045 planning period are summarized in Table 4.14-1, which include groundwater, surface water, recycled water, and imported sources.

Table 4.14-2 provides a supply and demand comparison for normal year conditions, demonstrating that available supplies meet projected demand. Table 4.14-3 presents a single dry year comparison, showing that the city can continue to meet water needs during isolated drought years through increased reliance on groundwater and imported supplies. Table 4.14-4 outlines the reliability of the water supply over multiple consecutive dry years, confirming a sustained supply-demand balance under stressed conditions.

Table 4.14-1
PROJECTED WATER SUPPLIES (2025–2045) (afy)
Water Supply REASONABLY AVAILABLE VOLUME
2025 2030 2035 2040 2045
Groundwater: Bunker Hill Subbasin and Yucaipa Basin 13,973 14,922 15,861 16,677 17,484 Recycled Water 3,766 4,015 4,275 4,513 4,760
Surface Water: Santa Ana River and Mill Creek 10,500 10,500 10,500 10,500 10,500 Imported Water 700 700 700 700 700
Recycled Water: Direct non-potable reuse 2,100 2,100 2,100 2,100 2,100 Total 31,039 32,238 33,436 34,490 35,544
Note: afy (Acre Feet per Year): One acre foot = 325,851 gallons Source: City of Redlands, 2021. 2020 Urban Water Management Plan Table 4.14-2
NORMAL YEAR SUPPLY AND DEMAND COMPARISON (2025–2045) (afy) Supply/Demand Component 2025 2030 2035 2040 2045
Total Water Supply 31,039 32,238 33,436 34,490 35,544
Total Demand 26,991 28,033 29,075 29,991 30,908
Supply-Demand 4,049 4,205 4,361 4,499 4,636
Source: City of Redlands, 2021. 2020 Urban Water Management Plan Table 4.14-3
SINGLE DRY YEAR SUPPLY AND DEMAND COMPARISON (2025–2045) afy Supply/Demand Component 2025 2030 2035 2040 2045
Total Water Supply 34.143 35,461 36,780 37,939 39,098
Total Demand 29,690 30,836 31,982 32,990 33,998
Supply-Demand 4,453 4,625 4,797 4,949 5,100
Source: City of Redlands, 2021. 2020 Urban Water Management Plan

and Tertiary Treatment: filtration of wastewater to remove any solids remaining after the first two phases of treatment.

Most wastewater that undergoes tertiary treatment is subsequently disinfected, and much of it is reused (i.e., recycled) for landscape and agricultural irrigation, groundwater recharge, and industrial uses.  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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Table 4.14-4
MULTIPLE DRY YEAR SUPPLY AND DEMAND COMPARISON (2025–2045) afy Scenario 2025 2030 2035 2040 2045
First Year
Supply 34,143 35,461 36,780 37,939 39,098
Demand 29,690 30,836 31,982 32,990 33,998
Difference 4,453 4,625 4,797 4,949 5,100
Second Year
Supply 34,143 35,461 36,780 37,939 39,098
Demand 29,690 30,836 31,982 32,990 33,998
Difference 4,453 4,625 4,797 4,949 5,100
Third Year
Supply 34,143 35,461 36,780 37,939 39,098
Demand 29,690 30,836 31,982 32,990 33,998
Difference 4,453 4,625 4,797 4,949 5,100
Fourth Year
Supply 34,143 35,461 36,780 37,939 39,098
Demand 29,690 30,836 31,982 32,990 33,998
Difference 4,453 4,625 4,797 4,949 5,100
Fifth Year
Supply 34,143 35,461 36,780 37,939 39,098
Demand 29,690 30,836 31,982 32,990 33,998
Difference 4,453 4,625 4,797 4,949 5,100
Source: City of Redlands, 2021. 2020 Urban Water Management Plan Domestic Water Conveyance
The project site is served by an existing 16-inch water main on California Street and a 12-inch main on West Lugonia Avenue, both of which are components of the City’s Primary Pressure Zone distribution network.

The 2020 UWMP prepared by the City of Redlands confirms that the Primary Pressure Zone serving the project site has adequate hydraulic capacity to meet current and future demands under normal, single dry, and multiple dry year conditions until 2045 (Redlands 2020, Table 7-6). Fire flow in this area is consistent with the California Fire Code, which requires a minimum flow of 1,500 gallons per minute for low-density commercial and medical office uses with a duration of at least two hours and adequate hydrant spacing.

Wastewater Treatment and Conveyance
The City of Redlands WRP is owned and operated by the City and has a permitted capacity of 9.5 mgd, with an average daily flow of approximately 5.9 mgd as of 2020. The plant is regulated by the Waste Discharge Requirements (Order No. R8-2015-0012) issued by the Santa Ana Regional Water Quality Control Board (RWQCB). It treats wastewater to tertiary standards in accordance with the California Code of Regulations, Title 22, making it suitable for non-potable reuse, including landscape irrigation and aquifer recharge.

The 2020 UWMP and Sewer Master Plan of the City confirm that there is sufficient capacity within both the collection system and the WTP to accommodate the anticipated growth, including the future buildout of the East Valley Corridor Specific Plan.
 SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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Solid Waste Disposal and Diversion
The environmental setting for the disposal of solid waste in the Initial Study contained an error, stating that solid waste from the city of Redlands was disposed of at one landfill, California Street Landfill, in the city of Redlands. In 2023, the latest year for which data are available, about 93 percent of the solid waste landfilled from the city of Redlands was actually disposed of in two landfills—the California Street Landfill and the San Timoteo Sanitary Landfill south of the city of Redlands (CalRecycle, 2024a).). The two landfills are described below in Table 4.14-5. The impact significance conclusion (less than significant) is not changed compared to that in the Initial Study; therefore, this topic is not addressed in Section 4.14.4.

Table 4.14-5

LANDFILLS SERVING REDLANDS
Facility and nearest
city/community
Remaining
Capacity
Daily
Permitted
Disposal
Capacity
Actual
Daily
Disposal
Residual
Daily
Disposal
Capacity
Estimated
Closing
Date
California Street Landfill 4,184,751 CY 829 tons 170 tons 659 tons 2042 San Timoteo Sanitary Landfill 12,360,396 CY 2,000 tons 1,234 tons 766 tons 2039 Total 16,545,147 CY 2,829 tons 1,404 tons 1,425 tons N/A Daily disposal calculated based on annual disposal tonnage assuming 300 operating days per year, that is, six days per week less certain holidays.

Sources: CalRecycle. 2020a. Jurisdiction Disposal by Facility; CalRecycle. 2020[b, and c]. Solid Waste Information System (SWIS): SWIS Facility/Site Search; CalRecycle. 2020d. 2019 Landfill Summary Tonnage Report.

4.14.4 Environmental Impact Analysis

4.14.4.1 Thresholds of Significance
For the purposes of this Environmental Impact Analysis, Significance Thresholds for evaluating potential impacts to Utilities and Service Systems are based on the criteria set forth in Appendix G of the 2025 State CEQA Guidelines. The project would have a significant impact related to Utilities and Service Systems if it would:

A. Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? B. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? C. Result in a determination by the waste water treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
D. Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? E. Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
The Initial Study (refer to Appendix A1) determined that impacts would be less than significant for Thresholds D and E. Under Threshold D, sufficient capacity is available at recycling and landfill facilities in the region for the demolition debris estimated to be generated by the project and solid waste generated by the project would be approximately 0.48 percent of the residual daily capacity of  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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the landfill, thus impacts would be less than significant. The project will comply with federal, state, and local management and reduction statutes and regulations related to solid waste and thus impacts under Threshold E would be less than significant. This analysis therefore evaluated impacts only for Appendix G Thresholds A, B, and C.

4.14.4.2 Analysis of Project Impacts
Threshold A: Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Less Than Significant Impact
Significance Threshold A focuses on the project’s potential to require the relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas or telecommunications facilities. Potential impacts related to electricity and natural gas supply, and consumption are comprehensively addressed in Section 4.5 and potential impacts on stormwater drainage facilities are evaluated in Section 4.10 of this DEIR and are therefore not analyzed further in this section. The impacts associated with the telecommunications infrastructure were determined to be less than significant in the Initial Study and are not analyzed further in this section. Accordingly, this analysis evaluates the potential impacts of the project solely in terms of water supply and wastewater treatment facilities, to determine if existing capacity is sufficient to meet the projected demand. The project proposes hospital and medical offices to be built in four phases.

Water Supplies and Project Water Demands
MUED provides water to the City of Redlands including the project site. Under CEQA Guidelines §15155 and Water Code §10910 et seq. (SB 610), the City of Redlands, as the public water purveyor, must verify that it has sufficient existing and future water supplies to meet the project's demands over a 20-year horizon.

A WSA was completed for the proposed project by Michael Baker International, dated April 22, 2025,which was included as Appendix 4.9a to this DEIR. The WSA utilized the highest Water Demand Factor (WDF) of 5,705 gallon per day(gpd)/acre to calculate the expected demands for the existing MOB 1 and the proposed MOB 2, CUP, and MOB 3. The hospital and hospital Tower WDF is 350 gpd/bed, with 213 and 108 beds, respectively. The Average Day Demand (ADD) for the project using this methodology is 114.7 gpm. The Maximum Day Demand (MDD) and Peak Hour Demand (PHD) were calculated using peaking factors of 1.7 and 2.75 respectively per the City of Redlands 2022 Water Master Plan. The MDD is 195 gpm and PHD is 315 gpm for the project as demonstrated in Table 4.14-7 below (Michael Baker, 2025. p. 3).

Demands for MOB 2 and MOB 3 will be individually measured while demand for the hospital and the hospital tower will be routed through the CUP. Table 4.14-8 breaks down the domestic water demands by phase (Michael Baker, 2025, p. 4).
 SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
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Table 4.14-7

PROPOSED PROJECT DOMESTIC WATER DEMANDS
Building Area
(x 1000 sf) Acreage WDF (gpd/acre) ADD (gpm) MDD (gpm) PHD (gpm) Existing MOB 1 120 2.75 5,705 10.91 18.55 30.01
ASC/MOB 2 165 3.79 5,705 15.01 15.51 41.27
CUP 35 0.80 5,705 3.18 5.41 8.75
MOB 3 83 1.9 5,705 7.55 12.83 20.76
Building Beds WDF (gpd/acre) ADD (gpm) ADD (gpm) MDD (gpm) PHD (gpm) Hospital 213 350 74,550 51.77 88.01 142.37
Hospital Tower 108 350 37,800 26,25 44.63 72.19
Total 114.67 194.95 315.35
Source: Michael Baker, 2025. Water Supply Assessment for Kaiser Permanente Redlands Medical Center.

Table 4.14-8

PROPOSED PROJECT DOMESTIC WATER DEMANDS BY PHASE
Building Phase ADD (gpm) ADD by Phase (gpm) MDD (gpm) PHD (gpm) Existing MOB 1 1 10.9 25.92 44.07 71.28 ASC/MOB 2 1 15.01 Hospital 2 51.77 54.95 93.42 151.12 CUP 2 3.18
MOB 3 3 7.55 7.55 12.83 20.76
Hospital Tower 4 26.25 26.25 44.63 72.19
Source: Michael Baker, 2025. Water Supply Assessment for Kaiser Permanente Redlands Medical Center.

As shown in Table 4.14-9, the existing water infrastructure of the City of Redlands, managed by the MUED, is expected to adequately meet the demands of the proposed project. In addition, close coordination with MUED throughout the design and implementation process will ensure that all improvements in water infrastructure align with the objectives and supply planning outlined in the City’s 2020 UWMP (City of Redlands, 2022).

Table 4.14-9
COMPARISON OF PROPOSED PROJECT DEMAND VS. AVAILABLE WATER SUPPLY Parameter Project Demand Redlands Water Supply Assessment Average Daily Demand
(ADD)
114.7 gpm
(165,168 gpd or 185 afy)
16,317 afy (2045)
(Normal Year) 1.2% of 2045 supply
Maximum Day Demand
(MDD)
195 gpm
(280,800 gpd or 314 afy)
Not reported daily, but within
system hydraulic design
Expected to be within
pressure zone capacity
Peak Hour Demand
(PHD) 315 gpm Managed through Primary Pressure Zone
Design accounts for
diurnal peaks
Single-Dry Year Supply No change in demand 13,133 afy 1.4% of supply Multiple-Dry Year Supply No change in demand 11,835 afy 1.6% of supply Fire Flow Requirement 1,500 gpm, 2-hour
duration
Met through looped network
and hydrant capacity
Compliant with
CA Fire Code
Source(s): Michael Baker, 2025. Water Supply Assessment for Kaiser Permanente Redlands Medical Center; City of Redlands, 2021. 2020 Urban Water Management Plan.

Project buildout will occur over four distinct phases, each generating incremental increases in water demand. As a result, municipal water infrastructure upgrades will be required to maintain service reliability and compliance with water quality standards. Infrastructure upgrades and coordination with MUED will ensure system adequacy, pressure zone performance, and consistency with the City’s  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.14-11 Program Environmental Impact Report November 2025
2020 Urban Water Management Plan (UWMP). Therefore, the proposed project would have a less than significant impact in this regard.

Water Treatment
The proposed project includes approximately 983,000 square feet of new medical development, consisting of a hospital, medical office buildings (MOBs) and a CUP. Based on industry standard benchmarks from the DWR and the SBMWD, the estimated total water demand is approximately 847 afy. This includes demand factors of approximately 0.5 afy per 1,000 square feet for MOBs and 0.8 afy per 1,000 square feet for hospital uses as shown in Table 4.14-10.

Table 4.14-10

ESTIMATED PROJECT WATER DEMAND (AT BUILDOUT)
Proposed Use Square
Feet
Water Demand
Rate afy
Hospital (high-intensity): ~0.8–1.2 afy per 1,000 sq. ft. 580,000 0.8 464 Medical Office (standard use): ~0.5 afy per 1,000 sq. ft. 368,000 1.0 368 Central Plant (mechanical loads) 35,000 .04 15
Total 983,000 N/A 847
Source(s): DWR UWMPs Guidebook for Urban Water Suppliers; LA Department of Water & Power Land Use Budget Water Conveyance
The proposed domestic water service connections will support existing and new medical facilities on the Kaiser Permanente Redlands Medical Center campus, including a CUP and two hospital towers.

According to the Water Supply Assessment (WSA), implementation of the proposed project will necessitate new domestic water service connections to meet increased demand associated with phased development. The project includes the following infrastructure upgrades:
• California Street Connection: A new 4-inch domestic water service connection will be established to the existing 16-inch diameter water main on California Street. This line will exclusively serve the existing Medical Office Building 1 (MOB 1). • Lugonia Avenue Connection: A new 6-inch domestic water service connection will tie into the 12-inch diameter water main on Lugonia Avenue. This connection is designed to accommodate water supply needs for the new Medical Office Buildings 2 and 3 (MOB 2 and MOB 3), Central Utility Plant (CUP), the new Hospital facility, and the proposed Hospital Tower.

Domestic Water
The proposed project will require reliable and adequate water conveyance infrastructure to serve approximately 983,000 square feet of new healthcare facilities, including hospitals, medical office buildings, and a CUP. The project will connect to the existing municipal water distribution system operated by the City of Redlands and will be evaluated for capacity and pressure adequacy through utility coordination and hydraulic modeling. On-site conveyance improvements, including looped water mains, service laterals, and backflow prevention devices, will be designed in accordance with the California Plumbing Code, City design standards, and applicable American Water Works Association guidelines. All water infrastructure will also be coordinated with fire protection design to ensure dual purpose conveyance for both domestic and fire water supply. No significant impacts are anticipated, as the required infrastructure can be extended or upgraded within existing rights-  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.14-12 Program Environmental Impact Report November 2025
of-way and will be sized to meet the average daily and peak demand conditions identified in the project’s Water Supply Assessment.

Fire Water
The project will require the installation or upgrade of the fire water conveyance infrastructure on site, including underground mains, hydrants, and fire department connections, to meet the minimum fire flow and pressure requirements. Pursuant to the California Fire Code (CFC), 2022 Edition, codified in Title 24, Part 9 of the California Code of Regulations, projects classified under Group I-2 (Hospitals) and Group B (Medical Offices) must provide fire flow and hydrant spacing according to Table B105.1(2) and §507, with typical required fire flows ranging from 3,000 to 4,500 gpm, subject to the type of fire-resistive construction and the presence of automatic sprinkler systems. The final design will ensure looped water lines, dual connection points, and appropriate backflow prevention.

No significant impact related to fire water infrastructure is anticipated, as improvements will be constructed in coordination with the Redlands Fire Department and in compliance with California Fire Code.

Wastewater Treatment Facilities
Projected wastewater generation is approximately 86,075 gallons per day (gpd), consistent with standard discharge rates for healthcare facilities as shown in Table 4.14-11. All sewer improvements will comply with the California Plumbing Code, City Public Works standards, and best management practices to prevent inflow, infiltration, and system surcharges. Project-level coordination will confirm that sufficient treatment and conveyance capacity exists to support the proposed development without significant environmental impact.

Table 4.14-11

ESTIMATED PROJECT WASTEWATER GENERATION
Proposed Use Project Phases Quantity and units Wastewater Generation (gpd) Per unit Total
Hospital 2 and 4 321 beds 75 24,075
Medical Office Building 1 and 3 248,000 square feet 0.25 62,000 Total 86,075
Source: Los Angeles County Sanitation District, 2025
In this estimate utility demands by the CUP are treated as ancillary to the primary uses and thus are not estimated separately.

The generation factors presented in Table 4.14-11 references LACSD's Will Serve Program wastewater planning criteria. The estimated flows represent standard operational and occupancyrelated wastewater discharges consistent with established planning methodologies.

Collection and Conveyance Infrastructure
The proposed project will increase wastewater generation through the phased development of medical office buildings, a 321-bed hospital, and associated infrastructure. Wastewater will be conveyed via new or upgraded on-site sewer laterals and gravity mains, which will connect to existing regional sewer lines on Lugonia Avenue and Almond Avenue, maintained by the City of Redlands. The existing lines are part of the City’s gravity-based sewer collection network, which conveys flows to the Redlands WTP approximately 2.5 miles southeast of the site.  SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.14-13 Program Environmental Impact Report November 2025
Conclusion
As previously noted, the project will connect to existing on-site laterals or construct new service laterals to tie into the adjacent sewer mains, and no off-site improvements or upgrades are required.

Based on the City of Redlands' 2020 UWMP, the estimated annual water demand of the project of 847 afy, as shown in Table 4.14-10 above, represents approximately 3.01 percent of the total available water supply of the City. Given this relatively small proportion of the overall supply, the existing water infrastructure has sufficient capacity to meet the project’s demand of the project without requiring the relocation or construction of new or expanded water supply facilities that could have significant environmental effects. Similarly, the wastewater generated by the project would be within the capacity of existing wastewater treatment systems and no new or expanded treatment facilities would be required. Therefore, the impacts would be less than significant.

Threshold B: Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less than Significant Impact
MUED has sufficient forecast water supplies to meet project water demand during normal, dry and multiple dry years, as substantiated above, and impacts would be less than significant.

As analyzed above, MUED’s 2020 UWMP projects reliable supplies of 31,000–35,500 AFY through 2045, with surpluses of about 4,000–5,100 AFY under normal, single-dry, and multiple-dry year scenarios. The project’s demand of roughly 185 AFY represents less than 2 percent of available supplies and is already accounted for in UWMP forecasts. Because MUED’s portfolio of groundwater, surface water, recycled water, and imports maintains adequate margins in all planning years, sufficient supplies exist to meet project demand under normal, dry, and multiple-dry conditions, and impacts would be less than significant.

Threshold C: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less than Significant Impact
As previously examined, the City of Redlands has adequate wastewater treatment capacity to meet project wastewater generation; thus, impacts would be less than significant.

4.14.5 Cumulative Impacts
Water
The impact analysis for impacts on water supplies and facilities is cumulative, addressing systemwide water supplies and demands for the City of Redlands MUED. Future water demands were projections based on demographic forecasts from the Southern California Association of Governments, which in turn are based on General Plan buildout projections. MUED forecasts that it will have adequate water to meet water demands in its service area over the 2025-2045 period.

Cumulative impacts would be less than significant.
 SECTION 4.14 – UTILITIES AND SERVICE SYSTEMS 
7214/Redlands – Kaiser Permanente Medical Center Page 4.14-14 Program Environmental Impact Report November 2025
Wastewater
The impact analysis for wastewater treatment above is cumulative, addressing City of Redlands systemwide wastewater generation and treatment. The City of Redlands WRP is owned and operated by the City and has a permitted capacity of 9.5 mgd, with an average daily flow of approximately 5.9 mgd as of 2020. The 2020 UWMP and Sewer Master Plan of the City confirm that there is sufficient capacity within both the collection system and the WTP to accommodate the anticipated growth, including the future buildout of the East Valley Corridor Specific Plan. Cumulative impacts would be less than significant.

4.14.6 Mitigation Measures
Project-level and cumulative impacts related to utilities and service systems have been determined to be less than significant. Therefore, no mitigation measures are required.

4.14.7 Level of Significance after Mitigation
Impacts related to utilities and service systems would be less than significant without mitigation.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-1 Program Environmental Impact Report November 2025

5.0 ALTERNATIVES

5.1 Introduction
An essential aspect of the environmental review process under CEQA is the identification and analysis of alternatives to a proposed project. Specifically, Public Resources Code (PRC) § 21002 states that the environmental review process is intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives which will avoid or substantially lessen such significant effects. In addition, PRC § 21002.1 (a) states, in part, that the purpose of an environmental impact report is to identify the significant effects on the environment of a project, identify alternatives to the project, and to indicate the manner in which those significant effects can be mitigated or avoided.

Section 15126.6 of the CEQA Guidelines provides guidance regarding the consideration and discussion of project alternatives in an EIR. More specifically, CEQA Guidelines § 15126.6(a) states the following:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather, it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible.

Furthermore, the CEQA Guidelines advise that project alternatives be selected primarily based on the ability to avoid or substantially lessen significant impacts relative to those of the proposed project, even if the alternatives would impede, to some extent, the attainment of the project objectives, or would even be more costly. The CEQA Guidelines further instruct that the identification of alternatives be guided by a "rule of reason," so that only those alternatives necessary to permit a reasoned choice are addressed. In selecting project alternatives for analysis, potential alternatives must be feasible. CEQA Guidelines § 15126.6(f)(1) states that:

Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries [...], and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site [...]
In addition, CEQA Guidelines § 15126.6(e) requires analysis of a "no project" alternative and § 15126.6(f)(2) requires an evaluation, if feasible, of alternative location(s) for the project. Based on the alternatives analysis, an environmentally superior alternative is then designated. If the No project/No Build Alternative ends up as the “environmentally superior alternative,” then the EIR shall identify an environmentally superior alternative among the other alternatives.

Under CEQA, the goal of identifying the environmentally superior alternative is to assist decisionmakers in considering project approval. However, CEQA does not require an agency to select the environmentally superior alternative (CEQA Guidelines § 15042-15043). Specifically, CEQA Guidelines § 15043 states that a public agency may approve a project even though the project would  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-2 Program Environmental Impact Report November 2025
cause a significant effect on the environment if the agency makes a fully informed and publicly disclosed decision that:
(a) There is no feasible way to lessen or avoid the significant effect (see CEQA Guidelines § 15091); and
(b) Specifically identified expected benefits from the project outweigh the policy of reducing or avoiding significant environmental impacts of the project (see CEQA Guidelines §15093).

As stated in CEQA Guidelines § 15093(a):

CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental 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, including region-wide or statewide environmental benefits, of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.”
In accordance with CEQA Guidelines §15126.6, the following section discusses a reasonable range of alternatives that would “feasibly attain most of the basic objectives of the project but would avoid or substantially lessen potential significant impacts of the project and evaluate the comparative merits of the alternatives.”

5.2 Overview of Selected Alternatives
As discussed above, alternatives are identified to reduce the significant impacts of a proposed project on the environment. Based on the analyses provided in Section 4.0, Environmental Impact Analysis, of this Draft PEIR, implementation of the project would result in significant impacts that cannot be feasibly mitigated with respect to construction noise (Section 4.11).

After implementation of mitigation measures, the project would still have significant environmental effects, which would necessitate the adoption of a Statement of Overriding Considerations for impacts regarding GHG emissions and transportation (vehicle miles traveled).

Therefore, the alternatives to the project, listed below, were selected for evaluation based on the significant environmental impacts of the project, the basic objectives established for the project as presented in Section 2.0 of this Draft PEIR, and the feasibility of the alternatives considered. Each of these alternatives is described in the following sections. • Alternative 1: No Project/No Development Alternative
• Alternative 2: No Project/General Plan Buildout Alternative • Alternative 3: Reduced Intensity Alternative
• Alternative 4: Dispersed Facilities Alternative
In addition, CEQA Guidelines § 15126.6(c) requires that an EIR identify any alternatives that were considered for analysis but rejected as infeasible. Such potential alternatives are described below.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-3 Program Environmental Impact Report November 2025
Note that project site in this Section refers to just the 28.15 acres that are currently vacant and would be developed with hospital and medical office uses in the proposed project and omits the 9.35 acres developed with an existing medical office building that would not be substantially altered as a result of project activities.

5.3 Alternatives Considered and Rejected as Infeasible
According to CEQA Guidelines § 15126.6(c), an EIR should identify any alternatives that were considered for analysis but rejected as infeasible and briefly explain the reasons for their rejection.

The factors that may be used to eliminate an alternative from detailed consideration may include the alternative's failure to meet most of the basic project objectives, the alternative's infeasibility, or the alternative's inability to avoid significant environmental impacts. Alternatives to the project that have been considered and rejected as infeasible include the following:
• Alternative Project Site: The proposed project is intended to serve Kaiser Permanente members in the San Bernardino-Riverside area. An alternative project site was considered and rejected during project planning because Kaiser Permanente does not own or control another site in the region with sufficient space and regional access for the proposed medical center.
• Home Care: In this alternative, as much care as is practicable would be provided in patients’ homes, and care that could not be provided in a home setting would be provided at existing Kaiser Permanente facilities (for instance, hospitals in Fontana and Riverside). This alternative was rejected for the following reasons:
• Travel to patients’ homes by staff would have increased vehicle miles traveled, not decrease it, compared to the proposed project;
• Many kinds of care (surgical, critical care, etc.) cannot be provided in home settings; and • This alternative would not have replaced the medical office uses proposed by the project (physicians and some other providers would not start making house calls).

5.4 Alternatives Analysis Format
Consistent with the CEQA Guidelines § 15126.6(d), each alternative was assessed at a level of detail necessary to determine if the overall environmental impacts would be less, similar, or greater than the corresponding impacts of the proposed project. Furthermore, each alternative was evaluated to determine whether the project's basic objectives, identified in Section 2.0 of this Draft PEIR, would be significantly attained by the alternative. The evaluation of each of the alternatives follows the process described below:

1. An alternative’s net environmental impact for each environmental issue area (analyzed in Section 4.0 of this Draft PEIR) was determined assuming that the alternative would implement the same project design features and mitigation measures identified in Section 4.0.

2. The post-mitigation significant and non-significant environmental impacts of an alternative and the project were compared for each environmental issue area as follows:
• Less: If the net impact of an alternative would be clearly less adverse or more beneficial than the impact of the project, the comparative impact was determined to be "less."  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-4 Program Environmental Impact Report November 2025
• Greater: If the net impact of an alternative would clearly be more adverse or less beneficial than the project, the comparative impact was determined to be "greater." • Similar: Where the impact of an alternative and project would be roughly equivalent, the comparative impact was determined to be "similar."

3. The comparison of the impacts is followed by a general discussion of whether the underlying purpose and basic project objectives are feasibly and substantially attained by the alternative.

Table 5.4-1 on the following page provides a summary of the proposed project description and a narrative description of each alternative and its components, as compared with that of the proposed project. Table 5.4-2 provides a summary comparison, by environmental topic, of the project impacts and the impacts of each of the alternatives. Table 5.4-3 provides a summary comparison of each of the alternatives’ ability to meet the goals and objectives of the project.

Table 5.4-1

SUMMARY OF ALTERNATIVES
Alternative Brief Description Number of Parking
Spaces
Proposed Project
The proposed project includes the development of a
580,000-square-foot, 321-bed hospital in two phases
(project phases 2 and 4); two medical office
buildings, in phases 1 and 3, totaling 248,000 square
feet; a central utilities plant; and a parking structure. 2,803 (600 existing
plus net increase of
2,203)
Alternative 1:

No Project
Alternative
This alternative would involve the continuation of
existing conditions (one medical office building and
vacant land) on the site.
600 existing parking
spaces will remain.

Alternative 2:

No Project/General
Plan Buildout
This alternative would involve development of the

28.15-acre site with approximately 552,000 square
feet of commercial and/or industrial uses.

As required per City of
Redlands Municipal
Code
Alternative 3:

Reduced Intensity
Alternative
This alternative includes the development of a
435,000-square-foot, 213-bed hospital in one phase;
one 165,000-square-foot ambulatory
surgery/medical office building; a central utilities
plant; and a parking structure.
2,231
Alternative 4:

Dispersed Facilities
Alternative
This alternative consists of development of about six
small facilities totaling approximately 650,000
square feet in the San Bernardino-Redlands region.

As required per
municipal/county
codes of affected
jurisdictions
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-5 Program Environmental Impact Report November 2025
Table 5.4-2

COMPARISON SUMMARY OF PROJECT IMPACTS AND ALTERNATIVES IMPACTS Environmental Topic Proposed project
Alternative 1:

No project/
No Action
Alternative
Alternative 2:

No Project
/General Plan
Buildout
Alternative
Alternative 3:

Reduced Intensity
Alternative
Alternative 4:

Dispersed Facilities
Alternative
Aesthetics
Construction
Scenic Vistas LTS Similar (no impact) Similar (no impact) Similar (no impact) Similar (no impact) Visual Character LTS Less (no impact) Less Similar Less Shading LTS Less (no impact) Less Similar Less
Light and Glare LTS Less (no impact) Less Similar Less
Operation
Scenic Vistas LTS Similar (no impact) Greater Similar (no impact) Similar (no impact) Visual Character LTS Less (no impact) Less (LTS) Similar Less Shading LTS Less (no impact) Greater Similar Less
Light and Glare LTS Less (no impact) Less (LTS) Similar Less Air Quality
Construction
Regional Emissions LTS Less (no impact) Similar (no impact) Similar (no impact) Similar (no impact) Localized Emissions LTS Less (no impact) Similar (no impact) Similar (no impact) Similar (no impact) Toxic Air
Contaminates LTS Less (no impact) Similar (no impact) Similar (no impact) Similar (no impact) Operation
Regional Emissions LTS w/Mitigation Less (no impact) Similar Less Less Toxic Air
Contaminates LTS Less (no impact) Similar Less Less
Biological Resources
Construction LTS w/Mitigation Less (no impact) Similar Similar Less Operation No Impact Similar (no impact) Similar Similar Similar Cultural Resources
Archaeological Resources LTS w/Mitigation Less (no impact) Similar Similar Less Historic Resources No impact Similar (no impact) Similar (no impact) Similar Similar Energy
Construction LTS Less (no impact) Less Less Less
Operation LTS Less (no impact) Less Less Less
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-6 Program Environmental Impact Report November 2025
Environmental Topic Proposed project
Alternative 1:

No project/
No Action
Alternative
Alternative 2:

No Project
/General Plan
Buildout
Alternative
Alternative 3:

Reduced Intensity
Alternative
Alternative 4:

Dispersed Facilities
Alternative
Geology and Soils
Geology and Soils LTS Less (no impact) Similar Similar Similar Paleontological Resources LTS w/Mitigation Less (no impact) Similar Similar Less Greenhouse Gas Emissions
Construction LTS w/Mitigation Less (no impact) Less Similar Less Operation S/U Less (no impact) Less (S/U) Less (S/U) Less (S/U) Hazards and Hazardous Materials
Construction LTS Less (no impact) Similar Less Similar
Operation LTS Less (no impact) Less Similar Similar
Hydrology and Water Quality
Construction LTS Less (no impact) Similar Similar Less
Operation LTS Less (no impact) Similar Less Less
Noise
Construction
Onsite Noise LTS Less (no impact) Less Less Less
Offsite Noise LTS Less (no impact) Less Less Less
Vibration LTS Less (no impact) Less Less Less
Operation
Onsite Noise LTS Less Less Similar Less
Offsite Noise LTS Less Less Similar Less
Public Services
Fire Protection LTS Less (no impact) Similar Similar Similar Police Protection LTS Less (no impact) Similar Similar Similar Transportation/Traffic
Construction LTS Less (no impact) Less Similar Less
Operation
Vehicle Miles Traveled S/U Less (no impact) Similar Less (S/U) Similar Bicycle, Pedestrian,
and Vehicular Safety LTS Less (no impact) Similar Similar Similar Tribal Cultural Resources
Construction LTS w/Mitigation Less (no impact) Similar Similar Less Operation No Impact Less (no impact) Similar Similar Similar Utilities and Service Systems
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-7 Program Environmental Impact Report November 2025
Environmental Topic Proposed project
Alternative 1:

No project/
No Action
Alternative
Alternative 2:

No Project
/General Plan
Buildout
Alternative
Alternative 3:

Reduced Intensity
Alternative
Alternative 4:

Dispersed Facilities
Alternative
Water Supply LTS Less (no impact) Similar Less Less
Wastewater Treatment LTS Less (no impact) Greater Less Less Stormwater Drainage LTS Less (no impact) Similar Less Similar Electric Power LTS Less (no impact) Less Less Similar
Natural Gas LTS Less (no impact) Less Less Similar
Telecommunications LTS Less (no impact) Less Less Less
Solid Waste LTS Less (no impact) Similar Less Less
Source: UltraSystems, 2021.

Table Notes:

Similar= the alternative would have similar impacts as the project Less= the alternative would have a lesser impact than the project Greater= the alternative would have more of an impact than the project SU= Significant and Unavoidable Impact
LTS= Less than significant
LTS w/ Mit= Less than significant with mitigation
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-8 Program Environmental Impact Report November 2025
Table 5.4-3

COMPARISON OF ALTERNATIVES AND THEIR ABILITY TO MEET PROJECT OBJECTIVES Project Objective Proposed
Project
Alternative
1: No Project
Alternative
Alternative 2:

No
Project/General
Plan Buildout
Alternative
Alternative
3: Reduced
Intensity
Alternative
Alternative
4:

Dispersed
Facilities
Alternative

1. Provide health care capacity for Kaiser
Permanente members in the San BernardinoRedlands region.

Objective
Fully Met
Objective Not
Met
Objective Not
Met
Objective
Partially Met
Objective
Fully Met

2. Incorporate numerous sustainability features
such as vegetated swales, tree-based
infiltration, and inert bioswales; highperformance building enclosure systems, external shading, energy efficient and carbon
neutral building systems and equipment
selections, and solar panels. The buildings
will meet or exceed Leadership in Energy and
Environmental Design (LEED) Gold
certification.

Objective
Fully Met
Objective Not
Met
Objective
Partially Met
Objective
Fully Met
Objective
Fully Met

3. Develop the project site in accordance with the
Medical Facilities designation in Redlands
Business Center Concept Plan No. 1.

Objective
Fully Met
Objective Not
Met
Objective Not
Met
Objective
Partially Met
Objective
Not Met

4. Phase development over 25 years to keep
pace with projected increase in Kaiser
Permanente membership in the facility’s
service area over that period.

Objective
Fully Met
Objective Not
Met
Objective
Partially Met
Objective
Partially Met
Objective
Partially Met
Source: UltraSystems, 2021.
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-9 Program Environmental Impact Report November 2025

5.5 Analysis of Alternative 1 – No Project/No Development Alternative

5.5.1 Description of the Alternative
In accordance with the CEQA Guidelines, the No Project Alternative for a development project on an identifiable property consists of the circumstances under which the project does not proceed. Section 15126.6(e)(3)(B) of the CEQA Guidelines states in part that, “in certain circumstances, the No project Alternative means ‘no build’ wherein the existing environmental setting is maintained.” Accordingly, for the purposes of this analysis, Alternative 1, the No Project Alternative, assumes that the proposed project would not proceed. The existing medical office building onsite would remain operational. The balance of the site would remain vacant as is currently the case. Kaiser Permanente members in the service area of the proposed facility would continue traveling to Kaiser Permanente facilities in the cities of Fontana and Ontario.

5.5.2 Environmental Impacts

5.5.2.1 Aesthetics
Scenic Vistas
Under Alternative 1, the existing building would remain on the project site, and the project would not be developed. Thus, Alternative 1 would not result in an increase in height or mass of onsite structures, and existing views of, and across, the project site would remain the same. Therefore, Alternative 1 would not obstruct a scenic vista, and no impacts to scenic vistas would occur. Thus, impacts related to scenic vistas would be similar to those of the project, which would have no impacts to scenic vistas.

Visual Character and Scenic Resources
Construction
Under the No Project Alternative, no construction activities would occur; therefore, no changes in the visual character of the project site would result. Therefore, there would be no potential for the construction activities to affect the visual character of the area on a short-term or long-term basis under Alternative 1. Impacts of the proposed project relative to zoning and other regulations governing scenic quality would be less than significant. Impacts to such regulations would be reduced under Alternative 1 compared to those of the proposed project.

Operation
The No Project Alternative would not involve development of the vacant part of the project site.

Therefore, this alternative would have no impact on the existing visual character or quality of the site and its surroundings and impacts on visual character during operation would be less when compared to the less than significant impacts of the project.

Shading
The No Project Alternative would not create or cast new shadows on surrounding uses since new buildings would not be constructed on the project site. Existing shadows from the existing medical office building do not generate shadows on surrounding sensitive uses. Therefore, no shading  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-10 Program Environmental Impact Report November 2025
impacts would occur under Alternative 1. Thus, shading impacts under Alternative 1 would be less when compared to the less-than-significant impacts of the project.

Light and Glare
Construction
The No Project Alternative would not involve any demolition or construction activities. Therefore, Alternative 1 would not introduce light sources associated with construction equipment or construction-related equipment and materials that could cause glare. Artificial lighting is currently utilized onsite and in the surrounding area for security, parking, signage, architectural highlighting, and landscaping/decorative purposes. Streetlights and traffic on local streets also contribute to the ambient light levels in the area. No buildings with additional windows and lighting would be constructed under this alternative; therefore, no impacts to lighting and glare would occur under the No Project Alternative. Thus, light and glare impacts during construction would be less when compared to the less-than-significant impacts of the project.

Operation
The No Project Alternative would not alter the existing uses on the project site, introduce any new sources of light or glare on the project site, or otherwise increase the amount of activity occurring onsite. No operation-related light and glare impacts would occur under Alternative 1. Thus, impacts related to operational light and glare under Alternative 1 would be less in comparison to the lessthan-significant impacts of the project.

5.5.2.2 Air Quality
Construction
Regional Emissions
The No Project Alternative would not involve demolition of existing surface parking or construction of the proposed structures and other improvements. Therefore, this alternative would not result in any construction emissions from construction worker and construction truck traffic, fugitive dust from demolition and excavation, or the use of heavy-duty construction equipment, and constructionrelated regional air quality impacts would not occur. Thus, the No Project Alternative would eliminate the less-than-significant regional emissions impact of the project. Therefore, no construction-related air quality impacts would occur under Alternative 1, and impacts would be less than the less-than-significant impacts of the project.

Localized Emissions
The No Project Alternative would not result in any construction emissions, and construction-related localized air quality impacts would not occur. Thus, the No Project Alternative would eliminate the less-than-significant impacts of the project associated with localized emissions. Impacts of Alternative 1 would be less than the less-than-significant impacts of the project.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-11 Program Environmental Impact Report November 2025
Toxic Air Contaminants
Since construction activities would not occur on the project site, the No Project Alternative would not generate diesel particulate emissions during construction that could contain substantial toxic air contaminants (TACs). Therefore, no impacts associated with the release of TACs would occur under Alternative 1. Thus, TAC impacts under Alternative 1 would be less when compared to the less-thansignificant impacts of the project.

Operation
Regional Emissions
The No Project Alternative would not result in new development or increased operations that could generate additional operational emissions related to vehicular traffic or the consumption of electricity and natural gas beyond what is currently generated by the existing medical office building on the project site. Therefore, no operational impacts on regional air quality emissions would occur under Alternative 1. The No Project Alternative would avoid the regional emissions impacts of the project, which would be less than significant after mitigation. Thus, such impacts under Alternative 1 would be less than those of the project.

Toxic Air Contaminants
As analyzed in Section 4.2, Air Quality, the project would result in some TAC emissions, primarily from mobile sources. Since Alternative 1 would not result in new development or increase the intensity of the existing uses on the project site, no new increase in mobile source emissions would occur. No operational TAC emissions impacts would occur under Alternative 1, and such impacts would be less when compared to the less-than-significant impacts of the project.

5.5.2.3 Biological Resources
The No Project Alternative would not remove any vegetation, including existing shrubs and trees, or existing buildings on the project site. No new buildings would be constructed that may impact plant and/or wildlife species. The No Project Alternative would not cause indirect impacts on nesting birds from increased noise, vibration, and dust during construction and would not impact migratory nongame breeding birds. Therefore, this alternative would have no impact on biological resources, and impacts would be less when compared to those of the project, which would be less-than-significant after mitigation.

5.5.2.4 Cultural Resources
Archaeological Resources
Under the No Project Alternative, no demolition, grading, or other earthwork activities that could potentially affect subsurface archaeological resources would occur. Therefore, impacts on archaeological resources would not occur under Alternative 1, and impacts would be less compared to impacts of the project, which would be less than significant with mitigation incorporated.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-12 Program Environmental Impact Report November 2025
Historical Resources
Since this alternative would include no demolition or new construction and the medical office building would have no change in operations, there would be no impact on historical resources.

Therefore, impacts would be reduced compared to those of the proposed project, which would less than significant with mitigation incorporated.

5.5.2.5 Energy
Energy Use
Construction
Construction activities would not occur under the No Project Alternative. Therefore, Alternative 1 would not generate short-term energy demand during construction, and construction-related impacts on energy would not occur. Thus, short-term construction impacts under the No Project Alternative would be less when compared to the less-than-significant impacts of the project.

Operation
The No Project Alternative would not alter the existing land uses or operations on the project site. It would not develop a medical center onsite. Therefore, the No Project Alternative would not increase the long-term energy demand on the project site. Therefore, long-term operational impacts under the No Project Alternative would be less when compared to the less-than-significant impacts of the project.

5.5.2.6 Geology and Soils
Geology and Soils
The No Project Alternative would not involve soil disturbance or grading on the existing project site, and would not cause any degree of soil loss greater than under existing conditions. The potential for seismically-induced ground settlement, liquefaction, lateral spreading, expansive soils, and landslides would remain as they are described under Existing Conditions in Section 4.6, Geology and Soils, and in the Geotechnical Investigation (Appendix N) because those are the baseline conditions of the proposed project site. Therefore, the No Project Alternative would not cause or accelerate geologic hazards related to fault rupture, strong seismic shaking, liquefaction, seismically induced settlement, soil stability, subsidence, or expansive soils, which would result in substantial damage to structures or infrastructure or expose people to substantial risk of injury. No impacts related to geology and soils would occur under Alternative 1, and thus impacts would be less when compared to the less-than-significant impacts of the project.

Paleontological Resources
The No Project Alternative would not involve demolition, construction or soil disturbance on the project site, and therefore it would not cause potential impacts on paleontological resources due to construction. Alternative 1 would have a lesser impact on paleontological resources than the project, which would have less-than-significant impacts after mitigation.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-13 Program Environmental Impact Report November 2025

5.5.2.7 Greenhouse Gas Emissions
This alternative would include no construction or operation of land uses. Thus, no greenhouse gas (GHG) emissions would be generated by such construction or operation. However, in this alternative, Kaiser Permanente members in the service area of the proposed project would continue traveling to existing Kaiser Permanente facilities in the cities of Fontana and Ontario, slightly increasing use of motor fuels—and GHG emissions from such use—compared to the proposed project. Therefore, impacts associated with GHG emissions under the No project Alternative would be less when compared to the significant and unavoidable impacts of the project.

5.5.2.8 Hazards and Hazardous Materials
The No Project Alternative would not involve demolition, grading, or other construction activities.

Therefore, this alternative would not have the potential to uncover subsurface hazards. This alternative would not use or release hazardous materials, or generate hazardous waste, during construction. Construction impacts of this alternative would be less than those of the proposed project.

This alternative would involve continuing operation of the existing medical office building involving use, storage, and disposal of hazardous materials and medical wastes. Since Alternative 1 would not result in any changes to the current operation or configuration of the project site, no impacts would occur to the current emergency response or evacuation plans for the site. Impacts under the No Project Alternative would be reduced compared to the less-than-significant impacts of the project.

5.5.2.9 Hydrology and Water Quality
The No Project alternative would not add impervious surfaces to the project site; would not increase the generation of pollutants that could contaminate stormwater; and would not involve changes to drainage or groundwater recharge onsite. Impacts of this alternative on hydrology and water quality would be reduced by this alternative compared to the less-than-significant impacts of the proposed project.

5.5.2.10 Land Use and Planning
With this alternative no medical center would be developed on site. This alternative would have no land use or planning impacts. Under the No Project Alternative, there would be no changes to the physical or operational characteristics of the existing medical office building. No land use approvals or permits would be required. Therefore, Alternative 1 would not cause any conflicts with existing land use plans and policies that govern the project site. Impacts would be less than the less-thansignificant impacts of the project.

Redlands City CouncilApril 7, 2026

Redlands City Council
April 7, 2026