Mayor and City Council
October 15, 2025

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It is assumed that the offsite sewer system is adequate for the project site and that the existing water system has adequate capacity and pressure for the site. If additional offsite facilities are needed for the project and/or offsite utility plans are required, an additional scope and fee will be required.

Scope does not cover plan revisions based on unforeseeable project changes or agency changes outside of their standards.

Water Net Analysis
Consultant will prepare a water study for the project site as follows:
• Prepare a letter-report to summarize design criteria, hydraulic modeling, and recommendations for water system sizing for the project. Water system sizing will be performed in accordance with the requirements of City of San Bernardino Municipal Water Department (SBMWD). The written report will include graphics and appendices of computer modeling results supporting the recommended onsite water system configuration and offsite points of connection. This task includes coordination with SBMWD to obtain existing water system boundary conditions with which to complete the water hydraulic calculations. SBMWD fee to generate the boundary conditions is not included in our proposal and is assumed paid for the Client. • Attend project team meetings and meetings with SBMWD as required to complete the Scope of Services. Two meetings are included. • Address SBMWD review comments on the water study to obtain final approval.

Conceptual Layout of WQ, Detention, and Drainage
Consultant will prepare a conceptual layout for approach to Drainage, detention, and Stormwater Quality features. As a redevelopment project that is creating or replacing more than 5,000 square feet of impervious area, it is anticipated that a project-specific WQMP a nd post construction BMP(s) will be required. This will support project compliance with the requirements of the 2010 MS4 Permit for Santa Ana Region (Order No. R8 -2010-0036), the County of San Bernardino Technical Guidance Document for Water Quality Manage ment Plans (2013), and the San Bernardino County Hydrology Manual (dated August 1986). It is anticipated that the offsite frontage improvements will be treated onsite or via an offset of treated existing impervious area, as feasible.

Final Drainage Study
Consultant will prepare and submit to the City of San Bernardino one (1) drainage study to be used for the final engineering design of the storm water conveyance system and conveyance of flows through the project. Included are preparing the modified rational method hydrology for pre-project and post-project conditions (for up to 20 acres of tributary area), sizing pipes (utilizing normal depth), sizing inlet locations, identifying a riprap outlet location (where applicable), spread width analysis (where applicable), preparing the drainage study maps for pre-project and post-project conditions, and preparing the report. This scope assumes that

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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topographic information for the area tributary to the project will be available from the City and/or County of San Bernardino. The hydrologic analysis will analyze the 10-year and 100-year storm event in accordance with the San Bernardino County Hydrology Manual (dated August 1986). This scope assumes that there will be no proposed diversion of drainage area.

The Drainage Study will be submitted to the City of San Bernardino at 85% stage of design and then will be considered as final with the 100% submittal.

Final Detention Analysis
Flood control detention is anticipated to be required for the site as the planned receiving storm drain system consisting of “6 -WA-03” identified by the Comprehensive Storm Drain Plan (CSDP #6) dated August 31, 2001 is understood to not be planned for constructi on. Due to the anticipated magnitude of the net increase of imperious area on the site from the historic or existing condition, Consultant will prepare a flood control detention hydraulic analysis to provide a size for up to two (2) proposed detention facilities for up to two (2) points of interest. It is anticipated that only one (1) storm event (i.e. the 100 -year 1-hour storm event) will be analyzed for storage. If a detention analysis for additional storm events is requested, a separate scope of work will be prepared. This assumes that there will be no proposed diversion of drainage area requiring over-detention. The results of the detention analysis will be included as a section of the final drainage study.

Final WQMP
Consultant will prepare and submit to the City of San Bernardino, one (1) Final Water Quality Management Plan (WQMP) for the final engineering design of the project. As a redevelopment project that is creating or replacing more than 5,000 square feet of impervious area, it is anticipated that a project -specific WQMP and post construction BMP(s) will be required. The redevelopment of is anticipated to result in an increase of impervious area that is more than 50% of the previously existing impervious surfaces. Therefore, the requirement for water quality treatment are anticipated to apply for the entire development. The WQMP will be provided to address the requirements for permanent stormwater Best Management Practices (BMPs) throughout the site as a result of the project. It will be prepared in accordance with the County of San Bernardino Technical Guidance Document for Water Quality Management Plans (2013), based on requirements of the 2010 MS4 Permit for Santa Ana Region (Order No. R8 -2010-0036). The San Bernardino County Stormwater Program Water Quality Management Plan Template, 2012 version, will be utilized.

This task includes calculating on-site storm water quality volumes in order to design structural BMPs, selecting and sizing appropriate site design and storm water structural BMP(s) based on the site layout, and providing a WQMP exhibit showing the project site and location of permanent BMP(s). It is anticipated that the offsite frontage improvements will be treated onsite or via an offset of treated existing impervious area, as feasible. The report will include an Operation and Maintenance Plan (OMP) for the permanent BMPs in text format, and one will also be prepared in tabular format for inclusion on the plans, as applicable. This scope assumes up

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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to two (2) structural BMPs on the project site. The BMP(s) are anticipated to function via infiltration. It is anticipated that coordination with geotechnical engineer will be required to address the feasibility of proposed BMPs. The project -specific geotechnical engineering service will be engaged separately and are not included as part of this scope and fee., but site specific infiltration testing will be required by others to confirm this approach.

The Final WQMP will be submitted to the City of San Bernardino at the 85% stage of design and then will be considered as final with the 100% submittal.

Final WR Reports Processing
Includes up to thirty-six (36) hours of an engineer’s time in support of meetings, coordination, and processing the WR technical reports, including drainage study and final WQMP with the City of San Bernardino and design team. This assumes addressing up to two rounds of plan review co mments and it is assumed that comments are minor in nature.

Construction Storm Water Pollution Prevention Plan (SWPPP) Consultant will prepare a SWPPP based on the requirements of the State Water Resources Control Board (SWRCB) National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities Order WQ 2022-0057-DWQ NPDES No. CAS000002 (adopted September 8, 2022, effective September 1, 2023). The SWPPP will be prepared utilizing the RICK SWPPP template. The scope and fee for the SWPPP includes two major tasks. The first task will be conducted to determine the Risk Level (either Risk Level 1, 2 or 3) for the project. The next task will be to prepare a SWPPP for the specific Risk Level determined by the Risk Determination Analysis. RICK will be responsible to conduct a Risk Determination Analysis to determine the project’s Risk Level based on one set of construction start and end dates. RICK will prepare a SWPPP based on the project’s Risk Level determined in the Risk Determination Analysis. RICK is not responsible for paying filing fees for coverage under the CGP and any future annual fees.

This task will include the preparation of a Notice of Intent (NOI) on the Storm Water Multi Application Report Tracking System (SMARTS) database. The Discharger must designate RICK as a Data Entry Person to prepare the NOI. The Discharger/LRP must electronically certify and submit the NOI on SMARTS.

RICK will act as the initial Qualified SWPPP Developer (QSD) for the preparation of the SWPPP, however the Discharger must hire a QSD and a Qualified SWPPP Practitioner (QSP) for implementation of the SWPPP throughout the life of the project. It's assumed the SWPPP will be prepared and submitted with the 100% Submittal, and again with the Final Submittal if there are comments received from the City of San Bernardino.

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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Plan Processing
Consultant will process the engineering plans through the City of San Bernardino Public Works for plan review. It is assumed up to three rounds of review only.

Consultant will coordinate submittals with Public Works, setup meetings to discuss the plan check comments, if needed, prepare plan check comment response letters, and address plan check comments. Scope does not cover plan revisions based on unforeseeable project changes or agency changes outside of their standards.

The actual time requirement is unknown. A budget of twenty-four (24) hours is assumed. If the time exceeds this assumption, an additional scope and fee will be required.

Meetings, Management, and Coordination
Consultant will attend meetings and coordinate with client, client’s other consultants and agencies during the final engineering phase. Scope includes project management time. Actual time constraint is unknown. A budget of forty (40) hours has been assumed for this task.

Specifications and Estimate
Consultant will prepare and provide technical specifications to the City of San Bernardino at 85% and final submittal following the Standard Specifications for Public Works Construction (“Greenbook”). Consultant will also provide an opinion of probable cost and bid schedule based on the signed improvement plans. Scope is only for specifications for the improvement plans covered in th is proposal. Any additional scope to plans may require additional scope for specifications.

Direct Expenses
Reimbursable expenses include copying, printing, report binding, delivery, mailing, and mileage expenses incurred for the items described within the scope of work of this proposal. These expenses will be on a time and materials basis for a not -to- exceed amount below.

Landscape Architecture Services
Landscape Concept Plans
Consultant will prepare two (2) Landscape Concept Plans based on City of San Bernardino’s vision and project needs. The intent is for the landscape to visually and physically integrate with the proposed buildings and provide outdoor spaces to support homeless service s, as well as to create a safe, healthy and welcoming environment.

Concept Plans will provide a general layout of pedestrian paths and access points.

The concept plans will show gathering areas, quiet spaces, community garden areas, a dog run, and courtyards to support group activities. Site elements such as

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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shade structures and general layout of fences and walls, will be incorporated into the conceptual design to provide shelter, privacy and any specific site needs.

Concept Plans will identify plant material, shrubs, and groundcovers. Preliminary plant selection will focus on appropriate drought -tolerant species that require minimum maintenance.

The Concept Plans will be initially developed through sketches, allowing for a thoughtful representation of the design. Once the preferred alternative is identified the Construction Documents will be prepared.

Landscape Construction Documents
Based on the preferred Landscape Concept Plan and feedback from the City of San Bernardino, RICK will prepare Construction Documents for hardscape, planting and irrigation for the Hope Campus Center.

A detailed construction layout plan will be prepared for all exterior areas at the SB Homeless Center, clearly identifying key elements such as pedestrian paths, fences, and gathering areas. Construction details will be provided to clearly identify design intent and how landscape improvements are integrated with one another.

An irrigation plan will be prepared and will diagrammatically illustrate landscape irrigation piping, valves, control equipment, irrigation heads, and related irrigation equipment. The plans will specifically call out pipe and equipment sizing and types and will include the necessary details to install the system. RICK will coordinate with the civil engineer to locate irrigation connections, sleeving, saw cutting and other irrigation improvements into the overall irrigation system. Irrigation specifications will also be provided.

A planting plan will be prepared to graphically locate and identify trees, shrubs, and groundcover plant materials, including specific quantities, sizes, and varieties, and include the necessary details and legends for installation. RICK will utilize trees , shrubs and groundcovers that are drought tolerant and regionally appropriate landscape materials. Planting specifications will also be provided.

Prior to the submittal, RICK will conduct an "in-house" interdisciplinary coordination check, cross-reference check, dimension check, terminology and spelling check, and technical check of the construction documents. RICK will be responsible for preparing the Model Water Efficient Landscape Ordinance (MWELO) water use calculations and developing a detailed watering schedule that complies with both City and State standards.

RICK will submit the Construction Documents for review and submittal to City of San Bernardino. RICK assumes two (2) review cycles for the Construction Documents.

Offsite Landscape Construction Documents
Consultant will develop Construction Documents for the off -site landscape improvements along 6th Street in the City of San Bernardino as part of the

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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development for the Navigation Center Homeless Shelter. This task will include the preparation of planting and irrigation plans and associated construction details.

Planting plans will graphically identify and locate all proposed trees, shrubs, and groundcover, and will include specific quantities, sizes, varieties, installation legends, and notes. Plant materials will be drought -tolerant and/or native species, selected for their suitability to the site conditions and City standards. Coordination with the civil engineer will address any potential stormwater management strategies.

Irrigation plans will diagrammatically illustrate the layout of irrigation components, including piping, valves, irrigation heads, and control equipment. Plans will call out specific pipe and equipment sizes/types and include installation details.

Coordination will be conducted with the civil engineer regarding Point of Connection (POC), sleeves, saw cuts, and related infrastructure.

RICK will prepare the Model Water Efficient Landscape Ordinance (MWELO) water use calculations specific to the 6th Street improvements. A detailed watering schedule will be developed in compliance with local and state standards. Before final submittal, all documents will undergo a thorough in -house quality control review including coordination, cross-referencing, and technical accuracy.

RICK will submit the Construction Documents for review and submittal to City of San Bernardino. RICK assumes two (2) review cycles for the Construction Documents.

ASSUMPTIONS AND EXCLUSIONS

1. The project will be awarded as a single prime contract for construction. Phased design and/or issue of early documents are not required.

2. The City will distribute bidding documents and prepare and administer the contract, including front end specifications, for construction.

3. Plans will be submitted electronically to the City.

4. The city’s contracted representative will coordinate and submit deliverables for the processing and approvals of applicable construction permits.

5. Agency review is limited to City of San Bernardino Public Works. Changes to the plans because of reviews by agencies not listed above will be prepared under a separate agreement.

6. All Services not listed in scope of services above are excluded.

7. Additional professional services can be provided under separate authorization.

8. Assumes Geotechnical Report to be provided by others.

9. Assumes the client shall provide payments for all agency fees.

10. Assumes site lighting is to be designed by others.

11. Assumes structural engineering to be provided by others.

12. Assumes construction administration is excluded from this scope of work.

COMPENSATION

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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We propose to provide the above-described services for a fixed fee of $200,000 broken down as follows:

SERVICES NOT INCLUDED
The following items may be required but are not included in the scope of work outlined above.

Additional authorization will be required for these services.

A. Changes in scope of design directed and authorized by Client, in writing, after the start of working drawings. In this case, the amount of extra work shall be that required to bring the revised work to the same stage of completion as the original work, at the time of the change order. In the event the Client desires any changes to the above scope of work, the terms and conditions indicated in Sections III and IV are subject to revision.

B. Work of a general or promotional nature not connected with the actual design, approval, or construction of the project.

ENGINEERING SERVICES FEE
A. Research $3,000
B. Boundary Survey and Analysis $11,000
C. Existing Topography Check $5,200
D. Supplemental Topography (As Needed) $4,300
E. Final Site Layout $10,000
F. Precise Grading Plan $25,400
G. 6th Ave. Street Improvement Plans $6,500
H. Onsite Utility Plan $20,000
I. Water Net Analysis $8,000
J. Concept Layout of WQ, Detention, & Drainage $4,000
K. Final Drainage Study $12,000
L. Final Detention Analysis $5,000
M. Final WQMP $9,500
N. Final WR Report Processing $7,200
O. SWPPP $7,000
P. Plan Processing $5,800
Q. Meetings, Management, and Coordination $9,600
R. Specifications and Estimate $12,000
S. Direct Expenses $2,000

LANDSCAPE ARCHITECTURE SERVICES FEE
T. Landscape Concept Plans $8,000
U. Landscape Construction Documents $17,000
V. Offsite Landscape Construction Documents $7,500
TOTAL FIXED FEE $200,000

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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C. Design and approval of a water or sewer net analysis, booster stations, pressure- reducing stations, sewer pump stations, reclaimed water systems or other utility systems, and the legal descriptions or plat preparations thereof.

D. Administration, processing, or negotiations to obtain approvals and/or signatures from third parties for such items as Letters of Permission, easements, access roads, driveways, etc.

E. Aerial Topography
F. Traffic Control Plans
G. Revisions/relocations of any existing utilities
H. Revisions/relocation to existing street improvements I. Traffic Analysis
J. 3-D grading model
K. HCOC/HMP analysis – This should not be required as the project is not anticipated to be considered a Priority Project.

L. Geotechnical Investigation
M. Critical Course Sediment Yield Analysis
N. Alternative Compliance
O. FEMA – The project improvements will be outside of the FEMA floodplain/floodway limits; therefore, any submittals/processing thru FEMA should not be applicable.

P. Environmental work of any nature
Q. LOMR/CLOMR
R. Any surveying or mapping tasks other than those noted above S. Easements
T. Construction staking
U. Construction Administration
V. Processing with Caltrans, Department of Fish and Game, Coastal Commission or the Corps of Engineers
W. Preparation of bid packages
X. Construction observation services
Y. Storm water collection and analysis services
Z. As-built measurements
AA. Dry utility coordination/design
BB. Existing utility study
CC. Structural Calculations
DD. Any other services performed at the direction of the Client, which are not defined in the above-listed services, shall be in addition to those set forth in Item III of this agreement.

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Boules Ghaly-City of San Bernardino
Navigation Center Task Order Number 004
July 3, 2025; Revised September 4, 2025

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We will begin our services following acceptance of this task order for engineering services.

Please provide the appropriate City of San Bernardino contract for execution.

See next page for signatures.

Sincerely,

RICK ENGINEERING COMPANY

Richard O’Neill, R.C.E. No. 63285, LEED AP, QSD
Associate Principal

City of San Bernardino Public Works
Accepted this day of , 20 .

By:

Name:

Title:

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Attachment 2
Navigation Center Project Site
400 ft
N➤➤
N

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DISCUSSION
City of San Bernardino
Request for Council Action
Date: October 15, 2025
To: Honorable Mayor and City Council Members
From: Eric Levitt, City Manager
Department: City Manager's Office
Subject: Approve a City Clerk Employment Agreement (All Wards) Recommendation:

It is recommended that the Mayor and City Council of the City of San Bernardino, California:

1. Approve a City Clerk Employment Agreement on behalf of the Mayor and City Council; and

2. Authorize the Mayor to execute the City Clerk Employment Agreement on behalf of the Council.

Executive Summary
The City of San Bernardino is seeking to appoint Telicia Lopez to the position of City Clerk, a vital role responsible for maintaining official records, managing public meetings, overseeing elections, and ensuring transparency in municipal operations.

Telicia Lopez has been selected as the recommended candidate based on her extensive experience in municipal administration, knowledge of public records law, and demonstrated leadership in civic engagement.

Background
Section 400 of the City Charter of the City of San Bernardino states that the Mayor and City Council shall appoint a City Clerk and set the City Clerk’s compensation, as provided in section 304(b) of the Charter which requires five affirmative votes of the Mayor and members of the Council.

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Discussion
The Mayor and City Council provided direction to negotiate an employment agreement upon the terms and conditions summarized below and set forth in the attachment to this report.

The agreement includes the following terms:

Salary terms: Commencing on the effective date, the Employee's annual base salary will be $161,000.00. This salary is scheduled to increase to $169,000.00 ($14,083.33 per month) beginning January 5, 2026. Following that, on August 4, 2026, and each year thereafter, the Employee's annual salary will be automatically increased according to the Consumer Price Index (CPI), with a maximum increase of three percent (3%).

Health Insurance: City Clerk will receive a City contribution in accordance with the Executive Compensation and Benefits Plan Resolution.

Vehicle Allowance: City Clerk shall receive $725.00 per pay period for use of her personal vehicle for City business.

Paid Leave: Vacation, Sick, Administrative and other: City Clerk shall receive leave and accrue in accordance with the Agreement and the Executive Compensation and Benefits Plan Resolution.

At-Will Employee: City Clerk shall serve at the will and pleasure of the Mayor and City Council. Nothing in the Employment Agreement shall prevent, limit or otherwise interfere with the right of the City Council to suspend from duty, remove from office or otherwise terminate the services of Employee at any time, at the sole discretion of the City Council.

Severance: City Clerk shall be entitled to and receive upon termination a severance payment equivalent to six (6) month’s base salary plus benefits in effect on her termination date.

Performance Evaluation: The City Council shall review City Clerk’s job performance at least once annually. City Clerk shall remind the City Council of its obligations under this Section each year and shall work with the City Council in finding an appropriate time to place his or her annual evaluation on the agenda. The City Council may also review City Clerk’s performance at other intervals as it deems appropriate. In connection with review of City Clerk’s job performance, City shall utilize Resolution No. 94-392 and shall consider a step increase of Employee’s Base Annual Salary. 2021-2025 Strategic Targets and Goals
The approval of a City Clerk Employment Agreement aligns with Strategic Goal No. 2a: Focused Aligned Leadership & Unified Community – Build a culture that attracts, retains, and motives the highest quality talent.

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Fiscal Impact
Due to savings accrued through the City Clerk receiving Acting pay and the fact that the Deputy City Clerk position remained vacant, there will be no Fiscal Impact to the budget with the current contract. The HR Department performed an informal market study on comparisons with other City Clerk positions in the region.

Conclusion
It is recommended that the Mayor and City Council of the City of San Bernardino, California:

1. Approve a City Clerk Employment Agreement on behalf of the Mayor and City Council; and

2. Authorize the Mayor to execute the City Clerk Employment Agreement on behalf of the Council.

Attachments
Attachment 1 City Clerk’s Employment Agreement
Attachment 2 Resolution No. 2022-059 Executive Compensation And Benefits
Attachment 3 Resolution No. 94-392 Establishing Compensation Attachment 4 Resolution No. 2024-034 Auto Allowance
Ward:

All Wards
Synopsis of Previous Council Actions:

N/A
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CITY CLERK EMPLOYMENT AGREEMENT
This Employment Agreement
(“Agreement”) is entered into as of the 13 th day
of October, 2025 (the “Effective Date”), between the City of San Bernardino, a California charter city (“City”), and Telicia Lopez (“Employee”). The City and Employee are sometimes
referred to in this Agreement as “Party” and collectively as “Parties.”

RECITALS
WHEREAS, it is the desire of the City Council to retain the services of Employee as City
Clerk, and
WHEREAS, it is the desire of the City Council to provide certain benefits, establish certain conditions of employment and to set certain working conditions of the City Clerk
.

NOW, THEREFORE,
the above named Parties hereby mutually agree
and promise as follows:

1. Duties, A
cceptance of Appointment, Hours of Work.

1.1 Appointment and Scope of Services.

Employee has been appointed as City Clerk by the City Council, and shall perform the functions of City Clerk, a position involving highly -specialized and critically-needed skills set forth in the attached job description, in the San Bernardino City Charter , and as provided by law. Such employment is “at will,” subject to the terms of this Agreement, and Employee shall perform said duties at the pleasure of and under the direct supervision of the City Council.

1.2 Acceptance of Appointment.

Employee hereby accepts the appointment as City Clerk of the City of San Bernardino subject to all terms and conditions set forth in this Agreement.

1.3 Hours of Work.

Employee is expected to devote necessary time, within and outside normal business hours, to the business of the City as an exempt employee under the Fair Labor Standards Act.

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2. Ter
m.

This Agreement shall be deemed effective for an initial term beginning on October 13
, 2025 (“Effective Date”) and shall continue until terminated in accordance wi
th
Section 10 of this Agreement.

3. Compe
nsation.

3.1 Salary
(a) City agrees to pay Employee as compensation for services rendered pursuant to this Agreement, an annual base salary, commencing on the Effective Date, in the amount of $161,000.00 D ollars ($13,416.66 per month ), payable in installment payments in the same manner and at the same times as other City employees.

Commencing on January 15, 2026, Employee’s annual base salary shall increase to $169,000.00 Dollars ($14,083.33 per month).
(b) Annual Salary Adjustments . Commencing August 4, 2026 and each year thereafter, said Annual Base Salary shall be automatically increased by the percentage change to the Consumer Price Index for All Urban Consumers (CPI – U) for the Riverside-SanBernardino-Ontario area for the preceding 12 months ending in July (subject to a (three percent) 3% maximum cap) (“CPI Increase”). (c) Annual salary adjustments shall be memorialized by a written amendment to this Agreement. An automatic increase adjustment shall be in writing as an amendment to this Agreement and shall be signed by the Finance Director, the Human Resources Director and the City Attorney. Any salary adjustment that exceeds the amount provided for in Section 3(b) above shall be in the form of a written amendment approved by a vote of five members of the Mayor and City Council and announced at a properly noticed public meeting of the Mayor and City Council. (d) Reduction in Salary or Benefits. In the event the City implements cost - saving measures, such as work furloughs, salary reductions, changes to health or welfare benefits and allowances (a s further described in Sections 3.2, 3.3, and 6), or any other changes to the monetary terms of the Executive Group as provided in the applicable benefit summary, Employee will receive the same downward adjustment or adhere to the change in terms as are applicable to the Executive Group. In the event that such cost -saving measures are subsequently eliminated (i.e. former salary or benefit levels are restored) for the Executive Group, Employee will receive the same restoration of salary or benefits as the Executive Group.

3.2 Benefits
Employee shall be eligible for and entitled to those benefits listed in RESOLUTION NO. 2022 -59 (attached hereto and incorporated herein as Exhibit A )

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availa
ble and applicable to Employee’s class of employment, unless this Agreement states terms and benefits that are (1) of the type not provided for in said resolution, or (2) the benefits as described in this Agreement are more expansive than said resolution.

It is the intention of City and Employee that any resolution adopted by the City to supersede the aforementioned resolution become applicable to Employee to the extent the superseding resolution increases various benefits for Employee.

In addition, and except as otherwise specified herein, Employee shall receive all such other benefits and compensation that are generally applicable to City Management/Confidential employees, including but not limited to Executive Leave as described in Section 11 of Resolution NO. 2022 -59. Leave accruals shall be based on years of service to the city.

3.3 Mobile Phone
The City shall provide Employee with a mobile phone for use in City business. Employee understands that all data and information stored on the phone, including but not limited to records of calls made and received, voice mail messages, and text messages may be considered public records under the California Public Records Act.

4. Performance Evaluation .

The City Council shall review Employee’s job performance at least once annually. Employee shall remind the City Council of its obligations under this Section each year and shall work with the City Council in finding an appropriate time to place his or her annual evaluation on the agenda. The City Council may also review Employee’s performance at other intervals as it deems appropriate. In connection with review of Employee’s job performance, City shall utilize RESOLUTION NO. 94 -392 (attached hereto and incorporated herein as Exhibit B ) and shall consider a step increase of Employee’s Base Annual Salary.

5. Bonds.

City shall bear the full cost of any fidelity or other bonds required of Employee under any law or policy.

6. Vehicle Allowance.

The City agrees to pay to the Employee, during the term of this Agreement and in addition to other salary and benefits herein provided, a monthly vehicle allowance in accordance with RESOLUTION NO. 2024 -034 (attached hereto and incorporated herein as Exhibit C), to be used to purchase, lease, or own, operate and maintain a vehicle for use by the Employee when conducting City business.

Employee shall be responsible for paying for liability, property damage, and

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compr
ehensive insurance coverage upon such vehicle and shall further be responsible for all expenses attendant to the purchase, operation, maintenance, repair, and regular replacement of said vehicle. It is understood that the vehicle allowance may be considered taxable income subject to withholdings.

Employee is not eligible for and shall not be separately reimbursed for mileage driven in her personal vehicle; provided, however that the Employee may seek reimbursement for mileage driven in his personal vehicle in cases where the mileage exceeds 150 miles and the reimbursement costs are lower than the published airfare for the same travel.

7. Business Expenses

7.1 General Expenses
City recognizes that Employee may incur expenses of a non -personal, job- related nature that are reasonably necessary to Employee’s service to the City. The City agrees to either pay such expenses in advance or to reimburse the expenses, so long as the expenses are incurred and submitted in accordance with the City ’s normal expenditure reimbursement procedures. To be eligible for reimbursement, all expenses must be supported by documentation meeting the City’s normal requirements and must be submitted within time limits established by the City.

7.2 Work- Related Employee Events
City shall grant Employee a reimbursement allowance of up to Fifty Dollars ($50.00) per month to cover work-related employee events.

8. Abuse of Office or Position.

Pursuant to Government Code Sections 53243, 53243.1 and 53243.2, if Employee is convicted of a crime involving an abuse of his or her office or position, all of the following shall apply: (1) if Employee is provided with administrative leave pay pending an investigation, Employee shall be required to fully reimburse City such amounts paid; (2) if the City pays for the criminal legal defense of Employee (which would be in its sole discretion, as it is generally not obligated to pay for a criminal defense), Employee shall be required to fully reimburse the City such amounts paid; and (3) if this Agreement is terminated, any s everance pay and s everance benefits related to the termination that Employee may receive from the City shall be fully reimbursed to City or void if not yet paid. For purposes of this Section, abuse of office or position means either: (1) an abuse of public authority, including waste, fraud, and violation of the law under color of authority; or (2) a crime against public justice, including, but not limited to, a crime described in Title 7 (commencing with Section 92) of Part 1 of the Penal Code.

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9. Notice
s.

A
ny notice required or permitted by this Agreement shall be in writing and shall be personally served upon the other Party, or sent by United States Postal Service, postage prepaid and addressed to the appropriate Party as follow:

If to Ci
ty: City of San Bernardino
Attn: Eric Levitt, City Manager
290 North “D” Street
San Bernardino, CA 92401
If to Emplo
yee: Telicia Lopez, City Clerk
Personal Address on File
Notice shal
l be deemed given as of the date of personal service or upon the date of deposit in the course of transmission with the United States Postal Service.

10. Termination.

10.1 Severance
Unless E mployee is terminated for cause, subject to the limitations set forth in Government Code section 53260, and upon delivery to City of an executed separation agreement and release of any and all claims against the City and all officials and employees in a form acceptable to City within 30 days following her termination, Employee shall be entitled to and receive upon termination a severance payment equivalent to six (6) month’s base salary plus benefits in effect on her termination date.

10.2 At-Will Employee
Employee shall serve at the will and pleasure of the City Council.

Nothing in this Agreement shall prevent, limit or otherwise interfere with the right of the City Council to suspend from duty, remove from office or otherwise terminate the services of Employee at any time, at the sole discretion of the City Council . This Agreement may be terminated as follows.

10.3 Termination – Mayor and Council Vote
In accordance with Section 505 of Article V of the San Bernardino City Charter, the Mayor and City Council may remove the Employee with or without cause by motion adopted by five affirmative votes of the Mayor and members of the City Council.

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10.4 Res
ignation
Employee may voluntarily resign their position as City Clerk, after giving the City at least thirty (30) days written notice prior to the effective date of such resignation, unless such notice is waived in whole or part by the Mayor and City Council.

10.5 Disability.

In the event the Employee is permanently disabled or is otherwise unable to perform his or her duties because of physical or mental incapacity for a period of six (6) consecutive months, the City may terminate the Employee’s employment and this Agreement. Notwithstanding the above, nothing in this subsection shall be interpreted to waive any obligation the City may have to provide Employee with a reasonable accommodation or to engage in an interactive process with Employee to determine whether a reasonable accommodation is available.

11. General Provisions.

11.1 This writing constitutes th e entire agreement between the P arties with respect to the subject matter hereof, and supersedes all prior oral or written representations or written agreements on the subject matter hereof, which may have been entered into between the parties. No modification or revision to this Agreement shall be of any force or effect, unless the same is in writing and executed by the Parties hereto.

11.2 Each Party agrees and acknowledges that no representations, inducements, promises, or agreements, orally or otherwise, have been made by any party, or anyone acting on behalf of any Party, which are not embodied herein and that any agreement, statement, or promise not contained in this Agreement shall not be valid or binding on either Party.

11.3 If any provision, or portion thereof, contained in the Agreement is held unconstitutional, invalid or unenforceable, the remainder of this Agreement, or portion thereof, shall be deemed severable, shall not be affected and shall remain in full force and effect.

11.4 This Agreement shall be governed by and construed in accordance with the law of the State of California. Venue shall be in San Bernardino County.

11.5 This Agreement shall be construed as a whole, according to its fair meaning, and not in favor or against any Party. By way of example and not in limitation, this Agreement shall no t be construed in favor of the Party receiving a benefit or against the Party responsible for any particular language in this Agreement.

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11.6 Emplo
yee acknowledges that he or s he has had an opportunity to consult legal counsel in regard to this Agreement, that he or s he has read and understands this Agreement, that he or s he is fully aware of its legal effect, and that he or she has entered into it freely and voluntarily and based on his or her own judgment and not on any representations or promises other than those contained in this Agreement.

11.7 In any dispute arising out of this Agreement, the prevailing P arty shall recover its reasonable attorneys’ fees and costs.

IN WITNESS WHEREOF, the Parties have executed this Employment Agreement on the 15th day of October, 2025.

EMPLOYEE

Telicia Lopez

CITY

Eric Levitt
City manager

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EXHI
BIT A
RESOLUTION NO. 2022-59
[**INSERT**]

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EXHI
BIT B
RESOLUTION NO. 94-392
[**INSERT**]

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EXHI
BIT C
RESOLUTION NO. 2024-034
[**INSERT**]

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RESO
LUTION NO. 2022-59

RESOLUTION OF THE MAYOR AND CITY COUNCIL OF

THE CITY OF SAN BERNARDINO, CALIFORNIA,

APPROVING THE EXECUTIVE COMPENSATION AND

BENEFITS PLAN

WHEREAS, on February 9, 2022, the Board of the San Bernardino Confidential and Management Association (SBCMA) met and conferred with the City and reached an agreement to separate the Executive Team from the SBCMA.

WHEREAS, it is necessary to codify the compensation and benefits provided to the City’s Executives an unrepresented group of employees of the City of San Bernardino; and WHEREAS, services provided by Executives shall be subject to the terms and conditions as set forth herein.

BE IT RESOLVED BY THE MAYOR AND CITY COUNCIL OF THE CITY OF SAN BERNARDINO AS FOLLOWS:

SECTION 1 . The City Council of the City of San Bernardino (City) hereby adopts a compensation and benefits plan for Executive employees an unrepresented at -will group as follows:

1. Terms. The term of this Resolution extends through June 30, 2025.

2. Confidential Management Association Compensation and Benefits Plan. Resolution No. 2021-269 is hereby amended to exclude the Executive positions noted below from the SBCMA Compensation and Benefits Plan.

3. At-will/Unclassified (U). In accordance with Chapter 2.040.030 of the San Bernardino Municipal Code, Executive employees are not included in the classified service of the City and shall serve at the will and pleasure of the City Manager . They may be appointed, controlled, ordered and directed by the City Manager in any manner which is in compliance with applicable law, and may be disciplined or removed from city employment by the City Manager without proof of cause or other justification and without the right of appeal.

4. Classifications
The following classifications are recognized as at-will unclassified (U) Executives:
• Assistant City Manager (U)
• Chief of Police (U)
• Director of Animal Services (U)
• Director of Community & Economic Development (U)

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• Di
rector of Finance (U)
• Director of Human Resources (U)
• Director of Information Technology (U)
• Director of Parks, Recreation, and Community Services (U) • Director of Public Works (U)

5. Compensation. At present Executives are compensated in accordance with the City-wide Salary Schedule adopted by Resolution No. 2022-30. Effective the first pay period following July 1, 2022, July 1, 2023, and July 1, 2024, the salary ranges for Executives shall be increased by two and seven tenths percent (2.7%) to reflect a cost -of-living adjustment (COLA). All salary ranges for Executives shall be amended by the Mayor and City Council in accordance with this provision.

6. Public Safety Executive. The City Manager is authorized to enter into an employment agreement with the Chief of Police with terms that differ from other Executives to provide for up to the following: 1) A compensation range for the Chief of Police salary with a maximum annual compensation step of three hundred twenty- five thousand dollars ($325,000.00); 2) The maximum compensation step shall be adjusted to reflect the cost-of- living adjustments payable in the same manner and time as the other Executive Management employees as noted in the Compensation section above ; 3) An incentive of eight hundred dollars ($800) per month for possessing of a POST Executive Certificate and an annual uniform allowance of nine hundred fifty dollars ($950) at the completion of each full-service year; 4) A city-owned vehicle and fuel; 5) In lieu of the Administrative Leave provided to other Executives under the Administrative Leave section below, the Chief of Police shall receive one hundred (100) hours of Administrative Leave advanced at the time of hire, which has no cash value and shall not be paid out at any time ; 6) The cash value of
nine (9) months of base salary with one (1) additional month for each full year of service beyond three years, not to exceed twelve (12) months (this severance payment shall be subject to all the restrictions set forth in Section 20 of this Resolution) ; and 7) Chief of Police may not be terminated without cause within ninety (90) days following the certification of a City election in which a new Mayor or any new Council Member is elected or within ninety (90) days following the appointment of a new City Manager (whether acting, interim, or permanent).

7. Higher Acting Pay. An Executive may temporarily perform in the capacity of City Manager, Assistant City Manager, or assume the role of another Executive position while performing the duties of their current position. An employee temporarily acting in a higher classification during periods of absence of the incumbent or during a vacancy in the position for more than ten (10) consecutive days shall receive the bottom step of the higher classification or 5% above their current base pay, whichever is greater. In no event shall the base pay salary exceed the top step of the classification in which the Executive is acting.

This does not apply to a situation in which there is no higher-level position for which funds have been appropriated.

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8. Insurance (Medical, Dental & Vision) . Effective the first pay period of the following month upon hire, the City will contribute: a) $1,125.00 per month towards the purchase of health care benefits for Employee Only; b) $1,289.00 per month towards the purchase of health care benefits for Employee Plus One Dependent; and c) $ 1,724.00 per month towards the purchase of health care benefits for Employee Plus Two or More Dependents.

For the term of this agreement only, health contributions shall be benchmarked at the Kaiser rates.

The City’s contributions for health care benefits are available to Executive s for the purchase of medical, dental, vision, life and accidental death and dismemberments through City selected plans. The amount of the City’s contributions is based upon the “m edical” enrollment category, i.e., Employee Only, Employee Plus One or Employee Plus Two or More Dependents. For example, if an employee elects “employee only” medical coverage, then the “employee only” allowance will be contributed. Any City contributions not used by an employee for health benefits will revert to the City; however, if an employee selects a medical plan (Employee Only, Employee Plus One or Employee Plus Two or More Dependents), any additional contributions beyond the amounts identified above, may be contributed toward additional life insurance or a City- provided deferred compensation plan.

Health Insurance Waiver Stipend: Any employee who chooses not to enroll in any health care plan offered by the City, must provide evidence of group h ealth care insurance coverage and execute a Waiver of Benefits and Release Agreement, releasing the City from any responsibility or liability to provide health care insurance coverage on an annual basis.

Employees participating in this option are required to waive all medical, dental and vision coverage provided by the City. Employees who do not enroll in a City health care plan during open enrollment for calendar year 2021 and execute the forms above, shall receive a stipend of $3,500.00 on the first pay period in December. Employees who do not enroll in a City health care plan during open enrollment for calendar year 2022 and execute the forms above, shall receive a stipend of $4,000.00 on the first pay period in December 2022.

Employees participating in this option are required to waive all medical, dental and vision coverage provided by the City.

9. Life and Accidental Death & Dismemberment (AD&D) Insurance. The City shall provide Term Life and Accidental Death & Dismemberment Insurance of one time the employees’ annual salary.

10. Holidays. Executives shall be entitled to twelve (12) City -designated holidays, the equivalent of one hundred twenty- six (126) holiday hours each year for those E xecutives working a 5/8 or 9/80 work schedule and one hundred thirty-eight (138) holiday hours each year for those Executives working on a 4/10 work schedule. On January 1 st of each year that this Resolution is in effect, all Executives will receive an additional eighteen (18) hours of holiday leave (“Floating Holidays”). Executives working a 5/8 or 9/80 work schedule may only carry over 126 hours per fiscal year; Executives working a 4/10 work schedule

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may onl
y carry over 138 hours per fiscal year. On June 30 th any holiday bank hours exceeding 126 or 138 hours will be eligible for sellback. On or about November 30 th of each calendar year, the City Manager shall determine, and the Human Resources Director will distribute, th e schedule of specific days that the twelve designated holidays will be observed for the next calendar year. At the time of separation from employment, Executives will receive a payout of 100% for all accrued but unused post -petition holiday pay.

11. Jury Duty. The City will pay for all working days in a calendar year of a covered employee who is required to serve on jury duty.

12. Administrative Leave. Upon hire and on July 1st of each fiscal year that this Resolution is in effect, Executive employees shall receive eighty (80) hours of Administrative Leave.

On June 30th of each year, any unused Administrative Leave up to twenty (20) hours will be automatically carried over to the following fiscal year. Additional administrative leave may be granted at any time during a fiscal year, up to a maximum of twenty (20) hours, with a request in writing, including justification, recommended by the City Manager. Any Administrative Leave has no cash value and shall not be paid out at any time.

13. Sick and Vacation Hours Upon Hire . To attract highly qualified and experienced level staff, Executives hired on or after the adoption of this resolution, shall receive upon commencement of employment one hundred twenty (120) hours of Vacation and eighty (80) hours of Sick Leave.

14. Vacation Leave.
a. Executives hired before the adoption of this resolution shall accrue eighty (80) hours of paid vacation upon the first day of the second year of continuous full -time employment with the City of San Bernardino. Thereafter, vacation shall accrue each pay period prorated according to the number of days or shifts per year in the following chart:

Completed Years of
Continuous Service
Rate of Accrual
Per Pay Period
Equivalent Hours
Per Year
1 Year** 3.0769 hours 80 hours
5 Years 4.6153hours 120 hours
15 Years 6.1538 hours 160 hours
20 Years 7.6923 hours 200 hours

**No vacation shall be granted if service is less than one (1) year.

Vacation credits may accrue and accumulate for a maximum of two (2) years' total accumulated vacation credits on a carry-over basis from year to year: 1) 1 through 5 years

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of se
rvice = 160 hours; 2) 6 through 15 years of service = 240 hours; 3) 16 through the completion of 20 years of service = 320 hours; and, 4) 21 or more years of service = 400 hours. Once the cap has been reached, a bargaining unit member may not accrue any additional hours until the employee’s accrued leave is below the cap.

In the event an employee works less than fifty percent (50%) of the total normal work hours in a pay period, he/she shall not be credited with any vacation leave for such pay period.

Approved vacation, sick, holiday, and administrative leave shall be considered as time worked for this item only.

When an employee resigns or otherwise leaves the service of the City, payment shall be made to the employee for the earned portion of his/her post-petition vacation hours on the basis of the hourly rate of pay being received by the employee on the date of separation.

Vacation Sell Back . Executives may sell back up to forty (40) hours of post -petition vacation time per year providing the following conditions have been met:

1. Employees must have a minimum of one hundred twenty (120) hours remaining in their vacation balance after the sell back occurs;

2. Employees must have taken at least forty (40) cumulative hours of vacation during the past year prior to the sell back of hours;

3. Employees must complete a sell back form, which must include the si gnature of the City Manager’s approval of the sell back;

4. Forms must be submitted to the Finance Department on or before November 1 st each year this Resolution is in effect; and,

Payment for vacation sell back hours will be paid (using the current Council approved salary rates in the Salary Resolution) on the employee’s first paycheck in December each year.

b. Executives hired on or after the adoption of this resolution, shall accrue one hundred twenty (120) hours of paid vacation upon the first day of the second year of continuous full-time employment with the City of San Bernardino. Thereafter, vacation shall accrue each pay period prorated according to the number of days or shifts per year in the following chart:

Completed Years of
Continuous Service
Rate of Accrual
Per Pay Period
Equivalent Hours
Per Year
1 Year** 4.615 hours 120 hours

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5 Year
s 5.769 hours 150 hours
10 Years+ 7.307 hours 190 hours

**No vacation shall be granted if service is less than one (1) year.

Vacation credits may accrue and accumulate for a maximum of 540 hours. Once the cap has been reached, Executives may not accrue any additional hours until their accrued leave is below the cap.

In the event an employee works less than fifty percent (50%) of the total normal work hours in a pay period, he/she shall not be credited with any vacation leave for such pay period.

Approved vacation, sick, holiday, and administrative leave shall be considered as time worked for this item only.

When an employee resigns or otherwise leaves the service of the City, payment shall be made to the employee for the earned portion of his/her post-petition vacation hours on the basis of the hourly rate of pay being received by the employee on the date of separation.

Vacation Sell Back . Executives may sell back up to eigh ty (80) hours of post -petition vacation time per year providing the following conditions have been met:

1. Employees must have a minimum of one hundred twenty (120) hours remaining in their vacation balance after the sell back occurs;

2. Employees must complete a sell back form, which must include the signature of the City Manager’s approval of the sell back;

3. Forms must be submitted to the Finance Department on or before November 1 st each year this Resolution is in effect; and,

Payment for vacation sell back hours will be paid (using the current Council approved salary rates in the Salary Resolution) on the employee’s first paycheck in December each year.

11. Executive Leave. To attract and retain highly qualified and experienced level employees, Executives hired on after the adoption of this resolution, shall accrue Executive Leave at the rate of 8.46 hours per pay period (220 hours or 5.5 weeks annually). Upon completion of three years continuous service, Executive Leave is eligible for sellback. Amounts in excess of 660 hours may be cashed in at 30% of value with the remaining 70% value to a 457 (b) plan, 401 (a) plan, Retiree Health Plan, or if such Plan is not available to an account of the Executives choice. Maximum accrual shall not exceed a total of 880 hours.

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Upon com
pletion of three years of continuous service and assuming proper notice is given in accordance with the Voluntary Separation of City Service Section or if an Executive is terminated without caus e in accordance with Termination/Severance Section , the Executive shall be eligible to cash out the Executive Leave bank in its entirety subject to the 7 0% restriction f or amounts in excess of 660 hours t o be placed in a tax-deferred account.

15. Sick Leave.
a. Executives who are covered by this Resolution shall accrue paid sick leave at a rate of ninety -six (96) hours per year, 3.6923 hours per pay period. Such paid sick leave may be used for employee or family illness or for medical reasons or other reasons provided under the City’s Paid Sick Leave Policy (AB 1522), adopted by the Mayor and City Council on June 18, 2015 by Resolution 2015- 116. Employees may only accrue a maximum of 1040 hours of sick leave at any time.

b. In the event an employee works less than fifty percent (50%) of the total normal work hours in the pay period, he/she shall not be credited with any sick leave for such pay period. Approved vacation, sick leave, holiday, or administrative leave shall be considered as time worked for the purpose of computing sick leave benefits only.

Whenever an employee uses all allowable sick leave, further absences may be charged against accrued vacation or with department head approval, the employee may take loss of pay rather than vacation.

c. Sick leave means the absence from duty of an employee because of illness or injury, exposure to contagious disease, attendance upon a member of his/her immediate family who is seriously ill and requires the care of or attendance of an employee, or death in the immediate family of the employee. Immediate family means: husband, wife, grandmother, grandfather, mother, father, sister, brother, son or daughter, mother -in-law, father-in-law, sister -in-law, brother -in-law, son- in-law or daughter -in-law, stepmother, stepfather, or domestic partner.

d. Upon the City Manager’s request, an employee must provide a physician's statement to justify sick leave usage of five (5) consecutive days or longer. Employees suspected of abuse of excessive use of sick leave may also be required to furnish a written statement from their health care provider supporting the use of sick leave and/or the ability to return to work.

e. No absence due to illness or injury in excess of five (5) working days shall be approved except after the presentation of satisfactory evidence of illness or injury; namely a certificate from a practicing physician or an authorized practicing chiropractor approved by the City Manager or his/her designee. The City Manager or his/her designee shall have the power to require that any person claiming the sick leave benefits of this resolution be examined at any reasonable time or intervals by the City's designated physician, and in the event of an adverse report to reject such claim for sick leave, in whole

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or in pa
rt, and to terminate sick leave compensation. In the event of the refusal of any person to submit to such examination after notification, the City Manager or his/her designees may terminate sick leave compensation and r eject any claim there of. The City Manager or his/her designee shall have the right to require the presentation of a certificate.

f. At the time of separation, any employee having six (6) or more years of service, may cash out unused post -petition sick leave as follows: 1) 288 hours or less, no cash out; 2) 289-479 hours = 20% of the total accrued hours; 3) 480- 959 hours = 25% of the total accrued hours; and, 4) 960 or more accrued hours = 35%.

16. CalPERS Retirement. Executives are provided retirement benefits under the California Public Employees’ Retirement System (CalPERS) as follows:

Non-Safety Employees:

Tier I: Employees hired on or before October 3, 2011 shall receive a 2.7% @ 55 retirement benefit;

Tier II: CalPERS “Classic Members” hired on or after October 4, 2011 shall receive a 2% @ 55 retirement benefit;

Tier III: CalPERS “New Members” hired on or after January 1, 2013 shall receive a 2% @ 62 retirement benefit in accordance with the Public Employees’ Pension Reform Act of 2013 (PEPRA).

Employee Share. Effective 2/1/2013, all Tier I and Tier II employees shall pay the employee’s share of the retirement contribution, either 8% for the 2.7@ 55 formula or 7% for the 2%@ 55 formula. Effective 1/1/2013, Tier III employees shall pay the employee contribution required by the PEPRA, calculated at 50% of the normal cost.

Employer Share. Effective 2/1/2013, all employees shall contribute 9.304% (either

1.304% or 2.304% depending on whether the employee rate is 8% or 7%) of their salary toward the employer cost of retirement in accordance with Section 20516 of the California Government Code.

The City will pay the employer contribution for the Fourth Level 1959 Survivor Benefit.

For Tier I and II employees, the final compensation retirement calculation shall be based upon their single highest year of compensation earnable as provided under Section 20042 of the California Government Code. The compensation earnable period for Tier III PEPRA employees will be three years.

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PEP
RA laws and regulations shall govern a determination of whether employees are hired as “new members” or “classic or legacy” members.

Safety Employees:

Tier I: Employees hired prior to September 1, 2011 shall receive a 3% @ 50 retirement benefit;

Tier II: CalPERS “Classic Members” hired on or after September 1, 2011 shall receive a 3% @ 55 retirement benefit;

Tier III: CalPERS “New Members” hired between January 1, 2013 and December 31, 2015 shall receive a 2.7% @ 57 retirement benefit in accordance with the Public Employees’ Pension Reform Act of 2013 (PEPRA);

Tier IV: CalPERS “New Members” hired on or after January 1, 2016 shall receive a 2.5% @ 57 retirement benefit in accordance with PEPRA.

Contributions/Cost Sharing. Classic employees as defined under CalPERS law shall contribute 12% (9% employee share and 3% employer share). PEPRA employees shall contribute 50% of the normal cost as defined under the Act.

17. Personnel Rules. Executives shall be subject to the City’s Personnel Rules unless such provisions conflict with at-will status.

18. Wellness Benefit. Executives are eligible to receive a taxable wellness/physical benefit of $250.00/year during each calendar year that this Resolution is in effect. This amount does not roll over to the next calendar year and any amounts not used by December 31 st shall be
forfeited. Employees have until March 31 st of the following calendar year to turn in receipts from the prior year. All reimbursement requests shall be made on forms provided by the Human Resources Department. Expenditures must follow the guidelines provided in Exhibit B to this Resolution.

19. Performance Evaluations. Performance evaluations and any corresponding merit pay increases will be administered through the provisions of the City’s Department Director Letter (DDL) No. 66, as may be amended.

20. Department Head Allowance. A n Executives may be reimbursed up to fifty dollars ($50) per month to cover work related employee events such as lunches, department celebrations, employee recognitions, and other events and functions. The allowance shall not accumulate from month to month. Requests for reimbursement shall be submitted to the Finance Department on prescribed forms.

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21. Bankruptcy Provisions/Release of Claims/Pre-Petition Leave Balances. Section 9 of Resolution No. 2015-242 Pre-Petition Leave Balances and Appendix A to Resolution No. 2015-242 Bankruptcy Provisions and Release of Claims shall continue to be in effect and are incorporated herein to this Resolution.

22. Termination/Severance. For Executives hired on or after the adoption of this resolution, if the City Manager desires to terminate employment without cause, during which time the Executive is willing and able to perform the functions and duties set forth in the respective Job Classification, then the City Manager agrees to provide Executive with severance pay representing six (6) months’ base salary or the monthly base salary multiplied by the number of months remaining on Executive’s term of employment, whichever is less. This severance payment shall be the only form of severance available to such executives.

Receipt of any severance payment is conditioned upon the Executive executing a release and waive of any and all potential claims against the City in a form similar to the release contained in Exhibit ‘A’.

23. Separation for Cause. As “at will” employees, nothing within th is resolution can be construed to create a property interest in the respective positions. Executives hired on after the adoption of this resolution will be disqualified from receiving Severance Pay if: (1) Executive refuses or fails to act in accordance with any specific direction or lawful order of the City Manager; (2) Executive commits an illegal act; or (3) Executive commits an act involving moral turpitude.

24. Voluntary Separation of City Service.

Executives hired on or after the adoption of this resolution may voluntarily resign from their positions after : (1) G iving the City Manager at least thirty (30) days written notice prior to the effective date of such resignation; or (2) Executives shall provide at least ninety (90) days written notice prior to the effective date of resignation to qualify for any portion of the Executive Leave at separation from City service; and (3) In the event of resignation, the Executive shall not be entitled to any Severance Pay. Executives hired before the adoption of this resolution may voluntarily resign by following the procedure established in the City’s Personnel Rules.

25. Cellular Phone. The City shall provide Executives with a cellular phone for City business.

All data and information stored on the phone, including but not limited to records of calls made and received, voice mail messages, and text message may be considered public records pursuant to the California Public Records Act.

26. Indemnification. Executives hired on or after the adoption of this resolution, the City shall defend, hold harmless and indemnify Executive against any tort, professional liability claim or demand or other legal action, whether groundless or otherwise, arising out of any alleged act or omission occurring in the performance of City Manager’s duties or resulting from the exercise of his judgment or discretion in connection with the performance of their respective duties, unless the act or omission involved unlawful conduct. The City shall not

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unrea
sonably refuse to provide for legal representation at City’s expense. Legal representation, provided by the City, shall extend until a final determination of the legal action including any and all losses, damages, judgment, interests, settlements, fines, court costs, and the reasonable costs and expenses of legal proceedings, including appeals, and including attorneys’ fees, and expert witness fees and all other trial and appellate costs, and other liabilities incurred, imposed upon, or suffered by such Executive in connection with or resulting from any claim, action, suit, or proceeding, actual or threatened, arising out of or in connection with the performance of Executive’s duties.

The City agrees to pay all reasonable litigation expenses of City Manager throughout pendency of any City-related litigation to which the Executive is a party, witness or advisor to the City. Such expense payments shall continue beyond E xecutive’s employment with the City as long as litigation is pending. Post -employment, City agrees to pay Executive for reasonable consulting fees, travel expenses and other costs, when City Manager serves as a witness, advisor or consultant to City regarding pending litigation.

SECTION 2. The above recitals are true and correct and are incorporated herein by this reference.

SECTION 3. The wages, hours and working conditions for Executive employees, as incorporated in the Compensation and Benefits Plan is hereby approved through June 30, 2025.

SECTION 4. The City Manager is authorized to implement the terms and conditions of the resolution for Executive employees and enter into an employment agreement with the Chief of Police subject to the terms and conditions set forth herein.

SECTION 5. The Mayor and City Council finds this Resolution is not subject to the California Environmental Quality Act (CEQA) in that the activity is covered by the general rule that CEQA applies only to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty, as in this case, that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.

SECTION 6. Severability. If any provision of this Resolution or the application thereof to any person or circumstance is held invalid, such invalidity shall not affect other provisions or applications, and to this end the provisions of this Resolution are declared to be severable.

SECTION 7. Effective Date. This Resolution shall become effective immediately.

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APPRO
VED and ADOPTED by the City Council and signed by the Mayor and attested by the City Clerk this ___ day of __________ 2022.

John Valdivia, Mayor
City of San Bernardino

Attest:

Genoveva Rocha, CMC, City Clerk

Approved as to form:

Sonia Carvalho, City Attorney

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CERTI

FICATION

STATE OF CALIFORNIA)
COUNTY OF SAN BERNARDINO) ss

CITY OF SAN BERNARDINO)

I, Genoveva Rocha, CMC, City Clerk, hereby certify that the attached is a true copy of Resolution No. 2022-___, adopted at a regular meeting held on the ___ day of _______ 2022 by the following vote:

Council Members: AYES NAYS ABSTAIN ABSENT
SANCHEZ _____ _____ _______ _______
IBARRA _____ _____ _______ _______
FIGUEROA _____ _____ _______ _______
SHORETT _____ _____ _______ _______
REYNOSO _____ _____ _______ _______
CALVIN _____ _____ _______ _______
ALEXANDER _____ _____ _______ _______

WITNESS my hand and official seal of the City of San Bernardino this ___ day of ____________ 2022.

Genoveva Rocha, CMC, City Clerk

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Exhibi
t “A”
GENERAL WAIVER AND RELEASE.

I, the undersigned, do hereby acknowledge and attest that I have read and understood my Executive Agreement with the City of San Bernardino and hereby agree that by accepting Severance Pay, I agree to waive all rights to further claims, remedies, or legal action against the City of San Bernardino its officers and employees.

In exchange for receipt of the Severance Pay, and all other salary and benefits owing, I and my representatives, heirs, successors, and assigns do hereby completely release and forever discharge the City of San Bernardino and its related entities and their present and former officers, directors, council members, agents, employees, attorneys, and successors (collectively, “Re lease Parties”) from all claims, rights, demands, actions, obligations, liabilities, and causes of action of every kind and character, known and unknown, mature or unmatured, which I may have now or in the future arising from any act or omission or condition occurring on or prior to the date this General Waiver and Release is signed whether based on tort, contract (express or implied), or any federal, state, or local law, statute, or regulations (collectively, the “Released Claims”). Released Claims shall a lso include, but not be limited to, claims for wages or other compensation due, severance pay, bonuses, sick leave, vacation pay, life or health insurance, or any other fringe benefit. This General Waiver and Release specifically releases and waives any an d all claims arising out of my employment and separation from employment with the City of San Bernardino, including but not limited to claims arising under the California Family Rights Act (“CFRA”), the California Constitution, federal Title VII of the Civil Rights Act of 1964, as amended, the federal Age Discrimination in Employment Act (“ADEA”), the federal Equal Pay Act (“EPA”), the federal Americans with Disabilities Act (“ADA”), the federal Fair Labor Standards Act (“FLSA”), the federal Family and Medical Leave Act (“FMLA”), tort and contract claims, privacy claims, and any other applicable local, state, federal or other laws that may apply.

I knowingly and voluntarily waive any and all rights or benefits that I may now have, or in the future may have, under the terms of Section 1542 of the California Civil Code, which provides as follows:

A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR

DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME

OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST

HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.

I acknowledge that I have read and understand this waiver and voluntarily and knowingly am waiving rights under Section 1542 to pursue unknown or unanticipated claims, rights, demands, actions, obligations, liabilities, and causes of action of any kind that may have materially affected this General Waiver and Release.

Unless otherwise required by law, I shall not file any claim, sue or initiate an action against any Released Party or participate in any compliance review, action, or proceeding, individually or as a

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memb
er of a class, under any contract (express or implied), or any local, state, federal law, state, or regulation pertaining in any manner to the Released Claims.

By signing this Agreement, I certify that Executive has read all of this Agreement, understands its terms and conditions, and knowingly and voluntarily consents to such terms. Employee acknowledges that the Company has advised Executive in writing to consult with an attorney before signing this Agreement. Employee certifies that Employee has been given at least twenty - one (21) days to consider this Agreement, and that Employee’s signature below indicates either that Employee has taken twenty- one (21) days to consider this Agreement or has knowingly and voluntarily waived some or all of this consideration period. In addition, Employee has seven (7) days from the date of signing this Agreement to revoke the Agreement, after which the Agreement will become final and binding (which shall be deemed the “Effective Date” of this Agreement). If Employee does not execute and return this Agreement upon expiration of the twenty-one (21) day period, the Agreement and any severance payment offer it contains shall be deemed rescinded and no longer offered to Employee.

Approved and Agreed to by:

City Manager Date:

City of San Bernardino Date:

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Exhibi
t “B”
Wellness/Fitness Benefits Table (All Require Pre-Approval for Reimbursement) Benefit Description Notes

Health club memberships to
pursue or maintain personal
health and physical fitness

Offsite health clubs
Physical fitness/exercise classes

Locations within San Bernardino
County or county of residence

Recreational classes, sport
lessons, nutrition

Includes personal training and
entire individual coaching

Fees for individual employee
Fee for team or family members
excluded

Entry, registration, participation
and league fees

Includes fees for participation in
group, team or league sporting
activities
Fees for individual employee
participating on a team only
Fee for entire team or family
members excluded

Physical fitness products and
equipment

For use outside the workplace

Reimbursement based on
current accrued balance
No advance on excess costs

Weight reduction programs to
improve general health or as
treatment for a specific disease

Exercise programs
Diet management programs
Stress reduction programs
Excludes food, food preparation
equipment and food and
nutritional supplements,
medications and residential
dietary/weight loss programs

Smoking cessation programs

Smoking cessation programs
Patches
Stress reduction programs
Coverage is for programs not
covered or offered by your
health plan.

No electronic cigarettes or
similar options

Health and wellness promotion
and education
Classes and educational
programs with primary focus to
improve health and wellness
Wellness workshops, on-line
training; includes meditation,
massage and acupuncture
Classes and educational
programs may include family
members if attending with
employee; family members
excluded from fees for services
(massage, acupuncture, etc.)

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AGENCY Class Max Comments
SAN BERNARDINO CITY CLERK $12,493.00
CORONA CITY CLERK $13,238.00
MORENO VALLEY CITY CLERK $17,409.60
MURRIETA CITY CLERK $25,071.18
ONTARIO ASST. CITY CLERK/RECORDS MGT DIRECTOR $19,890.00 ORANGE CITY CLERK SVCS DIR $12,175.00
POMONA CITY CLERK $17,973.00
RANCHO CUCAMONGA CITY CLERK $14,747.00
RIALTO CITY CLERK/DIR MGT SVCS $17,682.00 DUAL FT/ELECTED RIVERSIDE CITY CLERK $22,256.00
Mean: $17,826.86
Difference between SBC & Mean -$5,333.86
Pay Differential from Mean: -42.69%
Median: $17,682.00
Difference between SBC & Median -$5,189.00
Pay Differential from Median: -41.54%

CITY OF SAN BERNARDINO

CITY CLERK SALARY SURVEY
SEPTEMBER, 2025

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DISCUSSION
City of San Bernardino
Request for Council Action
Date: October 15, 2025
To: Honorable Mayor and City Council Members
From: Gabriel Elliott, Director of Community Development & Housing Department: Community Development & Housing
Subject: Approve Funding Commitment for Lutheran Social Services San Bernardino Community Wellness Campus with Lutheran
Social Service of Southern California and Dignity Moves (All Wards)
Recommendation
It is recommended that the Mayor and City Council of the City of San Bernardino, California:

1. Approve a waiver of eligible City-imposed development and permit fees for the San Bernardino Community Wellness Campus, in an amount not to exceed $134,319, limited to City-controlled fees; and

2. Approve a Regulatory and Loan Agreement with Lutheran Social Services of Southern California, a Nonprofit Corporation, and DignityMoves, a Nonprofit Corporation, to ensure project completion and protect the $34,944,702 Homekey investments; and

3. Adopt Resolutions No. 2025-377 authorizing the Finance and Management Services to amend the Fiscal Year 2025/2026 operating and capital budget by $1,798,969, appropriating $1,798,969 in 2021-2023 Permanent Local Housing Allocation funds to fund the final construction cost to complete the San Bernardino Community Wellness, and $261,539.40 of PLHA for administration; and

4. Authorize the City Manager or designee to execute all regulatory agreements, loan agreements, and amendments with LSSSC and DignityMoves after review and approval by the City attorney and take any further action necessary to carry out the terms and objectives of the resolution and agreement.

City Manager Comments
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The City Manager recommends that the City Council approve the $1.7 million in PLHA.

If San Bernardino County (County) does not approve the approximate $1.4 million, there will still be a shortfall. The City Council could additionally authorize the $1.4 million from General Fund reserves in the event the County does not approve.

Executive Summary
The San Bernardino Community Wellness Campus (SBCWC) is a 140-unit Homekey

3.0 interim housing project for unhoused men led with Lutheran Social Services of Southern California (LSSSC) and DignityMoves in partnership with the City, faces a $3,412,885 construction shortfall driven by cost escalation and unforeseen solar and fee expenses. The campus is 69% complete under a State of California’s Housing and Community Development (HCD) approved extension with a construction deadline of December 31, 2025, and 90% occupancy due by March 31, 2026. Without immediate local funding, work is projected to halt, risk default, potentially claw back the $34.9M Homekey award, expose the City to legal and financial exposure, and reduce eligibility for future State housing grants.

To prevent delay and protect prior investments, staff recommend a gap-closure financing allocating $1,798,969 in 2021–2023 PLHA funds, and City Council consider whether to conditionally commit up to $1,479,597 in General Fund (subject to County participation). This package will be coupled with a Regulatory & Loan Agreement with LSSSC/Dignity Moves to establish enforceable milestones, reporting requirements, and eligible uses, as well as allow prioritization of up to 24 reserved beds for City referrals (e.g., outreach and PEACE teams). Council action would authorize related budget amendments (totaling approximately $3,500,105.40), to preserve this critical shelter expansion, and maintain the City’s competitive standing for future State funding.

Background
The City is partnering with LSSSC on a State of California Homekey Project to develop a 140-bed, non-congregate interim housing unit for men.

The project will be called the San Bernardino Community Wellness Campus (SBCWC), and is being constructed using prefabricated modular units. The need for a campus of this nature is significant as homeless men in the City outnumber homeless women by two to one. The Community Wellness Campus will assist some of the City’s most vulnerable residents with housing, jobs and health services while generating revenue for the City with its retail market.

According to the 2025 Point-in-Time Count, the City of San Bernardino accounts for 40% of the County’s homeless population, the highest share of any jurisdiction in the region. While the City is actively partnering with affordable housing developers to grow its long-term housing inventory, increasing shelter capacity remains essential to helping its most vulnerable residents stabilize and transition out of homelessness.

On October 27, 2022, the City held a Homeless Workshop. The Mayor and City Council agreed that there was a great need to expand shelter bed capacity and services for those experiencing homelessness within the city.

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On December 7, 2022, the Mayor and City Council allocated $5 million in American Rescue Plan Act (ARPA) funds to LSSSC to increase shelter bed capacity and services. They also authorized the City to submit a joint Homekey 3.0 application with LSSSC to expand shelter bed capacity via interim housing.

On February 1, 2023, The Mayor and City Council adopted Resolution No. 2023-028, declaring a Homelessness State of Emergency.

On December 19, 2023-The City, in partnership with LSSSC and Dignity Moves, was awarded $34.9 million in Homekey 3.0 funds to develop the SBCWC.

On September 4, 2024, the Council adopted Resolution No. 2024-201, reaffirming the Homelessness State of Emergency and granting the City Manager authority to pursue contracts and funding.

Discussion
The Urgent Need for Additional Shelter Beds
To meet the urgent and growing need for shelter and supportive services, the City must act to ensure the completion of the SBCWC, which will significantly expand interim housing capacity for unhoused men. The project is located at 1354 N G St, San Bernardino.

Without additional City investment, this transformative project risks stalling, jeopardizing critical state funding and its ability to provide safe, service-rich housing for its most vulnerable residents. The SBCWC will triple the current shelter capacity provided by LSSSC. This expansion is critical as unhoused men in the City outnumber women by more than two to one. The following supportive services will be offered on campus:
 On-site medical clinic;
 Comprehensive social services addressing educational, physical, mental health, and social needs;
 Workforce development training;
 Services to both campus residents and the surrounding community Campus residents can stay for up to 180 days, during which no rent will be charged.

This will enable participants to stabilize and work toward transitioning into permanent housing. Each unit will include a bed, underbed storage, a desk, and a wall rack for coats and personal items. A two-story building is being constructed with prefabricated modular units, approved by HCD, and is currently 69% complete. Its targeted completion date is November 27, 2025.

The State initially set a 12-month full occupancy deadline of March 19, 2025, for the project. Following a formal request, the State granted a one-time extension, revising the deadline to March 31, 2026.

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Performance
Milestone
Per Standard
Agreement
Requested
Extension
Dates

APPROVED EXTENSION
Construction/Rehab 12/19/2025 12/31/2025 12/31/2025
Full Occupancy
(90%+)
3/19/2025 12/31/2025 3/31/2026 90 days after
construction
completion
deadline.

Despite this extension, the project has experienced financial setbacks due to rising construction material costs and unforeseen expenses related to solar requirements. As a result, the project is facing a funding shortfall of $3,238,555. Without additional financial support from the City to close this gap, the project is at serious risk of missing its revised deadline, which could result in substantial consequences, including potential State enforcement actions and loss of funding.

Risks of Non-Performance Under Homekey Grant Terms
If the City fails to meet the revised completion deadline or fails to deliver the promised housing units and services outlined in its grant agreement, the California Department of Housing and Community Development (HCD) could declare the City and its partners in default of its Homekey grant terms. This could result in:
 Claw back of funds: The City could be required to return all or part of the awarded Homekey funds.
 Legal and financial liability: The City may incur further liability if state auditors or oversight bodies determine that public funds were misused or improperly accounted for.
 The most immediate long-term consequence of non-completion is likely:
 Disqualification from future Homekey funding opportunities:
o Ineligibility for Homekey 4.0 and beyond.
o Reduced competitiveness in other State housing and homelessness- related grants, as past performance is a critical scoring criterion in state evaluations.

The State has explicitly stated in Homekey Notices of Funding Availability (NOFAs) that project performance and timely delivery are essential to remaining in good standing for future funding. To avoid these outcomes, the City could consider the following:
 Identify and commit local funding.
 Establish a new Agreement that would require LSSSC to earmark 24 beds from SBCWC specifically for the City of San Bernardino, to be used by the City’s homeless outreach teams and the police department’s PEACE (proactive enforcement and community engagement) team.

By identifying and committing to the following actions, the City can ensure the on-time Packet Page. 397

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completion of SBCWC.

1. Reallocation of 2021-2023 Permanent Local Housing Allocation (PLHA) Funds- $1,798,969
The City’s FY 2021–2023 PLHA funds had initially been designated to supplement the operations of the SB HOPE Campus, in combination with $2 million in General Funds (beginning in FY 2026–2027). However, a total of $1,798,969 in 2021-2023 PLHA funds could be reallocated to help cover the construction completion costs for the SBCWC.

The City’s SB HOPE Campus is not scheduled to be completed and operational until November 2026. As a result, future PLHA funds can be allocated toward its operations. Specifically, the next PLHA five-year allocation cycle (2024–2028) is expected to open its NOFA in October of this year. Based on the 2019–2023 allocation, the City anticipates receiving approximately $9.3 million in PLHA funds, which may be used to help sustain operations at the SB HOPE Campus.

2. General Funds $1,479,597
While the Mayor and City Council can alleviate a portion of the $3,412,885 funding gap by allocating $1,798,969 in existing PLHA funds, a remaining balance of $1,479,597 must still be addressed. LSSSC and the City are in ongoing discussions with the County to explore whether the County can cover this remaining gap.

The City Council could conditionally commit $1,479,59 if the County does not provide funding. This fiscally responsible approach safeguards the project timeline, upholds prior public commitments, and ensures the timely delivery of urgently needed housing for our community’s most vulnerable residents.

3. Allocation of 2021-2023 PLHA Administration Funding - $261,539.40 The PLHA funding allocation permits the City to use up to 5% of the total award for administrative purposes. These funds will support city staff salaries, legal services, consultant services for technical assistance, regulatory compliance, reporting, and other costs related to the administration of PLHA- funded projects.

Regulatory and Loan Agreement-Shelter Bed Prioritization The City will enter into a Regulatory and Loan Agreement with LSSSC to ensure that the final construction phase can be completed without delay, enforce conditions, performance standards, and reporting obligations, and ensure that public funds are spent solely on eligible and approved construction-related activities. The loan structure may include forgiveness or repayment terms tied to long-term compliance, which balances financial stewardship and support for community services.

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The Agreement also includes provisions for LSSSC to prioritize 24 shelter beds for the City’s homeless outreach teams and the Police Department’s PEACE (Proactive Enforcement and Community Engagement) team. The City had previously awarded LSSSC $5 million in ARPA funds for operations. This regulatory and loan agreement would establish a dedicated referral pathway by contractually requiring LSSSC to prioritize a percentage of its shelter capacity specifically for City-initiated placements, thereby strengthening coordination and ensuring timely access to shelter for individuals encountered through City-led engagement efforts.

The City will ensure that LSSSC and DignityMoves remain accountable partners and fulfill their scopes of work. Funding to complete the project will be connected to the following provisions:
 Formalized Agreement: Execute detailed and clear deliverables, timelines, performance benchmarks, and roles for both organizations.  Execute a Regulatory Agreement as required by HCD
 Milestone-Based Funding: Tie disbursement of to achievement of specific project milestones and deliverables.
 Regular Reporting: Require frequent financial and programmatic reporting, expenditure tracking and progress updates.
 Monitoring and Oversight: Conduct regular site visits, performance reviews, and compliance audits.
 Corrective Action Provisions: Include remediation or funding suspension clauses if partners fail to meet expectations.

These steps will help protect the public investment and ensure timely project completion and service delivery.
2021-2025 Strategic Targets and Goals
The request for a commitment of the PLHA and General Fund aligns with Strategic Target No. 3: Improved Quality of Life, by expanding accessibility to interim housing and services, improving living conditions for the unhoused population, and positively impacting the community.

Fiscal Impact

FINANCIAL
DATA
Current
Fiscal Year:

Next Fiscal
Year:

Total Cost: Ongoing
Cost:

COST $ 3,412,885 $ 0 $ 3,412,885 $ 0

GENERAL
FUND
SHARE
$ 1,439,597 $ 0 $ 1,439,597 $ 0
SOURCE OF FUNDS:

PLHA $1,798,969
Budget Adjustment:

Yes
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Conclusion
It is recommended that the Mayor and City Council of the City of San Bernardino, California:

1. Approve a waiver of eligible City-imposed development and permit fees for the San Bernardino Community Wellness Campus, in an amount not to exceed $134,319,000 limited to City-controlled fees; and

2. Approve a Regulatory and Loan Agreement with Lutheran Social Services of Southern California, a Nonprofit Corporation, and DignityMoves, a Nonprofit Corporation, to ensure project completion and protect the $34,944,702 Homekey investments; and

3. Adopt Resolutions No. 2025-377 authorizing Finance and Management Services to amend the Fiscal Year 2025/2026 operating and capital budget by $3,500,105.40, appropriating $1,798,969 in 2021-2023 , and $261,539.40 of PLHA for administration; and

4. Authorize the City Manager or designee to execute all regulatory agreements, loan agreements, and amendments with LSSSC and DignityMoves after review and approval by the City attorney and take any further action necessary to carry out the terms and objectives of the resolution and agreement.

Attachments

1. Attachment 1: Dignity Moves Fee Waiver Letter

2. Attachment 2: Resolution 2025-377
Ward:

All Wards
Synopsis of Previous Council Actions:

October 16, 2022 Homeless Workshop hosted by the City December 7, 2022 The Mayor and City Council allocated $5 million in American Rescue Plan Act (ARPA) to LSSSC to
increase shelter bed capacity and services. (NOFA) for
the Rapid Rehousing Program under the Encampment
Resolution Fund initiative
December 7, 2022 The mayor and City Council also authorized the City to submit a joint Homekey 3.0 application with LSSSC to
expand shelter bed capacity via interim housing.

February 1, 2023 The Mayor and City Council adopted Resolution No. 2023-028, declaring a Homelessness State of
Emergency.

May 17, 2023 The Mayor and City Council adopted Resolution No. 2023-057 to submit a joint Homekey application with
Lutheran Social Services of Southern California
(LSSSC).

For Fiscal Year: 25/26
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December 19, 2023 The City, in partnership with LSSSC and Dignity Moves, was awarded $34.9 million in Homekey 3.0
funds to develop the SBCWC.

July 5, 2024 The Mayor and City Council adopted Resolution No. 2023-057 to amend the joint Homekey Application to
include LSSSSC and Dignity Moves.

September 4, 2024 Council adopted Resolution No. 2024-201, reaffirming the Homelessness State of Emergency and granting
the City Manager authority to pursue contracts and
funding.

CC: Eric Levitt, City Manager
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290 North D St, San Bernardino, CA 92401 | P: 909-384-7272 | www.SBCity.org February 19, 2025
Ms. Joanne Price
Dignity Moves
870 Market Street #1153
San Francisco, CA 94102
RE: Dignity Moves/Lutheran Social Services of Southern California (LSSSC) October 2024 Request for Waiver of Development and Permit Fees for the Homekey Project Dear Ms. Price:

Thank you for your patience while the City thoroughly reviewed and analyzed your request for waiver of permit and development fees related to the Lutheran Social Services of Southern California (LSSSC) Homekey Project. We value the partnership between the City and LSSSC and look forward to the completion of the 140 housing units that will shelter many unhoused in our community.

In your October 10, 2024, letter you requested a waiver of both permit processing and development impact fees under the criteria set forth in Section 3.13.030 of the San Bernardino Municipal Code. We proceeded with this request and thank you for working with our staff to identify the specific fees and the amount of each waiver. While discussing your request with the City Council Ad Hoc Committee on Homelessness on January 22, 2025, it was brought to our attention that Section

3.13.030, the one you referen ced in your request, only applies to waiving permit processing fees.

Chapter 3.27 applies to requests for deferral of development impact fees and is much more restrictive as these fees are connected to fee studies providing for the building and replacemen t of critical infrastructure. When these fees are not paid they negatively impact the ability of the public agency to complete the necessary improvements. In some cases, the City Council does not have the authority to waive the fees. For example, section 3.27.170 says that the regional circulation fees cannot be waived.

Of the $523,941.21 in currently accrued permit and development impact fees, $261,323.46 cannot be waived.

The City will ask the Council at a public meeting to consider waiving the permit processing fees in the amount of $134,318.99. These fees are broken down as follows:
$ 5,298.90 MP24-05 (Parcel Map)
$ 49,510.00 LD2400001 (Grading Plan)
$ 3,091.00 THR24-019 (Land Development)
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$ 12,106.84 E2400028 (Street Improvements)
$ 44,999.64 B2402368 (Support Building)
$ 9,214.79 B2401769 (Roof Rails)
$ 10,097.82 B2401768 (Electrical Shed)
As for the development impact fees, a recommendation must first be made by the Community Development Director1. The request may only be granted after notice and hearing at a public Council meeting. The Council decision to waive development impact fees must be properly supported by specific findings. The findings must be based on written and other evidence submitted by the property owner, substantiating the owner's contention that the fee should be deferred. Findings must include facts supporting deferral, including without limitation, findings that in the case of deferral (1) other properties to be benefited by any fee will not be burdened by the review and delay in fee imposition, or, (2) alternative financing methods involving more than one owner have been proposed for review, or (3) delay will result in a more fair funding arrangement.

We estimate the development impact fees that are subject to be waived are $128,298.76 as set forth below:
$ 67,596.54 CD-Law Enforcement DIF
$ 28,247.48 Local Circulation DIF
$ 32,454.74 CD-Storm Drain Fee
If you desire to seek waiver of the development impact fees we will need you to submit a written request with information to help us recommend the necessary findings to the City Council.

The City is truly supportive of the project and wishes to continue to work with you on these and other matters.

Sincerely,
Tanya Romo
Acting City Manager
1 Section 3.27.170 refers to the Director of Development Services who duties are now assumed by the person holding the Community Development Director position.

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Resolution No. 2025-377
Resolution No. 2025-377
October 15, 2025

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RESOLUTION NO.2025-377

RESOLUTION OF THE MAYOR AND CITY COUNCIL OF

THE CITY OF SAN BERNARDINO, CALIFORNIA,

AUTHORIZING THE AMENDMENT OF THE FISCAL
YEAR 2025/2026 OPERATING AND CAPITAL BUDGET BY
APPROPRIATING $1,798,969 IN 2021-2023 PERMANENT

LOCAL HOUSING ALLOCATION FUNDS

CONSTRUCTION COST TO COMPLETE THE SAN

BERNARDINO COMMUNITY WELLNESS, AND
$261,539.40 IN PERMANENT LOCAL HOUSING
ALLOCATION PROGRAM ADMINISTRATION.

WHEREAS, the California Department of Housing and Community Development (“Department”) issued a Notice of Funding Availability (“NOFA”) on March 29, 2023, for the Homekey Program (“Homekey” or “Program”), pursuant to Health and Safety Code section 50675.1.3 (Assem. Bill No. 140 (2021–2022 Reg. Sess.), § 20); and WHEREAS, the City of San Bernardino (“Lead Applicant”) jointly applied for Homekey grant funds with Lutheran Social Services and Dignity Moves (“Co-Applicants”) to develop a 140- unit interim housing complex with onsite supportive services and a medical clinic to serve unhoused individuals; and
WHEREAS, the City has at any given time, approximately 1,535 people experiencing homelessness Citywide; and
WHEREAS, on December 19, 2023, the Department issued a conditional award of $34,944,702 in Homekey Round 3.0 grant funds to the City and its Co-Applicants for the San Bernardino Community Wellness Campus (SBCWC) located at 1354 N G Street, San Bernardinoto to develop a 140-unit interim housing project to serve men experiencing homelessness, including on-site supportive services and a medical clinic; and WHEREAS, the City and its Co-Applicants have acknowledged and agreed to the terms and conditions set forth in the Homekey Standard Agreement and are committed to fulfilling all program obligations in accordance with State requirements; WHEREAS, the project has experienced cost escalations that have resulted in a funding shortfall; and
WHEREAS, the City desires to support the timely and successful completion of the project in alignment with its strategic goals of reducing homelessness, expanding interim housing, and improving community wellness; and
WHEREAS, the City has available 2021–2023 Planned Local Housing Allocation (PLHA) funds in the amount of $2,060,508.40, which may be reallocated to support the construction of SBCWC and program administration; and
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Resolution No. 2025-377
Resolution No. 2025-377
October 15, 2025

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WHEREAS, the City is actively engaged in discussions with the County of San Bernardino to secure County participation in funding the remaining gap of $1,479,597; and WHEREAS, to prevent delays, the City desires to authorize the conditional commitment of $1,479,597 in General Funds, which shall become a firm commitment only in the event that County funding is not secured.

BE IT RESOLVED BY THE MAYOR AND CITY COUNCIL OF THE CITY OF SAN BERNARDINO AS FOLLOWS:

SECTION 1. The above recitals are true and correct and are incorporated herein by this reference.

SECTION 2. The Mayor and City Council hereby authorize the Director of Finance and Management Services to amend the Fiscal Year 2025–2026 Operating and Capital Budget in the amount of $2,060,508.40 from 2021–2023 PLHA funds to fund the final construction costs of the San Bernardino Community Wellness Campus (SBCWC).

SECTION 3. The City Manager is authorized to take all necessary and appropriate actions to implement this Resolution, including the execution or amendment of agreements, coordination with the Department of Housing and Community Development, County officials, and project partners, and any other actions required to carry out the intent of this Resolution.

SECTION 3. CEQA. The Mayor and City Council find this Resolution is not subject to the California Environmental Quality Act (CEQA) in that the activity is covered by the general rule that CEQA applies only to projects which have the potential to cause a significant effect on the environment. Where it can be seen with certainty, as in this case, that there is no possibility that the activity in question may significantly affect the environment, the activity is not subject to CEQA.

SECTION 4. Severability. If any provision of this Resolution or the application thereof to any person or circumstance is held invalid, such invalidity shall not affect other provisions or applications, and to this end the provisions of this Resolution are declared to be severable.

SECTION 5. Effective Date. This Resolution shall become effective immediately.

APPROVED and ADOPTED by the City Council and signed by the Mayor and attested by the City Clerk this 15th day of October 2025.

Helen Tran, Mayor
City of San Bernardino
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Resolution No. 2025-377
Resolution No. 2025-377
October 15, 2025

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Attest:

Telicia Lopez, Acting City Clerk
Approved as to form:

Sonia Carvalho, City Attorney
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Resolution No. 2025-377
Resolution No. 2025-377
October 15, 2025

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Resolution No. 2025-377
Resolution No. 2025-377
October 15, 2025

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CERTIFICATION

STATE OF CALIFORNIA )
COUNTY OF SAN BERNARDINO) ss

CITY OF SAN BERNARDINO )
I, Telicia Lopez, CMC, Acting City Clerk, hereby certify that the attached is a true copy of Resolution No. 2025-377, adopted at a regular meeting held on the 15 th day of October, 2025 by the following vote:

Council Members: AYES NAYS ABSTAIN ABSENT
SANCHEZ _____ _____ _______ _______
IBARRA _____ _____ _______ _______
FIGUEROA _____ _____ _______ _______
SHORETT _____ _____ _______ _______
KNAUS _____ _____ _______ _______
FLORES _____ _____ _______ _______
ORTIZ _____ _____ _______ _______
WITNESS my hand and official seal of the City of San Bernardino on this 15 th day of October 2025.

Telicia Lopez, CMC, Acting City Clerk
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DISCUSSION
City of San Bernardino
Request for Council Action
Date: October 15, 2025
To: Honorable Mayor and City Council Members
From: Gabriel Elliott, Director of Community Development & Housing Department: Community Development & Housing
Subject: Oxbow Debris Removal – 6920 Palm Avenue (Ward 5) Recommendation
It is recommended that the Mayor of City Council of the City of San Bernardino take the following actions:

1. Adopt Resolution No. 2025-378 of the Mayor and City Council of the City of San Bernardino, California, rescinding Resolution No. 2020-265, which prohibits the crushing of concrete on site within 1,000 feet of residentially zoned property; and

2. Review the three alternatives provided in the Oxbow Debris Removal Project Environmental Study dated May 22, 2025, select Alternative 3 which is concluded to result in least levels of impact to the community among the three alternatives, and adopt Resolution No. 2025-379 memorializing that decision; and

3. Direct the City Manager or his designee to prepare public outreach for the residents of Ward 5, regarding the removal of the Oxbow Debris.

City Manager Comments
In evaluating the Environmental Study completed on May 22, 2025, there are three options before the City Council. As the Council is aware the movement of the debris occurred in September 2020. There is not any ideal solution to removing or crushing the debris. The study evaluated the three best alternatives in limiting environmental and noise impacts to the neighborhood.

If either alternative 1 or alternative 2 occurred, the study recommends that it occur during the Summer when school is on recess. If Alternative 3 is desired it may also Packet Page. 409
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be best to occur when school is on recess, although I would recommend that the developer and City engage the community on it preference for time of year.

Based on air quality emissions and other environmental considerations, Alternative 3 appears to be the best approach. If Alternative 3 is preferred by the City Council, I recommend a Lokotrack Urban LT96 be utilized to minimize dust emissions and noise. I also would recommend that the developer and City work with the community on timing of the operation. This would result in an 85% dust reduction and 60% noise reduction due to its process.

If alternatively, alternative 1 or 2 were chosen, I would recommend that occur during off times for the school and utilize single end dump trucks.

Executive Summary
The Oxbow debris, located at 6920 Palm Avenue, has been a source of community concern and complaints since the debris was deposited on the project site in 2020. Through a Temporary Use Permit and Haul Permit issued in 2020, the debris has been part of the Palm Avenue landscape for the last five years. The analysis provided in the Oxbow Debris Removal Project Environmental Study prepared by CSG in May 2025, provides the City of San Bernardino with solid options to remove the debris based on a thorough analysis. The preferred alternative would require the crushing of the debris on site, City Council Resolution No. 2020-265, prohibiting the crushing of debris within 1,000 feet of residentially zoned property would need to be repealed if this option is selected. Repeal of Resolution No. 2020-265 would allow for on-site crushing of the debris for use on the project site. Based on the thorough study, this is the best alternative.

The CSG report was prepared at a cost of about $73,000, with additional cost of about $12,800 to test the debris and surrounding soil. The cost of the report and soil testing will be borne by the city, and additional costs will be incurred by the City if it solicits the services of a paid consultant for a community outreach effort. It is anticipated costs for community outreach would be approximately $40,000.

Background
In 2009, the Oxbow development was approved by the City of San Bernardino under Tentative Tract Map 16794 which subdivided an existing 18.45-acre parcel into 44- single family lots with minimum lot size of 10,882 square feet, at 6920 Palm Avenue.

On July 2020, the then project owner submitted a Temporary Use Permit (TUP) to allow stockpile of materials for future grading of the site. The materials comprised of approximately 60,000 tons of concrete in 3,000 truckloads, which originated from the demolition of a fire damaged Amazon warehouse building located at 2255 W. Lugonia Avenue in Redlands, which burned down in June 2020.

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On August 4, 2020, the Public Works Department issued a Haul Permit (Permit # H20- 002) to Oxbow and their associate Greenleaf Engineering to transport the 60,000-ton stockpile to the project site at 6920 Palm Avenue. In 2020, based on concerns about the safety of the stockpile, the debris was tested and found to be clean. A 2025 test of the stockpile and surrounding soil has since been conducted and will be included with the staff report.

City Council adopted Resolution No. 2020-265 on October 21, 2020, regarding San Bernardino Municipal Code (SBMC) Section 19.70.020(2) under which the TUP was allowed. The Resolution permits the issuance of a TUP for on-and off-site contractors’ construction yard in conjunction with an approved development project. The Resolution also declared that City Staff should not issue any TUP allowing the crushing or grinding of unfinished materials, such as concrete, within 1,000 feet of residentially zoned properties.

The transported stockpile was left uncovered at the Palm Avenue site and according to residents of the area, began to generate dust. Not covering the pile was a violation of the conditions of issuing the TUP. Residents of the area raised concerns to the City and the City requested covering of the pile. The property has changed ownership over the years, and today, the pile coverings have been eroded by wind and weather conditions. While residents are still concerned about the debris, the new owner has met with staff and began clearing the site around the debris of overgrown weed and illegal dumping.

On January 15, 2021, the City issued a Notice of Revocation of the Temporary Use Permit and Notice to Abate. On January 16, 2021, the then property owner directed the City to engage with the former Oxbow owner to remove the stockpile and if the then current owner had to abate, the City would be responsible for the cost of abatement. No actions from the City followed.

On October 4, 2023, the City Council directed staff to bring back a Resolution repealing Resolution No. 2020-265 and issue a written notice to the Planning Commission to render within 40 days, a report on crushing restriction of unfinished materials within 1,000 feet of the residentially zoned property. That request and directive is now coming to the City Council for action.

In June 2024, Aberdeen Developers, the then owner of the development, proposed a solution to remove the material from the project site by requesting a waiver of the impact fees associated with the development to offset the cost of removal. The developer also agreed to be responsible for the additional import and transport of 30,000 cubic yards of additional filling material to site for grading purposes. Staff considered that request at the time, but did not present to the City Council due to complications with the request; including, a request to waive regional impact fees.

During that period, staff was made aware that Aberdeen Developers listed the property for sale and discussions ceased. As of September 2025, Aberdeen Developers no longer owns the Oxbow development.

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The City entered into a contract with CSG Consultants in March 2025, to provide a comprehensive analysis of the options available to the City for the removal of the Oxbow debris. The report included a thorough The report considered all the options discussed over the years that had not been environmentally vetted for their impact. In May of 2025, CSG, in collaboration with Kimley-Horn, completed the report (Attachment 4) and proposed three alternatives for the removal of the debris. The report included an executive summary which summarized the analyses conducted by the firm and provided recommendations based on air quality, health risk, noise, and truck routing impacts for the three alternatives analyzed. The City will engage with the new project owner to present the conclusions of the CSG report and discuss the details of the crushing activities on site.

The environmental study considered three main alternatives: Alternatives 1 and 2 would result in the material being hauled offsite as either processed or unprocessed concrete, which would require truck hauling trips to occur along Palm Avenue. Due to the proximity of Palm Avenue Elementary School, the report recommended that the hauling operation for Alternatives 1 and 2 occur during the school’s summer recess period (approximately early June to early August), to limit safety concerns associated with truck travel along Palm Avenue.

Additionally, the hauling operation could be completed through the use of either bobtail dump trucks or single-end dump trucks. Bobtail dump trucks are smaller and would require a greater number of truck trips, while single-end dump trucks are long and could be more difficult to maneuver around the Project site. Alternatives 1 and 2 include sub- alternatives that consider the use of either bobtail or single-end dump trucks. For Alternatives 1 and 2, the report anticipated that the concrete would be hauled to the Rialto Recycle Yard, owned and operated by ARCOSA Crushed Concrete, located at 250 East Santa Ana Avenue, Rialto. Alternative 3 involves crushing the material onsite and retaining it onsite, to be used as fill for future residential development. Alternative 3 does not include a hauling operation.

The Project site is currently undeveloped, and grading and site preparation would be required for all three alternatives in order to provide site access and allow for equipment to be located onsite.

Also, the city is proposing a community outreach program to address the results of the study. One option considered is the hiring of a public relations consulting firm to conduct the outreach. There are costs associated with this option. Alternatively, staff can conduct the community outreach in conjunction with the community leaders and residents of the Ward 5.

Discussion
Alternative 1 Alternative 1 involves crushing the concrete debris onsite, then hauling the processed concrete offsite to a recycling center. This alternative would require the Packet Page. 412
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use of a crusher, breaker, front-end loader, street sweeper, loaders, and hauling trucks.

The breaker would be used to break the concrete debris into smaller chunks for placement in the crusher, the front-end loader would load the material into the crusher, and the loaders would move the processed concrete from the pile created by the crusher, into the hauling trucks. It is anticipated that the processed concrete would be approximately 33,600 cubic yards of material.

Alternative 1.1 Alternative 1.1 includes the use of bobtail dump trucks for the hauling operation. In order to complete the removal process during one summer school recess period using bobtail dump trucks, Alternative 1.1 would require 400 truck trips per day along Palm Avenue (200 loaded, 200 empty) and would take approximately 38 working days to complete. This option would result in approximately 15,200 truck trips.

Alternative 1.2 Alternative 1.2 includes the use of single-end dump trucks, which would take approximately 35 working days to complete and would require 162 hauling trips per day on Palm Avenue (81 loaded, 81 empty) resulting in approximately 5,670 truck trips.

Alternative 2 Alternative 2 involves hauling the unprocessed concrete debris offsite to be processed at the Rialto Recycle Yard. This alternative would require the use of a street sweeper, loaders, hauling trucks, and possibly a small bobcat breaker to break the debris into smaller pieces to fit in the hauling trucks. The unprocessed concrete is anticipated to contain approximately 42,000 cubic yards of material. Therefore, it would take longer to remove from the project site than the processed concrete, which would contain approximately 33,600 cubic yards of material.

Alternative 2.1 Alternative 2.1 involves removing the entire concrete debris pile over one summer recess period.

Alternative 2.1.1 Alternative 2.1.1 includes the use of bobtail dump trucks, which would require 520 hauling truck trips per day along Palm Avenue (260 loaded, 260 empty) and would take approximately 36 working days to complete. Resulting in approximately 18,720 trips.

Alternative 2.1.2 Includes the use of single-end dump trucks, which would require 200 hauling truck trips per day (100 loaded, 100 empty) and would take approximately 35 working days to complete. Resulting in approximately 7,000 trips.

Alternative 2.2 Involves removing the concrete debris pile over two summer recess periods, to decrease the number of required truck trips along Palm Avenue during each summer. Between the two summer recess periods, the remaining concrete debris pile would have to be covered in order to limit the potential for fugitive dust and debris in the surrounding area. With this option, completion would be by end of 2027.

Alternative 2.2.1 involves the use of bobtail dump trucks, which would require 264 hauling trips per day on Palm Avenue (132 loaded, 132 empty) and would take Packet Page. 413
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approximately 71 working days to complete. Resulting in approximately 18,744 trips.

Alternative 2.2.2 includes the use of single-end dump trucks, which would require 98 hauling truck trips per day (49 loaded, 49 empty) and would take approximately 72 working days to complete. Resulting in approximately 7,056 trips.

Alternative 3 considered by the consultant, is a variation of Alternative 1, with the crushing operation occurring onsite, and no hauling operation. Under Alternative 3, the crushed material would remain onsite for future use as onsite infill for residential development on the property. Alternative 3 would require the use of a breaker, front- end loader, and crusher. The breaker would be used to break the concrete pieces into smaller pieces for processing. The loader would move the debris into the crusher, which would create piles of processed concrete material around the project site.

Alternative 3 would require a Containment Plan to ensure that the processed concrete is contained between the time it is processed and when it is used for filling, in order to limit dust emissions. It is anticipated that it would take approximately three to four months to crush the entire concrete debris pile, assuming no equipment breakdowns or delays occur. It is important to note that this alternative will require the use of specialized crushing equipment compatible with residential settings.

If Alternative 3 is selected as the preferred alternative, a Containment Plan to mitigate and assure that crushed material does not result in dust emission nuisance to area residents will be required. The Containment Plan shall be prepared by the Project Applicant for development of the Project site and is subject to approval by the City of San Bernardino, prior to starting site preparation for the crushing operation. The Containment Plan may include, but not be limited to, the following requirements:
- The debris should be covered with a durable heavy-duty plastic sheeting or geotextile fabric and the following actions should be taken to ensure that the debris cover remains effective:
 Regular inspections: Regularly inspect the covering for damage or wear and tear and make repairs as needed, particularly after periods of heavy rain or high winds.
 Ensure Secure Coverage: Properly secure the coverings to prevent them from blowing away or becoming damaged, especially during windy conditions.
 Adjust Covering: Adjust the covering as necessary to accommodate any changes in the debris pile or weather conditions
Air Quality
Based on the air quality modeling analyzed in Section 3.1 and Tables 7 and 11 of the report, none of the proposed alternatives would exceed a South Coast Air Quality Management District (SCAQMD) threshold regarding emissions of criteria pollutants.

Using single-end dump trucks for the crushing operation (Alternative 1) would result in lesser emissions of every criteria pollutant compared to the use of bobtail dump trucks.

For Alternative 2, if the removal operation was completed during one summer recess period, using single-end dump trucks would result in less overall pollutant emissions Packet Page. 414
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than using bobtail dump trucks.

If the operation was completed over two summer recess periods, using single-end dump trucks would result in less emissions of NOx, SO2, PM10, and PM2.5, though ROG and CO emissions would be higher compared to the use of bobtail dump trucks. For all alternatives under Alternative 2, using single-end dump trucks over the course of two summer recess periods (Alternative 2.2.2) would result in less pollutant emissions.

Alternative 2.2.2 would also result in less overall pollutant emissions than Alternative

1.2, crushing onsite and using single-end dump trucks.

Though all alternatives for both crushing onsite and hauling the unprocessed material to an offsite facility would result in pollutant emissions well below regional thresholds, the use of single-end dump trucks would result in less emissions. Additionally, using single-end dump trucks to haul the unprocessed concrete debris offsite to be crushed (Alternative 2) would result in lesser pollutant emissions.

However, Alternative 3 would not include off-site truck hauling, and emissions would be less than Alternatives 1 and 2. Alternative 3 would therefore be considered the environmentally superior alternative.

Based on Table 13 of the report, Localized Significance of Emissions, none of the alternatives would exceed the SCAQMD localized screening threshold; therefore, none of the alternatives would affect human health or worsen local air quality at the nearest sensitive receptors. As is the case with pollutant emissions, using single-end dump trucks for Alternative 1 (crushing onsite) would result in less emissions at a locally significant level than using bobtail dump trucks. For Alternative 2, using single-end dump trucks over either one or two summers would result in less emissions. Overall, using single-end dump trucks over a period of two summer breaks would result in reduced emissions. Because Alternative 3 would not include a hauling operation, it would result in the least emissions and would be considered the superior alternative.

None of the alternatives would result in the generation of a carbon monoxide hotspot, nor would they conflict with or obstruct implementation of the AQMPs.

It is concluded that Alternative 3, crushing onsite and containing onsite, would result in the least air quality emissions.

Health Risk
Based on the calculations in the Health Risk Assessment and the results in Table 16, Carcinogenic Risk Assessment, none of the alternatives would generate TAC exposure-related cancer risk in exceedance of the SCAQMD’s thresholds. All of the alternatives would result in a negligible increase in cancer risk levels at nearby sensitive receptors compared to existing conditions. As noted in the Health Risk Assessment, the cancer risk levels analyzed do not imply that an exposed individual would contract cancer; rather, the cancer risk is a probability of developing cancer if other factors (i.e., heredity, exposure to environmental or workplace risks that Packet Page. 415
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compromise the immune system, and overall health) would result in an increased susceptibility to developing cancer.

Using single-end dump trucks for Alternative 1 would result in slightly lower cancer risk levels than using bobtail dump trucks. For Alternative 2.1, hauling to crush offsite during one summer recess period, using single-end dump trucks would result in lower cancer risk levels. For Alternative 2.2, which would utilize two summer recess periods, using single-end dump trucks would also result in lower cancer risk levels. In regard to Alternative 2 overall, completing the removal process during one summer would result in less cancer risk levels, because it would involve a shorter exposure duration.

Between using single-end dump trucks for Alternative 1 or Alternative 2, Alternative 1 would result in lower cancer risk levels. However, Alternative 3 would not include off- site truck hauling, and would generate less DPM exhaust, when compared to Alternatives 1 and 2. Alternative 3 would therefore result in the least cancer risk levels and would be considered the environmentally superior alternative.

Based on the calculations in the Health Risk Assessment and the results in Table 17, Chronic Hazard Assessment, none of the alternatives would generate a TAC exposure- related chronic hazard index in exceedance of the SCAQMD’s thresholds. All of the alternatives would result in a negligible chronic hazard index at nearby sensitive receptors compared to existing conditions. As noted in the Health Risk Assessment, a hazard index less than or equal to 1 indicates that non-carcinogenic health effects are not likely to occur over a lifetime of exposure.

Using single-end dump trucks for Alternative 1 would result in a slightly lower chronic hazard index than using bobtail dump trucks. For Alternative 2.1, hauling to crush offsite during one summer recess period, using single-end dump trucks would result in lower cancer risk levels. For Alternative 2.2, which would utilize two summer recess periods, using single-end dump trucks would also result in a lower chronic hazard index. In regard to Alternative 2 overall, completing the removal process during one summer recess period would result in lower chronic hazard indices, because it would involve a shorter exposure duration. Between using single-end dump trucks for Alternative 1 or Alternative 2, Alternative 1 would generally result in lower chronic hazard indices, by a small margin. Because Alternative 3 would not include a hauling operation and the associated DMP exhaust, Alternative 3 would result in the lowest chronic hazard indices.

It is concluded that Alternative 3, crushing onsite and containing onsite, would result in the lowest cancer risk levels and chronic hazard indices, due to no truck hauling operations.

Noise
Alternatives 1 and 3 would inherently result in higher noise levels from operation activities due to the use of a crusher and associated equipment onsite, compared to Alternative 2. Based on the noise measurements and calculations included in Section

3.3 and the results in Table 21, Maximum Operation Noise Levels, Alternatives 1 and Packet Page. 416
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3 would not generate noise levels in exceedance of the Federal Transit Administration’s thresholds for residential noise levels. It is concluded that Alternative 2 would result in lower noise levels overall, however, Alternatives 1 and 3 would not result in significant impacts related to noise.

As shown in Table 22, Typical Operation Equipment Vibration Levels, none of the equipment types required for either alternative would generate groundborne vibration in exceedance of the Caltrans thresholds for human annoyance or older residential uses. Therefore, Alternatives 1, 2 and 3 would not result in significant impacts related to vibration.
2021-2025 Strategic Targets and Goals
The removal of the Oxbow debris pile aligns with Mayor and City Council Goal No. 3 – Improved Quality of Life – in that the removal of the debris will improve the quality of life for the residents of Palm Avenue and areas surrounding the project site and improve air quality. The debris had been a constant source of complaints regarding air quality in the area.

Fiscal Impact
Conclusion
It is recommended that the Mayor and City Council of the City of San Bernardino, California, take the following actions:

1. Adopt Resolution No. 2025-378 of the Mayor and City Council of the City of San Bernardino, California, rescinding Resolution No. 2020-265, which prohibits the crushing of concrete on site within 1,000 feet of residentially zoned property; and

2. Review the three alternatives in the Oxbow Debris Removal Project

FINANCIAL
DATA
Current Fiscal Year: Next Fiscal Year: Total Cost: Ongoing Cost:

COST $ 78,000 +
$13,500
$ $ 91,500+
cost for
community
outreach
$

GENERAL
FUND
SHARE
$ 91,500 +
cost for
community
outreach
$ $ $
SOURCE OF FUNDS:

General Fund
Budget Adjustment:

No
For Fiscal Year: 24/25
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Environmental Study dated May 22, 2025, select Alternative 3 which is concluded to result in least levels of impact among the three alternatives, and adopt Resolution No. 2025- 379 memorializing that decision; and

3. Direct the City Manager or his designee to prepare a public outreach program for the residents of Ward 5, regarding the removal of the Ox Bow Debris.

Attachments
Attachment 1 City Council Resolution No. 2020-265
Attachment 2 City Council Resolution No. 2025-378 Rescinding City Council Resolution No. 2020-265
Attachment 3 City Council Resolution 2025-379 Adopting Alternative 3 Attachment 4 Oxbow Debris Removal Project Environmental Report.

Attachment 5 2020 Clearance Report for Concrete
Attachment 6 2025 Clearance Report for Concrete PowerPoint Presentation
Ward:

Fifth Ward
Synopsis of Previous Council Actions:

On October 21, 2020, the City Council adopted Resolution No. 2020-265 regarding San Bernardino Municipal Code Section 19.70.0202(2) under which the TUP was approved.

CC: Eric Levitt, City Manager
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Resolution No. 2025-378
Resolution No. 2025-378
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RESOLUTION NO. 2025-378

RESOLUTION OF THE MAYOR AND CITY COUNCIL OF

THE CITY OF SAN BERNARDINO, CALIFORNIA,
REPEALING RESOLUTION NO. 2020-265 OF THE MAYOR

AND CITY COUNCIL OF THE CITY OF SAN

BERNARDINO ESTABLISHING GUIDANCE RELATING

TO THE ISSUANCE OF TEMPORARY USE PERMITS

ALLOWING ON-SITE AND OFF-SITE CONTRACTORS'

CONSTRUCTION YARDS DEVELOPMENT PROJECTS

WHICH PROHIBITS CRUSHING OF CONCRETE WITHIN
1000 FEET OF RESIDENTIALLY ZONED PROPERTIES.

WHEREAS, in 2009, the Oxbow development, located at 6920 Palm Avenue, was approved by the City of San Bernardino under Tentative Tract Map 16794 which subdivided an existing 18.45-acre parcel into 43-single family lots with minimum lot sizes of 10,882 square feet.

WHEREAS, the topography of the site requires the import of dirt to flatten certain parts of the site and create buildable lots (grading).

WHEREAS, in July 2020, the property owner was issued a Temporary Use Permit (TUP 20-033), with conditions, to import approximately 3,000 truckloads and about 60,000 tons of concrete from a demolished, fire-damaged Amazon warehouse building located at 2255 W.

Lugonia Avenue in Redlands; and
WHEREAS, in response to complaints from the residents of Palm Avenue and Ward 5, in general, the City of San Bernardino commissioned an environmental study to determine the best alternative to remove the debris; and
WHEREAS, the City entered into a contract with CSG Consultants in March 2025, to provide a comprehensive analysis of the options available to the city for the removal of the Oxbow debris; and
WHEREAS, in May of 2025, CSG, in collaboration with Kimley-Horn, completed the report and proposed three alternatives for the removal of the Ox Box debris; and WHEREAS, the Mayor and City Council, after careful study, has elected to select an option from the Environmental Study prepared by CSG in collaboration with Kimley-Horn which would allow crushing of concrete onsite;
WHERES, in order to crush concrete onsite, Resolution No. 2020-265 has to be repealed;

BE IT RESOLVED BY THE MAYOR AND CITY COUNCIL OF THE CITY OF SAN BERNARDINO AS FOLLOWS:

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SECTION 1. The above recitals are true and correct and are incorporated herein by this reference.

SECTION 2. That the decision of the Mayor and City Council adopting one of the alternatives for the disposal of the debris pile is based on an exhaustive analysis provided by CSG and Kimley-Horn specifically for the Oxbox development site located at 6920 Palm Avenue.

SECTION 3. CEQA. The Mayor and City Council finds this Resolution is not subject to the California Environmental Quality Act (CEQA) in that the activity is covered by the general rule that CEQA applies only to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty, as in this case, that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.

SECTION 4. Severability. If any provision of this Resolution or the application thereof to any person or circumstance is held invalid, such invalidity shall not affect other provisions or applications, and to this end the provisions of this Resolution are declared to be severable.

SECTION 5. Effective Date. This Resolution shall become effective immediately.

APPROVED and ADOPTED by the City Council and signed by the Mayor and attested by the City Clerk this 15th day of October 2025.

Helen Tran, Mayor
City of San Bernardino
Attest:

Telicia Lopez, CMC, City Clerk
Approved as to form:

Sonia Carvalho, City Attorney
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CERTIFICATION

STATE OF CALIFORNIA )
COUNTY OF SAN BERNARDINO) ss

CITY OF SAN BERNARDINO )
I, Telicia Lopez, CMC, Acting City Clerk, hereby certify that the attached is a true copy of Resolution No. 2025-378, adopted at a regular meeting held on the 15 th day of October 2025, by the following vote:

Council Members: AYES NAYS ABSTAIN ABSENT
SANCHEZ _____ _____ _______ _______
IBARRA _____ _____ _______ _______
FIGUEROA _____ _____ _______ _______
SHORETT _____ _____ _______ _______
KNAUS _____ _____ _______ _______
FLORES _____ _____ _______ _______
ORTIZ _____ _____ _______ _______
WITNESS my hand and official seal of the City of San Bernardino this __ day of _____ 2025.

Telicia Lopez, CMC, Acting City Clerk
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RESOLUTION NO. 2025-379

RESOLUTION OF THE MAYOR AND CITY COUNCIL OF

THE CITY OF SAN BERNARDINO, CALIFORNIA,
SELECTING ALTERNATIVE 3 FROM THE OXBOW

DEBRIS REMOVAL PROJECT ENVIRONMENTAL STUDY

PREPARED BY CSG CONSULTANTS AND KIMLEY-HORN

FOR THE REMOVAL OF THE OXBOW DEBRIS LOCATED
AT 6920 PALM AVENUE.

WHEREAS, in 2009, the Oxbow development, located at 6920 Palm Avenue, was approved by the City of San Bernardino under Tentative Tract Map 16794 which subdivided an existing 18.45-acre parcel into 43-single family lots with minimum lot sizes of 10,882 square feet.

WHEREAS, the topography of the site requires the import of dirt to flatten certain parts of the site and create buildable lots (grading).

WHEREAS, in July 2020, the property owner was issued a Temporary Use Permit (TUP), with conditions, to import approximately 3,000 truckloads and about 60,000 tons of concrete from a demolished, fire-damaged Amazon warehouse building located at 2255 W. Lugonia Avenue in Redlands; and
WHEREAS, the materials were to be used for future on-site grading; and WHEREAS, on August 4, 2020, the Public Works Department issued a Haul Permit (Permit # H20-002) to transport the stockpile from Redlands to the project site; and WHEREAS, On January 15, 2021, the City issued a Notice of Revocation of the TUP and Notice to Abate because the transported stockpile was left uncovered and generated dust; and WHEREAS, in response to complaints from the residents of Palm Avenue and Ward 5, in general, the City of San Bernardino commissioned an environmental study to determine the best alternative to remove the debris; and
WHEREAS, the City entered into a contract with CSG Consultants in March 2025, to provide a comprehensive analysis of the options available to the city for the removal of the Oxbow debris; and
WHEREAS, in May of 2025, CSG, in collaboration with Kimley-Horn, completed the report and proposed three alternatives for the removal of the Ox Box debris; and WHEREAS, the Mayor and City Council now want to adopt one of the recommendations in the report that would allow for the crushing of the debris on-site.

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BE IT RESOLVED BY THE MAYOR AND CITY COUNCIL OF THE CITY OF SAN BERNARDINO AS FOLLOWS:

SECTION 1. The above recitals are true and correct and are incorporated herein by this reference.

SECTION 2. That the decision of the Mayor and City Council adopting one of the alternatives for the disposal of the debris pile is based on an exhaustive analysis provided by CSG and Kimley-Horn specifically for the Oxbox development site located at 6920 Palm Avenue.

SECTION 3. CEQA. The Mayor and City Council finds this Resolution is not subject to the California Environmental Quality Act (CEQA) in that the activity is covered by the general rule that CEQA applies only to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty, as in this case, that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.

SECTION 4. Severability. If any provision of this Resolution or the application thereof to any person or circumstance is held invalid, such invalidity shall not affect other provisions or applications, and to this end the provisions of this Resolution are declared to be severable.

SECTION 5. Effective Date. This Resolution shall become effective immediately.

APPROVED and ADOPTED by the City Council and signed by the Mayor and attested by the City Clerk this 15th day of October 2025.

Helen Tran, Mayor
City of San Bernardino
Attest:

Telicia Lopez, CMC, City Clerk
Approved as to form:

Sonia Carvalho, City Attorney
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Resolution No. 2025-379
Resolution No. 2025-379
October 15, 2025

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3 0
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Resolution No. 2025-379
Resolution No. 2025-379
October 15, 2025

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3 0

CERTIFICATION

STATE OF CALIFORNIA )
COUNTY OF SAN BERNARDINO) ss

CITY OF SAN BERNARDINO )
I, Telicia Lopez, CMC, Acing City Clerk, hereby certify that the attached is a true copy of Resolution No. 2025-379, adopted at a regular meeting held on the 15 th day of October 2025 by the following vote:

Council Members: AYES NAYS ABSTAIN ABSENT
SANCHEZ _____ _____ _______ _______
IBARRA _____ _____ _______ _______
FIGUEROA _____ _____ _______ _______
SHORETT _____ _____ _______ _______
KNAUS _____ _____ _______ _______
FLORES _____ _____ _______ _______
ORTIZ _____ _____ _______ _______
WITNESS my hand and official seal of the City of San Bernardino this ___day of ___ 2025.

Telicia Lopez, CMC, Acting City Clerk
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FINAL DRAFT
Prepared by:

CSG CONSULTANTS
3707 W. Garden Grove Boulevard,
Suite 100
Orange, California 92868
Contact: Glenn Lajoie, AICP
MAY 22, 2025
Prepared for:

City of San Bernardino
201 North E Street
San Bernardino, CA 92401
Contact: Gabriel Elliott
Director of Community Development
& Housing
Oxbow Debris Removal Project
Environmental Study
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Table of Contents

SECTION PAGE
Executive Summary ...................................................................................................................... 1 Project Summary .................................................................................................................................... 1 Analysis.................................................................................................................................................. 2 Conclusions and Recommendations ....................................................................................................... 3 1 Project Description ................................................................................................................ 7

1.1 Introduction .......................................................................................................................... 7

1.2 Project Location .................................................................................................................... 7

1.3 Existing Conditions Onsite ..................................................................................................... 7

1.4 Project Site History ................................................................................................................ 9

1.5 Debris Pile Characteristics .................................................................................................. 10

1.6 Existing Conditions in the Site Vicinity .................................................................................. 10 2 Debris Removal/Modifications Alternatives ........................................................................... 15

2.1 Alternative 1 – Crush Onsite and Haul Offsite ....................................................................... 15

2.2 Alternative 2 – Haul Concrete to Offsite Processing Facility ................................................... 18

2.3 Alternative 3 – Crush and Retain Material Onsite ................................................................... 21 3 Technical Analysis ............................................................................................................... 24

3.1 Air Quality ........................................................................................................................... 24

3.2 Health Risk Assessment ...................................................................................................... 38

3.3 Noise .................................................................................................................................. 55

3.4 Truck Routing ...................................................................................................................... 65 4 Conclusions and Recommendations ..................................................................................... 71

4.1 Conclusions ........................................................................................................................ 71

4.2 Recommendations .............................................................................................................. 72

APPENDICES
Appendix A - Air Quality Data
Appendix B – Health Risk Assessment Modeling Data
Appendix C – Noise Data
Appendix D – Truck Routing

EXHIBITS
Exhibit 1. Regional Vicinity Map ............................................................................................................... 8 Exhibit 2. Conditions Along Palm Avenue Map ........................................................................................ 14 Exhibit 3. Sensitive Receptors ............................................................................................................... 58 Exhibit 4. Noise Measurement Locations ............................................................................................... 60 Exhibit 5. City of San Bernardino Proposed Regulatory Truck Routes ....................................................... 67 Exhibit 6. City of Rialto Truck Routes ...................................................................................................... 68 Exhibit 7. Proposed Truck Route ............................................................................................................ 70 Packet Page. 432
TABLES
Table 1. Truck Hauling Summary ........................................................................................................... 21 Table 2. Ambient Air Quality Data .......................................................................................................... 25 Table 3. Sensitive Receptors ................................................................................................................. 26 Table 4. South Coast Air Quality Management District Significance Thresholds ....................................... 26 Table 5. Alternative 1 Equipment ........................................................................................................... 28 Table 6. Alternative 1 Daily Haul Truck Trips and Vehicle Miles Traveled .................................................. 29 Table 7. Alternative 1 Pollutant Emissions .............................................................................................. 30 Table 8. Alternative 2 Operations Equipment ......................................................................................... 31 Table 9. Alternative 2 Daily Haul Truck Trips and Vehicle Miles Traveled .................................................. 32 Table 10. Alternative 2 Daily Loaded Haul Truck Trips ............................................................................. 32 Table 11. Alternative 2 Pollutant Emissions ............................................................................................ 33 Table 12. Alternative 3 Equipment ......................................................................................................... 34 Table 13. Localized Significance of Emissions ........................................................................................ 36 Table 14. Sensitive Receptors ................................................................................................................ 41 Table 15. Exposure Assumptions ........................................................................................................... 49 Table 16. Carcinogenic Risk Assessment ............................................................................................... 52 Table 17. Chronic Hazard Assessment .................................................................................................. 54 Table 18. Sensitive Receptors ................................................................................................................ 57 Table 19. Existing Noise Measurements ................................................................................................. 59 Table 20. Project Operations Equipment Noise Levels ............................................................................ 61 Table 21. Maximum Project Operation Noise Levels ............................................................................... 63 Table 22. Typical Equipment Vibration Levels ......................................................................................... 65 Packet Page. 433
Executive Summary
Project Summary
The Oxbow Debris Removal Project site is located in the Verdemont neighborhood of the City of San Bernardino, at 6920 Palm Avenue. The Project site is in a residential area and is located approximately 40 feet west of the nearest residential use, and approximately 2,425 feet north of Palm Avenue Elementary School. Sensitive receptors are located to the south and east of the Project site, which is located in the southern foothills of the San Bernardino Mountains.

The proposed Project includes the processing and removal of the existing concrete debris pile located onsite, either through a crushing operation that would occur onsite, or through a hauling operation that would transport the concrete debris to a material recycling facility. The concrete debris pile consists of the remnants of an Amazon warehouse and distribution center that was located in the City of Redlands and was destroyed by fire in 2020. In 2020, the Project site owner at the time had the concrete debris hauled to the Project site with the intention of crushing it onsite to be used as fill for future residential development. Shortly after this operation occurred, the property changed ownership, and the new owner did not intend to use the concrete onsite.

Beginning in September 2020, neighbors living in the residential area immediately adjacent to the Project site expressed concerns about health and safety hazards created by the concrete debris, including fugitive dust and debris. In October 2020, samples from the debris pile were analyzed for the presence of toxic substances and hazardous materials. The report concluded that the concrete debris does not contain hazardous materials.

In February 2021, the City requested consent to abate form in order to address the public nuisance conditions on the property, however no form was executed. The City obtained an abatement warrant in March 2021; however, the City Council did not approve an agreement with the abatement service provider in April 2021. No further work was done on the Project site, and no grading permit to crush onsite was ever obtained. City staff have since requested that a white paper be drafted to determine the impacts of grinding and crushing grading materials within City limits, and a site-specific environmental review of methods to remove or clean up the concrete debris pile from the Project site. As of May 2025, if feasible, the current property owner has considered using the crushed concrete material onsite as fill for future residential development.

This environmental study considers three main alternatives, as described below. Alternatives 1 and 2 would result in the material being hauled offsite as either processed or unprocessed concrete, which would require truck hauling trips to occur along Palm Avenue. Due to the proximity of Palm Avenue Elementary School, it is recommended that the hauling operation for Alternatives 1 and 2 occur during the school’s summer recess period (approximately early June to early August), to limit safety concerns associated with truck travel along Palm Avenue. Additionally, the hauling operation could be completed through the use of either bobtail dump trucks or single-end dump trucks. Bobtail dump trucks are smaller and would require a greater number of truck trips, however, single-end dump trucks are long and could be more difficult to maneuver around the Project site. Alternatives 1 and 2 include sub-alternatives that consider the use of either bobtail or single-end dump trucks. For Alternatives 1 and 2, it is anticipated that the concrete would be hauled to the Rialto Recycle Yard, owned and operated by ARCOSA Crushed Concrete, located at 250 East Santa Ana Avenue, Rialto. Alternative 3 involves crushing the material onsite and retaining it onsite, to be used as fill for future residential development.

Alternative 3 does not include a hauling operation. The Project site is currently undeveloped, and grading and site preparation would be required for all three alternatives in order to provide site access and allow for equipment to be located onsite.

Alternative 1
Alternative 1 involves crushing the concrete debris onsite, then hauling the processed concrete offsite to a recycling center. This alternative would require the use of a crusher, breaker, front-end loader, street sweeper, loaders, and hauling trucks. The breaker would be used to break the concrete debris into smaller chunks for placement in the crusher, the front-end loader would load the material into the crusher, and the loaders would Packet Page. 434
move the processed concrete from the pile created by the crusher, into the hauling trucks. It is anticipated that the processed concrete would be approximately 33,600 cubic yards of material. Alternative 1.1 includes the use of bobtail dump trucks for the hauling operation. In order to complete the removal process during one summer recess period using bobtail dump trucks, Alternative 1.1 would require 400 truck trips per day along Palm Avenue (200 loaded, 200 empty), and would take approximately 38 working days to complete. Alternative 1.2 includes the use of single-end dump trucks, which would take approximately 35 working days to complete and would require 162 hauling trips per day on Palm Avenue (81 loaded, 81 empty).

Alternative 2
Alternative 2 involves hauling the unprocessed concrete debris offsite to be processed at the Rialto Recycle Yard. This alternative would require the use of a street sweeper, loaders, hauling trucks, and possibly a small bobcat breaker to break the debris into smaller pieces to fit in the hauling trucks. The unprocessed concrete is anticipated to contain approximately 42,000 cubic yards of material. Therefore, it would take longer to remove from the Project site than the processed concrete, which would contain approximately 33,600 cubic yards of material. Alternative 2.1 involves removing the entire concrete debris pile over one summer recess period.

Alternative 2.1.1 includes the use of bobtail dump trucks, which would require 520 hauling truck trips per day along Palm Avenue (260 loaded, 260 empty) and would take approximately 36 working days to complete.

Alternative 2.1.2 includes the use of single-end dump trucks, which would require 200 hauling truck trips per day (100 loaded, 100 empty) and would take approximately 35 working days to complete.

Alternative 2.2 involves removing the concrete debris pile over two summer recess periods, to decrease the number of required truck trips along Palm Avenue during each summer. Between the two summer recess periods, the remaining concrete debris pile would have to be covered in order to limit the potential for fugitive dust and debris in the surrounding area. Alternative 2.2.1 involves the use of bobtail dump trucks, which would require 264 hauling trips per day on Palm Avenue (132 loaded, 132 empty) and would take approximately 71 working days to complete. Alternative 2.2.2 includes the use of single-end dump trucks, which would require 98 hauling truck trips per day (49 loaded, 49 empty) and would take approximately 72 working days to complete.

Alternative 3
Alternative 3 is a variation of Alternative 1, with the crushing operation occurring onsite, and no hauling operation. Under Alternative 3, the crushed material would remain onsite for future use as onsite infill for residential development on the property. Alternative 3 would require the use of a breaker, front-end loader, and crusher. The breaker would be used to break the concrete pieces into smaller pieces for processing. The loader would move the debris into the crusher, which would create piles of processed concrete material around the Project site. Alternative 3 would require a Containment Plan to ensure that the processed concrete is contained between the time it is processed and when it is used for fill, in order to limit dust emissions. It is anticipated that it would take approximately three to four months to crush the entire concrete debris pile, assuming no equipment breakdowns or delays.

Analysis
This environmental study includes the following technical analyses in order to determine potential environmental impacts of the proposed Project: an air quality analysis, health risk assessment, noise analysis, and truck routing memorandum. The air quality analysis evaluated the anticipated air quality and fugitive dust emissions related to each alternative as a result of the required equipment and number of truck hauling trips. The health risk assessment evaluated the potential for each alternative to expo se sensitive receptors to cancer risks and non -carcinogenic health impacts associated with diesel particulate matter that would be generated by the required equipment and hauling trucks. The noise analysis modeled the anticipated noise levels to be generated by the operation of the equipment and trucks associated with each alternative. The truck routing memorandum determined the safest and most direct route to be used by the hauling trucks in Alternatives 1 and 2, between the Project site and the Rialto Rec ycle Yard. The results of the technical analyses were used to determine the anticipated air quality and noise impacts of each alternative, Packet Page. 435
and conclude which alternative is environmentally superior. The conclusions of the analyses are presented below. Recommendations are also included in order to reduce potential impacts related to noise, air quality, and safety to the greatest extent feasible.

Conclusions and Recommendations
Conclusions
Air Quality
Based on the air quality modeling analyzed in Section 3.1 and Tables 7 and 11, none of the proposed alternatives would exceed a SCAQMD threshold regarding emissions of criteria pollutants. Using single-end dump trucks for the crushing operation (Alternative 1) would result in lesser emissions of every criteria pollutant compared to the use of bobtail dump trucks. For Alternative 2, if the removal operation was completed during one summer recess period, using single-end dump trucks would result in less overall pollutant emissions than using bobtail dump trucks.

If the operation was completed over two summer recess periods, using single-end dump trucks would result in less emissions of NO
x, SO2, PM10, and PM2.5, though ROG and CO emissions would be higher compared to the use of bobtail dump trucks. For all alternatives under Alternative 2, using single-end dump trucks over the course of two summer recess periods (Alternative 2.2.2) would result in less pollutant emissions. Alternative

2.2.2 would also result in less overall pollutant emissions than Alternative 1.2, crushing onsite and using single- end dump trucks.

Though all alternatives for both crushing onsite and hauling the unprocessed material to an offsite facility would result in pollutant emissions well below regional thresholds, the use of single-end dump trucks would result in less emissions. Additionally, using single-end dump trucks to haul the unprocessed concrete debris offsite to be crushed (Alternative 2) would result in lesser pollutant emissions. However, Alternative 3 would not include off-site truck hauling, and emissions would be less than Alternatives 1 and 2. Alternative 3 would therefore be considered the environmentally superior alternative.

Based on Table 13, Localized Significance of Emissions, none of the alternatives would exceed the SCAQMD localized screening threshold; therefore, none of the alternatives would affect human health or worsen local air quality at the nearest sensitive receptors. As is the case with pollutant emissions, using single-end dump trucks for Alternative 1 (crushing onsite) would result in less emissions at a locally significant level than using bobtail dump trucks. For Alternative 2, using single-end dump trucks over either one or two summers would result in less emissions. Overall, using single-end dump trucks over a period of two summer recesses would result in reduced emissions. Because Alternative 3 would not include a hauling operation, it would result in the least emissions and would be considered the superior alternative.

None of the alternatives would result in the generation of a carbon monoxide hotspot, nor would they conflict with or obstruct implementation of the AQMPs.

It is concluded that Alternative 3, crushing onsite and containing onsite, would result in the least air quality emissions.

Health Risk
Based on the calculations in the Health Risk Assessment and the results in Table 1 6, Carcinogenic Risk Assessment, none of the alternatives would generate TAC exposure -related cancer risk in exceedance of the SCAQMD’s thresholds. All of the alternatives would result in a negligible increase in cancer risk levels at nearby sensitive receptors compared to existing conditions. As noted in the Health Risk Assessment, the cancer risk levels analyzed do not imply that an exposed individual would contract cancer; rather, the cancer risk is a probability of developing cancer if other factors (i.e., heredity, exposure to environmental or Packet Page. 436
workplace risks that compromise the immune system, and overall health) would result in an increased susceptibility to developing cancer.

Using single-end dump trucks for Alternative 1 would result in slightly lower cancer risk levels than using bobtail dump trucks. For Alternative 2.1, hauling to crush offsite during one summer recess period, using single-end dump trucks would result in lower cancer risk levels. For Alternative 2.2, which would utilize two summer recess periods, using single -end dump trucks would also result in lower cancer risk levels. In regard to Alternative 2 overall, completing the removal process during one summer woul d result in less cancer risk levels, because it would involve a shorter exposure duration. Between using single -end dump trucks for Alternative 1 or Alternative 2, Alternative 1 would result in lower cancer risk levels. However, Alternative 3 would not include off-site truck hauling, and would generate less DPM exhaust, when compared to Alternatives 1 and 2. Alternative 3 would therefore result in the least cancer risk levels and would be considered the environmentally superior alternative.

Based on the calculations in the Health Risk Assessment and the results in Table 17, Chronic Hazard Assessment, none of the alternatives would generate a TAC exposure-related chronic hazard index in exceedance of the SCAQMD’s thresholds. All of the alternatives would result in a negligible chronic hazard index at nearby sensitive receptors compared to existing conditions. As noted in the Health Risk Assessment, a hazard index less than or equal to 1 indicates that non-carcinogenic health effects are not likely to occur over a lifetime of exposure.

Using single-end dump trucks for Alternative 1 would result in a slightly lower chronic hazard index than using bobtail dump trucks. For Alternative 2.1, hauling to crush offsite during one summer recess period, using single- end dump trucks would result in lower cancer risk levels. For Alternative 2.2, which would utilize two summer recess periods, using single-end dump trucks would also result in a lower chronic hazard index. In regard to Alternative 2 overall, completing the removal process during one summer recess period would result in lower chronic hazard indices, because it would involve a shorter exposure duration. Between using single-end dump trucks for Alternative 1 or Alternative 2, Alternative 1 would generally result in lower chronic hazard indices, by a small margin. Because Alternative 3 would not include a hauling operation and the associated DMP exhaust, Alternative 3 would result in the lowest chronic hazard indices.

It is concluded that Alternative 3, crushing onsite and containing onsite, would result in the lowest cancer risk levels and chronic hazard indices, due to no truck hauling operations.

Noise
Alternatives 1 and 3 would inherently result in higher noise levels from operation activities due to the use of a crusher and associated equipment onsite, compared to Alternative 2. Based on the noise measurements and calculations included in Section 3.3 and the results in Table 21, Maximum Operation Noise Levels, Alternatives 1 and 3 would not generate noise levels in exceedance of the Federal Transit Administration’s thresholds for residential noise levels. It is concluded that Alternative 2 would result in lower noise levels overall, however, Alternatives 1 and 3 would not result in significant impacts related to noise.

As shown in Table 22, Typical Operation Equipment Vibration Levels, none of the equipment types required for either alternative would generate groundborne vibration in exceedance of the Caltrans thresholds for human annoyance or older residential uses. Therefore, Alternatives 1, 2 and 3 would not result in significant impacts related to vibration.

Recommendations
Environmental Considerations
Based on the technical analyses in Section 3 and the results described above, Alternative 3 is concluded to result in lesser levels of impacts among the alternatives. For hauling offsite, Alternative 2, including crushing offsite and using single-end dump trucks for the hauling operation, would result in less impacts related to air quality and Packet Page. 437
noise. Specifically, Alternative 2.2.2, using single-end dump trucks to haul the concrete debris offsite over two summer recess periods, would result in less pollutant emissions. Alternative 2.2.2 would result in marginally higher cancer risk levels and chronic hazard indices than Alternatives 1 and 3, however, the levels and indices would be well below the SCAQMD threshold for all of the alternatives. It is concluded that Alternative 3 is the recommended and preferred alternative, with Alternative 2.2.2 recommended as the preferred alternative for offsite hauling, based on impact conclusions for air quality and noise. It is noted that all alternatives would result in less than significant impacts with regard to air quality, including health risks, and noise.

Additional Recommendations
All Alternatives:
• To the extent feasible, employee parking and truck staging areas (Alternatives 1 and 2) shall be designated with signage at the northern end of Palm Avenue to reduce congestion along Palm Avenue near the Project site.
• Pursuant to Municipal Code Section 8.54.070, construction related activities related to all Alternatives, and particularly Alternatives 1 and 3, should be limited to daylight hours of operation (7:00 AM to 8:00 PM) in consideration of the residential uses in close proximity to the site. - To the extent feasible, truck hauling activities associated with Alternatives 1 and 2 should primarily occur outside of identified commute times and school drop-off and pick-up windows. • In compliance with state law (Section 2485 and Section 2449 of Title 13 of the California Code of Regulations), the contractor will be required to limit diesel truck/equipment idling to no more than five minutes.

Alternatives 1 and 2:
• Due to increased cubic yard capacity, single-end dump trucks should be utilized for the hauling operation, to the greatest extent possible. The greater hauling capacity would result in significantly fewer truck trips per day on Palm Avenue and would therefore reduce safety risks associated with truck trips.
• Enhanced safety measures should be utilized with regard to truck travel along Palm Avenue, including safety signage, flagmen, safety personnel, cones, and reduced speed zones in proximity to Palm Avenue Elementary School, Tom Minor Park, and other areas of heightened local activity along the roadway.

Temporary stop signs should be placed at the driveways of the Project site when hauling trucks and other equipment enter and exit the site.
• For the hauling operation, most of the removal operation should occur during the school’s summer recess to limit potential safety concerns with regard to truck travel along Palm Avenue, to the extent feasible.
- Grading and site preparation activities should occur during the school year, in advance of the summer recess.
• The applicant should coordinate with the City of San Bernardino to determine if approval and/or a permit is needed to use Palm Avenue as a truck hauling route. • Haul trucks should enter the site via the north driveway on Palm Avenue, near the north side of the Project site. Truck staging should be completely onsite in order to prevent any truck queuing from spilling out onto Palm Avenue and affecting nearby residents using Palm Avenue. Trucks should circulate onsite and exit the site via the south driveway on Palm Avenue, near the south side of the Project site. In order to accommodate the Project operations, the two existing driveway access points would need to be graded and/or leveled with adequate width to allow for both ingress and egress of trucks and hauling of equipment.
• The applicant should coordinate with the City of San Bernardino to temporarily add truck restriction signs that prohibit trucks from parking and stopping along Palm Avenue adjacent to the Project site. This would help prevent trucks from queuing along Palm Avenue.

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Alternatives 1 and 3:
• For the crushing operation, the Lokotrack Urban LT96 is recommended to minimize dust emissions and noise to the greatest extent feasible. The Urban LT96 crusher includes dust covers and a dust suppression system that uses high-pressure water sprays inside the crusher chamber and at the end of the conveyor to prevent dust when aggregates are unloaded. The Urban LT96 dust suppression system results in an approximately 85 percent reduction in dust emissions. The LT96 is also designed for quieter operation, with up to 60 percent noise reduction compared to conventional crushers. The Urban LT96 uses noise covers that provide noise suppression across several points, including the main conveyor beneath the crushing mechanism.
- It is noted that the technical analyses included herein conservatively used the Lokotrack LT106 mobile jaw crusher to calculate emissions and noise levels, and use of the LT106 would not generate emissions or noise levels in exceedance of applicable thresholds. However, due to the proximity of sensitive receptors, the Lokotrack Urban LT96 with additional dust suppression is recommended considering the site’s historical dust nuisances and potential noise nuisances for nearby receptors.

Alternative 1:
• Processed, crushed debris should not be stockpiled onsite. Crushed debris should be immediately removed to limit onsite stockpiles and potential new dust sources, particularly resulting from local wind events. As such, the crusher should be operated at a rate that is commensurate with the pace that the specific haul trucks can export the material.

Alternative 3:
• If Alternative 3 is selected as the preferred alternative, a Containment Plan to mitigate and assure that crushed material does not result in dust emission nuisance to area residents will be required. The Containment Plan shall be prepared by the Project Applicant for development of the Project site and is subject to approval by the City of San Bernardino, prior to starting site preparation for the crushing operation. The Containment Plan may include, but not be limited to, the following requirements:
- The debris should be covered with a durable heavy-duty plastic sheeting or geotextile fabric and the following actions should be taken to ensure that the debris cover remains effective:
 Regular inspections: Regularly inspect the covering for damage or wear and tear and make repairs as needed, particularly after periods of heavy rain or high winds.  Ensure Secure Coverage: Properly secure the coverings to prevent them from blowing away or becoming damaged, especially during windy conditions.
 Adjust Covering: Adjust the covering as necessary to accommodate any changes in the debris pile or weather conditions.

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1 Project Description

1.1 Introduction
The following is a review of environmental considerations for the removal of the Oxbow debris pile, located at 6920 Palm Avenue in the City of San Bernardino. The review considers scenarios for removal and a scenario to retain crushed material onsite. The study concludes with optional actions and recommendations for the City to proceed forward with removal.

1.2 Project Location
The City of San Bernardino is located in the southwestern portion of San Bernardino County, California, north of the City of Riverside, south of the San Bernardino Mountains, east of the City of Rancho Cucamonga, and northwest of the City of Redlands. The proposed Project involves removal of debris at 6920 Palm Avenue, which is in the Verdemont neighborhood of northern San Bernardino. The Project site is located on an 18.45-acre property immediately west of Palm Avenue, in the foothills of the San Bernardino Mountains, at the southern end of Bailey Canyon and near the northern terminus of Palm Avenue. Refer to Exhibit 1, Regional Location.

Surrounding conditions include residential uses immediately to the east of Palm Avenue, which also occur south along both sides of Palm Avenue for approximately one mile. San Bernardino National Forest is situated immediately north of the Project site. Palm Avenue Elementary School is adjacent to the east side of Palm Avenue, approximately 2,425 feet south of the Project site. Tom Minor Park is also located on the east side of Palm Avenue, approximately 3,290 feet south of the Project site. Generations Church is approximately 4,000 feet south of the Project site, east of Palm Avenue. Uses to the west of the Project site consist of undeveloped land with low to moderate vegetative cover.

1.3 Existing Conditions Onsite
The 18.45-acre Project site is vacant and undeveloped. The onsite existing condition is dominated by a large, approximately five-story high concrete debris pile, located in the northern portion of the property. The concrete debris pile consists of building materials, unprocessed concrete, rubble, and garbage from an Amazon warehouse distribution facility that was destroyed in a fire. Fabric coverings were placed on top of the debris pile in 2021 and have since been shredded by weather conditions. Remnants of this fabric occur throughout the debris pile and around the property. A chain link fence is located along the property perimeter, including along Palm Avenue. Ingress and egress is provided, with one unpaved driveway located along Palm Avenue. The property generally slopes southwest, with varying topography across the site.

The Project site currently has a General Plan Land Use designation of Residential Low (RL), for single-family detached residences in a low density setting of 3.1 dwelling units per acre and is zoned Residential Low (RL). As of February 2025, the City is continuing the draft preparation of SanBernardino2050, a planning initiative, which includes an update to the General Plan and an update to the Development Code. In March 2023, the proposed SanBernardino2050 Land Use Plan became available for public review, and adoption of the General Plan Update is pending. Based on the proposed Land Use Plan, the Project site General Plan Land Use designation would be modified to Rural/Estate Neighborhood (RR), intended for single-family homes, accessory dwelling units, public facilities such as parks and schools, and development at a maximum of one dwelling unit per acre.

The corresponding proposed zoning for the Project site would be Residential Estate (RE), which permits one dwelling unit per acre.
1 1 City of San Bernardino. 2023. Proposed General Plan Land Use Plan Classifications. March 14. https://futuresb2050.com/wp- content/uploads/2023/03/Proposed_LUP_classifications_REVISED_03.13.23.pdf. Accessed January 29, 2025.

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1.4 Project Site History
On June 5, 2020, an approximately 600,000 square-foot Amazon warehouse and distribution facility, located at 2255 West Lugonia Avenue in the City of Redlands, was destroyed by fire. The warehouse was used for housing and shipping of “extra-large” items. It is anticipated that items in the warehouse included televisions, refrigerators, couches, mattresses, treadmills, and related items.2 In July 2020, the subject site property owner at the time requested a haul permit from the City of San Bernardino in order to transport the concrete debris remains from the warehouse site to the Palm Avenue site. The applicant for the entitlement of the 18.45-acre subject site reported an interest in utilizing concrete that would be crushed onsite, for incorporation into the onsite material and fill for future residential development on the Project site. The Project site was proposed to be divided into 44 parcels, including 43 parcels for single-family residences and one parcel for a water retention basin. The concrete debris was unprocessed at the time of transport and was intended to be processed onsite. 3 The City issued the haul permit in August 2020, which permitted a maximum of six haul trucks to be used for the transport operation, a maximum of eight to ten truck loads per day, and allowed trucking only between 7:30 AM and 3:30 PM on weekdays, and the permit expired after 20 working days. 4 In September 2020, neighbors living in the residential area immediately adjacent to the Project site expressed concerns about health and safety hazards created by the concrete debris. Residents were concerned about the legality of the dumping operation, degradation of Palm Avenue from hauling truck operations, whether or not the operation was compliant with the appropriate regulations, and if the concrete debris contained toxic materials.

Concerns were also raised regarding dust and particulate matter blowing from the debris pile and into residential areas.

It is further noted that the City is subject to extremely high winds, the most significant of which occur at the canyon mouths and valleys extending downslope from the San Bernardino Mountains. The highest velocities are associated with downslope canyon and Santa Ana winds, which can reach 90-100 miles per hour. The Project site is located within a City-designated “High Wind Area”. 5 The presence of the uncovered concrete debris
stockpile onsite presents safety and health concerns related to the distribution of dust and other debris during high wind events.

In October 2020, three samples from the debris pile were submitted to be analyzed for the presence of asbestos, volatile organic compounds (VOCs) and CAM metals, which are heavy metals defined by the California Administrative Manual and include antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium, and zinc. ENCORP Environmental Management and Services conducted the testing and the report was submitted by a Certified Industrial Hygienist. The report concluded that no asbestos or VOCs are present in the concrete material, and the concrete does not contain hazardous levels of CAM metals. The Certified Industrial Hygienist determined that the concrete debris does not contain hazardous materials and could be crushed and used as a fill base for the site.
6 In October 2020, the City Council passed a Resolution (Resolution No. 2020-265) which imposed restrictions on the onsite crushing or grinding of unfinished raw materials within 1,000 feet of residentially zoned property under a temporary use permit or a grading permit. Pursuant to this resolution, stockpiling could only occur on or near a residentially zoned site if the materials were already processed. As a result, the planned crushing of the concrete debris did not occur and the concrete debris remained stockpiled at the subject site. In September 2 Fausto, Alma and Brian Rokos. 2020. Redlands Daily Facts. “Massive fire tears through warehouse in Redlands.” June 5. https://www.redlandsdailyfacts.com/2020/06/05/firefighters-battle-massive-warehouse-blaze-in-redlands-part-of-10-freeway- closed/. Accessed January 29, 2025.
3 Written communication. Letter from Eric Cernich of Oxbow SB 44 LLC to City of San Bernardino Public Works Permits. July 30, 2020. 4 City of San Bernardino Haul Permit No. H20-00002. Issued to Oxbow Partners on August 5, 2020. 5 City of San Bernardino General Plan Safety Element. Page 10-35. 2005. 6 Written correspondence. ENCORP. Letter from William Bohning, Certified Associate Industrial Hygienist to Tim Greenleaf Engineering. October 26, 2020.

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2020, the property changed ownership. The current property owner may not use the concrete debris for grading material or any other purpose onsite. In January 2021, the temporary use permit for the Project site was revoked because Best Management Practices (BMPs), which include covering the debris pile to prevent the spread of dust and debris particles, were not being followed to minimize impacts to surrounding uses. In addition, the continued presence of the debris pile was in violation of multiple sections of the San Bernardino Municipal Code.7 In February 2021, the City requested consent to abate form in order to address the public nuisance conditions on the property, however no form was executed. The City obtained an abatement warrant in March 2021; however, the City Council did not approve an agreement with the abatement service provider in April 2021. No further work was done on the Project site, and no grading permit to crush onsite was ever obtained. The City has continued to receive numerous complaints via emails and phone calls from nearby residents during heavy wind events, including the following:8
• Dust, sand, and debris being blown around the neighborhood and impacting air quality; • Poor air quality impacting residents in the neighborhood who have asthma and other breathing related illnesses;
• The concrete debris potentially having silica dust that could contribute to negative health impacts to the neighborhood;
• Debris being blown against cars and causing damage;
• Airborne sediment ending up in nearby pools; and
• Heavy winds shredding and blowing the tarp material that had been used to cover the stockpile at one point around the neighborhood.

City staff have since requested that a white paper be drafted to determine the impacts of grinding and crushing grading materials within City limits, and a site-specific environmental review of methods to remove or clean up the concrete debris pile from the Project site.
9 As of May 2025, if feasible, the current property owner has considered using the crushed concrete material onsite as fill for future residential development.

1.5 Debris Pile Characteristics
The concrete debris pile contains approximately 41,496 cubic yards of material. The transport of the concrete debris from the warehouse site in Redlands to the Project site required 2,964 truckloads, using six hauling trucks, five days per week, with a maximum of eight to ten loads per day.10 A proposal received from a licensed demolition and abatement contractor in 2024 regarding the removal, loading, hauling and offsite processing of the material estimated up to 3,000 loads would be required for the approximately 60,000 tons of concrete.11 Removal of the concrete debris would disturb approximately 4.10 acres of the site.

1.6 Existing Conditions in the Site Vicinity
The Project site is located adjacent to Palm Avenue to the east, near the northern terminus of the roadway. Palm Avenue is the only roadway that provides access to the Project site. Regional access to the Project site is provided by Interstate 215. Exit 50, along Interstate 215, provides direct access to Palm Avenue. The subject site is located approximately 1.3 miles from the freeway.

According to the current 2005 General Plan, Palm Avenue, from Interstate 215 to Ohio Avenue, is designated a secondary arterial roadway, and a collector arterial, continuing north of the Ohio Avenue intersection. Palm Avenue is considered a major north-south street in the area as it provides access beyond the freeway for the 7 Declaration of Community and Economic Development Director Michael Huntley. 8 Declaration of Community and Economic Development Director Michael Huntley. 9 Written communication. Email from City of San Bernardino Assistant City Manager to Deputy City Manager and Director of Public Works. January 18, 2024.
10 Written communication. Letter from Tim Greenleaf Engineering to Eric Cernich of Oxbow SB 44 LLC. N.d. 11 Resource Environmental, Inc. Proposal No. 7393 for Removal and Crushing of Concrete at Oxbow Site. January 19, 2024.

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Verdemont Heights neighborhood. The intersection of Exit 50 and Palm Avenue has a stoplight and no crosswalks. Vehicles southbound on Palm Avenue can enter westbound Interstate 215 at this stoplight.

Southbound vehicles on Palm Avenue, heading eastbound on Interstate 215, must cross under the freeway and make a protected left turn onto the eastbound onramp, south of the freeway. The intersection of eastbound Exit 50 and Palm Avenue also has a stoplight and no crosswalks.

Beginning at the westbound offramp of Interstate 215, Palm Avenue is a two -lane roadway with two additional turn lanes, one right and one left, at the intersection of Palm Avenue and Kendall Drive. This intersection has a stoplight and four crosswalks. Use s between the offramp and the Kendall Drive intersection include commercial uses on both sides, with sidewalks along both sides of Palm Avenue and no driveways. North of the Kendall Drive intersection, a drainage channel occurs that has gated driveway acce ss on both sides of Palm Avenue.

San Bernardino County Fire Station 232 is located east of Palm Avenue approximately 5,217 feet south of the Project site and has two driveway access points off Palm Avenue. Other uses between the Kendall Drive intersection and Washington Street include residential uses, with two ingress/egress points on the east side of Palm Avenue. This section of Palm Avenue is comprised of four lanes, including two southbound and two northbound lanes. Sidewalks and parallel parking are provided on both sides of Palm Avenue.

Washington Street intersects Palm Avenue with a stop sign. No turn lanes are present on Palm Avenue at the Washington Street intersection. Between the Washington Street intersection and the Irvington Avenue intersection, Palm Avenue remains a four-lane roadway with sidewalks on both sides. Left turn lanes are present at the Irvington Avenue intersection, which includes a four-way stoplight and crosswalks on all sides.

Uses between Washington Street and Irvington Avenue include residential uses on the west side and Generations Church on the east side.

Worship service at Generations Church occurs on Sundays at 10:00 AM, and youth services occur on Sundays at 5:30 PM. A variety of other services are offered at the Church on weekdays, including Men’s Ministry, Bible Study, and Branch Church Services; however, all weekday services offered occur at or after 6:00 PM. Three ingress/egress points occur along this section of Palm Avenue, two of which are on the west side for residential use, and one is located at the church site on the east side.

Uses north of Irvington Avenue include single-family residential uses to the west and east, as well as Tom Minor Park on the east side of Palm Avenue. Tom Minor Park includes open grassy areas, a playground, splash pad, and picnic areas. The park is open every day of the week from 9:00 AM to 5:00 PM. Between the Irvington Avenue and Belmont Avenue West intersections, four residential driveways occur on the west side of Palm Avenue, and six residential ingress/egress points occur on the east side of Palm Avenue. This section of Palm Avenue has sidewalks on both sides and has four lanes, until the rightmost northbound lane becomes a right-turn-only lane at the Belmont Avenue West intersection. The Belmont Avenue West intersection includes a four-way stop with stop signs and crosswalks on all sides.

North of Belmont Avenue West, Palm Avenue becomes a two-lane roadway with parallel parking allowed on both sides of the road. Uses between Belmont Avenue West and Akron Street on the west side of Palm Avenue include residential uses with two driveways along Palm Avenue. Akron Street intersects Palm Avenue from the west with a stop sign; there are no protected turn lanes on Palm Avenue at this intersection. On the east side of Palm Avenue, north of Belmont Avenue West, is Palm Avenue Elementary School. This school is part of San Bernardino City Unified School District and is located approximately 2,425 feet south of the Project site.

The current student enrollment at Palm Avenue Elementary School is 538 students, 29 teachers, and 34 classified employees. The school serves kindergarten through sixth grade students. The school gates open at 8:30 AM, and the bell rings at 8:50 AM every morning, Monday through Friday. Some students wait outside the school before 8:30 AM. On Mondays, school ends at 1:00 PM, and at 3:30 PM Tuesday through Friday. Parents typically line up for school pick-up around 2:45 PM. An after-school program is offered Monday through Friday and ends at 6:00 PM. Additionally, the T-K students are dismissed at 12:10 PM or 12:30 PM every day of the week, and a special education bus arrives at 11:35 AM every day to pick up and drop off students. The school Packet Page. 444
also offers guitar club, chess club, and soccer, flag football, basketball, and softball programs that result in after-hours uses onsite. Based on the 2024-2025 academic year calendar for the school district, the following holidays and recess periods are observed:12
• Summer recess: June 9 – July 29; teacher workdays begin July 30, and students return to campus on August 5
• Back to school night occurs on a Thursday night in August • Labor Day is observed
• One Monday in October is observed as a vacation day
• Veterans Day is observed
• Thanksgiving recess occurs Monday through Friday the week of Thanksgiving • Winter recess occurs for three weeks, beginning the Monday before Christmas and ending the third Friday after
• Martin Luther King Jr. Day is observed in January
• Abraham Lincoln’s Birthday is observed in February
• George Washington’s Birthday is observed in February
• Spring break occurs over two weeks at the end of March/beginning of April • Memorial Day is observed
School drop-off for Palm Avenue Elementary occurs via a northbound drop-off lane immediately adjacent to Palm Avenue on the east side. The ingress point occurs approximately 116 feet north of Belmont Avenue West, and the egress point occurs approximately 300 feet north. A second driveway for the school occurs approximately 200 feet north of the drop-off lane exit, along the east side of Palm Avenue. Between Akron Street and the western portion of West Meyers Road, on the west side of Palm Avenue, there are two residential uses.

A crosswalk is located across Palm Avenue near West Meyers Road, and another crosswalk is located across West Meyers Road. West Meyers Road enters Palm Avenue from the west via a stop sign. There are no protected turn lanes on Palm Avenue at this intersection.

North of the school along the east side of Palm Avenue, the curb is reserved as a fire lane and no parallel parking is allowed. The eastern portion of West Meyers Street intersects Palm Avenue with a stop sign; there are no protected turn lanes on Palm Avenue at this intersection. The next intersection occurs at Briarwood Drive on the west side of Palm Avenue. Briarwood Drive has a stop sign, and there are no turn lanes on Palm Avenue at this intersection. No other driveways occur along Palm Avenue between Belmont Avenue West and Ohio Avenue. This section of Palm Avenue is a two-lane roadway with sidewalks on both sides. Residential uses occur along both sides of Palm Avenue.

At the Ohio Avenue intersection, located approximately 1,159 feet south of the Project site, both sides of Ohio Avenue intersect Palm Avenue with a stop sign. No stop signs or turn lanes occur along Palm Avenue at this intersection. Between Ohio Avenue and the southeast corner of the Project site, Palm Avenue is a two-lane roadway, with sidewalks along both sides. Uses on both sides of the street include single-family residential uses. Approximately 12 driveways and/or ingress/egress points occur along the west side of Palm Avenue, between Ohio Avenue and the Project site. On the east side, there are six driveways between Ohio Avenue and Garfield Avenue. Garfield Avenue enters Palm Avenue from the east and has a stop sign. Between Garfield Avenue and West Verdemont Drive, there are six additional driveways on the east side of Palm Avenue. West Verdemont Drive intersects Palm Avenue from the east, and there is a three-way stop at this intersection, including north- and south-bound Palm Avenue, and West Verdemont Drive. Between West Verdemont Drive and the northern terminus of Palm Avenue, only the east side of Palm Avenue has a sidewalk. There is no sidewalk along the eastern boundary of the Project site. 12 San Bernardino City Unified School District. 2024-2025 Traditional School Year Calendar. https://www.sbcusd.com/about- us/school-year-calendars. Accessed January 30, 2025.

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Between West Verdemont Drive and North Huntington Drive, immediately east of the Project site, are single- family residential homes. North Huntington Drive intersects Palm Avenue from the east, almost directly across from the existing dirt driveway at the Project site. North Huntington Drive has a stop sign, however there are no stop signs on Palm Avenue at this intersection. Between North Huntington Drive and North Melvin Avenue, directly east of the Project site, single-family residential uses are present. North Melvin Avenue intersects Palm Avenue from the east and has a stop sign. No other stop signs are located along Palm Avenue. One additional residential use occurs on the east side of Palm Avenue north of North Melvin Drive.

At the northeast corner of the Project site, Palm Avenue turns into a dirt road and becomes Bailey Canyon Road.

A dirt parking area is located north of the Project site at the end of Palm Avenue, which provides access to hiking trails in the foothills north of the Project site.

Between the Interstate 215 Exit 50 and Belmont Avenue West, the speed limit along Palm Avenue is 45 miles per hour. North of Belmont Avenue West, where Palm Avenue becomes a two-lane roadway, the speed limit decreases to 25 miles per hour. Streetlights occur along the entire length of Palm Avenue from Exit 50 to the northern terminus. No streetlights occur on the west side of Palm Avenue along the perimeter boundary of the Project site, however, there are overhead powerlines. There are no designated bike lanes or shoulders along Palm Avenue between Exit 50 and the northern terminus of the road. With the exception of the fire lane located in front of Palm Avenue Elementary School, both sides of Palm Avenue north of Kendall Drive allow parallel parking.

Refer to Exhibit 2 for an overview of uses and conditions along Palm Avenue.

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2 Debris Removal/Modifications Alternatives
Three methods of debris removal are under consideration. One alternative (Alternative 1) is to bring equipment to the property and to crush the concrete debris onsite, as was considered when the material was placed onsite several years ago. This option would involve extensive machinery and crushing operations which may affect the surrounding area. Rather than utilizing the crushed material onsite for future residential development grading material (which is considered in Alternative 3), the broken-down material would be transported from the site to a local concrete recycling facility.

A second alternative (Alternative 2) involves loading and hauling the entire mound of concrete debris pieces, in their current state/condition, to a designated crushing and processing facility. This method would also require heavy machinery onsite and would require a significant number of truck trips along Palm Avenue.

A third alternative (Alternative 3) has also been reviewed for consideration, which would involve the crushing operation referenced in Alternative 1. The crushed material would then be retained onsite for use as fill material when grading is initiated for a future residential community development. Alternative 3 would not involve trucking material offsite to a recycling center. The environmental review of the alternatives is presented in the sections which follow, providing further detail on assumptions, equipment use, and operations. The descriptions will then be used to analyze the level of effects for each alternative, and to determine recommendations.

2.1 Alternative 1 – Crush Onsite and Haul Offsite
Alternative 1 would involve bringing crushing equipment to the subject property, processing/crushing the entire concrete debris pile onsite, and transporting the material offsite for disposal. The process would involve the following stages:

Site Preparation
The remnants of the fabric coverings that occur throughout the debris pile area and property would need to be gathered and disposed of, in order to prepare the site and concrete debris for processing.

In order to accommodate the required crushing machinery and hauling trucks onsite, the existing dirt driveway access point would need to be graded and/or leveled to allow for ingress and egress of equipment. Also, a portion of the Project site would need to be graded and/or leveled for equipment staging and movement. The existing site conditions include variable topography, slopes to the southwest, as well as soil areas and vegetation around the concrete debris pile. The crushing equipment would need to be located on relatively level ground in order to operate properly. In addition, the site must be prepared for staging multiple pieces of equipment to move around the Project site concurrently.

Best Management Practices (BMPs) would need to be in place onsite prior to beginning the crushing operation.

BMPs would include, but would not be limited to, the following: stormwater runoff prevention measures, dust mitigation, traffic control, and rumble plates to reduce the amount of dirt and debris carried onto Palm Avenue by equipment and hauling trucks. Traffic control measures would be required at the existing site access, at a minimum, to prevent traffic safety hazards. Dust control measures may include vacuums, physical barriers, and other related options. The technique of watering material to reduce dust emissions from the site has the potential to harden the crushed concrete material, which would be counterproductive for the entire operation, and therefore watering is not an appropriate BMP for this alternative.

Equipment
The crushing operation would require the following types of equipment:

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• Breaker: A large excavator with a breaker bit attached to the machinery, in order to break the concrete debris into pieces that could fit inside the crusher.
• Front-end Loader: A front-end loader would be required to feed the broken-down concrete into the crusher.
• Crusher: A crusher machine equipped with a mobile jaw crushing device would crush the concrete material into recycled/processed concrete, which would be fed through a conveyor belt and into a pile of processed material. A Quinn Cat Metso Lokotrack LT106 model crusher would be an example to utilize.

The hauling operation would require the following types of equipment:
• Loaders: Front-end loaders would be required to load the processed material into the hauling/dump trucks. It is assumed that one loader would load a truck in 15 minutes. • Hauling/dump trucks: A fleet of hauling/dump trucks would be required to haul the processed material to an offsite concrete disposal facility.

The following types of equipment would be optional for use on the Project site:
• Street sweeper: A street sweeper could be staged onsite and used to remove debris from Palm Avenue adjacent to the Project site.

Transportation of the different types of equipment would require a truck and trailer that may require a transport permit. Depending on the model, the crusher could be approximately 41 to 70.5 feet long, which does not account for the length of the truck and trailer used for transport.

Crushing Process
Timeframe
The timeframe it would take to crush the entire concrete debris pile onsite depends on the permitted operating hours and the possibility of equipment breakdowns. The use of the heavy machinery required, particularly the breaker and crusher, could generate high levels of noise and vibration in the vicinity of the Project site. It is anticipated that it would take approximately three to four months to crush the concrete debris, assuming no equipment breakdowns and an eight-hour workday, five days per week. However, factors such as equipment malfunction, weather, operator errors, etc., could make the process take longer.

If available, the example crusher (Quinn Cat Metso Lokotrack LT106) is made in an encapsulated version called the Lokotrack Urban Series, which is designed to comply with stricter noise and dust regulations and enable crushing closer to populated areas.13 The LT96, which is the most compact urban crusher, has a maximum production range of 430 tons per hour. The LT106 has a maximum production range of 560 tons per hour.14 The LT96 is designed for quieter operation, with up to 60 percent noise reduction and 85 percent dust emissions reduction compared to conventional crushers. The Urban LT96 uses noise covers that provide noise suppression across several points, including the main conveyor beneath the crushing mechanism. The LT96 also includes a dust suppression system that includes high-pressure water sprays inside the crusher chamber and at the end of the conveyor to prevent dust from spreading when aggregates are loaded. For purposes of this analysis, it is conservatively assumed that an LT106 would be used and would process 560 tons of concrete per hour.

Existing uses along Palm Avenue include residential uses and a school, for which travel times could be impacted by the continued presence of hauling trucks along Palm Avenue. Peak commute hours are generally considered to be 7:00 AM to 10:00 AM in the mornings and 4:00 PM to 7:00 PM in the evenings, on weekdays. It is anticipated that residents living in the vicinity of the Project site commute during these hours; potential hauling truck activity on 13 Metso. Lokotrack LT106 mobile jaw crusher. Website: https://www.metso.com/portfolio/lokotrack-lt-series/lokotrack-lt106- mobile-jaw-crusher/. Accessed February 13, 2025.
14 Metso. Crushing and Screening. PDF. https://www.empire-cat.com/metso_product_guide. Accessed February 13, 2025.

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Palm Avenue could impact commute times for residents in the surrounding area. Additionally, Palm Avenue Elementary School is in session from 8:50 AM to 1:00 PM on Mondays, and until 3:30 PM Tuesday through Friday.

Student drop-off and pick-up activities therefore occur along Palm Avenue generally between 8:00 AM and 9:00 AM and 2:45 PM and 3:45 PM.

The school could potentially have children onsite from 8:00 AM to later than 3:00 PM on weekdays. In order to minimize impacts to the school related to noise and traffic, the crushing operation could potentially be limited to the school’s summer recess, which would increase the intensity of the hauling operation during a shorter period of time. The school’s summer recess is two months long, from early June to early August. This analysis assumes that the crushing operation (Alternative 1) would occur over the school’s summer break, from June to August.

The timeframe for removal would depend on the type of truck used. Bobtail dump trucks can hold approximately 4.5 cubic yards of material. Single-end dump trucks can carry up to 12 cubic yards of material, however, they are larger and would be more difficult to stage and maneuver around the Project site. Time for completion is also dependent on a number of unpredictable factors, including breakdowns, traffic delays, and weather conditions.

Alternative 1.1 Bobtail Dump Trucks
It is anticipated that the amount of processed concrete produced by the crusher would be approximately 33,600 cubic yards of material, based on an average compaction factor of 80 percent. The crushed material hauling operation could be completed through the use of 20 bobtail dump trucks with a maximum of 10 loads per truck per day. Assuming bobtail dump trucks can hold approximately 4.5 cubic yards of material and the processed concrete would contain approximately 33,600 cubic yards of material, approximately 900 cubic yards of material could be hauled offsite per day, and it would take approximately 38 working days to completely remove the concrete debris pile from the Project site. Using bobtail dump trucks in this alternative would require seven additional loaders onsite. Site preparation work should be completed prior to the start of the school’s summer recess. The crushing and hauling operation would begin at the start of the summer recess.

Under these conditions and assuming no delays as a result of weather, equipment malfunctions, or other factors, it is anticipated that the entire concrete pile could be cleared from the Project site within one summer recess period for Palm Avenue Elementary.

However, this alternative would require 400 hauling truck trips (200 loaded, 200 empty) per day on Palm Avenue. Existing uses and traffic conditions along Palm Avenue would be affected by the ongoing presence of these trucks.

Alternative 1.2 Single-End Dump Trucks
Alternatively, the crushed material hauling operation could be completed through the use of nine single-end dump trucks with a maximum of nine loads per truck per day. Assuming single-end dump trucks can hold approximately 12 cubic yards of material and the processed concrete would contain approximately 33,600 cubic yards of material, approximately 972 cubic yards of material could be hauled offsite per day, and it would take approximately 35 working days to completely remove the concrete debris pile from the Project site. Under these conditions and assuming no delays as a result of weather, equipment malfunctions, or other factors, it is anticipated that the entire concrete pile could be cleared from the Project site within one summer recess period for Palm Avenue Elementary. This option would require 162 hauling truck trips (81 loaded, 81 empty) per day on Palm Avenue, and three additional loaders on site. The trucks required for this option would be larger and more difficult to maneuver and stage around the Project site simultaneously with the crushing operation.

Operation
During the crushing operation, most of the equipment would need to maneuver around the Project site. The crusher would be staged on level ground and away from the stockpile in order to allow room for the loader to maneuver the material into the crusher. The breaker would move around the Project site to collect and break apart the larger pieces of concrete debris. The loader would then grab the pieces and move the material into the crusher. The crusher would create a pile of material at the end of the conveyor belt. The crusher and conveyor Packet Page. 450
belt would remain in the same location until the pile created by the conveyor belt is too high for the conveyor belt to empty any further. The crusher would then be moved to a new, flat location to start creating another pile of processed material, if necessary.

In order to achieve maximum efficiency, it is anticipated that hauling trucks would be operating at the same time as the crushing operation. As the processed material is piled up by the conveyor belt, the loaders would move the material from that pile into hauling trucks. As soon as each truck has a full load, it would depart from the Project site and transfer the material to the designated recycling facility. If the hauling operation occurs concurrently with the crushing operation and results in sufficient removal of the new pile each day, the crusher would remain in the same location and continue to recreate the pile of processed material in the same location.

It is anticipated that the material would be transferred to and processed at the Rialto Recycle Yard, owned and operated by ARCOSA Crushed Concrete, located at 250 East Santa Ana Avenue, Rialto. The Rialto facility is located approximately 17 miles south of the Project site. Multiple hauling trucks could be staged at the Project site at the same time, as one truck is full and leaves the site, the next truck could be loaded. Depending on the grading of the site, hauling trucks could be staged onsite, away from the crushing operation, or they could be temporarily parked adjacent to the Project site along Palm Avenue. Another possible staging location is the vacant lot at the north end of Palm Avenue, adjacent to the Project site. If the hauling trucks are staged onsite, staging areas would need to be clearly marked with signs and/or cones in order to avoid contact with the crushing activities. Safety signage for the site operations would be subject to Cal/OSHA regulations.

Additionally, safety measures would be required along Palm Avenue to minimize safety hazards associated with adjacent uses and traffic along Palm Avenue. Signage, flagmen, cones, and temporary stop signs would be required at the driveway of the Project site, when hauling trucks and other equipment enters and exits the site.

Additionally, onsite crushing activities would require a permit from the South Coast Air Quality Management District and approvals from relevant agencies, including the City’s Public Works/Engineering NPDES Department, the San Bernardino Water Department, the Community Development and Housing Department, and affected utility providers.

2.2 Alternative 2 – Haul Concrete to Offsite Processing Facility Alternative 2 involves the hauling of all of the concrete debris, as is, offsite to a designated concrete recycling facility. It is anticipated that the material would be transferred to and processed at the Rialto Recycle Yard.

Under this alternative, no crushing or processing of the stockpile would occur onsite. All of the debris would be processed and disposed of according to existing regulations and permits in the offsite facility. The process would require the following stages:

Site Preparation
The remnants of the fabric coverings that occur throughout the debris pile area and property would need to be gathered and disposed of, in order to prepare the site and concrete debris for processing.

In order to accommodate the hauling trucks onsite, the existing dirt driveway access point would need to be graded and/or leveled to allow for ingress and egress of equipment. Also, a portion of the Project site would need to be graded and/or leveled for equipment movement. The existing site conditions include variable topography, slopes to the southwest, as well as soil areas and vegetation around the concrete debris pile.

Best Management Practices (BMPs) would need to be in place onsite prior to beginning the loading operation.

BMPs would include, but would not be limited to, the following: stormwater runoff prevention measures, dust mitigation, traffic control, and rumble plates to reduce the amount of dirt and debris carried onto Palm Avenue by hauling trucks. Traffic control measures would be required at the existing site access, at a minimum, to prevent traffic safety hazards. Dust control measures may include vacuums, physical barriers, watering of the material, or other related options. However, excessive watering could result in surface runoff offsite that could result in environmental impacts.

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Equipment
The hauling operation would require the following types of equipment:
• Loaders: Front-end loaders would be required to load the processed material into the hauling/dump trucks. It is assumed that one loader would load a truck in 15 minutes. • Hauling/dump trucks: A fleet of hauling/dump trucks would be required to haul the processed material to an offsite concrete disposal facility.

The following types of equipment would be optional for use on the Project site:
• Street sweeper: A street sweeper could be staged onsite and used to remove debris from Palm Avenue adjacent to the Project site.
• Small bobcat breaker: A small breaker could be used to break down parts of the concrete debris such that it would more easily fit in the loader and hauling trucks.

Hauling Process
Timeframe
Existing uses along Palm Avenue include residential uses and a school for which travel times could be impacted by the continued presence of hauling trucks along Palm Avenue. Peak commuter hours are generally considered to be 7:00 AM to 10:00 AM in the mornings and 4:00 PM to 7:00 PM in the evenings on weekdays. It is anticipated that residents living in the vicinity of the Project site commute during these hours; potential hauling truck activity on Palm Avenue could impact commute times for residents in the surrounding area. Additionally, Palm Avenue Elementary School is in session from 8:50 AM to 1:00 PM on Mondays, and until 3:30 PM Tuesday through Friday. Student drop-off and pick-up activities therefore occur along Palm Avenue generally between 8:00 AM and 9:00 AM and 2:45 PM and 3:45 PM.

The school could potentially have children onsite or along Palm Avenue from 8:00 AM to later than 3:00 PM on weekdays. In order to minimize potential impacts to the school related to traffic, the hauling operation could potentially be limited to the school’s summer recess, which would increase the intensity of the hauling operation during a shorter period of time. The school’s summer recess is two months long, from early June to early August. This analysis assumes that the hauling operation (Alternative 2) would occur over either one summer break (Alternative 2.1), or two summer breaks (Alternative 2.2). Site preparation and grading activities should be completed before the first summer break in either alternative.

The timeframe for removal would depend on the type of truck used. Bobtail dump trucks can hold approximately 4.5 cubic yards of material. Single-end dump trucks can carry up to 12 cubic yards of material, however, they are larger and would be more difficult to stage and maneuver around the Project site. Time for completion is also dependent on a number of unpredictable factors, including breakdowns, traffic delays, and weather conditions.

Alternative 2.1 – One Summer Option
Alternative 2.1.1 – Bobtail Dump Trucks
The hauling operation could be completed through the use of 20 bobtail dump trucks with a maximum of 13 loads per truck, per day. Assuming bobtail dump trucks can hold approximately 4.5 cubic yards of material and the existing pile contains approximately 42,000 cubic yards of material, approximately 1,170 cubic yards of material could be hauled offsite per day, and it would take approximately 36 working days to completely remove the concrete debris pile from the Project site. The hauling operation would begin at the start of the summer recess. Under these conditions and assuming no delays as a result of weather, equipment malfunctions, or other factors, it is anticipated that the entire concrete pile could be cleared from the Project site within one summer recess period for Palm Elementary.

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However, this alternative would require 520 hauling truck trips (260 loaded, 260 empty) per day on Palm Avenue, and the use of nine loaders onsite. Existing uses and traffic conditions along Palm Avenue would be affected by the ongoing presence of these trucks. This alternative involves an aggressive Project schedule that would intensify impacts along Palm Avenue but would result in the completion of the removal process within one summer recess period.

Alternative 2.1.2 – Single-End Dump Trucks
Alternatively, the hauling operation could be completed through the use of 10 single-end dump trucks with a maximum of 10 loads per truck, per day. Assuming single-end dump trucks can hold approximately 12 cubic yards of material and the existing pile contains approximately 42,000 cubic yards of material, approximately 1,200 cubic yards of material could be hauled offsite per day, and it would take approximately 35 working days to completely remove the concrete debris pile from the Project site. Under these conditions and assuming no delays as a result of weather, equipment malfunctions, or other factors, it is anticipated that the entire concrete pile could be cleared from the Project site within one summer recess period for Palm Elementary.

This option would require 200 hauling truck trips (100 loaded, 100 empty) per day on Palm Avenue, and four loaders onsite.

Alternative 2.2 – Two Summers Option
In order to limit impacts on existing uses and traffic conditions along Palm Avenue, Alternative 2.2 includes dividing the hauling process into two summer recess periods.

Alternative 2.2.1 – Bobtail Dump Trucks
Under this alternative, the hauling operation could be limited to 12 bobtail hauling trucks with a maximum of 11 loads per truck, per day. Assuming bobtail dump trucks can hold 4.5 cubic yards of material and the existing pile contains approximately 42,000 cubic yards of material, approximately 594 cubic yards of material could be hauled offsite per day. As a result, it would take approximately 71 working days to remove the concrete debris pile from the Project site. Under these conditions and assuming no delays as a result of weather, equipment malfunctions, or other factors, it is anticipated that the entire concrete pile could be cleared from the Project site within two summer recess periods. This alternative would result in approximately 264 hauling truck trips (132 loaded, 132 empty) per day on Palm Avenue and would require five loaders onsite.

Alternative 2.2.2 – Single-End Dump Trucks
Alternatively, the hauling operation could be completed through the use of seven single-end dump trucks with a maximum of seven loads per truck, per day. Assuming single-end dump trucks can hold approximately 12 cubic yards of material and the existing pile contains approximately 42,000 cubic yards of material, approximately 588 cubic yards of material could be hauled offsite per day, and it would take approximately 72 working days to completely remove the concrete debris pile from the Project site. Under these conditions and assuming no delays as a result of weather, equipment malfunctions, or other factors, it is anticipated that the entire concrete pile could be cleared from the Project site within two summer recess periods. This option would result in approximately 98 hauling truck trips (49 loaded, 49 empty) per day on Palm Avenue and would require two loaders onsite. Single-end dump trucks are larger and could be more difficult to stage and maneuver around the Project site.

Operation
Loaders would be used to move the material from the existing debris pile into the hauling trucks. It is anticipated that it would take approximately 15 minutes to load one truck. As soon as each truck has a full load, it would depart from the Project site and transport the unprocessed material to the Rialto recycling facility. Multiple hauling trucks could be staged at the Project site at the same time, as one truck is full and leaves the site, the next truck can be loaded. Depending on the grading of the site, hauling trucks could be staged onsite, or they could be temporarily parked adjacent to the Project site along Palm Avenue. Another possible staging location is the vacant lot at the north end of Palm Avenue, adjacent to the Project site. If the hauling trucks are staged Packet Page. 453
onsite, staging areas would have to be clearly marked with signs and/or cones in order to avoid contact with the truck being loaded, and trucks entering the site. Safety signage for the site operations would be subject to Cal/OSHA regulations. Additionally, safety measures would be required along Palm Avenue to minimize safety hazards associated with adjacent uses and traffic along Palm Avenue. Signage, flagmen, cones, and temporary stop signs would be required at the driveway of the Project site, when hauling trucks enter and exit the site.

The concrete debris would be transported to the Rialto Recycle Yard located at 250 East Santa Ana Avenue. The recycling facility is located approximately 17 miles south of the Project site. The hauling truck drivers would follow a designated travel route in order to maximize efficiency within approved truck routes between the Project site and the recycling facility. Once unloaded, the concrete debris would be crushed and processed according to existing regulations and permits for the facility.

Under Alternative 2.2, the concrete debris that would remain onsite between the first and second summers would need to be covered in order to reduce impacts related to dust emissions. The debris should be covered with a durable heavy-duty plastic sheeting or geotextile fabric and the following actions should be taken to ensure that the debris covers remain effective:
• Regular inspections: Regularly inspect the covering for damage or wear and tear and make repairs as needed, particularly after periods of heavy rain or high winds. • Ensure Secure Coverage: Properly secure the coverings to prevent them from blowing away or becoming damaged, especially during windy conditions.
• Adjust Covering: Adjust the covering as necessary to accommodate any changes in the debris pile or weather conditions.

Table 1, Truck Hauling Summary, compares the truck trips and hauling quantities for each alternative and hauling option.

Table 1.

Truck Hauling Summary
Alternative 1:

Crushing
Alternative 2: Non-Crushing
Alternative 2.1
One Summer Option
Alternative 2.2
Two Summers Option
Bobtail Single-End Bobtail Single-End Bobtail Single-End Trucks 20 9 20 10 12 7
Loads/Truck/Day 10 9 13 10 11 7
Trucks/Day 200 81 260 100 132 49
Truck Trips/Day 400 162 520 200 264 98
Capacity
(CY/Truck) 4.5 12 4.5 12 4.5 12
CY Removed/Day 900 972 1,170 1,200 594 588
Approximate Days 38 35 36 35 71 72
* CY = cubic yards

2.3 Alternative 3 – Crush and Retain Material Onsite
Alternative 3 is a variation of Alternative 1, with the crushing operation serving as a key feature. Alternative 1 would result in hauling crushed material to an offsite facility. Alternative 3 differs from Alternative 1 in that the crushed material would remain onsite for future use as onsite infill for residential development on the property.

The use of loading equipment into haulers and truck transport of materials offsite would not occur with Alternative 3. This alternative involves the following stages:

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Site Preparation
The remnants of the fabric coverings that occur throughout the debris pile area and property would need to be gathered and disposed of, in order to prepare the site and concrete debris for processing.

In order to accommodate the required crushing machinery and hauling trucks onsite, the existing dirt driveway access point would need to be graded and/or leveled to allow for ingress and egress of equipment. Also, a portion of the Project site would need to be graded and/or leveled for equipment staging and movement. The existing site conditions include variable topography, slopes to the southwest, as well as soil areas and vegetation around the concrete debris pile. The crushing equipment would need to be located on relatively level ground in order to operate properly. In addition, the site must be prepared for staging multiple pieces of equipment to move around the Project site concurrently.

Best Management Practices (BMPs) would need to be in place onsite prior to beginning the crushing operation.

BMPs would include, but would not be limited to, the following: stormwater runoff prevention measures and dust mitigation. Dust control measures may include vacuums, physical barriers, and other related options. The technique of watering material to reduce dust emissions from the site has the potential to harden the crushed concrete material, which would be counterproductive for the entire operation, and therefore watering is not an appropriate BMP for this alternative.

Equipment
The crushing operation would require the following types of equipment:
• Breaker: A large excavator with a breaker bit attached to the machinery, in order to break the concrete debris into pieces that could fit inside the crusher.
• Front-end Loader: A front-end loader would be required to feed the broken-down concrete into the crusher.
• Crusher: A crusher machine equipped with a mobile jaw crushing device would crush the concrete material into recycled/processed concrete, which would be fed through a conveyor belt and into a pile of processed material. A Quinn Cat Metso Lokotrack LT106 model crusher would be an example to utilize.

Transportation of the different types of equipment would require a truck and trailer that may require a transport permit. Depending on the model, the crusher could be approximately 41 to 70.5 feet long, which does not account for the length of the truck and trailer used for transport.

Crushing Process
Timeframe
The timeframe it would take to crush the entire concrete debris pile onsite depends on the permitted operating hours and the possibility of equipment breakdowns. The use of the heavy machinery required, particularly the breaker and crusher, could generate high levels of noise and vibration in the vicinity of the Project site. It is anticipated that it would take approximately three to four months to crush the concrete debris, assuming no equipment breakdowns and an eight-hour workday, five days per week. However, factors such as equipment malfunction, weather, operator errors, etc., could make the process take longer.

If available, the example crusher (Quinn Cat Metso Lokotrack LT106) is made in an encapsulated version called the Lokotrack Urban Series, which is designed to comply with stricter noise and dust regulations and enable crushing closer to populated areas.
15 The LT96, which is the most compact urban crusher, has a maximum 15 Metso. Lokotrack LT106 mobile jaw crusher. Website: https://www.metso.com/portfolio/lokotrack-lt-series/lokotrack-lt106- mobile-jaw-crusher/. Accessed February 13, 2025.

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production range of 430 tons per hour. The LT106 has a maximum production range of 560 tons per hour.16 The LT96 is designed for quieter operation, with up to 60 percent noise reduction and 85 percent dust emissions reduction compared to conventional crushers. The Urban LT96 uses noise covers that provide noise suppression across several points, including the main conveyor beneath the crushing mechanism. The LT96 also includes a dust suppression system that includes high-pressure water sprays inside the crusher chamber and at the end of the conveyor to prevent dust from spreading when aggregates are loaded. For purposes of this analysis, it is conservatively assumed that an LT106 would be used and would process 560 tons of concrete per hour.

Operation
During the crushing operation, most of the equipment would need to maneuver around the Project site. The crusher would be staged on level ground and away from the stockpile in order to allow room for the loader to maneuver the material into the crusher. The breaker would move around the Project site to collect and break apart the larger pieces of concrete debris. The loader would then grab the pieces and move the material into the crusher. The crusher would create a pile of material at the end of the conveyor belt. The crusher and conveyor belt would remain in the same location until the pile created by the conveyor belt is too high for the conveyor belt to empty any further. The crusher would then be moved to a new, flat location to start creating another pile of processed material.

Onsite crushing activities would require a permit from the South Coast Air Quality Management District and approvals from relevant agencies, including the City’s Public Works/Engineering NPDES Department, the San Bernardino Water Department, the Community D evelopment and Housing Department, and affected utility providers.

If this alternative is selected as the preferred alternative, a material containment plan for stockpiling crushed material onsite will be required by the property applicant, subject to approval by the City of San Bernardino. The containment plan will need to be in place and approved, prior to implementing the crushing process. The plan will need to assure and mitigate any potential for dust nuisance effects to surrounding residents. The containment plan is anticipated to maintain the crushed material in place, onsite, until the residential development project grading and site development are initiated. 16 Metso. Crushing and Screening. PDF. https://www.empire-cat.com/metso_product_guide. Accessed February 13, 2025.

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3 Technical Analysis
The following technical studies were conducted to determine potential impacts related to the proposed alternatives: air quality analysis, health risk assessment, noise analysis, and truck routing memorandum. The results of these studies are described below.

3.1 Air Quality
Environmental Setting
Local Air Quality
The Project site is located within the SCAQMD and the South Coast Air Basin (SCAB). The SCAQMD is the regulatory agency responsible for improving air quality within Orange County and portions of Los Angeles, Riverside, and San Bernardino Counties. The air pollutants regulated by SCAQMD are known as “criteria air pollutants” and include ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), sulfur oxides (SOX), and reactive organic gases (ROG). The SCAB is a distinct geographic subarea within the SCAQMD’s jurisdiction.

The SCAQMD maintains a network of air quality monitoring stations throughout the SCAB to measure historical, existing, and projected ambient pollutant concentrations.17 The criteria air pollutants of concern in the SCAB are O3, PM10, and PM2.5. The nearest air monitoring station to the Project site that monitors ambient concentrations of O3, PM10, and PM2.5 is the Crestline Monitoring Station (located approximately 4.9 miles to the northeast). Table 2, Ambient Air Quality Data summarizes the local air quality data from 2021 to 2023 (the latest currently available), including the monitored maximum concentrations and annual exceedances of California Ambient Air Quality Standards (CAAQS) or National Ambient Air Quality Standards (NAAQS). 17 These stations usually measure pollutant concentrations ten feet above ground level; therefore, air quality is often referred to in terms of ground-level concentrations.

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Table 2.

Ambient Air Quality Data
Criteria Pollutant 2021 2022 2023
Ozone (O3)1
1-hour Maximum Concentration (ppm) 0.148 0.143 0.142
8-hour Maximum Concentration (ppm) 0.120 0.122 0.111
Number of Days Standard Exceeded
CAAQS 1-hour (>0.09 ppm) 65 61 44
NAAQS 8-hour (>0.070 ppm) 110 100 91
Carbon Monoxide (CO)2
1-hour Maximum Concentration (ppm) 1.966 1.749 1.607
Number of Days Standard Exceeded
NAAQS 1-hour (>35 ppm) 0 0 0
CAAQS 1-hour (>20 ppm) 0 0 0
Nitrogen Dioxide (NO2)2
1-hour Maximum Concentration (ppm) 0.056 0.053 0.056
Number of Days Standard Exceeded
NAAQS 1-hour (>0.100 ppm) 0 0 0
CAAQS 1-hour (>0.18 ppm) 0 0 0
Particulate Matter Less Than 10 Microns (PM10)1
National 24-hour Maximum Concentration (μg/m3) 33.4 49.1 29.8 State 24-hour Maximum Concentration (μg/m3) 28.2 41.5 25.2 National Annual Average Concentration (μg/m3) 16.4 14.7 16.0 Number of Days Standard Exceeded
NAAQS 24-hour (>150 μg/m3) 0 * 0
CAAQS 24-hour (>50 μg/m3) * * *
Particulate Matter Less Than 2.5 Microns (PM2.5)1
National 24-hour Maximum Concentration (μg/m3) * * *
State 24-hour Maximum Concentration (μg/m3) 24.8 * *
National Annual Average Concentration (μg/m3) * * *
Number of Days Standard Exceeded
NAAQS 24-hour (>35 μg/m3) * * *
Source: All pollutant measurements are from the CARB Aerometric Data Analysis and Management system database (https://www.arb.ca.gov/adam) except for CO, which were retrieved from the CARB Air Quality and Meteorological Information System (https://www.arb.ca.gov/aqmis2/aqdselect.php).

NAAQS = National Ambient Air Quality Standards; CAAQS = California Ambient Air Quality Standards; ppm = parts per million; *= insufficient data available.
1 Measurements were taken at the Crestline Monitoring Station located at 24171 Lake Drive, Crestline, CA 92325 (ARB #36181) 2 Measurements were taken at the San Bernardino Monitoring Station located at 24302 East 4th Street, San Bernardino, CA 92410 (ARB #36203)
Sensitive Receptors
Sensitive populations are more susceptible to the effects of air pollution than the general population. Sensitive receptors that are near localized toxics sources are of particular concern. Land uses considered sensitive receptors include residences, schools, playgrounds, childcare centers, long-term health care facilities, Packet Page. 458
rehabilitation centers, convalescent centers, and retirement homes. The nearest sensitive receptors to the disturbance area are listed in Table 3, Sensitive Receptors.

Table 3.

Sensitive Receptors
Sensitive Receptor1 Distance2 and Direction from the Disturbance Area 1-Residential Uses 40 feet to the east
2-Residential Uses 114 feet to the southeast
3-Residential Uses 600 feet to the south
4-Residential Uses 893 feet to the southwest
5-Palm Avenue Elementary School 2,425 feet to the south Source: Google Earth, 2025
1 The residential uses listed above are the nearest sensitive receptors surrounding the disturbance area and are representative of the existing environment between the disturbance area and the Palm Avenue Elementary School. 2 Distance measured from the disturbance area to the nearest sensitive receptor property line.

Regulatory Setting
South Coast Air Quality Management District Thresholds
The SCAQMD CEQA Air Quality Handbook provides significance thresholds for ROG, nitrogen oxides (NOx), CO, SOX, PM10, and PM2.5. The thresholds shown in Table 4, South Coast Air Quality Management District Significance Thresholds, apply to debris disposal activities within the SCAQMD. If the SCAQMD thresholds are exceeded, a significant air quality impact may occur, and additional analysis is warranted to fully assess the significance of impacts. However, as the Lead Agency under CEQA, the City ultimately determines the significance thresholds for impacts.

Table 4.

South Coast Air Quality Management District Significance Thresholds Pollutant Mass Daily Thresholds (pounds per day)
Debris Disposal Operations
Volatile Organic Compounds (VOC)1 75
Nitrogen Oxides (NOx) 100
Carbon Monoxide (CO) 550
Sulfur Oxides (SOx) 150
Coarse Particles (PM10) 150
Fine Particles (PM2.5) 55
Source: South Coast Air Quality Management District, South Coast AQMD Air Quality Significance Thresholds, March 2023. 1 VOCs and reactive organic gases (ROGs) are subsets of organic gases emitted from the incomplete combustion of hydrocarbons or other carbon-based fuels. Although they represent slightly different subsets of organic gases, they are used interchangeably for the purposes of this analysis.

City of San Bernardino General Plan
The City’s General Plan includes a Safety Element and Natural Resources and Conservation Element that establishes goals and policies to protect residents from locally generated emissions.

Safety Element
The following goal and policy are applicable to the Project:

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Goal 10.1 Protect the environment, public health, safety, and welfare from hazardous wastes.

Policy 10.1.2 Ensure the protection of surface and groundwater quality, land resources, air quality, and environmentally sensitive areas through safe transportation of waste through the City and comprehensive planning of hazardous materials, wastes, and sites.

Natural Resources and Conservation Element
The following goal and policies are applicable to the Project:

Goal 12.5 Promote air quality that is compatible with the health, wellbeing, and enjoyment of life.

Policy 12.5.1 Reduce the emission of pollutants including carbon monoxide, oxides of nitrogen, photochemical smog, and sulfate in accordance with South Coast Air Quality Management District (SCAQMD) standards.

Policy 12.5.3 Require dust abatement measures during grading and construction operations. (LU-1).

Air Quality Impacts
Regional Emissions
Project related pollutant emissions are short-term and of temporary duration, lasting only as long as debris removal activities occur, and would be considered a significant air quality impact if the criteria pollutant emissions exceed the SCAQMD’s thresholds of significance; see Table 4 above. The criteria pollutants of primary concern within the Project area are ozone-precursor pollutants (i.e., VOC and NOX), PM10, and PM2.5.

Debris removal activities would require minimal grading along the existing dirt driveway and to level a portion of the disturbance area to accommodate for equipment staging and movement. Once the grading has been completed, then the debris removal activities would be able to commence.

Alternative 1: Crushing and Hauling Offsite
Alternative 1 would generate short-term criteria pollutant emissions from onsite equipment exhaust and off-site and onsite haul truck exhaust. In addition, Alternative 1 would generate fugitive dust (airborne particulate matter) emissions from earthmoving activities such as grading, ground disturbance activities on unpaved (onsite) and paved (off-site) surfaces such as haul truck and operations equipment movement, concrete crushing activities, and debris loading activities. Fugitive dust emissions are largely dependent on weather conditions and the appropriate application of water (on unpaved onsite travel surfaces)18, and may have a substantial, temporary impact on local air quality.

The Metso Lokotrack Urban LT96 crusher includes dust encapsulation doors (dust covers). The Urban LT96 dust covers and dust suppression system that includes high-pressure water sprays inside the crusher chamber and at the end of the conveyor to prevent dust from spreading when aggregates are unloaded. This system results in an approximately 85 percent reduction in dust emissions.19 This analysis conservatively did not apply the dust reduction from the Urban LT96 but includes standard dust control measures required by SCAQMD Rule 403.

SCAQMD Rule 403 requires fugitive dust sources to implement Best Available Control Measures (BACM) for all sources, and all forms of visible particulate matter are prohibited from crossing any property line. Specifically, Rule 403 dust control BACM were applied to onsite unpaved road dust (i.e., limiting onsite haul-truck speeds 18 Watering concrete debris for dust suppression should be done minimally as excessive watering can cause clumping. The water molecules attract and bind fine concrete particles, making them heavier and more prone to sticking together and settling out of the air. This effectively reduces the amount of airborne dust but can create larger, clumped debris. 19 Metso, Lokotrack Urban Series Mobile Crushing Plant With Noise and Dust Encapsulation, June 2022.

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and watering onsite roads. Watering dust control was not assumed for debris stockpiles. Emissions from each source are described in further detail below.
• Onsite Equipment Exhaust: Emissions were calculated using the California Air Resources Board’s (CARB) OFFROAD model emission rates for the anticipated operations equipment. The OFFROAD model captures the latest off-road operations assumptions, including emission inventories, equipment population, and activity data collected by CARB. The anticipated equipment to be used is shown in Table 5, Alternative 1 Equipment.

Table 5.

Alternative 1 Equipment
Operations
Phase Equipment Number Hours/Day Horsepower Load Factor Alternative 1.1: Bobtail Dump Trucks
Grading Grader 91 8 148 0.41
Removal
Crusher 1 3.52 300 0.85
Breaker 1 3.52 257 0.38
Loader 13 3.52 300 0.36
Loader 73 8 300 0.36
Bobcat Breaker 1 8 71 0.37
Street Sweeper 1 8 134 0.46
Alternative 1.2: Single-End Dump Trucks
Grading Grader 91 8 148 0.41
Removal
Crusher 1 3.52 300 0.85
Breaker 1 3.52 257 0.38
Loader 13 3.52 300 0.36
Loader 33 8 300 0.36
Bobcat Breaker 1 8 71 0.37
Street Sweeper 1 8 134 0.46
Source: Operations equipment based on input from CSG Consultants. Horsepower and load factor based on input from CSG consultants and CalEEMod User Guide Appendix G, Table G-12, Horsepower and Load Factors for Construction Equipment by Fuel Type, 2022.
1 It is assumed that a grader would disturb half an acre per day. It is conservatively assumed that the Project would grade 4.1 acres daily; therefore, grading activities would require nine graders. 2 It is assumed that crushing operations would occur every day of the removal period. Given that the LT106 would process 560 tons of concrete hourly, it is assumed the crusher operations would only occur for 3.5 hours daily to process enough concrete for the haul trucks.
3 A loader would load the broken concrete into the crusher. Additional loaders would be required to load the processed concrete into the haul trucks. It is assumed that a loader would load a truck in 15 minutes. The number of additional loaders was based on the number of daily loaded haul truck trips. Alternative 1.1 would require 200 daily loaded haul truck trips and Alternative 1.2 would require 81 daily loaded haul truck trips.
• Off-Site Haul Truck Exhaust: Emissions from haul truck trips were calculated using CARB’s EMission FACtor 2021 (EMFAC) model emission rates, daily truck trip estimates, and vehicle miles traveled (VMT) estimates. The daily truck trip and VMT estimates are shown in Table 6, Alternative 1: Daily Haul Truck Trips and Vehicle Miles Traveled.

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Table 6.

Alternative 1 Daily Haul Truck Trips and Vehicle Miles Traveled Alternative Daily Haul Truck Trips Daily Vehicle Miles Traveled1 Alternative 1.1: Bobtail Dump Trucks 400 6,800
Alternative 1.2: Single-end Dump Trucks 162 2,754
1 It is conservatively assumed the haul trucks would travel from the Rialto Recycling Yard to the disturbance area. • Onsite Haul Truck Exhaust: Emissions from idling haul trucks were calculated using CARB’s EMFAC model idling emission rates and the daily loaded haul truck trips estimates. Alternative 1.1 would require 200 daily loaded haul truck trips and Alternative 1.2 would require 81 daily loaded haul truck trips. • Grading Fugitive Dust: Emissions were calculated using the equation from the U.S. Environmental Protection Agency (U.S. EPA) AP-42 Section 11.9 and the daily acres graded. It is conservatively assumed the Project would grade 4.1 acres daily. This is a conservative estimation as the Project would not grade the areas occupied by the debris pile.
• Onsite Unpaved Road Fugitive Dust: Emissions from the haul trucks traveling on the onsite unpaved road were calculated using the equation from U.S. EPA AP-42 Section 13.2.2 and the daily vehicle miles traveled onsite. SCAQMD Rule 403 (Fugitive Dust Control), which requires watering and limiting vehicle speeds on unpaved roads, was incorporated into the modeling based on SCAQMD fugitive dust control efficiencies20.
• Off-Site Paved Road Fugitive Dust: Emissions from haul trucks traveling off-site on paved roads were calculated using the equation from U.S. EPA AP-42 Section 13.2.1 and the daily vehicle miles traveled; see Table 6 above.
• Concrete Crushing Fugitive Dust: Emissions were calculated using the equation from U.S. EPA AP-42 Section 11.19.2 and the daily tons of processed concrete. It is assumed that crushing operations would occur every day of the removal period and would process 1,960 tons of concrete daily. • Truck Loading Fugitive Dust: Emissions from loading the concrete into the haul trucks were calculated using the equation from U.S. EPA AP-42 Section 13.2 and the total tons of concrete loaded. The crusher would process approximately 65,772 tons of concrete.

See Appendix A: Air Quality Data for more information regarding the operations assumptions used in this analysis.

Table 7, Alternative 1 Pollutant Emissions summarizes the maximum daily emissions associated with Alternative 1. See Appendix A for the modeled emissions from each source. As shown in Table 7, the Alternative 1 pollutant emissions would not exceed the respective SCAQMD thresholds. Furthermore, it is noted that emissions would likely be lower than shown in Table 7 if debris removal operations were to occur in later years due to equipment technology improvements. Impacts would be less than significant, and no mitigation would be required.
20 South Coast Air Quality Management District, Fugitive Dust Table XI-A and Table XI-C https://www.aqmd.gov/home/rulescompliance/ceqa/air-quality-analysis-handbook/mitigation-measures-and-control- efficiencies/fugitive-dust, accessed April 2025.

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Table 7.

Alternative 1 Pollutant Emissions
Alternative Emissions (pounds per day)
ROG NOx CO SO2 PM10 PM2.5
Alternative 1.1: Bobtail Dump Trucks 9.65 75.47 460.76 0.33 28.29 5.79 Alternative 1.2: Single-end Dump Trucks 7.06 52.93 249.62 0.20 19.61 4.01 SCAQMD Threshold 75 100 550 150 150 55
SCAQMD Threshold Exceeded? No No No No No No
ROG = Reactive Organic Gases; NOX = Nitrogen Oxides; CO = Carbon Monoxide; SO2 = Sulfur Dioxide; PM10 = Particulate Matter 10 microns in diameter or less; PM2.5 = Particulate Matter 2.5 microns in diameter or less.

Alternative 2: Non-Crushing and Transport Offsite
Alternative 2 would generate short-term criteria pollutant emissions from onsite equipment exhaust and off-site and onsite haul truck exhaust. In addition, Alternative 2 would generate fugitive dust emissions from earthmoving activities such as grading, ground disturbance activities on unpaved (onsite) and paved (off-site) surfaces such as haul truck movement, and debris loading activities. Fugitive dust emissions are largely dependent on weather conditions and the appropriate application of water, and may have a substantial, temporary impact on local air quality. Emissions from each source are described in further detail below. • Onsite Equipment Exhaust: Emissions were calculated using CARB’s OFFROAD model emission rates for the anticipated equipment. The OFFROAD model captures the latest off-road assumptions, including emission inventories, equipment population, and activity data, collected by CARB. The anticipated operations equipment is shown in Table 8, Alternative 2 Equipment.

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Table 8.

Alternative 2 Operations Equipment
Operations
Phase Equipment Number Hours/Day Horsepower Load Factor Alternative 2.1: One Summer
Alternative 2.1.1 Bobtail Dump Trucks
Grading Grader 91 8 148 0.41
Removal
Loader 92 8 300 0.36
Bobcat Breaker 1 8 71 0.37
Street Sweeper 1 8 134 0.46
Alternative 2.1.2: Single-End Dump Trucks
Grading Grader 91 8 148 0.41
Removal
Loader 42 8 300 0.36
Bobcat Breaker 1 8 71 0.37
Street Sweeper 1 8 134 0.46
Alternative 2.2: Two Summers
Alternative 2.2.1: Bobtail Dump Trucks
Grading Grader 91 8 148 0.41
Removal
Loader 52 8 300 0.36
Bobcat Breaker 1 8 71 0.37
Street Sweeper 1 8 134 0.46
Alternative 2.2.1: Bobtail Dump Trucks
Grading Grader 91 8 148 0.41
Removal
Loader 22 8 300 0.36
Bobcat Breaker 1 8 71 0.37
Street Sweeper 1 8 134 0.46
Source: Operations equipment based on input from CSG Consultants. Horsepower and load factor based on input from CSG Consultants and CalEEMod User Guide Appendix G, Table G-12, Horsepower and Load Factors for Construction Equipment by Fuel Type, 2022.
1 It is assumed that a grader would disturb half an acre per day. It is conservatively assumed that the Project would grade 4.1 acres daily; therefore, grading activities would require nine graders. 2 It is assumed that a loader would load a truck in 15 minutes. The number of loaders was based on the number of daily loaded haul truck trips, shown in Table 10 below.
• Off-Site Haul Truck Exhaust: Emissions from haul truck trips were calculated using CARB’s EMFAC model emission rates, daily haul truck trip estimates, and VMT estimates. The daily haul truck trip and VMT estimates are shown in Table 9, Alternative 2 Daily Haul Truck Trips and Vehicle Miles Traveled.

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Table 9.

Alternative 2 Daily Haul Truck Trips and Vehicle Miles Traveled Alternative Daily Haul Truck Trips Daily Vehicle Miles Traveled1 Alternative 2.1: One Summer
Alternative 2.1.1: Bobtail Dump Trucks 520 8,840
Alternative 2.1.2: Single-end Dump
Trucks 200 3,400
Alternative 2.2: Two Summers
Alternative 2.2.1: Bobtail Dump Trucks 264 4,488
Alternative 2.2.2: Single-end Dump
Trucks 98 1,666
1 It is conservatively assumed the haul trucks would travel from the Rialto Recycling Yard to the disturbance area. • Onsite Haul Truck Exhaust: Emissions from idling haul trucks were calculated using CARB’s EMFAC model idling emission rates and the daily loaded haul truck trips estimates, shown in Table 10, Alternative 2 Daily Loaded Haul Truck Trips.

Table 10.

Alternative 2 Daily Loaded Haul Truck Trips
Alternative Daily Loaded Haul Truck Trips
Alternative 2.1: One Summer
Alternative 2.1.1: Bobtail Dump Trucks 260
Alternative 2.1.2: Single-end Dump Trucks 100
Alternative 2.2: Two Summers
Alternative 2.2.1: Bobtail Dump Trucks 264
Alternative 2.2.2: Single-end Dump Trucks 98
• Grading Fugitive Dust: Emissions were calculated using the equation from the U.S. EPA AP-42 Section

11.9 and the daily acres graded. It is conservatively assumed that the Project would grade 4.1 acres daily.

This is a conservative estimation as the Project would not grade the areas occupied by the debris pile. • Unpaved Road Fugitive Dust: Emissions from the haul trucks traveling on the onsite unpaved road were calculated using the equation from U.S. EPA AP-42 Section 13.2.2 and the daily vehicle miles traveled onsite. SCAQMD Rule 403 (Fugitive Dust Control), which requires watering and limiting vehicle speeds on unpaved roads, was incorporated into the modeling based on SCAQMD fugitive dust control efficiencies.21
• Paved Road Fugitive Dust: Emissions from haul trucks traveling off-site on paved roads were calculated using the equation from U.S. EPA AP-42 Section 13.2.1 and the daily vehicle miles traveled; see Table 9 above.
• Truck Loading Fugitive Dust: Emissions from loading the concrete into the haul trucks were calculated using the equation from U.S. EPA AP-42 Section 13.2 and the total tons of concrete loaded. The debris pile contains approximately 65,772 tons of concrete.
21 South Coast Air Quality Management District, Fugitive Dust Table XI-A and Table XI-C, https://www.aqmd.gov/home/rulescompliance /ceqa/air-quality-analysis-handbook/mitigation-measures-and-control- efficiencies/fugitive-dust, accessed April 2025.

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See Appendix A for more information regarding the assumptions used in this analysis.

Table 11, Alternative 2 Pollutant Emissions, summarizes the maximum daily emissions associated with Alternative

2. See Appendix A for the modeled emissions from each source. As shown in Table 11, the Alternative 2 pollutant emissions would not exceed the respective SCAQMD thresholds. Furthermore, it is noted that emissions would likely be lower than shown in Table 11 if debris removal operations were to occur in later years due to equipment technology improvements. Impacts would be less than significant, and no mitigation would be required.

Table 11.

Alternative 2 Pollutant Emissions
Alternative Emissions (pounds per day)
ROG NOx CO SO2 PM10 PM2.5
Alternative 2.1: One Summer
Alternative 2.1.1: Bobtail Dump Trucks 10.62 77.31 543.43 0.39 28.59 6.38 Alternative 2.1.2: Single-end Dump Trucks 7.34 56.50 277.25 0.22 16.71 3.95 Alternative 2.2: Two Summers
Alternative 2.2.1: Bobtail Dump Trucks 2.39 41.87 40.04 0.18 16.77 3.63 Alternative 2.2.2: Single-end Dump Trucks 5.02 38.59 167.62 0.14 10.88 2.61 SCAQMD Threshold 75 100 550 150 150 55
SCAQMD Threshold Exceeded? No No No No No No
ROG = Reactive Organic Gases; NOX = Nitrogen Oxides; CO = Carbon Monoxide; SO2 = Sulfur Dioxide; PM10 = Particulate Matter 10 microns in diameter or less; PM2.5 = Particulate Matter 2.5 microns in diameter or less.

Alternative 3: Crushing Onsite and Retain Onsite
Alternative 3 involves the crushing operation and resulting air analysis conclusions presented in Alternative 1.

However, Alternative 3 eliminates the air quality consideration related to truck hauling trips to a recycling facility, as well as onsite and offsite truck exhaust.

Alternative 3 would generate short-term criteria pollutant emissions from onsite equipment exhaust. In addition, Alternative 3 would generate fugitive dust (airborne particulate matter) emissions from earthmoving activities, such as grading and ground disturbance activities on unpaved (onsite) surfaces such as operations equipment movement and concrete crushing activities. Fugitive dust emissions are largely dependent on weather conditions and the appropriate application of water (on unpaved onsite travel surfaces)22, and may have a substantial, temporary impact on local air quality. Emissions from each source are described in further detail below.
• Onsite Equipment Exhaust: Emissions were calculated using the California Air Resources Board’s (CARB) OFFROAD model emission rates for the anticipated operations equipment. The OFFROAD model captures the latest off-road operations assumptions, including emission inventories, equipment population, and activity data collected by CARB. The anticipated equipment to be used is shown in Table 12, Alternative 3 Equipment.
22 Watering concrete debris for dust suppression should be done minimally as excessive watering can cause clumping. The water molecules attract and bind fine concrete particles, making them heavier and more prone to sticking together and settling out of the air. This effectively reduces the amount of airborne dust but can create larger, clumped debris.

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Table 12.

Alternative 3 Equipment
Operations
Phase Equipment Number Hours/Day Horsepower Load Factor Alternative 3: Crushing Onsite to Retain Onsite
Grading Grader 91 8 148 0.41
Removal
Crusher 1 3.52 300 0.85
Breaker 1 3.52 257 0.38
Loader 13 3.52 300 0.36
Source: Operations equipment based on input from CSG Consultants. Horsepower and load factor based on input from CSG consultants and CalEEMod User Guide Appendix G, Table G-12, Horsepower and Load Factors for Construction Equipment by Fuel Type, 2022.
1 It is assumed that a grader would disturb half an acre per day. It is conservatively assumed that the Project would grade 4.1 acres daily; therefore, grading activities would require nine graders. 2 It is assumed that crushing operations would occur every day of the removal period. Given that the LT106 would process 560 tons of concrete hourly, it is assumed the crusher operations would only occur for 3.5 hours daily to process enough concrete for the haul trucks.
3 A loader would load the broken concrete into the crusher. • Grading Fugitive Dust: Emissions were calculated using the equation from the U.S. Environmental Protection Agency (U.S. EPA) AP-42 Section 11.9 and the daily acres graded. It is conservatively assumed the Project would grade 4.1 acres daily. This is a conservative estimation as the Project would not grade the areas occupied by the debris pile.
• Concrete Crushing Fugitive Dust: Emissions were calculated using the equation from U.S. EPA AP-42 Section 11.19.2 and the daily tons of processed concrete. It is assumed that crushing operations would occur every day of the removal period and would process 1,960 tons of concrete daily.

Alternative 3 would not include the following sources of emissions that would be generated by Alternative 1: off- site haul truck exhaust, onsite haul truck exhaust, onsite unpaved road fugitive dust, off-site paved road fugitive dust, or truck loading fugitive dust. As shown in Table 7, Alternative 1 would not generate air quality emissions in exceedance of applicable thresholds, and impacts would be less than significant. Since Alternative 3 would not include several of the sources of emissions included in Alternative 1, it can therefore be concluded that Alternative 3 would not generate air quality emissions in exceedance of applicable thresholds, and impacts would be less than significant. Alternative 3 would reduce emissions impacts compared to Alternative 1, with the elimination of the hauling operation.

Localized Impacts
The SCAQMD recommends addressing Localized Significance Thresholds (LSTs) to identify localized impacts on sensitive receptors. LSTs represent the maximum NO
X, CO, PM10, and PM2.5 emissions that can be generated at a Project site without causing or substantially contributing to an exceedance of the CAAQS or NAAQS.

Therefore, off-site emissions are not included in the LST analysis. LSTs are based on the ambient concentrations of that pollutant within the applicable source receptor area (SRA), as demarcated by the SCAQMD, and the distance to the nearest sensitive receptor.

It should be noted that LSTs are screening thresholds and are therefore conservative. Projects that exceed LSTs are required to implement mitigation measures to prevent air pollution before it negatively affects human health. Projects that do not exceed LSTs would not affect human health or worsen local air quality. LSTs were developed in response to the SCAQMD Governing Boards' Environmental Justice Enhancement Initiative (I-4).

The SCAQMD provides the Final Localized Significance Threshold Methodology (dated June 2003 [revised 2008]) as guidance. The LST methodology assists lead agencies in analyzing localized emissions impacts on nearby sensitive receptors.

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The appropriate SRA for the LSTs is the Central San Bernardino Valley (SRA 34) because this area includes the Project site. The SCAQMD produced look-up tables for projects that disturb areas less than or equal to five acres. The Project is anticipated to disturb approximately 4.1-acres in a single day. As such, the LSTs for a maximum daily disturbance of four acres were used in this analysis.

The nearest sensitive receptors to the disturbance area are the residential uses located approximately 40 feet (12 meters) to the east. LST thresholds are provided for distances of 25, 50, 100, 200, and 500 meters to the nearest sensitive receptors. The SCAQMD developed the 25-meter LST for receptors located 25 meters or less from the emissions source.23 Therefore, as recommended by the SCAQMD, the 25-meter LSTs were used for receptors located within 25 meters of the disturbance area.

Table 13, Localized Significance of Emissions, presents the onsite localized emissions for each alternative during each phase. As noted above, LSTs apply to onsite emissions sources. Therefore, the emissions shown in Table 13 are from the following sources:
• Onsite Equipment Exhaust (all Alternatives)
• Onsite Haul Truck Exhaust (Alternatives 1 and 2)
• Grading Fugitive Dust (all Alternatives)
• Onsite Unpaved Road Fugitive Dust (Alternatives 1 and 2) • Truck Loading Fugitive Dust (Alternatives 1 and 2)
• Concrete Crushing Fugitive Dust (Alternatives 1 and 3) Grading represents the activities required to level a portion of the disturbance area and the existing dirt driveway to accommodate equipment staging and movement. Grading emissions include onsite heavy-duty equipment exhaust and fugitive dust. Debris removal includes crushing fugitive dust (Alternative 1 and 3), onsite material movement fugitive dust (all Alternatives), onsite unpaved road fugitive dust (Alternatives 1 and 2), onsite equipment exhaust (all Alternatives), and onsite haul truck exhaust (Alternatives 1 and 2). See Appendix A for the modeled emissions from each source.
23 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, page 3-3, July 2008.

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Table 13.

Localized Significance of Emissions
Alternative Emissions (pounds per day)
NOx CO PM10 PM2.5
Alternative 1: Crushing (Onsite Only)
Alternative 1.1: Bobtail Dump Trucks
Grading1 18.16 14.56 5.20 1.25
Debris Removal2 45.97 442.16 11.62 1.57
Alternative 1.2: Single-End Dump Trucks
Grading1 18.16 14.56 5.20 1.25
Debris Removal2 22.95 228.38 8.18 1.07
Alternative 2: Non-Crushing (Onsite Only)
Alternative 2.1: One Summer
Alternative 2.1.1: Bobtail Dump Trucks
Grading1 18.16 14.56 5.20 1.25
Debris Removal2 40.29 523.62 8.47 1.27
Alternative 2.1.2: Single-End Dump Trucks
Grading1 18.16 14.56 5.20 1.25
Debris Removal2 23.74 254.44 4.89 0.61
Alternative 2.2: Two Summers
Alternative 2.2.1: Bobtail Dump Trucks
Grading1 18.16 14.56 5.20 1.25
Debris Removal2 29.77 308.28 4.37 0.70
Alternative 2.2.2: Single-End Dump Trucks
Grading1 18.16 14.56 5.20 1.25
Debris Removal2 13.27 149.02 1.92 0.34
SCAQMD Localized Screening Threshold (adjusted for 4
acres at 25 meters) 237 1,488 12 7
SCAQMD Threshold Exceeded? No No No No
1 Grading would only be required for the existing dirt driveway and to level a portion of the disturbance area to accommodate equipment staging and movement. Grading emissions include onsite heavy-duty equipment exhaust and fugitive dust. 2 Debris removal includes crushing fugitive dust (Alternative 1 only), onsite material movement fugitive dust, onsite unpaved road fugitive dust, onsite equipment exhaust, and onsite haul truck exhaust.

Table 13 shows the pollutant emissions on the peak day of activity would not exceed their respective SCAQMD LSTs for any Project alternative. Alternative 3 is a reduced version of Alternative 1 and would not include exhaust or fugitive dust emissions related to hauling trucks. With the conclusion that Alternative 1 would not exceed LST thresholds, Alternative 3 also would not exceed SCAQMD LSTs. As such, Project activities would not result in significant pollutant concentrations at the nearest sensitive receptor and would not affect human health or worsen local air quality. Impacts would be less than significant, and no mitigation would be required.

Carbon Monoxide Hotspots
An analysis of CO “hot spots” is needed to determine whether the change in the level of service (LOS) of an intersection associated with Project implementation would have the potential to result in exceedances of the CAAQS or NAAQS. It has long been recognized that CO exceedances are caused by vehicular emissions, primarily when vehicles are idling at intersections. Vehicle emissions standards have become increasingly Packet Page. 469
stringent in the last 20 years. Currently, the CAAQS for CO is a maximum of 3.4 grams per mile for passenger cars (requirements for certain vehicles are more stringent). CO concentrations have steadily declined with the turnover of older vehicles, the introduction of cleaner fuels, and the implementation of control technology in industrial facilities. Accordingly, with the steadily decreasing CO emissions from vehicles, even very busy intersections do not result in exceedances of the CO standard.

The SCAQMD’s 2003 Air Quality Management Plan includes an analysis of CO attainment in the SCAB. Since the SCAB was re-designated as attainment for CO in 2007, it is no longer addressed in the SCAQMD’s AQMP.

Therefore, the 2003 AQMP is the most recent version that addresses CO concentrations. As part of the SCAQMD CO Hotspot Analysis, the Wilshire Boulevard and Veteran Avenue intersection, one of the most congested intersections in Southern California with an average daily traffic (ADT) volume of approximately 100,000 vehicles, was modeled for CO concentrations. This modeling effort identified a CO concentration high of 4.6 parts per million (ppm), which is well below the 35-ppm NAAQS.

Alternative 2.1.1 would generate the highest number of daily haul truck trips along Palm Avenue. As CO hotspots were not experienced at the Wilshire Boulevard and Veteran Avenue intersection even as it accommodates 100,000 vehicles daily, it can be reasonably inferred that CO hotspots would not be experienced at any intersections within the Project area resulting from a maximum of 520 daily haul truck trips attributable to the Project. Therefore, all Project alternatives would not generate or contribute to a CO hot spot.

Impacts would be less than significant, and no mitigation would be required.

Air Quality Management Plan Consistency
As stated above, the Project site is located within the SCAB and is under the SCAQMD’s jurisdiction. The SCAQMD is required, pursuant to the Federal Clean Air Act (FCAA), to reduce emissions of criteria pollutants for which the SCAB is in nonattainment. To reduce such emissions, the SCAQMD drafted the 2016 AQMP and 2022 AQMP (AQMPs).24 The AQMPs establish a program of rules and regulations directed at reducing air pollutant emissions and achieving the CAAQS and NAAQS.

The AQMPs are a regional and multi-agency effort, including the SCAQMD, the CARB, the Southern California Association of Governments (SCAG), and the U.S. Environmental Protection Agency (U.S. EPA). The AQMPs’ pollutant control strategies are based on the latest scientific and technical information and planning assumptions, including SCAG’s Connect SoCal (2024 - 2050 Regional Transportation Plan/Sustainable Communities Strategy) (RTP/SCS) and SCAG’s latest growth forecasts. SCAG’s latest growth forecasts were defined in consultation with local governments and with reference to local general plans. The Project is subject to the AQMPs.

Criteria for determining consistency with the AQMPs are defined by the following indicators:
• Consistency Criterion No. 1: The Project will not result in an increase in the frequency or severity of existing air quality violations, or cause or contribute to new violations, or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP. • Consistency Criterion No. 2: The Project will not exceed the assumptions in the AQMPs or increments based on the years of the Project build-out phase.

According to the SCAQMD’s CEQA Air Quality Handbook, the purpose of the consistency finding is to determine if a Project is inconsistent with the assumptions and objectives of the regional air quality plans and, thus, if it would interfere with the region’s ability to comply with CAAQS and NAAQS.25 The violations to which Consistency Criterion No. 1 refers to are exceedances of the CAAQS or NAAQS. As shown in Table 7, Table 11, and Table 13, the Project’s pollutant emissions would not exceed the respective 24 The 2016 AQMP was adopted in March 2017 and was developed to address attainment of multiple O3 and PM2.5 standards. The 2022 AQMP was adopted in December 2022 and was developed to address attainment of the 2015 8-hour O3 standard. 25 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.

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SCAQMD thresholds. As such, the Project would not cause or contribute to an existing air quality violation or delay the attainment of the CAAQS or NAAQS. The Project is consistent with the first criterion.

Concerning Consistency Criterion No. 2, the AQMPs contain air pollutant reduction strategies based on SCAG’s latest growth forecasts, which were defined in consultation with local governments and with reference to local general plans. The Project site is designated and zoned Residential Low (RL). The Project does not propose land development. Therefore, the Project would not increase the population or employment within the City and would not cause an exceedance of the population or employment growth Projections used by the SCAQMD to develop the AQMPs. The Project is consistent with the second criterion.

Based on these criteria, the Project would not conflict with or obstruct implementation of the AQMPs. Impacts would be less than significant, and no mitigation is required.

Conclusion
The operations-related pollutant emissions for all Project alternatives would not exceed their respective SCAQMD thresholds. As Project emissions for all alternatives would not exceed SCAQMD’s Localized Significance Thresholds, the Project would not affect human health or worsen local air quality. Project emissions impacts would be less than significant, and no mitigation is required.

However, due to the proximity of receptors, use of the Metso Lokotrack Urban LT96 is recommended to minimize dust emissions to the greatest extent feasible. The Urban LT96 crusher includes dust covers and a dust suppression system that uses high-pressure water sprays inside the crusher chamber and at the end of the conveyor to prevent dust when aggregates are unloaded. Urban LT96 dust suppression system results in an approximately 85 percent reduction in dust emissions. This analysis conservatively did not apply the dust reduction from the Urban LT96; however, this crusher with additional dust suppression is recommended considering the site’s historical dust nuisances for nearby receptors.

Crushed material resulting from Alternative 3 would require a Containment Plan to mitigate and assure that crushed material onsite does not result in dust emission nuisance to area residents. The Containment Plan is subject to approval by the City of San Bernardino, prior to starting site preparation for the crushing operation.

3.2 Health Risk Assessment
The purpose of this Health Risk Assessment (HRA) is to evaluate potential health risks associated with Diesel Particulate Matter (DPM) resulting from implementation of the Project. This HRA was prepared in accordance with South Coast Air Quality Management District (SCAQMD) requirements and Office of Environmental Health Hazard Assessment (OEHHA) guidance to determine if health risks are likely to occur from the Project. In addition to this HRA, an Air Quality Memorandum has also been prepared for this Project. The Air Quality Memorandum modeling outputs used in this HRA are provided in Appendix B: Health Risk Assessment Modeling Data.

Environmental Setting
Climate
The general region (South Coast Air Basin – SCAB) lies in the eastern Pacific’s semi-permanent high-pressure zone. The climate is mild and tempered by cool sea breezes. The usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds. The extent and severity of the South Coast Air Basin (SCAB) air pollution problem is a function of the area’s natural physical characteristics (weather and topography), as well as man-made influences (development patterns and lifestyle). Factors such as wind, sunlight, temperature, humidity, rainfall, and topography all affect the accumulation and/or dispersion of pollutants throughout the SCAB. These factors along with applicable regulations are discussed below.

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The average annual temperature varies little throughout the SCAB, averaging 75 degrees Fahrenheit (°F).

However, with a less-pronounced oceanic influence, SCAB’s eastern inland portions (i.e., where the Project site is located) show greater variability in annual minimum and maximum temperatures. All SCAB portions have had recorded temperatures of over 100°F in recent years.

Meteorology
Although the SCAB has a semi-arid climate, the air near the surface is moist due to the presence of a shallow marine layer. The ocean effect is dominant except for infrequent periods when offshore winds bring dry, continental air into the SCAB. Periods with heavy fog are frequent, and low stratus clouds, occasionally referred to as “high fog,” are a characteristic climate feature. Annual average relative humidity is 70 percent at the coast and 57 percent in SCAB’s eastern portion. Precipitation in the SCAB is typically nine to 14 inches annually and is rarely in the form of snow or hail due to typically warm weather. The frequency and amount of rainfall is greater in SCAB’s coastal areas.

A temperature inversion is defined as an increase in temperature with height, or to the layer within which such an increase occurs. The inversion’s height is important in determining pollutant concentration. When the inversion is approximately 2,500 feet above sea level, the sea breezes carry the pollutants inland to escape over the mountain slopes or through the passes. At a height of 1,200 feet, the terrain prevents the pollutants from entering the upper atmosphere, resulting in a settlement in the foothill communities. Below 1,200 feet, the inversion puts a tight lid on pollutants, concentrating them in a shallow layer over the entire SCAB. Usually, inversions are lower before sunrise than during the day. Mixing heights for inversions are lower in the summer and more persistent, being partly responsible for high ozone (O3) levels observed during summer months in the SCAB. Smog in Southern California is generally the result of these temperature inversions, which trap pollutants. Coastal winds and local mountains further contain pollutants, allowing them to react with sunlight and form secondary pollutants. The SCAB has a limited ability to disperse these pollutants due to typically low wind speeds.

The area where the Project site is located offers clear skies and sunshine yet is still susceptible to air inversions.

These inversions trap a layer of stagnant air near the ground, where it is then further loaded with pollutants.

These inversions cause haziness, which is caused by moisture, suspended dust, and a variety of chemical aerosols emitted by trucks, automobiles, furnaces, and other sources.

Toxic Air Contaminants
Toxic Air Contaminants (TAC) are airborne substances capable of causing short-term (acute) and long-term (chronic or carcinogenic, i.e., cancer-causing) adverse human health effects (i.e., injury or illness). TACs include both organic and inorganic chemical substances. They may be emitted from a variety of common sources including gasoline stations, automobiles, dry cleaners, industrial operations, and painting operations.

The current California list of TACs includes approximately 200 compounds, including particulate emissions from diesel-fueled engines.

Hazardous Air Pollutants (HAP) is a term used by the Federal Clean Air Act (FCAA) that includes a variety of pollutants generated or emitted by industrial production activities. Identified as TACs under the California Clean Air Act (CCAA), ten have been singled out through ambient air quality data as being the most substantial health risk in California. Direct exposure to these pollutants has been shown to cause cancer, birth defects, damage to the brain and nervous system, and respiratory disorders. The California Air Resources Board (CARB) provides emission inventories for only the larger air basins.

TACs do not have ambient air quality standards because no safe levels of TACs can be determined. Instead, TAC impacts are evaluated by calculating the health risks associated with a given exposure. The Air Toxic “Hot Spots” Information and Assessment Act (Assembly Bill [AB] 2588) requirements apply to facilities that use, produce, or emit toxic chemicals. Facilities subject to AB 2588 toxic emission inventory requirements must prepare and submit toxic emission inventory plans and reports and periodically update those reports.

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Toxic contaminants often result from fugitive emissions during fuel storage and transfer activities, and from leaking valves and pipes. For example, the electronics industry, including semiconductor manufacturing, uses highly toxic chlorinated solvents in semiconductor production processes. Sources of air toxics go beyond industry, however. Automobile exhaust also contains toxic air pollutants such as benzene and 1,3-butadiene.

In California, on-road diesel-fueled engines contribute approximately 51 percent of the Statewide total DPM, with an additional 43 percent attributed to other mobile sources such as construction and mining equipment, agricultural equipment, and transport refrigeration units.26 Stationary sources contribute approximately 6 percent of total DPM.27 It is noted that CARB has developed several plans and programs to reduce diesel emissions such as the Diesel Risk Reduction Plan (DRRP), the Statewide Portable Equipment Registration Program (PERP), and the Diesel Off-Road Reporting System (DOORS). The PERP and DOORS programs allow owners or operators of portable engines and certain other types of equipment to register their units to operate their equipment throughout California without having to obtain individual permits from local air districts.

As noted above, diesel exhaust and the many individual substances it contains (e.g., arsenic, benzene, formaldehyde, and nickel) could contribute to mutations in cells that can lead to cancer. Long-term exposure to diesel exhaust particles poses the highest cancer risk of any TAC evaluated by OEHHA. CARB estimates that approximately 70 percent of the cancer risk that the average Californian faces from breathing toxic air pollutants stems from diesel exhaust particles.28
In its comprehensive assessment of diesel exhaust, OEHHA analyzed more than 30 studies of people who worked around diesel equipment, including truck drivers, railroad workers, and equipment operators. The studies showed these workers were more likely to develop lung cancer than workers not exposed to diesel emissions. These studies provide strong evidence that long-term occupational exposure to diesel exhaust increases the risk of lung cancer. Using information from OEHHA’s assessment, CARB estimates that diesel particle levels measured in California’s air in 2000 could cause 540 “excess” cancers in a population of one million people over a 70-year lifetime.
29 Other researchers and scientific organizations, including the National Institute for Occupational Safety and Health, have calculated cancer risks from diesel exhaust similar to those OEHHA and CARB developed.

Exposure to diesel exhaust can have immediate health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. In studies with human volunteers, diesel exhaust particles made people with allergies more susceptible to the materials to which they are allergic, such as dust and pollen. Exposure to diesel exhaust also causes inflammation in the lungs, which may aggravate chronic respiratory symptoms and increase the frequency or intensity of asthma attacks.

The elderly and people with emphysema, asthma, chronic heart and lung disease are especially sensitive to fine-particle pollution. Numerous studies have linked elevated particle levels in the air to increased hospital admissions, emergency room visits, asthma attacks, and premature deaths among those suffering from respiratory problems. Because children’s lungs and respiratory systems are still developing, they are also more susceptible than healthy adults to fine particles. Exposure to fine particles is associated with an increased frequency of childhood illnesses and can also reduce lung function in children. In California, diesel exhaust particles have been identified as a carcinogen.

Sensitive Receptors
Sensitive populations are more susceptible to air pollution effects than the general population. Sensitive receptors that are in proximity to localized TAC sources are of particular concern. Land uses considered to be 26 California Air Resources Board, California Toxics Inventory, 2013. https://ww2.arb.ca.gov/california-toxics-inventory, accessed March 2025.
27 Ibid.
28 California Air Resources Board, Summary: Diesel Particulate Matter Health Impacts, https://ww2.arb.ca.gov/resources/summarydiesel-particulate-matter-health-impacts, accessed March 2025. 29 California Air Resources Board, Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles, Table 6 and Table 7, October 2000.

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sensitive receptors include residences, schools, playgrounds, childcare centers, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. The nearest sensitive receptors to the disturbance area within the Project site are listed in Table 14, Sensitive Receptors.

Table 14.

Sensitive Receptors
Sensitive Receptor1 Distance2 and Direction from the Disturbance Area 1-Residential Uses 40 feet to the east
2-Residential Uses 114 feet to the southeast
3-Residential Uses 600 feet to the south
4-Residential Uses 893 feet to the southwest
5-Palm Avenue Elementary School 2,425 feet to the south Source: Google Earth, 2025
1 The residential uses listed above are the nearest sensitive receptors surrounding the disturbance area and are representative of the existing environment between the disturbance area and the Palm Avenue Elementary School. 2 Distance measured from the disturbance area to the nearest sensitive receptor property line.

Regulatory Setting
Federal
Federal Clean Air Act
The FCAA was amended in 1990 to address the numerous air pollutants that are known to cause or may reasonably be anticipated to cause adverse effects to human health or adverse environmental effects. 188 specific pollutants and chemical groups were initially identified as Hazardous Air Pollutants (HAPs), and the list has been modified over time. The FCAA Amendments included new regulatory programs to control acid deposition and for the issuance of stationary source operating permits.

In 2001, the United States Environmental Protection Agency (U.S. EPA) issued its first Mobile Source Air Toxics Rule, which identified 21 mobile source air toxic (MSAT) compounds as being HAPs that required regulation. A subset of six of these MSAT compounds were identified as having the greatest influence on health and included benzene, 1,3-butadiene, formaldehyde, acrolein, acetaldehyde, and DPM. More recently, the U.S. EPA issued a second MSAT Rule in February 2007, which generally supported the findings in the first rule and provided additional recommendations of compounds having the greatest impact on health. The rule also identified several engine emission certification standards that must be implemented. Unlike the criteria pollutants, toxics do not have National Ambient Air Quality Standards (NAAQS), making evaluation of their impacts more subjective.

National Emissions Standards for Hazardous Air Pollutants (NESHAPs) were incorporated into a greatly expanded program for controlling toxic air pollutants. The provisions for NAAQS attainment and maintenance were substantially modified and expanded. Other revisions included provisions regarding stratospheric ozone protection, increased enforcement authority, and expanded research programs.

FCAA Amendments Section 112 governs the federal control program for HAPs. NESHAPs are issued to limit the release of specified HAPs from specific industrial sectors. These standards are technology-based, meaning that they represent the best available control technology an industrial sector could afford. The level of emissions controls required by NESHAPs is not based on health risk considerations because allowable releases and resulting concentrations have not been determined to be safe for the general public. The FCAA does not establish air quality standards for HAPs that define legally acceptable concentrations of these pollutants in ambient air.

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Federal Emissions for On-Road Trucks
To reduce emissions from on-road, heavy-duty diesel trucks, the U.S. EPA established a series of increasingly strict emission standards for new engines, starting in 1988. The U.S. EPA promulgated the final and cleanest standards with the 2007 Heavy-Duty Highway Rule.30 The particulate matter (PM) emission standard of 0.01 gram per horsepower-hour (g/hp-hr) is required for new vehicles beginning with model year 2007. Also, the nitrogen oxide (NOX) and nonmethane hydrocarbon (NMHC) standards of 0.20 g/hp-hr and 0.14 g/hp-hr, respectively, were phased in together between 2007 and 2010 on a percent of sales basis: 50 percent from 2007 to 2009 and 100 percent in 2010.

Emission Standards for Off-Road Diesel Engines
To reduce emissions from off-road diesel equipment, the U.S. EPA established a series of cleaner emission standards for new off-road diesel engines.31 Tier 1 standards were phased in from 1996 to 2000 (year of manufacture), depending on the engine horsepower category. Tier 2 standards were phased in from 2001 to 2006. Tier 3 standards were phased in from 2006 to 2008. Tier 4 standards, which generally require add-on emission control equipment to attain them, were phased in from 2008 to 2015. The Tier 4 standards require that emissions of PM and NOX be further reduced by about 90 percent from Tier 3 standards.

State of California
California Air Resources Board
CARB’s statewide comprehensive air toxics program was established in 1983 with AB 1807 the Toxic Air Contaminant Identification and Control Act (Tanner Air Toxics Act of 1983). AB 1807 created California's program to reduce exposure to air toxics and set forth a formal procedure for CARB to designate substances as TACs. Once a TAC is identified, CARB adopts an airborne toxics control measure (ATCM) for sources that emit designated TACs. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure below that threshold. If there is no safe threshold, the measure must incorporate toxics best available control technology (T-BACT) to minimize emissions.

CARB also administers the State’s mobile source emissions control program and oversees air quality programs established by State statute, such as AB 2588. Under AB 2588, TAC emissions from individual facilities are quantified and prioritized by the air quality management district or air pollution control district. High-priority facilities are required to perform a health risk assessment and, if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings. In September 1992, AB 2588 was amended by Senate Bill (SB) 1731 which required facilities that pose a significant health risk to the community to reduce their risk through a risk management plan.

Diesel Reduction Plan
The identification of DPM as a TAC in 1998 led CARB to adopt the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles (DRRP) in October 2000. The DRRP's goals include an 85 percent reduction in DPM by 2020 from the 2000 baseline.32 CARB estimates that emissions of DPM in 2035 will be less than half those in 2010, further reducing Statewide cancer risk and non-cancer health 30 United States Environmental Protection Agency (U.S. EPA), Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements, Final Rule. 40 Code of Federal Regulations, Parts 69, 80, and 86. January 18, 2001.
31 U.S. EPA, Regulations for Emissions from Heavy Equipment with Compression-Ignition (Diesel) Engines, 2024. Available at:
https://www.epa.gov/regulations-emissions-vehicles-and-engines/regulations-emissions-heavy-equipment-compression, accessed March 2025.
32 California Air Resources Board, Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel‐Fueled Engines and Vehicles, October 2000.

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effects.33 The DRRP includes regulations to establish cleaner new diesel engines, cleaner in-use diesel engines (retrofits), and cleaner diesel fuel.

Truck and Bus Regulation Reducing Emissions from Existing Diesel Vehicles On December 12, 2008, CARB approved the Truck and Bus Regulation to significantly reduce PM and NOX emissions from existing diesel vehicles operating in California. The regulation requires diesel trucks and buses that operate in California to be upgraded to reduce emissions. Heavier trucks must be retrofitted with PM filters beginning January 1, 2012, and older trucks must be replaced starting January 1, 2015. Beginning on January 1, 2023, nearly all trucks and buses are required to have 2010 model-year engines or equivalent.

The regulation applies to most privately and federally owned diesel-fueled trucks and buses and to privately and publicly owned school buses with a gross vehicle weight rating (GVWR) greater than 14,000 pounds. Small fleets with three or fewer diesel trucks can delay compliance for heavier trucks and there are several extensions for low-mileage trucks, early PM filter retrofits, adding cleaner vehicles, and other situations. Privately and publicly owned school buses have different requirements.

Heavy-Duty Vehicle Idling Emission Reduction Program
The purpose of the CARB ATCM to Limit Diesel-Fueled Commercial Motor Vehicle Idling is to reduce public exposure to diesel particulate matter and criteria pollutants by limiting the idling of diesel-fueled commercial vehicles. The driver of any vehicle subject to this ATCM is prohibited from idling the vehicle’s primary diesel engine for greater than five minutes at any location and is prohibited from idling a diesel-fueled auxiliary power system (APS) for more than five minutes to power a heater, air conditioner, or any ancillary equipment on the vehicle if it has a sleeper berth and the truck is located within 100 feet of a restricted area (homes and schools).

CARB Final Regulation Order, Requirements to Reduce Idling Emissions from New and In-Use Trucks, beginning in 2008, requires new 2008 and subsequent model-year heavy-duty diesel engines be equipped with an engine shutdown system that automatically shuts down the engine after 300 seconds of continuous idling operation once the vehicle is stopped, the transmission is set to “neutral” or “park”, and the parking brake is engaged.

California Code of Regulations Title 13 Sections 2485 and 2449 limit diesel-fueled motor vehicle idling to no more than five minutes. Section 2485 limits idling for diesel-fueled commercial motor vehicles with gross vehicle weight ratings of greater than 10,000 pounds that are or must be licensed to operate on publicly maintained highways and streets within California. Section 2449 limits idling for off-road diesel-fueled fleets.

CARB Emissions Standards for Off-Road Diesel Engines
Similar to the U.S. EPA’s off-road diesel engine emission standards, CARB adopted the In-Use Off- Road Diesel- Fueled Fleets Regulation (Off-Road Regulation) in 2007. CARB’s Off-Road Regulation phases out the oldest and highest-emitting off-road engines (Tiers 0, 1, and 2) from operation in California. Engine “tier” refers to the emissions certification level of an engine and is defined in the Off-Road Regulation Section 2449(c).

Additionally, all fleets are required to procure and use renewable diesel in all vehicles owned or operated in California that are subject to the Off-Road Regulation, with some limited exceptions, including lack of availability. Fleets must document and retain records related to the fleet’s procurement of renewable diesel.

CARB is currently developing potential amendments to the off-road diesel engine standards, in a Tier 5 rulemaking. The Tier 5 rulemaking aims to reduce NOX and PM emissions from new, off-road compression ignition (CI) engines, by an additional 50 percent to 90 percent, compared to what is allowed by today’s Tier 4 final emission standards.34
33 California Air Resources Board, Overview: Diesel Exhaust & Health, https://ww2.arb.ca.gov/resources/overview-diesel- exhaustand-health, accessed March 2025.
34 California Air Resources Board, Public Workshop to Discuss Proposed Off-Road New Diesel Engine Emissions Standards, https://ww2.arb.ca.gov/events/public-workshop-discuss-proposed-road-new-diesel-engine-emissions-standards-tier-5, accessed March 2025.

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CalEnviroScreen
OEHHA has developed CalEnviroScreen 4.0, which is a mapping tool that helps identify California communities that are most affected by various pollution sources, and where people are often especially vulnerable to pollution’s effects. CalEnviroScreen uses screening methodology used to identify California communities disproportionately burdened by pollution based on environmental, health, and socioeconomic information to produce scores for every census tract in the State. The scores are mapped so that different communities can be compared. An area with a high score experiences a much higher pollution burden than areas with low scores.

According to CalEnviroScreen, the Project site and the nearest sensitive receptors (i.e., single-family residential uses located approximately 40 feet to the east of the Project site) are within Census Tract 6071004504, which is within the 62nd percentile.35 This means that the Project site ranks higher than 62 percent of other areas in terms of cumulative environmental impacts and vulnerabilities (i.e., is exposed to more pollutants or is more vulnerable to its effects). The percentile score is based on a combination of factors, including exposures to pollution, environmental effects of pollution, sensitive populations, and socioeconomic factors.

It is noted that the CalEnviroScreen scores are relative to other census tracts and are not an expression of health risk, and do not provide quantitative information on increases in cumulative impacts for specific sites or Projects. Further, as a comparative screening tool, the results do not provide a basis for determining when differences between scores are significant in relation to public health or the environment. However, the CalEnviroScreen scores enable decision-makers to craft and implement policies that target the state's most vulnerable communities, such as programs that direct improvements and investments to under-resourced neighborhoods, and regulations that minimize or avoid harms against already overburdened communities.

Senate Bill 535
Senate Bill (SB) 535 directs 25 percent of the proceeds from the Greenhouse Gas Reduction Fund (i.e., funds from the AB 32 cap-and-trade program) to go to projects that provide a benefit to disadvantaged communities (DACs) (as identified by the OEHHA mapping). These funds must be used for programs that further reduce greenhouse gas emissions. Funding programs that reduce greenhouse gas emissions would also potentially reduce exposure to other emissions including TACs. Based on OEHHA mapping, the Project site is not located within an SB 535 designated disadvantaged community (Census Tract 6071004504).36 SB 535 does not include Project-specific requirements, regulate land uses, or prohibit onsite activities.

CARB Advanced Clean Truck Regulation
CARB adopted the Advanced Clean Truck Regulation in June 2020 requiring truck manufacturers to transition from diesel trucks and vans to electric zero-emission trucks beginning in 2024. By 2045, every new truck sold in California is required to be zero-emission. This rule directly addresses disproportionate risks and health and pollution burdens and puts California on the path for an all zero-emission short-haul drayage fleet in ports and railyards by 2035, and zero-emission “last-mile” delivery trucks and vans by 2040. The Advanced Clean Truck Regulation accelerates the transition of zero-emission medium- and heavy-duty vehicles from Class 2b to Class 8.

The regulation has two components (a manufacturer sales requirement and a reporting requirement), as follows:
• Zero-Emission Truck Sales: Manufacturers who certify Class 2b through 8 chassis or complete vehicles with combustion engines are required to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero emission truck/chassis sales need to be 55 percent of Class 2b – 3 truck sales, 75 percent of Class 4 – 8 straight truck sales, and 40 percent of truck tractor sales.
• Company and Fleet Reporting: Large employers including retailers, manufacturers, brokers, and others would be required to report information about shipments and shuttle services. Fleet owners, with 50 or 35 California Office of Environmental Health Hazard Assessment, CalEnviroScreen 4.0 Results (October 2021 Update), https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40, accessed March 2025. 36 California Office of Environmental Health Hazard Assessment, SB 535 Disadvantaged Communities (2022 Update), https://oehha.ca.gov/calenviroscreen/sb535, accessed March 2025.

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more trucks, would be required to report about their existing fleet operations. This information would help identify future strategies to ensure that fleets purchase available zero-emission trucks and place them in service where suitable to meet their needs.

Executive Order N-79-20
Signed in September 2020, Executive Order N-79-20 establishes as a goal that where feasible, all new passenger cars and trucks, as well as all drayage/cargo trucks and off-road vehicles and equipment, sold in California, will be zero-emission by 2035. The executive order sets a similar goal requiring that all medium and heavy-duty vehicles will be zero-emission by 2045 where feasible. It also directs CARB to develop and propose rulemaking for passenger vehicles and trucks, medium and heavy-duty fleets where feasible, drayage trucks, and off-road vehicles and equipment “requiring increasing volumes” of new zero-emission vehicles (ZEVs) “towards the target of 100 percent.” The executive order directs the California Environmental Protection Agency, the California Geologic Energy Management Division (CalGEM), and the California Natural Resources Agency to transition and repurpose oil production facilities to meet carbon neutrality by 2045. Executive Order N-79-20 builds upon the CARB Advanced Clean Trucks regulation, which CARB adopted in July 2020.

CARB Advanced Clean Fleets Regulation
CARB approved Advanced Clean Fleets Regulation (ACF) on April 28, 2023, which includes requirements for drayage trucks transporting cargo to and from California’s intermodal seaports and railyards. Under ACF, drayage trucks will be required to start transitioning to zero-emission technology beginning in 2024, with full implementation by 2035.

On January 13, 2025, California withdrew its request for federal approval of the ACF and is evaluating next steps.

CARB will not enforce portions of the regulation requiring federal authorization, such as those affecting high- priority and drayage fleets. However, State and local government fleet requirements remain unchanged.37 Regional
South Coast Air Quality Management District
The CCAA provides the SCAQMD with the authority to manage transportation activities at indirect sources and regulate stationary source emissions. Indirect pollution sources are generated when minor sources collectively emit a substantial amount of pollution. An example of this would be the motor vehicles at an intersection, a mall, and on highways. As a State agency, CARB regulates motor vehicles and fuels for their emissions.

Air Toxics Control Plan
The Air Toxics Control Plan (March 2000, revised March 26, 2004) is a planning document intended to examine the overall direction of the SCAQMD’s air toxics control program. It includes the development and implementation of strategic initiatives to monitor and control air toxics emissions. Control strategies that are deemed viable and are within the SCAQMD’s jurisdiction will each be brought to the SCAQMD Board for further consideration through the normal public review process. Strategies that are to be implemented by other agencies will be developed in a cooperative effort, and the progress will be reported back to the SCAQMD Board periodically.

Multiple Air Toxics Exposure Study
The SCAQMD conducted an in-depth analysis of TACs and their resulting health risks for all of Southern California. The Multiple Air Toxics Exposure Study in the SCAB (MATES V) (August 2021) shows that carcinogenic risk from air toxics in the SCAB, based on the average concentrations at the 10 monitoring sites, is approximately 40 percent lower than the monitored average in MATES IV and 84 percent lower than the average in MATES II. MATES V also evaluated the population-weighted cancer risk within Environmental Justice (EJ) 37 California Air Resources Board, ACF Waiver Update, https://ww2.arb.ca.gov/our-work/programs/advanced-clean-fleets, accessed March 2025.

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communities using the SB 53538 definition of disadvantaged communities. Between MATES IV and MATES V, air toxic cancer risk decreased by 57 percent in EJ communities overall compared to a 53 percent reduction in non- EJ communities.

MATES V is the most comprehensive dataset documenting the ambient air toxic levels and health risks associated with SCAB emissions. Therefore, the MATES V study represents the baseline health risk for a cumulative analysis. MATES V estimates the average excess cancer risk level from exposure to TACs is 424 in one million Basin-wide. In comparison, the MATES IV basin's average risk was 897 per million. These model estimates were based on monitoring data collected at ten fixed sites within the SCAB. None of the fixed monitoring sites are near the Project site. However, MATES V has extrapolated the excess cancer risk levels throughout the SCAB by modeling the specific grids. MATES V modeling predicted an excess cancer risk of 410 in one million for the Project area.39
Significance Criteria and Methodology
Health Risk Analysis Thresholds
Project health risks are determined by examining the types and levels of air toxics generated and the associated impacts on factors that affect air quality. While the final determination of significance thresholds is within the Lead Agency’s purview pursuant to the State CEQA Guidelines, the SCAQMD recommends that lead agencies use the following air pollution thresholds in determining whether a Project’s impacts are significant. If the lead agency finds that the Project has the potential to exceed the air pollution thresholds, a Project’s impacts should be considered significant. The TAC emissions thresholds are as follows. • Cancer Risk (Individual): Emit contaminants that result in a maximum individual incremental cancer risk equal to or greater than 10 in one million.
• Non-Cancer Risk: Emit contaminants that result in a chronic or acute hazard index equal to or greater than 1.0 (Project increment).

Cancer risk is expressed in terms of expected incremental incidence per million population. The SCAQMD has established an incidence rate of 10 persons per million as the maximum acceptable incremental cancer risk due to TAC exposure. This threshold is an upper-bound incremental probability to determine whether or not a given Project has a potentially significant development-specific and cumulative impact and to ensure an individual new source does not contribute a cumulatively significant impact. The 10 in one million standard is a health-protective significance threshold. A risk level of 10 in one million implies a likelihood that up to 10 persons, out of one million equally exposed persons, would contract cancer if exposed continuously (24 hours per day) to the TAC levels over a specified duration of time. This risk would be an excess cancer that is in addition to any cancer risk borne by a person not exposed to these TACs.

The SCAQMD has also established non-carcinogenic risk parameters for use in HRAs. Noncarcinogenic risks are quantified by calculating a "hazard index," expressed as the ratio between the ambient pollutant concentration and its toxicity or Reference Exposure Level (REL). A REL is a concentration at or below which health effects are not likely to occur. A hazard index of less than 1.0 means that adverse health effects are not expected. Within this analysis, non-carcinogenic exposures of less than 1.0 are considered less than significant.

Methodology
This HRA was prepared in accordance with SCAQMD guidance which largely follows OEHHA but includes some notable local preferences. The Project site has been tested by a Certified Industrial Hygienist, and it was 38 SB 535 established initial requirements for minimum funding levels to “Disadvantaged Communities” (DACs). The legislation also gives California EPA the responsibility for identifying those communities, stating that the designation of disadvantaged communities must be based on “geographic, socioeconomic, public health, and environmental hazard criteria.” 39 South Coast Air Quality Management District, MATES V Estimated Risk, https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23/page/Main-Page/?views=Click-tabs-for- otherdata% 2CCancer-Risk#data_s=id%3AdataSource_105-a5ba9580e3aa43508a793fac819a5a4d%3A253, accessed March 2025.

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determined that no asbestos or volatile organic compounds (VOCs) are present in the concrete material, and the concrete does not contain hazardous levels of heavy metals (i.e., metals listed in the California Administrative Manual [CAM]). The Certified Industrial Hygienist determined that the concrete debris does not contain hazardous materials and could be crushed and used as a fill base for the site. Therefore, this HRA focuses on evaluating potential health risks associated with on- and off-road DPM exhaust emissions resulting from Project implementation. Off-road equipment and heavy-duty truck traffic (occurring both on- and off-road) generate diesel exhaust, which is a known TAC. Diesel exhaust from off-road equipment operating at the site poses a health risk to nearby sensitive receptors.

Debris Removal and Hauling Sources
Debris removal and hauling would generate DPM emissions from the use of diesel off-road equipment and on- road haul trucks. DPM is the primary TAC of concern because it is the most potent TAC emitted from off-road equipment and haul truck exhaust and includes hundreds of chemicals. Although DPM is a subset of PM10 exhaust, the analysis conservatively assumes all PM10 exhaust emissions are DPM.40 Health-related risks associated with diesel-exhaust emissions are primarily linked to long-term exposure and the associated risk of contracting cancer. Project-related debris removal (including crushing options) would have a short duration, lasting approximately two months or as long as four months, split over two years (depending on the alternative selected). Current models and methodologies for conducting health risk assessments are associated with longer-term exposure periods of 9, 30, and 70 years, which do not correlate well with the temporary and highly variable nature of the short-term debris removal activities. The use of diesel- powered on- and off-road equipment would be temporary and episodic and would occur throughout the Project site. In compliance with state law (Section 2485 and Section 2449 of Title 13 of the California Code of Regulations), the contractor would be required to limit diesel truck/equipment idling to no more than five minutes, which would further reduce nearby sensitive receptors’ exposure to temporary and variable DPM emissions. Furthermore, even during the most intense period of activity, DPM emissions would be generated from different locations on the Project site rather than in a single location because different activities (e.g., grading and crushing/loading/hauling) would not occur at the same time. PM10 (DPM) emission rates were calculated using the CARB OFFROAD model and the CARB EMFAC model; refer to Appendix B.

The model was run for heavy-duty diesel vehicles traveling off-site along Palm Avenue (Alternatives 1 and 2) and off-road equipment operating on site (all Alternatives). The onsite off-road equipment modeled includes the following:
• Graders
• Crushing/Processing Equipment (crushing alternatives only) • Breaker/Excavators
• Rubber Tire Loader for Loading Crusher
• Skid Steer Loaders
• Sweepers/Scrubbers
On-road truck emissions were modeled as heavy heavy-duty trucks for the single-end dump truck alternatives and medium-heavy-duty trucks for the bobtail dump truck alternatives. 40 More than 90 percent of DPM is less than 1 μm in diameter and is a subset of PM2.5 and PM2.5 comprises a portion of PM10. Thus, assuming PM10 as the surrogate for DPM constitutes a conservative analysis. CARB, Inhalable Particulate Matter and Health (PM2.5 and PM10): https://ww2.arb.ca.gov/resources/inhalable-particulate-matter-and-health#:~:text=Fine%20particulate%20matter%20 is%20defined,comprises%20a%20portion%20of%20PM10. CAPCOA and CARB, Non-Vehicular Diesel Engine Risk Assessment Guidance, July 2024 (https://ww2.arb.ca.gov/sites/default/files/classic/ab2588/2024%20DICE%20Screening%20Risk%20 Guidelines.pdf)
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Dispersion Modeling
The HRA’s air dispersion modeling was performed using the American Meteorological Society (AMS) and U.S.

Environmental Protection Agency (EPA) Regulatory Model (AERMOD). AERMOD is a steady state, multiple- source, Gaussian dispersion model designed for use with emission sources situated in terrain where ground elevations can exceed the stack heights of the emission sources. AERMOD estimates hourly concentrations for each source/receptor pair and calculates concentrations for user-specified averaging times, including an average concentration for the complete simulation period. AERMOD includes atmospheric dispersion options for both urban and rural environments and can address flat, gently rolling, and complex terrain situations. The modeling and analysis were prepared in accordance with the SCAQMD Modeling Guidance for AERMOD.41 The parameters used in AERMOD include the following:
• Meteorological Data. AERMOD requires hourly meteorological data consisting of wind vectors, wind speed, temperature, atmospheric stability, and mixing height. The latest 5-year meteorological data set for the Fontana (FONT) Monitoring Station (Station 36197) was obtained from the SCAQMD.42 The Fontana Monitoring Station is the closest station to the Project site and located approximately 11 miles to the southwest. Surface and upper air meteorological data from this station were selected as being the most representative of meteorology based on proximity to the Project site, as well as terrain, surrounding land uses, and surface characteristics.
• Project Sources. On- and off-road emission sources (i.e., onsite equipment and off-site haul trucks) were modeled in AERMOD as line volume sources (comprised of smaller adjacent volume sources). Off- road equipment operating onsite and on-road equipment (hauling materials from the Project site) were assigned a release height of 10.5 feet (3.2 meters) and a plume height of 20.6 feet (6.3 meters) based on a vehicle height of 12 feet (3.7 meters). The methodology used to determine release and plume heights was based on U.S. EPA guidance for vehicle volume sources.43 • Receptor Grid. To identify the maximum impacted sensitive receptors, a uniform Cartesian grid was placed over the sensitive receptors in the Project site’s vicinity. According to the SCAQMD, a grid spacing of 100 meters or less must be used to identify the maximum impacted receptors (i.e., peak cancer risk and peak hazard indices).44 Given the Project site’s size, sensitive receptors were modeled with a maximum of 50-meter grid spacing.
• Terrain Characteristics. As recommended by the SCAQMD, the United States Geological Survey (USGS) National Elevation Dataset (NED) terrain data was imported into AERMOD. AERMOD regulatory defaults, the “Urban” modeling option for the County, and “Elevated” terrain were used for this analysis.
• Averaging Times. AERMOD was run to obtain the annual average (period) concentration in micrograms per cubic meter (μg/m3) of PM10 at the nearby sensitive receptors. According to the SCAQMD’s Supplemental Guidelines for Preparing Risk Assessments for AB 2588, air dispersion modeling is required to estimate annual average concentrations to calculate the Maximally Exposed Individual Resident (MEIR), the maximum chronic hazard index, and the zones of impact.

Risk Assessment
Cancer Risk. Based on the OEHHA methodology, residential inhalation cancer risk from annual average DPM concentrations are calculated by multiplying the daily inhalation dose, cancer potency factor, age sensitivity factor (ASF), frequency of time spent at home, and exposure duration divided by averaging time, yielding the 41 South Coast Air Quality Management District, SCAQMD Modeling Guidance for AERMOD, http://www.aqmd.gov/home/airquality/ meteorological-data/modeling-guidance, accessed March 2025. 42 South Coast Air Quality Management District, Health Risk Assessment Tool and AERMOD-Ready Meteorological Data Files, https://www.aqmd.gov/assets/aermet/AERMET_files_And_HRA_Tool.html, accessed March 2025. 43 U.S. EPA, Haul Road Workgroup Final Report, 2012,
https://www.epa.gov/sites/default/files/202010/documents/haul_road_workgroup-final_report_package-20120302.pdf, accessed March 2025.
44 South Coast Air Quality Management District, SCAQMD Modeling Guidance for AERMOD, https://www.aqmd.gov/home/airquality/meteorological-data/modeling-guidance, accessed March 2025.

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excess cancer risk. These factors are discussed in more detail below. Exposure through inhalation (Dose-air) is a function of breathing rate, exposure frequency, and concentration of substance in the air. To estimate cancer risk, the dose was estimated by applying the following formula to each ground-level concentration:

Dose-air = Cair*(BR/BW)*A*EF*10-6
Dose-air = dose through inhalation (mg/kg/day)
Cair = air concentration (μg/m3) from air dispersion model (DBR/BW) = daily breathing rate normalized to body weight (L/kg bodyweight-day) A = inhalation absorption factor (unitless)
EF = exposure frequency (approximately 365 days per year) 10-6 = conversion factor (micrograms to milligrams, liters to cubic meters) Table 15, Exposure Assumptions presents assumptions utilized to calculate cancer risk. Fraction of time at home (FAH) during the day is used to adjust exposure duration and cancer risk from a specific facility’s emissions, based on the assumption that exposure to the facility’s emissions is not occurring away from home. ASFs, FAH, and daily breathing rates are based on the OEHHA methodology. The Project exposure duration would range from 35 to 72 days depending on the alternative selected. OEHHA developed ASFs to consider the increased sensitivity to carcinogens during early-life exposure. However, OEHHA’s ASF factors generally cannot validly be applied to Project-level HRAs because neither the City nor SCAQMD has developed guidance or rules as to whether these factors should be used to analyze the DPM health risk associated with construction/operations of a non- stationary-source land use Project.45 Nonetheless, ASFs were conservatively included in this Project-level HRA.

Table 15.

Exposure Assumptions
Scenario Age
Exposure
Frequency
(days/year)1
Exposure
Duration
(years)2
Age
Sensitivity
Factor (ASF)3
Fraction of
Time at Home
(FAH)4
Daily
Breathing
Rate (L/kg
BW-day)5,6
Debris
Removal/Hauling
Residential 350 0.20 10 100% 1,090
Student 180 0.20 3 N/A 640
Source: California Office of Environmental Health Hazard Assessment, Air Toxics Program Guidance Manual for the Preparation of Health Risk Assessments, February 2015 and South Coast Air Quality Management District, Permit Application Package “N” Risk Assessment Procedures for Rules 1401, 1401.1, and 212 Version 8.1. 1 The exposure frequency is based on OEHHA Air Toxics Program Guidance Manual for the Preparation of Health Risk Assessments, February 2015 (OEHHA Manual); refer to OEHHA Manual Section 5.4.1, Estimation of Exposure through Inhalation. 2 The exposure duration is based on the OEHHA Manual) refer to OEHHA Manual Equation 8.2.4 A. As debris removal and hauling activities would occur for 35 to 72 days (depending on the alternative), the exposure duration was conservatively adjusted to 0.2 years (i.e., 72/365), which is the longest anticipated duration. The exposure duration also conservatively uses the earliest start age. 3 The age sensitivity factor is based on OEHHA Manual Table 8.3, Age Sensitivity Factors by Age Group for Cancer Risk Assessment. 4 The fraction of time at home is based on OEHHA Manual Section 8.2.2, Fraction of Time Spent at Home for Cancer Risk Assessment.
5 Daily breathing rate normalized to body weight (L/kg body weight – day) (95th percentile for 3rd trimester to 2 years and 80th percentile for other age groups) per OEHHA Manual Table 5.7, Daily Breathing Rate Distributions by Age Group for Residential Stochastic Analysis (L/kg BW-day).
6 Student breathing rates are 95th percentile 8-hour breathing rates based on moderate intensity activity.

To estimate the cancer risk, the dose is multiplied by the cancer potency factor, the exposure duration divided by averaging time, and the frequency of time spent at home (for residents only):

Riskinh-res = (Doseair*CPF*(ED/AT)*FAH)
45 Stationary sources can include large power plants and refineries to the corner gas station. Many consumer products such as house paint, furniture varnish, and products containing solvents are also considered stationary sources. (SCAQMD, Air Quality Sensor Performance Evaluation Center, https://www.aqmd.gov/aq-spec/aboutscaqmd, accessed April 2025.) Packet Page. 482
Riskinh-res = residential inhalation cancer risk (potential chances per million) Doseair = daily dose through inhalation (mg/kg-day)
CPF = inhalation cancer potency factor (mg/kg-day-1)
ED = exposure duration (years)
AT = averaging time of lifetime cancer risk (years)
FAH = fraction of time spent at home (unitless)
Non-Cancer Risk. The chronic non-cancer risk is calculated by dividing the annual average concentration by the REL for that substance. The REL is defined as the concentration at which no adverse non-cancer health effects are anticipated. According to OEHHA, the REL for DPM is 5 and the target organ is the respiratory system.46 The following equation was used to determine the chronic non-cancer risk hazard index:

Hazard Index = Ci/RELi
Ci = concentration in the air of substance (annual average concentration in μg/m3) RELi = chronic noncancer Reference Exposure Level for substance (μg/m3) Health Risk Computation. A health risk computation was performed to determine the cancer risk and chronic non- cancer risk using the approach described in the OEHHA Air Toxics Program Guidance Manual for the Preparation of Health Risk Assessments, dated February 2015 (OEHHA Guidance Manual). Health risks were analyzed at the point of maximum impact and are a conservative estimate. The pollutant concentrations are then used to estimate the long-term cancer risk to an individual as well as the chronic non-cancer risk hazard index.

The individual cancer and chronic non-cancer risks are based on the annual average concentration of PM 10 (used as a proxy for DPM). As noted above, the chronic and carcinogenic health risk calculations are based on the standardized equations contained in the U.S. EPA Human Health Evaluation Manual (1991) and the OEHHA Guidance Manual. The concentration estimates developed using this methodology are conservative and not a specific prediction of the actual concentrations that would occur at the Project site at any given point in time.

Actual pollutant concentrations and health risk levels are dependent on numerous variables, particularly the number and types of vehicles and equipment operating at specific distances during periods of adverse meteorology. The health risk computation was performed to determine the risk of developing an excess cancer risk calculated on these worst-case exposure duration scenarios. Only the risk associated with the Project’s worst-case location was assessed.

Potential Health Risk Impacts
CARB identified DPM as a TAC in 1998. Mobile sources (including trucks, buses, automobiles, trains, ships, and farm equipment) are by far the largest diesel emissions source. Diesel exhaust is emitted from a broad range of on- and off-road diesel engines. As the Project site is near existing sensitive receptors (e.g., the single-family residences located approximately 40 feet to the east as well as student receptors along Palm Avenue, 2,425 feet to the south), an analysis of DPM was performed using the U.S. EPA-approved AERMOD model.

Carcinogenic Risk
Table 16, Carcinogenic Risk Assessment shows the unmitigated health risk for the Project alternatives. As detailed in Table 16 below, the worst-case alternative would result in a maximum cancer risk of 3.40 in one million for residential receptors and 0.24 at the student receptors. Alternative 2.2.1 has the highest risk levels due to the overall duration and number of truck trips. Exposure to carcinogenic TACs (DPM for this Project) does not imply that the exposed individual would contract cancer; rather, the cancer risk is a probability of developing cancer if other factors (e.g., heredity, exposure to environmental or workplace risks that compromise the immune system, overall health) would result in an increased susceptibility to developing cancer. The overall risk levels for the Project’s worst-case alternative demonstrate a low probability increase (in a population of one million) for cancer risk from debris removal. It is noted that this analysis uses OEHHA’s 46 California Office of Environmental Health Hazard Assessment, Guidance Manual for Preparation of Health Risk Assessments Appendices A-F, February 2015.

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health-protective exposure assumptions to avoid underestimating risk. For example, the risk estimate for airborne exposure to chemical emissions uses the health-protective assumption that the individual has a high breathing rate and exposure began early in life when cancer risk is highest.

The analysis in Table 16 includes Alternatives 1 and 2, and therefore includes risk related to DPM from both onsite equipment exhaust and onsite and off-site haul truck exhaust. Because Alternative 3 would not include hauling off-site, the DPM associated with Alternative 3 would only be generated by onsite equipment operations, and Alternative 3 would inherently result in less risk than Alternative 1. As none of the alternatives in Table 16 exceed the SCAQMD’s 10 in one million threshold, impacts would be less than significant.

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Table 16.

Carcinogenic Risk Assessment
Receptor Type Receptor Location Cancer Risk (per
Million)1
Significance
Threshold
(per Million)
Risk Exceeds
Threshold?
Alternative 1.1
Residential Northeast corner of Melvin Ave.
and Palm Avenue 0.06 10 No
Residential Along east side of N. Windsong
Court 0.15 10 No
Student Palm Avenue Elementary School
665 Palm Avenue 0.01 10 No
Alternative 1.2
Residential Northeast corner of Melvin Ave.
and Palm Avenue 0.04 10 No
Residential Along east side of N. Windsong
Court 0.14 10 No
Student Palm Avenue Elementary School
665 Palm Avenue 0.01 10 No
Alternative 2.1.1
Residential Northeast corner of Melvin Ave.
and Palm Avenue 0.06 10 No
Residential Along east side of N. Windsong
Court .020 10 No
Student Palm Avenue Elementary School
665 Palm Avenue 0.01 10 No
Alternative 2.1.2
Residential Northeast corner of Melvin Ave.
and Palm Avenue 0.04 10 No
Residential Along east side of N. Windsong
Court 0.16 10 No
Student Palm Avenue Elementary School
665 Palm Avenue 0.01 10 No
Alternative 2.2.1
Residential Northeast corner of Melvin Ave.
and Palm Avenue 1.27 10 No
Residential Along east side of N. Windsong
Court 3.40 10 No
Student Palm Avenue Elementary School
665 Palm Avenue 0.24 10 No
Alternative 2.2.2
Residential Northeast corner of Melvin Ave.
and Palm Avenue 0.80 10 No
Residential Along east side of N. Windsong
Court 2.76 10 No
Student Palm Avenue Elementary School
665 Palm Avenue 0.20 10 No
1 The reported risk is at the closest maximally exposed individual residents (MEIR).

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Non-Carcinogenic Risk
The SCAQMD also requires an evaluation of non-cancer risk from TAC exposure stated in terms of a hazard index. The chronic non-carcinogenic health impacts expressed as a hazard index is an indicator of whether non- cancer health effects can occur due to exposure to toxic air contaminants. As discussed above, off-road equipment and hauling activities would generate DPM emissions, which is the primary TAC of concern. Table 17, Chronic Hazard Assessment shows the chronic noncancer risk hazard index from Project emissions. A chronic non-cancer risk hazard index of 1.0 or greater is considered individually significant. The analysis in Table 17 includes Alternatives 1 and 2 and therefore includes a hazard index related to DPM from both onsite equipment exhaust and onsite and off-site haul truck exhaust. Because Alternative 3 would not include hauling off-site, the DPM associated with Alternative 3 would only be generated by onsite equipment operations, and Alternative 3 would inherently result in a lower hazard index than Alternative 1. The highest maximum chronic hazard index from Project DPM emissions would be 0.0207 at the nearest residential receptors, and 0. 0166 at the nearest student receptors. A hazard index that is less than or equal to one indicates that noncarcinogenic health effects are not likely to occur over a lifetime of exposure. Therefore, as the noncarcinogenic hazards are well below the 1.0 hazard index threshold, health effects from short-term exposure are not likely to occur and a less than significant impact would occur.

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Table 17.

Chronic Hazard Assessment
Receptor Type Receptor Location Concentration
(μg/m3) 1 Chronic Hazard2
Alternative 1.1
Residential Northeast corner of Melvin Ave. and Palm
Avenue 0.002 0.0004
Residential Along east side of N. Windsong Court 0.005 0.0009 Student Palm Avenue Elementary School
665 Palm Avenue 0.004 0.0008
Alternative 1.2
Residential Northeast corner of Melvin Ave. and Palm
Avenue 0.001 0.0003
Residential Along east side of N. Windsong Court 0.004 0.0008 Student Palm Avenue Elementary School
665 Palm Avenue 0.003 0.0007
Alternative 2.1.1
Residential Northeast corner of Melvin Ave. and Palm
Avenue 0.002 0.004
Residential Along east side of N. Windsong Court 0.006 0.0012 Student Palm Avenue Elementary School
665 Palm Avenue 0.005 0.0010
Alternative 2.1.2
Residential Northeast corner of Melvin Ave. and Palm
Avenue 0.001 0.0002
Residential Along east side of N. Windsong Court 0.005 0.0010 Student Palm Avenue Elementary School
665 Palm Avenue 0.004 0.0008
Alternative 2.2.1
Residential Northeast corner of Melvin Ave. and Palm
Avenue 0.039 0.0078
Residential Along east side of N. Windsong Court 0.104 0.0207 Student Palm Avenue Elementary School
665 Palm Avenue 0.083 0.0166
Alternative 2.2.2
Residential Northeast corner of Melvin Ave. and Palm
Avenue 0.024 0.0049
Residential Along east side of N. Windsong Court 0.084 0.0168 Student Palm Avenue Elementary School
665 Palm Avenue 0.068 0.0136
SCAQMD Threshold N/A 1.0
Threshold Exceeded? N/A No
1 The reported pollutant concentration (annual period) is at the closest receptor (maximally exposed individual receptor). 2 It is noted that there is no acute REL for DPM and acute health risk cannot be calculated.

Conclusion
As concluded above, the Project’s cancer and non-cancer risks from DPM emissions would be less than significant, as both would be below the SCAQMD’s thresholds of significance for all Alternatives.

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It is noted that this analysis assesses the Project’s incremental contribution to health risk impacts, consistent with the SCAQMD guidance and methodology. The SCAQMD has not established separate cumulative thresholds and does not require combining impacts from cumulative Projects. The SCAQMD considers Projects that do not exceed the Project-specific individual incremental thresholds to not be cumulatively significant.47 Therefore, because the Project’s health risks (i.e., cancer and non-cancer) would not exceed the Project- specific incremental thresholds, the Project would not result in a cumulatively significant impact and the Project’s contribution would be less than cumulatively considerable.

3.3 Noise
Noise Background
Sound is technically described in terms of amplitude (loudness) and frequency (pitch). The standard unit of sound amplitude measurement is the decibel (dB). The decibel scale is a logarithmic scale that describes the physical intensity of the pressure vibrations that make up any sound. The pitch of the sound is related to the frequency of the pressure vibration. Since the human ear is not equally sensitive to a given sound level at all frequencies, a special frequency-dependent rating scale has been devised to relate noise to human sensitivity.

The A-weighted decibel scale (dBA) provides this compensation by discriminating against frequencies in a manner approximating the human ear's sensitivity.

Noise, on the other hand, is typically defined as unwanted sound. A typical noise environment consists of a base of steady ambient noise that is the sum of various distant and indistinguishable noise sources.

Superimposed on this background noise is the sound from individual local sources. These can vary from an occasional aircraft or train passing by to virtually continuous noise from traffic on a major highway.

Several rating scales have been developed to analyze the adverse effects of community noise on people. Since environmental noise fluctuates over time, these scales consider that the effect of noise on people is largely dependent on the total acoustical energy content of the noise as well as the time of day when the noise occurs.

For example, the equivalent continuous sound level (Leq) is the average acoustic energy content of noise for a stated period of time; thus, the Leq of a time-varying noise and that of a steady noise are the same if they deliver the same acoustic energy to the ear during exposure. The Day-Night Sound Level (Ldn) is a 24-hour average Leq with a 10 dBA “weighting” added to noise from 10:00 PM to 7:00 AM to account for noise sensitivity in the nighttime. The Community Noise Equivalent Level (CNEL) is a 24-hour average Leq with a 10 dBA weighting added to noise from 10:00 PM to 7:00 AM and an additional 5 dBA weighting from 7:00 PM to 10:00 PM to account for noise sensitivity in the evening and nighttime.

Regulatory Setting
State of California Noise Standards
The State of California does not have standards for environmental noise, but the Governor’s Office of Land Use and Climate Innovation (Governor’s Office) has established general plan guidelines for evaluating the compatibility of various land uses as a function of community noise exposure.48 The purpose of these guidelines is to maintain acceptable noise levels in a community setting for different land use types. The guidelines rank noise land use compatibility in terms of “normally acceptable,” “conditionally acceptable,” “normally unacceptable,” and “clearly unacceptable” noise levels for various land use types.

In addition, California Government Code Section 65302(f) mandates that the legislative body of each county and city adopt a noise element as part of its comprehensive general plan. The local noise element must recognize the land use compatibility guidelines established by the Governor’s Office. 47 South Coast Air Quality Management District, White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution, August 2003.
48 State of California Governor’s Office of Planning and Research, General Plan Guidelines, Appendix D: Noise Element Guidelines, page 374, 2017, https://opr.ca.gov/docs/OPR_COMPLETE_7.31.17.pdf, accessed March 2025.

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City of San Bernardino General Plan
The City General Plan includes a Noise Element that contains goals and policies to protect residents from potentially adverse noise impacts.

Noise Element
The following goals and policies are applicable to the Project:

Goal 14.2 Encourage the reduction of noise from transportation related noise sources such as motor vehicles, aircraft operations, and railroad movements.

Policy 14.2.3 Require that development that increases the ambient noise level adjacent to noise-sensitive land uses provide appropriate mitigation measures. (LU-1) Policy 14.2.8 Minimize noise attributable to vehicular travel in residential neighborhoods by inhibiting through trips by the use of cul-de-sacs, one-way streets, and other traffic controls.

Policy 14.2.9 Enforce sections of the California Vehicle Code related to mufflers and modified exhaust systems.

Policy 14.2.19 As may be necessary, require acoustical analysis and ensure the provision of effective noise mitigation measures for sensitive land uses, especially residential uses, in areas significantly impacted by noise.

Goal 14.3 Protect residents from the negative effects of “spill over” or nuisance noise.

Policy 14.3.1 Require that construction activities adjacent to residential units be limited as necessary to prevent adverse noise impacts. (LU-1)
Policy 14.3.2 Require that construction activities employ feasible and practical techniques that minimize the noise impacts on adjacent uses. (LU-1) City of San Bernardino Municipal Code
The City regulates temporary and excessive noise sources through Municipal Code Chapter 8.54: Noise Control.

Municipal Code 8.54.020, Prohibited Acts, prohibits the following:
• Loud and excessive noise associated with loading or unloading vehicles; and • the use of pile driver, steam shovel, pneumatic hammers, derrick, steam or electric hoist, power driven saw or any other tool or apparatus that causes loud and excessive noise between hours of 10:00 PM and 8:00 AM, except with the City’s approval.

Municipal Code 8.54.050, Controlled Hours of Operations, limits the following activities to the hours of 8:00 AM and 8:00 PM in residential zones:
• The loading or unloading of vehicles and the use of dollies, carts, forklifts or other wheeled equipment that causes any impulsive or unnecessary noise within 1,000 feet of a residence; and • the use of any motor vehicle with a gross vehicle weight rating in excess of 10,000 pounds or of any auxiliary equipment attached to such a vehicle for a period longer than 15 minutes in any hour while the vehicle is stationary and on a public right-of-way or public space.

Municipal Code 8.54.070, Disturbances from Construction Activity, establishes that the demolition, construction, or improvement of any building or structure is restricted to the hours of 7:00 AM and 8:00 PM.

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City of San Bernardino Development Code
The City regulates residential noise standards through the Development Code, Chapter 19.20: Property Development Standards. Section 19.20.030.15 establishes that no exterior noise level in residential areas shall exceed 65 dBA.

Environmental Setting
Mobile noise sources, especially cars and trucks, are the City's most common and significant noise sources.

The existing mobile noise sources in the Project area are generated by motor vehicles traveling on Palm Avenue, adjacent to the Project site. Other noise sources within the City are generated by the various land uses (i.e., residential, commercial, institutional, and recreational). The primary stationary noise sources in the Project area are those associated with the surrounding residential uses, which include idling and moving vehicles, mechanical equipment (e.g., heating, ventilation, and air conditioning [HVAC] equipment), dogs barking, yard maintenance, and people talking. The noise associated with these stationary sources may represent a single- event noise occurrence or short-term noise.

Sensitive Noise Receptors
Noise exposure standards and guidelines for various types of land uses reflect varying noise sensitivities associated with uses. Sensitive noise receptors are defined as residences, schools, childcare centers, long term health facilities, and houses of worship. The nearest sensitive receptors to the disturbance area are listed in Table 18, Sensitive Receptors and shown in Exhibit 3, Sensitive Receptors.

Table 18.

Sensitive Receptors
Sensitive Receptor1 Distance2 and Direction from the Disturbance Area 1-Residential Uses 40 feet to the east
2-Residential Uses 114 feet to the southeast
3-Residential Uses 600 feet to the south
4-Residential Uses 893 feet to the southwest
5-Palm Avenue Elementary School 2,425 feet to the south Source: Google Earth, 2025
1 The residential uses listed above are the nearest sensitive receptors surrounding the disturbance area and are representative of the existing environment between the disturbance area and the Palm Avenue Elementary School. 2 Distance measured from the disturbance area to the nearest sensitive receptor property line.

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Not to scale
Exhibit 3: Sensitive Receptors
Oxbow Debris Removal Project
Source: Google Earth, 2025
LEGEND
Sensitive Receptors
Disturbance Area
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Noise Measurements
To quantify existing ambient noise levels in the Project site, Kimley-Horn conducted four short-term (10-minute) noise measurements on March 5, 2025; see Appendix C: Noise Data for additional details regarding how the ambient noise measurements were taken. The noise measurement sites were selected to represent the existing noise exposure at the nearest sensitive noise receptors to the disturbance area within the Project site. The 10- minute daytime measurements were taken between 10:03 AM and 11:01 AM. Measurements of Leq are considered representative of the noise levels throughout the day. The average noise levels measured at each location are listed in Table 19, Existing Noise Measurements. The noise measurement locations are shown in Exhibit 4, Noise Measurement Locations.

Table 19.

Existing Noise Measurements
Site Location Measurement Period Duration dBA Leq
ST-1 Within the Palm Avenue Elementary School
parking lot, south of the Project site 10:11 AM – 10:21 AM 10 minutes 50.7 ST-2
Southwest corner of Palm Avenue and West
Verdemont Drive, adjacent to the residential use
and south of the Project site
10:29 AM – 10:39 AM 10 minutes 48.0
ST-3
Cul-de-sac on North Zachary Court, adjacent to
the residential uses and southeast of the Project
site
10:43 AM – 10:53 AM 10 minutes 61.4
ST-4 6961 North Melvin Avenue, adjacent to the
residential uses and east of the Project site 10:59 AM – 11:09 AM 10 minutes 45.0 Source: Noise measurements taken by Kimley-Horn and Associates, March 5, 2025. See Appendix C for the noise measurement results.

Noise Impacts
Onsite Operations Noise
Operational noise typically occurs intermittently and varies depending on the nature or phase of the activity (e.g., land clearing, grading, excavation, or paving). Noise generated by equipment, including earth movers and material handlers, can reach high levels. During debris removal operations, exterior noise levels could affect sensitive noise receptors nearest the site, herein referred to as the disturbance area.

The Project activities would include site preparation/grading and debris removal. Such activities would require graders for grading and loaders, tractors, hoe rams, crushers, and dump trucks for debris removal. Alternative 3 would require only one loader and would not include dump trucks.

Typical equipment operating cycles may involve 1 or 2 minutes of full-power operation followed by 3 to 4 minutes at lower power settings. Other primary sources of acoustical disturbance would be random incidents, which would last less than one minute (such as dropping large pieces of equipment or the hydraulic movement of machinery lifts). Typical noise levels associated with individual equipment anticipated to be used during Project operations are listed in Table 20, Project Operations Equipment Noise Levels.49 49 Federal Highway Association, Roadway Construction Noise Model, User Guide, 2005.

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Not to scale
Not to scale
Exhibit 4: Noise Measurement Locations
Oxbow Debris Removal Project
Source: Google Earth, 2025
LEGEND
Noise Measurement
Locations
Disturbance Area
11 22 33
44 ##
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Table 20.

Project Operations Equipment Noise Levels
Operations Phase Equipment1
Typical Noise Level
(dBA Lmax) at 50 feet
from Source
Usage Factor (%)2
Grading Grader 85 40
Alternative 1: Crushing
Removal
Hoe Ram (Breaker)
Crusher
Street Sweeper
Loader
Dump Truck
90 85
82 79
77 20
50 10
40 40
Alternative 2: Non-Crushing
Removal
Hoe Ram (Breaker)
Street Sweeper
Loader
Dump Truck
90 82
79 77
20 10
40 40
Alternative 3: Crushing Onsite and Retaining Onsite
Removal
Hoe Ram (Breaker)
Crusher
Loader
90 85
79 20
50 40
Source: Federal Highway Association, Roadway Construction Noise Model, User Guide, 2005. 1 Equipment based on input from CSG Consultants.
2 The usage factor represents the fraction of time that the equipment would be in use at full power over a specific period.

It should be noted that the values shown in Table 20 account for the equipment operating at full power at 50 feet from the source, without any intervening structures or topography that may reduce noise levels. Noise was calculated accounting for each piece of equipment’s usage factor, or the fraction of time that the equipment would be in use at full power over a specific period of time.50 As the usage factor indicates the fraction of time the equipment operates at full power, the remaining fraction of time the equipment may be operating at lower power settings. The usage factors are derived from empirical data and are essential for calculating the overall noise levels generated by debris removal activities.51 Usage factors are used alongside other parameters such as equipment noise emission levels and acoustical propagation formulas to provide a detailed prediction of noise that represents activities occurring under normal operating conditions during a full workday.

The Federal Highway Administration’s (FHWA’s) Roadway Construction Noise Model (RCNM) was used to calculate the noise levels at the sensitive receptors nearest the disturbance area. Noise levels at other receptors surrounding the disturbance area would be located further away and would experience lower noise levels than the modeled receptors. When calculating noise, the street sweeper and the loudest piece of anticipated equipment is conservatively assumed to operate at the property line nearest to the modeled receptor while all other anticipated equipment for each phase is assumed to operate at the center of the disturbance area. In addition, it is conservatively assumed the equipment would operate in a simultaneous manner. This methodology represents a worst-case noise scenario, as this accounts for the known street sweeper location and the equipment operating throughout the area at different intervals and not at a fixed location for extended periods of time.
52 50 Ibid.
51 Federal Highway Administration, Construction Noise Handbook, 2017, https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook00.cfm accessed April 2025. 52 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018.

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The City has not established quantitative construction/operations noise standards. For purposes of this analysis, the criteria from the Federal Transit Administration (FTA) Transit Noise and Vibration Manual are used as significance thresholds to determine the noise impact on the nearest sensitive receptors. The FTA’s residential use noise threshold is 80 dBA Leq.53 As the FTA has not included a recommended threshold for institutional uses, this analysis uses the residential use noise threshold as the significance threshold. The FTA’s 80 dBA daytime noise threshold is designed to balance the need for operation activities with the protection of public health and welfare. It considers factors such as:
• Human response to noise: Studies on how different noise levels affect people's comfort, health, and productivity.
• Environmental impact: The potential effects of noise on wildlife and natural habitats. • Technical feasibility: The ability to implement noise mitigation measures effectively during operations.

This threshold considers the temporary nature of the debris removal activity and recognizes that construction related equipment is a routine aspect of the urban environment. The City frequently issues building permits for similar activities (e.g., construction projects), making such activities a common occurrence. As a result, the City’s threshold reflects reasonable noise expectations while incorporating absolute noise limits designed to protect human health. Although Project operations may cause a noticeable increase in ambient noise levels, the noise would be temporary and would occur during daytime hours (outside of the sensitive sleeping hours).

Crushing activities associated with Alternatives 1 and 3 would involve a crushing device that would process the concrete, and a conveyor belt would discharge the processed concrete into a pile. The urban version of the LT96 is designed for quieter operation, with up to 60 percent noise reduction compared to conventional crushers. 54 The
Urban LT96 uses noise covers that provide noise suppression across several points, including the main conveyor beneath the crushing mechanism. This analysis conservatively did not apply the noise reduction from the Urban LT96.

Table 21, Maximum Project Operations Noise Levels summarizes the maximum estimated Project noise level at the nearest sensitive receptors. For Alternative 1.1, operation activities would produce the highest noise levels compared to the other alternatives, as this alternative would require crushing equipment onsite and would require more daily haul trucks onsite than Alternative 1.2. Alternative 3, which would only include the crushing activities associated with Alternative 1 and would not include a hauling operation, would produce lower noise levels than Alternatives 1.1 and 1.2. See Appendix C for the estimated noise for each alternative.53 For reference, 80 dBA is comparable to the noise level along a busy city street (California Office of Planning and Research, General Plan Guidelines, 2017, U.S. Department of Housing and Urban Development, Noise Guidebook, 1985). 54 Metso, Lokotrack Urban Series, Solutions for Populated Environments, 2023.

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Table 21.

Maximum Project Operation Noise Levels
Receptor Maximum Noise Level at
Receptor (dBA Leq)1 Threshold (dBA Leq) Exceeded?
1 – Residential Uses 73.8 80 No
2 – Residential Uses 67.1 80 No
3 – Residential Uses 58.8 80 No
4 – Residential Uses 56.1 80 No
5 – Palm Avenue Elementary
School 56.4 80 No
Source: Federal Highway Administration, Appendix A: Best practices for Calculating Estimated Shielding for Use in RCNM, https://www.fhwa.dot.gov/Environment/noise/construction_noise/rcnm/rcnm10.cfm#appa, accessed March 2025.

Source: Federal Highway Administration, Roadway Construction Noise Model, 2006. Refer to Appendix C for the noise modeling results for each alternative.
1 The maximum noise level at the residential uses assumes an 8 dBA reduction, as the residential uses would be shielded by a solid barrier.

As shown in Table 21, the highest anticipated noise level of 73.6 dBA Leq would not exceed the FTA’s threshold of 80 dBA Leq for residential uses. Operation-related noise would be temporary, lasting only as long as the activities occur. Therefore, it would not be appropriate to evaluate the ambient noise increase attributable to Project activities. Project activities would not result in a permanent increase in ambient noise levels in the Project area.

Pursuant to Municipal Code Section 8.54.070, construction related activities within the City would be restricted to the hours of 7:00 AM to 8:00 PM. The City’s permitted hours of operation are required in recognition that operational activities undertaken during daytime hours are a typical part of living in an urban environment and do not cause a significant impact. Impacts would be less than significant, and no mitigation is required.

Off-Site Noise
Project activities would generate mobile source noise from haul trucks (Alternatives 1 and 2) and workers traveling to and from the disturbance area (all Alternatives). Haul trucks and worker vehicles would travel to and from the disturbance area using Palm Avenue. Haul trucks would continuously arrive and leave during debris removal activities to transport the concrete debris off-site. Workers are expected to arrive at the disturbance area before operations begin and leave when operations end.

The noise level associated with haul truck trips on Palm Avenue was calculated using the Housing and Urban Development Day/Night Noise Level Calculator, which accounts for the vehicle type, average speed, distance from centerline, and traffic volumes. Alternative 2.1.1 would require the highest number of daily bobtail (medium duty) dump truck trips, with 260 bobtail dump trucks (520 truck trips) accessing the disturbance area.
55 The maximum noise generated by using bobtail dump trucks would be 54 CNEL at 50 feet from the roadway centerline and would not exceed the City’s residential exterior noise standard of 65 dBA. On-road truck noise levels were calculated with the U.S. Department of Housing and Urban Development’s (HUD) Day/Night Noise Level Assessment Tool,56 the roadway noise tool which calculates roadway noise based on HUD’s Noise Assessment Guidelines. Noise levels are based on vehicle type, daily vehicle trips, vehicle speed, night fraction of traffic, and distance from the roadway.

Alternative 2.2.1 would require the highest number of daily single-end (heavy-duty) dump truck trips, with 132 single-end dump trucks (264 truck trips) accessing the disturbance area.57 The maximum noise generated by using single-end dump trucks would be 62 CNEL at 50 feet from the roadway centerline58 and would not exceed 55 Daily haul trips based on input from CSG Consultants. 56 U.S. Department of Housing and Urban Development, Day/Night Noise Level Assessment Tool https://www.hudexchange.info/programs/environmental-review/dnl-calculator/, accessed February 2025. 57 Daily haul trips based on input from CSG Consultants. 58 Traffic noise calculated with HUD’s Day/Night Noise Level Assessment Tool.

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the City’s residential exterior noise standard of 65 dBA. Noise level estimates do not account for the presence of intervening structures or topography; however, the closest sensitive receptors nearest the disturbance area would be shielded by a solid barrier (i.e., concrete masonry block walls are located along the residential property lines across Palm Avenue adjacent to the Project site). Therefore, the noise levels herein represent a conservative, worst-case estimation of the haul truck noise on Palm Avenue. Impacts would be less than significant, and no mitigation is required.

Vibration Impacts
Onsite Operations Vibration
Project-related increases in ground-borne vibration levels would be primarily associated with the operation of heavy-duty equipment. Project operations would have the potential to result in varying degrees of temporary ground-borne vibration, depending on the specific equipment used, and the operations involved. The ground- borne vibration generated by equipment spreads through the ground and diminishes in magnitude with increases in distance.

The types of vibration impacts include human annoyance and building damage. Human annoyance occurs when vibration rises significantly above the threshold of human perception for extended periods of time.

Building damage can be cosmetic or structural. Ordinary buildings that are not particularly fragile would not experience cosmetic damage (e.g., plaster cracks) at distances beyond 30 feet. This distance can vary substantially depending on the soil composition and underground geological layer between the vibration source and receiver. In addition, not all buildings respond similarly to vibration generated by equipment.

The City has not established quantitative vibration standards. For purposes of this analysis, the criteria from the California Department of Transportations (Caltrans) Transportation and Construction Vibration Manual are used as significance thresholds to determine the noise impact on the nearest sensitive receptors. Caltrans identifies the following building damage criteria:
• Extremely fragile historic buildings, ruins, ancient monuments: 0.08 • Fragile buildings: 0.1 PPV
• Historic buildings: 0.25 PPV
• Older residential structures: 0.3 PPV
• New residential structures: 0.5 PPV
• Modern industrial/commercial buildings: 0.5 PPV
The residential structures closest to the disturbance area were constructed around 2006. Caltrans does not specify the age of the building to be considered older residential structures. For vibration impact analyses, a building over 50 years old is typically considered an “older” residential structure. However, the 0.30 in/sec PPV older residential building structural damage standard is conservatively used for this analysis. Additionally, Caltrans’ 0.10 in/sec standard is used to evaluate human annoyance.

The nearest sensitive receptor and structure would be located 68 feet to the east of the disturbance area.

Vibratory equipment with the greatest PPV levels that are anticipated to be used at the disturbance area would include loaded trucks and a hoe ram. Table 22, Typical Equipment Vibration Levels, lists the vibration levels for the anticipated equipment at 25 feet (the reference distance) and 68 feet (the distance to the nearest sensitive receptor and structure).

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Table 22.

Typical Equipment Vibration Levels
Equipment Peak Particle Velocity at 25 feet
(in/sec)
Peak Particle Velocity at 68 feet
(in/sec)
Loaded Trucks 0.076 0.017
Hoe Ram (Breaker) and Crusher 0.089 0.020
Rock Breaker 0.059 0.013
Jackhammer 0.035 0.008
Small Bulldozer/Tractor 0.003 0.0007
Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, 2018.

As shown in Table 22, the vibration from anticipated heavy-duty equipment would range from 0.0007 to 0.020 in/sec at the nearest sensitive receptor and structure. Therefore, vibration associated with Project activities would not exceed the Caltrans’ threshold of 0.10 in/sec PPV for human annoyance or 0.30 in/sec PPV for older residential uses. Impacts would be less than significant, and no mitigation is required.

Off-Site Vibration
Under Alternatives 1 and 2, haul trucks traveling to and from the disturbance area would generate vibration events on Palm Avenue. According to the FTA’s Transit Noise and Vibration Impact Assessment, a truck rarely creates vibration levels that exceed 70 VdB (equivalent to 0.012 inches per second PPV) when on a roadway.59 The factors influencing levels of ground-borne vibration include vehicle speed, vehicle suspension, and wheel condition and type. The frequency of vibration events is not listed as an influencing factor for vibration velocity by the FTA.60 Therefore, multiple haul trucks traveling on the roadway would increase the frequency of vibration events but would not affect the vibration velocity experienced by receptors. Impacts would be less than significant, and no mitigation is required.

Conclusion
The crushing, debris removal, and hauling noise and vibration levels for all Project alternatives would not exceed the applicable standards. The proposed debris removal/hauling would increase noise levels above existing conditions. However, these activities would be temporary and would occur during daytime hours only.

Daytime activities would not affect most of the general public’s sleeping. Potential human health impacts are addressed by the FTA’s thresholds used in this analysis. Also, daytime noise is reduced within buildings by noise insulation standards, which has the effect of reducing operation noise within habitable structures. Project noise and vibration impacts would be less than significant, and no mitigation is required.

However, due to the proximity of receptors, use of the Metso Lokotrack Urban LT96, for crushing under Alternatives 1 and 3, is recommended to minimize noise levels to the greatest extent feasible. As noted above, the Urban LT96 is designed for quieter operation, with up to 60 percent noise reduction compared to conventional crushers. The Urban LT96 uses noise covers that provide noise suppression across several points, including the main conveyor beneath the crushing mechanism.

This analysis conservatively did not apply the noise reduction from the Urban LT96; however, this crusher with additional noise suppression is recommended to minimize nuisances for nearby receptors.

3.4 Truck Routing
A truck routing memorandum has been prepared to outline the recommended truck routes for the proposed Project. The routing analysis applies to Alternatives 1 and 2. 59 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018. 60 Ibid.

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Palm Avenue Description
Palm Avenue is a north-south undivided roadway with residential uses to the east and west from the north end of Palm Avenue to the Interstate 215 (I-215) freeway. Palm Elementary School is located on Palm Avenue between Meyers Road and Belmont Avenue. There is a marked school crossing crosswalks near the north side of the school at the intersection of Palm Avenue and Meyers Road. The street width is approximately 40 feet total (20 feet per lane) at the marked crosswalk with on-street parking prohibited, which is sufficient width for trucks traveling through. Truck drivers should drive cautiously and be aware of their surroundings near the school and residential areas.

From the north end of Palm Avenue near the Project site to Belmont Avenue, Palm Avenue has one lane traveling in each direction. The street width is approximately 40 feet total (20 feet per lane), which is sufficient width for trucks traveling through. On-street parking is permitted along this segment. As such, truck drivers should drive cautiously and be aware of parked vehicles along this segment of Palm Avenue.

From Belmont Avenue to the I-215 freeway interchange, Palm Avenue has two lanes traveling in each direction.

The street width is approximately 64 feet total (12-20 feet per lane), which is sufficient width for trucks traveling through. On-street parking is permitted from Washington Street to Kendall Drive. As such, truck drivers should drive cautiously and be aware of parked vehicles along this segment of Palm Avenue.

Site Access
Trucks should enter the site via the north driveway on Palm Avenue near the north side of the Project site. Truck staging should be completely onsite in order to prevent any truck queuing from spilling out onto Palm Avenue and affecting nearby residents using Palm Avenue. Trucks should circulate onsite and exit the site via the south driveway on Palm Avenue near the south side of the Project site. In order to accommodate the Project operations, the two existing driveway access points would need to be graded and/or leveled with adequate width to allow for both ingress and egress of trucks and hauling of equipment.

Project Truck Safety Measures
The Project plans to provide Best Management Practices (BMPs) in the form of traffic control measures at the existing site access, at minimum, to prevent traffic safety hazards. Safety signage for the site would be subject to Cal/OSHA regulations. Additionally, safety measures would be implemented along Palm Avenue to minimize safety hazards associated with adjacent uses and traffic along Palm Avenue. Signage, flagmen, cones, and temporary stop signs would be placed at the driveways of the Project site when hauling trucks and other equipment enter and exit the site.

The applicant should coordinate with the City of San Bernardino to temporarily add truck restriction signs that prohibit trucks from parking and stopping along Palm Avenue adjacent to the Project site. This would help prevent trucks from queuing along Palm Avenue.

It is recommended that the hauling operation and any crushing operation take place during the school’s summer recess for Palm Elementary School to prevent truck traffic interaction along Palm Avenue during school peak drop-off and pick-up times. Either bobtail dump trucks or single-end dump trucks could be used during this summer recess.

Recommended Project Truck Route
The City of San Bernardino City-Wide Truck Route Study (November 2022) provides designated routes for commercial and industrial trucks. A copy of the City of San Bernardino Proposed Regulatory Truck Routes map is provided on Exhibit 5.

The City of Rialto Ordinance No. 1684 (February 2023) provides designated truck routes within the City of Rialto and established a moratorium to prohibit truck traffic on all other streets except as otherwise provided by law. A copy of the City of Rialto Truck Routes map is provided on Exhibit 6.

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Exhibit 5

CITY OF SAN BERNARDINO TRUCK ROUTES MAP
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Exhibit 6

CITY OF RIALTO TRUCK ROUTES MAP
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Trucks traveling to and from the Project site to the Rialto Recycle Yard would be using the Interstate 215 (I-215) and Interstate 10 (I-10) freeways. Trucks accessing the Project site would use the I-215 freeway at the Palm Avenue interchange. Trucks accessing the Rialto Recycle Yard would use the I-10 freeway at the Riverside Avenue interchange.

Based on review of the City of San Bernardino and City of Rialto truck routes, the following truck route is recommended for the Project:

Project Site to Rialto Recycle Yard:
• Head southwest on Palm Avenue
• Turn left to merge onto I-215 South
• Take exit 40 on I-215 South to merge onto I-10 West
• Take exit 68 on I-10 West for Riverside Avenue
• Turn left onto Riverside Avenue
• Turn left onto Santa Ana Avenue
• Turn left into the Project site via the west driveway Rialto Recycle Yard to Project Site:
• Head west on Santa Ana Avenue
• Turn right onto Riverside Avenue
• Turn right to merge onto I-10 East
• Take exit 72 on I-10 East to merge onto I-215 North
• Take exit 50 on I-215 North for Palm Avenue
• Turn right onto Palm Avenue
• Turn left into the Project site
A map of the recommended truck route is provided in Exhibit 7.

The Project site is located along Palm Avenue. Although this segment of Palm Avenue is not classified as a truck route, it is the most direct street for trucks to use to travel to/from the I-215 freeway. The applicant should coordinate with the City of San Bernardino to determine if approval and/or a permit is needed to use this segment of Palm Avenue.

The recommended truck route includes segments of Riverside Avenue and Santa Ana Avenue, which are classified as truck routes in the City of Rialto. As such, there are no other streets that trucks would need to use other than classified truck routes (Riverside Avenue and Santa Ana Avenue), the I-215 and I-10 freeways, and Palm Avenue.

Conclusion
For Alternatives 1 and 2, trucks moving debris from the Project site to the Rialto Recycle Yard would be using the I-215 and I-10 freeways. Trucks accessing the Project site from the I-215 freeway would use the Palm Avenue interchange. Trucks accessing the Rialto Recycle Yard from the I-10 freeway would use the Riverside Avenue interchange. Within the City of San Bernardino, trucks would use Palm Avenue to enter and exit the Project site.

Within the City of Rialto, trucks would use Riverside Avenue and Santa Ana Avenue to enter and exit the Rialto Recycle Yard.

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Exhibit 7

PROPOSED TRUCK ROUTE

FOR THE OXBOW DEBRIS REMOVAL PROJECT

PROJECT SITE

RIALTO RECYCLE YARD

PALM AVE

RIVERSIDE AVE
INTERSTATE-10
INTERSTATE-215

SANTA ANA AVE
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4 Conclusions and Recommendations

4.1 Conclusions
Air Quality
Based on the air quality modeling analyzed in Section 3.1 and Tables 7 and 11, none of the proposed alternatives would exceed a SCAQMD threshold regarding emissions of criteria pollutants. Using single-end dump trucks for the crushing operation (Alternative 1) would result in lesser emissions of every criteria pollutant compared to the use of bobtail dump trucks. For Alternative 2, if the removal operation was completed during one summer recess period, using single-end dump trucks would result in less overall pollutant emissions than using bobtail dump trucks.

If the operation was completed over two summer recess periods, using single-end dump trucks would result in less emissions of NOx, SO2, PM10, and PM2.5, though ROG and CO emissions would be higher compared to the use of bobtail dump trucks. For all alternatives under Alternative 2, using single-end dump trucks over the course of two summer recess periods (Alternative 2.2.2) would result in less pollutant emissions. Alternative

2.2.2 would also result in less overall pollutant emissions than Alternative 1.2, crushing onsite and using single- end dump trucks.

Though all alternatives for both crushing onsite and hauling the unprocessed material to an offsite facility would result in pollutant emissions well below regional thresholds, the use of single-end dump trucks would result in less emissions. Additionally, using single-end dump trucks to haul the unprocessed concrete debris offsite to be crushed (Alternative 2) would result in lesser pollutant emissions. However, Alternative 3 would not include off-site truck hauling, and emissions would be less than Alternatives 1 and 2. Alternative 3 would therefore be considered the environmentally superior alternative.

Based on Table 13, Localized Significance of Emissions, none of the alternatives would exceed the SCAQMD localized screening threshold; therefore, none of the alternatives would affect human health or worsen local air quality at the nearest sensitive receptors. As is the case with pollutant emissions, using single-end dump trucks for Alternative 1 (crushing onsite) would result in less emissions at a locally significant level than using bobtail dump trucks. For Alternative 2, using single-end dump trucks over either one or two summers would result in less emissions. Overall, using single-end dump trucks over a period of two summer recesses would result in reduced emissions. Because Alternative 3 would not include a hauling operation, it would result in the least emissions and would be considered the superior alternative.

None of the alternatives would result in the generation of a carbon monoxide hotspot, nor would they conflict with or obstruct implementation of the AQMPs.

It is concluded that Alternative 3, crushing onsite and containing onsite, would result in the least air quality emissions.

Health Risk
Based on the calculations in the Health Risk Assessment and the results in Table 1 6, Carcinogenic Risk Assessment, none of the alternatives would generate TAC exposure -related cancer risk in exceedance of the SCAQMD’s thresholds. All of the alternatives would result in a negligible increase in cancer risk levels at nearby sensitive receptors compared to existing conditions. As noted in the Health Risk Assessment, the cancer risk levels analyzed do not imply that an exposed individual would contract cancer; rather, the cancer risk is a probability of developing cancer if other factors (i.e., heredity, exposure to environmental or workplace risks that compromise the immune system, and overall health) would result in an increased susceptibility to developing cancer.

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Using single-end dump trucks for Alternative 1 would result in slightly lower cancer risk levels than using bobtail dump trucks. For Alternative 2.1, hauling to crush offsite during one summer recess period, using single-end dump trucks would result in lower cancer risk levels. For Alternative 2.2, which would utilize two summer recess periods, using single -end dump trucks would also result in lower cancer risk levels. In regard to Alternative 2 overall, completing the removal process during one summer woul d result in less cancer risk levels, because it would involve a shorter exposure duration. Between using single -end dump trucks for Alternative 1 or Alternative 2, Alternative 1 would result in lower cancer risk levels. However, Alternative 3 would not include off-site truck hauling, and would generate less DPM exhaust, when compared to Alternatives 1 and 2. Alternative 3 would therefore result in the least cancer risk levels and would be considered the environmentally superior alternative.

Based on the calculations in the Health Risk Assessment and the results in Table 17, Chronic Hazard Assessment, none of the alternatives would generate a TAC exposure-related chronic hazard index in exceedance of the SCAQMD’s thresholds. All of the alternatives would result in a negligible chronic hazard index at nearby sensitive receptors compared to existing conditions. As noted in the Health Risk Assessment, a hazard index less than or equal to 1 indicates that non-carcinogenic health effects are not likely to occur over a lifetime of exposure.

Using single-end dump trucks for Alternative 1 would result in a slightly lower chronic hazard index than using bobtail dump trucks. For Alternative 2.1, hauling to crush offsite during one summer recess period, using single- end dump trucks would result in lower cancer risk levels. For Alternative 2.2, which would utilize two summer recess periods, using single-end dump trucks would also result in a lower chronic hazard index. In regard to Alternative 2 overall, completing the removal process during one summer recess period would result in lower chronic hazard indices, because it would involve a shorter exposure duration. Between using single-end dump trucks for Alternative 1 or Alternative 2, Alternative 1 would generally result in lower chronic hazard indices, by a small margin. Because Alternative 3 would not include a hauling operation and the associated DMP exhaust, Alternative 3 would result in the lowest chronic hazard indices.

It is concluded that Alternative 3, crushing onsite and containing onsite, would result in the lowest cancer risk levels and chronic hazard indices, due to no truck hauling operations.

Noise
Alternatives 1 and 3 would inherently result in higher noise levels from operation activities due to the use of a crusher and associated equipment onsite, compared to Alternative 2. Based on the noise measurements and calculations included in Section 3.3 and the results in Table 21, Maximum Operation Noise Levels, Alternatives 1 and 3 would not generate noise levels in exceedance of the Federal Transit Administration’s thresholds for residential noise levels. It is concluded that Alternative 2 would result in lower noise levels overall, however, Alternatives 1 and 3 would not result in significant impacts related to noise.

As shown in Table 22, Typical Operation Equipment Vibration Levels, none of the equipment types required for either alternative would generate groundborne vibration in exceedance of the Caltrans thresholds for human annoyance or older residential uses. Therefore, Alternatives 1, 2 and 3 would not result in significant impacts related to vibration.

4.2 Recommendations
Environmental Considerations
Based on the technical analyses in Section 3 and the results described above, Alternative 3 is concluded to result in lesser levels of impacts among the alternatives. For hauling offsite, Alternative 2, including crushing offsite and using single-end dump trucks for the hauling operation, would result in less impacts related to air quality and noise. Specifically, Alternative 2.2.2, using single-end dump trucks to haul the concrete debris offsite over two summer recess periods, would result in less pollutant emissions. Alternative 2.2.2 would result in marginally Packet Page. 505
higher cancer risk levels and chronic hazard indices than Alternatives 1 and 3, however, the levels and indices would be well below the SCAQMD threshold for all of the alternatives. It is concluded that Alternative 3 is the recommended and preferred alternative, with Alternative 2.2.2 recommended as the preferred alternative for offsite hauling, based on impact conclusions for air quality and noise. It is noted that all alternatives would result in less than significant impacts with regard to air quality, including health risks, and noise.

Additional Recommendations
All Alternatives:
• To the extent feasible, employee parking and truck staging areas (Alternatives 1 and 2) shall be designated with signage at the northern end of Palm Avenue to reduce congestion along Palm Avenue near the Project site.
• Pursuant to Municipal Code Section 8.54.070, construction related activities related to all Alternatives, and particularly Alternatives 1 and 3, should be limited to daylight hours of operation (7:00 AM to 8:00 PM) in consideration of the residential uses in close proximity to the site. - To the extent feasible, truck hauling activities associated with Alternatives 1 and 2 should primarily occur outside of identified commute times and school drop-off and pick-up windows. • In compliance with state law (Section 2485 and Section 2449 of Title 13 of the California Code of Regulations), the contractor will be required to limit diesel truck/equipment idling to no more than five minutes.

Alternatives 1 and 2:
• Due to increased cubic yard capacity, single-end dump trucks should be utilized for the hauling operation, to the greatest extent possible. The greater hauling capacity would result in significantly fewer truck trips per day on Palm Avenue and would therefore reduce safety risks associated with truck trips.
• Enhanced safety measures should be utilized with regard to truck travel along Palm Avenue, including safety signage, flagmen, safety personnel, cones, and reduced speed zones in proximity to Palm Avenue Elementary School, Tom Minor Park, and other areas of heightened local activity along the roadway.

Temporary stop signs should be placed at the driveways of the Project site when hauling trucks and other equipment enter and exit the site.
• For the hauling operation, most of the removal operation should occur during the school’s summer recess to limit potential safety concerns with regard to truck travel along Palm Avenue, to the extent feasible.
- Grading and site preparation activities should occur during the school year, in advance of the summer recess.
• The applicant should coordinate with the City of San Bernardino to determine if approval and/or a permit is needed to use Palm Avenue as a truck hauling route. • Haul trucks should enter the site via the north driveway on Palm Avenue, near the north side of the Project site. Truck staging should be completely onsite in order to prevent any truck queuing from spilling out onto Palm Avenue and affecting nearby residents using Palm Avenue. Trucks should circulate onsite and exit the site via the south driveway on Palm Avenue, near the south side of the Project site. In order to accommodate the Project operations, the two existing driveway access points would need to be graded and/or leveled with adequate width to allow for both ingress and egress of trucks and hauling of equipment.
• The applicant should coordinate with the City of San Bernardino to temporarily add truck restriction signs that prohibit trucks from parking and stopping along Palm Avenue adjacent to the Project site. This would help prevent trucks from queuing along Palm Avenue.

Alternatives 1 and 3:

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• For the crushing operation, the Lokotrack Urban LT96 is recommended to minimize dust emissions and noise to the greatest extent feasible. The Urban LT96 crusher includes dust covers and a dust suppression system that uses high-pressure water sprays inside the crusher chamber and at the end of the conveyor to prevent dust when aggregates are unloaded. The Urban LT96 dust suppression system results in an approximately 85 percent reduction in dust emissions. The LT96 is also designed for quieter operation, with up to 60 percent noise reduction compared to conventional crushers. The Urban LT96 uses noise covers that provide noise suppression across several points, including the main conveyor beneath the crushing mechanism.
- It is noted that the technical analyses included herein conservatively used the Lokotrack LT106 mobile jaw crusher to calculate emissions and noise levels, and use of the LT106 would not generate emissions or noise levels in exceedance of applicable thresholds. However, due to the proximity of sensitive receptors, the Lokotrack Urban LT96 with additional dust suppression is recommended considering the site’s historical dust nuisances and potential noise nuisances for nearby receptors.

Alternative 1:
• Processed, crushed debris should not be stockpiled onsite. Crushed debris should be immediately removed to limit onsite stockpiles and potential new dust sources, particularly resulting from local wind events. As such, the crusher should be operated at a rate that is commensurate with the pace that the specific haul trucks can export the material.

Alternative 3:
• If Alternative 3 is selected as the preferred alternative, a Containment Plan to mitigate and assure that crushed material does not result in dust emission nuisance to area residents will be required. The Containment Plan shall be prepared by the Project Applicant for development of the Project site and is subject to approval by the City of San Bernardino, prior to starting site preparation for the crushing operation. The Containment Plan may include, but not be limited to, the following requirements:
- The debris should be covered with a durable heavy-duty plastic sheeting or geotextile fabric and the following actions should be taken to ensure that the debris cover remains effective:
 Regular inspections: Regularly inspect the covering for damage or wear and tear and make repairs as needed, particularly after periods of heavy rain or high winds.  Ensure Secure Coverage: Properly secure the coverings to prevent them from blowing away or becoming damaged, especially during windy conditions.
 Adjust Covering: Adjust the covering as necessary to accommodate any changes in the debris pile or weather conditions.

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APPENDIX A
Air Quality Data
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kimley-horn.com 1100 W. Town and Country Rd., Suite 700, Orange, CA 92868 714-939-1030

TECHNICAL MEMORANDUM
To: Glenn Lajoie, AICP, CSG Consultants, Inc.

Kelli Allen, CSG Consultants, Inc.

From: Ace Malisos, Kimley-Horn and Associates, Inc.

Dharma Truong, Kimley-Horn and Associates, Inc.

Date: May 12, 2025
Subject: Oxbow Debris Removal Project, San Bernardino, CA – Air Quality Analysis

Purpose
The purpose of this technical memorandum is to identify the air pollutant emissions associated with the Oxbow
Debris Removal Project (Project).

Project Location
The Project site totals 18.45-acre and is located at 6920 Palm Avenue in the City of San Bernardino (City), San Be
rnardino County (County), California; see Figure 1: Regional Map. The Project site is surrounded by the San Bernardino National Forest to the north, Palm Avenue to the east, residential uses immediately to the east of Palm Avenue and to the south, and undeveloped land to the west. Regional access to the Project site is provided by Interstate 215, located approximately 1.3 miles to the south of the Project site.

Local access to the Project site is provided by Palm Avenue, located directly to the east of the Project site; see Figure 2: Local Vicinity Map. Exit 50 along Interstate 215 provides direct access from Interstate 215 to Palm Avenue. The Project site is currently designated and zoned Residential Low (RL).

Project Description
The northern portion of the Project site is occupied by an approximately five-story high debris pile contain
ing approximately 42,000 cubic yards (CY) of concrete that is covered in shredded fabric. The Project would disturb approximately 4.10 acres to remove the debris pile from the Project site.

The Project would gather and dispose of the shredded fabric remnants and would grade the existing dirt driveway and a portion of the Project site to allow for equipment movement on-site. The Project would either crush the concrete on-site before removal (Alternative 1: Crushing) or off-site after removal (Alternative 2: Non-Crushing). The Project would use haul/dump trucks to transport the crushed or non- crushed concrete to the Rialto Recycle Yard, located approximately 17 miles to the south of the Project site.

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