Redlands City Council
April 7, 2026

5.5.2.11 Noise
Construction
No new construction activities would occur under the No Project Alternative. Therefore, no construction-related noise or vibration would be generated onsite or offsite. Therefore, no onsite or offsite noise or vibration impacts would occur during construction under Alternative 1, and impacts would be less when compared to the less-than-significant impacts of the proposed project  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-14 Program Environmental Impact Report November 2025
Operation
The No Project Alternative would not develop new uses on the project site, and no changes to existing site operations would occur. Therefore, no new stationary or mobile noise sources would be introduced to the project site or the project vicinity. Therefore, no impacts associated with operational noise would occur under No Project Alternative, and long-term impacts would be less when compared to the less-than-significant impacts of the project.

5.5.2.12 Transportation
Construction
The No Project Alternative would not include demolition or the development of any new buildings onsite. Therefore, Alternative 1 would not generate vehicle trips associated with heavy-duty construction equipment, haul trucks, or construction worker vehicles. Thus, no construction-related traffic impacts would occur under the No Project Alternative, and the project's less-than-significant project-level construction traffic impacts would be eliminated. Construction impacts would be less when compared to those of the proposed project, which would be less than significant after mitigation.

Operation
Since the No Project Alternative would not develop new land uses on the project site, the operation of Alternative 1 would not generate any additional vehicle trips or alter existing access or circulation within the project site. Therefore, no impacts would occur with respect to operational traffic, including vehicle miles traveled; intersection levels of service; the regional transportation system; neighborhood intrusion; access and circulation; and bicycle, pedestrian, and vehicular safety.

Therefore, the No Project Alternative would also avoid the project's significant and unavoidable VMT impact. Impacts under the No Project Alternative would be less when compared to those of the project.

5.5.2.13 Tribal Cultural Resources
Grading and other earthwork activities would not occur under the No Project Alternative. Therefore, there would be no potential for Alternative 1 to uncover subsurface tribal cultural resources. No impacts on tribal cultural resources would occur, and impacts would be less than those of the proposed project, which would have less than significant impacts with mitigation incorporated.

5.5.2.14 Utilities and Service Systems
Water Supply
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, and, thus, would not increase water demand onsite.

Therefore, impacts related to water supply under the No Project Alternative would be less when compared to the less-than-significant impacts of the project.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-15 Program Environmental Impact Report November 2025
Wastewater
The No Project Alternative would not develop a medical center onsite and thus would not increase wastewater generation onsite. Therefore, impacts related to wastewater treatment under the No Project Alternative would be less when compared to the less-than-significant impacts of the project.

Stormwater Drainage
The project site is currently mostly vacant. This alternative would not involve the development of impervious areas on site as compared to the proposed project. Therefore, impacts related to stormwater drainage under the No Project Alternative would be reduced compared to the less-thansignificant impacts of the project.

Telecommunications
The No Project Alternative would not develop a medical center onsite. Therefore, the No Project Alternative would not increase the demand for telecommunication services on the project site.

Therefore, impacts related to telecommunications under the No Project Alternative would be less when compared to the less-than-significant impacts of the project.

Solid Waste Disposal
The No Project Alternative would not develop a medical center onsite. Therefore, the No Project Alternative would not increase solid waste generation onsite. Therefore, impacts related to solid waste disposal under the No Project Alternative would be less when compared to the less-thansignificant impacts of the project.

5.5.3 Comparison of Impacts
The No Project Alternative would eliminate the project’s significant and unavoidable construction transportation impact. The No Project Alternative would have similar impacts as the project for wildfire hazards. Impacts associated with the remaining environmental issues would be less than those of the proposed project. None of the impacts of this alternative would be considerably greater than those of the proposed project.

5.5.4 Relationship of the Alternative to Project Objectives Under the Alternative 1 - No Project Alternative, no new development would occur. Therefore, this alternative would not meet any of the project’s objectives. Specifically, this alternative would not:
• Provide health care capacity for Kaiser Permanente members in the San BernardinoRedlands region (objective 1). • Incorporate numerous sustainability features such as vegetated swales, tree-based infiltration, and inert bioswales; high-performance 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 2).
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-16 Program Environmental Impact Report November 2025
• Develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1 (objective 3).
• 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 4).

Overall, the No Project Alternative would not meet the project’s objectives of developing a medical center serving Kaiser Permanente members in the San Bernardino-Redlands region.

5.6 Analysis of Alternative 2 – No Project/General Plan Buildout Alternative

5.6.1 Description of the Alternative
In this alternative the proposed project is not developed. The existing medical office building remains present and in operation. This alternative assumes that the balance of the project site (28.15 acres) would be built out in accordance with the existing General Plan land use designation for the site, which is Commercial Industrial. The Commercial/Industrial land use category permits the development of certain types of commercial and light industrial uses. It includes flex commercial space as well as business parks. Uses permitted in this category include auto services, commercial retail and services, and manufacturing (City of Redlands, 2017, p. 4-11). The maximum floor area ratio in the Medical Facilities district is 0.6 (City of Redlands, 2017, p. 4-11). Thus, this alternative supposes development of the vacant part of the site with about 552,000 square feet of commercial and/or industrial uses.35 The maximum building height would be 150 feet (Urban Environs, 2004).

The EVCSP requires that at least 15 percent of Industrial land be used for landscaping (City of Redlands, 2017, p. D4-70). This alternative, if developed with industrial uses, would include at least 183,932 square feet of landscaping (28.15 acres x 43,560 square feet per acre x 15%). The proposed project, at buildout, would include 563,000 square feet of landscaping. Construction effort would be reduced in this alternative (552,000 square feet) compared to the proposed project (863,000 square feet plus six-level, 456,000-square-foot parking structure, or 1,319,000 square feet total).36

5.6.2 Environmental Impacts

5.6.2.1 Aesthetics
Scenic Vistas
Under Alternative 2, the existing building would remain on the project site, and the balance of the site would be developed with commercial or industrial uses. The maximum building height under this alternative would be 150 feet, compared to 122 feet for the proposed project. Thus, Alternative 2 would have greater impacts on scenic vistas compared to the proposed project.

Visual Character and Scenic Resources
Construction
35 In calculating potential land use intensity, the maximum intensity per the permitted floor area ratio, 735,728 square feet, was multiplied by 0.75; land is rarely built out to the maximum intensity permitted under General Plan and zoning policies. 36 The estimate of 456,000 square feet for the parking structure is based on footprint of 76,000 square feet (380 feet x 200 feet) x 6 levels.
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-17 Program Environmental Impact Report November 2025
Under the No Project/General Plan Buildout Alternative, construction effort onsite would be substantially reduced compared to that of the proposed project: 552,000 square feet of commercial or industrial uses for this alternative compared to 1.319 million square feet of medical center use for the proposed project. Thus, impact of construction on the visual character of the area on a short-term or long-term basis under Alternative 2 would be less than that of the proposed project.

Operation
It is expected that the commercial and industrial land uses developed in this alternative would contain less landscaping than the medical center would (see explanation in Section 5.6.1 above).

While the proposed project and this alternative are both expected to have beneficial impacts on visual character, beneficial impacts of the proposed project would be greater.

Shading
Shade and shadow impacts of this alternative would be greater than those of the proposed project, as maximum building height in this alternative would be 150 feet compared to 122 feet for the proposed project (107 feet roof height plus 15 feet roof equipment screen). Existing shadows from the existing medical office building do not fall on on surrounding sensitive uses. However, taller buildings would create more shade and shadow. Thus, shading impacts under Alternative 2 would be greater when compared to the less-than-significant impacts of the project.

Light and Glare
Construction
The No Project/General Plan Buildout Alternative would involve construction of commercial and/or industrial uses onsite. Most construction would occur during daylight, as construction would be limited to the hours construction and demolition work are permitted under City of Redlands Municipal Code Section 8.06.090 (Amlegal.com, 2025). No light sources are present in the vacant parts of the site. Construction effort in this alternative would be reduced compared to the proposed project. Thus, light and glare impacts during construction would be less when compared to the lessthan-significant impacts of the project.

Operation
Operation of this alternative would include lighting for safety and security purposes. The operating schedules of future commercial or industrial occupants are unknown; however, most such uses do not operate 24 hours per day. Such uses may include lighting for operational purposes. Operationrelated light and glare impacts would be reduced under Alternative 2 compared to the proposed project, a hospital that would operate 24 hours per day. Thus, impacts related to operational light and glare under Alternative 2 would be less in comparison to the less-than-significant impacts of the project.

5.6.2.2 Air Quality
Construction
Regional Emissions
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-18 Program Environmental Impact Report November 2025
The No Project/General Plan Buildout Alternative would involve a reduction in land use intensity of about 58 percent compared to the proposed project.37 However, the daily level of construction activity would be similar to that of the proposed project. Therefore, this alternative would result in about the same construction emissions from construction worker and construction truck traffic, fugitive dust from demolition and excavation, and use of heavy-duty construction equipment. Since the SCAQMD’s construction emission thresholds are in pounds per day, construction-related regional air quality impacts would be similar to those of the proposed project. Impacts would be less than significant in both scenarios.

Localized Emissions
This alternative would generate reduced construction emissions compared to the proposed project.

Impacts would be less than significant for both scenarios.

Toxic Air Contaminants
The No Project/General Plan Buildout Alternative would generate reduced diesel particulate emissions during construction that could contain substantial toxic air contaminants (TACs). TAC emissions impacts would be reduced by this alternative and would be less than significant in both scenarios.

Operation
Regional Emissions
This Alternative would reduce trip generation compared to the proposed project. Two land use scenarios were used in estimating daily trip generation for this alternative, using trip generation rates from the San Diego Association of Governments (SANDAG, 2002). For office park use trip generation is estimated at 12 trips per 1,000 square feet, or 6,624 trips; for industrial/business park use (including commercial use) trip generation is estimated at 16 trips per 1,000 square feet, or 8,832 trips. The proposed project is estimated to generate 16,093 trips per day. Therefore, operational impacts on regional air quality emissions would be reduced under this alternative and would be less than significant after mitigation for the proposed project.

Toxic Air Contaminants
As analyzed in Section 4.2, the project would result in some TAC emissions, primarily from mobile sources. Since this alternative involves reduced development intensity, mobile source emissions would be decreased. Operational TAC emissions impacts would be reduced under Alternative 2 and would be less than significant for both scenarios.

5.6.2.3 Biological Resources
This alternative would involve the removal of existing vegetation from the entire project site, as would the proposed project. Impacts of this alternative on biological resources would be similar to those of the proposed project and would be less than significant after mitigation for both scenarios. 37 The percent reduction in land use intensity compared to the proposed project includes the proposed parking structure (456,000 square feet) as part of the proposed project.
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-19 Program Environmental Impact Report November 2025

5.6.2.4 Cultural Resources
Archaeological Resources
Under the No Project/General Plan Buildout Alternative, the entire vacant part of the project site would be graded, as would occur with the proposed project. The depth of grading is expected to be more for this alternative compared to the proposed project due to the heights of buildings (122 feet proposed project, compared to 150 feet for this alternative); however, the difference in grading depth is expected to have little effect on impacts on archaeological resources. Impacts on archaeological resources of this alternative would be similar to those of the proposed project, and less than significant after mitigation for both scenarios.

Historical Resources
The analysis for archaeological resources also applies to historical resources. Therefore, the impacts would be similar to those resulting from the proposed project.

5.6.2.5 Energy
Energy Use
Construction
Construction effort would be reduced in this alternative compared to the proposed project (see explanation in Section 5.6.1). Therefore, Alternative 2 would generate less short-term energy demand during construction. Thus, short-term construction impacts under the No Project/Existing General Plan Alternative would be less when compared to the less-than-significant impacts of the project.

Operation
Operational energy demand by this alternative is expected to be less than that of the proposed project due to the reduced development intensity and because the commercial and/or industrial land uses in this alternative would most likely not operate 24 hours per day as the proposed hospital would.

Therefore, long-term operational impacts under this alternative would be less when compared to the less-than-significant impacts of the project.

5.6.2.6 Geology and Soils
Geology and Soils
The No Project/General Plan Alternative would involve soil disturbance and grading on the entire vacant part of the project site, as would the proposed project. Geology and soils impact of this alternative would generally be similar to those of the proposed project.

Paleontological Resources
The analysis of geology and soils impacts applies to paleontological resources impacts as well.

Impacts would be less than significant after mitigation for each of the two scenarios.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-20 Program Environmental Impact Report November 2025

5.6.2.7 Greenhouse Gas Emissions
Greenhouse gas (GHG) emissions under the No Project/General Plan Buildout Alternative are reasonably expected to be less than those of the proposed project. While the specific type, intensity, and mix of land uses under this alternative are not known, and project-level construction details are not available, for the purposes of this alternatives analysis this alternative is anticipated to require less construction activities due to fewer square feet of construction compared to the proposed project.

Similarly, this alternative is assumed to result in less operational emissions due to reduced landscaping and building square footage compared to the proposed project. On this basis, it is reasonable to assume that overall GHG emissions would be reduced compared to the significant and unavoidable impacts of the proposed project. However, any reduction of GHG impacts in comparison to the proposed project is expected to be minor and GHG impacts from this alternative are expected to remain significant and unavoidable.

5.6.2.8 Hazards and Hazardous Materials
Construction
Construction effort would be reduced in this alternative. Construction of commercial/industrial uses in this alternative would involve generally the same types of hazardous materials as construction of the proposed project would. Each scenario would involve soil disturbance on the entire project site.

Soils onsite could be contaminated with pesticide residues from historical agricultural use; impacts arising from such potential contamination would be similar for each scenario.

Operation
The specific land uses in this alternative, and the uses of hazardous materials by such land uses, are unknown. The commercial and/or industrial land uses in this alternative would not generate medical waste. Operational impacts are expected to be reduced by this alternative (if only because this alternative would not generate medical waste), and impacts would be less than significant for both scenarios.

5.6.2.9 Hydrology and Water Quality
This alternative may include less permeable area (landscaping) than the proposed project would, as explained above in Section 5.6.2.1. This analysis therefore assumes that impacts of this alternative on runoff and drainage would be greater for this alternative than for the proposed project. Each scenario would be required to comply with MS4 permit provisions mandating use of BMPs to infiltrate stormwater into soil (see Section 4.9). Thus, impacts of the two scenarios on groundwater recharge are expected to be similar and would be less than significant for both scenarios.

5.6.2.10 Land Use and Planning
Development of this alternative would conform with the existing General Plan land use designation for the project site, Commercial Industrial.. The proposed project also requires an amendment to Concept Plan 1 to modify the permitting procedure. Impacts of this alternative on land use and planning would be increased compared to those of the proposed project due to the change in land use; and would be less than significant for each of the two scenarios.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-21 Program Environmental Impact Report November 2025

5.6.2.11 Noise
Construction
Construction effort would be reduced under this alternative; thus, construction noise and vibration impacts would be reduced by this alternative compared to those of the proposed project; impacts would be less than significant in both scenarios.

Operation
Land use intensity would be reduced in this alternative; and onsite facilities would probably not operate 24 hours per day as the proposed project would. Thus, operational noise impacts would be reduced in this alternative compared to the less-than-significant impacts of the proposed project.

5.6.2.12 Transportation
Construction
Construction transportation impacts of this alternative would be reduced, due to less construction effort, compared to the proposed project (see discussion in Section 5.6.1). Construction transportation impacts would be less than significant for each of the two scenarios.

Operation
VMT under the No Project/General Plan Buildout is expected to be approximately equivalent to that of the proposed project. A quantitative VMT analysis for the No Project/General Plan Buildout Alternative cannot be conducted because the specific type, intensity, and distribution of land uses under this scenario are unknown.

However, this alternatives analysis assumes that the significant and unavoidable VMT impact identified for the proposed project would also occur under the No Project/General Plan Buildout Alternative. This assumption is based on the understanding that buildout consistent with the General Plan would likely generate substantial vehicle trips and associated VMT similar in scale to those of the proposed project. Therefore, VMT impacts from this alternative are expected to remain significant and unavoidable.

5.6.2.13 Tribal Cultural Resources
Under the No Project/General Plan Buildout Alternative, the entire vacant part of the project site would be graded, as would occur with the proposed project. Impacts on tribal cultural resources of this alternative would be similar to those of the proposed project, and less than significant after mitigation for both scenarios.

5.6.2.14 Utilities and Service Systems
This alternative would reduce water demand; increase wastewater generation; and reduce solid waste generation, compared to the proposed project; see Table 5.6-1 below. Impacts would be less than significant for both scenarios. Impacts on electricity and natural gas demands by this alternative are addressed above in Section 5.6.2.5. Impacts regarding telecommunications facilities are expected to be reduced by this alternative, as demands for telecommunications services by industrial  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-22 Program Environmental Impact Report November 2025
or commercial uses are expected to be substantially lower than those by the hospital and medical office uses in the proposed project. Impacts would be less than significant for each of the two scenarios.

Table 5.6-1

ESTIMATED UTILITIES DEMANDS, NO PROJECT/GENERAL PLAN BUILDOUT ALTERNATIVE Scenario Square
Feet
Utility Demand
Per 1,000 sq. feet Total
Water Demand
No Project/General Plan Buildout Alternative 552,000 250 gallons per day 138,000 gallons per day Proposed Project See Section 4.15 165,168 gallons per day Wastewater Generation
No Project/General Plan Buildout Alternative 552,000 200 gallons per day 110,400 gallons per day Proposed Project See Section 4.15 86,075 gallons per day Solid Waste Generation
No Project/General Plan Buildout Alternative 552,000 6 pounds per day 3,312 pounds per day Proposed Project See Appendix A1, Initial Study 6,063 pounds per day Source: Los Angeles County Sanitation Districts, 2025; UltraSystems, 2025

5.6.3 Comparison of Impacts
Evaluation of this alternative involves some uncertainty because the specific mix, intensity, and timing of land uses under full General Plan buildout are not known.

For greenhouse gas emissions, the No Project/General Plan Buildout Alternative is assumed to reduce emissions compared to the proposed project; however, impacts of this alternative are assumed to remain significant and unavoidable. This alternative is assumed to reduce impacts related to aesthetics, air quality, energy, hazards and hazardous materials, noise, and utilities.

Impacts under this alternative would generally be similar to those of the proposed project for biological resources, cultural resources, geology and soils, hydrology and water quality, transportation and tribal cultural resources. Impacts on land use and planning would likely be greater than those of the proposed project because General Plan buildout could allow more dispersed or incompatible development patterns compared against the proposed project. In summary, while the No Project/General Plan Buildout Alternative is anticipated to reduce certain environmental impacts, it would not avoid any of the proposed project’s significant and unavoidable impacts. The remaining environmental effects would be generally similar to or greater than those of the proposed project.

5.6.4 Relationship of the Alternative to Project Objectives Under the Alternative 2 - No Project/General Plan Buildout Alternative, the project site would be developed with 552,000 square feet of commercial and/or industrial uses rather than the proposed hospital and medical office uses. Therefore, this alternative would not meet any of the following project objectives (objectives 1 and 3) as shown on Table 5.4-3. • Provide health care capacity for Kaiser Permanente members in the San BernardinoRedlands region (objective 1).  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-23 Program Environmental Impact Report November 2025
• Develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1 (objective 3).

This alternative would only partially meet the following project objective (objectives 2 and 4):
• Incorporate numerous sustainability features such as vegetated swales, tree-based infiltration, and inert bioswales; high-performance 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 2).
• 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 4).

This alternative would partially meet objective #2 through compliance with the 2025 CALGreen. This alternative does not assume that the commercial or industrial buildings to be developed under this alternative would be designed to obtain LEED certification.

Overall, the No Project/General Plan Buildout Alternative would not meet the project’s objectives of providing health care capacity for Kaiser Permanente members in the San Bernardino-Redlands region.

5.7 Analysis of Alternative 3 – Reduced Intensity Alternative

5.7.1 Description of the Alternative
This alternative consists of reducing the intensity of the proposed project by deleting phases 3 and 4 from the project (see Table 5.7-1 below); and reducing the capacity of the proposed parking structure by 572 spaces, and the number of spaces allocated to phases 3 and 4. Thus, the parking structure would be reduced by about half, from 1,288 to 716 spaces. This alternative is intended to reduce the significant and unavoidable vehicle miles traveled impact of the proposed project. This analysis assumes that the parking structure would be reduced from seven levels in the proposed project (including one basement level) to four levels in this alternative (one at-grade level and three above-ground levels). Total square footage onsite at completion of this alternative would be 720,000 square feet compared to 983,000 square feet for the proposed project. In this alternative project trip generation would be reduced to 10,694 from 16,093 for the proposed project (see Table 5.7-2 below). In this alternative the footprints of phases 3 and 4 of the proposed project, which total 263,000 square feet, would be landscaped with native drought-tolerant vegetation.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-24 Program Environmental Impact Report November 2025
Table 5.7-1

SUMMARY, PROPOSED PROJECT COMPARED TO REDUCED INTENSITY ALTERNATIVE All areas in square feet
Phase Description
Total
Development
Area
Building Area
(per phase)
Total
Building
Coverage
Total
Landscaping
Proposed Project
Existing MOB 1 407,000 120,000 42,600 N/A
1 ASC/MOB 2 1,194,000 165,000 76,000 411,000
2 Hospital and Utilities
Plant
1,513,000 435,000 213,000 602,000
3 MOB 3 1,632,000 83,000 233,000 593,000
4 Hospital Addition 1,632,000 180,000 263,000 563,000
Total,
hospital
N/A 321 beds/580,000 square feet
Total,
medical
office
Not applicable 368,000 (248,000 SF proposed + 120,000 SF existing) Total Not applicable 983,000 (863,000 proposed plus 120,000 existing) Reduced Intensity Alternative
Existing MOB 1 (medical office) 407,000 120,000 42,600 N/A 1 ASC/MOB 2 1,194,000 165,000 76,000 411,000
2 Hospital (213 beds) and
Central Utilities
1,513,000 435,000 213,000 602,000
Total,
medical
office
N/A 285,000 (165,000 SF proposed + 120,000 SF existing) Total N/A 720,000 (600,000 proposed + 120,000 existing) Source: Masterplan Development Permit Submittal, June 29, 2023 Table 5.7-2

ESTIMATED TRIP GENERATION
Phase Land Use Trip Generation
Type Quantity Units Per unit Total
Proposed Project
1 Medical Office Building 165 1,000 square feet 36 5,940 2 Hospitala 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 Not
applicable
Not applicable Not
applicable
16,093
Reduced Intensity Alternative
1 Medical Office Building 165 1,000 square feet 36 5,940 2 Hospitala 213 Beds 22.32 4,754
Total Not applicable Not
applicable
Not applicable Not
applicable
10,694
a 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
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-25 Program Environmental Impact Report November 2025

5.7.2 Environmental Impacts

5.7.2.1 Aesthetics
The Reduced Intensity Alternative would include the tallest building included in the proposed project: the hospital building included in Phase 2, 122 feet including a 15-foot rooftop equipment screen. Impacts of this alternative on the visual character of the site and surroundings would be beneficial, as would impacts of the proposed project. Impacts of this alternative on scenic vistas would be slightly reduced due to the deletion of the four-story medical office building in Phase 3 and the five-story hospital addition in Phase 4. Light and glare impacts of this alternative would be generally similar to those of the proposed project. Most aesthetics impacts of this alternative would be similar to those of the proposed project except for the slightly reduced impacts on scenic vistas in this alternative.

5.7.2.2 Air Quality
Construction
Regional Emissions
Alternative 3 would reduce total building area by 263,000 square feet, or about 30 percent, compared to the proposed project. However, the daily level of construction activity would be similar to that of the proposed project. Therefore, this alternative would result in about the same construction emissions from construction worker and construction truck traffic, fugitive dust from demolition and excavation, and use of heavy-duty construction equipment. Since the SCAQMD’s construction emission thresholds are in pounds per day, construction-related regional air quality impacts would be similar to those of the proposed project. Impacts would be less than significant in both scenarios.

Localized Emissions
Daily localized construction emissions would be similar to those of the proposed project and would be less than significant for both scenarios.

Toxic Air Contaminants
The preceding analysis for localized emissions also applies to TAC emissions.

Operation
Regional Emissions
This alternative would reduce trip generation, and thus vehicle miles traveled (VMT), by about 34 percent compared to the proposed project (see Table 5.7-2 above). The generation of onroad criteria pollutants with this alternative would also be reduced by roughly the same percentage. Air quality impacts would therefore also be less than significant and reduced when compared to the less-thansignificant regional operational air quality impacts associated with the project.

Toxic Air Contaminants
The preceding analysis of regional operational emissions also applies to TAC emissions.  SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-26 Program Environmental Impact Report November 2025

5.7.2.3 Biological Resources
The Reduced Intensity alternative would involve the same development footprint and thus would have the same impacts on biological resources as the proposed project. Impacts to biological resources would be less than significant after mitigation in both scenarios.

5.7.2.4 Cultural Resources
This alternative would involve the same development footprint and excavation depth as that for the proposed project, except that no excavation and grading for building pads would be conducted on the sites of phases 3 and 4 of the proposed project. Therefore, impacts of this alternative to historical and archaeological resources and human remains would be slightly reduced compared to impacts of the proposed project, and would be less than significant after mitigation in both scenarios.

5.7.2.5 Energy
Energy Use
Construction
Construction energy use by this alternative would be reduced compared to the proposed project due to the reduced construction effort.

Operation
Operation of this alternative with respect to building energy use and appliances would demand less electricity and natural gas than the proposed project; it is assumed here that energy use would be proportional to the land use intensity of the two scenarios, and intensity of this alternative is about 30 percent lower than that of the proposed project (see Table 5.7-1). This alternative would reduce operational trip generation by approximately 34% compared to the proposed project (see Table 5.7- 2), thus reducing transportation fuel use compared to the proposed project. Overall, energy use impacts would be reduced by this alternative compared to the proposed project and would be less than significant in both scenarios.

Plans for Renewable Energy or Energy Efficiency
The Reduced Intensity Alternative and the proposed project would both comply with plans for renewable energy and/or energy efficiency, including the City of Redlands General Plan. Impacts respecting such plans would be similar, and less than significant, for both scenarios.

5.7.2.6 Geology and Soils
Geology and Soils
This alternative would involve a reduced development footprint compared to the proposed project.

The Modified Land Use Alternative would also be subject to the same City of Redlands building code requirements as that of the proposed project. Therefore, the impacts of Alternative 3 related to geology and soils would be similar to those of the proposed project, that is, less than significant for both scenarios.
 SECTION 5.0 – ALTERNATIVES 
7214/Redlands – Kaiser Permanente Medical Center Page 5-27 Program Environmental Impact Report November 2025
Paleontological Resources
Impacts of Alternative 3 on paleontological resources would be slightly reduced compared to those of the proposed project because of the reduced grading and excavation in the footprints of phases 3 and 4 of the proposed project. Impacts would be less than significant after mitigation for both scenarios.

5.7.2.7 Greenhouse Gas Emissions
Development of Alternative 3 would involve reduced construction effort as for the proposed project, and therefore would use less energy as would construction of the proposed project. The change in land use intensity would reduce VMT by approximately 34 percent during the operational phase.

With the reduced VMT, the mobile source GHG emissions would also decrease, thereby leading to a decrease in total operational GHG emissions. However, GHG emissions by the proposed project are estimated to be 14,306 metric tons of CO2e per year (see further discussion in Section 4.7).

Supposing the reduction in operational GHG emissions by this alternative were proportional to the reduction in VMT compared to the proposed project, GHG emissions by this alternative would be about 9,442 metric tons annually, still over the 3,000-metric-ton threshold. Thus, GHG emissions impacts of this alternative would remain significant and unavoidable

5.7.2.8 Hazards and Hazardous Materials
Construction of this alternative would use less hazardous materials due to the reduced construction effort. In each scenario hazardous materials would be used, stored, transported, and disposed of in accordance with existing regulations.

Operation of this alternative would generate less medical waste than would the proposed project due to the reduced development intensity. In both scenarios medical wastes would be stored, transported, and disposed of in accordance with federal, state, and county regulations. Hazardous materials impacts of this alternative would be slightly reduced compared to proposed project impacts and would be less than significant in both scenarios.

5.7.2.9 Hydrology and Water Quality
The amount of landscaping at project completion in this alternative would be increased to 723,000 square feet, 160,000 square feet greater than that for the proposed project. Thus, impacts related to runoff, drainage, and groundwater recharge would be reduced by this alternative. Impacts related to stormwater quality would also be reduced by this alternative because more space would be available for treatment and control BMPs. Impacts would be less than significant for both scenarios.

5.7.2.10 Land Use and Planning
The Reduced Intensity Alternative would conform with City of Redlands General Plan and zoning code, requirements for the project site, as would the proposed project. Impacts would be less than significant in each of the two scenarios.
 SECTION 5.0 – ALTERNATIVES 
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5.7.2.11 Noise
Construction
This alternative would involve reduced construction effort by about 30 percent compared to the proposed project. Therefore, construction noise and vibration impacts under this alternative would be decreased compared to those of the proposed project, which would be less than significant.

Operation
This alternative would reduce trip generation by about 34 percent, that is, 5,399 trips per day, compared to the proposed project. Trip generation, for this alternative as well as the proposed project, would be distributed over several roadways so that project trip generation on any one roadway would be a rather small fraction of 5,399 trips (Fehr & Peers, 2025, Figure 4). Daily traffic volumes in 2015 on the segment of California Street fronting the project site were 10,136; and 2,695 on the segment of Lugonia Avenue fronting the site (City of Redlands, 2023). Traffic volumes would need to be reduced by 50 percent for the reduction in traffic noise to be noticeable. The reductions in traffic volumes would be less than 50 percent; thus, the decrease in traffic noise would not be noticeable.

Operational noise by mechanical equipment on the proposed buildings in this alternative would be reduced due to the reduced building area. Overall, operational noise impacts of this alternative would be very slightly reduced compared to those of the proposed project and would be less than significant in both scenarios.

5.7.2.12 Transportation
Operation of the Reduced Intensity Alternative would generate 34 percent fewer vehicle trips than the proposed project would. VMT is calculated from two components: the number of trips generated; and the average trip length. This alternative is not expected to change the average trip length compared to the proposed project. The threshold and project VMT are both measured in VMT per employee. Therefore, it is expected that project VMT would remain significant and unavoidable for this alternative, as it would be for the proposed project.

5.7.2.13 Tribal Cultural Resources
In this alternative the development footprint would be reduced by 263,000 square feet, that is, about 16 percent of the development area of the proposed project. The reduced area would be landscaped in this alternative, involving shallow ground disturbance with less potential to damage tribal cultural resources than excavations for buildings would. Thus, impacts on tribal cultural resources would be slightly reduced in this alternative and would be less than significant after implementation of mitigation for each of the two scenarios.

5.7.2.14 Utilities and Service Systems
Water Supply
Alternative 3 would involve reduced construction effort, and thus reduced construction water demand, compared to the proposed project. Operation of Alternative 3 would generate reduced water demand compared to the proposed project; the reduction is assumed to be proportional to the  SECTION 5.0 – ALTERNATIVES 
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reduction in building area (600,000 square feet for this alternative compared to 863,000 square feet for the proposed project, or about 30 percent). Water supply impacts would be less than significant for both scenarios.

Wastewater
The preceding water demand analysis also applies to wastewater generation.

Stormwater Drainage
Alternative 3 would have reduced impacts on runoff and drainage compared to the proposed project due to the increased landscaping area in this alternative; impacts would be less than significant for each scenario.

Electricity and Natural Gas
Electricity and natural gas demands by this alternative would be reduced due to the reduced building area; impacts would be less than significant for this alternative as well as for the proposed project.

Telecommunications
The preceding analysis also applies to impacts on telecommunications facilities.

Solid Waste Disposal
The analysis of water demand impacts above also applies to solid waste disposal.

5.7.3 Comparison of Alternative to the Proposed project The Reduced Intensity Alternative, compared to the project, would reduce impacts on air quality, energy, greenhouse gas emissions, hydrology and water quality, noise, transportation, and utilities and service systems. Impacts on aesthetics, biological resources, cultural resources, geology and soils, land use and planning, and tribal cultural resources would be similar to those of the proposed project. No impacts would be increased by this alternative compared to the proposed project.

5.7.4 Relationship of the Alternative to Project Objectives Under the Alternative 3 - Reduced Intensity Alternative, the following project objective (objective 2) would be fully met as shown on Table 5.4-3:
• Incorporate numerous sustainability features such as vegetated swales, tree-based infiltration, and inert bioswales; high-performance 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 2).

The following objectives (objectives 1, 3, and 4) would be partially met:
 SECTION 5.0 – ALTERNATIVES 
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• Provide health care capacity for Kaiser Permanente members in the San BernardinoRedlands region (objective 1). • Develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1 (objective 3).
• 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 4).

5.8 Analysis of Alternative 4 – Dispersed Facilities Alternative

5.8.1 Description of the Alternative
This alternative consists of development of approximately six small medical office facilities in the San Bernardino–Redlands region (the service area for the proposed project). The alternative was devised to reduce the significant and unavoidable transportation (vehicle miles traveled, or VMT) impact of the proposed project by distributing outpatient care across multiple locations. For comparison, existing Kaiser Permanente medical office facilities are located in Redlands (at the proposed project site), San Bernardino, and Colton. Additional small facilities under this alternative would be located within the region, including the cities of San Bernardino, Redlands, Highland, Colton, and Yucaipa, as well as surrounding unincorporated areas of San Bernardino County. In-patient care, including surgeries, intensive care, and critical care, would continue to be provided at existing Kaiser Permanente hospitals in Ontario and Fontana.

Although use of multiple smaller facilities could result in increased VMT for Kaiser Permanente staff traveling between sites, it is anticipated that overall VMT reductions would result from shorter average patient travel distances. Thus, reductions in patient travel are the principal means by which this alternative could reduce VMT compared to the proposed project.

The total building area of the six small facilities would be somewhat less than the approximately 1.32 million square feet of the proposed project (including a 456,000-square-foot parking structure).

Excluding the parking structure, the proposed project would contain 863,000 square feet of building space. This alternative assumes the six small facilities would collectively total about 75 percent of that building area—approximately 650,000 square feet. Each small facility would therefore be expected to be about 100,000 to 125,000 square feet, not including any required parking.

It is assumed that most of the small facilities would involve redevelopment or reuse of existing buildings, and that no greenfield development (i.e., development on currently vacant land) would occur. Facility sites would likely be located in areas already developed with medical, medical office, and/or commercial uses.

5.8.2 Environmental Impacts

5.8.2.1 Aesthetics
In this alternative the medical center on 28.15 acres of the proposed project site would not be developed, and that site would remain vacant. This alternative assumes that the small facilities sites would probably be surrounded by existing medical, medical office, and/or commercial uses.

Therefore, the small facilities would be visually compatible with surrounding land uses. Impacts of this alternative on scenic vistas would be reduced, as the facilities would be smaller than the  SECTION 5.0 – ALTERNATIVES 
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proposed medical center that includes buildings up to 122 feet high. While the facilities in this alternative would include outdoor lighting (exterior building lighting, signage, and parking lot lighting), the facilities would be sited within urban areas with substantial outdoor lighting; thus, development of these facilities would not cause substantial light and glare impacts. Aesthetics impacts of this alternative would be less than significant and would be reduced compared to impacts of the proposed project.

5.8.2.2 Air Quality
Construction
Regional Emissions
Although the total building area for this alternative would be about 650,000 square feet compared to

1.32 million square feet for the proposed project,38 the amount of construction on a given day would be comparable to that of the proposed project. Therefore, short-term regional emissions would be similar to those of the proposed project. Construction impacts on air quality would be less than significant for both scenarios.

Localized Emissions
The amount of construction on a given day would be comparable to that of the proposed project.

Therefore, localized emissions would be similar to those of the proposed project.. Localized construction impacts on sensitive receptors would be less than significant under both the proposed project and Alternative 4.

Toxic Air Contaminants
The amount of construction on a given day would be comparable to that of the proposed project.

Therefore, TAC emissions would be similar to those of the proposed project.. TAC impacts on sensitive receptors would be less than significant under both the proposed project and Alternative 4.

Operation
Regional Emissions
VMT under this Alternative is expected to be approximately equivalent to that of the proposed project. Overall, this alternative could reduce VMT compared to the proposed project by potentially shortening average patient travel distances to medical facilities. However, the degree of reduction cannot be reliably quantified as the location of these facilities is unspecified. Further, because staff would need to travel between and among multiple smaller facilities (as compared to travelling to the one, centralized location in the proposed project), VMT associated with employee trips would be expected to increase.

For the purposes of this alternatives analysis, this Alternative is assumed to reduce VMT in comparison to the proposed project. However, any reduction of VMT in comparison to the proposed project is expected to be minor and VMT impacts from this alternative are expected to remain 38 The square footage estimate for this alternative omits parking structures. Parking configurations for this alternative are unknown; therefore, any attempt to estimate building area of potential parking structures would be speculative.  SECTION 5.0 – ALTERNATIVES 
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significant and unavoidable. If reductions in VMT were to occur, corresponding decreases in on-road criteria pollutant emissions would also be expected, but the magnitude of such reductions is unknown. Given that air quality impacts of the proposed project are less than significant, they would remain less than significant under this alternative regardless of whether VMT is reduced.

Toxic Air Contaminants
In this alternative TAC emissions are expected to be reduced slightly. More importantly, TAC emissions would be distributed across the region due to the development of several small facilities.

TAC emissions impacts would be reduced by this alternative and would be less than significant for both scenarios.

5.8.2.3 Biological Resources
Sites of the small facilities under this alternative were not identified. This alternative assumes that the small facilities would most likely be redeveloped; or existing buildings will be reused, and no greenfield development would occur. It is also assumed that most of the small facilities would be located next to existing medical, medical office, and/or commercial uses. Terrestrial impacts (that is, impacts on biological resources on the ground) are expected to be reduced by this alternative, as this alternative is expected to consist of redevelopment or reuse. Facilities sites in this alternative are expected to include trees and other vegetation that could be used by birds for nesting. Thus, this alternative is expected to require mitigation to reduce impacts on nesting birds to less than significant. Impacts would be less than significant after mitigation for both scenarios.

5.8.2.4 Cultural Resources
Development sites in this alternative are expected to be redeveloped or there would be reuse of sites where soil has been disturbed by previous development. Thus, impacts on resources that could be buried in site soils would be reduced by this alternative. Regarding impacts on built environment cultural resources, a phase 1 cultural resources inventory would be required for each site in this alternative; and mitigation would be required for any significant impacts identified. Impacts would be reduced by this alternative compared to impacts of the proposed project (due to reduction of impacts on resources potentially buried in soil); and would be less than significant after mitigation for both scenarios.

5.8.2.5 Energy
Energy Use
Construction
Development of this alternative would involve less construction effort than would the proposed project and therefore would use less energy than would construction of the proposed project.

Operation
The total building area of the small facilities under this alternative is expected to be less than that of the proposed project. As a result, overall electricity and natural gas demand for building operations (lighting, HVAC, appliances) would likely be lower. This alternative could also reduce operational trip generation due to shorter patient travel distances; however, as discussed in the transportation analysis, the extent of any VMT reduction is uncertain. Increased staff travel between multiple  SECTION 5.0 – ALTERNATIVES 
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facilities is anticipated to offset some patient travel reductions. For the purposes of this alternatives analysis, the overall VMT—and the associated transportation energy use—is assumed to be less for this Alternative than the proposed project.

This alternative is assumed to result in somewhat reduced building-related energy use and levels of transportation-related energy demand. Therefore, overall energy consumption under this alternative is assumed to be modestly less than, that of the proposed project. In either this Alternative or the proposed project, however, energy impacts would remain less than significant.

The small facilities in this alternative are expected to include solar arrays, as would the proposed project. This alternative and the proposed project would both comply with plans for renewable energy and/or energy efficiency. Impacts respecting such plans would be similar, and less than significant, for both scenarios.

5.8.2.6 Geology and Soils
Geology and Soils
This alternative consists of the development of several small facilities on redevelopment sites or through reuse of existing buildings. The locations of the facilities are unknown; thus, geologic conditions on the sites are unknown and cannot be compared to those of the proposed project. As with the proposed project, the design and construction of facilities in this alternative would be mandated to comply with requirements of the California Department of Health Care Access and Information, and of the California building standards codes. Impacts of this alternative regarding geologic and seismic hazards would be similar to those of the proposed project and less than significant for both construction and operation.

Paleontological Resources
It is assumed that the small facilities in this alternative would be developed on sites where soils would already have been disturbed by previous development; thus, impacts of this alternative on paleontological resources would be reduced compared to those of the proposed project and less than significant after implementation of project design features and mitigation for both scenarios.

5.8.2.7 Greenhouse Gas Emissions
Development of this alternative would involve less construction effort than the proposed project and therefore would use less energy than would construction of the proposed project. Operation of this alternative would generate less GHG emissions than the proposed project due to both decreased building area and decreased trip generation. This alternative would reduce GHG emissions impacts compared to the significant-and-unavoidable impacts of the proposed project. This analysis assumes that GHG emissions by this alternative would remain above the 3,000-metric-ton CO2e threshold and would therefore be significant and unavoidable.

5.8.2.8 Hazards and Hazardous Materials
Existing conditions on and near the sites of the small facilities in this alternative are unknown. Thus, impacts regarding existing hazardous materials on and near the sites of the facilities cannot be compared to those of the proposed project.
 SECTION 5.0 – ALTERNATIVES 
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As with the proposed project, medical wastes generated by this alternative would be stored, transported, and disposed of in accordance with federal, state, and county regulations. Hazardous materials impacts of this alternative would be slightly reduced compared to proposed project impacts and would be less than significant in both scenarios.

5.8.2.9 Hydrology and Water Quality
Existing hydrology and water quality conditions at facilities sites for this alternative are unknown and thus cannot be compared to those of the proposed project site. The design, construction, and operation of facilities in this alternative would be mandated to meet the same regulatory requirements as would the proposed project.:preparation and implementation of a SWPPP for project construction, and preparation and implementation of a WQMP for project design and project operation. Construction and operational impacts of this alternative are expected to be slightly reduced compared to those of the proposed project due to the slightly reduced building area in this alternative. Impacts of this alternative on hydrology and water quality would be less than significant, as would impacts of the proposed project.

5.8.2.10 Land Use and Planning
The General Plan and zoning designations for facilities sites in this alternative are unknown.

However, it is expected that this alternative would involve choices of sites where the general plan and zoning designations permitted medical office and outpatient health care uses, and, therefore, general plan amendments and zone changes would not be required. Impacts are expected to be less than significant for this alternative and similar to the less-than-significant impacts of the proposed project.

5.8.2.11 Noise
Construction
This alternative would involve reduced construction effort on dispersed sites compared to the proposed project. Therefore, construction noise and vibration impacts under this alternative would be less than those of the proposed project and would be less than significant for both scenarios.

Operation
Operational noise impacts of this alternative would be reduced due to the reduction in building area and would be less than significant in both scenarios. While the project sites in this alternative have not been chosen and thus the distances from each site to the nearest sensitive receptors cannot be determined, this analysis assumes that operational noise impacts would be less than significant.

5.8.2.12 Transportation
Construction
Construction transportation impacts of this alternative would be reduced compared to those of the proposed project both due to the overall slight reduction in building area in this alternative; and because construction trips in this alternative would be to and from six dispersed sites instead of one large project site.
 SECTION 5.0 – ALTERNATIVES 
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Operation
A VMT analysis for this alternative is not possible because the locations of the small facilities have not been identified, and therefore trip distribution patterns and travel behaviors cannot be reliably estimated. While it is reasonable to assume that patient trip lengths could decrease with facilities dispersed throughout the region, VMT associated with Kaiser Permanente staff is anticipated to increase due to travel between and among multiple facilities. The overall magnitude of change is unknown and not anticipated to be substantial when compared to the proposed project.

For the purposes of this alternatives analysis, this Alternative is assumed to reduce VMT in comparison to the proposed project. However, any reduction of VMT in comparison to the proposed project is expected to be minor and VMT impacts from this alternative are expected to remain significant and unavoidable, as with the proposed project.

5.8.2.13 Tribal Cultural Resources
This alternative would involve development of six small sites in the eastern Upper Santa Ana River Valley that are expected to have been previously disturbed. By comparison, the proposed project would involve development of 28.15 acres of vacant land. Thus, impacts of this alternative on tribal cultural resources would be reduced compared to those of the proposed project and would be less than significant after mitigation for both scenarios.

5.8.2.14 Utilities and Service Systems
Utilities demand by this alternative is expected to be somewhat reduced (see the discussion of building area for this alternative compared to the proposed project above in Section 5.8.1). This alternative would not involve installation of utilities, laterals and mains on the 28.15-acre proposed project site. This alternative assumes that the dispersed facilities would be developed on alreadydeveloped sites served by utilities. Thus, regarding installation of infrastructure, this alternative at most would involve installation of laterals from existing mains next to the sites; or upsizing of existing laterals with laterals accommodating proposed facilities utility demands. Impacts would be less than significant for this alternative as well as for the proposed project. This analysis applies to water supplies, wastewater conveyance and treatment, electric power, natural gas, telecommunications, and solid waste disposal.

Stormwater Drainage
This alternative would not involve development of the proposed project site and instead would develop several small facilities on redevelopment or reuse sites. Development of each site in this alternative would be required to comply with the MS4 Permit, through implementation of LID BMPs, as the proposed project would. Overall storm drainage impacts would be similar in this alternative to those of the proposed project, just spread over several smaller sites in this alternative.

Wildfire
In this alternative it is expected that the small facilities would be developed in urbanized portions of the cities of San Bernardino, Redlands, Highland, Colton, and Yucaipa. Most of those areas are outside of fire hazard severity zones. Thus, it is expected that facilities in this alternative would be developed outside of fire hazard severity zones. No significant impact respecting wildfire risk is expected to occur in either scenario.
 SECTION 5.0 – ALTERNATIVES 
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5.8.3 Comparison of Alternative to the Proposed project The Dispersed Facilities Alternative, compared to the proposed project, would generally be expected to reduce impacts related to aesthetics, air quality, biological resources, cultural resources, energy, noise, utilities and service systems, and wildfire. Impacts on geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, and land use and planning would likely be similar to those of the proposed project. With respect to transportation, and specifically vehicle miles traveled (VMT), evaluation of this alternative involves some uncertainty because the locations of the small facilities have not been identified, and therefore trip distribution patterns and travel behaviors cannot be reliably estimated. As discussed in the VMT section, while it is reasonable to assume that patient trip lengths could decrease with facilities dispersed throughout the region, VMT associated with Kaiser Permanente staff is anticipated to increase. For the purposes of this alternatives analysis, this Alternative is assumed to result in some reduction in VMT in comparison to the proposed project, but VMT impacts are expected to remain significant and unavoidable.

In summary, while the Dispersed Facilities Alternative is anticipated to reduce certain environmental impacts, it would not avoid any of the proposed project’s significant and unavoidable impacts. The remaining environmental effects would be generally similar to those of the proposed project.

5.8.4 Relationship of the Alternative to Project Objectives Under the Alternative 4 - Dispersed Facilities Alternative, the following project objective (objectives 1 and 2) would be fully met as shown on Table 5.4-3:
• Provide health care capacity for Kaiser Permanente members in the San BernardinoRedlands region (objective 1). • Incorporate numerous sustainability features such as vegetated swales, tree-based infiltration, and inert bioswales; high-performance 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 2).

The following objective (objective 4) would be partially met:
• 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 4).

The following objective (objective 3) would not be met:
• Develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1 (objective 3).

5.9 Environmentally Superior Alternative
Section 15126.6(e)(2) of the CEQA Guidelines indicates that an analysis of alternatives to a project shall identify an Environmentally Superior Alternative among the alternatives evaluated in an EIR.

The CEQA Guidelines also state that should it be determined that the No Project/No Build Alternative  SECTION 5.0 – ALTERNATIVES 
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is the Environmentally Superior Alternative, the EIR shall identify another Environmentally Superior Alternative among the remaining alternatives.

With respect to identifying an Environmentally Superior Alternative among those analyzed in this Draft PEIR, the range of feasible alternatives includes the No Project Alternative; the No Project/General Plan Buildout Alternative; the Reduced Intensity Alternative; and the Dispersed Facilities Alternative.

Table 5.4-1 above provides a summary of the description of alternatives and a comparison of the different project components with the alternatives. 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 objectives of the project.

A more detailed description of the potential impacts associated with each alternative is provided above.

Pursuant to § 15126.6(c) of the CEQA Guidelines, the analysis below addresses the ability of the alternatives to "avoid or substantially lessen one or more of the significant effects" of the project.

As shown in the analysis above, of the alternatives analyzed in this Draft PEIR, Alternative 1, the No Project Alternative would avoid all the project's significant environmental impacts, including the project's significant and unavoidable GHG and construction noise impacts. Although Alternative 1 would reduce most of the project's less-than-significant and less-than-significant-with-mitigation impacts, it would not meet any of the project's objectives.

In accordance with the CEQA Guidelines requirement to identify an Environmentally Superior Alternative other than the No Project/No Build Alternative, a comparative evaluation of the remaining alternatives as shown in the analysis above indicates that Alternative 3, the Reduced Intensity Alternative, would be the Environmentally Superior Alternative. The Reduced Intensity Alternative would reduce impacts of the project related to construction and operational toxic air contaminants; operational regional air pollutant emissions; construction noise and vibration; and operational noise impacts. All other impacts of this alternative would be similar to those of the proposed project. Alternative 3 would comparatively reduce the significant and unavoidable impacts of the proposed project (GHG emissions and VMT). However, Alternative 3’s GHG and VMT impacts would remain significant and unavoidable. No impacts of Alternative 3 would be greater than those of the proposed project.

Alternative 3 would fully meet one of the four objectives for the project. It would fully meet objective 2 as shown in Table 5.4-3 and below.
• Incorporate numerous sustainability features such as vegetated swales, tree-based infiltration, and inert bioswales; high-performance 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 2).

Alternative 3 would partially meet three of the four objectives for the project. The following objectives (objectives 1, 3, and 4) would be partially met:
• Provide health care capacity for Kaiser Permanente members in the San BernardinoRedlands region (objective 1). • Develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1 (objective 3).
• 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 4).  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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6.0 OTHER CEQA CONSIDERATIONS

6.1 Significant Unavoidable Impacts
This section includes a description of the significant and unavoidable impacts of the proposed project.

Section 15126.2(b) of the State CEQA Guidelines requires that the EIR describe any significant impacts, including those that can be mitigated but not reduced to less-than-significant levels.

Section 15126.2(b) of the State CEQA Guidelines is written as follows:

Significant Environmental Effects Which Cannot Be Avoided if the Proposed Project is Implemented. Describe any significant impacts, including those which can be mitigated but not reduced to a level of insignificance. Where there are impacts that cannot be alleviated without imposing an alternative design, their implications and the reasons why the project is being proposed, notwithstanding their effect, should be described.

Potential environmental effects of the proposed project and proposed mitigation measures are discussed in Sections 4.1 through 4.15. This PEIR determined that there would be unavoidable significant adverse impacts related to greenhouse gas emissions (Section 4.7) due to exceeding SCAQMD emission thresholds and transportation (Section 4.12) due to an increase of vehicle miles traveled (VMT) above the City’s thresholds. After implementation of mitigation measures, the proposed project would still have significant GHG thresholds and VMT impacts, which would necessitate the adoption of a Statement of Overriding Considerations.

6.1.1 Greenhouse Gas Emissions
As discussed in Section 4.7 of this Draft PEIR, the proposed project would generate an estimated 3,492.8 metric tons per year and 14,306 metric tons per year during construction and operational phases, respectively, which would exceed the SCAQMD threshold of 3,000 MTCO2e per year. The project includes MM GHG-1, which must be implemented during both the construction and operational phases of the project. During construction, the project shall incorporate a variety of GHGreducing practices as recommended by the California Air Pollution Control Officers Association (CAPCOA). These measures include the use of alternative fuels and electric or hybrid construction equipment, which may reduce emissions by up to 22 percent and 80 percent, respectively, if used consistently. Additional practices include limiting equipment idling, instituting a heavy-duty offroad vehicle plan, and implementing a vehicle inventory tracking system to ensure compliance. During project operation, GHG emissions are expected to primarily result from mobile sources, such as employee and visitor trips. To mitigate these emissions, the project will implement vehicle miles traveled (VMT) reduction strategies based on the accompanying traffic study. These include commute trip reduction marketing (4 percent Home-Base Work (HBW) VMT reduction), employee rideshare programs (4 percent HBW VMT), installation of end-of-trip bicycle facilities (0.3 percent HBW VMT), employer-sponsored vanpool services (1.6 percent HBW VMT), and a multiplicative dampening adjustment (0.6 percent). However, with implementation of mitigation measures, the project would still exceed SCAQMD thresholds, resulting in significant and unavoidable impacts.

6.1.2 Transportation
As discussed in Section 4.12 of this Draft PEIR, the proposed project would generate approximately 16,093 trips per day. The Transportation Study prepared for the project determined that the proposed project’s VMT per employee ratio is 12 percent higher than the City’s VMT threshold (Fehr & Peers, 2025). The proposed project would implement MM TRANS-1 to MM TRANS-4, which would  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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incorporate VMT reducing programs such as a commute trip reduction program, a ridesharing program for employees, installation and maintenance of end-of-trip facilities for employee use, and implement an employer-sponsored vanpool service. The four mitigation measures for VMT combined are estimated to reduce project VMT by 9.9 percent. Therefore, impacts associated with VMT would still remain significant and unavoidable.

6.2 Reasons Why the Project is Being Proposed, Notwithstanding Significant Unavoidable Impacts
In addition to identification of a project’s significant unavoidable impacts, Section 15126.2(c) of the CEQA Guidelines requires that an EIR describe the reasons why a project is being proposed, notwithstanding the effects of the identified significant and unavoidable impacts. The reasons why the proposed project has been proposed are included in Section 2.0, of this Draft PEIR and are summarized below.

The underlying purpose and objectives of the project are closely linked to the City’s need to provide additional hospital services to better serve residents in the project vicinity. The nearest Kaiser Permanente acute care hospital is located in the city of Fontana, approximately 12 miles west of the project site. Additionally, beyond the existing medical office building, the remainder of the project site is undeveloped. The proposed project would improve the underutilized project site to provide additional hospital and other medical services for the City and surrounding area. Therefore, the benefits of the proposed project would outweigh significant and unavoidable impacts of the project.

Additionally, as discussed in the Alternatives section, the No Project/No Action Alternative would not achieve any of the project’s objectives of providing additional hospital services. The Reduced Intensity Alternative would partially achieve the project objectives but would not fully utilize the undeveloped and disturbed areas of the project site, which would not be beneficial if they were not developed.

6.3 Significant Irreversible Environmental Changes
Section 15126.2(d) of the State CEQA Guidelines requires that an EIR discuss “any significant irreversible environmental changes which would be involved in the proposed project should it be implemented.” It defines an irreversible impact as an impact that uses nonrenewable resources during the initial and continued phases of the proposed project. Irreversible impacts can also result from damage caused by environmental accidents associated with the proposed project. Irretrievable commitments of resources should be evaluated to ensure that such consumption is justified.

Section 15126.2(d) of the State CEQA Guidelines is written as follows:

Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts, and particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses.

Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.

Construction and implementation of the proposed project would involve the commitment of building materials, human resources (labor) and energy, commensurate with that of other projects of similar  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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nature and magnitude. Construction of the proposed project would require the use of water, timber, steel, sand, gravel and other minerals and natural resources. Although this is not an unusual demand for these resources, it nonetheless is an incremental increase in demand for nonrenewable resources.

Labor would also be committed to the construction of the proposed structures with associated underground parking and landscaping. Nonrenewable energy resources would be used during construction and subsequent operation of the proposed project. This commitment of energy resources would be a long-term obligation, as, once the project site has been developed, it is highly unlikely that the land could be returned to its original condition. However, as discussed in Section 4.5 regarding energy conservation, impacts resulting from increased energy usage would be less than significant.

6.3.1 Building Materials and Solid Waste
Construction of the proposed project would require the use of resources that may be considered non-renewable or not quickly replenished. These resources would include lumber and other forest products, aggregate materials used in concrete and asphalt (e.g., sand, gravel and stone), metals (e.g., steel, copper and lead), and petrochemical construction materials (e.g., plastics). As discussed in Section 4.10 of this PEIR, the proposed project would use a variety of common building materials such as lumber and concrete. However, as discussed in Section 2.0 of this PEIR, the proposed project would utilize sustainable planning and building strategies installation of photovoltaic (PV) panels and the buildings will meet or exceed Leadership in Energy and Environmental Design (LEED) Gold certification. This is achieved through the combinations of high-performance building enclosure systems, external shading, energy efficient and carbon neutral building systems and equipment selections, solar panels and other energy efficiency measures. Thus, although the consumption of non-renewable building materials and resources would occur due to the proposed project, the proposed building would be developed to be energy efficient.

As discussed in Section 4.19 of the IS, solid waste landfilled from the City of Redlands was disposed of at two landfills—the California Street Landfill and the San Timoteo Sanitary Landfill south of the City of Redlands, and the impacts of the project on the disposal of solid waste would be less than significant in the IS. Therefore, this impact is not analyzed in this PEIR.. During operation, the proposed project would generate only a small portion of the city’s available solid waste capacity. The proposed project would have a less than significant impact to landfills because it would be required to comply with all applicable solid waste regulations including AB 939 and Section 5.408 of the 2019 CALGreen.

6.3.2 Water
Construction of the proposed project would require the typical use of water for activities such as dust control. Water for construction activities would be conveyed using the existing water infrastructure at the project site, and no major offsite infrastructure improvements would be needed for construction activities. Use of water during construction would be temporary and amounts needed for dust control would be negligible.

Additionally, as concluded in the City's 2025-2045 Urban Water Management Plan (UWMP), projected water demand for the city would be met by the available supplies during an average year, single-dry year, and multiple-dry year in each year from 2025 through 2045. Therefore, the project's temporary and intermittent demand for water during construction could be met by the city's available supplies during project construction.
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Consumption of water during operation of the project is addressed in Section 4.15 of this DPEIR.

The projected increase in water use from the proposed project would result in a negligible increase of the city’s future available water supplies.

6.3.3 Energy Consumption
During construction of the project, non-renewable fossil fuels would represent the primary energy source, and thus the existing finite supplies of these resources would be incrementally reduced. Fossil fuels, such as diesel, gasoline, and oil, would also be consumed in the use of construction vehicles and equipment. Project consumption of non-renewable fossil fuels for energy use during construction and operation of the project is addressed in Section 4.5 of this DPEIR. As discussed therein, construction activities for the project would not require the consumption of natural gas, but would require the use of electricity and fossil fuels. As the consumption of fossil fuels would occur on a temporary basis during construction, impacts related to the consumption of fossil fuels during construction of the project would be less than significant.

Project operation would use electricity for medical-serving needs, street lighting, and conveyance and treatment of water; and gasoline for on-road motor vehicles. 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 Residential and Nonresidential Buildings (Title 24); and (2) the 202219 CalGreen. 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).

Project impacts would be less than significant regarding wasteful, inefficient, or unnecessary energy use after compliance with energy efficiency plans.

6.3.4 Environmental Hazards
The proposed project’s potential use of hazardous materials is evaluated in Section 4.8 of this DPEIR.

As discussed therein, construction and operation of the proposed project would involve the transport, storage, and use of chemical agents, solvents, paints, and other hazardous materials.

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,39 Division of OSHA, and South Coast Air Quality Management District (SCAQMD) requirements.

Construction, onsite maintenance, and operation of the project would involve storage and use of small amounts of commercially available janitorial and landscaping supplies, typical of those materials used in commercial developments. The use, handling, and storage of these materials could increase the potential for hazardous materials releases and, subsequently, the exposure of people and the environment to hazardous materials. However, all potentially hazardous materials would be used and stored in accordance with manufacturers' specifications and instructions, thereby reducing the risk of hazardous materials use. In addition, the proposed project would be in full compliance with all applicable federal, state, and local requirements concerning the use, storage, and management of hazardous materials. Therefore, the proposed project would not cause irreversible 39 Codified in California Health and Safety Code, Division 20, Chapter 6.5, Hazardous Waste Control.  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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damage from environmental accidents associated with the use of typical, potentially hazardous materials.

6.3.5 Conclusion
Based on Sections 6.3.1 through 6.3.4 above, construction and operation of the project would require an irretrievable commitment of resources that are limited, slowly renewable, or nonrenewable, and consequently limit the availability of these resources, including the project site, for other uses or for future generations. However, the consumption of these resources for the project would not be considered substantial and would be consistent with regional and local growth forecasts and development goals for the area. These resources would not be used in a wasteful manner and would not be depleted much quicker than existing conditions. Therefore, although the project would result in irreversible environmental changes, those changes would be less than significant. Considering that the project would consume an inconsequential amount of natural resources, the limited use of nonrenewable resources is considered justified.

6.4 Growth-Inducing Impacts
In compliance with CEQA regulations, this section discusses the growth inducing impacts of a project.

CEQA Guidelines § 15126.2(e) requires a discussion of potential growth-inducing impacts of a project. Growth-inducing impacts are defined by CEQA as the ways in which a project could directly or indirectly foster economic or population growth or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth. In addition, as discussed in the CEQA Guidelines, increases in the population may tax existing community service facilities, thus requiring construction of new facilities that could cause significant environmental effects. It must not be assumed that growth in an area is necessarily beneficial, detrimental, or of little significance to the environment.

6.4.1 Population and Housing
The proposed project would develop a medical campus. As discussed in Section 4.14 of the Initial Study (refer to Appendix A1), the proposed project would not directly create housing or increase the population of the city and therefore would not increase the city’s population or housing availability.

6.4.2 Employment
The proposed project would have the potential to generate indirect population growth as a result of the temporary construction employment opportunities and employment opportunities associated with project operation.

The proposed project would create temporary construction-related jobs. Due to the specialized nature and expertise of their work, construction workers may remain at a job site for the time during which their specific skills are utilized to complete a particular phase of project construction.

Construction workers are not anticipated to relocate to the project vicinity due to the temporary nature of construction work. Therefore, construction of the project would not be considered growth inducing from a short-term employment perspective.

As detailed in Section 4.14 of the Initial Study (refer to Appendix A1), it is anticipated that employees from the local workforce would be hired during the operational phase of the project and that the  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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project would not require workers from outside the region. The project is not of the scope or scale to induce people to move from out of the project area to work on the proposed project. Therefore, the proposed project would be unlikely to create an indirect demand for additional housing or households in the area, and impacts would be less than significant.

6.4.3 Utility Infrastructure Improvements
As detailed in Section 4.14 of this DEIR, the project site is located in an urban area and within the existing service area for most utilities. where existing utility infrastructure would be able to connect to and adequately serve the project site. Therefore, the proposed project would not require utility infrastructure improvements that would induce growth within the city, and impacts would be less than significant.

6.4.4 Conclusion
The proposed project would not cause population growth directly because the project does not create any housing within the city. Additionally, the project’s scale and uses would not create regional draw for job opportunities. Additionally, the project would not result in major roadway improvements as it is located on an infill site surrounded by existing roadways. It involves infill development that makes use of existing land to create a campus within an urbanized area. Therefore, direct and indirect growth-inducing impacts of the project would be less than significant.

6.5 Potential Secondary Effects of Mitigation Measures
Section 15126.4(a)(1)(D) of the CEQA Guidelines states that "if a mitigation measure would cause one or more significant effects in addition to those that would be caused by the project as proposed, the effects of the mitigation measure shall be discussed, but in less detail, than the significant effects of the project as proposed." The following provides a discussion of the potential secondary impacts that could occur as a result of the implementation of proposed mitigation measures for each environmental issue area included in this DPEIR. Environmental issue areas with no impacts or with impacts less than significant and requiring no mitigation would have no potential secondary impacts associated with implementation of mitigation measures and therefore, are not discussed further in this section. The areas in this PEIR requiring mitigation are:
• Air Quality
• Biological Resources
• Cultural Resources
• Geology and Soils (Paleontological Resources)
• Greenhouse Gas Emissions
• Tribal Cultural resources
• Transportation
The mitigation measures will be implemented by the project applicant in coordination with the City of Redlands, as required during different phases of the project.

6.5.1 Air Quality
Mitigation measures MM AQ-1, MM AQ-2 and MM TRANS-1 through MM TRANS-4 are included in Section 4.2 of this PEIR to reduce the project's potential impacts on air quality during construction.

MM AQ-1 would replace gas powered landscaping equipment with zero-emission landscape  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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equipment. MM AQ-2 would provide electric vehicle charging infrastructure. MM TRANS-1 would implement a commute trip reduction marketing. MM TRANS-2 would provide an employee rideshare program. MM TRANS-3 would provide end-of-trip bicycle facilities. MM TRANS-4 would provide an employer-sponsored vanpool. Implementation of these mitigation measures would ensure that impacts regarding air quality emissions are less than significant during construction and operation phases of the project. Therefore, implementation of these mitigation measures would not result in adverse secondary impacts.

6.5.2 Biological Resources
Mitigation measures MM BIO-1 through MM BIO-5 are included in Section 4.3 of this DEIR PEIR to reduce the project's potential impacts to biological resources during construction. Specifically, MM BIO-1 would require focused presence/absence surveys for Crotch’s bumble bee following CDFW guidelines, with survey results informing whether further conservation actions or an ITP are required if the species is detected onsite. MM BIO-2 would require both focused and preconstruction surveys for burrowing owl during the breeding and non-breeding seasons, with protective buffers, monitoring, and a relocation plan developed in consultation with the City of Redlands, CDFW, and USFWS if burrowing owls are observed. MM BIO-3 would ensure compliance with the Migratory Bird Treaty Act and California Fish and Game Code by requiring pre-construction surveys for active nests, with appropriate avoidance buffers and monitoring to prevent take or disturbance of nesting birds.

MM BIO-4 would require preconstruction surveys for bat roosts within and adjacent to the project site, with preparation and implementation of a Bat Management Plan if special-status bats or significant roosts are detected. MM BIO-5 would require a formal jurisdictional delineation to assess potential impacts to waters of the U.S. and State, and, if necessary, secure all applicable permits from USACE, CDFW, and RWQCB prior to construction. Implementation of these mitigation measures would ensure that impacts to sensitive species, nesting birds, bats, and jurisdictional aquatic resources are avoided or minimized to the extent feasible.

Surveys required by the mitigation measures would result in additional foot traffic within the project site and potential soil disturbance if soil pits are dug during the jurisdictional delineation. If required, based on the results of the surveys, protection measures may include passive and active relocation and exclusion of disturbances. Also, if required, habitat restoration and/or replacement, and active relocation sites, would be offsite. However, the result of the mitigation would be beneficial to sensitive species or jurisdictional waters and thus would not cause a net adverse impact. Many of the other mitigation actions would also involve some disturbance to habitats; direct disturbance to special status species; and disturbances to trees. Mitigation measures would be implemented, and have been designed, by qualified biologists with the intention of reducing adverse impacts on biological resources. Therefore, net adverse impacts on biological resources from implementation of mitigation measures for minimizing impacts on biological resources are not anticipated, and thus any potential secondary impacts from the mitigation measures would be less than significant. Therefore, implementation of these mitigation measures would not result in adverse secondary impacts.

6.5.3 Cultural Resources
Mitigation measures CUL-1 through CUL-3 are included in Section 4.4 of this DPEIR to reduce the project's potential impacts to cultural resources during construction. MM CUL-1 would require the project applicant to retain a qualified archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards to monitor ground-disturbing activities and re-survey the ground surface once vegetation is cleared. If unanticipated cultural resources are discovered, the archaeologist would be given adequate time to recover, analyze, and curate the find(s), and  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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determine whether additional monitoring is needed to protect any remaining resources. MM CUL-2 would require a 50-foot buffer and halt of construction in the vicinity of any discovered historical or unique archaeological resources, with a qualified Principal Archaeologist overseeing evaluation and recovery, and potentially preparing an Archaeological Resources Treatment Plan (ARTP) to guide further monitoring and management. MM CUL-3 would ensure proper protocols are followed in the event that human remains are encountered during excavation, including immediate work stoppage within 30 feet of the discovery, notification of the County Coroner, and coordination with the Native American Heritage Commission to identify a Most Likely Descendant (MLD) to determine appropriate disposition of the remains. Implementation of these mitigation measures would ensure that potential impacts to cultural and archaeological resources, including human remains, are minimized or avoided entirely. Therefore, implementation of these mitigation measures would not result in adverse secondary impacts.

6.5.4 Geology and Soils
MM GEO-1 is included in Section 4.6 of this DEIR PEIR to reduce potential impacts to paleontological resources during excavation and grading activities. This measure would require the project applicant to retain a qualified paleontologist, approved by both the City of Redlands and the Western Science Center, prior to the commencement of any ground-disturbing activities. The retained paleontologist would prepare and implement a site-specific Paleontological Resources Impact Mitigation Program (PRIMP) consistent with guidelines developed by the Society for Vertebrate Paleontology. The PRIMP would include monitoring of ground disturbance in fossil-bearing sediments, specimen recovery, screen washing, fossil identification and preparation, curation of any recovered specimens at an accredited repository, and submission of a final monitoring report. In addition, the paleontologist would coordinate with construction personnel prior to excavation to ensure proper procedures are followed if fossil materials are uncovered during unmonitored periods. The paleontologist would also conduct periodic inspections during excavation and have the authority to temporarily halt work if paleontological resources are discovered. Fossils recovered during mitigation would be curated at a scientific institution for long-term preservation and study. Implementation of this measure would ensure that potential impacts to paleontological resources are minimized and appropriately mitigated. Therefore, implementation of this mitigation measure would not result in adverse secondary impacts.

6.5.5 Greenhouse Gas Emissions
To reduce potential impacts associated with greenhouse gas (GHG) emissions, Section 4.7 of this DEIR PEIR includes Mitigation Measure GHG-1, which must be implemented during both the construction and operational phases of the project. During construction, the project shall incorporate a variety of GHG-reducing practices as recommended by the California Air Pollution Control Officers Association (CAPCOA). These measures include the use of alternative fuels and electric or hybrid construction equipment, which may reduce emissions by up to 22 percent and 80 percent, respectively, if used consistently. Additional practices include limiting equipment idling, instituting a heavy-duty offroad vehicle plan, and implementing a vehicle inventory tracking system to ensure compliance. During project operation, GHG emissions are expected to primarily result from mobile sources, such as employee and visitor trips. To mitigate these emissions, the project will implement vehicle miles traveled (VMT) reduction strategies based on the accompanying traffic study. These include commute trip reduction marketing (4 percent HBW VMT reduction), employee rideshare programs (4 percent HBW VMT), installation of end-of-trip bicycle facilities (0.3 percent HBW VMT), employer-sponsored vanpool services (1.6 percent HBW VMT), and a multiplicative dampening  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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adjustment (0.6 percent). Implementation of these measures would reduce the project’s GHG emissions but would still exceed emission thresholds. Therefore, the project would have secondary effects regarding greenhouse gas emissions.

6.5.6 Transportation
To reduce potential transportation impacts and associated greenhouse gas emissions, Section 4.12 of this DEIR PEIR includes four transportation-related mitigation measures that must be implemented prior to the issuance of a Certificate of Occupancy for each phase of the project.

Mitigation Measure TRANS-1 requires the project proponent to implement a commuter trip reduction program that provides employees with information and marketing to promote alternatives to single-occupancy vehicle use, such as transit, carpooling, walking, and biking. Mitigation Measure TRANS-2 requires a formal ridesharing program for employees with similar commutes, with funding commitments by employers and the use of regional programs such as IE Commuter. Mitigation Measure TRANS-3 mandates the installation and maintenance of end-of-trip bicycle facilities— including secure bike parking, lockers, and showers—to encourage bike commuting. Finally, Mitigation Measure TRANS-4 requires implementation of an employer-sponsored vanpool service to provide shared commute options for employees, targeting up to two percent participation.

Collectively, these measures are designed to reduce vehicle miles traveled (VMT), mitigate transportation-related impacts, and contribute to the project's overall GHG emissions reduction strategy. However, the mitigation measures would not reduce the project’s VMT under the City’s threshold and would cause secondary impacts regarding transportation.

6.5.7 Tribal Cultural Resources
Mitigation measures TCR-1 through TCR-3 are included in Section 4.14 of this DEIR PEIR to reduce potential impacts to tribal cultural resources associated with ground-disturbing activities. MM Mitigation Measure TCR-1 would require the project applicant to retain a Native American monitor(s) from one or more Consulting Tribe(s). 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). The monitor(s) will complete daily monitoring logs. 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 grounddisturbing 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 would require construction to 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 outlines the procedures to be followed in the event of a discovery of human remains or associated funerary items, requiring adherence to California Public Resources Code § 5097.98 and Health and Safety Code § 7050.5. Preservation in place is the preferred treatment, and all such discoveries must remain confidential to protect the integrity of the site. Implementation of these measures would ensure that tribal cultural resources are protected and respectfully managed during construction. Therefore, implementation of these mitigation measures would not result in adverse secondary impacts.  SECTION 6.0 – OTHER CEQA CONSIDERATIONS 
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6.6 Effects Not Found to be Significant
Section 15128 of the State CEQA Guidelines requires that EIRs “contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR.” An Initial Study was prepared for the proposed project (refer to Appendix A1). Based on the findings of the Initial Study prepared for the project, the following topics were found to have either no impact or a less than significant impact on the environment and therefore did not warrant further analysis in the PEIR and thus do not warrant mitigation: agriculture and forestry resources; mineral resources; population and housing, recreation, and wildfire. Refer to the text below for a brief discussion of each of these environmental topics, which were eliminated from further analysis in the PEIR, as detailed in the Initial Study (refer to Appendix A1).

6.6.1 Agriculture and Forestry Resources
As discussed in Section 4.2 of the Initial Study (Appendix A1), a portion of the project site contains important farmland. However, a Land Evaluation and Site Assessment (LESA) was conducted for the project site determining that the land is no longer viable for agriculture. Additionally, the project site is surrounded by urban development, not part of the Williamson Act, does not contain forest lands and is not zoned for agriculture. Therefore, there would be less than significant impacts to agriculture and forestry resources.

6.6.2 Mineral Resources
As discussed in Section 4.12 of the Initial Study (Appendix A1), the project site is within Mineral Resource Zone (MRZ)-3, which is an area containing mineral deposits, the significance of which cannot be evaluated from available data. The project site and surrounding developments are within a fully developed portion of the city, and no mining or mineral extraction activities would occur on the project site. Therefore, no impacts are anticipated to: (1) the availability of known mineral resources of value to the region or state residents, ; or (2) a locally important mineral resource recovery site delineated on a local general, specific, or other land use plan. Therefore, there would be no impacts on mineral resources.

6.6.3 Population and Housing
As discussed in Section 4.14 of the Initial Study (Appendix A1), the proposed project would develop a medical building campus on undeveloped land, which would not develop housing that would increase the population of the city or displace any housing. Therefore, the project would have less than significant impacts in regard to population growth and housing.

6.6.4 Recreation
As discussed in Section 4.16 of the Initial Study (Appendix A1), recreation impacts would occur if the proposed project would cause population growth within the city. The proposed project would not create housing and therefore there would be no increase the population within the city.

Therefore, there would be no impacts in this regard.
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6.6.5 Wildfire
As discussed in Section 4.20 of the Initial Study (Appendix A1), the project site is not located in an State Responsibility Area (SRA) (i.e., where the State is responsible for the costs of wildfire prevention and suppression), nor is it located in a Very High Fire Hazard Severity Zone (VHFHSZ) within an Local Responsibility Area (LRA). Therefore, there would be no wildfire impacts.  SECTION 7.0 – REFERENCES 
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7.0 REFERENCES
Amlegal.com (American Legal Publishing), 2025. City of Redlands Municipal Code Section 18.12.080:

Site Plan Approval and Procedures. Accessed online at:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0- 15692#JD_18.12.080, on February 21, 2025.

Amlegal.com (American Legal Publishing), 2025. City of Redlands Municipal Code Section 8.06.090:

Noise Disturbances Prohibited: Accessed online at:
https://codelibrary.amlegal.com/codes/redlandsca/latest/redlands_ca/0-0-0-5302, on February 25, 2025.

ARB (California Air Resources Board), 2005. Methods to Find the Cost-Effectiveness of Funding Air Quality Projects for Evaluating Motor Vehicle Registration Fee Projects and Congestion Mitigation and Air Quality Improvement (CMAQ) Projects. May 2005. Accessed online at https://ww2.arb.ca.gov/sites/default/files/2020-
06/Congestion_Mitigation_Air%20_Quality_Improvement_Program_costeffectiveness_methods_may2005.pdf on May 13, 2025.

ARB, 2008. Climate Change Scoping Plan: a framework for change. California Air Resources Board.

December 2008. Accessed online at
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/document/adopted_sc oping_plan.pdf, on December 15, 2024.

ARB, 2014. First Update to the Climate Change Scoping Plan, Building on the Framework. California Air Resources Board. May 2014. Accessed online at
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/2013_update/first_up date_climate_change_scoping_plan.pdf, on December 15, 2024.

ARB, 2017. California’s 2017 Climate Change Scoping Plan. California Air Resources Board. Accessed online at https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf, on September 12, 2024.

ARB, 2018. SB 375 Regional Targets. Accessed online at https://ww2.arb.ca.gov/ourwork/programs/sustainable-communities-program/sb-375-regional-targets on February 20, 2025.

ARB, 2021. California 2015 And Subsequent Model Criteria Pollutant Exhaust Emission Standards And Test Procedures And 2017 And Subsequent Model Greenhouse Gas Exhaust Emission Standards And Test Procedures For Passenger Cars, Light-Duty Trucks, And Medium-Duty Vehicles. Accessed online at https://ww2.arb.ca.gov/sites/default/files/2022- 04/ldtps_2015%2BCP%262017%2BGHG_MY_leviii_12_21_ac.pdf on June 9, 2025.

ARB, 2022. 2022 Scoping Plan. Accessed online at https://ww2.arb.ca.gov/sites/default/files/2022- 12/2022-sp.pdf, on December 15, 2024.

ARB, 2023a. Maps of State and Federal Area Designations. Accessed online at https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-areadesignations, on March 31, 2024.  SECTION 7.0 – REFERENCES 
7214/Redlands – Kaiser Permanente Medical Center Page 7-2 Program Environmental Impact Report November 2025
ARB, 2023b. Advanced Clean Cars Program. Accessed online at https://ww2.arb.ca.gov/ourwork/programs/advanced-clean-cars-program on April 24, 2025.

ARB, 2024. iADAM Air Quality Data Statistics. California Air Resources Board. http://www.arb.ca.gov/adam. Accessed April 2025.

ARB, 2025a. LCFS Regulation. Accessed online at https://ww2.arb.ca.gov/our-work/programs/lowcarbon-fuel-standard/lcfs-regulation, on February 20, 2025 ARB, 2025b. Final Regulation Order to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen, and Other Pollutants from In-Use Heavy-Duty Diesel-Fueled Vehicles. Accessed online at
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2008/truckbus08/eofroatt1.pdf . On April 24, 2025.

ARB, 2025c. EMission FACtor 2021(EMFAC2021) v1.0.2. Emissions Inventory. Accessed online at https://arb.ca.gov/emfac/emissionsinventory/ea3fc4dba0e550de415f06987ec18d592690392f on May 12, 2025.

ARB, 2025d. In-Use Off-Road Diesel-Fueled Fleets Regulation. Accessed online at https://ww2.arb.ca.gov/our-work/programs/use-road-diesel-fueled-fleets-regulation on June 5, 2025
Beery, Kevin, 2023. Personal Communication to Stephen O’Neil. Senior Planner, City of Redlands SB18 Consultation; November 7, 2023.

Beery, Kevin, 2024. Personal Communication to Stephen O’Neil. Senior Planner, City of Redlands SB18 Consultation; October 12, 2024.

Beery, Kevin (Senior Planner, City of Redlands), 2024. Email to Robert Reicher.

Bolster, B.C., editor. 1998. Terrestrial mammal species of special concern in California. Report prepared by P.V. Brylski, P.W. Collins, E.D. Pierson, W.E. Rainey, and T.E. Kucera for California Department of Fish and Game, Wildlife Management Division, Nongame Bird and Mammal Conservation Program. Bird and Mammal Conservation Program Report No. 98014.

Cadre Environmental, 2025. Biological Resources Technical Report, Kaiser Permanente Redlands Medical Center, City of Redlands, California. Prepared for UltraSystems Environmental.

March 7, 2025.

CAL FIRE (California Department of Forestry and Fire Prevention), 2025. FHSZ Viewer. Accessed online at: http://egis.fire.ca.gov/FHSZ/, on October 9, 2023.

Calflora, 2023. Information on California plants for education, research and conservation.

Observation Search. Available at https://www.calflora.org/entry/observ.html. Accessed on October 20, 2023.

California Department of Transportation (Caltrans), 2023. California State Scenic Highway System Map. Accessed online at:
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https://www.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057 116f1aacaa, on November 28, 2023.

CalRecycle (California Department of Resources Recycling and Recovery), 2024a. RDRS Report 2:

Jurisdiction Disposal and Beneficial Reuse by Destination. Accessed online at:
https://www2.calrecycle.ca.gov/RecyclingDisposalReporting/Reports/JurisdictionDispos alAndBeneficial, on September 26,2024.

Caltrans, 2019. California Department of Transportation, California Scenic Highway Mapping System, Available online at
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46c c8e8057116f1aacaa. Accessed on November 28, 2023.

Cal-IPC (California Invasive Plant Council), 2006. California Invasive Plant Inventory. Cal-IPC Publication 2006-02. California Invasive Plant Council, Berkeley, CA. Accessed online at:
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 SECTION 7.0 – REFERENCES 
7214/Redlands – Kaiser Permanente Medical Center Page 7-4 Program Environmental Impact Report November 2025
CAPCOA, 2010. Quantifying Greenhouse Gas Mitigation Measures. Accessed online at https://www.aqmd.gov/docs/default-source/ceqa/handbook/capcoa-quantifyinggreenhouse-gas-mitigation-measures.pdf, on March 31, 2025.

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CAPCOA, 2025. LL-1. Replace Gas-Powered Landscape Equipment with Zero-Emission Landscape Equipment. Accessed online at https://www.caleemod.com/documents/measures/LL1.pdf on June 10, 2025.

CASGEM (California Statewide Groundwater Elevation Monitoring Program), 2022. Well Details for State Well Number 01N05W32N001S. Available at https://www.casgem.water.ca.gov/.

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 SECTION 7.0 – REFERENCES 
7214/Redlands – Kaiser Permanente Medical Center Page 7-5 Program Environmental Impact Report November 2025
https://www.cdph.ca.gov/Programs/CEH/DRSEM/CDPH%20Document%20Library/EM B/MedicalWaste/Medical_Waste_Transporters_040825.pdf.

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 SECTION 7.0 – REFERENCES 
7214/Redlands – Kaiser Permanente Medical Center Page 7-6 Program Environmental Impact Report November 2025
City of Redlands. 2014. Bicycle Master Plan. Accessed online at:
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 SECTION 7.0 – REFERENCES 
7214/Redlands – Kaiser Permanente Medical Center Page 7-7 Program Environmental Impact Report November 2025
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7214/Redlands – Kaiser Permanente Medical Center Page 7-8 Program Environmental Impact Report November 2025
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7214/Redlands – Kaiser Permanente Medical Center Page 7-9 Program Environmental Impact Report November 2025
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7214/Redlands – Kaiser Permanente Medical Center Page 7-11 Program Environmental Impact Report November 2025
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Service. https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx USEPA (U.S. Environmental Protection Agency), 2023a. WATERS GeoViewer. Available at https://www.epa.gov/waterdata/waters-geoviewer. Accessed on March 9, 2022.

USEPA, 2000. Air Quality Criteria for Carbon Monoxide. Accessed online at https://planning.lacity.gov/eir/CrossroadsHwd/deir/files/references/B29.pdf on June 9, 2025.

USEPA, 2025. Timeline of Major Accomplishments in Transportation, Air Pollution, and Climate Change, www.epa.gov/air-pollution-transportation/timeline-major-accomplishmentstransportation-air-pollution-and-climate, accessed June 9, 2025.  SECTION 7.0 – REFERENCES 
7214/Redlands – Kaiser Permanente Medical Center Page 7-13 Program Environmental Impact Report November 2025
UltraSystems, 2023. Phase I Cultural Resources Inventory For The Kaiser Permanente Medical Center Project, Redlands, San Bernardino, California.

Wang, S. 2005. Email from South Coast Air Quality Management District, Diamond Bar, CA to Michael Rogozen, UltraSystems Environmental Inc. Irvine, April 3.

WBWG (Western Bat Working Group), 2023. Species Matrix. Available at http://wbwg.org/matrices/species-matrix/. Accessed on October 14, 2023.

Western Science Center, 2023. Paleontology Record Search Request dated October 23, 2023.

Wong, S., 2025. Email from South Coast Air Quality Management District to Michael Rogozen, UltraSystems Environmental Incorporated, April 3.

WRCC (Western Regional Climate Center), 2016. Redlands, California (047306). 1898-2016 Monthly Climate Summary. Accessed online at https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca7306, on March 12, 2025.

WSC (Water Systems Consulting, Inc.), 2021. Integrated Regional Urban Water Management Plan (IRUWMP); Redlands 2020 Urban Water Management Plan. Available at https://www.cityofredlands.org/utilities-0. Downloaded on April 28, 2025.

Zeiner, D.C., W.F. Laudenslayer, Jr., K.E. Mayer, and M. White, eds. 1988-1990., California's Wildlife.

Vol. I-III. California Department of Fish and Game, Sacramento, California.  SECTION 8.0 – ACRONYMS AND ABBREVIATIONS 
7214/Redlands – Kaiser Permanente Medical Center Page 8-1 Program Environmental Impact Report November 2025

8.0 ACRONYMS AND ABBREVIATIONS
Acronym /
Abbreviation Term
AAQS Ambient Air Quality Standards
AB Assembly Bill
ADD Average Daily Demand
AFY Acre Feet per Year
AMSL Above Mean Sea Level
APE Area Of Potential Effect
APN Assessor’s Parcel Number
ARB Air Resources Board
ARTP Archaeological Resources Treatment Plan
ASC Ambulatory Services Center
BAU Business As Usual
BMPs Best Management Practices
BRTR Biological Resources Technical Report
BSA Biological Survey Area
BUOW Burrowing Owl
CAAQS California Ambient Air Quality Standards
CAFE Corporate Average Fuel Economy
CAISO California Independent System Operator
CalEEMod California Emissions Estimator Model
CAL FIRE California Department Of Forestry And Fire Protection Caltrans California Department Of Transportation
CAO(s) Cleanup and Abatement Order(s)
CAP Climate Action Plan
CARB California Air Resources Board
CBC California Building Code
CCAA California Clean Air Act
CCR California Code of Regulations
CDO(s) Cease and Desist Order(s)
CDFW California Department of Fish and Wildlife
CDPH California Department of Public Health
CEC California Energy Commission
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CESA California Endangered Species Act
CFC California Fire Code
CGS California Geological Survey
CH4 Methane
CHRIS California Historic Resources Inventory System
CI Carbon Intensity
CIP Capital Improvements Project
City City Of Redlands
CMP Congestion Management Program
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
 SECTION 8.0 – ACRONYMS AND ABBREVIATIONS 
7214/Redlands – Kaiser Permanente Medical Center Page 8-2 Program Environmental Impact Report November 2025
Acronym /
Abbreviation Term
CNPPA California Native Plant Protection Act
CNPS California Native Plant Society
CO Carbon Monoxide
CO2 Carbon Dioxide
CP-1 Concept Plan 1
CPUC California
CRC California Residential Code
CRHR California Register Of Historical Resources
CUP Conditional Use Permit
CWA Clean Water Act
cy Cubic Yards
dB Decibel
dBA A-Weighted Decibel Scale
DERs Distributed Energy Resources
DEIR Draft EIR
DOC California Department Of Conservation
DOGGR Division of Oil, Gas, and Geothermal Resources
DOSH California Division Of Safety And Health
DPM Diesel Particulate Matter
DTSC Department of Toxic Substance Control
DWR Department of Water Resources
EHS Environmental Health Services
EISA Energy Independence and Security Act
EIR Environmental Impact Report
EMS Emergency Medical Service
EPCA Energy Policy and Conservation Act
EPCRA Emergency Planning and Community Right-to-Know Act ERP San Bernardino County Operational Area Emergency Response Plan ESA Endangered Species Act
EV Electric Vehicle
EVCSP East Valley Corridor Specific Plan
FEIR Final Environmental Impact Report
FHSZ Fire Hazard Severity Zone
FMCSA Federal Motor Carrier Safety Administration
FMMP Farmland Mapping and Monitoring Program
GHG Greenhouse Gas
GIS Geographic Information System
GPEIR General Plan EIR
HCD Department of Housing and Community Development
HCP Habitat Conservation Plan
HDPUVs Heavy-duty pickup trucks and vans
HFCs Hydrofluorocarbons
HMTA Hazardous Materials Transportation Act
HMR Hazardous Materials Regulations
HSWA Hazardous and Solid Waste Act
HVAC Heating, Ventilation, and Air Conditioning
 SECTION 8.0 – ACRONYMS AND ABBREVIATIONS 
7214/Redlands – Kaiser Permanente Medical Center Page 8-3 Program Environmental Impact Report November 2025
Acronym /
Abbreviation Term
IEPR Integrated Energy Policy Report
IOU Investor-Owned Utility
IRWMP Integrated Regional Water Management Plan
ISA International Society of Arboriculture
KOPs Key Observation Points
L90 Noise Level That Is Exceeded 90 percent Of The Time Leq Equivalent Noise Level
LACCEO Los Angeles County Chief Executive Office
LCC Land Capacity Classification
LCFS Low Carbon Fuel Standard
LE Land Evaluation
LESA Land Evaluation and Site Assessment
LEV Low-Emission Vehicle
LHMP Local Hazard Mitigation Plan
LID Low Impact Development
Lmax Root Mean Square Maximum Noise Level
LOS Level Of Service
LQGs Large Quantity Generators
LRA Local Responsibility Area
LSAA Lake or Streambed Alteration Agreement
LUST Leaking Underground Storage Tank
MBTA Migratory Bird Treaty Act
MDD Maximum Day Demand
MGD Million Gallons Per Day
MJHMP County of San Bernardino Multi-Jurisdictional Hazard Mitigation Plan MLD Most Likely Descendant
MM Mitigation Measure
MOB Medical Office Building
MRZ Mineral Resource Zone
MUED Municipal Utilities and Engineering Department
MWD Metropolitan Water District of Southern California
N2O Nitrous Oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Communities Conservation Plan
NCP National Contingency Plan
ND Negative Declaration
NEPA National Environmental Policy Act
NHPA National Historic Preservation Act
NHTSA National Transportation Safety Administration
NMFS National Marine Fisheries Service
NRCS Natural Resources Conservation Service
NOx Nitrogen Oxides
NOP Notice of Preparation
NPDES National Pollutant Discharge Elimination System
NPW Non-Potable Water
 SECTION 8.0 – ACRONYMS AND ABBREVIATIONS 
7214/Redlands – Kaiser Permanente Medical Center Page 8-4 Program Environmental Impact Report November 2025
Acronym /
Abbreviation Term
NRMP Natural Resource Management Plan
O3 Ozone
OES Governor’s Office of Emergency Services
OIR Order Instituting Rulemaking
OSHA Occupational Safety And Health Administration
OWOW One-Water, One-Watershed Plan
PEIR Program Environmental Impact Report
PHD Peak Hour Demand
PFCs Perfluorocarbons
PHMSA Pipeline and Hazardous Materials Safety Administration PPB Parts Per Billion
PPM Parts Per Million
PM Particulate Matter
PM2.5 Fine Particulate Matter
PM10 Respirable Particulate Matter
PPV Peak Particle Velocity
PRC Public Resource Code
PRIMP Paleontological Resources Impact Mitigation Program PV Photovoltaic
PW Potable Water
R-GPCD Residential Gallon Per Capita Per Day
RCRA Resource Conservation And Recovery Act
RMS Root Mean Square
ROG Reactive Organic Gases
ROW Right-of-way
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy RW Recycled Water
RWQCB Regional Water Quality Control Board
SAWPA Santa Ana Watershed Project Authority
SAR Santa Ana River
SARA Superfund Amendments and Reauthorization Act
SB Senate Bill
SBB San Bernardino Basin
SBCFD San Bernardino County Fire Department
SBCTA San Bernardino County Transportation Authority
SBIA San Bernardino Internation Airport
SBMWD San Bernardino Municipal Water Department
SBTAM+ San Bernardino Transportation Analysis Model
SBVT San Bernardino Valley Traction
SBVWCD San Bernardino Valley Water Conservation District SBVMWD San Bernardino Valley Municipal Water District
SCAB South Coast Air Basin
SCAG Southern California Association Of Governments
SCAQMD South Coast Air Quality Management District
SCCIC South Central Coastal Information Center
SCE Southern California Edison
 SECTION 8.0 – ACRONYMS AND ABBREVIATIONS 
7214/Redlands – Kaiser Permanente Medical Center Page 8-5 Program Environmental Impact Report November 2025
Acronym /
Abbreviation Term
SCG Southern California Gas Company
SF6 Sulfur Hexafluoride
SIP State Implementation Plan
SLF Sacred Lands File
SMARTS Stormwater Multiple Application and Report Tracking System SoCalGas Southern California Gas Company
SRA State Responsibility Area
SRAs Source Receptor Areas
STIP Statewide Transportation Improvement Program
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TACs Toxic Air Contaminants
TAZ Traffic Analysis Zone
TCPs Traditional Cultural Properties
TCRs Tribal Cultural Resources
TDM Transportation Demand Management
U.S. United States
USACE U.S. Army Corps of Engineers
U.S.C. United States Code
USDA United States Department Of Agriculture
USDOT United States Department of Transportation
USEPA United States Environmental Protection Agency
USFWS United States Fish and Wildlife Service
USARW Upper Santa Ana River Watershed
USGS United States Geological Survey
UWMP Urban Water Management Plan
VdB Vibration Decibels
VHFHSZs Very High Fire Hazard Severity Zones
VMT Vehicle Miles Traveled
VOC Volatile Organic Compound
WDRs Water Discharge Requirements
WQC Water Quality Certification
WQMP Water Quality Management Plan
WRP Water Reclamation Plant
WSA Water Supply Assessment
WSMP Water Systems Master Plan
WWTP Wastewater Treatment Plan
ZEV Zero-Emission Vehicle
 SECTION 9.0 – LIST OF PREPARERS 
7214/Redlands – Kaiser Permanente Medical Center Page 9-1 Program Environmental Impact Report November 2025

9.0 LIST OF PREPARERS

9.1 CEQA Lead Agency
Kevin Beery, Senior Planner
City of Redlands, Planning Division
35 Cajon Street, Suite 20
Redlands, CA 92373
Phone Number: (909) 758-7555 x1297
Email address: [email protected]

9.2 Project Applicant
Deborah Wong, Senior Land Use Manager
Kaiser Hospitals Foundation, Corporate Real Estate & Workplace Services 393 E. Walnut Ave., 4th floor
Pasadena, CA 91188
Phone Number: (626) 344-4519
Email Address: [email protected]

9.3 UltraSystems Environmental Inc.

9.3.1 Environmental Planning Team
Betsy Lindsay, ENV SP, Project Director
M.A., Urban and Regional Planning, California State Polytechnic University, Pomona, CA Public Policy and Administration, California State University, Long Beach, CA Business Administration, Pepperdine University, Irvine, CA B.A., Geography, California State University, Long Beach, CA Years of Experience: 35+
Robert Manford, President
DPPD, Policy, Planning, and Development, University of Southern California, Los Angeles, CA, MPL, Urban and Regional Planning, University of Southern California, Los Angeles, CA B.A., Geography and Resource Development, University of Ghana, Accra, Ghana Years of Experience: 30+
Robert Reicher, ENV SP, Senior Project Manager
MBA, Marketing, University of Southern California, Los Angeles, CA B.S., Marketing, University of California Los Angeles Los Angeles, CA Years of Experience, 40+
Project Management and QA/QC
Billye Breckenridge, Deputy Project Manager
B.A., Environmental Studies/ Biology Minor, University of Nevada Las Vegas, Nevada Years of Experience: 27
GIS Data Processing and Mapping

9.3.2 Technical Team
Allison Carver, Senior Biologist
 SECTION 9.0 – LIST OF PREPARERS 
7214/Redlands – Kaiser Permanente Medical Center Page 9-2 Program Environmental Impact Report November 2025
B.S., Biology, California State University, San Bernardino, CA B.A., Environmental Studies, California State University, San Bernardino, CA Years of Experience: 20
Biological Resources, Hydrology and Water Quality
Amir Ayati, Staff Scientist
B.S., Earth System Science, University of California, Irvine, CA Years of Experience: 4
Air Quality, Greenhouse Gas Emissions, Energy, and Noise Andrew Soto, Word Processor
B.A., Communications, California State University Fullerton, Fullerton, CA Years of Experience: 5
Word Processing/Technical Editing
Erik Segura, Associate Planner
B.S., Environmental Planning and Policy, California State University Humboldt, Arcata, CA Years of Experience: 6
Noise, and Water Quality
Isha Shah, Staff Engineer/Scientist
M.S., Environmental and Water Resources Engineering, University of California, Los Angeles, CA Years of Experience: 5
Air Quality, Greenhouse Gas Emissions, Energy, and Noise Marissa Kassisieh, Associate Planner
MURP, Master of Urban and Regional Planning, University of California, Irvine, CA B.A., Urban Studies, University of California, Irvine, CA Years of Experience: 2
Environmental Research, Introduction, Project Description, Executive Summary, Agriculture and Forestry Resources, Population and Housing, Mineral Resources, Recreation, List of Preparers Megan Black Doukakis, Assistant Project Archaeologist
M.A., Public Archaeology, California State University, Northridge, CA B.A., Anthropology, California State University, Long Beach, CA Years of Experience: 13
Cultural Resources, and Tribal Cultural Resources
Michael Milroy, Project Manager
M.S., Interdisciplinary Studies / Neuroscience, California State University Long Beach, CA B.S., Biological Sciences, California State University Long Beach, CA Years of Experience: 15
Aesthetics, Energy, Geology and Soils, Hazardous Materials, Hydrology and Water Quality, Utilities, and Alternatives Analysis
 SECTION 9.0 – LIST OF PREPARERS 
7214/Redlands – Kaiser Permanente Medical Center Page 9-3 Program Environmental Impact Report November 2025
Michael Rogozen, Senior Principal Engineer
D.Env., Environmental Science and Engineering, University of California, Los Angeles, CA M.S., Systems Engineering, University of California, Los Angeles, CA B.S., Engineering, University of California, Los Angeles, CA Years of Experience: 48
Health Risk Assessment, Air Quality, Greenhouse Gas Emissions, Energy, and Noise Patricia Haigh, Staff Scientist
B.S., Earth Systems Science, University of California, Irvine, CA B.A., Environmental Science and Policy, University of California, Irvine, CA Years of Experience: 4
Health Risk Assessment, Air Quality, Greenhouse Gas Emissions, Energy, and Noise Stephen O’Neil, Cultural Resources Manager
M.A., Anthropology, California State University, Fullerton, CA B.A., Anthropology, California State University, Long Beach, CA Registered Professional Archaeologist
Years of Experience: 42
Cultural Resources, and Tribal Cultural Resources
Steven Borjeson, Senior Planner
B.A., Geography, Emphasis in Urban Studies, University of Colorado, Denver, CO California Environmental Quality Act (CEQA) Studies, University of San Diego, San Diego CA Years of Experience: 8
Land Use, Transportation, Utilities and Services, Other CEQA Considerations, Environmental Impact Analysis, Public Services and Aesthetics

9.4 Other Firms
Fehr & Peers – Traffic Study
Michael Baker Internation – Water Supply Assessment
Cadre Environmental – Biological Resources Assessment
Dudek – Visual Impacts Study, Drainage Study, WQMP
Twining – Geotechnical Investigation Report
 SECTION 10.0 – CONSULTATION AND COORDINATION 
7214/Redlands – Kaiser Permanente Medical Center Page 10-1 Program Environmental Impact Report November 2025

10.0 CONSULTATION AND COORDINATION
This section provides a list of federal, state, and local agencies and organizations contacted during preparation of the PEIR.

Agency Contact Person Address
Federal Agencies
U.S. Fish & Wildlife Services Carlsbad
Field Office
N/A 2177 Salk Avenue, Suite 250,
Carlsbad, CA 92008
U.S. Army Corps of Engineers N/A 915 Wilshire Boulevard, Suite 930, Los Angeles, CA 90017
State Agencies
N/A
Regional Agencies
San Bernardino Valley Municipal Water
District
N/A 380 East Vanderbilt Way, San
Bernardino, CA 92408
South Coast Air Quality Management
District, Planning and Environmental
Review
N/A 21865 Copley Drive, Diamond
Bar, CA 91765
OmniTrans Anna Jaiswal, Development Planning
Manager
1700 West Fifth Street, San
Bernardino, CA 92411
Santa Ana Regional Water Quality
Control Board (Region 8)
N/A 3737 Main Street, Suite 500,
Riverside, CA 92501
Southern California Association of
Governments (SCAG) Regional Office
Arnold San Miguel 1170 West 3rd Street, Suite 140,
San Bernardino CA 92410
Local Agencies
San Bernardino County
San Bernardino County Clerk of the
Board of Supervisors
N/A 385 North Arrowhead Avenue,
San Bernardino, CA 92401
San Bernardino County Land Use
Services Department
K. Watkins, Planning Manager 385 North Arrowhead Avenue, 1st Floor, San Bernardino, CA
92415
County of San Bernardino Public Works
Department – Traffic Division
N/A 825 East 3rd Street, Room 115
San Bernardino County Flood Control
District
N/A 825 East 3rd Street, Room 115
San Bernardino County Transportation
Authority
Steve Smith, Planning Director 1170 West 3rd Street, 2nd Floor, San Bernardino, CA 92410
San Bernardino Valley Water
Conservation District
N/A 1630 West Redlands Boulevard,
Suite A, Redlands, CA 92373
Riverside County Planning Department N/A P.O. Box 1409, Riverside, CA 92502
Redlands Unified School District
RUSD – Facilities Planning Department K. Morse, Facilities Planning 20 West Lugonia Avene, Redlands, CA 92373
City of Redlands
Redlands Airport Association N/A 1745 Sessums Drive, Suite 1, Redlands, CA 92374
Redlands Chamber of Commerce Evan Sanford, President 47 North 1st, Redlands, CA 92373
 SECTION 10.0 – CONSULTATION AND COORDINATION 
7214/Redlands – Kaiser Permanente Medical Center Page 10-2 Program Environmental Impact Report November 2025
Agency Contact Person Address
City of Calimesa
City of Calimesa Community
Development Department
Kelly Lucia, Planning Manager 908 Park Avenue, Calimesa, CA 92373
City of San Bernardino
City of San Bernardino Community and
Economic Development Department
N/A 290 North D Street, San
Bernardino, CA 92401
City of Yucaipa
City of Yucaipa Community
Development Department
Fermin Preciado, Director 34272 Yucalpa Boulevard,
Yucalpa CA 92399
City of Highland
City of Highland Community
Development Department
N/A 27215 Baseline Avenue,
Highland, CA 92346
City of Loma Linda
City of Loma Linda Community
Development Department
N/A 25541 Barton Road, Loma
Linda, CA 92354
Utility Companies
Southern California Edison Service
Planning Department
N/A 287 Tennessee Street, Redlands,
CA 92373
Southern California Gas Company
Planning Department
N/A 155 South G Street, San
Bernardino, CA 92410
Western Heights Water Company N/A 32352 Avenue D, Yucaipa, CA 92399
Native American Tribal Organizations
Agua Caliente Band of Cahuilla Patricia Garcia-Plotkin, THPO and Jeff Grubbe, Chairperson
5401 Dinah Shore Drive, Palm
Springs CA 92264
Gabrieleno Band of Mission Indians –
Kizh Nation
Andrew Salas, Chairman P.O Box 393, Covina CA, 91723
Morongo Band of Mission Indians Ann Brierty, THPO and Charles Martin, Chairperson, and Robert Martin,
Chairman
12700 Pumarra Road, Banning,
CA 92220
Soboba Band of Luiseno Indians Joseph Ontiveros, THPO and Isaiah Vivanco, Chairperson
P.O Box 487, San Jacinto, CA
95281
Torres Martinez Desert Cahuilla Indians Michael Mirelez, Cultural Resources Coordinator and Thomas Torez Jr.,
Chairperson
P.O. Box 1160, Thermal CA
92274
Yuhaaviatam of San Manuel Nation Alexandra McCleary, Ph.D 26569 Community Center Drive, Highland CA 92346
San Manuel Band of Mission Indians
Resources Management Department
Jessica Mauck, Cultural 26569 Community Center,
Highland, CA 92346
N/A: Not Available or Not Applicable
 SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-1 Program Environmental Impact Report November 2025

11.0 MITIGATION MONITORING AND REPORTING PROGRAM
Section 21081.6 of the Public Resources Code requires all state and local agencies to establish monitoring or reporting programs whenever approval of a project relies upon a mitigated negative declaration or an environmental impact report (EIR). The monitoring or reporting program must ensure implementation of the measures being imposed to mitigate or avoid the significant adverse environmental impacts identified in the mitigated negative declaration or EIR.

The mitigation measures will be implemented by the project applicant, the City of Redlands or other agencies at different times during the implementation of the project. Some mitigation will require implementation prior to the issuance of any building permits, while others will be implemented during construction, and others throughout all the phases. The following table lists the potentially significant environmental impacts, the mitigation measures, the level of significance after mitigation, the responsible parties and monitoring parties, and the phase in which mitigation is to be implemented.

The environmental areas requiring mitigation are:
• Air Quality
• Biological Resources
• Cultural Resources
• Geology and Soils/Paleontological Resources
• Greenhouse Gas Emissions
• Transportation
• Tribal and Cultural Resources
Those environmental topics for which there would be less than significant impacts without mitigation are discussed in their respective sections in this document but are not included in the table below because no mitigation is warranted. Those environmental topics include:
• Aesthetics
• Energy
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Noise
• Public Services
• Utilities and Service Systems
 SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-2 Program Environmental Impact Report November 2025
Table 11.0-1

MITIGATION MONITORING AND REPORTING PROGRAM
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage

4.2 Air Quality
Threshold A:

Would the project
result in a
cumulatively
considerable net
increase of any
criteria pollutant for
which the project
region is nonattainment under an
applicable federal or
state ambient air
quality standard?
MM AQ-1
Replace Gas Powered Landscape Equipment with ZeroEmission Landscape Equipment (listed at A-1 in the aforementioned CAPCOA Handbook, and LL-1 in CalEEMod).

Less than
Significant
Project Applicant/City
of Redlands
During Project
Operation
MM AQ-2
Provide Electric Vehicle Charging Infrastructure (listed as T14 in CalEEMod).

Less than
Significant
Project Applicant/City
of Redlands
Include in Building
Plans; and During
Project Construction
MM TRANS-3
Provide End-of-Trip Bicycle Facilities including bike parking, bike lockers, showers, and personal lockers. The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT
and GHG emissions.

Less than
Significant
Project Applicant/City
of Redlands
Include in Building
Plans; and During
Project Construction
MM TRANS-4
Provide Employer-Sponsored Vanpool. 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.

Less than
Significant
Project Applicant/City
of Redlands
During Project
Operation

4.3 Biological Resources
 SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-3 Program Environmental Impact Report November 2025
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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?
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:

Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Before
beginning of
ground
disturbance;
three surveys
shall be
conducted with
at least two
weeks between
surveys from
April to June.
 SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-4 Program Environmental Impact Report November 2025
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage

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).

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
Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
A total of four surveys
shall be conducted by
a qualified avian
biologist during the
breeding season: 1) at
least one site visit
 SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-5 Program Environmental Impact Report November 2025
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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 grounddisturbing 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.
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. Nonbreeding season
surveys shall include
four surveys spread
out evenly from July
15 to February 15.

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.
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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 non-breeding
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 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
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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 Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Prior to the issuance
of grading permits for
the project. Preactivity 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.
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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.

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  SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-9 Program Environmental Impact Report November 2025
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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
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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:

Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Prior to
implementation of
project activities
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1. Bat status, distribution and habitat information within and adjacent to the project site.

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
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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 Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Prior to approval of
grading permits and
initiation of project
activities
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Material to Waters of the State (Procedures) (SWRCB, 2019) to delineate waters of the state.

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
RWQCB-Region 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 projectspecific approval. All conditions of these permits shall be adhered to during project development.

4.4 Cultural Resources
Threshold A: Would
the Project cause a
substantial adverse
change in the
significance of a
historical resource
pursuant to §
15064.5?
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 Less than
Significant
Qualified archaeologist;
project applicant; and
City of Redlands
Before beginning of
ground-disturbing
work; and during site
clearance
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And
Threshold B: Would
the Project cause a
substantial adverse
change in the
significance of an
archaeological
resource pursuant to
§ 15064.5?
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.

Less than
Significant
Qualified archaeologist;
project applicant; and
City of Redlands
During construction
activities
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2. Impact assessment.

3. Mitigation strategies, which may include:
a. Potential avoidance measures.
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.
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Threshold C: Would
the Project disturb
human remains,
including those
interred outside of
dedicated cemeteries?
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).

Less than
Significant
Qualified archaeologist;
project applicant; and
City of Redlands
During excavations
associated with this
project

4.5 Geology and
Soils
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.

4. 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
Less than
Significant
Qualified
paleontologist/project
applicant; City of
Redlands
Prior to excavation
and grading activities
at the project site; and
during excavation and
grading activities
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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
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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

5. 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.

6. The qualified paleontologist shall perform periodic
inspections of excavation and grading 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
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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.

4.7 Greenhouse Gas Emissions
Threshold A: Would
the Project generate
greenhouse gas
emissions, either
directly or indirectly,
that may have a
significant impact on
the environment?
MM GHG-1
Using alternative fuels for construction equipment (0 to 22 percent).

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 (varies with the amount of project idling
occurring and the amount reduced).

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:

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

Significant
and
Unavoidable
Project applicant and
project construction
contractor
Include in project
building plans; and
during project
construction
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7. 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.

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

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

10. 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).

4.12 Transportation
Threshold B: Would
the project conflict or
be inconsistent with
CEQA Guidelines
section 15064.3,
subdivision (b)?
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, Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project
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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.

Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project
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 provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions.

Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project
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 longdistance, 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.

Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project
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4.13 Tribal Cultural Resources
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
MM-TCR-1:

Retain a Native American Monitor Prior to Commencement
of Ground-Disturbing Activities
A. 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). “Ground-disturbing
activity” shall include, but is not limited to,
demolition, pavement removal, potholing, auguring,
grubbing, tree removal, boring, grading, excavation,
drilling, and trenching.

B. 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 ground-disturbing
activity, or the issuance of any permit necessary to
commence a ground-disturbing activity.

C. The monitor(s) will complete daily monitoring logs
that will provide descriptions of the relevant grounddisturbing activities, the type of construction activities performed, locations of ground-disturbing
activities, soil types, cultural-related materials, and Less than
Significant
Native American
Monitor/Project
Applicant/City of
Redlands
Prior to
Commencement of
Ground-Disturbing
Activities; and during
ground-disturbing
activities
 SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-23 Program Environmental Impact Report November 2025
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
defined in Public
Resources Code
§ 5020.1(k); or
v. 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.
any other facts, conditions, materials, or discoveries
of significance to the Tribe. Monitor logs will identify and 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.

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/Non-Ceremonial)
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)..

Less than
Significant
Native American
Monitor/Project
Applicant/City of
Redlands
Prior to
Commencement of
Ground-Disturbing
Activities; and during
ground-disturbing
activities
MM-TCR-3: Unanticipated Discovery of Human Remains and Less than Native American Monitor/Project
Prior to
Commencement of
 SECTION 11.0 – MITIGATION MONITORING AND REPORTING PROGRAM  7214/Redlands – Kaiser Permanente Medical Center Page 11-24 Program Environmental Impact Report November 2025
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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.

Significant Applicant/City of
Redlands
Ground-Disturbing
Activities; and during
ground-disturbing
activities
 SECTION 12.0 – RECIPIENTS OF THE DRAFT PEIR 
7214/Redlands – Kaiser Permanente Medical Center Page 12-1 Program Environmental Impact Report November 2025

12.0 RECIPIENTS OF THE DRAFT PEIR
This section includes a list of agencies, organizations, and individuals to whom notification of preparation (NOP) of the Draft EIR was sent. A copy of the NOP and agency distribution list is provided in Appendix A4 to this PEIR.

12.1 Agencies and Organizations
• Patricia Garcia-Plotkin, THPO, Agua Caliente Band of Cahuilla • Jeff Grubbe, Chairperson, Agua Caliente Band of Cahuilla • Andrew Salas, Chairman, Gabrieleno Band of Mission Indians – Kizh Nation • Ann Brierty, THPO, Morongo Band of Mission Indians
• Charles Martin, Chairperson, Morongo Band of Mission Indians • Joseph Ontiveros, THPO, Soboba Band of Luiseno Indians • Isaiah Vivanco, Chairperson, Soboba Band of Luiseno Indians • Michael Mirelez, Cultural Resources Coordinator, Torres Martinez Desert Cahuilla Indians • Thomas Torez Jr., Chairperson, Torres Martinez Desert Cahuilla Indians • Alexandra McCleary, Ph.D., Yuhaaviatam of San Manuel Nation • Clerk of the Board of Supervisors, San Bernardino County • San Bernardino Valley Municipal Water District
• K. Watkins, Planning Manager, San Bernardino County Land Use Services Department • County of San Bernardino Public Works Department – Traffic Division • Supervising Planner, San Bernardino County Flood Control District • Steve Smith, Planning Director, San Bernardino County Transport Authority • South Coast Air Quality Management District
• K. Morse, Facilities Planning, Redlands Unified School District • Anna Jaiswal, Development Planning Manager, Omnitrans • Water Quality Control Board
• Kelly Lucia, Planning Manager, City of Calimesa Community Development Department • City of San Bernardino, Community and Economic Development Department • Western Heights Water Company
• Redlands Airport Association
• Evan Sanford, President, Redlands Chamber of Commerce • Fermin Preciado, Director, City of Yucaipa, Community Development Department • San Bernardino Valley Water Conservation District
 SECTION 12.0 – RECIPIENTS OF THE DRAFT PEIR 
7214/Redlands – Kaiser Permanente Medical Center Page 12-2 Program Environmental Impact Report November 2025
• Southern California Edison Service Planning Department • City of Loma Linda Community Development Department
• Riverside County Planning Department
• Arnold San Miguel, SCAG Regional Office
• Jessica Mauck, San Manuel Band of Mission Indians
• Southern California Gas Co. Planning Department
• Verizon Communications Planning and Construction Department • Kaiser Foundation Hospitals
• Lit Industrial Limited Partnership
• CLPF- Redlands Business Center
• Watson Land Company
• Ashley Furniture Industries Inc.
• BCI-OEF Redlands DC LP
• Teachers Insurance and Annuity Association
• CRP/NPP Redlands Industrial Owner, LLC
• Andrew Green, Cultural Resource Analyst, Native American Heritage Commission • Sam Wang, Program Supervisor, CEQA IGR Planning
• Nancy J. Sansonetti, Supervising Planner, Environmental Management Division, San Bernardino County Department of Public Works

12.2 Individuals (Owners)
There were no known individuals who were interested in the development of the proposed project and would be notified of any project documents that are circulated to the public.  SECTION 12.0 – RECIPIENTS OF THE DRAFT PEIR 
7214/Redlands – Kaiser Permanente Medical Center Page 12-3 Environmental Impact Report November 2025

12.3 Commenters Who Commented During the Initial Study Public Review Period and Provided Their Contact Information
The following are individuals who commented during Initial Study public review period. These individuals will be notified of any project documents that are circulated to the public.

Appendix A4 includes a comment matrix identifying environmental issues addressed in each comment letter.

No. Commenters Designation Organization/
Company
Contact Info
Email/Phone Number
1 Andrew Green
Cultural
Resource
Analyst
Native American
Heritage
Commission
[email protected]
2 Sam Wang Program
Supervisor
South Coast Air
Quality Management
District
[email protected]
3 Michael Fam Engineering
Manager
San Bernardino
County Department
of Public Works
(909) 387-8120
4 Anthony Fam, P.E. Engineering
Manager
San Bernardino
County Department
of Public Works
(909) 387-8186

FINAL PROGRAM ENVIRONMENTAL IMPACT REPORT
(PEIR) AND RESPONSE TO COMMENTS
(SCH # 2025010666)

FOR THE

KAISER PERMANENTE REDLANDS MEDICAL CENTER
Prepared for:

City of Redlands
Kevin Beery, Senior Planner
35 Cajon Street, Suite 20
Redlands, CA 92373
Prepared by:

UltraSystems Environmental Inc.
16431 Scientific Way
Irvine, CA 92618
Telephone: 949.788.4900
Fax: 949.788.4901
February 2026
Project: 7214
❖ TABLE OF CONTENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page i Response to Comments February 2026

TABLE OF CONTENTS

1.0 INTRODUCTION....................................................................................................................................1-1

1.1 Organization of the Final PEIR ....................................................................................................... 1-1

1.2 Public Review Process ....................................................................................................................... 1-2

1.3 Background of Environmental Review Process for the Project........................................ 1-3

2.0 RESPONSES TO COMMENTS .............................................................................................................2-1

2.1 Introduction........................................................................................................................................... 2-1

2.2 Bracketed Comment Letters............................................................................................................ 2-2

2.3 Comments and Responses................................................................................................................ 2-4

3.0 ERRATA...................................................................................................................................................3-1

3.1 Section 1.0 Executive Summary..................................................................................................... 3-1

3.2 Section 3.4 Approach to Cumulative Impacts Analysis ......................................................3-13

3.3 Section 4.1 Aesthetics......................................................................................................................... 3-0

3.4 Cultural Resources .............................................................................................................................. 3-0

3.5 Noise.......................................................................................................................................................... 3-0

3.6 Tribal Cultural Resources................................................................................................................. 3-1

3.7 Section 7.0 References...................................................................................................................... 3-2

4.0 FINAL MITIGATION MONITORING AND REPORTING PROGRAM........................................4-1

ATTACHMENTS
Attachment A Notice of Availability
Attachment B Posting at the State of California, Office of Land Use and Climate Innovation State Clearinghouse
Attachment C San Bernardino County Clerk/Recorder Posting/Recording - NOA Attachment D Newspaper Posting and Affidavit - NOA
❖ SECTION 1.0 -INTRODUCTION ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 1-1 Response to Comments February 2026

1.0 INTRODUCTION
In accordance with California Environmental Quality Act (CEQA) Guidelines § 15089, the City of Redlands, the Lead Agency, must prepare a Final Environmental Impact Report (EIR) before approving a project. The purpose of a Final EIR is to provide an opportunity for the lead agency to respond to comments made by the public and agencies regarding the Kaiser Permanente Medical Center Draft Program EIR (PEIR). Pursuant to CEQA Guidelines § 15132, this Final PEIR includes revisions to the Draft PEIR; a list of persons, organizations, and agencies that provided comments on the Draft PEIR; comments and recommendations received regarding the Draft PEIR; responses to environmental comments received; and other information added by the Lead Agency. The Final PEIR also includes the final Mitigation Monitoring and Reporting Program.

This Final PEIR constitutes the second part of the PEIR for the project and is intended to be a companion to the Draft PEIR. The Draft PEIR for the project, which circulated for public review and comment from November 18, 2025 to January 5, 2026, constitutes the first part of the PEIR and is incorporated by reference and bound separately.

1.1 Organization of the Final PEIR
This Final PEIR is organized into the following four sections:

Section 1.0 Introduction—This section describes the purpose of the Final PEIR, outlines the contents of the Final PEIR, summarizes the Final PEIR process, and provides a summary of the proposed project.

Section 2.0 Responses to Comments—This section provides a matrix depicting those individuals and entities that commented on the Draft PEIR and the issues that they raised.

Section 3.0. Errata—This section provides a list of revisions made to the Draft PEIR based on public comments and other items requiring revision.

These changes are minor and do not add significant new information that would affect the analysis or conclusions presented in the Draft EIR. Section 15088.5(a) of the CEQA Guidelines specifically states:

New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
• A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
• A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
❖ SECTION 1.0 -INTRODUCTION ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 1-2 Response to Comments February 2026
• A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it. • The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

CEQA Guidelines § 15088.5(b) states that “recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.”
As detailed in this Final PEIR the comments submitted on the Draft PEIR, the responses to these comments, the corrections and additions presented in Section III of this Final PEIR, do not constitute new significant information warranting recirculation of the Draft PEIR as set forth in CEQA Guidelines § 15088.5. Rather, the Draft PEIR is comprehensive and has been prepared in accordance with CEQA.

Section 4.0 Mitigation Monitoring and Reporting Program (MMRP) - This section provides the full and final MMRP for the proposed project. The MMRP lists project design features and mitigation measures by environmental topic and identifies the level of significance after mitigation, the responsible party/monitoring party and the implementation stage.

This Final PEIR also includes the following attachments:

Attachment A Notice of Availability (NOA)
Attachment B Posting at the State of California, Office of Land Use and Climate Innovation State Clearinghouse
Attachment C San Bernardino County Clerk/Recorder Posting/Recording - NOA Attachment D Newspaper Posting and Affidavit - NOA

1.2 Public Review Process
In accordance with CEQA, the environmental review process for the project commenced with solicitation of comments from identified responsible and trustee agencies, as well as interested parties on the scope of the Draft PEIR, through a Notice of Preparation (NOP) process. The NOP was circulated for public comment to the State Clearinghouse, Office of Planning and Research, responsible agencies, owners, local addresses, and other interested parties from January 22, 2025 through February 21, 2025. The NOP was Appendix A3 in the Draft PEIR and the public comments received on the Initial Study were included as Appendix A1 in the Draft PEIR.

Consistent with the requirements of § 15087 of the CEQA Guidelines, the Draft PEIR was submitted to the State Clearinghouse, Office of Planning and Research for distribution to state agencies and was circulated for a 45-day public review commencing on November 18, 2025, and ending on January 5, 2026. A Notice of Availability of the Draft PEIR was emailed to those interested parties who requested notice. A press release describing the PEIR and public review thereof was published in the Redlands Daily Facts newspaper on November 18, 2025. The Draft PEIR was made available for review on City of Redlands website (available here: https://www.cityofredlands.org/post/environmental- ❖ SECTION 1.0 -INTRODUCTION ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 1-3 Response to Comments February 2026
documents) and at the City’s Development Services Department at 35 Cajon Street, Suite 20, Redlands, CA 92373, A.K. Smiley Public Library at 125 W. Vine Street, Redlands, CA 92373, and at the County’s Clerk of the Board Office located at 385 N. Arrowhead Avenue, #2, San Bernardino, CA 92415. Following the Draft PEIR public comment period, this Final PEIR has been prepared and includes responses to the comments raised regarding the Draft PEIR.

1.3 Background of Environmental Review Process for the Project The Initial Study for the project was distributed for public review from January 22 to February 21, 2025, for 30 days, as part of the Notice of Preparation (NOP) process. Below is a summary of the public notification and scoping process for the project. The NOP includes information regarding the project, notice of availability of the Initial Study, the public comment period, and notice regarding the public scoping meeting. A copy of the NOP, which included notice for the scoping meeting, was sent to owners adjacent to the project site.

On January 22, 2025, the following documents were submitted to the State Clearinghouse CEQA Submit database: one signed copy of the NOC, a copy of the NOP, and an electronic version of the Initial Study and Initial Study appendices. A public scoping meeting for the project was held at 4:30 p.m. on February 12, 2025. As part of the public distribution process for the Initial Study for the proposed project, Native American tribal contacts were sent a copy of the NOP and a CD with the Initial Study and Initial Study appendices.

Tribal Consultation
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:
• 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
❖ SECTION 1.0 -INTRODUCTION ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 1-4 Response to Comments February 2026
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
In response to the consultation invitations, six responses were received regarding the project, but not the DPEIR. 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. While no formal consultation request was received from the Yuhaaviatam of San Manuel Nation, so no agreement was made to include their proposed Mitigation Measures, edits to the project’s MM CUL-2 were made to accommodate the request regarding notification. Further, project documents pertaining to archaeological and/or cultural resources will be provided to requesting tribes, including the Yuhaaviatam of San Manuel Nation, upon receipt of a request pursuant to the California Public Records Act, consistent with CA. Gov’t Code sections 6254(r) and 6254.10, and CA. Pub. Res. Code section 21074.”
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 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 ❖ SECTION 1.0 -INTRODUCTION ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 1-5 Response to Comments February 2026
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.
❖ SECTION 2.0 - RESPONSES TO COMMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 2-1 Response to Comments February 2026

2.0 RESPONSES TO COMMENTS

2.1 Introduction
Sections 21091(d) and 21092.5 of the Public Resources Code (PRC) and CEQA Guidelines § 15088 govern the lead agency’s responses to comments on a Draft EIR. CEQA Guidelines § 15088(a) states:
“The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The Lead Agency shall respond to comments raising significant environmental issues received during the noticed comment period and any extensions and may respond to late comments.” In compliance with these requirements, this section of the Final PEIR provides the responses to each of the written comments received regarding the Draft PEIR.

Section 2.2 contains bracketed comment letters, as received for the Kaiser Permanente Medical Center Project. Section 2.3, Comment Letters and Responses, provides a response to each written comment raised.
❖ SECTION 2.0 - RESPONSES TO COMMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 2-2 Response to Comments February 2026

2.2 Bracketed Comment Letters

2.2.1 Comment Letter A
❖ SECTION 2.0 - RESPONSES TO COMMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 2-3 Response to Comments February 2026

2.2.2 Comment Letter B
❖ SECTION 2.0 - RESPONSES TO COMMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 2-4 Response to Comments February 2026

2.3 Comments and Responses
The comments and responses are included in the table below.

Letter Agency, Organization, or Individual Date
A Xitlaly Madrigal NAGPRA Supervisor
Tribal Historic Preservation Office
Agua Caliente Band of Cahuilla Indians (ACBCI)
December 2, 2025
Comment A-1 At this time the concerns of the ACBCI THPO have been addressed and proper mitigation measures have been proposed to ensure the protection of tribal cultural resources. This letter shall conclude our consultation efforts.

Response A-1 Comment noted. Thank you.

B Sophia Pina, Executive Assistant to Hereditary
Chief and Chairman Andrew Salas
Gabrieleño Band of Mission Indians - Kizh Nation
January 6, 2026
Comment B-1 We are writing to request a revision to the Draft Program Environmental Impact Report (PEIR). While the Tribal Cultural Resource (TCR) mitigation measures in the draft appear to reflect those developed and submitted by the Gabrieleño Band of Mission Indians – Kizh Nation through the AB 52 consultation process, the language does not clearly identify our Tribe as the consulting tribal government that provided these measures.

Response B-1 In Section 4.13 of the Draft PEIR, under the subheading Consultation with Gabrieleño Band of Mission Indians –Kizh Nation, on Page 4.13-13, it states “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.” Comment B-2 We respectfully request that the Draft PEIR be revised to explicitly identify the Gabrieleño Band of Mission Indians – Kizh Nation as the consulting Tribe that provided both the substantial evidence and the project-specific TCR mitigation measures.

Response B-2 In Section 4.13 of the Draft PEIR , under the subheading Consultation with Gabrieleño Band of Mission Indians –Kizh Nation, on Page 4.13-13, it states “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.” Comment B-3 Failure to properly identify the consulting Tribe fundamentally undermines the integrity of the AB 52 consultation process, renders the mitigation measures deficient, and creates a risk that they will be misapplied or implemented inconsistently with the Tribe’s authority and expertise.

Response B-3 The Gabrieleño Band of Mission Indians – Kizh Nation was identified specifically in Section 4.13 of the Draft PEIR, under the subheading Consultation with Gabrieleño Band of Mission Indians –Kizh Nation, on

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.” Furthermore, the Gabrieleño Band of Mission Indians – Kizh ❖ SECTION 2.0 - RESPONSES TO COMMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 2-5 Response to Comments February 2026
Letter Agency, Organization, or Individual Date
Nation is now identified specifically in the mitigation measures TCR-1 and TCR-2 in the text and the MMRP (Section 1.10.7 Tribal Cultural Resources, Page 1-20; Section 4.13.7 Mitigation Measures, pages 4.13-15 to 4.13-16 and Section

11.0, Mitigation Monitoring and Reporting Program, pages 11-22 to 11-23).

Comment B-4 Please confirm that the City will make this correction in the PEIR and the associated Mitigation Monitoring and Reporting Program (MMRP). If a meeting or discussion would be helpful to ensure accuracy, we are available.

Response B-4 The City has added the Gabrieleño Band of Mission Indians – Kizh Nation to mitigation measures TCR-1 and TCR-2 in Section III.1, Corrections and Additions to Draft PEIR Sections and Appendices, Section III.1.1 Section

1.10.7 Tribal Cultural Resources, Page 1-20; Section 4.13.7 Mitigation Measures, pages 4.13-15 to 4.13-16 and Section 11.0, Mitigation Monitoring and Reporting Program, pages 11-22 to 11-23. These changes are also reflected in the Final MMRP shown in this Final PEIR Section IV. ❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-1 Response to Comments February 2026

3.0 ERRATA
This section of the Final PEIR provides changes to the Draft PEIR that have been made to revise, clarify, or correct the environmental analysis for the Kaiser Permanente Medical Center Project.

Changes in this section are a result of comments received in response to the Draft PEIR. The changes detailed in this section do not result in the project creating any new or increased significant environmental impacts.

Added text is shown underlined and deleted text in strikeout.

3.1 Section 1.0 Executive Summary

3.1.1 Section 1.10 Mitigation Measures, Pages 1-11 to 1-21 Section 1.10, Mitigation Measures, is revised and the mitigation measures are replaced with the mitigation measures below to accurately reflect revisions to text in the PEIR Section 4.0 and the MMRP Section 11.0 for consistency.

3.1.1.1 Section 1.10.1 Air Quality, Pages 1-11 to 1-12
Impacts associated with significance threshold B would be potentially significant without mitigation.

Therefore, the following mitigation measures would be required, if feasible, to minimize potential impacts related to air quality emissions:

MM AQ-1: Include in a Plan or Policy that Gas Powered Landscape Equipment must be replaced with Zero-Emission Landscape Equipment (listed at A-1 in the aforementioned CAPCOA Handbook, and LL-1 in CalEEMod). If feasible, landscape and maintenance contracts shall require only Zero-Emission Landscape Equipment be used.

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

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.

Additional measures that were not incorporated in the emissions calculations but further reduce VMT-related emissions are listed below. The project includes several targeted mitigation strategies, evaluated and quantified by Fehr & Peers in the traffic impact study (Fehr & Peers, 2025). A multiplicative dampening factor was applied to account for overlap among measures addressing the same trip types. The following mitigation measures and corresponding VMT reductions are proposed and further discussed in Sections 1.10.6 and 4.12.5:

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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 provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions.

3.1.1.2 Section 1.10.2 Biological Resources, Pages 1-12 to 1-16 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,
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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).

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 ❖ SECTION 3.0 - ERRATA❖
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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 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:
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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.

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
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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.

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.
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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 highvibration 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.

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.

3.1.1.3 Section 1.10.3 Cultural Resources, Pages 1-16 to 1-17 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. ❖ SECTION 3.0 - ERRATA❖
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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, the Yuhaaviatam of San Manuel Nation, the Gabrieleño Band of Mission Indians – Kizh Nation, 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:

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, the Yuhaaviatam of San Manuel Nation, the Gabrieleño Band of Mission Indians – Kizh Nation, 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.
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.
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1. Consultation with relevant groups, such as Native American tribes, historians, and regulatory agencies, to determine the value of resources and appropriate treatment measures.

2. 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).

3.1.1.4 Section 1.10.4 Geology and Soils, Pages 1-17 to 1-18 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:
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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 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.

3.1.1.5 Section 1.10.5 Greenhouse Gas Emissions, Pages 1-18 to 1-19 MM GHG-1 Using alternative fuels for construction equipment (0 to 22 percent).

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 −
𝑡𝑚
𝑡𝑏
)100, where 𝑡𝑚 is the
mitigated idling period and 𝑡𝑏 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.
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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).

MM TRANS-4, MM AQ-1 and MM AQ-2 were taken into account in calculations for greenhouse gas emissions in Section 4.7.5. These measures are detailed in Section 1.10.1 above.

3.1.1.6 Section 1.10.6 Transportation, Page 1-19
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 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 ❖ SECTION 3.0 - ERRATA❖
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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.

3.1.1.7 Section 1.10.7 Tribal Cultural Resources, Pages 1-20 to 1-21 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), including Gabrieleño Band of Mission Indians – Kizh Nation. 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). “Ground-disturbing 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), including Gabrieleño Band of Mission Indians – Kizh Nation, shall be submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

3. The monitor(s), including Gabrieleño Band of Mission Indians – Kizh Nation, 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 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, including Gabrieleño Band of Mission Indians – Kizh Nation.

4. On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Consulting Tribe(s) , including Gabrieleño Band of Mission Indians – Kizh Nation, 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) , including Gabrieleño Band of Mission Indians – Kizh Nation, 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)

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the discovered TCR has been fully assessed by the Consulting Tribe(s) , including Gabrieleño Band of Mission Indians – Kizh Nation, monitor(s) and/or archaeologist(s).

MM-TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects

1. 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.

2. 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.

3. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

4. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

5. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

3.2 Section 3.4 Approach to Cumulative Impacts Analysis

3.2.1 Section 3.4.1 Cumulative Projects, Pages 3-10 to 3-13 During the Draft PEIR public review period, County of San Bernadino provided cumulative project information for the San Bernardino County area shown on Figure 3.4-1 and referred to as “an island of unincorporated San Bernardino County (the East Valley Area Plan area)”.

This information included a total of six projects including four industrial and two residential (County of San Bernardino, 2025). These projects have been added to Figure 3.4-1 (page 3-11) and Table 3.4- 1 (pages 3-12 to 3-13). These changes are shown below.

Four of the six projects were approved prior to 2024 (one in 2020, one in 2022, and two in 2023) and appear on current aerial maps (County of San Bernardino, 2025); their construction would not overlap with Kaiser Permanente Redlands Medical Center. These projects are the same as the existing surrounding land uses, which were accounted for in the cumulative impacts analysis. Therefore, this new information would not change the results of the cumulative impacts analysis. ❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-0 Response to Comments February 2026
Figure 3.4-1

CUMULATIVE PROJECTS LOCATIONS
❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-0 Response to Comments February 2026
Table 3.4-1

CUMULATIVE PROJECTS LIST
Map
ID Address Land Use Type
Square Feet Residential
Industrial Commercial Units
City of Redlands
1 1101 California St warehouse/distribution 357,610
2 1700 Orange Tree Ln Woodspring Suites Hotel: 123 rooms 3 1301 Lugonia Avenue Fast-food restaurant with drive through: 3,860 4 1234-1528 Tennessee St Commercial and Multifamily residential 18,000 460 5 1110-1130 W Lugonia Ave Tennessee Shopping Center:

Retail/Restaurant 60,385
6 1005 W Lugonia Ave retail and restaurant 22,047
7 1305-1499 Karon St Multifamily residential 511
8 Pioneer Av east of SR-210 Motorcourt residential 75
9 Mountain View Av at I-10 Planned Development No. 4: two warehouse/ distribution buildings 420,937
10 10796 New Jersey St. manufacturing 28,000
11 1980 Park Av Industrial 48,079
12 1941 Park Av Industrial 38,740
13 10843 New Jersey Street Industrial 179,400
14 10756 Nevada St. Industrial 87,771
15 Redlands Blvd east of Nevada St 2 medical office buildings 16,714 16 1702 W Park Av Industrial 7,198
17 Iowa St at Park Av Manufacturing 25,000
18 350 Iowa St Warehouse/distribution 185,000
19 Alabama St at Citrus Dr Medical and medical office 8,853 20 10616 Kansas St. and 27314 W. Park Ave. Warehouse 83,875 21 Alabama St at Orange Ave apartments 328
22 Orange Av west of Alabama St apartments 164
23 27240 Alabama St Commercial 8,015
24 301 Tennessee St. Warehouse/distribution 197,397
❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-1 Response to Comments February 2026
Map
ID Address Land Use Type
Square Feet Residential
Industrial Commercial Units
25 New York St at Brockton Av Auto sales/service 53,800 26 Tennessee St at Lugonia Av retail 4,100
City of San Bernardino
27 Central Av west of Tippecanoe Compressed natural gas fueling facility City of Loma Linda
28 Redlands Blvd at Richardson St Medical office and retail 30,382 29 Heirloom Way at Park Av apartments 213
30 Southeast of Park Av at Bryn Mawr Community Park: 15 acres 31 Southeast of Park Av at Bryn Mawr Community Center: 6,000 sf 32 Southeast of Park Av at Bryn Mawr Fire Station, 3,690 sf 33 24850 Redlands Blvd Motel, 25 rooms
34 Barton Rd and Nevada St Single-family residential 126 35 North of Citrus Ave, west of Bryn Mawr Ave Condominiums 103 36 California St and Orange Ave Single-family residential 126 37 25450 Park Ave Single-family residential 18
38 East of Bryn Mawr Ave, north of Park Ave,
south of Redlands Mixed use (multifamily residential and retail) 100,000 219 39 913 California Street, The Commons at CA
Project Business Hotel 60,224
40 E of Hwy 210 between Pioneer & San
Bernardino Ave Single-family residential and apartments 263 County of San Bernardino
41 North side of San Bernardino Avenue,
approx. 590 feet west of Alabama Street
Warehouse building 190,000
42 24000 Lugonia Ave Multi-family residential 282
43 27195 Almond Ave Warehouse 208,000
44 25000 Lugonia Four parcels Medium Density Residential 45 27630 Pioneer Ave, #A, B, C Warehouse building with office space 9,950 46 27081 Almond Ave Existing warehouse expansion 95,963 ❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-2 Response to Comments February 2026
Map
ID Address Land Use Type
Square Feet Residential
Industrial Commercial Units
Total 1,659,007
2,162,920 386,380 2,6062,888
Note: An island of unincorporated San Bernardino County (the East Valley Area Plan area) is present in the northwest part of the City of Redlands near the project site.

The San Bernardino County Planning Division was contacted via phone April 14, 2025, then again via phone, email, and County Land Use Services Department contact form October 29, 2025. No information was provided or readily available for the unincorporated San Bernardino County area shown on the map and thus not included on the map and table. During the Draft PEIR public review period, the San Bernadino County provided cumulative project information and it was added to this table.

Source: City of Redlands 2024; City of Loma Linda 2024; City of San Bernardino 2024; County of San Bernardino, 2025. ❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-0 Response to Comments February 2026

3.3 Section 4.1 Aesthetics

3.3.1 Section 4.1.4.1 Thresholds of Significance, last paragraph, Page 4.1-6 The following text was added to the end of the last paragraph of Section 4.1.4.1.

Further, the areas surrounding the project site are already developed and any additional light or glare from the project is anticipated to be consistent with levels already present in the vicinity of the project site. The surrounding commercial businesses operate as logistical warehousing with semi tractor trailer trucks operating with large light beams continuously as well as many installations of security lighting. The project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area and the project would have no significant impacts regarding threshold d.

3.4 Cultural Resources

3.4.1 Section 1.10.3 Cultural Resources, Page 1-16; Section 4.4.7 Mitigation Measures,

11-14
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, the Yuhaaviatam of San Manuel Nation, the Gabrieleño Band of Mission Indians – Kizh Nation, 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.

3.5 Noise

3.5.1 Section 4.10.5.2 Analysis of Project Impacts, Page 4.10-13 The following text was added to the end of the first paragraph on page 4.10-13. "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 Lead Agency review and consideration construction of Phase 3 to ensure that noise levels during construction would not exceed the 80 dBA Leq FTA threshold." ❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-1 Response to Comments February 2026

3.6 Tribal Cultural Resources

3.6.1 Section 1.10.7 Tribal Cultural Resources, Page 1-20; Section 4.13.7 Mitigation Measures, Pages 4.13-15 to 4.13-16; and Section 11.0 Mitigation Monitoring and Reporting Program, Pages 11-22 to 11-23
The MM-TCR-1 and MM-TCR-2 were revised to include the Gabrieleño Band of Mission Indians – Kizh Nation as follows.

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), including Gabrieleño Band of Mission Indians – Kizh Nation. 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). “Ground-disturbing 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), including Gabrieleño Band of Mission Indians – Kizh Nation, shall be submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

3. The monitor(s), including Gabrieleño Band of Mission Indians – Kizh Nation, 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 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, including Gabrieleño Band of Mission Indians – Kizh Nation.

4. On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Consulting Tribe(s) , including Gabrieleño Band of Mission Indians – Kizh Nation, 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) , including Gabrieleño Band of Mission Indians – Kizh Nation, 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) ❖ SECTION 3.0 - ERRATA❖
7214/Kaiser Permanente Redlands Medical Center PEIR Page 3-2 Response to Comments February 2026

1. 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) , including Gabrieleño Band of Mission Indians – Kizh Nation, monitor(s) and/or archaeologist(s).

3.7 Section 7.0 References

3.7.1 Top of Page 7-7
The following reference is added to the references section.

County of San Bernardino, 2025. [Document Released to Requester] San Bernardino County public records request #25-28287. PRA 25-28287 Active Projects in EVZD.xlsx and Active Projects in East Valley Zoning Districts.pdf (map). Email from San Bernardino County Public Records to Michael Milroy (UltraSystems Environmental Inc.). November 20, 2025. ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-1 Response to Comments February 2026

4.0 FINAL MITIGATION MONITORING AND REPORTING PROGRAM
The Final Mitigation Monitoring and Reporting Program (MMRP) has been prepared in conformance with § 21081.6 of the Public Resources Code and § 15097 of the CEQA Guidelines, which requires all state and local agencies to establish monitoring or reporting programs whenever approval of a project relies upon a MND or an EIR. The MMRP ensures implementation of the measures being imposed to mitigate or avoid the significant adverse environmental impacts identified through the use of monitoring and reporting. Monitoring is generally an ongoing or periodic process of project oversight; reporting generally consists of a written compliance review that is presented to the decision-making body or authorized staff person.

It is the intent of the MMRP to: (1) provide a framework for document implementation of the required mitigation; (2) identify monitoring/reporting responsibility; (3) provide a record of the monitoring/reporting; and (4) ensure compliance with those mitigation measures (MMs) that are within the responsibility of the City and/or Applicant to implement.

This MMRP includes specific project design features (PDFs) and best management practices (BMPs) referenced in the PEIR that will be implemented with the project's construction and operation. The specific PDFs and BMPs are presented in Table 4.0-1 below.

The required MMs are presented in Table 4.0-2 below. Environmental topics for which mitigation is required are listed in Table 4.0-2 under their corresponding impact category. This table also lists impacts, mitigation measures adopted by the City of Redlands in connection with approval of the proposed project, level of significance after mitigation, responsible and monitoring parties, and the project phase in which the measures are to be implemented. ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-2 Response to Comments February 2026
Table 4.0-1
PROJECT DESIGN FEATURES (PDFs) AND BEST MANAGEMENT PRACTICES (BMPs) Issue Area Project Design Features (PDFs) and Best Management Practices (BMPs)

4.5 Geology and Soils
Threshold F:

Would the project
directly or indirectly
destroy a unique
paleontological
resource or site or
unique geologic
feature?
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 Investigation Report prepared for the Medical Office Building 2 (MOB 2) project at the Kaiser Redlands site located at 1301 California Street in Redlands.

Prepared by Twining, dated March 31, 2023; provided in Appendix D7 of this PEIR.

4.7 Greenhouse Gas Emissions
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. ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-3 Response to Comments February 2026
Issue Area Project Design Features (PDFs) and Best Management Practices (BMPs) 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).

4.10 Noise
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?
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.
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-4 Response to Comments February 2026
Table 4.0-2

FINAL MITIGATION MONITORING AND REPORTING PROGRAM
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage

4.2 Air Quality
Threshold A:

Would the project
result in a
cumulatively
considerable net
increase of any
criteria pollutant for
which the project
region is nonattainment under an
applicable federal or
state ambient air
quality standard?
MM AQ-1
Replace Gas Powered Landscape Equipment with ZeroEmission Landscape Equipment (listed at A-1 in the aforementioned CAPCOA Handbook, and LL-1 in CalEEMod).

Less than
Significant
Project Applicant/City of
Redlands
During Project
Operation
MM AQ-2
Provide Electric Vehicle Charging Infrastructure (listed as T14 in CalEEMod).

Less than
Significant
Project Applicant/City of
Redlands
Include in Building
Plans; and During
Project Construction
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.

Less than
Significant
Project Applicant/City of
Redlands
During Project
Operation
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 singleoccupied vehicle trips, thereby reducing the number of trips, VMT, and GHG emissions. Existing programs including IE
Less than
Significant
Project Applicant/City of
Redlands
During Project
Operation
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-5 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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 provision and maintenance of secure bike
parking and related facilities encourages commuting by
bicycle, thereby reducing VMT and GHG emissions.

Less than
Significant
Project Applicant/City of
Redlands
Include in Building
Plans; and During
Project Construction
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, singleoccupied 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.

Less than
Significant
Project Applicant/City of
Redlands
During Project
Operation

4.3 Biological Resources
Threshold A: Would
the Project have a
substantial adverse
effect, either directly
or through habitat
modifications, on any
species identified as a
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 Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Before
beginning of
ground
disturbance;
three surveys
shall be
conducted with
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-6 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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?
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
at least two
weeks between
surveys from
April to June.
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-7 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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).

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 Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
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
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-8 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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:

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

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

5. 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
after June 15. Nonbreeding season
surveys shall include
four surveys spread
out evenly from July
15 to February 15.

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.
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-9 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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 non-breeding 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 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.
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-10 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage

6. Passive and/or active relocation activities.

7. 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 Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Prior to the issuance
of grading permits for
the project. Preactivity 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.
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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.

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 ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-12 Response to Comments February 2026
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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 ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-13 Response to Comments February 2026
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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.

2. Results of the bat surveys.

Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Prior to
implementation of
project activities
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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.
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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 Less than
Significant
Qualified
biologist/Applicant/City
of Redlands
Prior to approval of
grading permits and
initiation of project
activities
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waters of the state.

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.

4.4 Cultural Resources
Threshold A: Would
the Project cause a
substantial adverse
change in the
significance of a
historical resource
pursuant to §
15064.5?
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 Less than
Significant
Qualified archaeologist;
project applicant; and
City of Redlands
Before beginning of
ground-disturbing
work; and during site
clearance
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And
Threshold B: Would
the Project cause a
substantial adverse
change in the
significance of an
archaeological
resource pursuant to §
15064.5?
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, the Yuhaaviatam of San Manuel Nation, the Gabrieleño Band of Mission Indians – Kizh Nation, 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:

6. Results of the Cultural Resources Inventory:

Less than
Significant
Qualified archaeologist;
project applicant; and
City of Redlands
During construction
activities
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archaeological resources and their condition and threats on the project site.

7. Impact assessment.

8. Mitigation strategies, which may include:
a. Potential avoidance measures.
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.

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

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

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

9. Documenting and reporting format and procedures.
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Threshold C: Would
the Project disturb
human remains,
including those
interred outside of
dedicated cemeteries?
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).

Less than
Significant
Qualified archaeologist;
project applicant; and
City of Redlands
During excavations
associated with this
project

4.5 Geology and Soils
Threshold F: Would
the Project directly or
indirectly destroy a
unique paleontological
resource or site or a
unique geologic
feature?
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 Less than
Significant
Qualified
paleontologist/project
applicant; City of
Redlands
Prior to excavation
and grading activities
at the project site; and
during excavation and
grading activities
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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
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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 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.

4.7 Greenhouse Gas Emissions
Threshold A: Would
the Project generate
MM GHG-1 Significant
and
Project applicant and
project construction
Include in project
building plans; and
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greenhouse gas
emissions, either
directly or indirectly,
that may have a
significant impact on
the environment?
And
Threshold B: Would
the Project conflict
with an applicable
plan, policy or
regulation adopted for
the purpose of
reducing the
emissions of
greenhouse gases?
Using alternative fuels for construction equipment (0 to 22 percent).

Unavoidable contractor during project
construction
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).

Significant
and
Unavoidable
Project applicant and
project construction
contractor
Include in project
building plans; and
during project
construction
MM GHG-3
Limiting construction equipment idling beyond regulation requirements (varies with the amount of project idling
occurring and the amount reduced).

Significant
and
Unavoidable
Project applicant and
project construction
contractor
Include in project
building plans; and
during project
construction
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:

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

7. 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):

Significant
and
Unavoidable
Project applicant and
project construction
contractor
Include in project
building plans; and
during project
construction
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Install verified diesel emission control strategies
(e.g., exhaust retrofits) on existing engines.

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

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

10. 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).

Significant
and
Unavoidable
Project applicant and
project construction
contractor
Include in project
building plans; and
during project
construction
MM AQ-1-2 and MM TRANS 1-4
See 4.2 Air Quality Above.

Significant
and
Unavoidable

4.12 Transportation
Threshold B: Would
the project conflict or
be inconsistent with
CEQA Guidelines
section 15064.3,
subdivision (b)?
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, Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project
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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 singleoccupied vehicle trips, thereby reducing the number of trips, VMT, and GHG emissions. Existing programs including IE
Commuter can be leveraged for this measure.

Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project
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 provision and maintenance of secure bike
parking and related facilities encourages commuting by
bicycle, thereby reducing VMT and GHG emissions.

Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project
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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, singleoccupied 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.

Significant
and
Unavoidable
Project applicant/City of
Redlands
Prior to issuance of a
certificate of
occupancy for each
phase of the project

4.13 Tribal Cultural Resources
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
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),
including Gabrieleño Band of Mission Indians – Kizh
Nation. 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 onsite 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). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, Less than
Significant
Native American
Monitor/Project
Applicant/City of
Redlands
Prior to
Commencement of
Ground-Disturbing
Activities; and during
ground-disturbing
activities
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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
auguring, grubbing, tree removal, boring, grading,
excavation, drilling, and trenching.

2. A copy of the executed monitoring agreement with each monitoring Consulting Tribe(s), including Gabrieleño
Band of Mission Indians – Kizh Nation, shall be submitted to the lead agency prior to the earlier of the
commencement of any ground-disturbing activity, or the
issuance of any permit necessary to commence a grounddisturbing activity.

3. The monitor(s), including Gabrieleño Band of Mission Indians – Kizh Nation, 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 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, including Gabrieleño Band of Mission Indians – Kizh Nation.

4. On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the
Consulting Tribe(s) , including Gabrieleño Band of
Mission Indians – Kizh Nation, from a designated point
of contact for the project applicant that all grounddisturbing activities and phases that may involve ground- ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-27 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
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.
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) , including Gabrieleño Band of Mission Indians – Kizh Nation, 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/Non-Ceremonial)

1. 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), including Gabrieleño Band of Mission Indians – Kizh Nation, monitor(s) and/or
archaeologist(s).

Less than
Significant
Native American
Monitor/Project
Applicant/City of
Redlands
Prior to
Commencement of
Ground-Disturbing
Activities; and during
ground-disturbing
activities
MM-TCR-3: Unanticipated Discovery of Human Remains and
Associated Funerary or Ceremonial Objects

1. 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.

2. 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.

3. Human remains and grave/burial goods shall be treated Less than
Significant
Native American
Monitor/Project
Applicant/City of
Redlands
Prior to
Commencement of
Ground-Disturbing
Activities; and during
ground-disturbing
activities
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-28 Response to Comments February 2026
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage
alike per California Public Resources Code section
5097.98(d)(1) and (2).

4. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains
and/or burial goods.

5. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026

ATTACHMENT A

NOTICE OF AVAILABILITY
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
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7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
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7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
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7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
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7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026

ATTACHMENT B

POSTING AT THE STATE OF CALIFORNIA, OFFICE OF LAND

USE AND CLIMATE INNOVATION STATE CLEARINGHOUSE
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026

ATTACHMENT C

SAN BERNARDINO COUNTY CLERK/RECORDER

POSTING/RECORDING - NOA
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
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7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026

ATTACHMENT D

NEWSPAPER POSTING AND AFFIDAVIT - NOA
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026
❖ ATTACHMENTS ❖
7214/Kaiser Permanente Redlands Medical Center PEIR
Response to Comments February 2026

CEQA FINDINGS OF FACT AND

STATEMENT OF OVERRIDING CONSIDERATIONS

KAISER PERMANENTE REDLANDS MEDICAL CENTER

FINAL ENVIRONMENTAL IMPACT REPORT (FEIR)
(SCH # 2025010666)
Prepared for:

City of Redlands
City of Redlands
Kevin Beery, Senior Planner
35 Cajon Street, Suite 20
Redlands, CA 92373
Prepared by:

UltraSystems Environmental Inc.
16431 Scientific Way
Irvine, CA 92618
Telephone: 949.788.4900
Fax: 949.788.4901
January 2026
Project: 7214
 TABLE OF CONTENTS 
7214/Kaiser Permanente Redlands Medical Center Page i
Findings of Fact and Statement of Overriding Considerations January 2026

TABLE OF CONTENTS

1.0 INTRODUCTION....................................................................................................................................1-1

1.1 Organization and Format of Findings.......................................................................................... 1-1

1.2 Statutory Requirements for Findings and Statement of Overriding Considerations ...................................................................................................................................... 1-2

2.0 PROJECT OBJECTIVES.........................................................................................................................2-1

3.0 PROJECT DESCRIPTION.....................................................................................................................3-2

3.1 Program Environmental Impact Report And Discretionary Actions.............................. 3-2

4.0 EFFECTS DETERMINED TO BE LESS THAN SIGNIFICANT IN THE INITIAL STUDY AND DURING THE SCOPING PROCESS............................................................................4-1

4.1 Aesthetics ................................................................................................................................................ 4-1

4.2 Agriculture and Forestry Resources ............................................................................................ 4-1

4.3 Air Quality............................................................................................................................................... 4-2

4.4 Biological Resources........................................................................................................................... 4-3

4.5 Geology and Soils ................................................................................................................................. 4-3

4.6 Hazards and Hazardous Materials................................................................................................ 4-3

4.7 Hydrology and Water Quality......................................................................................................... 4-4

4.8 Land Use and Planning ...................................................................................................................... 4-5

4.9 Mineral Resources ............................................................................................................................... 4-6

4.10 Noise.......................................................................................................................................................... 4-6

4.11 Population and Housing.................................................................................................................... 4-6

4.12 Public Services ...................................................................................................................................... 4-7

4.13 Recreation............................................................................................................................................... 4-7

4.14 Transportation...................................................................................................................................... 4-7

4.15 Tribal Cultural Resources................................................................................................................. 4-8

4.16 Utilities and Services Systems ........................................................................................................ 4-8

4.17 Wildfire .................................................................................................................................................... 4-9

5.0 EFFECTS FOUND IN THE PEIR TO CREATE NO IMPACT OR A LESS THAN SIGNIFICANT IMPACT WITHOUT MITIGATION.........................................................................5-1

5.1 Aesthetics ................................................................................................................................................ 5-1

5.2 Air Quality............................................................................................................................................... 5-1

5.3 Biological Resources........................................................................................................................... 5-2

5.4 Energy....................................................................................................................................................... 5-2

5.5 Geology and Soils ................................................................................................................................. 5-2

5.6 Hazards and Hazardous Materials................................................................................................ 5-4

5.7 Hydrology and Water Quality......................................................................................................... 5-4

5.8 Noise.......................................................................................................................................................... 5-5

5.9 Public Services ...................................................................................................................................... 5-5

5.10 Utilities and Service Systems .......................................................................................................... 5-6

6.0 POTENTIALLY SIGNIFICANT ENVIRONMENTAL IMPACTS DETERMINED TO BE MITIGATED TO A LESS THAN SIGNIFICANT LEVEL ...........................................................6-1

6.1 Air Quality............................................................................................................................................... 6-1

6.2 Biological Resources........................................................................................................................... 6-4

6.3 Cultural Resources ............................................................................................................................6-14  TABLE OF CONTENTS 
7214/Kaiser Permanente Redlands Medical Center Page ii
Findings of Fact and Statement of Overriding Considerations January 2026

6.4 Geology and Soils ...............................................................................................................................6-19

6.5 Greenhouse Gas Emissions ............................................................................................................6-21

6.6 Tribal Cultural Resources...............................................................................................................6-25

7.0 ENVIRONMENTAL EFFECTS THAT REMAIN SIGNIFICANT AND
UNAVOIDABLE AFTER MITIGATION.............................................................................................7-1

7.1 Greenhouse Gas (GHG) Emissions ................................................................................................ 7-1

7.2 Transportation – Vehicle Miles Traveled (VMT).................................................................... 7-4

8.0 FINDINGS REGARDING PROJECT ALTERNATIVES....................................................................8-1

8.1 Alternative 1: No Project Alternative .......................................................................................... 8-1

8.2 Alternative 2: No Project/General Plan Buildout Alternative........................................... 8-2

8.3 Alternative 3: Reduced Intensity Alternative........................................................................... 8-3

8.4 Alternative 4: Dispersed Facilities Alternative........................................................................ 8-4

9.0 GENERAL CEQA FINDINGS ................................................................................................................9-1

9.1 Procedural Compliance With California Environmental Quality Act ............................. 9-1

9.2 Environmental Mitigation Monitoring Program..................................................................... 9-2

9.3 CEQA Guidelines Section 15091 and 15092 Findings .......................................................... 9-2

9.4 City of Redland’s Independent Judgment................................................................................... 9-3

9.5 Reliance on Record.............................................................................................................................. 9-3

9.6 Recirculation Not Required ............................................................................................................. 9-4

9.7 Certification Of The Final Program Environmental Impact Report................................ 9-6

10.0 ADOPTION OF STATEMENT OF OVERRIDING CONSIDERATIONS.................................... 10-1

ATTACHMENTS
Attachment A Final Mitigation Monitoring and Reporting Program (MMRP)

1.0–INTRODUCTION 
7214/Kaiser Permanente Redlands Medical Center Page 1-1 Findings of Fact and Statement of Overriding Considerations January 2026

1.0 INTRODUCTION
The California Environmental Quality Act (CEQA) requires that a number of written findings be made by the lead agency in connection with certification of an environmental impact report (EIR) prior to approval of the project pursuant to Sections 15091 (Findings) and 15093 (Statement of Overriding Considerations) of the CEQA Guidelines and Section 21081 of the California Public Resources Code.

This document provides the findings required by CEQA for the Lead Agency City of Redland’s (City) approval of the proposed Project.

The potential environmental effects of the proposed Kaiser Permanente Redlands Medical Center project (project or proposed project) have been analyzed in a Draft Program Environmental Impact Report (Draft PEIR) (State Clearinghouse (SCH) 2025010666) dated November 2025. A Final PEIR has also been prepared that incorporates the Draft PEIR, including supporting technical reports and appendices, and contains comments received on the Draft PEIR, responses to the individual comments, errata to the Draft PEIR, revisions to the Draft PEIR including any clarifications based on the comments and the responses to the comments, and a Mitigation Monitoring and Reporting Program (MMRP) for the proposed project. These findings are based upon all of the foregoing, as well as reports and presentations by City staff and consultants and all written and oral evidence contained in the administrative record of these proceedings.

1.1 Organization and Format of Findings
Section 1, Introduction, contains the general purpose of this Findings of Fact (Findings) and Statement of Overriding Considerations, organization of this document, and a description of the statutory requirements for the Findings and the Statement of Overriding Considerations.

Section 2 describes the project objectives.

Section 3 contains a summary project description, including the discretionary actions that support and are a part of the project.

Sections 4 – 7 describe the City’s independently judged CEQA findings. Section 4 identifies the proposed project's potential environmental effects that were determined to be less than significant in the Initial Study and during the scoping process. Section 5 identifies the proposed project’s environmental effects found in the PEIR to create no impact or a less than significant impact without mitigation. Section 6 identifies the proposed project’s potentially significant environmental impacts determined in the PEIR to be mitigated to a less than significant level. Section 7 identifies environmental effects that cannot be mitigated to a less than significant level, even though all feasible mitigation measures have been identified and incorporated into the project.

Section 8 identifies the proposed project alternatives that were studied in the PEIR and findings regarding same.

Section 9 discusses the general CEQA findings in support of project approval including findings regarding the project’s procedural and substantive compliance with CEQA..

Section 10 includes the Statement of Overriding Considerations providing the City’s views on the balance between the project’s significant environmental effects and the merits and objectives of the proposed project.

1.0–INTRODUCTION 
7214/Kaiser Permanente Redlands Medical Center Page 1-2 Findings of Fact and Statement of Overriding Considerations January 2026

1.2 Statutory Requirements for Findings and Statement of Overriding Considerations
CEQA (CA. Pub. Res. Code §§ 21000, et seq.) and the State CEQA Guidelines (Guidelines) (14 CA. Code Regs §§ 15000, et seq.) promulgated thereunder, require the environmental impacts of a project to be examined before a project is approved.

Guidelines Section 15043 (Authority to Approve Projects Despite Significant Effects) provides:

A public agency may approve a project even though the project would 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 Section 15091); and
(b) Specifically identified expected benefits from the project outweigh the policy of reducing or avoiding significant environmental impacts of the project. (See Section 15093.)
In relevant part, Guidelines Section 15090 (Certification of the Final EIR) provides:
(a) Prior to approving a project the lead agency shall certify that:
(1) The final EIR has been completed in compliance with CEQA; (2) The final EIR was presented to the decision making body of the lead agency and that the decision making body reviewed and considered the information contained in the final EIR prior to approving the project; and (3) The final EIR reflects the lead agency's independent judgment and analysis.

Regarding findings, Guidelines Section 15091 (Findings) provides:
(a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project, unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:

1. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect as identified in the final EIR.

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.

1.0–INTRODUCTION 
7214/Kaiser Permanente Redlands Medical Center Page 1-3 Findings of Fact and Statement of Overriding Considerations January 2026

3. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.
(b) The findings required by subsection (a) shall be supported by substantial evidence in the record.
(c) The finding in subdivision (a)(2) shall not be made if the agency making the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The finding in subsection (a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives.
(d) When making the findings required in subdivision (a)(1), the agency shall also adopt a program for reporting on or monitoring the changes which it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures. (e) The public agency shall specify the location and custodian of the documents or other material which constitute the record of the proceedings upon which its decision is based.
(f) A statement made pursuant to Section 15093 does not substitute for the findings required by this section.

The “changes or alterations” referred to in Section 15091(a)(1) above, that are required in, or incorporated into, the project which mitigate or avoid the significant environmental effects of the project, may include a wide variety of measures or actions as set forth in Guidelines Section 15370 (Mitigation), including:
(a) Avoiding the impact altogether by not taking a certain action or parts of an action. (b) Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
(c) Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment.
(d) Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
(e) Compensating for the impact by replacing or providing substitute resources or environments.

Guidelines Section 15092 (Approval) provides, in relevant part:

1.0–INTRODUCTION 
7214/Kaiser Permanente Redlands Medical Center Page 1-4 Findings of Fact and Statement of Overriding Considerations January 2026 (a) After considering the final EIR and in conjunction with making findings under Section 15091, the lead agency may decide whether or how to approve or carry out the project.
(b) A public agency shall not decide to approve or carry out a project for which an EIR was prepared unless either:
(1) The project as approved will not have a significant effect on the environment, or (2) The agency has:
(A) Eliminated or substantially lessened all significant effects on the environment where feasible as shown in findings under Section 15091, and (B) Determined that any remaining significant effects on the environment found to be unavoidable under Section 15091 are acceptable due to overriding concerns as described in Section 15093. …
Regarding a Statement of Overriding Considerations, Guidelines Section 15093 (Statement of Overriding Considerations) provides:
(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 proposal project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable."
(b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. (c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091.  2.0–PROJECT OBJECTIVES 
7214/Kaiser Permanente Redlands Medical Center Page 2-1 Findings of Fact and Statement of Overriding Considerations January 2026

2.0 PROJECT OBJECTIVES
As described in the Project Description in Chapter 2.0 of the PEIR, the proposed Kaiser Permanente Redlands Medical Center project aims to achieve the following primary objectives:

1. Provide health care capacity for Kaiser Permanente members in the San BernardinoRedlands region.

2. Incorporate numerous sustainability features such as vegetated swales, tree-based infiltration, and inert bioswales; high-performance 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.

3. Develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1.

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.  3.0–PROJECT DESCRIPTION 
7214/Kaiser Permanente Redlands Medical Center Page 3-2 Findings of Fact and Statement of Overriding Considerations January 2026

3.0 PROJECT DESCRIPTION
The Kaiser Permanente Redlands Medical Center project involves the expansion and full buildout of an approximately 37-acre healthcare campus located at 1301 California Street in the City of Redlands, within Concept Plan No. 1 of the East Valley Corridor Specific Plan. The campus is currently developed with a 120,000-square-foot medical office building and associated parking on the eastern portion of the site; the remaining area consists of undeveloped land. The site is bounded by Almond Avenue to the north, California Street to the east, and West Lugonia Avenue to the south, with a trailer parking area to the west. Interstate 10 lies approximately 0.25 mile to the south, and the San Bernardino International Airport runway system is approximately 1.4 miles to the northwest.

The project requires City approval of Amendment No. 8 to Concept Plan 1 to create a Development Plan entitlement procedure under the East Valley Corridor Specific Plan, and Planned Development No. 6, which establishes a phased development plan for future construction of the proposed facility.

The proposed project is consistent with the “Commercial Industrial” General Plan designation and the CP-1 Medical Facilities District zoning.

Development would occur in four phases extending through approximately 2050 and ultimately establish a regional medical center anchored by a 213-bed acute care hospital with the ability for future expansion. Key facility components include:
• Phase 1 – Ambulatory Services Center/Medical Office Building No. 2 • Phase 2 – 213-Bed Acute Care Hospital, parking structure, and Central Utility Plant • Phase 3 – Medical Office Building No. 3
• Phase 4 – Hospital expansion adding 108 beds
Upon completion, the campus would include approximately 948,000 square feet of medical facilities, structured parking, designated patient and emergency access, photovoltaic systems, and a microgrid-enabled central utility plant. The project would provide 2,803 parking spaces, exceeding City requirements.

The project includes external roadway and utility improvements to support hospital operations, including widening of Almond Avenue and installation of new and upgraded utility connections.

Construction would be phased to maintain existing medical office operations on the campus and would comply with City development standards as well as State hospital licensing requirements under the California Department of Health Care Access and Information (HCAI). Additional CEQA review will be conducted as required prior to approval of subsequent phases pursuant to CEQA Guidelines §§15162–15164.

3.1 Program Environmental Report And Discretionary Actions The Final PEIR addresses the direct, indirect, and cumulative environmental effects associated with the adoption of the project. The Final PEIR provides the environmental information necessary for the City to make a final decision on the requested discretionary actions. Discretionary actions to be considered by the City may include, but are not limited to, the following:
• Certification of the Kaiser Permanente Redlands Medical Center project Program Environmental Impact Report (SCH 2025010666)
 3.0–PROJECT DESCRIPTION 
7214/Kaiser Permanente Redlands Medical Center Page 3-3 Findings of Fact and Statement of Overriding Considerations January 2026 • The proposed project will require the City of Redlands Planning Commission and City Council approval of:
o Amendment No. 8 to Concept Plan 1, which would amend the permitting procedure in Concept Plan No. 1, Section IV, Part A (Discretionary Actions) under the East Valley Corridor Specific Plan; and
o Planned Development No. 6.
• All mitigation measures identified for earlier phases of the project must be fully implemented to the satisfaction of the City of Redlands Planning Division prior to Planning Commission consideration or approval of any subsequent phases.
• Each phase of the project will require a development permit from the City of Redlands Planning Commission, pursuant to East Valley Corridor Specific Plan § EV1.0405(c), and in accordance with the City’s Commission Review and Approval Process set forth in City of Redlands Municipal Code chapter 18.12 (amlegal.com, 2025). In addition, any work within the public right-of-way, including required off-site improvements, will require issuance of an encroachment permit by the City of Redlands Municipal Utilities & Engineering Department.

Further, prior to approval of subsequent project phases, the City will evaluate whether additional environmental analysis is required under CEQA to address project changes, updated conditions, or new information; such review would occur in compliance with CEQA Guidelines §§ 15162–15164.

Other Permits and Approvals
Following the City’s approval of the PEIR, the following permits/approvals would be required prior to the start of construction.
• City of Redlands: Grading Permit, Building Permits, and Encroachment Permits. • City of Redlands and/or Caltrans: Street closure(s)/traffic controls. • California Department of Health Care Access and Information (HCAI): Hospital permitting. • SCAQMD: Permit to Construct and Permit to Operate central utility plant under Rule 203 and other SCAQMD rules.
• Santa Ana Regional Water Quality Control Board: Will be determined through a jurisdictional delineation conducted in accordance with applicable mitigation measures. • United States Army Corps of Engineers: Will be determined through a jurisdictional delineation conducted in accordance with applicable mitigation measures. • California Department of Fish and Wildlife: Will be determined through a jurisdictional delineation conducted in accordance with applicable mitigation measures. • Southern California Edison Co.: Approval of application for interconnection and operation of microgrid.
 4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-1 Findings of Fact and Statement of Overriding Considerations January 2026

4.0 EFFECTS DETERMINED TO BE LESS THAN SIGNIFICANT IN THE INITIAL STUDY

AND DURING THE SCOPING PROCESS
The City of Redlands, acting as Lead Agency under CEQA, issued a Notice of Preparation (NOP) pursuant to State CEQA Guidelines §15082 to initiate preparation of the Draft Program Environmental Impact Report.

CEQA Guidelines Section 15128 (Effects Not Found to be Significant) requires an EIR to contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were, therefore, not discussed in detail in the EIR. Based on substantial evidence in the record, including the environmental evaluation presented in the Initial Study (Appendix A) and further analyzed in Chapter 4.0 of the EIR, the City determined and now finds that the project would result in either no impact or less than significant impacts for the environmental topics listed below and no mitigation measures are required for these topics pursuant to Public Resources Code section 21081(a) and CEQA Guidelines section 15091(a).

4.1 Aesthetics
Except as provided in public resources code Section 21099, would the project:

Threshold b): Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? The City finds no state-designated scenic highways are located in the project vicinity; therefore, the project would not damage scenic resources such as trees, rock outcroppings, or historic buildings along a state scenic highway and the project would have no significant impacts. (see Appendix A — §4.1).

Threshold d): Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Exterior lighting would comply with applicable City standards requiring shielding and downwarddirection, minimizing light spill and glare onto surrounding areas. Building materials would not create substantial reflective glare. Further, the areas surrounding the project site are already developed and any additional light or glare from the project is anticipated to be consistent with levels already present in the vicinity of the project site. The surrounding commercial businesses operate as logistical warehousing with semi tractor trailer trucks operating with large light beams continuously as well as many installations of security lighting. The City finds that the project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area and the project would have no significant impacts. (see Appendix A — §4.1).

4.2 Agriculture and Forestry Resources
In determining whether impacts on agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and  4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-2 Findings of Fact and Statement of Overriding Considerations January 2026 forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

Threshold a): Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? While regional mapping identifies limited Important Farmland in the area, the project site is urbanized and designated for non-agricultural use. The City finds that the project would not directly convert active farmland or disrupt agricultural production and would have no significant impacts. (see Appendix A — §4.2).

Threshold b): Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?
The site is not zoned for agricultural use and is not under a Williamson Act contract. Therefore, City finds that the project would not result in any conflicts with agricultural zoning or contracted agricultural lands and would have no significant impacts. (see Appendix A — §4.2).

Threshold c): Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
No portion of the site or surrounding area is designated or zoned as forest land, timberland, or Timberland Production Zone. Therefore, the City finds that no such conflicts would occur and the project would have no significant impacts. (see Appendix A — §4.2).

Threshold d): Would the project result in the loss of forest land or conversion of forest land to nonforest use? The City finds that the project area is fully urbanized and contains no forest lands, timber resources, or comparable natural vegetation communities that could be converted or removed and the project would have no significant impacts. (see Appendix A — §4.2).

Threshold e): Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
The City finds that the project’s development would not introduce land use changes that could indirectly convert farmland located off-site and the project would have no significant impacts. The surrounding setting is urban, and no agricultural operations are present that could be affected by project-related land use incompatibility. (see Appendix A — §4.2).

4.3 Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project:
 4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-3 Findings of Fact and Statement of Overriding Considerations January 2026 Threshold d): Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The largest potential source of odors during construction is equipment exhaust. Odors from these sources would be localized and generally confined to the immediate project area. The project would use typical construction techniques, and the odors would be typical of most construction sites, would be temporary in nature, and would not be sufficient to impact a substantial number of people or result in a nuisance per SCAQMD Rule 402. According to the SCAQMD CEQA Air Quality Handbook (SCAQMD, 1993), land uses and industrial operations that are associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies and fiberglass molding. The project involves no industrial elements, so no long-term operational objectionable odors are anticipated. The City finds that the project would not result in other emissions (such as those leading to odors) that would adversely affect a substantial number of people. (see Appendix A — §4.3).

4.4 Biological Resources
Would the project:

Threshold f): Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
The project would not affect any protected trees, habitat conservation areas, or other sensitive biological resources subject to local ordinances or adopted conservation plans. The City finds that the project would remain consistent with the City’s land use regulations , does not conflict with any biological resource protection policies and would have no significant impacts. (see Appendix A — §4.4).

4.5 Geology and Soils
Would the project:

Threshold e): Would the project 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 waste water?
The project site would connect to the local sewer system and would not use septic tanks or alternative wastewater disposal systems. Therefore, the City finds that no significant impacts associated with septic tanks or alternative wastewater disposal systems would occur. (see Appendix A — §4.7).

4.6 Hazards and Hazardous Materials
Would the project:

Threshold c): Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?  4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-4 Findings of Fact and Statement of Overriding Considerations January 2026 There are no existing or proposed schools within 0.25 miles of the project site. Construction activities and medical operations would comply with applicable federal and state hazardous materials regulations. The City finds that the project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school and would have no significant impacts. (see Appendix A — §4.9).

Threshold 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? The project site is outside of noise contours for San Bernardino International Airport (SBIA) approximately 1.3 miles to the north and there are no applicable zoning regulations relating to aviation-related hazards to persons on the ground. As such, the City finds that the project development would not cause airport-related hazards, or excessive noise, to people occupying the project area and would have no significant impacts. (see Appendix A — §4.9).

Threshold f): Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The project would comply with City emergency access requirements and maintain adequate emergency vehicle circulation during construction and operation. Coordination with fire and emergency services and standard traffic control measures would ensure that site access remains available. The City finds that the project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan and would have no significant impacts. (see Appendix A — §4.9).

Threshold g): Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? The site is located within a developed urban area and is not within or adjacent to a Very High Fire Hazard Severity Zone or other wildland interface area. Construction and operational compliance with fire codes and building safety standards would further reduce any risk. The City finds that the project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires and would have no significant impacts. (see Appendix A — §4.9).

4.7 Hydrology and Water Quality
Would the project:

Threshold a): Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Construction stormwater controls and post-construction best management practices (BMPs) consistent with the City’s WQMP requirements and the NPDES Construction General Permit would prevent pollutants from entering stormwater runoff. The City finds the project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality and would have no significant impacts. (see Appendix A — §4.10).  4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-5 Findings of Fact and Statement of Overriding Considerations January 2026 Threshold c): Would the project 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 offsite;
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?
Project drainage systems would maintain overall drainage flows to existing discharge points.

Engineering design and erosion control measures would prevent off-site erosion and avoid increased on- or off-site flood hazards. Accordingly, the City finds that the project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in any of significant impacts of the types listed above. (see Appendix A — §4.10).

Threshold d): Would the project, in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
The City finds that the project would not modify or redirect a stream or river, nor is it located in a flood hazard area or subject to tsunami, seiche, or mudflow risk and would have no significant impacts. (see Appendix A — §4.10).

Threshold e): Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The City finds that stormwater design and operational requirements are fully consistent with the applicable water quality control plan or sustainable groundwater management plan, including the Santa Ana RWQCB Basin Plan and City stormwater management programs and the project would have no significant impacts. (see Appendix A — §4.10).

4.8 Land Use and Planning
Threshold a): Would the project physically divide an established community? The site is already urbanized and surrounded by roadway infrastructure. The City finds that the project would be contained within existing parcels and would not create barriers , alter established neighborhood circulation patterns, or physically divide an established community and the project would have no significant impacts. (see Appendix A — §4.11).

Threshold b): Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
The project is consistent with the City’s General Plan land use designation and zoning provisions for medical center development. The City finds that there are no adopted regional, community, or environmental land use plans that the project would conflict with and thus, the project would have no significant impacts. (see Appendix A — §4.11).
 4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-6 Findings of Fact and Statement of Overriding Considerations January 2026

4.9 Mineral Resources
Threshold a): Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? The project site is located within a fully developed urban area and is not mapped by the California Geological Survey as containing any known regionally significant mineral resource deposits. The City finds that the project’s development would not restrict access to mineral resources and would have no significant impacts. (see Appendix A — §4.12).

Threshold b): Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? There are no designated or active mineral extraction operations on or adjacent to the site, nor is the site identified in any local mineral resource management plans. Accordingly, the City finds that the project’s implementation would not interfere with mineral extraction or reserve availability and would have no significant impacts. (see Appendix A — §4.12).

4.10 Noise
Threshold 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 nearest public-use airport to the project site is San Bernardino International Airport (SBIA) approximately 1.3 miles to the north. The project site is outside of noise contours for SBIA. The San Bernardino International Airport Authority Airport Layout Plan Narrative Report does not designate zones surrounding SBIA where land uses are regulated to minimize aviation-related hazards to persons on the ground (SBIA, 2010). Project development would not cause airport-related hazards, or excessive noise, to persons at the project site. No impacts would occur, and no mitigation is required. The City finds that the will not expose people residing or working in the project area to excessive noise levels and would have no significant impacts. (see Appendix A — §4.13).

4.11 Population and Housing
Threshold a): Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The project would generate employment associated with hospital and medical office operations; however, staffing needs are consistent with regional growth forecasts and are not expected to directly result in substantial unplanned residential development. The project is located within a planned urban area with infrastructure to support anticipated growth. The City finds that the project will not induce substantial unplanned housing growth and that the project would have no significant impacts. (see Appendix A — §4.14).

Threshold b): Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?  4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-7 Findings of Fact and Statement of Overriding Considerations January 2026 The City finds that the project site does not contain residential units or housing-supportive uses, that no off-site displacement would occur as a result of construction or operation, and the project would have no significant impacts. (see Appendix A — §4.14).

4.12 Public Services
Threshold a): Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
• Schools? The project involves medical, and hospital uses that do not generate student enrollment. Therefore, the City finds that there would be no demand for new school facilities or expansion of existing facilities and that the project would have no significant impacts. (see Appendix A — §4.15).
• Parks? Hospitals and medical offices do not induce recreational use in the same manner as residential development. The City finds that the project would not increase demand for parks or require development or expansion of recreational facilities and that the project would have no significant impacts. (see Appendix A — §4.15).
• Other public facilities? The City finds that the project would not generate new population that would require construction or expansion of libraries or other governmental service facilities, that existing public facilities adequately serve the site, and the project would have no significant impacts. (see Appendix A — §4.15).

4.13 Recreation
Threshold a): Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
The City finds that the project would have no significant impacts as it would not increase demand for recreational amenities because it includes no residential uses and does not contribute to population growth that drives park usage. (see Appendix A — §4.16).

Threshold b): Would the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? The City finds that the project would have no significant impacts as no recreational facilities are included in the project, none are required to support medical operations, and the project would not necessitate new or expanded park facilities. (see Appendix A — §4.16).

4.14 Transportation
Threshold a): Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?  4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-8 Findings of Fact and Statement of Overriding Considerations January 2026 .The City finds that the project would have no significant impacts as it would not conflict with any relevant transportation plans, ordinances and policies, including California’s Statewide Transportation Improvement Program (STIP), San Bernardino County Congestion Management Program (CMP), City of Redlands General Plan – Connected City Chapter, City of Redlands Sustainable Mobility Plan, or the City of Redlands Bicycle Master Plan. (see Appendix A — §4.17).

Threshold c): Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? The City finds that the project would have no significant impacts as project driveways and circulation patterns are designed to City standards and adequate sight distance and access controls ensure safe vehicle, pedestrian, and emergency circulation. (see Appendix A — §4.17).

Threshold d): Would the project result in inadequate emergency access? Emergency vehicle access would be maintained during both construction and operation.

Coordination with fire and medical response agencies would ensure compliance with emergency access requirements. The City finds that the project would not result in inadequate emergency access and would have no significant impacts. (see Appendix A — §4.17).

4.15 Tribal Cultural Resources
Threshold 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 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 section 5020.1(k), or The project site is highly disturbed, and no tribal cultural resources were identified during consultation and record review. Therefore, City finds that no impact to recognized tribal resources would occur. (see Appendix A — §4.18).

4.16 Utilities and Services Systems
Would the project:

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? The City finds that the project would be served by the City’s existing wastewater treatment plant which has adequate wastewater treatment capacity. and ensures impacts would remain less than significant. (see Appendix A — §4.19; Draft and Final PEIR §4.14).

Threshold d): Would the project 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?
 4.0–EFFECTS LESS THAN SIGNIFICANT IN INITIAL STUDY/SCOPING  7214/Kaiser Permanente Redlands Medical Center Page 4-9 Findings of Fact and Statement of Overriding Considerations January 2026 The project would be served by existing solid waste providers with adequate permitted landfill capacity. The City finds that compliance with state waste reduction requirements ensures impacts would remain less than significant. (see Appendix A — §4.19; Draft and Final PEIR §4.14).

Threshold e): Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
The project would comply with the applicable local, state, and federal standards for solid waste disposal standards, including the California Integrated Waste Management Act (Assembly Bill (AB) 939 (1989)), AB 341 (2011), AB 1826 (2014), Senate Bill (SB) 1383 (2016), and Section 5.408 (Construction Waste Reduction, Disposal, and Recycling) of the 2022 California Green Building Standards Code, and therefore, the City finds that the impacts would be less than significant.. (see Appendix A — §4.19; Draft and Final PEIR §4.14).

4.17 Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones:

Thresholds a): Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
Thresholds b): Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Thresholds c): Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? Thresholds d): Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
The site is located within an urbanized area and is not within or adjacent to a State-designated Very High Fire Hazard Severity Zone. The City finds that Compliance with the California Fire Code, defensible space requirements, and emergency access standards would ensure fire-related risks remain less than significant. (see Appendix A — §4.20).  5.0-EFFECTS IN THE PEIR-NO IMPACT/LESS THAN SIGNIFICANT -WO MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 5-1 Findings of Fact and Statement of Overriding Considerations January 2026

5.0 EFFECTS FOUND IN THE PEIR TO CREATE NO IMPACT OR A LESS THAN

SIGNIFICANT IMPACT WITHOUT MITIGATION
The City of Redlands, as Lead Agency, evaluated the Kaiser Permanente Redlands Medical Center project in the Final PEIR. CEQA Guidelines Section 15128 (Effects Not Found to be Significant) requires an EIR to contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were, therefore, not discussed in detail in the EIR.

Based on substantial evidence in the administrative record, including the environmental evaluation presented in the Initial Study, (Appendix A) and further analyzed in Chapter 4.0 of the Final PEIR, among others, the PEIR determined and the City now finds the following environmental topics would result in No Impact or a Less Than Significant impact without mitigation. Therefore, no mitigation measures are required for these topics pursuant to Public Resources Code section 21081(a) and CEQA Guidelines section 15091(a).

5.1 Aesthetics
Except as provided in public resources code Section 21099:

Threshold a): Would the project have a substantial adverse effect on a scenic vista? The project is in an urbanized area without designated scenic vistas. Although distant mountain views exist, surrounding buildings already partially obstruct those views. Visual simulations confirm and the City finds that the project would not significantly alter scenic vistas or designated scenic corridors.
(see Draft and Final PEIR — §4.1).

Threshold c): Would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? The project is located in an urbanized area and would adhere to and not conflict with applicable zoning and other regulations governing scenic quality, including under the City’s General Plan, development and design guidelines of the East Valley Corridor Specific Plan, and Redlands Business Plan Concept Plan No. 1. Accordingly, the City finds that the project’s impacts would be less than significant as the project would not substantially degrade the existing visual character or quality of public views of the site and its surroundings and would not conflict with applicable zoning and other regulations governing scenic quality.(see Draft and Final PEIR — §4.1).

5.2 Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Threshold a): Would the project conflict with or obstruct implementation of the applicable air quality plan?
The project is consistent with the City’s General Plan and with SCAG regional growth assumptions utilized in the South Coast AQMD 2022 Air Quality Management Plan (AQMP). Additionally,  5.0-EFFECTS IN THE PEIR-NO IMPACT/LESS THAN SIGNIFICANT -WO MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 5-2 Findings of Fact and Statement of Overriding Considerations January 2026 construction- and operational-phase emissions would not exceed SCAQMD regional significance thresholds. Therefore, the City finds that the project would not conflict with or obstruct implementation of the applicable air quality plan and the impact would be less than significant. (see Draft and Final PEIR — §4.2).

Threshold c): Would the project expose sensitive receptors to substantial pollutant concentrations? Localized construction emissions would remain below SCAQMD screening thresholds at the nearest sensitive receptors, including onsite medical facilities. Emergency generator screening also shows cancer and non-cancer risks below SCAQMD significance criteria. Therefore, the City finds that the project would not expose sensitive receptors to substantial pollutant concentrations and the impact would be less than significant. (see Draft and Final PEIR — §4.2).

5.3 Biological Resources
Threshold e): Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? 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).

The City finds that 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. (see Appendix A — §4.4; Draft and Final PEIR — §4.3).

5.4 Energy
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?
Threshold b): Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Construction and operation of the project would result in the use of electricity, transportation fuel, and minimal diesel; however, all activities would comply with applicable state efficiency regulations, including California Energy Code (Title 24) and CARB fuel-use requirements. The project includes a fuel cell micro-grid and on-site solar generation, which substantially reduces long-term reliance on the electrical grid and avoids inefficient energy consumption. The City finds that project would not require new off-site energy infrastructure nor interfere with adopted state or local renewable energy and energy-efficiency plans, including SB 100 and the City of Redlands Climate Action Plan and that the project’s impacts would be less than significant. (see Draft and Final PEIR — §4.5).

5.5 Geology and Soils
Thresholds a) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
 5.0-EFFECTS IN THE PEIR-NO IMPACT/LESS THAN SIGNIFICANT -WO MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 5-3 Findings of Fact and Statement of Overriding Considerations January 2026 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?
The project site is not located within an Alquist-Priolo Earthquake Fault Zone, and the likelihood of surface fault rupture onsite is considered remote. Although the region is subject to seismic ground shaking, all proposed structures would be designed and constructed in compliance with the California Building Code seismic safety standards, which ensures appropriate structural protection.

Site-specific geotechnical investigations confirm that groundwater is located at depths greater than 50 feet and the site is not mapped within a liquefaction hazard area, resulting in negligible liquefaction risk. The site is also situated on generally level terrain outside mapped landslide hazard areas. Therefore, the City finds that the project would have a less than significant impact regarding the rupture of a known earthquake fault, strong seismic groundshaking, seismic-related ground failure, or landslides, and that the project’s impacts would be less than significant. (see Draft and Final PEIR — §4.6).

Threshold b): Would the project result in substantial soil erosion or the loss of topsoil? Construction activities would temporarily expose soils and create potential for erosion; however, the project must comply with the State Water Resources Control Board’s General Construction Permit, including preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) and use of required BMPs to control runoff and stabilize disturbed soils. Upon completion, the development would include permanent paving, structures, and landscaping that would minimize ongoing erosion potential. Therefore, the City finds that the project would not result in substantial soil erosion or loss of topsoil and therefore, impacts would be less than significant. (see Draft and Final PEIR — §4.6).

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 off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Site-specific geotechnical investigations confirm the project site is not located within an area of known geologic instability, nor is it susceptible to landslides, liquefaction, lateral spreading, or collapse. Groundwater depth is greater than 50 feet, further reducing liquefaction potential.

Compliance with the California Building Code and implementation of the geotechnical recommendations provided for project design and construction ensure soil stability. The City finds that the project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project and that impacts would be less than significant. (see Draft and Final PEIR — §4.6).

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? Geotechnical laboratory testing indicates that on-site soils exhibit a very low expansion potential.

Standard engineering design and construction practices required by the California Building Code will be implemented to ensure foundation stability. Based on the results of these potential expansion  5.0-EFFECTS IN THE PEIR-NO IMPACT/LESS THAN SIGNIFICANT -WO MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 5-4 Findings of Fact and Statement of Overriding Considerations January 2026 index tests, the City finds that surficial soils have a very low expansion potential and the project would have a less than significant impact. (see Draft and Final PEIR — §4.6).

5.6 Hazards and Hazardous Materials
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? Routine transport, handling, and disposal of hazardous materials during construction and hospital operations would comply with applicable federal, state, and local requirements, including those governing medical waste. As a result, the City finds that the project would not create a significant hazard to the public or the environment and that the project’s impacts would be less than significant. (see Draft and Final PEIR — §4.8).

Threshold b): Would the project 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?
The project will comply with applicable hazardous materials regulations during construction and operation, including requirements for containment, spill response, and medical waste management.

The City finds that these regulatory controls will ensure that reasonably foreseeable upset or accidental release of hazardous materials does not pose a significant hazard to the public or environment.
and that the project’s impacts would be less than significant. (see Draft and Final PEIR — §4.8).

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 § 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
The project site is not identified on the Cortese List of hazardous materials sites under Government Code §65962.5. Nearby listed facilities are closed cases or otherwise managed under regulatory oversight and do not present a significant risk to future occupants or the environment. Therefore, the City finds that the project would not create a significant hazard due to its location and that the project’s impacts would be less than significant. (see Draft and Final PEIR — §4.8).

5.7 Hydrology and Water Quality
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?
Water use by project operation would not substantially decrease groundwater supplies. The proposed project would use approximately 107,594 gallons of water per day (0.33 af) or annual water demand of 120.5 af which is accounted for in the City of Redlands Municipal Utilities & Engineering Department (MUED) water demand forecasts. Further, low impact development (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, and not interfere with groundwater recharge. The City finds that the project would not substantially decrease groundwater supplies or substantially interfere with groundwater recharge such that the project  5.0-EFFECTS IN THE PEIR-NO IMPACT/LESS THAN SIGNIFICANT -WO MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 5-5 Findings of Fact and Statement of Overriding Considerations January 2026 impedes sustainable groundwater management and that the project’s impacts would be less than significant. (see Draft and Final PEIR — §4.9).

5.8 Noise
Threshold a): Would the project cause the 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? Unless an exception permit is granted, construction would be confined to City-allowed hours, and equipment would meet manufacturer muffler standards. Modeled maximum construction exposure at the nearest sensitive receiver is 80 dBA Leq (Phase 3 fine grading), which meets the FTA construction threshold. To ensure that the threshold is not exceeded, BMP NOISE-1 shall be implemented with the review and approval of Phase 3. The City finds that the project would not cause a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of applicable noise standards and that impacts would be less than significant. (see Draft and Final PEIR — §4.10).

Threshold b): Would the project cause the generation of excessive groundborne vibration or groundborne noise levels?
Construction-related groundborne vibration would result from intermittent use of heavy equipment, jackhammers, and haul trucks. Vibration levels were modeled at distances to the nearest sensitive receptor (existing or newly built medical buildings). The highest predicted vibration, from large bulldozers at 342 feet, is 0.005 in/sec PPV and 53 VdB—well below the FTA thresholds of 0.12 in/sec PPV for potential structural damage and 80 VdB for human annoyance. Haul truck vibration on California Street is also below impact thresholds. No pile driving or other high-vibration methods are proposed. Thus, the City finds that construction activities would not generate excessive groundborne vibration, and impacts would be less than significant. Best Management Practice BMP NOISE-1 will ensure noise levels during Phase 3 are verified and do not result in new or greater impacts. (see Draft and Final PEIR — §4.10).

5.9 Public Services
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.

The project would be served by existing City of Redlands fire and police facilities. Development would comply with the California Building Code, California Fire Code, and City access and emergency response requirements, ensuring adequate fire and life safety protection. The project will also pay required Fire Protection Facilities Fees and Police Facilities Fees pursuant to Municipal Ordinance No. 2968, which fund capital improvements necessary to maintain acceptable service ratios and response performance. As such, the City finds that the project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities or need for new or physically altered governmental facilities and impacts would be less than significant. (see Draft and Final PEIR — §4.11).
 5.0-EFFECTS IN THE PEIR-NO IMPACT/LESS THAN SIGNIFICANT -WO MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 5-6 Findings of Fact and Statement of Overriding Considerations January 2026

5.10 Utilities and Service Systems
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?
Project buildout will occur over four distinct phases, each generating incremental increases in water demand. Infrastructure upgrades and coordination with the City of Redlands Municipal Utilities & Engineering Department (MUED) will ensure service reliability, compliance with water quality standards, system adequacy, pressure zone performance, and consistency with the City’s 2020 Urban Water Management Plan (UWMP). The City of Redlands Water Reclamation Plant (WRP) has a permitted capacity of 9.5 mgd and treats about 5.9 mgd on average, leaving substantial reserve capacity. Project wastewater generation is estimated at ~86,075 gpd (0.086 mgd), which can be accommodated within existing treatment and collection system capacities via standard on-site laterals to the Lugonia/Almond sewer mains. No off-site expansion of treatment facilities is required, and service will continue under existing Santa Ana Regional Water Quality Control Board (RWQCB) waste discharge requirements (WDRs). Compliance with National Pollutant Discharge Elimination System (NPDES) and municipal separate storm water system (MS4s, or storm drains) permit requirements would prevent exceedance of drainage system capacity and minimize pollutant discharges. The project would not conflict with or obstruct any state or local plan for renewable energy or energy efficiency. The project would not interfere with the operation of telecommunication facilities. Thus, the City finds project would have less than significant impacts as it would not 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. (see Appendix A §4.19; Appendix D11 (Water Supply Assessment); Draft and Final PEIR — §§4.5, 4.9, 4.14).

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? The City of Redlands Municipal Utilities & Engineering Department (MUED) projects water supply ranging from 31,039 AFY in 2025 to 35,544 AFY in 2045 under normal conditions, with comparable reliability during single-dry and multiple-dry years. The project demand of approximately 185 AFY (114.7 gpm average) represents less than 0.6 percent of total available supply and is already included in the City’s 2020 Urban Water Management Plan. Water will be delivered through existing infrastructure in the Primary Pressure Zone, with phased connections to 16-inch and 12-inch mains in California Street and Lugonia Avenue, respectively. No new or expanded water supply facilities are required, and service will remain consistent with SB 610 WSA findings and City planning documents.

Thus, the City finds project would have a less than significant impact on water supplies available to serve the project. (see Appendix D11 (Water Supply Assessment); Draft and Final PEIR — §§ 4.9, 4.14).

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? As examined and explained with respect to thresholds a) and b), the WRP has substantial reserve capacity and the existing treatment and collection system capacities can accommodate the Project.

The City finds that it has adequate wastewater treatment capacity to meet project wastewater generation and impacts would be less than significant. (see Draft and Final PEIR — §4.14).  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-1 Findings of Fact and Statement of Overriding Considerations January 2026

6.0 POTENTIALLY SIGNIFICANT ENVIRONMENTAL IMPACTS DETERMINED TO BE

MITIGATED TO A LESS THAN SIGNIFICANT LEVEL
The City of Redlands, as Lead Agency, evaluated the Kaiser Permanente Redlands Medical Center project in the Final PEIR. The PEIR identified the potential for the project to cause significant environmental impacts in the areas of Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Greenhouse Gas Emissions, and Tribal Cultural Resources.

With the exception of those unmitigable impacts discussed in Section 7.0, pursuant to Section 21081(a) of the Public Resources Code and Section 15091(a)(1) of the CEQA Guidelines, the City finds that for each of these significant effects identified in the Final PEIR, changes or alterations have been required in, or incorporated into, the proposed project which mitigate or avoid the identified significant effects on the environment to less than significant levels. Specifically, measures have been identified that would mitigate the specific impacts in each area to a less than significant level. The City adopts all of the feasible mitigation measures for the project described in the Final PEIR and as set forth in the Mitigation Monitoring and Reporting Program (MMRP) as conditions of approval of the project and incorporates those into the project.

These findings are explained below and are supported by substantial evidence in the administrative record, including but not limited to the environmental evaluation presented in the Initial Study (Appendix A) and further analyzed in Chapter 4.0 of the Final PEIR, among others.

6.1 Air Quality
The proposed Project would have a potentially significant impact related to air quality as follows:
▪ Air Quality Threshold B (net increase of any criteria pollutant)

6.1.1 Mitigation Measures
The following mitigation measures were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to air quality emissions to less than significant levels. These measures as provided include any revisions incorporated in the Final PEIR.

Mitigation Measure AQ-1:

Include in a Plan or Policy that Gas Powered Landscape Equipment must be replaced with ZeroEmission Landscape Equipment (listed at A-1 in the aforementioned CAPCOA Handbook, and LL-1 in CalEEMod). If feasible, landscape and maintenance contracts shall require only Zero-Emission Landscape Equipment be used.

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

Mitigation Measure 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.
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-2 Findings of Fact and Statement of Overriding Considerations January 2026 Mitigation Measure 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.

Mitigation Measure 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. Endof-trip facilities include bike parking, bike lockers, showers, and personal lockers. The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions.

Mitigation Measure 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. (see Draft and Final PEIR — §§4.2, 4.12, 11).

6.1.2 Air Quality Threshold B (net increase of any criteria pollutant) Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Threshold b): Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
As demonstrated by CalEEMod modeling in Draft PEIR Tables 4.2-6 through 4.2-15, projectgenerated criteria pollutant emissions from both construction and operation would remain below South Coast AQMD regional significance thresholds with implementation of required mitigation measures (MM AQ-1, MM AQ-2, and MM TRANS 1 through 4). Because emissions do not exceed these thresholds and the project is consistent with the regional Air Quality Management Plan, the project’s incremental contribution to cumulative air quality conditions in the South Coast Air Basin would not be cumulatively considerable. (see Draft and Final PEIR — §4.2).

6.1.2.1 Findings
Based on substantial evidence in the administrative record (including PEIR Section 4.2; Tables 4.2-6 through 4.2-15), the City finds that:
• With implementation of MM AQ-1, MM AQ-2, and MM TRANS-1 through MM TRANS-4, both construction and operational emissions of criteria pollutants and precursors would remain below South Coast AQMD regional significance thresholds. • The project would not conflict with or obstruct implementation of the applicable Air Quality Management Plan.
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-3 Findings of Fact and Statement of Overriding Considerations January 2026 • Accordingly, the project’s incremental contribution to cumulative regional air quality impacts in the South Coast Air Basin would not be cumulatively considerable.

Therefore, air quality impacts under CEQA Guidelines Appendix G Threshold (b) would be less than significant with mitigation incorporated.

The City finds that MM AQ-1, MM AQ-2, and MM TRANS-1 through MM TRANS-4 are feasible, will reduce the potential air quality-related impacts of the proposed project to less-than-significant levels, and are adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.1.2.2 Facts in Support of Findings
As demonstrated by CalEEMod modeling results in Tables 4.2-6 through 4.2-15 of the Draft PEIR, implementation of mitigation measures MM AQ-1 (enhanced dust control per SCAQMD Rule 403), MM AQ-2 (use of Tier 4 Final diesel construction equipment), and MM TRANS-4 (Transportation Demand Management to reduce vehicle trips) ensures that construction and operational emissions of criteria air pollutants remain below SCAQMD regional significance thresholds. Additional measures that were not incorporated in the emissions calculations but further reduce VMT-related emissions will also be implemented: MM TRANS-1 (Implement Commute Trip Reduction Marketing), MM TRANS-2 (Provide Employee Rideshare Program), and MM TRANS-3 (Provide End-of-Trip Bicycle Facilities).

The project’s consistency with the applicable Air Quality Management Plan further supports the conclusion that it would not result in a cumulatively considerable contribution to air quality impacts within the South Coast Air Basin. These facts provide substantial evidence that the project’s air quality impacts under CEQA Guidelines Appendix G Threshold (b) would be less than significant with mitigation. (see Draft and Final PEIR — §§4.2, 4.12).

6.1.2.3 Cumulative Impacts
As addressed in Section 6.1.1 and substantiated by emissions modeling in Draft PEIR Tables 4.2-6 through 4.2-15, the Kaiser Permanente Redlands Medical Center project would not generate construction or operational emissions that exceed the South Coast Air Quality Management District (SCAQMD) regional significance thresholds. The South Coast Air Basin (SCAB), where the project is located, is currently designated as non-attainment for ozone (O₃) and particulate matter (PM₁₀ and PM₂.₅) under both federal and state standards.

The cumulative impact assessment incorporates both project-level emissions and region-wide sources of criteria pollutants. The project’s consistency with the 2016 Air Quality Management Plan (AQMP), as well as its compliance with SCAQMD regulations and implementation of mitigation measures MM AQ-1 (enhanced dust control), MM AQ-2 (Tier 4 Final diesel equipment), MM TRANS1 (Implement Commute Trip Reduction Marketing), MM TRANS-2 (Provide Employee Rideshare Program), MM TRANS-3 (Provide End-of-Trip Bicycle Facilities), and MM TRANS-4 (trip reduction through Transportation Demand Management), ensures that its incremental emissions do not make a cumulatively considerable contribution to regional non-attainment conditions.  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-4 Findings of Fact and Statement of Overriding Considerations January 2026

6.2 Biological Resources
The proposed Project would have a potentially significant impact related to biological resources as follows:
▪ Biological Resource Threshold A (special status species) ▪ Biological Resource Threshold B (sensitive natural community) ▪ Biological Resource Threshold C (protected wetlands)
▪ Biological Resource Threshold D (wildlife corridors)

6.2.1 Mitigation Measures
The following mitigation measures were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to biological resources to less than significant levels. These measures as provided include any revisions incorporated in the Final PEIR.

Mitigation Measure 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,
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-5 Findings of Fact and Statement of Overriding Considerations January 2026

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).

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.

Mitigation Measure 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.  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-6 Findings of Fact and Statement of Overriding Considerations January 2026 b. A qualified monitoring biologist shall monitor the owls weekly during the non-breeding 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 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.

Mitigation Measure 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.  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-7 Findings of Fact and Statement of Overriding Considerations January 2026

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.

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.

Mitigation Measure 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 midMarch 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  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-8 Findings of Fact and Statement of Overriding Considerations January 2026 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.

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 reenter), 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).

Mitigation Measure 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  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-9 Findings of Fact and Statement of Overriding Considerations January 2026 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.

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.
(see Draft and Final PEIR — §§4.3, 11).

6.2.2 Biological Resource Threshold A (special status species) 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?
The site is largely disturbed, with only small areas of marginal habitat that could support certain special-status wildlife species such as burrowing owl, nesting birds/raptors, bats, and Crotch’s bumble bee. No federal or state listed species or critical habitat occur onsite. With implementation of required biological pre-construction surveys, avoidance buffers, seasonal timing, and speciesspecific protection measures (MM BIO-1 through MM BIO-4), the project would avoid or minimize potential direct disturbance to special-status species. Therefore, impacts would be less than significant with mitigation. (see Draft and Final PEIR — §4.3).

6.2.2.1 Findings
Substantial evidence in the administrative record, including the Draft PEIR (Section 4.3) supports the conclusion that special-status species may occur in limited disturbed habitats; however, implementation of MM BIO-1 through MM BIO-4 would ensure avoidance of individuals, active nests, or roosting/breeding sites, such that potential impacts would be reduced to less than significant levels and the project would not result in a substantial adverse effect on special-status species. The City finds that the MM BIO-1 through MM BIO-4 are feasible, will reduce the potential biological resource impacts of the proposed project to less-than-significant levels, and are adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-10 Findings of Fact and Statement of Overriding Considerations January 2026

6.2.2.2 Facts in Support of Findings
The project site consists primarily of previously developed and disturbed land, with only small patches of marginal habitat that could potentially support special-status species such as burrowing owl, nesting birds and raptors, bats, and Crotch’s bumble bee. Biological field surveys conducted for the Draft PEIR did not detect any federally or state-listed species or designated critical habitat onsite. However, to address the potential for presence of other sensitive species, the project includes implementation of MM BIO-1 through MM BIO-4, which require pre-construction biological surveys, establishment of species-appropriate avoidance buffers, restrictions on timing of construction to avoid nesting or breeding seasons, and protective measures if individuals or habitat use is confirmed.

These mitigation measures ensure that the project would avoid or substantially reduce the risk of direct or indirect disturbance to any special-status wildlife, resulting in less than significant impacts. (see Draft and Final PEIR — §4.3).

6.2.2.3 Cumulative Impacts
The South Coast region has experienced widespread urbanization and habitat fragmentation, contributing cumulatively to the decline of native biological resources. The proposed project is located on a previously disturbed site within an urbanized context and does not contain critical habitat or high-value ecological corridors. As documented in the Draft PEIR (Section 4.3), the project site supports only marginal and patchy habitat for special-status species such as burrowing owl, nesting birds/raptors, bats, and Crotch’s bumble bee.

The project would not substantially contribute to regional cumulative biological impacts because:
• No federal- or state-listed species or designated critical habitat would be affected. • The project’s impacts are localized and avoidable with implementation of mitigation measures MM BIO-1 through MM BIO-4, which require pre-construction surveys, avoidance buffers, seasonal timing restrictions, and protection protocols if species are encountered.

Therefore, the project’s incremental contribution to cumulative biological resource degradation is not considered cumulatively considerable under CEQA.

6.2.3 Biological Resource Threshold B (sensitive natural community) 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? The project would remove disturbed land and a small area of mule fat scrub within an existing detention basin that may qualify as riparian habitat. No other sensitive natural communities are present. To ensure protection and compliance with resource agency requirements, a jurisdictional delineation and permitting will be completed, and avoidance/minimization measures implemented as necessary (MM BIO-5). With these measures, potential adverse effects on riparian habitat would be reduced to less than significant. (see Draft and Final PEIR — §4.3).  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-11 Findings of Fact and Statement of Overriding Considerations January 2026

6.2.3.1 Findings
Substantial evidence in the administrative record demonstrates that any riparian vegetation impacts would be minimized, resource compliance requirements would be implemented through MM BIO-5, and impacts to sensitive natural communities would be less than significant with mitigation. The City finds that the MM BIO-5 is feasible, will reduce the potential biological resource impacts of the proposed project to less-than-significant levels, and is adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.2.3.2 Facts in Support of Findings
The project would remove a small area of mule fat scrub located within a disturbed detention basin that may qualify as riparian habitat, although no other sensitive natural communities are present onsite. As required by MM BIO-5, a formal jurisdictional delineation will be conducted to confirm the extent of any riparian features. Based on the results, the project will obtain all applicable regulatory permits and implement avoidance and minimization measures consistent with agency requirements.

These actions will ensure compliance with federal and state resource protection laws and avoid or minimize impacts to riparian vegetation. Therefore, potential adverse effects on sensitive natural communities, including riparian habitat, would be reduced to less than significant. (see Draft and Final PEIR — §4.3).

6.2.3.3 Cumulative Impacts
Cumulative impacts to riparian habitat and sensitive natural communities in the South Coast region are generally associated with continued land conversion, stream channelization, and loss of hydrologically connected features due to urban development. These effects can degrade watershed function and reduce regional habitat connectivity.

The Kaiser Permanente Redlands Medical Center project would result in removal of a small area of disturbed mule fat scrub within a detention basin that may qualify as riparian habitat. No other sensitive natural communities are present on-site. This localized impact, while minimal, is addressed by MM BIO-5, which requires jurisdictional delineation, regulatory permitting (e.g., Clean Water Act Section 404 or Fish and Game Code §1602), and implementation of avoidance or compensatory mitigation as needed.

6.2.4 Biological Resource Threshold C (protected wetlands) 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?
Limited areas on-site may meet federal and/or State jurisdictional definitions. Any disturbance could result in a potentially significant impact absent mitigation. A formal jurisdictional delineation and any necessary regulatory permits (e.g., Clean Water Act §§ 404/401, Fish and Game Code §1602) will be secured prior to grading (MM BIO-5). With implementation of required regulatory approvals and compliance measures, impacts to jurisdictional waters would be reduced to less than significant. (see Draft and Final PEIR — §4.3).
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6.2.4.1 Findings
Substantial evidence in the administrative record, including the Draft PEIR (Section 4.3) confirms that jurisdictional resources may occur within the proposed construction footprint; however, MM BIO-5 ensures agency coordination, regulatory compliance, and implementation of required best practices. With mitigation, impacts would be less than significant. The City finds that the MM BIO-5 is feasible, will reduce the potential biological resource impacts of the proposed project to less-thansignificant levels, and is adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.2.4.2 Facts in Support of Findings
The Draft PEIR identifies that limited portions of the project site may contain features that meet federal or state definitions of jurisdictional waters, such as those regulated under Clean Water Act §§ 404 or 401 or § 1602 of the California Fish and Game Code. To address potential impacts, MM BIO-5 requires the preparation of a formal jurisdictional delineation prior to any ground-disturbing activities. If jurisdictional features are confirmed, the project must obtain applicable permits from the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and/or California Department of Fish and Wildlife. These permits will include conditions for avoidance, minimization, and mitigation of impacts. Compliance with these regulatory requirements ensures that potential effects to jurisdictional waters are reduced to less than significant. (see Draft and Final PEIR — §4.3).

6.2.4.3 Cumulative Impacts
At the regional scale, the cumulative loss of wetlands and other jurisdictional waters has significantly reduced hydrologic function, biodiversity, and flood control capacity in Southern California. Urban expansion, infrastructure development, and channel modification continue to fragment or degrade aquatic resources despite existing regulatory frameworks.

The Kaiser Permanente Redlands Medical Center project could potentially affect limited areas that may qualify as federally or state-protected jurisdictional waters. These features, if present, are expected to be small, degraded, and isolated within a detention basin setting. As required by MM BIO5, the project will complete a formal jurisdictional delineation and obtain all necessary permits under Clean Water Act Sections 404/401 and California Fish and Game Code Section 1602 prior to grading.

Any adverse effects will be mitigated in accordance with permit conditions, including avoidance, minimization, or compensatory mitigation measures.

Given the confined scale of potential impacts and the full implementation of regulatory compliance procedures, the project would not contribute meaningfully to cumulative wetland loss or hydrological disruption in the region.

6.2.5 Biological Resource Threshold D (wildlife corridors) 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?  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-13 Findings of Fact and Statement of Overriding Considerations January 2026 The project site is surrounded by existing urban development and does not function as a regional wildlife movement corridor or support wildlife nursery areas. However, vegetation on-site may provide nesting habitat for Migratory Bird Treaty Act (MBTA)- and Fish and Game Code-protected birds. To prevent disturbance of active nests, pre-construction nesting bird surveys and avoidance buffers will be implemented (MM BIO-3). With these measures, potential impacts would be reduced to a less-than-significant level. (see Draft and Final PEIR — §4.3).

6.2.5.1 Findings
Substantial evidence in the administrative record, including the Draft PEIR’s analyses (Section 4.3), verifies no essential wildlife corridors or wildlife nursery areas would be affected. With MM BIO-3 ensuring avoidance of take of active nests, impacts to wildlife movement and nursery features would be less than significant with mitigation. The City finds that the MM BIO-3 is feasible, will reduce the potential biological resource impacts of the proposed project to less-than-significant levels, and is adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.2.5.2 Facts in Support of Findings
Although the project site is within a developed urban area and does not function as a regional wildlife corridor or support wildlife nursery areas, the existing vegetation could provide suitable nesting habitat for bird species protected under the MBTA and California Fish and Game Code. To avoid potential disturbance to active nests, MM BIO-3 requires that a qualified biologist conduct nesting bird surveys within the appropriate seasonal window prior to any construction activities. If active nests are found, species-specific no-disturbance buffers will be established and maintained until the young have fledged. These measures ensure compliance with state and federal protections for nesting birds and reduce potential impacts to less than significant. (see Draft and Final PEIR — §4.3).

6.2.5.3 Cumulative Impacts
Across the South Coast region, cumulative impacts to wildlife movement corridors and nursery sites result from progressive habitat fragmentation, roadway expansion, and intensifying urban development. These pressures limit habitat connectivity and can disrupt critical life-stage behaviors, particularly for wide-ranging mammals and nesting bird populations.

The Kaiser Permanente Redlands Medical Center site does not contribute to regional wildlife connectivity due to its urban setting and isolation from natural open space. No designated corridors or essential linkages traverse or adjoin the site. While some existing vegetation could provide nesting habitat for birds protected under the Migratory Bird Treaty Act and California Fish and Game Code, this potential is localized and common in the urban landscape.

With implementation of MM BIO-3—which requires pre-construction nesting bird surveys and protective no-disturbance buffers—any potential nesting disturbance will be avoided. Given the site’s developed context and the application of best practices, the project’s contribution to cumulative disruption of wildlife movement or nursery habitat would be less than cumulatively considerable.  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-14 Findings of Fact and Statement of Overriding Considerations January 2026

6.3 Cultural Resources
The proposed Project would have a potentially significant impact related to cultural resources as follows:
▪ Cultural Resources Threshold A (historical resources) ▪ Cultural Resources Threshold B (archeological resources) ▪ Cultural Resources Threshold C (human remains)

6.3.1 Mitigation Measures
The following mitigation measures were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to cultural resources to less than significant levels. These measures as provided include any revisions incorporated in the Final PEIR.

Mitigation Measure 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.

Mitigation Measure 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.
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-15 Findings of Fact and Statement of Overriding Considerations January 2026 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.

Mitigation Measure 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).
(see Draft and Final PEIR — §§4.4, 11).

6.3.2 Cultural Resources Threshold A (historical resources) Would the project:

Threshold a): Would the project cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5?
Buildings or features onsite qualify as historical resources under CEQA. Although the potential for previously unknown subsurface materials is low, ground disturbance could encounter buried resources. MM CUL-1 and MM CUL-2 require qualified monitoring and treatment of unanticipated discoveries consistent with CEQA and professional preservation standards. (see Draft and Final PEIR — §4.4).

6.3.2.1 Findings
Substantial evidence in the administrative record demonstrates that although no historical resources are present on the site, inadvertent discovery of buried resources remains possible. Implementation of MM CUL-1 and MM CUL-2 would ensure qualified oversight and compliance with established  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-16 Findings of Fact and Statement of Overriding Considerations January 2026 discovery and treatment procedures, reducing impacts to less than significant with mitigation incorporated. The City finds that the MM CUL-1 and MM CUL-2 are feasible, will reduce the potential cultural resource impacts of the proposed project to less-than-significant levels, and are adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.3.2.2 Facts in Support of Findings
The Draft PEIR confirms that no buildings or surface features on the project site qualify as historical resources under CEQA. However, due to the possibility of encountering previously unknown buried cultural materials during ground disturbance, the project includes MM CUL-1, requiring archaeological monitoring by a qualified professional during initial grading, and MM CUL-2, which outlines procedures for the evaluation and treatment of any inadvertent discoveries. These measures are consistent with CEQA Guidelines and Secretary of the Interior’s Standards for Archaeological Documentation and ensure that any potential impacts to cultural resources are properly managed and mitigated to a less-than-significant level. (see Draft and Final PEIR — §4.4).

6.3.2.3 Cumulative Impacts
Cumulative impacts to historical resources may occur when multiple projects in a region result in the collective loss of built environment features or buried cultural deposits that contribute to local or regional heritage. In older urbanizing areas such as Redlands, cumulative degradation is of concern where historic structures or archaeological contexts are not adequately identified, preserved, or documented.

The Kaiser Permanente Redlands Medical Center project site contains no identified historical resources as defined under CEQA Guidelines §15064.5. However, due to the potential for undiscovered subsurface cultural materials, mitigation measures MM CUL-1 and MM CUL-2 require archaeological monitoring and establish procedures for treatment of inadvertent finds.

Because the project does not remove or alter any documented historical resources and includes measures to ensure proper handling of any buried materials that may be revealed during ground disturbance, it would not contribute to a cumulatively considerable loss of historical resources in the region.

6.3.3 Cultural Resources Threshold B (archeological resources) Threshold b): Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
Background research indicates a low likelihood of encountering archaeological resources due to prior disturbance on the site. However, unknown subsurface archaeological materials could be uncovered during excavation. The project includes MM CUL-1 and MM CUL-2, which require archaeological monitoring where warranted, work stoppage procedures, and appropriate treatment if resources are discovered. (see Draft and Final PEIR — §4.4).  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-17 Findings of Fact and Statement of Overriding Considerations January 2026

6.3.3.1 Findings
Substantial evidence in the administrative record demonstrates that while the probability of archaeological finds is low, inadvertent discovery remains possible during excavation. MM CUL-1 and MM CUL-2 ensure proper evaluation and preservation measures consistent with CEQA Guidelines §15064.5, reducing potential impacts to less than significant with mitigation incorporated. The City finds that the MM CUL-1 and MM CUL-2 are feasible, will reduce the potential cultural resource impacts of the proposed project to less-than-significant levels, and are adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.3.3.2 Facts in Support of Findings
Although previous disturbance reduces the likelihood of encountering archaeological resources on the project site, the Draft PEIR acknowledges the potential for inadvertent discovery of buried materials during excavation and grading activities. MM CUL-1 requires archaeological monitoring by a qualified professional in areas where excavation could encounter native soils, while MM CUL-2 mandates immediate work stoppage, evaluation by a qualified archaeologist, and implementation of appropriate treatment measures if cultural resources are found. These protocols align with CEQA Guidelines §15064.5 and ensure any discovered archaeological materials are handled in a manner that avoids or substantially lessens impacts, resulting in a less-than-significant impact with mitigation incorporated. (see Draft and Final PEIR — §4.4).

6.3.3.3 Cumulative Impacts
Cumulative impacts to archaeological resources may result when successive development across a region disturbs or destroys subsurface cultural materials without adequate identification or treatment. This is particularly critical in areas where archaeological sensitivity is not fully mapped or where project-specific assessments fail to include appropriate discovery protocols.

For the Kaiser Permanente Redlands Medical Center project, although prior disturbance reduces the likelihood of encountering intact archaeological resources, there remains potential for inadvertent discovery during excavation. Mitigation Measures MM CUL-1 and MM CUL-2 require archaeological monitoring and treatment protocols in accordance with CEQA Guidelines §15064.5.

Because the project incorporates industry-standard discovery procedures and professional oversight, it ensures that any inadvertent finds will be managed in a way that avoids substantial loss of archaeological context. Therefore, the project would not make a cumulatively considerable contribution to regional archaeological resource degradation.

6.3.4 Cultural Resources Threshold C (human remains)
Threshold c): Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
There are no known burial sites or cemeteries within the project boundaries, and the site has been previously disturbed. However, the possibility of encountering unknown human remains during ground-disturbing activities cannot be fully dismissed. MM CUL-3 requires that if human remains  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-18 Findings of Fact and Statement of Overriding Considerations January 2026 are discovered, work shall immediately cease, a qualified archaeologist shall evaluate the find, and the County Coroner and Native American Heritage Commission shall be notified and procedures under state law followed. (see Draft and Final PEIR — §4.4).

6.3.4.1 Findings
Based on substantial evidence in the administrative record, implementation of MM CUL-3 ensures that, if any human remains are encountered, proper respectful handling and statutory requirements are followed. Therefore, impacts related to disturbance of human remains would be less than significant with mitigation incorporated. The City finds that the MM CUL-3 is feasible, will reduce the potential cultural resource impacts of the proposed project to less-than-significant levels, and is adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.3.4.2 Facts in Support of Findings
The Draft PEIR confirms that there are no known cemeteries or documented burial sites within the project area and that the site has been subject to prior disturbance, reducing the likelihood of encountering human remains. However, given the inherent uncertainty in subsurface conditions, MM CUL-3 has been included to address the potential discovery of human remains during grounddisturbing activities. This measure requires that all work stop immediately if remains are found, a qualified archaeologist evaluate the discovery, and that the San Bernardino County Coroner and, if necessary, the Native American Heritage Commission (NAHC) be notified. Procedures outlined in California Health and Safety Code §7050.5 and Public Resources Code §5097.98 will be followed to ensure respectful and lawful treatment of any human remains. These actions reduce the potential for significant impacts to less than significant with mitigation incorporated. (see Draft and Final PEIR — §4.4).

6.3.4.3 Cumulative Impacts
Cumulative impacts related to the disturbance of human remains can occur when development activities across a region increase the risk of unintentional discoveries, particularly in areas with undocumented or ancestral burial sites. Without adequate protocols, such discoveries can result in the irreversible loss of cultural knowledge and violate statutory and cultural obligations.

The Kaiser Permanente Redlands Medical Center project site contains no known cemeteries or mapped burial locations and has undergone previous ground disturbance. However, because the potential for encountering unknown human remains cannot be entirely ruled out, the project includes MM CUL-3, which requires compliance with California Health and Safety Code §7050.5 and Public Resources Code §5097.98 in the event of a discovery.

With these safeguards in place including immediate work stoppage, evaluation by a qualified archaeologist, and coordination with the County Coroner and the Native American Heritage Commission as appropriate the project would not contribute to a cumulatively considerable impact on cultural resources involving human remains.
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6.4 Geology and Soils
The proposed Project would have a potentially significant impact related to geology and soils as follows:
▪ Geology and Soils Threshold F (paleontological resources)

6.4.1 Mitigation Measures
The following mitigation measures were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to geology and soils to less than significant levels. The measures as provided include any revisions incorporated in the Final PEIR.

Mitigation Measure 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.

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  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-20 Findings of Fact and Statement of Overriding Considerations January 2026 e. Procedures of fossil recovery, removal, treatment, transport, and deposition facility f. Recording, documentation, and reporting procedures
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.

The qualified paleontologist shall perform periodic inspections of excavation and grading 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. (see Draft and Final PEIR — §§4.6, 11).

6.4.2 Geology and Soils Threshold F (paleontological resources) Would the Project:

Threshold f): Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The project site is underlain primarily by Holocene alluvial deposits with low potential for paleontological resources; however, deeper ground disturbance could encounter older, scientifically significant materials. The project incorporates project design feature (PDF) PDF-GEO-1, requiring adherence to all recommendations in the Geotechnical Investigation Report, and MM-GEO-1, which mandates professional paleontological monitoring, fossil recovery, and curation if resources are uncovered. Implementation of these measures will ensure that any unanticipated discoveries are properly managed and preserved, reducing potential impacts to less than significant. (see Draft and Final PEIR — §4.6).

6.4.2.1 Findings
Substantial evidence in the administrative record supports that although the potential for encountering paleontological resources is low at shallow depths, deeper excavation could encounter older, potentially significant fossil-bearing strata. Implementation of PDF-GEO-1 and MM GEO-1 requires professional monitoring, discovery protocols, and curation of fossil material consistent with CEQA Guidelines Appendix G, ensuring that any unanticipated discoveries are properly protected and managed. Therefore, impacts to paleontological resources under CEQA Geology and Soils Threshold (f) would be less than significant with mitigation incorporated. The City finds that MM GEO-1 is feasible, will reduce the potential geology and soils-related impacts of the proposed project to less-  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-21 Findings of Fact and Statement of Overriding Considerations January 2026 than-significant levels, and is adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.4.2.2 Facts in Support of Findings
The Draft PEIR identifies that while the project site is primarily underlain by recent Holocene alluvial deposits with low potential for paleontological sensitivity, deeper excavations may reach older geologic units that could contain scientifically significant fossil resources. To address this, PDF-GEO1 ensures appropriate excavation and safety practices. by requiring the following:

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 Investigation Report prepared for the Medical Office Building 2 (MOB 2) project at the Kaiser Redlands site located at 1301 California Street in Redlands. Prepared by Twining, dated March 31, 2023; provided in Appendix D7 of the PEIR.

Additionally, MM GEO-1 requires monitoring by a qualified paleontologist during ground-disturbing activities below the upper disturbed layers, with provisions for the recovery, documentation, and curation of any fossil materials encountered. These measures align with CEQA Guidelines Appendix G and professional standards, ensuring that any unanticipated paleontological discoveries are adequately managed and protected, thereby reducing potential impacts to less than significant. (see Draft and Final PEIR — §§ 1, 4.6).

6.4.2.3 Cumulative Impacts
Cumulative impacts to paleontological resources can arise when multiple development projects across a region involve deep excavation in fossil-bearing geologic formations without proper monitoring or recovery protocols. Over time, such activities can lead to the incremental loss of scientifically important paleontological data and specimens, particularly in areas with known or potential fossil sensitivity.

The Kaiser Permanente Redlands Medical Center project site has low paleontological sensitivity at shallow depths due to Holocene alluvium but may encounter deeper fossil-bearing strata during grading or trenching. Mitigation Measure MM GEO-1 requires paleontological monitoring, fossil salvage, documentation, and curation if significant resources are discovered. Project Design Feature PDF-GEO-1 also ensures adherence to geotechnical recommendations that guide excavation procedures.

Because the project includes proactive and professionally guided measures to avoid, minimize, and manage any paleontological discoveries, it would not contribute to a cumulatively considerable loss of paleontological resources in the region.

6.5 Greenhouse Gas Emissions
The proposed Project would have a potentially significant impact related to greenhouse gas emissions as follows:
▪ Greenhouse Gas Emissions Threshold B (reducing emissions)  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-22 Findings of Fact and Statement of Overriding Considerations January 2026

6.5.1 Mitigation Measures
The following mitigation measures were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to greenhouse gas emissions to less than significant levels. These GHG mitigation measures are taken from the California Air Pollution Control Officer’s Association’s (CAPCOA)’s Handbook For Analyzing Greenhouse Gas Emissions. These measures quantify GHG reductions that may be applied in potentially significant projects and include the range of potential GHG reductions in parentheses. The measures as provided include any revisions incorporated in the Final PEIR.

Mitigation Measure GHG-1. Using alternative fuels for construction equipment (0 to 22 percent).

Mitigation Measure 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).

Mitigation Measure 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 – 𝑡𝑚/𝑡𝑏)100, where 𝑡𝑚 is the mitigated idling period and 𝑡𝑏 is the baseline idling period) (CAPCOA, 2010, p. 429).

Mitigation Measure 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 CARB 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.

Mitigation Measure 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).
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-23 Findings of Fact and Statement of Overriding Considerations January 2026 (see Draft and Final PEIR — §§4.7, 11).

6.5.2 Greenhouse Gas Emissions Threshold B (reducing emissions) Would the project:

Threshold b): Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? The project is designed to comply with statewide and local Greenhouse Gas (GHG)-reduction policies, including Title 24, CALGreen, and the City of Redlands Climate Action Plan. The all-electric building design, clean on-site energy systems, and transportation demand strategies support continued consistency with adopted GHG-reduction goals. The project incorporates numerous project design features (PDF) GHG-PDF-1 through GHG-PDF-9, which reduce GHG emissions through the promotion of conservation and efficiency, as well as greenhouse gas emission mitigation measures for construction, MM-GHG-1 through MM-GHG-5, derived from CAPCOA’s Handbook For Analyzing Greenhouse Gas Emissions. Implementation of MM TRANS-1 through MM TRANS-4 and MM AQ-1 and MM AQ-2 will further reduce operational emissions. With these measures, the project would not conflict with applicable GHG-reduction plans. and the impacts would be less than significant. (see Draft and Final PEIR — §§ 1, 4.7).

6.5.2.1 Findings
Based on substantial evidence in the administrative record, the project would comply with applicable State and City GHG-reduction plans and building energy requirements, as well as incorporate GHG project design features beyond the minimum requirements of CalGreen (GHG-PDF-1 through GHGPDF-9). The project would further incorporate greenhouse gas emission mitigation measures MMGHG-1 through MM-GHG-5 which will reduce construction emissions, and operational GHG emissions would be reduced through implementation of MM TRANS-1 through MM TRANS-4 and MM AQ-1 and MM AQ-2. As such, the project would not generate GHG emissions that would conflict with adopted GHG-reduction strategies or result in a cumulatively considerable contribution to climate change. Impacts would be less than significant with mitigation incorporated.

The City finds that MM GHG-1 through MM GHG-5 are feasible, will reduce the potential greenhouse gas emission-related impacts of the proposed project to less-than-significant levels, and are adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.5.2.2 Facts in Support of Findings
The Draft PEIR confirms that the project incorporates numerous design and operational features aligned with State and local GHG reduction goals, including compliance with Title 24 building energy efficiency standards, the CALGreen Code, and the City of Redlands Climate Action Plan. The project’s all-electric building design, on-site renewable energy generation, and sustainable transportation measures contribute to minimizing GHG emissions. Additional conservation and efficiency GHG project design features are proposed beyond the minimum requirements of CalGreen:
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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).

With respect to construction emissions, CAPCOA has developed a method of quantifying GHG reducing measures that may be incorporated into potentially significant projects. These quantifiable construction mitigation measures (MM GHG-1 through MM GHG-5) and range of potential GHG reductions in parentheses will be incorporated into this project. These measures reduce GHG emissions during construction through the use of alternative fuels and electrified or hybrid construction equipment, limiting idling times, institution of a heavy-duty offroad vehicle plan, and construction vehicle inventory tracking system.

To further reduce operational GHG emissions, MM TRANS-1 through MM TRANS-4 implement transportation demand management strategies to lower vehicle miles traveled, while MM AQ-1 and MM AQ-2 require the use of low-emission landscaping equipment and the provision of electric vehicle charging infrastructure.

These combined design features and mitigation measures ensure that the project does not conflict with any applicable GHG-reduction plans and that its contribution to cumulative GHG emissions and climate change would be less than significant with mitigation incorporated. (see Draft and Final PEIR — §§ 1, 4.7).
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-25 Findings of Fact and Statement of Overriding Considerations January 2026

6.5.2.3 Cumulative Impacts
Cumulative impacts related to greenhouse gas (GHG) emissions are inherently global in scope.

Projects that fail to align with applicable climate action plans or exceed emission reduction targets may incrementally contribute to the broader impacts of climate change, including sea level rise, increased wildfire risk, and extreme weather events. CEQA requires that a project’s GHG emissions be evaluated for consistency with adopted plans and policies aimed at reducing such emissions statewide and locally.

The Kaiser Permanente Redlands Medical Center project incorporates building electrification, on-site renewable energy, and energy-efficient design consistent with Title 24, CALGreen, and the City of Redlands Climate Action Plan. The project would also incorporate conservation and efficiency GHG project design features beyond the minimum requirements of CalGreen (GHG-PDF-1 through GHGPDF-9). The project would incorporate greenhouse gas emission mitigation measures MM-GHG-1 through MM-GHG-5 which will reduce construction emissions. Operational GHG emissions are further reduced through transportation demand management (MM TRANS-1 through MM TRANS-4) and low-emission landscaping equipment and electric vehicle charging requirements (MM AQ-1 and MM AQ-2).

Because the project is consistent with applicable GHG-reduction policies and does not exceed relevant efficiency-based thresholds, it would not contribute to a cumulatively considerable GHG impact or conflict with the regional and statewide framework to combat climate change.

6.6 Tribal Cultural Resources
The proposed Project would have a potentially significant impact related to tribal cultural resources as follows:
▪ Tribal Cultural Resource Threshold A(i) and A(ii) (CA. Pub. Res Code §§ 5020.1(k), 5024.1(c))

6.6.1 Mitigation Measures
The following mitigation measures were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to tribal cultural resources to less than significant levels. The measures as provided include any revisions incorporated in the Final PEIR.

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), including Gabrieleño Band of Mission Indians – Kizh Nation. 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). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.
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2. A copy of the executed monitoring agreement with each monitoring Consulting Tribe(s), including Gabrieleño Band of Mission Indians – Kizh Nation, shall be submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

3. The monitor(s), including Gabrieleño Band of Mission Indians – Kizh Nation, 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 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, including Gabrieleño Band of Mission Indians – Kizh Nation.

4. On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Consulting Tribe(s) , including Gabrieleño Band of Mission Indians – Kizh Nation, 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) , including Gabrieleño Band of Mission Indians – Kizh Nation, 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) , including Gabrieleño Band of Mission Indians – Kizh Nation, monitor(s) and/or archaeologist(s).

MM-TCR-3: Unanticipated Discovery of Human Remains and Less than Native American Monitor/Project 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.
 6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-27 Findings of Fact and Statement of Overriding Considerations January 2026 E. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
(see Draft and Final PEIR — §§4.13, 11).

6.6.2 Tribal Cultural Resource Threshold A(i) and A(ii) (CA. Pub. Res Code §§ 5020.1(k), 5024.1(c))
Threshold 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 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 Resources Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Although no tribal cultural resources were identified during the pedestrian survey, a NAHC Sacred Lands File search returned positive results and tribal outreach indicated cultural sensitivity in proximity to traditional use areas. Given limited ground visibility and potential for previously unknown resources, MM TCR-1, MM TCR-2, and MM TCR-3 shall be implemented to ensure appropriate tribal monitoring, discovery procedures, and avoidance/treatment protocols during ground disturbance. (see Draft and Final PEIR — §4.13).

6.6.2.1 Findings
Substantial evidence in the administrative record demonstrates that while no known TCRs occur within the project boundaries, tribal input and Sacred Lands File records confirm that the broader area is culturally sensitive. MM TCR-1 through MM TCR-3 ensure compliance with AB 52 requirements, timely tribal notification, work stoppage procedures, and preservation/treatment consistent with tribal preferences. Therefore, potential impacts to tribal cultural resources would be less than significant with mitigation incorporated. The City finds that the MM TCR-1 through MM TCR-3 are feasible, will reduce the potential tribal cultural resource impacts of the proposed project to less-than-significant levels, and are adopted by the City. Accordingly, the City finds, that pursuant to PRC Section 21081(a)(1), and the CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the Final PEIR.

6.6.2.2 Facts in Support of Findings
Although the pedestrian survey of the project site did not identify any specific tribal cultural resources (TCRs), the Sacred Lands File search conducted by the Native American Heritage Commission (NAHC) returned positive results, and consultation with tribes under AB 52 indicated cultural sensitivity in the surrounding area. Due to limited ground surface visibility and the potential for previously unrecorded subsurface TCRs, the project includes MM TCR-1, requiring a tribal  6.0-POTENTIALLY SIGNIFICANT IMPACTS MITIGATED TO LESS THAN SIGNIFICANT  7214/Kaiser Permanente Redlands Medical Center Page 6-28 Findings of Fact and Statement of Overriding Considerations January 2026 monitor be present during initial ground-disturbing activities; MM TCR-2, which establishes work stoppage and evaluation protocols if potential TCRs are discovered; and MM TCR-3, ensuring treatment measures are developed in consultation with affiliated tribes. These mitigation measures ensure compliance with CEQA and AB 52 requirements and provide a culturally appropriate framework for the protection and management of any tribal resources that may be encountered, reducing potential impacts to less than significant with mitigation incorporated. (see Draft and Final PEIR — §4.13).

6.6.2.3 Cumulative Impacts
Cumulative impacts to tribal cultural resources may result when multiple development projects in culturally sensitive areas incrementally disturb or destroy landscapes, objects, or places of significance to California Native American tribes—particularly when appropriate tribal consultation, monitoring, and treatment protocols are not implemented. Such cumulative degradation can lead to irreversible loss of cultural heritage and spiritual value.

While no known tribal cultural resources (TCRs) were identified on the Kaiser Permanente Redlands Medical Center project site, the positive Sacred Lands File result and input received through AB 52 consultation confirm that the surrounding area holds cultural sensitivity. Due to the potential for unanticipated discoveries during excavation, the project includes MM TCR-1 (tribal monitoring), MM TCR-2 (work stoppage and evaluation protocols), and MM TCR-3 (treatment in coordination with consulting tribes).

These mitigation measures ensure tribal involvement in ground-disturbing activities and provide a culturally respectful framework for discovery and management of any TCRs. As a result, the project would not result in a cumulatively considerable contribution to the loss or degradation of tribal cultural resources.
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7.0 ENVIRONMENTAL EFFECTS THAT REMAIN SIGNIFICANT AND UNAVOIDABLE

AFTER MITIGATION
Pursuant to CEQA Guidelines §15126.2 and §15092, this section identifies environmental effects that would remain significant and unavoidable despite implementation of all feasible mitigation measures.

Pursuant to Section 21081(a) of the Public Resources Code and Section 15091(a)(1) of the CEQA Guidelines, the City finds that for each of these significant and unavoidable effects identified in the Final PEIR, changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the final PEIR.

The City adopts all of the feasible mitigation measures for the project described in the Final PEIR and as set forth in the Mitigation Monitoring and Reporting Program (MMRP) as conditions of approval of the project and incorporates those into the project.

However, there are no feasible mitigation measures that will reduce the impact of the proposed project to less than significant. Therefore, the following impacts would remain significant and unavoidable after mitigation.

Pursuant to CA. Pub. Res. Code § 21081 and CEQA Guidelines §§ 15093 and 15043, for those significant impacts that cannot be mitigated to a less than significant level, a public agency may nevertheless approve the project if the agency first adopts a statement of overriding considerations setting forth the specific reasons why the agency found that the project's benefits render its unavoidable adverse environmental effects “acceptable.” In accordance with Section 15093 of the State CEQA Guidelines, a Statement of Overriding Considerations is set forth below in Section 10 to substantiate the City’s decision to accept these unavoidable substantial, adverse environmental effects because of the benefits afforded by the Project.

These findings are explained below and are supported by substantial evidence in the administrative record, including but not limited to the environmental evaluation presented in the Initial Study (Appendix A) and further analyzed in Chapter 4.0 of the Final PEIR, among others.

7.1 Greenhouse Gas (GHG) Emissions

7.1.1 Significant and Unavoidable Impact – GHG Threshold A (GHG emissions) Threshold a): Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Even with project design features and feasible measures (including for example, fleet electrification/renewable diesel during construction (e.g., MMs GHG-1, MM GHG-2, and MM GHG4); on-site energy efficiency exceeding Title 24 (e.g., GHG-PDF-1); no natural-gas combustion (e.g., GHG-PDF-9); EV charging (e.g., MM AQ-2); commute/VMT reduction strategies such as vanpools and rideshare (e.g., MM TRANS-1 through MM TRANS-4 and MM AQ-2)), amortized construction plus operational emissions are expected to exceed the commonly used SCAQMD screening value of 3,000 MTCO₂e/yr for land use projects (draft, not formally adopted). Therefore, project GHG emissions remain significant and unavoidable. (see Draft and Final PEIR — §§1, 4.7, 11).  7.0-EFFECTS SIGNIFICANT AND UNAVOIDABLE AFTER MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 7-2 Findings of Fact and Statement of Overriding Considerations January 2026

7.1.2 Mitigation Measures
Greenhouse gas emission mitigation measures MM GHG-1 through MM GHG-5 (as described in Section 6.5.1 above) were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to greenhouse gas emissions.

These GHG mitigation measures are taken from the CAPCOA’s Handbook For Analyzing Greenhouse Gas Emissions. The measures as provided include any revisions incorporated in the Final PEIR. (see Draft and Final PEIR — §§4.7, 11).

7.1.3 Findings
Based on substantial evidence in the administrative record, the project would comply with applicable State and City GHG-reduction plans and building energy requirements, as well as incorporate GHG project design features beyond the minimum requirements of CalGreen (GHG-PDF-1 through GHGPDF-9). The project would further incorporate greenhouse gas emission mitigation measures MMGHG-1 through MM-GHG-5 which will reduce construction emissions, and operational GHG emissions would be reduced through implementation of MM TRANS-1 through MM TRANS-4 and MM AQ-1 and MM AQ-2. Despite the adoption of these measures however, there are no feasible mitigation measures that will reduce the impact of the proposed project to less than significant and this impact would remain significant and unavoidable after mitigation.

The City finds that implementation of the identified mitigation measures is feasible and will reduce impacts on GHG emissions attributable to the proposed project. Pursuant to Public Resources Code Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project which will mitigate, in part, this significant impact to GHG emissions attributable to the project, as identified in the Final PEIR.

However, the City finds that there are no feasible mitigation measures that will reduce the impact of the proposed project to less than significant. Therefore, this impact would remain significant and unavoidable. However, pursuant to Public Resources Code Section 21081(b), specific overriding economic, legal, social, technological, and other benefits of the proposed project outweigh this significant and unavoidable impact.

7.1.4 Facts in Support of Findings
The Draft PEIR confirms that the project incorporates numerous design and operational features aligned with State and local GHG reduction goals, including compliance with Title 24 building energy efficiency standards, the CaLGreen Code, and the City of Redlands Climate Action Plan. The project’s all-electric building design, on-site renewable energy generation, and sustainable transportation measures contribute to minimizing GHG emissions. Additional conservation and efficiency GHG project design features are proposed beyond the minimum requirements of CalGreen, including GHGPDF-1 through GHG-PDF-9 (as described in Section 6.5.2 above).

With respect to construction emissions, CAPCOA has developed a method of quantifying GHG reducing measures that may be incorporated into potentially significant projects. These quantifiable construction mitigation measures (MM GHG-1 through MM GHG-5) will reduce potential GHG reductions and will be incorporated into this project. These GHG mitigation measures reduce GHG emissions during construction through the use of alternative fuels and electrified or hybrid  7.0-EFFECTS SIGNIFICANT AND UNAVOIDABLE AFTER MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 7-3 Findings of Fact and Statement of Overriding Considerations January 2026 construction equipment, limiting idling times, institution of a heavy-duty offroad vehicle plan, and construction vehicle inventory tracking system.

To further reduce operational GHG emissions, MM TRANS-1 through MM TRANS-4 implement transportation demand management strategies to lower vehicle miles traveled, while MM AQ-1 and MM AQ-2 require the use of low-emission landscaping equipment and the provision of electric vehicle charging infrastructure.

Mitigated GHG emissions from the project 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 (MM TRANS-1 through MM TRANS-4) 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.

Therefore, for GHG Emissions Threshold A, the project’s impacts would be significant and unavoidable even with mitigation measures.
(see Draft and Final PEIR — §§ 1, 4.2, 4.7).

7.1.5 Cumulative Impacts
Cumulative impacts related to greenhouse gas (GHG) emissions are inherently global in scope. 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.

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 would also incorporate conservation and efficiency GHG project design features beyond the minimum requirements of CalGreen (GHG-PDF-1 through GHG-PDF-9). The project would incorporate greenhouse gas emission mitigation measures MM-GHG-1 through MM-GHG-5 which will reduce construction emissions. Operational GHG emissions are further reduced through transportation demand management (MM TRANS-1 through MM TRANS-4) and low-emission construction landscaping equipment and electric vehicle charging requirements (MM AQ-1 and MM AQ-2).

Despite these measures, 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.

The City finds that implementation of the identified mitigation measures are feasible and will reduce impacts on GHG emissions attributable to the proposed project. Pursuant to Public Resources Code Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project which will mitigate, in part, this significant impact to GHG emissions attributable to the project, as identified in the Final PEIR.

However, the City finds that there are no feasible mitigation measures that will reduce the impact of the proposed project to less than significant. Therefore, this impact would remain significant and  7.0-EFFECTS SIGNIFICANT AND UNAVOIDABLE AFTER MITIGATION  7214/Kaiser Permanente Redlands Medical Center Page 7-4 Findings of Fact and Statement of Overriding Considerations January 2026 unavoidable. However, pursuant to Public Resources Code Section 21081(b), specific overriding economic, legal, social, technological, and other benefits of the proposed project outweigh this significant and unavoidable impact.

7.2 Transportation – Vehicle Miles Traveled (VMT)

7.2.1 Significant and Unavoidable Impact – VMT Threshold B (CEQA Guidelines § 15064.3(b))
Threshold b): Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Substantial evidence in the record demonstrates that the project would generate Home-Based-Work VMT per employee that exceeds the City of Redlands VMT significance threshold under CEQA Guidelines §15064.3(b). Although feasible VMT-reduction measures would be implemented (including MM TRANS-1 through MM TRANS-4), these measures would not achieve sufficient VMT reduction to fall below the threshold. Therefore, the impact remains significant and unavoidable. (see Draft and Final PEIR — §4.12).

7.2.2 Mitigation Measures
Transportation mitigation measures MM TRANS-1 through MM TRANS-4 (as described in Sections

6.1.1 and 6.5.2 above) were included in the Draft PEIR and the Final PEIR, are applicable to the proposed project and would reduce potential project impacts related to transportation. The measures as provided include any revisions incorporated in the Final PEIR. (see Draft and Final PEIR — §§4.12, 11).

7.2.3 Findings
Based on substantial evidence in the administrative record, the project incorporates transportation mitigation measures MM-TRANS-1 through MM-TRANS-4 which will reduce operational VMT impacts. Despite the adoption of these measures, however, there are no feasible mitigation measures that will reduce the impact of the proposed project to less than significant, and this impact would remain significant and unavoidable after mitigation.

The City finds that implementation of the identified mitigation measures is feasible and will reduce VMT transportation impacts attributable to the proposed project. Pursuant to Public Resources Code Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project which will mitigate, in part, this significant impact to GHG emissions attributable to the project, as identified in the Final PEIR.

However, the City finds that there are no feasible mitigation measures that will reduce the impact of the proposed project to less than significant. Therefore, this impact would remain significant and unavoidable. However, pursuant to Public Resources Code Section 21081(b), specific overriding economic, legal, social, technological, and other benefits of the proposed project outweigh this significant and unavoidable impact.
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7.2.4 Facts in Support of Findings
The Draft PEIR confirms that the project will incorporate transportation mitigation measures MMTRANS-1 through MM-TRANS-4 which will reduce operational VMT impacts.

Project operation is estimated to generate 16,093 trips per day. VMT was estimated using the homebased work method that focuses on commute trips. This is the travel between a person's home and workplace. This method is used because it is consistent with the City's guidelines. Project employment at Master Plan buildout is estimated to be 1,900 employees (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 of the PEIR, estimated project VMT per employee in 2050 is 22.7, that is, 12 percent higher than the City’s threshold.

Therefore, for Transportation Threshold B, the project’s impacts would be significant and unavoidable even with mitigation measures.
(see Draft and Final PEIR — §4.12).

7.2.5 Cumulative Impacts
Pursuant to CEQA Guidelines § 15355 defines “cumulative impacts” in part, as two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. (a) The individual effects may be changes resulting from a single project or a number of separate projects. (b) The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.

The key is whether the project significantly adds to an existing or developing significant cumulative problem, often determined by comparing project effects against established thresholds of significance for a given region.

Per Section 4.12.5 of the PEIR, the VMT impact analysis summarized in Section 7.2 above applies to cumulative as well as direct impacts. Thus, despite the application of the transportation mitigation measures (MM TRANS-1 through MM TRANS-4), the project’s incremental contribution to VMT is estimated to be cumulatively considerable. For these reasons, the project’s cumulative contribution to VMT would be significant and unavoidable.

The City finds that implementation of the identified transportation mitigation measures are feasible and will reduce VMT impacts attributable to the proposed project. Pursuant to Public Resources Code Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed project which will mitigate, in part, this significant VMT impact attributable to the project, as identified in the Final PEIR.

However, the City finds that there are no feasible mitigation measures that will reduce the impact of the proposed project to less than significant. Therefore, this impact would remain significant and unavoidable. However, pursuant to Public Resources Code Section 21081(b), specific overriding economic, legal, social, technological, and other benefits of the proposed project outweigh this significant and unavoidable impact.
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7214/Kaiser Permanente Redlands Medical Center Page 8-1 Findings of Fact and Statement of Overriding Considerations January 2026

8.0 FINDINGS REGARDING PROJECT ALTERNATIVES
Section 15126.6(a) of the CEQA Guidelines requires the discussion of “a reasonable range of alternatives to a project, or the location of a 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.” The PEIR considered and analyzed the following four alternatives to the proposed project which would be capable, to varying degrees, of reducing identified impacts:
▪ Alternative 1 — No Project Alternative
▪ Alternative 2 — No Project/General Plan Buildout Alternative; ▪ Alternative 3 — Reduced Intensity Alternative; and
▪ Alternative 4 — Dispersed Facilities Alternative.

These alternatives are discussed below and evaluated for their ability to avoid or substantially lessen the impacts of the proposed project identified in the Final PEIR, as well as consideration of their ability to meet the basic objectives of the proposed project as described in the Final PEIR as follows:

1. Provide health care capacity for Kaiser Permanente members in the San BernardinoRedlands region.

2. Incorporate numerous sustainability features such as vegetated swales, tree-based infiltration, and inert bioswales; high-performance 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.

3. Develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1.

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.

The City finds that a good faith effort was made to evaluate all reasonable alternatives to the project that could feasibly obtain the basic objectives of the project, even when the alternatives might impede the attainment of the project objectives or might be more costly. The City also finds that all reasonable alternatives were reviewed, analyzed, and discussed in the review process of the Final PEIR and the ultimate decision on the project.

8.1 Alternative 1: No Project Alternative

8.1.1 Summary of Alternative
Under the No Project Alternative, the project would not be constructed. The existing medical office building would continue operating, and the remainder of the site would remain vacant. No demolition, grading, or construction would occur. Regional patients and staff would continue traveling to other Kaiser Permanente facilities (e.g., Fontana and Ontario).  8.0-PROJECT ALTERNATIVES FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 8-2 Findings of Fact and Statement of Overriding Considerations January 2026

8.1.2 Reasons for Rejecting Alternative
This alternative would avoid all project impacts, including significant and unavoidable GHG and VMT impacts. However, it would not achieve any of the project objectives. It would not expand regional care capacity, would not develop the project site in accordance with Redlands Business Center Concept No. 1, and would not support long-term development of medical facilities to keep pace with Kaiser Permanente’s anticipated membership increase or support long-term regional medical service needs. Additionally, no new employment, public-service benefits, or consistency with planned medical land uses would be provided. Therefore, despite environmental advantages, this alternative would not meet the needs for the project and is inconsistent with core health-care service and policy goals. (see Draft and Final PEIR — §§5.5, 6.4.2).

8.1.3 Findings
Under Alternative 1, the No Project alternative, the project would not be approved, and no development would occur. The No Project Alternative would eliminate the project’s significant and unavoidable construction transportation impact. The No Project Alternative would have similar impacts as the project for wildfire hazards. Impacts associated with the remaining environmental issues would be less than those of the proposed project. None of the impacts of this alternative would be considerably greater than those of the proposed project.

Accordingly, per CEQA Guidelines § 15126.6, Alternative 1, the No Project alternative, is the environmentally superior alternative (see Draft and Final PEIR - §§ 1.11.5, 5.1, 5.9). CEQA Guidelines Section 15126.6(e)(2) states that if the environmentally superior alternative is the “No Project” alternative, the PEIR must also identify an environmentally superior alternative among the other alternatives. Here, that would be Alternative 3, the Reduced Density Alternative, which is addressed below.

However, Alternative 1 would not meet any of the project objectives including the development of a medical center serving Kaiser Permanente members in the San Bernardino-Redlands region. Rather, the site would remain undeveloped land. Pursuant to Public Resources Code Section 21081(a)(3) and CEQA Guidelines Section 15091(a)(3), the City rejects the Alternative 1, No Project alternative, finding it undesirable due to the following: it fails the proposed project’s underlying purpose; and does not meet any of the project objectives..

8.2 Alternative 2: No Project/General Plan Buildout Alternative

8.2.1 Summary of Alternative
Under this alternative, the existing medical office building would remain present and in operation, and the remainder of the site (28.15 acres) would be developed with other uses, that are not necessarily related to the existing development, but are consistent with the current General Plan land use designation for the site, “Commercial Industrial.” Uses consistent with this designation include commercial, light industrial, flex commercial space, business parks, auto services, retail, services, manufacturing, and other institutional uses. Under this scenario, development may proceed incrementally under different proponents, potentially resulting in fragmented developmentand reduced functional and environmental performance.
 8.0-PROJECT ALTERNATIVES FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 8-3 Findings of Fact and Statement of Overriding Considerations January 2026

8.2.2 Reasons for Rejecting Alternative
Although this alternative may reduce or change the magnitude of some potential impacts (e.g., air quality, energy use), it would still result in significant and unavoidable Greenhouse Gas Emission and VMT (transportation) impacts and it would not fulfill the project’s purpose or core objectives.

Alternative 2 would not meet objective 1 because it would not improve regional access to comprehensive health care for Kaiser Permanente members. Alternative 2 would not meet objective 3 because it would not develop the project site in accordance with Redlands Business Center Concept No. 1 land use regulations. Compared with the proposed project, this Alternative would not as effectively support the phased, long-term development of medical facilities to keep pace with Kaiser Permanente’s anticipated increase in membership, and would reduce support for long-term regional medical office needs. Additionally, new employment, public-service benefits, or consistency with planned medical land uses are less likely to be provided than under the proposed project. Moreover, this scenario could result in less sustainable development patterns and increased VMT, as well as directly conflict with the existing zoning regulations applicable to the project location. For these reasons, this alternative is considered infeasible and inferior to the proposed project. (see Draft and Final PEIR — §5.6, 6.4.2).

8.2.3 Findings
Under Alternative 2, the No Project/General Plan Buildout alternative, the project would not be approved. The existing medical office building remains present and in operation but the balance of the project site (28.15 acres) would be built out in accordance with the existing General Plan land use designation for the site, which is Commercial Industrial.

While Alternative 2 is anticipated to reduce certain environmental impacts, it would not avoid any of the proposed project’s significant and unavoidable impacts. The remaining environmental effects would be generally similar to or greater than those of the proposed project.

Alternative 2 would not satisfy Project Objectives 1 and 3 and only partially meet Project Objectives 2 and 4. Overall, the No Project/General Plan Buildout Alternative would not meet the project’s objectives of providing health care capacity for Kaiser Permanente members in the San BernardinoRedlands region.

Pursuant to Public Resources Code Section 21081(a)(3) and CEQA Guidelines Section 15091(a)(3), the City rejects the Alternative 2, the No Project/General Plan Buildout alternative, finding it undesirable due to the following: it fails the proposed project’s underlying purpose; only partially meets two of the four project objectives; would not avoid the project’s significant and unavoidable impacts; and, because specific economic, legal, social, technological, or other considerations make the alternative infeasible.

8.3 Alternative 3: Reduced Intensity Alternative

8.3.1 Summary of Alternative
This alternative would reduce the intensity of the proposed project by omitting phases 3 and 4 from the project, constructing a smaller medical center, including a reduced-bed hospital and fewer outpatient services, along with a downsized parking structure. Trip generation, energy consumption, grading, and operational emissions would be lower than those associated with the proposed project.  8.0-PROJECT ALTERNATIVES FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 8-4 Findings of Fact and Statement of Overriding Considerations January 2026 Some regional health-care benefits would still occur; however, the reduced scale would limit care accessibility and long-term service delivery capacity.

8.3.2 Reasons for Rejecting Alternative
The Reduced Intensity Alternative would lessen several impacts (including air quality, energy use, and operational emissions) and would reduce, but not avoid, the significant and unavoidable GHG and VMT (transportation) impacts. However, it would only partially achieve the project objectives.

Compared with the proposed project, the Reduced Intensity Alternative would limit the project’s ability to meet Kaiser Permanente’s projected regional health-care demand; reduce operational efficiencies gained through the co-location of health-care services; reduce support for the long-term development of medical facilities to keep pace with Kaiser Permanente’s anticipated membership increase; and reduce support for long-term regional medical service needs. Additionally, new employment and public-service benefits would be decreased in comparison to the proposed project.

For these reasons, although environmentally advantageous in some areas, the Reduced Intensity Alternative is not preferred because it would not adequately fulfill critical health-care service needs for the region. (see Draft and Final PEIR — §§5.7, 6.4.2).

8.3.3 Findings
Under Alternative 3, the Reduced Intensity alternative, phases 3 and 4 of the project would not be implemented.

While Alternative 3 is anticipated to reduce some environmental impacts, it would not avoid any of the proposed project’s significant and unavoidable impacts. The remaining environmental effects would be generally similar to or greater than those of the proposed project.

Alternative 3 would only partially meet Project Objectives 1, 3 and 4. Overall, the Reduced Intensity Alternative would only partially meet project’s objectives of providing health care capacity for Kaiser Permanente members in the San Bernardino-Redlands region.

Per CEQA Guidelines Section 15126.6(e)(2), if the environmentally superior alternative is the “No Project” alternative (Alternative 1 above), the PEIR must also identify an environmentally superior alternative among the other alternatives. Here, that would be Alternative 3 (see Draft and Final PEIR - §§ 1.11.5, 5.1, 5.9).

Nevertheless, pursuant to Public Resources Code Section 21081(a)(3) and CEQA Guidelines Section 15091(a)(3), the City rejects the Alternative 3, the Reduced Intensity alternative, finding it undesirable due to the following: it only partially meets three of the four project objectives and only partially satisfies the proposed project’s underlying purpose; would not avoid the project’s significant and unavoidable impacts; and, because specific economic, legal, social, technological, or other considerations make the alternative infeasible.

8.4 Alternative 4: Dispersed Facilities Alternative

8.4.1 Summary of Alternative
Under this alternative, medical services would be distributed across multiple smaller facilities located throughout the region, rather than co-located on a single, integrated campus. While each  8.0-PROJECT ALTERNATIVES FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 8-5 Findings of Fact and Statement of Overriding Considerations January 2026 facility would serve specific functions (e.g., outpatient care, diagnostics, or urgent care), no centralized, consolidated medical center would be built under this Alternative.

8.4.2 Reasons for Rejecting Alternative
This alternative would avoid site-specific impacts at the Redlands location, but would still result in significant and unavoidable Greenhouse Gas Emission and VMT (transportation) impacts. The decentralized approach would not develop the project site in accordance with Redlands Business Center Concept No. 1. Compared with the proposed project, this Alternative would limit the project’s ability to develop adequatemedical facilities to serve Kaiser Permanente’s anticipated membership increase. Further, this Alternative would compromise staff coordination, reduce operational efficiency and service integration, and likely impede the timely implementation of modern healthcare facilities to address regional needs. This alternative would also be less consistent with the City’s General Plan land use and medical zoning designations.

Therefore, in addition to failing to fully satisfy the project objectives, this alternative is not preferred due to logistical, environmental, and policy alignment shortcomings. (see Draft and Final PEIR — §§5.8, 6.4.2).

8.4.3 Findings
Under Alternative 4, the Dispersed Facilities alternative, the project would develop approximately six small medical office facilities in the San Bernardino–Redlands region (the general service area for the proposed project).

While Alternative 4 is anticipated to reduce certain environmental impacts, including those relatd to VMT, it would not avoid any of the proposed project’s significant and unavoidable impacts. The remaining environmental effects would be generally similar to or greater than those of the proposed project.

Alternative 4 would not satisfy Project Objective 3 and only partially meet Project Objective 4.

Pursuant to Public Resources Code Section 21081(a)(3) and CEQA Guidelines Section 15091(a)(3), the City rejects the Alternative 4, the Dispersed Facilities alternative, finding it undesirable due to the following: of the four project objectives, it fails to satisfy Project Objective 3 and only partially meets Project Objective 4; would not avoid the project’s significant and unavoidable impacts; and, because specific economic, legal, social, technological, or other considerations make the alternative infeasible.  9.0- GENERAL CEQA FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 9-1 Findings of Fact and Statement of Overriding Considerations January 2026

9.0 GENERAL CEQA FINDINGS
As expressed more fully herein, the City certifies that the Final PEIR, dated January 2026, has been completed in compliance with CEQA and the CEQA Guidelines, that the PEIR was presented to the City, and that the City reviewed and considered the information contained therein before approving the proposed project, and that the EIR reflects the independent judgment and analysis of the City agency. (CEQA Guidelines § 15090.)
Any findings made by the City shall be deemed made, regardless of where it appears in this document.

All of the language included in this document constitutes findings by the City, whether or not any particular sentence or clause includes a statement to that effect. The City intends that these findings be considered as an integrated whole and, whether or not any part of these findings fail to crossreference or incorporate by reference any other part of these findings, that any finding required or committed to be made by the City with respect to any particular subject matter of the Final PEIR, shall be deemed to be made if it appears in any portion of these findings.

9.1 Procedural Compliance With California Environmental Quality Act The City published a Draft PEIR on November 18, 2025. A Final PEIR was completed in January of 2026 in compliance with CEQA requirements. The Final PEIR has been prepared in accordance with CEQA and the CEQA Guidelines. As authorized in State CEQA Guidelines Section 15084(d)(2), the City retained a consultant to assist with the preparation of the environmental documents. City staff from multiple departments, representing the Lead Agency, have directed, reviewed, and modified where appropriate all material prepared by the consultant. The key milestones associated with the preparation of the PEIR are summarized below. As presented below, an extensive public involvement and agency notification effort was conducted to solicit input on the scope and content of the PEIR and to solicit comments on the results of the environmental analysis presented in the Draft PEIR.

9.1.1 Environmental Review Process
In conformance with CEQA, the State CEQA Guidelines, and the County CEQA Guidelines, the City conducted an extensive environmental review of the proposed project.

The environmental review process for the project commenced with solicitation of comments from identified responsible and trustee agencies, as well as interested parties on the scope of the Draft PEIR, through a Notice of Preparation (NOP) process. The NOP was circulated for public comment to the State Clearinghouse, Office of Planning and Research, responsible agencies, owners, local addresses, and other interested parties from January 22, 2025 through February 21, 2025. A public scoping meeting for the project was held at 4:30 p.m. on February 12, 2025. As part of the public distribution process for the Initial Study for the proposed project, Native American tribal contacts were sent a copy of the NOP and a CD with the Initial Study and Initial Study appendices. The NOP was Appendix A3 in the Draft PEIR and the public comments received on the Initial Study were included as Appendix A1 in the Draft PEIR.

Consistent with the requirements of § 15087 of the CEQA Guidelines, the Draft PEIR was submitted to the State Clearinghouse, Office of Planning and Research for distribution to state agencies and was circulated for a 45-day public review commencing on November 18, 2025, and ending on January 5, 2026. A Notice of Availability of the Draft PEIR was emailed to those interested parties who requested notice. A press release describing the PEIR and public review thereof was published in the Redlands Daily Facts newspaper on November 18, 2025. The Draft PEIR was made available for review on City  9.0- GENERAL CEQA FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 9-2 Findings of Fact and Statement of Overriding Considerations January 2026 of Redlands website (available here: https://www.cityofredlands.org/post/environmentaldocuments) and at the City’s Development Services Department at 35 Cajon Street, Suite 20, Redlands, CA 92373, A.K. Smiley Public Library at 125 W. Vine Street, Redlands, CA 92373, and at the County’s Clerk of the Board Office located at 385 N. Arrowhead Avenue, #2, San Bernardino, CA 92415. Following the Draft PEIR public comment period, this Final PEIR has been prepared and includes responses to the comments raised regarding the Draft PEIR.

9.2 Environmental Mitigation Monitoring Program
Based on the entire record before the City and having considered the unavoidable significant impacts of the project, the City hereby determines and finds that all feasible mitigation within the responsibility and jurisdiction of the City has been adopted to reduce or avoid the potentially significant impacts identified in the Final PEIR, and that no additional feasible mitigation is available to further reduce significant impacts. The feasible mitigation measures are discussed in Sections 6 and 7, and are set forth in the MMRP attached hereto (Attachment A).

Section 21081.6 of the Public Resources Code requires the City to adopt a monitoring or compliance program regarding the changes in the project and mitigation measures imposed to lessen or avoid significant effects on the environment. The MMRP for the proposed project, which is attached hereto (Attachment A) and made a part of these Findings, is hereby adopted by the City in satisfaction of Section 21081.6 of the Public Resources Code and in fulfillment of the CEQA mitigation monitoring requirements as:
▪ The MMRP is designed to ensure compliance with the changes in the project and mitigation measures imposed on the project during project implementation; and ▪ Measures to mitigate or avoid significant effects on the environment are fully enforceable through conditions of approval, permit conditions, agreements, or other measures.

9.3 CEQA Guidelines Section 15091 and 15092 Findings
Based on the findings herein and the information contained in the administrative record, the City has made one or more of the following findings with respect to each of the significant effects of the project:

1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid significant effects on the environment.

2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and such changes have been adopted by such other agency, or can and should be adopted by such other agency.

3. Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make the mitigation measures or alternatives identified in the Final PEIR infeasible.

Based on the findings herein and the information contained in the administrative record, and as conditioned by the foregoing:
 9.0- GENERAL CEQA FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 9-3 Findings of Fact and Statement of Overriding Considerations January 2026

1. All significant effects on the environment due to the project have been eliminated or substantially lessened where feasible.

2. Any remaining significant effects that have been found to be unavoidable are acceptable due to the overriding considerations set forth in Section 10 herein.

9.4 City of Redland’s Independent Judgment
The Final PEIR for the proposed project reflects the City’s independent analysis and judgment. The City has exercised independent judgment in accordance with Public Resources Code 21082.1(c)(3) in retaining its own environmental consultant in the preparation of the PEIR, as well as reviewing, analyzing, and revising material prepared by the consultant.

Having received, reviewed, and considered the information in the Final PEIR, as well as any and all other information in the record, the City hereby makes these findings pursuant to and in accordance with Sections 21081, 21081.5, and 21081.6 of the Public Resources Code.

9.5 Reliance on Record
Each and all of the findings and determinations contained herein are based on substantial evidence, both oral and written, contained in the administrative record relating to the project.

9.5.1 Record of Proceedings
In accordance with PRC Section 21167.6(e) and for purposes of CEQA and these Findings, the record of proceedings for the City’s decision on the project includes the following documents and other evidence, at a minimum:
▪ The NOP and all other public notices issued by the City in conjunction with the proposed project.
▪ The Final PEIR for the proposed project and all appendices thereto. ▪ The Draft PEIR and all appendices thereto.
▪ All written comments submitted by agencies or members of the public during the public review comment period on the Draft PEIR.
▪ All responses to written comments submitted by agencies or members of the public during the public review comment period on the Draft PEIR.
▪ All written and verbal public testimony presented during a noticed public hearing for the proposed project.
▪ The Mitigation Monitoring and Reporting Program (MMRP). ▪ All documents, including but not limited to EIRs, reports, studies, memoranda, maps, staff reports, or other planning documents or materials cited and/or referenced in the Draft PEIR and Final EIR, or otherwise relied upon with respect to the City’s action on the project;  9.0- GENERAL CEQA FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 9-4 Findings of Fact and Statement of Overriding Considerations January 2026 ▪ All documents submitted by other public agencies or members of the public in connection with the project, up through the close of the final public hearing; ▪ Any minutes and/or verbatim transcripts of all information sessions, public meetings, and public hearings held in connection with the project;
▪ Any documentary or other evidence submitted at such information sessions, public meetings, and public hearings;
▪ All findings and resolutions adopted by the City in connection with the proposed project, and all documents cited and/or referenced therein, including comments received after the close of the comment period and responses thereto.
▪ Matters of common knowledge to the City, including but not limited to federal, state, and local laws and regulations.
▪ Any documents expressly cited in these Findings in addition to those above. ▪ Any other written materials relevant to the City’s compliance with CEQA or its decision on the merits of the project, including any documents or portions thereof, that were released for public review, relied upon in the environmental documents prepared for the project, or included in the City’s non-privileged retained files for the EIR or project; ▪ Any other relevant materials required to be in the record of proceedings by Public Resources Code Section 21167.6(e).
▪ The Notice of Determination.

The City intends that only those documents relating to the project and its compliance with CEQA and prepared, owned, used, or retained by the City and listed above shall comprise the administrative record for the project. Only that evidence was presented to, considered by, and ultimately before the City prior to reviewing and reaching its decision on the EIR and project.

9.5.2 Custodian and Location of Records
The documents and other materials that constitute the administrative record for the City’s actions related to the project are at the City of Redlands Development Services Department main office at 35 Cajon Street, Suite 20, Redlands, CA. Development Services Department is the custodian of the administrative record for the project. Copies of these documents, which constitute the record of proceedings, are and at all relevant times have been and will be available upon request at the offices of the Development Services Department. This information is provided in compliance with Public Resources Code Section 21081.6(a)(2) and Guidelines Section 15091(e).

9.6 Recirculation Not Required
CEQA Guidelines Section 15088.5 provides the criteria that a lead agency is to consider when deciding whether it is required to recirculate an EIR. Recirculation is required when “significant new information” is added to the EIR after public notice of the availability of the Draft EIR is given, but before certification. (CEQA Guidelines, §15088.5(a).)
 9.0- GENERAL CEQA FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 9-5 Findings of Fact and Statement of Overriding Considerations January 2026 In relevant part, CEQA Guidelines Section 15088.5(a) describes “significant new information,” as …information added to an EIR … that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. "Significant new information" requiring recirculation include, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented. (2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
(3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project's proponents decline to adopt it.
(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043).
(CEQA Guidelines, §15088.5(a)(1)-(3).).

Recirculation is not required where “the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.” (CEQA Guidelines, §15088.5(b).).

Recirculation also is not required simply because new information is added to the EIR. New information is routinely added given CEQA’s public/agency comment and response process and CEQA’s post-Draft EIR circulation requirement of proposed responses to comments submitted by public agencies. In brief, recirculation is “intended to be an exception rather than the general rule” (Laurel Heights Improvement Assn. v. Regents of University of California (1993) 6 Cal.4th 1112, 1132.).

Given this context, the City finds that recirculation of the Draft PEIR prior to certification is not required. In addition to providing responses to comments, the Final PEIR includes revisions to expand upon information presented in the Draft PEIR; explains or enhances the evidentiary basis for the Draft PEIR’s findings; updates information; and makes clarifications, amplifications, updates, or helpful revisions to the Draft PEIR. The Final PEIR’s revisions, clarifications and/or updates do not result in any new significant impacts or increase the severity of a previously identified significant impact.

In sum, the Final PEIR demonstrates that the project will not result in any new significant impacts or increase the severity of a significant impact, as compared to the analysis presented in the Draft PEIR.

The changes reflected in the Final PEIR also do not indicate that meaningful public review of the Draft PEIR was precluded in the first instance. Accordingly, recirculation of the PEIR is not required as revisions to the PEIR are not significant as defined in Section 15088.5 of the State CEQA Guidelines.  9.0- GENERAL CEQA FINDINGS 
7214/Kaiser Permanente Redlands Medical Center Page 9-6 Findings of Fact and Statement of Overriding Considerations January 2026

9.7 Certification Of The Final Program Environmental Impact Report In accordance with CEQA and the CEQA Guidelines, having received, reviewed, and considered the PEIR for the Kaiser Permanente Redlands Medical Center project (SCH 2025010666), as well as other information in the record of proceedings on this matter, the City of Redlands, as the Lead Agency certifies and adopts the Findings of Fact (Findings) and Statement of Overriding Considerations contained herein as part of its certification of the Final PEIR for the project. The Findings and Statements of Overriding Considerations set forth the environmental and other bases for current and subsequent discretionary actions to be undertaken by the City and responsible agencies for the implementation of the project.

The City hereby makes findings pursuant to and in accordance with Section 21081 of the California Public Resources Code and State CEQA Guidelines Sections 15043 (Authority to Approve Projects Despite Significant Effects), 15090 (Certification of the Final EIR) and 15091 (Findings) and hereby certifies that:
(1) the final PEIR has been completed in compliance with CEQA; (2) the final PEIR was presented to the City Council of the City of Redlands as the decision making body of the lead agency and that the City Council reviewed and considered the information contained in the final PEIR prior to approving the project; and (3) as noted in Section 9, the final EIR reflects the lead agency's independent judgment and analysis.

The City further certifies that changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant environmental effect as identified in the Final PEIR.

Specifically, and as further described herein, the Final PEIR for the proposed project identified potentially significant effects that could result from the project’s implementation. However, the City finds that the inclusion of certain mitigation measures as part of the project approval will reduce most, but not all, of those effects to less than significant levels. Those impacts that are not reduced to less than significant levels are identified and overridden due to specific project benefits described in the Statement of Overriding Considerations (Section 10).  10.0-ADOPTION OF STATEMENT OF OVERRIDING CONSIDERATIONS  7214/Kaiser Permanente Redlands Medical Center Page 10-1 Findings of Fact and Statement of Overriding Considerations January 2026

10.0 ADOPTION OF STATEMENT OF OVERRIDING CONSIDERATIONS Pursuant to Public Resources Code Section 21081(b) and CEQA Guidelines sections 15126.2, 15093(a) and (b), the City is required 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 of the project, including region-wide or statewide environmental benefits, outweigh the unavoidable adverse environmental effects, those effects may be considered “acceptable” (CEQA Guidelines, §15093 (a)).

CEQA requires the agency to support, in writing, the specific reasons for considering a project acceptable when significant impacts are not avoided or substantially lessened. Those reasons must be based on substantial evidence in the Final PEIR or elsewhere in the administrative record (CEQA Guidelines, §15093(b)).

Courts have upheld overriding considerations that were based on a variety of policy considerations including, but not limited to, new jobs, stronger tax base, and implementation of an agency’s economic development goals, growth management policies, redevelopment plans, the need for housing and employment, conformity to community plan, and provision of construction jobs. See Towards Responsibility in Planning v. City Council (1988) 200 Cal App. 3d 671; Dusek v. Redevelopment Agency (1985) 173 Cal App. 3d 1029; City of Poway v City of San Diego (1984) 155 Cal App. 3d 1037; Markley v. City Council (1982) 131 Cal App.3d 656.

Pursuant to State CEQA Guidelines § 15093, the City of Redlands, as Lead Agency, has reviewed and considered the information contained in the Draft and Final Program Environmental Impact Reports (collectively, “PEIR”) for the Kaiser Permanente Redlands Medical Center project, as well as the entire administrative record. In accordance with the requirements of CEQA and the CEQA Guidelines, the City finds and determines that:
(1) all significant environmental effects of the proposed Project have been substantially lessened where feasible;
(2) the proposed Project will result in certain significant adverse environmental effects that cannot be avoided or reduced to a less-than-significant level even with incorporation of all feasible mitigation measures; and
(3) there are no other feasible mitigation measures or feasible Project alternatives that will further mitigate, avoid, or reduce the remaining significant environmental effects to a lessthan-significant level.

As documented in the PEIR, the City finds that the project would result in the following significant and unavoidable environmental impacts, even after implementation of all feasible mitigation measures:
• Greenhouse Gas (GHG) Emissions (see PEIR Section 4.7) • Transportation — Vehicle Miles Traveled (VMT) (see PEIR Section 4.12) Even with mitigation (MM TRANS-1 through MM TRANS-4 and all applicable GHG reduction measures) no additional feasible mitigation or alternatives have been identified that would avoid or further reduce the significant and unavoidable impacts associated with GHG emissions and VMT  10.0-ADOPTION OF STATEMENT OF OVERRIDING CONSIDERATIONS  7214/Kaiser Permanente Redlands Medical Center Page 10-2 Findings of Fact and Statement of Overriding Considerations January 2026 while still achieving the project objectives. The Final PEIR provides detailed information regarding these impacts (see Section 7, Environmental Effects That Remain Significant And Unavoidable After Mitigation, of this document).

The City further finds that these remaining significant and unavoidable environmental effects are outweighed and are found to be acceptable due to specific overriding economic, legal, social, technological, or other considerable benefits based upon the facts set forth herein, the PEIR, and the record, including as follows:

1. The project is necessary to provide sufficient health care capacity for Kaiser Permanente members in the San Bernardino-Redlands region.
a. Specifically, the project will result in improved regional healthcare access and increase regional capacity for advanced inpatient and outpatient services for Kaiser Permanente members within the San Bernardino–Redlands service area. The project reduces travel distances and improves response times for urgent and specialty healthcare services. b. The project will also improve patient outcomes and operational efficiency. Co-location of medical services increases coordination of care, reduces delays in treatment, and enhances patient health outcomes over time. The project’s phased development approach facilitates healthcare service capacity expansion to keep pace with projected regional increases in Kaiser Permanente membership.

2. The project will incorporate numerous sustainability features such as vegetated swales, treebased infiltration, and inert bioswales; high-performance 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.
a. The project will promote long-term sustainability and resource efficiency via the incorporation of numerous sustainability features, including conservation and efficiency project design features (GHG-PDF-1 through GHG-PDF-9), high-performance building enclosure systems, external shading, energy efficient and carbon neutral building systems and equipment selections, solar panels, and water-efficient infrastructure, contributing to statewide and local climate and sustainability goals. New buildings will meet or exceed LEED Gold certification.
b. Further, the project design will enhance seismic safety and code compliance. The new facilities will incorporate a soils and geology project design feature (PDF-GEO-1) and comply with current seismic standards for hospitals and essential medical services, replacing reliance on older facilities.

3. The project will develop the project site in accordance with the Medical Facilities designation in Redlands Business Center Concept Plan No. 1.
a. Consistent with this plan, development of the project site will have economic and employment benefits. Construction and operation of the medical center would generate substantial local employment, provide long-term skilled medical and support jobs, and stimulate secondary economic growth in the region.
 10.0-ADOPTION OF STATEMENT OF OVERRIDING CONSIDERATIONS  7214/Kaiser Permanente Redlands Medical Center Page 10-3 Findings of Fact and Statement of Overriding Considerations January 2026

4. The project will phase development over 25 years to keep pace with projected increase in Kaiser Permanente membership in the facility’s service area over that period. a. The project will provide support for regional planning and smart growth. The project’s development consolidates high-quality medical services within an existing urbanized area, consistent with the City of Redlands General Plan, The East Valley Corridor Specific Plan, Redlands Business Center Concept Plan No. 1., and other City land use policies and infrastructure investment strategies designed to reduce sprawl and promote compact regional growth.

In accordance with State CEQA Guidelines §§ 15043 (Authority to Approve Projects Despite Significant Effects), 15091 (Findings), and 15093, (Statement of Overriding Considerations), and balancing the specific economic, legal, social, technological, and other considerable benefits associated with the project, the City finds that the project's remaining significant and unavoidable impacts are acceptable due to the factors described above. Therefore, the City of Redlands hereby adopts this Statement of Overriding Considerations as part of its approval of the Kaiser Permanente Redlands Medical Center project.
 ATTACHMENTS 

ATTACHMENT A

FINAL MITIGATION MONITORING AND REPORTING PROGRAM
(MMRP)
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-1 Response to Comments January 2026

4.0 FINAL MITIGATION MONITORING AND REPORTING PROGRAM
The Final Mitigation Monitoring and Reporting Program (MMRP) has been prepared in conformance with § 21081.6 of the Public Resources Code and § 15097 of the CEQA Guidelines, which requires all state and local agencies to establish monitoring or reporting programs whenever approval of a project relies upon a MND or an EIR. The MMRP ensures implementation of the measures being imposed to mitigate or avoid the significant adverse environmental impacts identified through the use of monitoring and reporting. Monitoring is generally an ongoing or periodic process of project oversight; reporting generally consists of a written compliance review that is presented to the decision-making body or authorized staff person.

It is the intent of the MMRP to: (1) provide a framework for document implementation of the required mitigation; (2) identify monitoring/reporting responsibility; (3) provide a record of the monitoring/reporting; and (4) ensure compliance with those mitigation measures (MMs) that are within the responsibility of the City and/or Applicant to implement.

This MMRP includes specific project design features (PDFs) and best management practices (BMPs) referenced in the PEIR that will be implemented with the project's construction and operation. The specific PDFs and BMPs are presented in Table 4.0-1 below.

The required MMs are presented in Table 4.0-2 below. Environmental topics for which mitigation is required are listed in Table 4.0-2 under their corresponding impact category. This table also lists impacts, mitigation measures adopted by the City of Redlands in connection with approval of the proposed project, level of significance after mitigation, responsible and monitoring parties, and the project phase in which the measures are to be implemented. ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-2 Response to Comments January 2026
Table 4.0-1
PROJECT DESIGN FEATURES (PDFs) AND BEST MANAGEMENT PRACTICES (BMPs) Issue Area Project Design Features (PDFs) and Best Management Practices (BMPs)

4.5 Geology and Soils
Threshold F:

Would the project
directly or indirectly
destroy a unique
paleontological
resource or site or
unique geologic
feature?
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 Investigation Report prepared for the Medical Office Building 2 (MOB 2) project at the Kaiser Redlands site located at 1301 California Street in Redlands.

Prepared by Twining, dated March 31, 2023; provided in Appendix D7 of this PEIR.

4.7 Greenhouse Gas Emissions
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. ❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-3 Response to Comments January 2026
Issue Area Project Design Features (PDFs) and Best Management Practices (BMPs) 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).

4.10 Noise
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?
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.
❖ SECTION 4.0 - FINAL MITIGATION MONITORING AND REPORTING PROGRAM ❖ 7214/Kaiser Permanente Redlands Medical Center PEIR Page 4-4 Response to Comments January 2026
Table 4.0-2

FINAL MITIGATION MONITORING AND REPORTING PROGRAM
Issue Area Mitigation Measures (MMs)
Level of
Significance
After
Mitigation
Responsible Party/
Monitoring Party
Implementation
Stage

4.2 Air Quality
Threshold A: