Attachment 7 Planning Commission Packet(SP23-01 and SUB23-05)

Public Hearing: Agenda Item No. 2

City of San Bernardino
Request for Planning Commission Action

Date: January 13, 2026

To: Honorable Chairperson and Planning Commissioners

From: Gabriel Elliott, Director of Community Development and Housing

By: Michael Rosales, Senior Planner

Subject: Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595) University Hills Specific Plan

Owner Applicant
Encore University Hills, LLC David Hardy
770 Tamalpais Drive, #401B 3333 Michelson Drive, Suite 620 Corte Madera, CA 94925 Irvine, CA 92612

Request
The applicant is requesting the following: (1) adopt the Addendum to the Final Subsequent Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155) in compliance with the California Environmental Quality Act; (2) approve Specific Plan Amendment No. 23-01 to amend the development standards and guidelines of the original development plan and reduce the number of proposed single-family residential lots from 980 to 327 within the University Hills Specific Plan; (3) approve Subdivision No. 23- 05 (Tentative Tract Map No. 20595) to allow the subdivision of a 404.3-acre site into 327 single-family residential lots; and (4) dissolve Development Agreement No. 08-02 and replace with a Memorandum of Understanding (Attachment A, Exhibit “C”, and Attachment E). The project site is located at Badger Canyon Road and W. Frontline Road in Ward 5.

APN: 0265-041-12, 0265-051-12 and - 1 3 ; 0 265- 061-16; 0265-011-06, -07, and -08; 0265-051-09; a n d 0265-021-13
Zones: University Hills Specific Plan (SP-UH)

Recommendation
Planning Division of the Community Development and Housing Department recommends that the Planning Commission take the following action:

1) Adopt Resolution No. 2026-001 of the Planning Commission of the City of San Bernardino, California, recommending that the Mayor and City Council: (1) adopt the Addendum to the Final Subsequent Environmental Impact Report and Mitigation Monitoring and Reporting

Program (SCH #2007071155) in compliance with California Environmental Quality Act Section 15164(a);

(2) Approve Specific Plan Amendment No. 23-01 to amend the development standards and guidelines of the original development plan and reduce the number of proposed single-family residential lots from 980 to 327 within the University Hills Specific Plan;

(3) Approve Subdivision No. 23-05 (Tentative Tract Map No. 20595) to allow the subdivision of a 404.3-acre site into 327 single-family residential lots; for properties located at APNs: 265-041-12, 265-051-12, 265-051-13, 265-061-16, 265-051-09, 265-021-13, 265-011-07, and 265-011-08, and 265-011-06 within the University Hills Specific Plan; and

(4) Dissolve Development Agreement No. 08-02 (Attachment A, Exhibit “C”,).

Public Hearing Noticing
December 18, 2025: Notices were mailed to all owners’ property located within 1,000 feet of the subject property, providing the nature of the request, location of the property, the date, time, and place of the Planning Commission meeting of January 13, 2026, for Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595) – University Hills Specific Plan.

January 3, 2026: Display advertisement was published in the San Bernardino Sun Newspaper.

Project Description
Pursuant to the requirements of Chapter 19.64 (Specific Plans), and Chapter 19.66 (Subdivision Maps) of the City of San Bernardino Development Code and California Government Code Section 65450, the applicant is requesting the first amendment to the City of San Bernardino’s 2008-approved University Hills Specific Plan (SP-UH) Specific Plan.

The amendment proposes revisions to the land use plan and significantly reduce development intensity within the 404-acre site. The amendment consolidates 24 planning areas into 4; lowers residential density from 20 to 3.1 dwelling units per acre; increases permanent open space from 235 to 300 acres; reduces total units from 980 to 327; updates park concepts; revises circulation to connect Badger Canyon Road to Campus Drive adding emergency access; and updates development standards to emphasize single-family homes.

Subdivision 23-05 (Tentative Tract Map No. 20595) is requested to allow for the subdivision of a 404.3-acre site into 327 single family lots, along with parcels for landscaping, parks, water quality basins, roads, trails, 46.86 acres of parks and open space, and an additional 300.44 acres of open space preserved within a remainder lot.

Background
1993: The Paradise Hills Specific Plan, approved in 1993 and based on the former General Plan, included a certified
Environmental Impact Report and proposed a 229-acre
development area extending north into Badger Canyon. The plan called for 504 residential units and 175 acres of open space, with two housing types—Foothill Residential at 3.5 units per acre and Hillside Residential at 1 unit per acre— resulting in overall densities of 1.25 and 2.2 units per acre.

The Paradise Hills Specific Plan was later revised to cluster development south of the San Andreas Fault, which crosses the property, eliminate development in Upper Badger Canyon, and create a land plan in association with California State University San Bernardino (CSUSB). The project was never built, and no development has occurred on the site since.

2005: After adoption of the new General Plan in 2005, The Paradise Hills Specific Plan was renamed the University Hills Specific Plan (SP-UH) via Resolution 2005-362 adopted November 1, 2005. The University Hills Specific Plan (SP-UH) applied updated goals, policies, and land-use designations to the site which included Residential Suburban (4.5 units/acre) on the southern third, Residential Low (3.1 units/acre) in the center, and Open Space along the northern edge, all designations consistent with the original plan. No movement on the plan occurred at this time.

2008: The Environmental Review Committee determined that the University Hills Specific Plan could have negative effects on the environment and warranted preparation of a Subsequent Environmental Impact Report. The Draft SEIR was distributed for the 45-day public review period from August 1, 2008 to September 1, 2008. On November 17, 2008 the Mayor and
Common Council accepted the Subsequent Environmental
Impact Report (SEIR) and adopted the University Hills
Specific Plan No. 07-01.

2008-2025: It is anticipated that the project in its current form will ultimately be developed.

Setting and Site Characteristics
The Project site is located within the northern end of the City of San Bernardino, just north of the California State University San Bernardino (CSUSB) campus and several large debris basins maintained by the County of San Bernardino Flood Control District.

The Project site occupies approximately 404 acres of vacant land in the western edge foothills of the San Bernardino Mountains which run for approximately 60 miles east from the Cajon Pass to the Coachella Valley. The elevation of the Project site ranges between 1,600 feet above sea level (asl) at its southerly boundary to an upper elevation of approximately 2,600 feet asl. An observatory to the south is located at Badger Hill which is utilized by CSUSB for educational purposes (Attachments C and D).

Table 1 provides a summary of the surrounding land use characteristics of the subject site and surrounding properties.

TABLE 1: SITE AND SURROUNDING LAND USES

LOCATION LAND USE ZONE GENERAL PLAN

DESIGNATION
Site Vacant University Hills Specific
Plan Single Family Residential
North San Bernardino National Forest National Forest N/A South Public Flood Control Public Flood Control (PFC) Public Flood Control East San Bernardino National Forest National Forest N/A West Public Flood Control Public Flood Control (PFC) Public Flood Control

Analysis
The Project consists of the first amendment to the approved University Hills Specific Plan (SP-UH) Project. The original Project was adopted by the City of San Bernardino in 2008.

This first amendment of the approved Project is a proposal to adopt the Final Subsequent Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155) (Exhibit “B”), modify the land use plan and reduce the development intensity and residential dwelling units allowed within the 404-acre site, Subdivide for 327 single family lots (Exhibit “A”), and dissolve and remove Development Agreement 08-02 from the property title and replace with a Memorandum of Understanding (Attachment E).

Amendment
Specifically, the amendment would include the following changes:
x Reduce the number of Planning Areas from 24 to 4.
x Reduce the residential density of the Proj ect from a maximum of 20 dwelling units per acre (du/acre) to 3 du/acre.
x Increase the amount of land preserved in perpetuity as open space from approximately 235 acres to approximately 300 acres, to better accommodate environmental site constraints, such as seismic and biological constraints. x Reduce the number of allowed residentia l dwelling units (DU) from 980 DU to 327 DU.
x Redesign of the conceptual park plans.
x Update the circulation plan to connect Badger Canyon Road south to Campus Drive and add additional emergency vehicle access roads.
x Update of development standards and design guidelines to focus on single-family residential development.

Approvals associated with the Specific Plan Amendment (SPA) include an amendment to the University Hills Specific Plan and a Tentative Tract Map (TTM):

Subdivision
The Tentative Tract Map is a subdivision proposing to implement the land uses identified in the first amendment to the University Hills Specific Plan ( SP-UH). Subdivision 23-05 (TTM No. 20595) proposes the subdivision of approximately 338.80 acres into 327 single family residential lots with a minimum lot size of 2,750 sq. ft. This includes lots for landscaping, passive park, water quality basin, roadways, trails and 46.86 acres of open space; 300.44 acres will be allotted to additional open space within a remainder lot.

Pedestrian and Bicycle Connectivity

The amendment would improve the Project site with pedestrian and bicycle infrastructure, as follows:
x The Pedestrian and bicycle r outes along roadways would incorporate pedestrian amenities such as benches, bike racks, shade structures, and lighting where appropriate.
x Pedestrian connections would link residential neighborhoods with recreation areas.
x Bike racks would be located at strategic points throughout the open space system, such as parks and other recreational amenities, to encourage non-vehicular circulation.
x Trails would be clearly marked with consistent signage and well-lit with bollard lighting as appropriate.

Roadways, Traffic, and Circulation
The originally approved Project of 2008 was designed with main access (to the site) through the Campus Parkway extension, with Badger Canyon Road (a dirt road) used only as an Emergency Vehicle Access (EVA) route. The current amended Project keeps these same roadways—Campus Parkway extension and EVA No. 1 (Badger Canyon Road)—as part of its land use plan. In addition, the Project would add two new vehicle access points:

x Campus Parkway Access:

A new driveway would connect to a future road off Campus Parkway. This new road is expected to link Campus Parkway with North Campus Circle at a future intersection located just north of the existing West Campus Circle/North Campus Circle intersection.
x Badger Canyon Road Access:

A second driveway would connect to a future fire access road along EVA No. 1 (Badger Canyon Road). Badger Canyon Road would tie into Devils Canyon Road just north of the current Campus Parkway and Northpark Boulevard/Devils Canyon Road intersection.

Utilities and Infrastructure
The Project presented would require the installation of utilities and infrastructure systems including potable water, water to fight fires, wastewater, storm drainage, electricity, natural gas, street lighting, and sidewalks would be installed to serve the Project. The updated UHSP includes utility master plans for water, sewer, storm drain, etc.

All Project utility connections would be located underground. Eight aboveground Frontier electricity power poles/power lines are located within the Project site. These electric power lines would go underground and relocated away from the residential lots as part of the Project onsite development activities.

Landscaping
Landscaping within Project site would consist of evergreen and deciduous canopy trees with flowering evergreen shrubs and groundcovers. It is intended that the landscaping would provide visual themes and continuity throughout the Project site, enhance desirable views, screen undesirable views, beautify and control erosion of graded slopes exposed to public views, preserve existing landscape material (whenever possible), and enhance interfaces between graded and natural open space areas.

Streetscape elements, such as landscaping, lighting, street furniture, and signage, would create an attractive, consistent, and cohesive community image and would complement the surrounding architectural styles.

Landscaping along major roadways and at Project entries would be designed to create an attractive and cohesive community identity. Water usage would be minimized through the planting of native and low-water species and the utilization of water-efficient and drip irrigation systems. Medians an d parkways would be used for water treatment and to reduce runoff, when possible.

Overall, landscaping would include the installation of shade trees throughout the Project site including fire-safe and drought tolerant landscaping that is located to help reduce the effect of harsh winds, provide shade, and highlight significant features. The Project would be maintained via Homeowners Association (HOA) agreements and Landscape and Lighting Maintenance Districts (LLMDs).

Recreation Areas
The Project would develop recreation and open space areas as follows:
• Recreation and open space areas would be designed to accommodate the needs of different ages and abilities.
• Canopy trees would be used to provide shade.
• Outdoor furniture would be provided in parks and common open space areas that would complement the surrounding architectural styles, materials, and colors. • A combination of hard and soft paving would be used depending on the function of the recreational amenities.
• Active areas would utilize turf, grass, and ornamental plantings. Passive areas would primarily be composed of drought-tolerant species.

Lighting
Lighting within the Project is intended to help define vehicular and pedestrian circulation patterns, provide safe pedestrian movement, distinguish community entries and activity areas, and contribute to the overall landscape theme of the community. The goal is to provide a sense of place by varying fixtures and illumination levels. Due to the proximity of Project site to the CSUSB observatory at Badger Hill, the use of lighting within the community shall not be excessive and would be consistent with the dark sky guidelines suggested by the International Dark Sky Association. Additionally, the Project lighting would implement the following features:

• Streetlights would implement the use of Light-Emitting Diode (LED) in accordance with City Standard No’s, SL-1, SL-2, and SL-3. Also, when more than three streetlights are proposed, a lighting plan would be prepared for all public areas within University Hills in accordance with the City of San Bernardino Street Lighting Design Policies. The lighting plan would establish uniform lighting standards regarding style, materials, and colors to ensure consistent design. The lighting plan would be submitted to the City’s Public Works Department for review and approval, prior to installation. • All exterior lights would be shielded and focused on driveways to minimize spill light into the night sky or adjacent properties (residential land uses located approximately 600 feet southeast of the Project site, along North “I” Street). • Exterior lighting would be consistent with City safety and illumination requirements for rural areas. Exterior lighting on homes would be set to automatic timers. Light standards would be energy efficient and in scale with the height and use of the structures on-site.
• Light standards would not exceed 15 feet in height above finish grade. Lighting in parks may exceed this limit where deemed appropriate by the University Hills Design Review Committee and approved by the City. The 15-foot height limit may be waived as deemed necessary by the City Engineer. • Lighting would be decorative, in keeping with the architectural theme of the facility served and shall be located within landscape planter areas. • All lighting, including security lighting, would be directed away from adjoining properties and the public right-of-way.
• Parking areas would have lighting that provides adequate illumination for safety and security. Parking lot lighting fixtures would maintain a minimum of 1 foot- candle of illumination at ground level at any location within the parking facility. • The level of lighting would not exceed 0.5 foot-candle at any residential property line or at the perimeter of the developed areas adjacent to the areas designated as Open Space.
• Game-court lighting is permitted on a case-by-case basis. Prior to installation, all game court lighting shall be reviewed and approved by the City of San Bernardino and any other responsible governing agency. Court lighting fixtures shall not exceed 30 feet in height.
• Exterior lighting may be used to illuminate significant exterior features and landscaping.

Off-site Improvements to the Project:

Offsite street improvements would include dr ainage, water, and sewer improvements. A fuel modification zone would be constructed on San Bernardino County Flood Control properties within public easement and reservoirs. The Project would also require the construction and realignment of main ingress and egress roads, and EVA roadway alignments.

Construction Schedule
The Project does not contain a specific ph asing plan or construction schedule for the Project; however, the Project would include backbone infrastructure that would include roads, water, and sewer lines prior to developing any planning areas. Assumed Project construction timelines are as follows:

x Site Preparation: January 2, 2027 to March 1, 2027
x Grading: March 5, 2027 to September 3, 2027
x Building Construction: September 4, 2027 to February 28, 2028 x Paving: May 1, 2028 to July 1, 2028
x Architectural Coating: October 1, 2028 to March 28, 2029

The Project site preparation is anticipated to occur over a period of 2 years, which the Specific Plan Amendment identified as 2027 to 2029. These timeframes are also assumed for air quality modeling purposes. However, these timeframes are subject to changes depending on various factors, including economic conditions and market demand.

Development Agreement 08-02
The applicant has requested Development Agreement 08-02 to be dissolved and removed from the property title. Section 3.1.1 within the agreement defines the “ 5 Year Performance Plan ”, requiring that within the first five years of the Effective date of 4/19/2012, off-site rights of way “must have been acquired,” construction plans for the backbone infrastructure “shall be submitted” and deemed complete plans for the first phase of residential structures and park “shall have been submitted.” None of these mandatory requirements were satisfied, so the developer failed to meet the obligations under Section 3.1.1. As a result of the failure to meet these obligations, the DA shall be terminated per Section 3.2.

In addition to the above, terms within Development Agreement 08-02 are no longer applicable to the proposed Specific Plan Amendment. Such terms include the City maintenance of the roadways and landscape areas, the provision of public parks and buildings, vested impact fee schedules, and the provision of multifamily housing including student/faculty housing.

In place of Development Agreement 08-02 there will be a Memorandum of Understanding as the expired Development Agreement referenced separate agreements between California State University San Bernardino (CSUSB) and the original developer. To preserve CSUSB’s intended protections and interests regarding roadway access, maintenance, open space access, and safeguards for campus facilities, Planning Conditions of Approval were incorporated into the Resolution as follows:
(Added as number 18 ) COA1: Prior to recordation of the Final Map or the issuance of building permits, whichever comes first, the applicant/developer/property owner shall provide a copy of a recorded agreement between applicant/developer/property owner and California State University, San Bernardino for access into the University Hills project for limited, educational purposes.

(Added as number 19) COA 2. Prior to recordation of the Final Map or the issuance of building permits, whichever comes first, the applicant/developer/property owner shall obtain easements or acquire all property necessary from the California State University, San Bernardino, San Bernardino County Flood Control, and any other property owner necessary to provide access to the site from an existing public right of way.

(Added as number 20) COA 3: Prior to recordation of the Final Map or the issuance of building permits, whichever comes first, the applicant/developer/property owner shall enter into a Memorandum of Understanding (MOU), or any other agreement deemed appropriate by both parties, with California State University, San Bernardino to address a variety of issues that could include access rights and conditions, construction management and campus protection, fault and land laboratory access, lighting and observatory protection, agency review and approval, term and termination, and dispute resolution. A current draft of the MOU will be included for reference as part of the staff report.

(Amended) COA 8: The applicant shall coordinate with other outside agencies including but not limited to California State University, San Bernardino, San Bernardino County Flood Control, and San Bernardino County Fire. All required approvals, permits, and clearances shall be obtained from all outside agencies prior to recordation of the final map and prior to issuance of grading, building, and occupancy permits, as applicable, for the project. Examples include but are not limited to encroachment permits, access agreements or Memorandums of Understanding.

In addition, CSUSB has prepared the Memorandum of Understanding to outline the key deal points between the CSUSB the new developer Encore University hills, LLC. These provisions will ultimately be formalized through an encroachment agreement, which will be recorded against the property title

General Plan Goals and Policies
The City of San Bernardino General Plan includes goals and policies to guide future development within the City, including the following:

Land Use Element

2.1 Preserve and Enhance San Bernardino’s Unique Neighborhoods. The University Hills Specific Land Use Plan is designed to be compatible with the surrounding residential and future commercial uses within the vicinity.

2.3 Create and Enhance Dynamic, Recognizable Places for San Bernardino’s Residents, Employees, and Visitors. The Specific Plan Design Guidelines provide for the creation of unique, quality residential development.

2.5 Enhance the Aesthetic Quality of Land Uses and Structures in San Bernardino.

The Specific Plan Design Guidelines provide for the creation of unique, quality residential development.

Housing Element
Policy 1.3 Design Features. Require new and rehabilitated housing to be well designed, with appropriate attention to site planning, materials and colors, building treatments, landscaping, open space, parking, and sustainable green designs. The Addendum to the University Specific Plan will increase the amount of land preserved in perpetuity as open space, Update the Parks Plan, and update the circulation to accommodate the project.

Community Design Element

5.3 Recognize Unique Features in Individual Districts and Neighborhoods and Develop a Program to Create Unifying Design Themes to Identify Areas Throughout the City. The Specific Plan Design Guidelines provide for the creation of unique, quality residential and commercial development.

Circulation Element

6.1 Provide a Well-Maintained Street System. The interior local roads will be maintained by a homeowner’s association.

Parks, Recreational and Trails Element

8.1 Improve the Quality of Life in San Bernardino by Providing Adequate Parks and Recreation Facilities and Services to Meet the Needs of Our Residents. The University Hills Specific Plan (SP-UH) provides for a variety of private parks and open space.

Utilities Element

9.1 Provide a System of Wastewater Collection and Treatment Facilities that will Adequately Convey and Treat wastewater Generated by Existing and Future Development in the City’s Service Area. The University Hills Specific Plan provides for the creation of a wastewater system that will tie into existing facilities.

9.3 Provide Water Supply, Transmission, Distribution, Storage, and Treatment Facilities to Meet Present and Future Water Demands in a Timely and Cost-Effective Manner. The University Hills Specific Plan provides for th e creation of a water system that will tie into existing facilities.

9.4 Provide Appropriate Storm Drain and Flood Control Facilities where Necessary. The University Hills Specific Plan provides for the cr eation of a drainage system that will tie into existing facilities.

9.10 Ensure that the Costs of Infrastructure Improvements are Borne by those who Benefit. The infrastructure improvements required by the University Hills Specific Plan will be financed by the builder.

Safety Element

10.5 Reduce Urban Run-Off from New and Existing Development.

The Specific Plan Design Guidelines provide a variety of measures to reduce urban run- off, including a drainage basin and bio-swales.

Energy and Water Conservation Element

13.1 Conserve Scarce Energy Resources. The University Hills Specific Plan contains a chapter on Sustainable Guidelines to reduce energy and water use and conserve natural resources.

Noise Element

14.1 Ensure that Residents are Protected from Excessive Noise Through Careful Land Planning. Through site planning and construction techniques, residents will be protected from excessive noise.

2020-2025 Key Strategic Targets and Goals
Specific Plan Amendment 23-01 and Subdivision 23-05-aligns with Key Target No. 4:

Economic Growth & Development. The proposed development will add needed attainable housing and grow the tax base in the City of San Bernardino.

California Environmental Quality Act
In accordance with CEQA Guidelines Section 15164(a), the applicant submitted, and the Planning Division accepted, an Addendum to the previously certified Subsequent Environmental Impact Report (SEIR), State Clearinghouse No. 2007071155. In conjunction with the Addendum, the Mitigation Monitoring and Reporting Program was amended to reflect the proposed project modifications (Exhibit “C”).

Based on the Addendum, the previously certified SEIR, the adopted Environmental Findings, Mitigation Monitoring and Reporting Program, Statement of Overriding Considerations, and the entire administrative record, the Planning Commission finds that preparation of a new subsequent or supplemental EIR is not required.

The project modifications evaluated in the Addendum:
(1) do not constitute substantial changes to the project requiring major revisions to the 2008 SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; (2) do not constitute substantial changes in the circumstances under which the project is undertaken that would require major revisions to the 2008 SEIR; and (3) do not involve new information of substantial importance that was not known, and could not have been known with the exercise of reasonable diligence at the time the 2008 SEIR was certified, that demonstrates any of the following:
(a) the project would have one or more significant effects not discussed in the 2008 SEIR; (b) previously identified significant effects would be substantially more severe; (c) previously infeasible mitigation measures or alternatives would be feasible and would substantially reduce one or more significant effects; or (d) mitigation measures or alternatives considerably different from those analyzed in the 2008 SEIR would substantially reduce one or more significant effects on the environment.

Conclusion
The development and establishment of the proposed Specific Plan Amendment is consistent with the policies of the City’s General Plan and complies with the standards of the City’s Development Code.

Staff recommends that the Planning Commission take the following action:

(3) Approve Subdivision No. 23-05 (Tentative Tract Map No. 20595) to allow the subdivision of a 404.3-acre site into 327 single-family residential lots; for properties located at APNs: 265-041-12, 265-051-12, 265-051-13, 265-061-16, 265-051-09, 265- 021-13, 265-011-07, and 265-011-08, and 265-011-06 within the University Hills Specific Plan; and

(4) Dissolve Development Agreement No. 08-02 (Attachment A, Exhibit “C”,).

Attachments
Attachment A Resolution No. 2026-001
Attachment B Project Justification Letter
Attachment C Location/Zoning Map
Attachment D Aerial Map
Attachment E University Hills-Draft MOU
Attachment F Original approval of SP-UH Resolution No. 2008-422 Attachment G Final Subsequent Environmental Impact Report Addendum (link) Attachment H Final Subsequent Environmental Impact Report Appendices (link) Attachment I University Hills-Fire Protection Plan (Draft) Attachment J Power Point

ATTACHMENT A
Resolution No. 2026-001

RESOLUTION NO. 2026-001 - PC

1 RESOLUTION NO. 2026-001 - PC

A RESOLUTION OF THE PLANNING COMMISSION OF

THE CITY OF SAN BERNARDINO, CALIFORNIA,

FORW ARDING A RECOMMENDATION TO THE MAYOR
AND CITY COUNCIL RECOMMENDING (1) ADOPTION OF

THE ADDENDUM TO THE FINAL SUBSEQUENT

ENVIRONMENTAL IMPACT REPORT AND MITIGATION

MONITORING AND REPORTING PROGRAM (SCH
#2007071155) IN COMPLIANCE WITH CALIFORNIA
ENVIRONMENTAL QUALITY ACT SECTION 15164(a); (2)
APPROV AL OF SPECIFIC PLAN AMENDMENT NO. 23-01

TO AMEND THE DEVELOPMENT STANDARDS AND

GUIDELINES OF THE ORIGINAL DEVELOPMENT PLAN

AND REDUCE THE NUMBER OF PROPOSED SINGLE -
FAMILY RESIDENTIAL LOTS FROM 980 TO 327 WITHIN
THE UNIVERSITY HILLS SPECIFIC PLAN; (3) APPROVE
SUBDIVISION NO. 23 -05 (TENTATIVE TRACT MAP NO.
20595) TO ALLOW THE SUBDIVISION OF A 404.3 -ACRE
SITE INTO 327 SINGLE-FAMILY RESIDENTIAL LOTS; AND
(4) DISSOLVE DEVELOPMENT AGREEMENT NO. 08 -02.

THE PROJECT IS LOCATED AT APNS: 265-041-12, 265-051-
12, 265-051-13, 265-061-16, 265-051-09, 265-021-13, 265-011-07, 265-011-08, AND 265 -011-06 WITHIN THE UNIVERSITY
HILLS SPECIFIC PLAN (SP-UH).

WHEREAS, In 1993, the City of San Bernardino Mayor and Common Council approved the Paradise Hills Specific Plan; and

WHEREAS, after adoption of the City of San Bernardino General Plan in 2005, The Paradise Hills Specific Plan was renamed the University Hills Specific Plan (SP -UH) via Resolution 2005-362 adopted November 1, 2005; and

WHEREAS, on November 17 2008, the Mayor and Common Council of the City of San Bernardino adopted Resolution No. 2008-422 certifying the Final Subsequent Environmental Impact Report (California State Clearinghouse No. 2007071155), adopting the Findings of Fact, Statement of Overriding Considerations and Mitigation Monitoring and Reporting Program, and approving Specific Plan 07-01 for the University Hills Specific Plan (SP-UH); and

WHEREAS, on February 27, 2023 , pursuant to the requirements of Chapter 19. 64 (Specific Plans), and Chapter 19. 66 (Subdivisions) of the City of San Bernardino Development Code, an application for Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595), was duly submitted by:

Property Owner: Encore University Hills, LLC
770 Tamalpais Drive, #401B
Corte Madera, CA 94925

RESOLUTION NO. 2026-001 - PC

2 Applicant: David Hardy
3333 Michelson Drive, Suite 620
Irvine, CA 92612

APN: 0265-041-12, 0265-051-12 and - 13 ; 0 2 6 5-061-16; 0265-011-06, -07, and -08; 0265-051-09; a n d 0265-021-13

Lot Area: 404.3 acres

WHEREAS, together, Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595), constitute the University Hills Specific Plan Project ("Project"); and

WHEREAS, Specific Plan Amendment 23-01 is a request to adopt the amendment to the Final Subsequent Environmental Impact Report and M itigation Monitoring and Reporting Program ( SCH #2007071155), and amend the development standards and guidelines of the original development plan reducing the number of proposed single -family residential lots from 980 to 327 within the University Hills Specific Plan; and

WHEREAS, Subdivision 23 -05 (Tentative Tract Map 20595) is a request to allow the subdivision of a 404.3-acre site into 327 single-family residential lots; and

WHEREAS, The applicant has requested Development Agreement 08-02 to be dissolved and removed from property title, and replaced with a Memorandum of Understanding between California State University San Bernardino and the Applicant only, agreeing to preserve California State University San Bernardino intended protections and interests regarding roadway access, maintenance, open space access, and safeguards for campus facilities; and

WHEREAS, pursuant to the California Environmental Quality Act (“CEQA”; Public Resources Code, Section 21000 et seq.), Section 21067, and State CEQA Guidelines (California Code Regulations, Section 15000 et seq.), Section 15367, the City of San Bernardino is the le ad agency for the Project; and

WHEREAS, pursuant to the requirements of Section 15164(a) (Addendum to an EIR) of the California Environmental Quality Act, the Planning Division of the Community Development and Housing Department accepted the Addendum to the Subsequent Final Environmental Impact Report prepared by Kimly -Horn, environmental consultant for SP 23-01 and SUB 23 -05 (TTM 20595) on behalf of the applicant due to the fact that: 1) there are no substantial changes in the proposed project that would require major revisions of the p revious Subsequent Final Environmental Impact Report due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; 2) there are no substantial changes that have occurred with respect to the circumstances under which the proposed project is undertaking which will require major revisions of the previous Subsequent Final Environmental Impact Report due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; and, 3) there is no new information of substantial importance which was not known and could not have been known with the exercise of reasonable diligence at the time that the previous Subsequent Final Environmental Impact Report was certified; and

RESOLUTION NO. 2026-001 - PC

3 WHEREAS, the Planning Division of the Community Development and Housing Department has reviewed Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595 for consistency with the City of San Bernardino General Plan , and compliance with the City of San Bernardino Development Code and University Hills Specific Plan; and

WHEREAS, on December 10, 2025, pursuant to Section 19.44.030 (Project Review) of the City of San Bernardino Development Code, the Development and Environmental Review Committee reviewed the application and forwarded (1) the Addendum to the Subsequent Final Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155), (2) Specific Plan Amendment 23-01, (3) Subdivision 23-05 (TTM 20595), and (4) the dissolution and removal of Development Agreement 08 -02 from the property title to the Planning Commission for consideration; and

WHEREAS, on January 3 , 202 6, pursuant to the requirements of Section 19.52.020 (Hearings and Appeals - Application Processing) of the City of San Bernardino Development Code, the City gave public notice by advertising in the San Bernardino Sun, a newspaper of general circulation within the City of San Bernardino, and by mailing notices to the owners of property located within 1,000 feet of the exterior boundary of the subject property of the holding of a public hearing at which the “Project” would be considered; and

WHEREAS, on January 13, 202 6, pursuant to the requirements of Section 19.52.040 (Hearings and Appeals – Hearing Procedures) of the City of San Bernardino Development Code, the Planning Commission held the duly-noticed public hearing at which interested persons had an opportunity to testify in support of, or opposition to, the Addendum to the Subsequent Final Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155), Specific Plan Amendment 23 -01 and Subdivision 23 -05 (TTM 20595), and the dissolution and removal of Development Agreement 08-02 from the property title; and

WHEREAS, no comments made in the public hearing conducted by the Planning Commission, and no additional information submitted to the Planning Commission, has produced substantial new information requiring substantial revisions that would trigger additional environmental review under State CEQA Guidelines Section 15073.5; and

WHEREAS, pursuant to the requirements of Chapter 19.52 (Hearing and Appeals), Chapter of the City of San Bernardino Development Code, the Planning Commission has the authority to recommend to the Major and City Council the adoption of the Addendum to the Subsequent Final Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155), Specific Plan Amendment 23 -01 and Subdivision 23 -05 (TTM 20595), and the dissolution and removal of Development Agreement 08-02 from the property title.

NOW THEREFORE, the Planning Commission of the City of San Bernardino does hereby resolve, determine, find, and order as follows:

SECTION 1. ENVIRONMENTAL DETERMINATION:

RESOLUTION NO. 2026-001 - PC

4 In accordance with Section 15164(a) (Addendum to an EIR), as the decision-making body for the project, the Planning Commission has reviewed and considered the information contained in the administrative record for the University Hills Specific Plan and the Addendum to the Final Subsequent Environmental Impact Report (SEIR) and Mitigation Monitoring and Reporting Program (SCH #2007071155), certified on November 17, 200 8. Based upon the facts and information contained in the administrative record and the previously certified Final EIR, including all written and oral evidence presented to the Planning Commission , the Planning Commission finds as follows:

(1) The environmental impacts of this project were previously analyzed in the Final Subsequent Environmental Impact Report (SEIR) certified on November 17, 2008 and within the Addendum for the approval of Specific Plan Amendment 23 -01 and Subdivision 23 -05 (TTM 20595);

(2) The certified Final SEIR and the Addendum contains a complete and accurate reporting of the environmental impacts associated with the project;

(3) The certified Final SEIR and the Addendum was completed in compliance with CEQA and the Guidelines promulgated thereunder;

(4) The certified Final SEIR and the Addendum reflects the independent judgment of the Planning Commission; and

(5) The proposed project will introduce no new significant environmental impacts beyond those previously analyzed in the certified Final SEIR, and all mitigation measures previously adopted with the Mitigation Monitoring and Reporting Program and the Addendum are incorporated herein by this reference.

SECTION 2. FINDINGS FOR SPECIFIC PLAN AMENDMENT 23-01:

Finding No. 1: The proposed plan is consistent with the General Plan.

Finding of Fact: The University Hills Specific Plan (SP -UH) is a comprehensive land use and zoning document encompassing approximately 404 acres, of which approximately 42 percent (169.5 acres) were dedicated for construction of 980 residential dwelling units and related uses. The balance of the UHSP included parks and recreational uses (10.2 ac res), among streets, lighting, landscaping, natural open space (234.8 acres) to the north of the developed area, among other common features generally associated with residential communities.

Specific Plan Amendment 23-01 proposes to amend development standards and guidelines of the original development plan and reduce the number of proposed single -family residential lots from 980 to 327 within the University Hills Specific Plan . The following demonstrates how the “Project” meets the General Plan Goals and Policies:

RESOLUTION NO. 2026-001 - PC

5 Land Use Element

2.5 Enhance the Aesthetic Quality of Land Uses and Structures in San Bernardino.

The Specific Plan Design Guidelines provide for the creation of unique, quality residential development.

Community Design Element

Circulation Element

6.1 Provide a Well-Maintained Street System. The interior local roads will be maintained by a homeowner’s association.

Parks, Recreational and Trails Element

8.1 Improve the Quality of Life in San Bernardino by Providing Adequate Parks and Recreation Facilities and Services to Meet the Needs of Our Residents. The University Hills Specific Plan (SP -UH) provides for a variety of private parks and open space.

Utilities Element

9.3 Provide Water Supply, Transmission, Distribution, Storage, and Treatment Facilities to Meet Present and Future Water Demands in a RESOLUTION NO. 2026-001 - PC

6 Timely and Cost -Effective Manner. The University Hills Specific Plan provides for the creation of a water system that will tie into existing facilities.

9.4 Provide Appropriate Storm Drain and Flood Control Facilities where Necessary. The University Hills Specific Plan provides for the creation of a drainage system that will tie into existing facilities.

Safety Element

10.5 Reduce Urban Run-Off from New and Existing Development.

The Specific Plan Design Guidelines provide a variety of measures to reduce urban run-off, including a drainage basin and bio-swales.

Energy and Water Conservation Element

13.1 Conserve Scarce Energy Resources. The University Hills Specific Plan contains a chapter on Sustainable Guidelines to reduce energy and water use and conserve natural resources.

Noise Element

14.1 Ensure that Residents are Protected from Excessive Noise Through Careful Land Planning. Through site planning and construction techniques, residents will be protected from excessive noise.

Finding No. 2: The proposed plan would not be detrimental to the public interest, health, safety, convenience, or welfare of the City.

Finding of Fact: The proposed Specific Plan Amendment would establish a land use and development framework to serve as a marketing tool for attracting developers to key sites and for boosting economic development. The Specific Plan is dedicated to creating a mixed -use neighborhood that compliments the surrounding community by type and quality of development. The project provides quality homes and options for interested parties looking to relocate to the area . Additionally, the University Hills Specific Plan promotes water and energy conservation through sustainable development requirements for drought tolerant landscaping, guidelines for implementing renewable energy sources for utilities, and creating a walkable and convenient neighborhood with open spaces for families to gather. Therefore, the proposed Specific Plan will not be detrimental to the public interest, health, safety, convenience, or welfare of the City.

Finding No. 3: The subject properties are physically suitable for the requested land use designations and the anticipated land use developments.

RESOLUTION NO. 2026-001 - PC

7 Finding of Fact: The original University Hills Specific Plan (SP-UH) adopted in November of 2008 was a comprehensive land use and zoning document encompassing approximately 404 acres, of which approximately 42 percent (169.5 acres) was dedicated to the construction of 980 residential dwelling units and related uses. The remaining area of the SP-UH included parks and recreational uses (10.2 acres), as well as streets, lighting, landscaping, and natural open space (234.8 acres) located north of the developed area, along with other common features generally associated with residential communities. Specific P lan Amendment 23 -01 proposes to amend the development standards and guidelines of the original development plan per the following:

• Reduce the number of Planning Areas from 24 to 4.
• Reduce the residential density of the Project from a
maximum of 20 dwelling units per acre (du/acre) to 3 per du/acre.
• Increase the amount of land preserved in perpetuity as open space to better accommodate environmental site constraints, such as seismic and biological constraints from
approximately 235 acres to approximately 300 acres.
• Reduce the number of allowed residential dwelling units (DU) from 980 DU to 327 DU.
• Redesign of the conceptual park plans.
• Update the circulation plan to connect Badger Canyon Road south to Campus Drive and add additional emergency
vehicle access roads.
• Update of development standards and design guidelines to focus on single-family residential development.

Therefore, as presented Specific Plan Amendment 23 -01 is physically suitable for the requested land use designations and the anticipated land use developments.

Finding No. 4: The proposed plan shall ensure development of desirable character which will be compatible with existing and proposed development in the surrounding neighborhood.

Finding of Fact: The University Hills Specific Plan (SP-UH) has been created with the great consideration for the surrounding neighborhood and future development of the Specific Plan area will create a low density, walkable neighborhood with open spaces for children and families to enjoy, while maintaining high quality design for the “Project” in whole. Specific Plan Amendment 23-01 proposes to amend the development standards and guidelines of the original development plan by reducing the number of Planning Areas from 24 to 4 and lowering the residential density of the Project from a maximum of 20 dwelling units per acre to 3 dwelling units per acre. The Amendment also increases the amount of land preserved in perpetuity as open space from approximately 235 acres to approximately 300 acres to better accommodate RESOLUTION NO. 2026-001 - PC

8 environmental site constraints, including seismic and biological constraints.

In addition, the Amendment reduces the number of allowed residential dwelling units from 980 to 327, includes a redesign of the conceptual park plans, and updates the circulation plan to connect Badger Canyon Road south to Campus Drive while adding additional emergency vehicle access roads. Lastly, the Amendment updates development standards and design guidelines to focus on single-family residential development.

Finding No. 5: The proposed plan will contribute to a balance of land uses so that local residents may work and shop in the community in which they live.

Finding of Fact: The University Hills Specific Plan (SP -UH) has been created with consideration for the surrounding neighborhood, and future development of the Specific Plan area is intended to create a low -density, walkable neighborhood with open spaces for children and fa milies to enjoy, while maintaining high-quality design for the Project as a whole. Specific Plan Amendment 23 -01 proposes to amend the development standards and guidelines of the original development plan by reducing the number of Planning Areas from 24 to 4 and lowering the residential density of the Project from a maximum of 20 dwelling units per acre to 3 dwelling units per acre.

The Amendment also increases the amount of land preserved in perpetuity as open space from approximately 235 acres to approximately 300 acres to better accommodate environmental site constraints, including seismic and biological constraints. In addition, t he Amendment reduces the number of allowed residential dwelling units from 980 to 327, includes a redesign of the conceptual park plans, and updates the circulation plan to connect Badger Canyon Road south to Campus Drive while adding additional emergency vehicle access roads. Lastly, the Amendment updates development standards and design guidelines to focus on single -family residential development. Therefore, The proposed plan will contribute to a balance of land uses so that local residents may work and shop in the community in which they live

SECTION 3. FINDINGS FOR SUBDIVISION 23-05 (TENTATIVE TRACT MAP 20595):

Finding No. 1: The proposed map is consistent with the General Plan.

Finding of Fact: The proposal is consistent with General Plan Land Use Element Policy

2.10.1 in which requires that all decisions related to the physical development and growth of the City of San Bernardino complies with the General Plan. Specifically, the provisions of th is plan shall be applied to proposed private development projects
Finding No. 2: The design and improvements of the proposed subdivision is consistent with the General Plan.

RESOLUTION NO. 2026-001 - PC

9 Finding of Fact: General Plan Land Use Goal 2.2 states: Promote development that integrates with surrounding land uses. "The proposed Tentative Parcel Map will be consistent with the pattern of the surrounding residential development.

General Plan Land Use policy 2. 7.5 states: "Require that developments conform to the availability of public infrastructure to accommodate its demands and mitigate its impacts. "The proposed Tentative Parcel Map will connect to existing water and sewer services, create roads and storm drains, and private utilities.

Finding No. 3: The site is physically suitable for the type of development.

Finding of Fact: The proposed project is permitted within the University Hills Specific Plan (SP-UH), subject to the approval of Subdivision 2 3-05 (Tentative Parcel Map 20595) and the appropriate Conditions of Approval and adoption of the Addendum to the Final Subsequent Environmental Impact Report (SEIR) and Mitigation Monitoring and Reporting Program (SCH #2007071155). The subject site as a residential development is sufficient in size to accommodate the proposal under Subdivision 23-05 as required by the City of San Bernardino Development Code and the University Hills Specific Plan (SP-UH). Therefore, the subject site is physically suitable for the proposal.

Finding No. 4: The site is physically suitable for the proposed density of development.

Finding of Fact: The proposed site has been designed to meet all of the standards required by the Development Code for the University Hills Specific Plan (SP-UH) in which it is located. The subdivision of the site will not create any inconsistencies with regard to the standard requirements for the Specific Plan as analyzed . Therefore, the site is physically suitable for the type of development proposed.

Finding No. 5: The design of the subdivision (s) and the proposed improvements will not cause substantial environmental damage or substantially or avoidably injure fish or wildlife or their habitat.

Finding of Fact: The design of the subdivision will not have any significant negative impacts to wildlife or their habitat. The project site was analyzed through a SEIR approved in November 2008 and re -analyzed through the Specific Plan Addendum 23-01. No significant negative impacts on the environment are anticipated to result from the proposed development that are not mitigated by the Mitigation Monitoring and Reporting Program.

Finding No. 6: The design of the subdivision (s) or type of improvements will not cause serious public health problems.

RESOLUTION NO. 2026-001 - PC

10 Finding of Fact: The design of the proposed subdivision meets all of the applicable Development Code and Specific Plan requirements and will not result in any serious public health problems. The proposed parcels will have access to existing public streets and utilities, and public services will be available to serve the project site and ensure the maintenance of public health and safety.

Finding No. 7: The design of the subdivision(s) or the type of improvements will not conflict with easements, acquired by the public at large, for access through or use of property within the proposed subdivision.

Finding of Fact: The design of the subdivision will not conflict with any public or private easements. All documentation relating to easements and dedications will be reviewed and approved by the City Engineer prior to recordation of the Final Map. Existing easements will be reserved in place or relocated, as necessary.

SECTION 4. CONDITIONS OF APPROV AL:

The approval of General Plan Amendment 23 -01, Specific Plan Amendment 23 -01 and Subdivision 23-05 shall be subject to the following Conditions of Approval:

1. This approval is for the following; Adopt the Addendum to the Final Subsequent Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155) in compliance with the California Environmental Quality Act; (2) approve Specific Plan Amendment No. 23-01 to amend the development standards and guidelines of the original development plan and reduce the number of proposed single -family residential lots from 980 to 327 within the University Hills Specific Plan; (3) approve Subdivision No. 23 -05 (Tentative Tract Map No. 20595) to allow the subdivision of a 404.3-acre site into 327 single-family residential lots; and (4) dissolve Development Agreement No. 08-02. The project is located at APNs: 0265-041-12, 0265- 051-12 and -13; 0265-061-16; 0265-011-06, -07, and -08; 0265-051-09; and 0265-021-13 within the University Hills Specific Plan (SP-UH).

2. The project site shall be developed and maintained in accordance with the plans stamped January 13, 2026 (Exhibit “A”), approved by the City, which includes a site plan , floor plan, exterior elevations and concept landscaping plan on file in the Planning Division; the Conditions of Approval contained herein; and, the City’s Municipal Code regulations.

3. The project shall be subject to all of the mitigation measures contained within the Mitigation Monitoring and Reporting Program (E xhibit “B”), dated January 13, 2026 and incorporated herein by reference, as Conditions of Approval.

4. Within two (2) years of the approval of the Development Permit, the commencement of construction shall have occurred, or the permit/approval shall become null and void. In addition, if at any time after the commencement of construction, work is discontinued for a period of one (1) year, then the permit/approval shall become null and void.

RESOLUTION NO. 2026-001 - PC

11 However, approval of the Development Permit does not authorize the commencement of construction. All necessary permits must be obtained prior to the commencement of specified construction activities included in the Conditions of Approval.

EXPIRATION DATE: January 13, 2028

5. The review authority may grant a time extension, for good cause, not to exceed twelve (12) months. The applicant must file an application, the processing fees, and all required submittal items thirty (30) days prior to the expiration date. The review autho rity shall ensure that the project complies with all Development Code provisions in effect at the time of the requested extension.

6. In the event this approval is legally challenged, the City will promptly notify the applicant of any claim, action or proceeding and will cooperate fully in the defense of this matter. Once notified, the applicant agrees to defend, indemnify and hold harml ess the City of San Bernardino (City), any departments, agencies, divisions, boards or commission of the City as well as predecessors, successors, assigns, agents, directors, elected officials, officers, employees, representatives and attorneys of the City from any claim, action or proceeding against any of the foregoing persons or entities.

The applicant further agrees to reimburse the City for any costs and attorneys’ fees, which the City may be required by a court to pay as a result of such action, but such participation shall not relieve applicant of his or her obligation under this condit ion. The costs, salaries, and expenses of the City Attorney and employees of his office shall be considered as “Attorney’s fees” for the purpose of this condition. As part of the consideration for issuing this Development Permit, this condition shall remai n in effect if the Development Permit is rescinded or revoked, whether or not at the request of applicant.

Planning Division

7. Construction-related activities may not occur between the hours of 8:00 pm and 7:00 am. No construction vehicles, equipment, or employees may be delivered to, or arrive at the construction site before 7:00 am or leave the site after 8:00 pm. Construction activities shall only occur Monday through Friday.

8. (Amended) The applicant shall coordinate with other outside agencies including but not limited to California State University, San Bernardino, San Bernardino County Flood Control, San Bernardino County Fire. All required approvals, permits, and clearances shall be obtained from all outside agencies prior to recordation of the final map and prior to issuance of grading, building, and occupancy permits, as applicable, for the project. Examples include but are not limited to encroachment permits, access agre ements or Memorandums of Understanding.

9. Development of the residential tracts will require the approval of a Development Permit Type- P prior to the issuance of building, grading, on-site, and off-site permits.

RESOLUTION NO. 2026-001 - PC

12 10. The applicant/property owner must sign and have notarized an affidavit acknowledging acceptance of the Conditions of Approval and return it to the Planning Division within thirty (30) days of the effective date of this approval.

11. The project landscape plans shall be in substantial compliance with the Conceptual Landscape plan and prepared in accordance with the Development Code, section 19.28.120 (Water Efficient Landscaping Standards).

12. Minor Modifications to the plans shall be subject to approval by the Director through the Minor Modification Permit process. Any modification that exceeds 10% of the allowable measurable design/site considerations shall require the refilling of the original application.

13. The project shall comply with all applicable requirements of the Building and Safety Division, San Bernardino Police Department, San Bernardino Municipal Water Department, Public Works Department, and the City Clerk’s Office/Business Registration Division.

14. This approval shall comply with the requirements of other outside agencies (i.e., San Bernardino County Health Department, Division of Environmental Health Services, San Bernardino County Flood Control , San Bernardino County Fire Department, and California Board of Equalization), as applicable.

15. The property owner shall be responsible for regular maintenance of the project site. The site shall be maintained in a clean condition and free of litter or any other undesirable material(s).

Vandalism, graffiti, trash, and other debris shall be removed and cleaned up within twenty - four (24) hours of being reported.

16. Signs are not approved as part of this permit. Prior to establishing any new signs, or to replacing existing signs, the applicant shall submit an application and receive approval for a Sign Permit from the Planning Division. Banners, flags, pennants, and similar signs are prohibited unless a Temporary Sign Permit is obtained.

17. Submittal requirements for permit applications (site improvements, landscaping, etc.) to Building Plan Check and/or Land Development must include all Conditions of Approval issued with this approval printed on the plan sheets.

18. If the colors of the buildings or other exterior finish materials are to be modified beyond the current proposal and improvement requirements, the revised color scheme and/or finish materials shall be reviewed and approved by the Planning Division prior to the commencement of work.

19. All new construction shall require permits prior to commencement.

20. (Added) Prior to recordation of the Final Map or the issuance of building permits, whichever comes first, the applicant/developer/property owner shall provide a copy of a recorded agreement between applicant/developer/property owner and California State Universi ty, San Bernardino for access into the University Hills project for limited, educational purposes.

RESOLUTION NO. 2026-001 - PC

13 21. (Added) Prior to recordation of the Final Map or the issuance of building permits, whichever comes first, the applicant/developer/property owner shall obtain easements or acquire all property necessary from the California State University, San Bernardino, San Be rnardino County Flood Control, and any other property owner necessary to provide access to the site from an existing public right of way.

22. (Added) Prior to recordation of the Final Map or the issuance of building permits, whichever comes first, the applicant/developer/property owner shall enter into a Memorandum of Understanding (MOU), or any other agreement deemed appropriate by both parties , with California State University, San Bernardino to address a variety of issues that could include access rights and conditions, construction management and campus protection, fault and land laboratory access, lighting and observatory protection, agency review and approval, term and termination, and dispute resolution. A current draft of the MOU will be included for reference as part of the staff report.

23. All Conditions of Approval and standard requirements shall be implemented and/or completed prior to final inspection and/or issuance of a Certificate of Occupancy.

Building & Safety Division

24. The Building and Safety Division has no material objection to the present proposal that would prevent the project from proceeding in the entitlement process. Please note that our review is limited to project feasibility and was not reviewed for building code compliance or to establish project conditions of approval.

25. The subdivision will require geotechnical reports for each prepared by a qualified geotechnical engineer.

Public Works Department – Engineering Division

26. Drainage and Flood Control
a) All necessary drainage and flood control measures shall be subject to requirements of the Building Official, which may be based in part on the recommendations of the San Bernardino County Department of Transportation and Flood Control. The developer's Engineer shall furnish all necessary data relating to drainage and flood control.

b) A permit will be required from the San Bernardino County Department of Transportation and Flood Control, if any work is required within the Flood Control District's right-of-way.

c) A local drainage study will be required for the project. Any drainage improvements, structures or storm drains needed to mitigate downstream impacts or protect the development shall be designed and constructed at the developer's expense, and right - of-way dedicated as necessary.

d) All drainage from the development shall be directed to an approved public drainage facility. If not feasible, proper drainage facilities and easements shall be provided to the satisfaction of the City Engineer.

RESOLUTION NO. 2026-001 - PC

14 e) If site drainage is to be discharged into the public street, the drainage shall be conveyed through a parkway culvert constructed in accordance with City Standard No. 400.

Conveyance of site drainage over the Driveway approaches will not be permitted.

f) A Final Full-Categorical Water Quality Management Plan (WQMP) is required for this project. The applicant is directed to the County of San Bernardino’s Flood Control web page for the template and Technical Guidance Document. The Land Development Division, prior to issuance of any permit, shall approve the WQMP. A CD/USB copy of the approved WQMP and Hydrology Study shall be required prior to grading permit issuance.

g) A Storm Water Pollution Prevention Plan (SWPPP) will be required. The applicant is directed to State Water Resources Control Board (SWRCB) SMART Login system.

The SWPPP shall be approved by the State and a CD/USB copy of the approved SWPPP shall be submitted to City prior to grading permit issuance.

h) A "Notice of Intent (NOI)" shall be filed with the State Water Resources Control Board for construction disturbing 1 acre or more of land (including the project area, construction yards, storage areas, etc.). A WDID number issued by the State of California is required prior to the issuance of grading permit.

i) The Land Development Division, prior to grading plan approval, shall approve an Erosion Control Plan. The plan shall be designed to control erosion due to water and wind, including blowing dust, during all phases of construction, including graded areas which are not proposed to be immediately built upon.

27. Grading and Landscaping
a) The grading and on -site improvement plan shall be signed by a Registered Civil Engineer, and a grading permit will be required. The grading plan shall be prepared in strict accordance with the City's "Grading Policies and Procedures" and the City's "Standard Drawings", unless otherwise approved by the Building Official.

b) If the grading plan indicates export or import, the source of the import material or the site for the deposition of the export shall be noted on the grading plan. Permit numbers shall be noted if the source or destination is in the City of San Bernardino.

c) If more than 50 cubic yards of earth is to be hauled on City Streets then a special hauling permit shall be obtained from the City Engineer. Additional conditions, such as truck route approval, traffic controls, bonding, covering of loads, street cleaning, etc. may be required by the City Engineer.

d) One 4' x 11' PCC pad at least 4" thick shall be provided in the rear or side yard area of each lot for storage of recycling containers. The pad shall be screened from public view and a 3' wide concrete walkway shall be provided from the driveway to the pad . All gates along the access way shall have a minimum clear width of 3'-6".

RESOLUTION NO. 2026-001 - PC

15 e) A liquefaction evaluation is required for the site. This evaluation must be submitted and approved prior to issuance of a grading permit. Any grading requirements recommended by the approved liquefaction evaluation shall be incorporated in the grading plan.

f) Wheel stops are not permitted by the Development Code, except at designated accessible parking spaces. Therefore, continuous 6” high curb shall be used around planter areas and areas where head in parking is adjacent to walkways. The parking spaces may be 16.5’ deep and may overhang the landscaping or walkway by 2.5’.

Overhang into the setback area or into an ADA path of travel (minimum 4’ wide) is not permitted.

g) Retaining walls, block walls and all on -site fencing shall be designed and detailed on the on -site improvement Plan. This work shall be part of the on -site improvement permit issued by the Building Official. All masonry walls shall be constructed of decorative block with architectural features acceptable to the City Planner.

h) No construction on a site shall begin before a temporary/security fence is in place and approved by the Building Official or his designee. Temporary/security fencing may not be removed until approved by the Building Official or his designee. The owner or owner’s agent shall immediately remove the temporary/security fencing upon the approval of the Building Official or his designee. Sites that contain multiple buildings shall maintain the temporary/security fencing around the portion of the site and buildings under construction as determined by the Building Official or his designee.

All temporary/security fencing for construction sites shall include screening, emergency identification and safety identification and shall be kept in neat and undamaged condition.

i) The design of on -site improvements shall also comply with all requirements of The California Building Code, Title 24, relating to accessible parking and accessibility, including retrofitting of existing building access points for accessibility, if applicable.

j) The project Landscape Plan shall be reviewed and approved by the Land Development Division prior to issuance of a grading permit. Submit 3 copies to the Land Development Division for Checking.

k) The public right -of-way, between the property line and top of curb (also known as “parkway”) along adjoining streets shall be landscaped by the developer and maintained in perpetuity by the property owner. Details of the parkway landscaping shall be included in the project’s on-site landscape plan.

28. On-Site Utilities
a) Design and construct all public utilities to serve the site in accordance with City Code, City Standards and requirements of the serving utility, including gas, electric, telephone, water, sewer and cable TV (Cable TV optional for commercial, industrial, or institutional uses).

b) Backflow preventers shall be installed for any building with the finished floor elevation below the rim elevation of the nearest upstream manhole.

RESOLUTION NO. 2026-001 - PC

16 c) This project is located in the sewer service area maintained by the City of San Bernardino therefore, any necessary sewer main extension shall be designed and constructed in accordance with the City's "Sewer Policy and Procedures" and City Standard Drawings.

d) Utility services shall be placed underground and easements provided as required.

e) Existing Utilities which interfere with new construction shall be relocated at the Developer's expense as directed by the City Engineer.

f) Sewers within private streets or private parking lots will be maintained by SBMWD but shall be designed and constructed to City Standards and inspected under a City On-Site Construction Permit. A private sewer plan designed by the Developer's Engineer and approved by the City Engineer will be required. This plan can be incorporated in the grading plan, where practical.

29. Mapping
a) A Final Tract Map based upon field survey will be required.

b) The applicant‘s surveyor/engineer shall submit a Final Tract Map with supporting documents for review and approval to Land Development. The Final Tract map shall be recorded prior to building permit issuance.

30. Off-Site Street Improvement and Dedications
a) For the streets listed below, dedication of adequate street right -of-way (R.W.) per the General Plan (Chapter 6) and Municipal Code (19.20.030-18-A,19.30.290, 19.30.300), shall provide the distance from street centerline to property line and placement of the curb line (C.L.) in relation to the street centerline shall be as follows:

Street Name
Dedication shall be
Right of Way(ft.)
From Centerline
Curb Widening shall be
Curb Line(ft)
From Centerline
Campus Parkway

PRIVATE
(265-011-06, 265-011-07
265-011-08, 265-021-13
265-041-12, 265-051-09
265-051-12, 265-051-13
265-061-16)
0’ Existing
30’ – 60’ Dedication/Road
Easement
for a total ½ width of 30’ – 60’
Total
“Secondary Arterial”

0’ Existing
32’ – 64’ Proposed w/o Median
34’ – 68’ w/median
for a total ½ width of 32’ – 64’ or 34’
– 68’ Total
Per General Plan
Secondary Road
Badger Canyon Road

PRIVATE
(265-011-06, 265-011-07
265-011-08, 265-021-13
265-041-12, 265-051-09
265-051-12, 265-051-13
265-061-16)
0’ Existing
22’ - 44’ Dedication/Road
Easement
for a total ½ width of 22’ – 44’
“Collector Street”
No Parking
0’ Existing
20’ - 40’ Proposed
for a total ½ width of 20’ – 40’
Per General Plan
”No Parking”
Continuous Streets
(Main Loop Streets)
A and C
(PRIVATE)
(265-011-06, 265-011-07
0’ Existing
30’ Dedication
for a total ½ width of 30’
60’ Total
0’ Existing
22’ – 44’ Proposed
for a total ½ width of 22’ – 44’
Per General Plan
RESOLUTION NO. 2026-001 - PC

17 Any changes from private roads shall require streets to follow City General Plan standards. b) Campus Parkway– TI = 7.5 : * - **
i. The street shall be rehabilitated to meet the requirements detailed in a soils report based on the “R” value of the subgrade and the Traffic Index, or The City’s has a minimum standard for new streets (4” AC over 8” Base) except truck usage (9”AC over 12” Base); However, if the Soils Report is obtained and indicates a thicker improvement, the thicker section shall be used.
ii. For transitioning from new curb alignment to existing edge of pavement outside project limits the edge shall be a deepened or thickened. Use Caltrans Design Manual or A Policy on Geometric Design of Highways and Streets for taper requirements.
iii. Both sides of Campus Parkway Street shall be paved as indicated above, As directed by the City Engineer.
iv. When Striping, all striping shall be thermoplastic paint per section 84 of the Caltrans specifications.
v. The corner shall be a 35’ Radius including a compliant ADA ramp with By -Pass and Truncated Domes. City of San Bernardino - Street Improvement Policy. vi. Installation of a bridge shall be determined by the reports and as directed by the City Engineer.
vii. Construct 8" Curb and Gutter per City Standard No. 200, type “B”, As directed by the City Engineer. City of San Bernardino - Street Improvement Policy. viii. Construct 6’ wide Cross Gutter with Apron per City Standard No 201 City of San Bernardino - Street Improvement Policy.
265-011-08, 265-021-13
265-041-12, 265-051-09
265-051-12, 265-051-13
265-061-16)
“Continuous Street”
(Main Loop Streets)

Continuous Streets

B, D, E, F, G, H, I, J, K, L, M, N, O,

X, Y, Z

PRIVATE
(265-011-06, 265-011-07
265-011-08, 265-021-13
265-041-12, 265-051-09
265-051-12, 265-051-13
265-061-16)

0’ Existing
25’ – 50’ Dedication
for a total ½ width of 25’ – 50’
Total
“Continuous Street”
(Neighborhood Local)
Required 48” ADA By-pass

0’ Existing
18’ -36’ Proposed
for a total ½ width of 18’ – 36’
Per General Plan
Cul-De-Sac Streets

G, I, M, L

PRIVATE
(265-011-06, 265-011-07
265-011-08, 265-021-13
265-041-12, 265-051-09
265-051-12, 265-051-13
265-061-16)
0’ Existing
25’ Dedication
for a total ½ width of 25’
“Cul-De-Sac”
Required 48” ADA By-pass
0’ Existing
18’ Proposed
for a total ½ width of 18’
Per General Plan
RESOLUTION NO. 2026-001 - PC

18 ix. Construct Sidewalk per City Standard No. 202; Case "A" (6’ wide adjacent to curb), as directed by the City Engineer. MC12.92.050, MC19.30.170, Ord. MC-1027, 9- 09-98; Ord. MC -691, 12 -19-89, City of San Bernardino - Street Improvement Policy.
x. Construction of a median/fire lane on Campus Parkway shall be per City Standard 206.
xi. Verify with planning about a Trial System, Include Horse Trail, Running Trail, connect to existing trials systems.
xii. An ADA Ramp shall be constructed at corner in accordance with the SPPWC (Standard Plans for Public Works Construction) or Caltrans Standard plans A88A, as directed by the City Engineer. Federal Highway – DIB82-04, City of San Bernardino - Street Improvement Policy.
xiii. Install Dark Sky Solar LED Street Lights adjacent to the site in accordance with City Standards. Also, when more than three (3) streetlights a separate street light plan sheet shall be submitted in the Offsite Improvement set in accordance with the City of San Bernardino Street Lighting Design Policies. Install ID Plate on Street light pole.
xiv. Install Storm Drain per County of San Bernardino’s CSDP (Comprehensive Storm Drain Plan), as directed by the City Engineer.
xv. Install Class I I Bike Lane per “Manual Uniform Traffic Control Devices - California”, as directed by the City Traffic Engineer, SBCTA (San Bernardino County Transportation Authority) Non-Motorized Transportation Plan rev. 2018. xvi. Install a city approved trash screen and filtration device in the catch basins, City of San Bernardino Phase I MS4 - Trash Provisions 13383 Order – 8-30-2017 by City Manager.
xvii. Appropriate Permits from Fish and Game, Army Corp of Engineers, Regional Water, and any others shall be required if Badger Canyon and percolation Basins are determined to be a blue line stream.
xviii. Appropriate Permits from County Flood Control, Municipal Water, Metro Water District and any others shall be required when adjacent, over, or under any of these Municipalities.
xix. No Parking/Stopping will be allowed on Campus Parkway install signs per city standards.
xx. Survey Monuments and ties shall be placed, replaced, tied out and recorded at any corner or alignment changes that are adjacent to the project area in accordance with California Land Surveyors Association – Monument Preservation Guidelines, Copies of Recor ded Monuments/Ties shall be delivered to Public Works/Engineering.
xxi. No Residential Driveway Access
xxii. Install a Traffic barrier on the south side of Campus parkway in areas adjacent to the existing CSUSB facilities yard.

RESOLUTION NO. 2026-001 - PC

19 xxiii. If a gate is constructed on Campus parkway, it shall be placed east of the future Campus Circle connection to allow free flow of traffic from Campus Parkway to CSUSB.

Badger Canyon Road Secondary Access Street – TI = 7.5 : * - ** xxiv. The street shall be rehabilitated to meet the requirements detailed in a soils report based on the “R” value of the subgrade and the Traffic Index, or The City’s has a minimum standard for new streets (4” AC over 8” Base) except truck usage (9”AC over 12” Base); However, if the Soils Report is obtained and indicates a thicker improvement, the thicker section shall be used.
xxv. For transitioning from new curb alignment to existing edge of pavement outside project limits the edge shall be a deepened or thickened. Use Caltrans Design Manual or A Policy on Geometric Design of Highways and Streets for taper requirements.
xxvi. Both sides of Little Mountain Drive, Secondary Access Road called Future Connection shall be paved as indicated above, As directed by the City Engineer. xxvii. Installation of a bridge shall be determined by the reports and as directed by the City Engineer.
xxviii. When Striping, all striping shall be thermoplastic paint per section 84 of the Caltrans specifications.
xxix. The corner shall be a 35’ Radius including a compliant ADA ramp with By -Pass and Truncated Domes. City of San Bernardino - Street Improvement Policy. xxx. Construct 8" Curb and Gutter per City Standard No. 200, type “B”, as directed by the City Engineer. City of San Bernardino - Street Improvement Policy. xxxi. Construct 6’ wide Cross Gutter with Apron per City Standard No 201, as directed by the City Engineer. City of San Bernardino - Street Improvement Policy. xxxii. An ADA Ramp shall be constructed at corner in accordance with the SPPWC (Standard Plans for Public Works Construction) or Caltrans Standard plans A88A, as directed by the City Engineer. Federal Highway – DIB82-04, City of San Bernardino - Street Improvement Policy.
xxxiii. Install Solar LED Street Lights adjacent to the site in accordance with City Standards. Also, when more than three (3) streetlights a separate street light plan sheet shall be submitted in the Offsite Improvement set in accordance with the City of San Bernardino Street Lighting Design Policies. Install ID Plate on Street light pole.
xxxiv. Install Storm Drain per County of San Bernardino’s CSDP (Comprehensive Storm Drain Plan), as directed by the City Engineer.
xxxv. Install a city approved trash screen and filtration device in the catch basins, City of San Bernardino Phase I MS4 - Trash Provisions 13383 Order – 8-30-2017 by City Manager.
xxxvi. Appropriate Permits from Fish and Game, Army Corp of Engineers, Regional Water, and any others shall be required if Devils Canyon Levy facility is determined to be a blue line stream.

RESOLUTION NO. 2026-001 - PC

20 xxxvii. Appropriate Permits from County Flood Control, Municipal Water, Metro Water District and any others shall be required when adjacent, over, or under any of these Municipalities.
xxxviii. No Parking/Stopping will be allowed on Badger mountain Canyon Road Secondary Access Road called Future, install signs per city standards. xxxix. At least 28 feet of pavement shall be provided along streets adjacent to the subdivision, unless otherwise approved by the City Engineer. xl. Two Independent means of access 28’ wide paved and dedicated shall be provided to the project. Additional width may be required for drainage control and traffic safety. xli. Survey Monuments and ties shall be placed, replaced, tied out and recorded at any corner or alignment changes that are adjacent to the project area in accordance with California Land Surveyors Association – Monument Preservation Guidelines, Copies of Recorded Monuments/Ties shall be delivered to Public Works/Engineering. xlii. No Residential Driveway Access
Continuous (Main Loops Streets)/Continuous Streets (Neighborhood Local Streets) – TI = 5.5 :
* - **
xliii. The street shall be rehabilitated to meet the requirements detailed in a soils report based on the “R” value of the subgrade and the Traffic Index, or The City’s has a minimum standard for new streets (4” AC over 8” Base) except truck usage (9”AC over 12” Base); However, if the Soils Report is obtained and indicates a thicker improvement, the thicker section shall be used.
xliv. When Striping, all striping shall be thermoplastic paint per section 84 of the Caltrans specifications.
xlv. The corner shall be a 35’ Radius including a compliant ADA ramp with By -Pass and Truncated Domes. City of San Bernardino - Street Improvement Policy. xlvi. Construct Residential Driveway Approach per City Standard No. 203, including an accessible by-pass around the top of the drive approach. No Driveways closer than 100’ from BCR/ECR as directed by the City Engineer. On corner lots only one frontage may have a driveway. MC12.28.060, MC12-28-100, MC15.04.230, MC16.20.030, 19.24.060, MC19.30.200, Ord. MC-1027, 9-09-98; Ord. MC -460, 5-15-85; Ord. MC-320, 12-06-83; Ord. 3918, 2 -25-80; Ord. 2519, 8 -20-63; Ord. 1963, 11 -18-52, Ord. MC -1531, 6 -03-20, City of San Bern ardino - Street Improvement Policy.
xlvii. If public street, construct 8" Curb and Gutter per City Standard No. 200, type “B”.

City of San Bernardino - Street Improvement Policy. If private street, 6” Curb and Gutter is allowed.
xlviii. Construct 6’ wide Cross Gutter with Apron per City Standard No 201 City of San Bernardino - Street Improvement Policy.
xlix. Construct Sidewalk per City Standard No. 202; Case "A" (6’ wide adjacent to curb), MC12.92.050, MC19.30.170, Ord. MC -1027, 9-09-98; Ord. MC -691, 12-19-89, City of San Bernardino - Street Improvement Policy.

RESOLUTION NO. 2026-001 - PC

21 l. Verify with planning about a Trial System, Include Horse Trail, Running Trail, connect to existing trials systems.
li. An ADA Ramp shall be constructed at corner in accordance with the SPPWC (Standard Plans for Public Works Construction) or Caltrans Standard plans A88A.

Federal Highway – DIB82-04, City of San Bernardino - Street Improvement Policy.
lii. Install Solar LED Street Lights adjacent to the site in accordance with City Standards. Also, when more than three (3) streetlights a separate street light plan sheet shall be submitted in the Offsite Improvement set in accordance with the City of San Bernardino Street Lighting Design Policies. Install ID Plate on Street light pole. Supply one (1) additional head for each solar head installed, As Directed by the City Traffic Engineer.
liii. Install Storm Drain per County of San Bernardino’s CSDP (Comprehensive Storm Drain Plan), as directed by the City Engineer.
liv. Install type II Bike Lane per “Manual Uniform Traffic Control Devices - California”, as directed by the City Traffic Engineer, SBCTA (San Bernardino County Transportation Authority) Non-Motorized Transportation Plan rev. 2018. lv. Install a city approved trash screen and filtration device in the catch basins, City of San Bernardino Phase I MS4 - Trash Provisions 13383 Order – 8-30-2017 by City Manager.
lvi. Appropriate Permits from County Flood Control, Municipal Water, Metro Water District and any others shall be required when adjacent, over, or under any of these Municipalities.
lvii. Survey Monuments and ties shall be placed, replaced, tied out and recorded at any corner or alignment changes that are adjacent to the project area in accordance with California Land Surveyors Association – Monument Preservation Guidelines, Copies of Recor ded Monuments/Ties shall be delivered to Public Works/Engineering.
lviii. Driveway Access from one frontage only
lix. B Street shall post signs to allow parking on one side of the street only for fire safety reason.

Cul-De-Sac Streets – TI = 4.5 : * - **
lx. The street shall be rehabilitated to meet the requirements detailed in a soils report based on the “R” value of the subgrade and the Traffic Index, or The City’s has a minimum standard for new streets (4” AC over 8” Base) except truck usage (9”AC over 12” Base); However, if the Soils Report is obtained and indicates a thicker improvement, the thicker section shall be used.
lxi. When Striping, all striping shall be thermoplastic paint per section 84 of the Caltrans specifications.
lxii. The corner shall be a 35’ Radius including a compliant ADA ramp with By -Pass and Truncated Domes. City of San Bernardino - Street Improvement Policy.

RESOLUTION NO. 2026-001 - PC

22 lxiii. Construct “Cul-De-Sac” Per City Standard No. 101, or by the approval of the City Engineer.
lxiv. Construct Residential Driveway Approach per City Standard No. 203, including an accessible by-pass around the top of the drive approach. No Driveways closer than 100’ from BCR/ECR as directed by the City Engineer. On corner lots only one frontage may have a driveway. MC12.28.060, MC12-28-100, MC15.04.230, MC16.20.030, 19.24.060, MC19.30.200, Ord. MC-1027, 9-09-98; Ord. MC -460, 5-15-85; Ord. MC-320, 12-06-83; Ord. 3918, 2 -25-80; Ord. 2519, 8 -20-63; Ord. 1963, 11 -18-52, Ord. MC -1531, 6 -03-20, City of San Bern ardino - Street Improvement Policy.
lxv. If public street, construct 8" Curb and Gutter per City Standard No. 200, type “B”.

City of San Bernardino - Street Improvement Policy. If private street, construct 6” Curb and Gutter is allowed.
lxvi. Construct 6’ wide Cross Gutter with Apron per City Standard No 201 City of San Bernardino - Street Improvement Policy.
lxvii. Construct Sidewalk per City Standard No. 202; Case "A" (6’ wide adjacent to curb), MC12.92.050, MC19.30.170, Ord. MC -1027, 9-09-98; Ord. MC -691, 12-19-89, City of San Bernardino - Street Improvement Policy.
lxviii. Verify with planning about a Trial System, Include Horse Trail, Running Trail, connect to existing trials systems.
lxix. An ADA Ramp shall be constructed at corner in accordance with the SPPWC (Standard Plans for Public Works Construction) or Caltrans Standard plans A88A.

Federal Highway – DIB82-04, City of San Bernardino - Street Improvement Policy.
lxx. Install Solar LED Street Lights adjacent to the site in accordance with City Standards. Also, when more than three (3) streetlights a separate street light plan sheet shall be submitted in the Offsite Improvement set in accordance with the City of San Bernardino Street Lighting Design Policies. Install ID Plate on Street light pole. Supply one (1) additional head for each solar head installed, As Directed by the City Traffic Engineer.
lxxi. Install Storm Drain per County of San Bernardino’s CSDP (Comprehensive Storm Drain Plan), as directed by the City Engineer.
lxxii. Install a city approved trash screen and filtration device in the catch basins, City of San Bernardino Phase I MS4 - Trash Provisions 13383 Order – 8-30-2017 by City Manager.
lxxiii. Survey Monuments and ties shall be placed, replaced, tied out and recorded at any corner or alignment changes that are adjacent to the project area in accordance with California Land Surveyors Association – Monument Preservation Guidelines, Copies of Recor ded Monuments/Ties shall be delivered to Public Works/Engineering.
lxxiv. Driveway Access from one frontage only
RESOLUTION NO. 2026-001 - PC

23 * These Conditions are set for an estimated construction with -in two years. If construction exceeds two years from DERC Approval these conditions shall be reviewed and updated as needed.
** If a Scoping Form is required, this form shall indicate the need of a Traffic Report, the results of the traffic report shall become conditions of this project which may increase or extend the above requirements in section 1(b) and 5(a). c) With Submittal of improvement plans including but not limited to grading plans, Street improvement plans, storm drain and retention/detention basin plans, and erosion/sediment control plans, The Applicant shall cause to be formed, or shall be annexed into an existing, Community Facilities District(s) (CFD) (2019-1 Maintenance if Public & 2018 -1 Safety) for landscaping, lighting, streets, drainage facilities, street sweeping, graffiti removal, or other infrastructure, and safety as required by the City to the satisfaction of the City Engineer. If Public, The Applicant shall initiate the maintenance and benefit assessment district(s) formation, or annexation, by submitting a landowner petition and consent form (provided by the City) and deposited necessary fees concurrent with the application for street and grading plan review and approval; and said maintenance and benefit assessment district(s) shall be established concurrent with the approval of the final map in the case of the subdivision of land, or prior issuance of any certificate of occupancy where there is no subdivision of land, and as approved by the City Engineer. Reso 2018-264, Reso 2019-178. d) If a drainage report is required by Land Development, A second copy of the drainage report will be delivered to public works, if offsite or overflow storm drain systems are identified, all systems shall be identified on the street improvement plans, and publ ic storm drain shall be on a separate set of plans.
e) City approved trash screens and filtration devices shall be installed in all catch basins or manhole connections. City of San Bernardino Phase I MS4 - Trash Provisions 13383 Order – 8-30-2017 by City Manager.
f) A temporary construction encroachment permit from Public Works Department shall be required for utility cuts into existing streets or any work within City’s right-of-way.

Pavement restoration or trench repair shall be in conformance with City Standard No. 310. Public facilities shall be restored or constructed back to Public Works Department satisfaction.
g) Any pavement works affecting the traffic loop detectors shall be coordinated and subjected to Public Works Traffic Division requirements. h) The applicant must post a performance bond (Insurance, Deposit) prior to issuance of the off -site permit. The amount of the bond is to be determined by Public Works Department. MC12.03.110, Ord. MC-1027, 9-09-98; Ord. MC-1004, 10-21-97. i) The above conditions shall comply with current codes, policies, and standards at time of construction.
j) No Direct Connections to City’s underground Storm Drain Systems or Catch Basins.

RESOLUTION NO. 2026-001 - PC

24 k) Prior to Certificate of Occupancy or Completion of Project all As-builts and Centerline Ties shall be submitted to Public Works.
l) Release of “Offsite Bond” requires an application and fees paid along with As -Builts signed by the Contractor and Inspector on a signed approved set of plans issued with permits, Centerline ties for all locations disturbed or created, and an electronic set of as-builts plans.

31. Required Engineering Plans
a) A complete submittal for plan checking shall consist of (MC19.30.170, City of San Bernardino Public Works - Improvement Policies):
▪ street improvement plans (include general notes, engineering conditions, city standards, and cross sections in these plans),
▪ if storm drain plans are required then public storm drains must be included on separate sheets with profiles in the street improvement plans, private storm drains shall be shown separate sheets with profiles in the on -site improvement plans,
▪ if traffic signal modifications are required, then traffic signal plans shall be submitted on separate plan sheets included in the street improvement plans, ▪ if signing and striping are required, then the signing and striping plan shall be on separate sheets included in the street improvement plans, ▪ if lighting is required (more than 2) then the lighting for offsite plans shall be on separate sheets included in the street improvement plans, if two (2) or less then they can be included directly on the street improvement sheets, ▪ If there are public common areas, CFD’s are required, the CFD Plans shall include Landscaping, Irrigation, Basins, etc. items that are included in the CFD that are not listed in the plans above, shall be on separate sheets included in the street improvement plans.
▪ other plans as required. Piecemeal submittal of various types of plans for the same project will not be allowed.
▪ All required supporting calculations, studies and reports must be included in the initial submittal (including but not limited to drainage studies, soils reports, structural calculations)
b) All off-site improvement plans submitted for plan check shall be prepared on the City’s standard 24” x 36” sheets. A signature block (city standard block) satisfactory to the City Engineer or his designee can be found on the City Web Site http://www.sbcity.org/city_hall/public_works/engineering_division/engineering_deve lopment_resources Engineering conditions of the project shall be inserted in the last pages of the plans.
c) After completion of plan checking, final mylar drawings with city standard block, stamped and signed by the Registered Civil Engineer in charge, shall be submitted to the City Engineer for approval.

RESOLUTION NO. 2026-001 - PC

25 d) Electronic files of all improvement plans/drawings shall be submitted to the City Engineer. The files shall be compatible with AutoCAD 2021 and include a .dxf file of the project. Files shall be on CD and shall be submitted at the same time the final mylar drawings are submitted for approval.
e) Copies of the City’s policies and procedures and standard drawings are available at the Public Works Counter for the cost of reproduction. They are also available at no charge at the Public Works Web Site at
http://www.sbcity.org/city_hall/public_works/engineering_division/design_policy_an d_procedure_documents .

32. Traffic Requirements
a) In general, as applicable, all roadway design, traffic signing and striping, traffic signal, street lighting, sidewalks and traffic control improvements relating to the proposed project should be constructed in accordance with applicable engineering standards and to the satisfaction of the City of San Bernardino Traffic Engineering Division.

b) In conjunction with standard City of San Bernardino development review procedures, on‐site traffic signing, and striping plans should be prepared in accordance with applicable State and Federal standards.

c) The final grading, landscaping, and street improvement plans should demonstrate that sight distance standards are met in accordance with applicable City of San Bernardino /California Department of Transportation sight distance standards.

d) Payment of applicable of local and regional development impact fees shall be paid to the City of San Bernardino.

e) The developer will submit engineered plans for the improvements for University Parkway at Northpark Boulevard: Add a second northbound left-turn lane.

f) Prior to submission of the offsite improvement plans, the developer will prepare a Traffic signal warrant analysis study for the intersection of Campus Parkway and Devils Canyon Road.

Public Works Department – Integrated Waste Division

33. Integrated Solid Waste Management
a) During demolition and/or construction, services are to be provided through the City of San Bernardino’s franchised hauler Burrtec Waste Industries, Inc. b) Project Description: Amend the development plan for the University Hills Specific Plan

c) Burrtec Waste review: Construct a 437-unit small lot residential subdivision with a minimum parcel size of 2,750 square feet. The Site Plan dated 8/19/22, presents a preliminary design for a subdivision. Lots front a series of looped streets and cul-de-sacs.

No dimensions are provided. Burrtec comments are as follows:

1. Please provide dimensions for all streets and cul-de-sacs. In order to safely provide residential cart service, all streets must have a paved section of at least 30 feet.

2. All cul-de-sacs must meet City of San Bernardino standards for cul-de-sac radii.

3. Residential collection services require a minimum of ten feet of curb frontage in order to stage the three carts for trash, mixed recyclables, and residential organics.

RESOLUTION NO. 2026-001 - PC

26 4. Carts shall not be staged in driveways or in front of garages. Carts cannot be staged in front of parked carts on the street.

5. In the event that cart service cannot be provided due to a lack of available curb face for cart staging, the locations of trash enclosures shall be provided on the Site Plan.

Enclosures must be within 150 feet of any residential unit.

Any changes to the overall project design, enclosure specifications or location, or access may adversely impact Burrtec's ability to service the project. Any design modifications that could impact Burrtec's service will be subject to review and approval by Burrtec.

Burrtec's review of this project is limited to determining whether it meets Burrtec's minimum standards for waste and recycling collection services. Any comments or approvals by Burrtec are limited to these minimum standards as they relate to our equipment and personnel and do not pertain to the project's compliance with applicable federal, state and local land use and environmental laws, building codes or other applicable government regulations. Any approvals by Burrtec do not warrant or represent that Burrtec accepts any liability relative to the performance of waste and recycling collection services within this project.

End of Burrtec comments.

d) Each single-family residential unit requires approximately 10 feet of clear space on the street along the curb adjacent to the driveway, for placement of the residential carts for trash, mixed recyclables, and residential organics on collection day, with a minimum 2- foot setback and 23 -foot vertical clearance of all obstructions such as walls, trees, streetlight poles, mailboxes, fences, and raised landscaping.

e) Each single-family residential unit requires a minimum 4’x11’concrete pad located out of view of the public right-of-way for the storage of residential carts. If visible from the public right-of-way, the storage area shall be screened.

f) A minimum 10.5 -foot space on the street along the curb adjacent to the driveway of each unit shall be clear for placement of the units’ residential carts on collection day, with a minimum 2-foot setback and 23-foot vertical clearance of all obstructions su ch as walls, trees, street light poles, mailboxes, fences, and raised landscaping.

g) Burrtec Waste Truck Turning Radius – All corners and intersections on streets and driveways, shall have a turning radius adequate for a 35 -foot long, three -axle collection truck. The minimum inside curb radius shall be at least 28 feet. The minimum outside curb radius shall be at least 42 feet. All streets and driveways shall comply with applicable City standards. Burrtec Waste’s truck turning template may be obtained from the Public Works Department in PDF and CAD.

h) Hammerhead Turnarounds shall meet or exceed San Bernardino County Fire Protection District Diagram A -1.12: Hammerhead Turnaround Detail dated July 1, 2021. San Bernardino County Hammerhead detail may be obtained from the Public Works Department.

i) If gated, access shall be provided by means of a key, code, or remote.

RESOLUTION NO. 2026-001 - PC

27 j) Senate Bill 1383 Short-Lived Climate Pollutants Reduction Act may apply.

k) Upon completion, service is provided through the City of San Bernardino’s franchised hauler Burrtec Waste Industries, Inc. 111 E. Mill Street, San Bernardino, CA 92408 (909) 804-4222.

34. Required Engineering Permits
a) Grading and On-site improvements permit (LD).
b) WQMP/Hydrology (THR).
c) Lot Merger (LM).
d) Off-site improvement construction permit. (E).
e) Traffic Control and Right-of-Way permit (ROW).
f) CFD/Street Dedication permit (RP).

35. Applicable Engineering Fees
a) All plan check, permit, inspection, and impact fees are outlined on the Public Works Fee Schedule. A deposit in the amount of 100% of the estimated checking fee for each set of plans will be required at time of application for plan check. The amount of t he fee is subject to adjustment at time of issuance.
b) The current fee schedule is available at the Public Works Counter and at http://www.sbcity.org or http://www.ci.san-
bernardino.ca.us/cityhall/publicworks/engineering_division/engineering_fee_schedul e.asp

36. Water Department-Engineering

a) If there are any street improvements associated with the project then it is the developer/s and/or engineer/s responsibility to submit a copy of the street improvements plans to SBMWD’S engineering section for review. b) -Water and sewer main extensions with easements may be required. c) -Water and sewer main extensions required per rule and regulation no. 20. d) -Development of new pressure zone required to meet water demand. e) R.P.P. Backflow Device Required at Service Connection for Domestic Service. f) Double Check Backflow Device Required at Service Connection for Fire and Irrigation.
g) Backflow Device to be Inspected before Water Service can be Activated. h) Sewer capacity fee must be 0 gallons a day paid to the Water Department. i) Subject to Recalculation of Fee prior to the Issuance of Building Permit.

37. Water Department Environmental Control

a) No comments until the development of the residential units.

RESOLUTION NO. 2026-001 - PC

28 San Bernardino County Fire Department Consolidated Conditions of Approval

38. The above referenced project is under the jurisdiction of the San Bernardino County Fire Department herein “Fire Department”. Prior to any construction occurring on any parcel, the applicant shall contact the Fire Department for verification of current fire protection requirements. All new construction shall comply with the current California Fire Code requirements and all applicable statutes, codes, ordinances, and standards of the Fire Department.

39. The FMZ report as included in University Hills Specific Plan dated May 2024 has been approved as submitted. A copy of this approved report shall be kept onsite in the HOA Office to reference FMZ areas for future yearly inspections. Building permits shall not be issued for this project until all fuel modifications are completed by contractor and inspected by the San Bernardino County Fire Protection District, Office of the Fire Marshal.

40. The required fire fees shall be paid to the San Bernardino County Fire Department/Community Safety Division.

41. Prior to combustibles being placed on the project site an approved all -weather fire apparatus access surface and operable fire hydrants with acceptable fire flow shall be installed. The topcoat of asphalt does not have to be installed until final inspection and occupancy.

42. Building plans shall be submitted to the Fire Department for review and approval.

43. The development shall have a minimum of three points of vehicular access. These are for fire/emergency equipment access and for evacuation routes. a. Single Story Road Access Width. All buildings shall have access provided by approved roads, alleys and pri vate drives with a minimum twenty -six (26) foot unobstructed width and vertically to fourteen (14) feet six (6) inches in height. b. Multi -Story Road Access Width. Fire apparatus access roadways serving buildings that are three (3) or more stories or thirty (30) feet or more in height shall be a minimum of thirty (30) feet in unobstructed width and vertically to fourteen (14) feet six (6) inches in height. One of the access points shall be an EVA located on the north west corner of the tract as shown on approved TTM.

44. Fire apparatus access roads shall be designed and maintained to support the imposed loads of fire apparatus and shall be surfaced so as to provide all -weather driving capabilities. Road surface shall meet the approval of the Fire Chief prior to installatio n. All roads shall be designed to 85% compaction and/or paving and hold the weight of Fire apparatus at a minimum of 80K pounds.

45. Turnaround. An approved turnaround shall be provided at the end of each roadway one hundred and fifty (150) feet or more in length. Cul-de-sac length shall not exceed six hundred (600) feet; all roadways shall not exceed a 12% grade and have a minimum of f orty-five (45) foot radius for all turns. In the Fire Safety Overlay District areas, there are additional requirements.

RESOLUTION NO. 2026-001 - PC

29 46. Prior to building permits being issued to any new structure, the primary access road shall be paved or an all-weather surface and shall be installed as specified in the General Requirement conditions including width, vertical clearance and turnouts.

47. Prior to building permits being issued to any new structure, the secondary access road shall be paved or an all-weather surface and shall be installed as specified in the General Requirement conditions including width, vertical clearance and turnouts.

48. A water system approved by the Fire Department is required. The system shall be operational prior to any combustibles being stored on the site. Detached single family residential developments may increase the spacing between hydrants to be no more than six hundred (600) feet and no more than three hundred (300) feet (as measured along vehicular travel-ways) from the driveway on the address side of the proposed single-family structure.

49. Please provide a fire flow test report from your water purveyor that has been completed in the last six months demonstrating that the fire flow demand is satisfied.

50. Prior to any land disturbance, the water systems shall be designed to meet the required fire flow for this development and shall be approved by the Fire Department. The required fire flow shall be determined by using California Fire Code. The Fire Flow for this project shall be: 2250 GPM for a two-hour duration at 20 psi residual operating pressure. Fire Flow is based on a 6700 sqrft. structure.

51. A water system approved by the Fire Department is required. The system shall be operational prior to any combustibles being stored on the site. Detached single family residential developments may increase the spacing between hydrants to be no more than six hundred (600) feet and no more than three hundred (300) feet (as measured along vehicular travel-ways) from the driveway on the address side of the proposed single-family structure.

52. Combustible vegetation shall be removed as follows: a. Where the average slope of the site is less than 15% -Combustible vegetation shall be removed a minimum distance of thirty (30) feet from all structures or to the property line, whichever is less. b. Where the average slope of the site is 15% or greater - Combustible vegetation shall be removed a minimum one hundred (100) feet from all structures or to the property line, whichever is less.

53. The applicant shall submit a fire lane plan to the Fire Department for review and approval. Fire lane curbs shall be painted red. The "No Parking, Fire Lane" signs shall be installed on public/private roads in accordance with the approved plan.

54. This project is required to have an approved street sign (temporary or permanent). The street sign shall be installed on the nearest street corner to the project. Installation of the temporary sign shall be prior any combustible material being placed on the construction site. Prior to final inspection and occupancy of the first structure, the permanent street sign shall be installed.

55. Blue reflective pavement markers indicating fire hydrant locations shall be installed as specified by the Fire Department. In areas where snow removal occurs or non -paved roads exist, the blue reflective hydrant marker shall be posted on an approved post along the side of the road, no more than three (3) feet from the hydrant and at least six (6) feet high above the adjacent road.

RESOLUTION NO. 2026-001 - PC

30 56. An automatic fire sprinkler system complying with NFPA Pamphlet #13, and the Fire Department standards is required. The applicant shall hire a Fire Department approved fire sprinkler contractor. The fire sprinkler contractor shall submit plans to the with hydraulic calculation and manufacturers specification sheets to the Fire Department for approval and approval. The contractor shall submit plans showing type of storage and use with the applicable protection system. The required fees shall be paid at the time of plan submittal.

57. The street address shall be installed on the building with numbers that are a minimum of four (4) inches in height and with a one half (½) inch stroke. The address shall be visible from the street. During the hours of darkness, the numbers shall be internally and electrically illuminated with a low voltage power source. Numbers shall contrast with their background and be legible from the street. Where the building is one hundred (100) feet or more from the roadway, the street address shall be displayed at the property entrances with numbers that are a minimum of four (4) inches in height and one half (½) inch stroke.

58. Where an automatic electric security gate is used, an approved Fire Department override switch (Knox ®) is required.

59. An approved spark arrestor is required. Every chimney that is used in conjunction with any fireplace or any heating appliance in which solid or liquid fuel are used, shall have an approved spark arrestor visible from the ground that is maintained in confor mance with the California Fire Code.

60. Permission to occupy or use the building (certificate of Occupancy or shell release) will not be granted until the Fire Department inspects, approves, and signs off on the Building and Safety job card for “fire final”.

61. Fire Condition Letters shall expire on the date determined by the Planning Division or Building and Safety.

62. The County General Plan designates this property as being within the Fire Safety Review Area.

All construction shall adhere to all applicable standards and requirements of the Fire Safety Review Area as adopted in the San Bernardino County Development Code.

63. A Fuel Modification Zone (FMZ) plan designed specifically for the subject project is required and shall be designed by a consultant approved by the Fire Department. The FMZ plan shall be submitted to the Fire Department for review and approval in complianc e with County standards.

64. The applicant shall construct and maintain all such roads. In addition, the applicant shall provide to the Fire Department a signed maintenance agreement as detailed in the General Requirement conditions for ongoing road maintenance and snow removal (where applicable).

This shall include all primary and secondary access routes that are not otherwise maintained by a public agency.

65. Where the natural grade between the access road and building is more than thirty percent (30%), an access road shall be provided within one hundred and fifty (150) feet of all buildings.

RESOLUTION NO. 2026-001 - PC

31 Where such access cannot be provided, a fire protection system shall be installed. Plans shall be submitted to and approved by the Fire Department.

66. Fire access roadways shall not exceed a maximum of twelve (12%) percent grade at any point.

Fire access roadways or driveways may be increased to fourteen (14%) percent grade for a distance not to exceed five hundred (500) feet. Fire access roadways provid ing access to no more than two (2) one or two -family dwellings may be increased to a maximum of sixteen (16%) percent grade not to exceed five hundred (500) feet. Grades across the width of a fire access roadway shall not exceed five (5%) percent.

In order to accommodate proper angles of approach and departure, gradient shall not exceed five (5%) percent change along any ten (10) foot section.

67. Roadways exceeding one hundred fifty (150) feet in length shall be approved by the Fire Department. Roadways shall be extended to within one hundred fifty (150) feet of and shall give reasonable access to all portions of the exterior walls of the first story of any building.

68. Each residential structure shall obtain a Residential Fire Letter form the County of San Bernardino County Fire protection District prior to any construction.

69. Any changes to the proposal shall require new Fire Department review and Condition Letter.

SECTION 5. PLANNING COMMISSION ACTION:

The Planning Commission hereby takes the following action:

1. Adoption of Planning Commission Resolution No. 2026-001 - PC forwarding a recommendation that the Mayor and City Council:

a. Consider the Addendum to the certified Final Subsequent Environmental Impact Report (SCH #2007071155) for Specific Plan Amendment 23-01 and Subdivision 23- 05, in accordance with Section 15164(a) of the Public Resources Code, and direct the Planning Commission Secretary to prepare and file with the Clerk of the County of San Bernardino a Notice of Determination as provided under Public Resources Code, Section 21152(c) and California Code of Regulations, Title 14, Section 15094; and

b. Approve Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595) based on the Findings of Fact and subject to the recommended Conditions of Approval.

SECTION 7. 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.

RESOLUTION NO. 2026-001 - PC

32 SECTION 8. CUSTODIAN OF RECORDS:

The location and custodian of the documents and any other material, which constitute the record of proceedings upon which the Planning Commission based its decision, is as follows: Telicia Lopez, City Clerk, 201 North E Street (Building A), 909-998-2680.

PASSED, APPROVED AND ADOPTED this 13th day of January 2026.

Lisa Sherrick, Chairperson
San Bernardino Planning Commission

ATTEST:

Gabriel Elliott, Planning Commission Secretary
City of San Bernardino, California

RESOLUTION NO. 2026-001 - PC

33 CERTIFICATION:

I, Alyssa Blancas, Recording Secretary of the Planning Commission of the City of San Bernardino, California, do hereby certify that the foregoing Resolution No. 2026-001 - PC, was duly adopted by the Planning Commission of the City of San Bernardino, California, at a regular meeting thereof held on the 13th day of January 2026, by the following vote, to wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

Alyssa Blancas, Recording Secretary
City of San Bernardino, California

RESOLUTION NO. 2026-001 - PC

34 EXHIBIT A

PROJECT PLANS

RESOLUTION NO. 2026-001 - PC

35 EXHIBIT B

MITIGATION MONITORING AND REPORTING SYSTEM

RESOLUTION NO. 2026-001 - PC

36 EXHIBIT C

DRAFT MEMORANDUM OF UNDERSTANDING

RESOLUTION NO. 2026-001 - PC
33 EXHIBIT A
352-(&7 PLANS
7 1

TITLE SHEET
TTM 20595

UNIVERSITY HILLS

SHEET LIST TABLE
TENTATIVE TRACT MAP NO. 20595 FOR

UNIVERSITY HILLS

CITY OF SAN BERNARDINO

OFFICIAL USE ONLY
LEGEND:

ABBREVIATIONS:

RAW GRADING:
7 2

BOUNDARY & LEGAL
TTM 20595

UNIVERSITY HILLS

PROPOSED LOT LINE TABLE
7 3

LOT LAYOUT & GRADING
TTM 20595

UNIVERSITY HILLS
LEGEND

PROPOSED AC PAVEMENT
NOTE
SEE SHEET 4
SEE SHEET 5

NEIGHBORHOOD LOCAL

STREETS B, D, E, F, G, H, I, J, K, L, M, N, O, X, Y, AND Z

SECONDARY COLLECTOR

STREETS A & C

PRIMARY COLLECTOR

CAMPUS PARKWAY
1 2 3 5 6 7 8 9 10 11 12 13 14 15
17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
7677787980818283
868788899091
92 9394
95 969798
110112
114
115
116 117 118
119 120
121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 155156157158161162
163
164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 319
320
321
322
323
325
326
99100101
102103104105107108109
33 16
4 74
75 327

STREET H

STREET F

STREET B

STREET G

STREET A
STREE

STREET H
REET J

STREET D
APN: 0265-021-13
APN: 0265-031-24

STREET Y
113
32 8485
106111
159
324
LOT B

OPEN SPACE
LOT C
PARK
LOT D
PARK
LOT F

OPEN SPACE

DESIGNATED

REMAINDER
LOT I

OPEN SPACE

DESIGNATED

REMAINDER
160
7 4

LOT LAYOUT & GRADING
TTM 20595

UNIVERSITY HILLS
LEGEND

PROPOSED AC PAVEMENT
SEE SHEET 3
SEE SHEET 5
NOTE
SEE SHEET 7
SEE SHEET 7
164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192
202
203
204
205
206
283
288
295 296 297
207
208209210211
212
213 214 215 216 217
218
219
220
221
305 306
308
309
310
311
313
314
316
317
318
319
320
321
222
223
225
227 229 230 232 233 234 236 237 238
241 242
243
244 245 246 247 248 249 252 253
254
255 256 257 258 259 261 264 266
274 273 272 271 270
269
268
267
275
276
277 278 279
281 282
239
240
250 251
262
284
285
286
287
289290291292293
294
298 299 300
302 303 304

STREET N

STREET M

STREET H

STREET A

STREET C

STREET H

STREET O

STREET L

STREET I

STREET J

STREET J
APN: 0265-031-25

STREET X

STREET Z

STREET L
APN: 0265-041-15
PROP. CAMPUS

PARKWAY
LOT A

OPEN SPACE
BASIN
CANYON RD.

ED BADGER CANYON ACCESS ROAD
BADGER
224
235231228260
263 265
280
301
307
315
312
LOT H

OPEN SPACE
LOT H
LOT G

OPEN SPACE
7 5

LOT LAYOUT & GRADING
TTM 20595

UNIVERSITY HILLS
SEE SHEET 3
LEGEND

PROPOSED AC PAVEMENT
NOTE

SEE BOTTOM RIGHT

SEE TOP LEFT
SEE SHEET 4
35 36 37 38 39 40 41 42 43 44 45 46 50
515253545556575859606162
68 6970
7172
6 51 3 6 137 138 139 140 141 142 143 144 145 146 147 148 149
150
154
188 189 190 191
192 193 195
196
197
198
199
200
201
202
203
204
205
206
220
221 222
223
225
226
241 242
243
253
240
33 34 47 48
152
153
49 63
74 75

STREET F

STREET B
C

STREET C

STREET H

STREET O

STREET L

STREET E

STREET C

STREET K
APN: 0265-021-13
APN: 0265-041-15
151
32 64656667
73 194
224
LOT E
PARK
LOT G

OPEN SPACE

LOT GOPEN SPACE
LOT H
LOT F

OPEN SPACE

REMAINDER
LOT I

OPEN SPACE

DESIGNATED

REMAINDER
LOT I

OPEN SPACE

DESIGNATED

REMAINDER
7 6

ACCESS ROADS
TTM 20595

UNIVERSITY HILLS
LEGEND

PROPOSED AC PAVEMENT
NOTE
STA 45+50 ± TO STA 53+00 ±STA 10+00.00 TO STA 45+50 ±

BADGER CANYON ACCESS ROADBADGER CANYON ACCESS ROAD
SEE SHEET 7SEE SHEET 7

PROPOSED CAMPUS PARKWAY ACCESS ROAD

EXISTING CAMPUSPARKWAY

PROPOSED BADGER CANYON ACCESS ROAD
EX. UNIVERSITY CAMPUS CIRCLE

STATE OF CALIFORNIA PROPERTY

SAN BERNARDINO COUNTY FLOOD CONTROL DISTRICT PROPERTY
7 7

ACCESS ROADS
TTM 20595

UNIVERSITY HILLS
LEGEND

PROPOSED AC PAVEMENT
NOTE
SEE SHEET 6
SEE SHEET 6

STREET C
APN: 0265-041-15
PROP. CAMPUS

PARKWAY
LOT A

OPEN SPACE
BASIN

PROPOSED CAMPUS PARKWAY ACCESS ROAD

PROPOSED BADGER CANYON ACCESS ROAD
LOT G

OPEN SPACE

STATE OF CALIFORNIA PROPERTY
RESOLUTION NO. 2026-001 - PC
34 EXHIBIT B
0,7,*$7,21021,725,1*$1'
5(3257,1*6<67(0
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-1 October 2025

MITIGATION MONITORING AND REPORTING PROGRAM
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
Air Quality and Greenhouse Gas Emissions
MM AIR-1a: Prior to construction of the proposed improvements, the project
proponent will provide a Fugitive Dust Control Plan (FDCP) that will describe the application of standard best management practices to control dust during construction. Best management practices will include:
Application of water on disturbed soils a minimum of two times per day.
Using track-out prevention devices at construction site access points.
Stabilizing construction area exit points.
Limiting onsite construction traffic to 15 miles per hour on unpaved roads.
Limiting onsite construction traffic to 25 miles per hour on paved roads.
Paving or providing a hard surface for onsite roads to reduce fugitive dust.
Covering dirt haul vehicles; and
Replanting disturbed areas as soon as practical and other measures, as deemed appropriate to the site, to control fugitive dust.

The Fugitive Dust Control Plan shall be submitted to the City for review and approval prior to grading.

Prior to
Construction and
Grading Activities
Provide a Fugitive Dust
Control Plan
City of San
Bernardino
Community
Development &
Housing
Department
MM AIR-1b: Prior to construction of the proposed improvements, a Construction Traffic Control Plan (CTCP) will be reviewed and approved by the City. CTCP will describe in detail safe detours around the project construction site and provide temporary traffic control (i.e., flag person) during construction-related truck hauling activities.

Prior to
Construction
Activities
Provide Construction
Traffic Control Plan
(CTCP)
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-2 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
MM AIR-1c: During construction of the proposed improvements, construction equipment shall be properly maintained at an offsite location, including proper tuning and timing of engines. Equipment maintenance records and equipment design specification data sheets shall be kept on-site during construction.

During
Construction and
Grading Activities
Construction
Equipment to occur at
an offsite location.

City of San
Bernardino
Community
Development &
Housing
Department
MM AIR-1d: During construction of the proposed improvements, all contractors will be advised not to idle construction equipment on the site for more than five minutes.

During
Construction and
Grading Activities
Construction
equipment to not idle
for longer than five
minutes.

City of San
Bernardino
Community
Development &
Housing
Department
MM AIR-1e: During construction of the proposed improvements, onsite electrical hook ups shall be provided for electric construction tools including saws, drills and compressors, to eliminate the need for diesel powered electric generators.

During
Construction
Activities
Provide Electrical Hook
ups
City of San
Bernardino
Community
Development &
Housing
Department
MM AIR-1f: Onsite grading equipment will comply with one or more of the following:
Use of onsite grading and construction equipment equipped with oxidized diesel catalyst and fueled with aqueous diesel fuel during grading and construction operations with a reduced equipment fleet or hours of operation totaling a maximum of 17,000 horsepower hours per day.
Use of onsite grading and construction equipment equipped with oxidized diesel catalyst with a reduced equipment fleet or hours of operation totaling a maximum of 14,000 horsepower hours per day.
Use of onsite grading and construction equipment fueled with aqueous diesel fuel during grading and construction operations During Grading
Activities
Onsite Grading
Equipment to Comply
with Grading
Equipment standards
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-3 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
with a reduced equipment fleet or hours of operation totaling a maximum of 13,000 horsepower hours per day; and
Reduce the grading and construction equipment fleet or hours of operation to a maximum total of 10,000 horsepower hours per day.

MM AIR-1g: Implementation of the Short-Term Air Quality Mitigation Measures shall be documented in an Air Quality Mitigation Implementation Plan. This plan will detail each mitigation measure and include daily logs documenting implementation of each mitigation measure. Daily logs for each piece of construction equipment will include the hours per day the equipment ran. A master daily log will document the hours of operation all equipment ran each day. The master daily log will also document timing and tuning of equipment, the type of fuel used on construction equipment, and any add-on emissions reduction equipment used such as oxidized diesel catalysts.

During
Construction
Activities
Document the Hours of
Operation of All
Equipment Ran Each
Day
City of San
Bernardino
Community
Development &
Housing
Department
MM AIR-3a: The project proponent shall install bicycle racks at the clubhouse, MDA and A (attached) housing areas (Planning Areas 6, 8-11, 13, 14, 16, 18, and 20), and all park sites to encourage non- vehicular trips within the project.

During
Construction
Activities
Install Bicycle Racks at
Housing Areas and Par
k
City of San
Bernardino
Community
Development &
Housing
Department
MM AIR-3b: The project design shall include signs posted in visible places in any truck parking areas that state, “No Idling.” During
Construction and
Operational
Activities
Install Signs On Visible
Places in Any Truck
Parking Areas that
State, “No Idling.”
City of San
Bernardino
Community
Development &
Housing
Department
MM AIR-9a: Areas and/or facilities to encourage recycling shall be provided and installed in all MDA and A (attached) residential areas consistent with City requirements.

During Operational
Activities
Encourage Recycling City of San
Bernardino
Community
Development &
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-4 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
Housing
Department
MM AIR-9b: To increase energy efficiency, the following measures shall be implemented to the satisfaction of the City of San Bernardino: a) there shall be a minimum 10 percent reduction in all buildings, combined space heating, cooling, and water heating energy compared to the current Title 24 Standards; b) the project shall incorporate light roof colors and cool pavements in the residential driveway areas; c) each appliance (i.e., washer/dryers, refrigerators, stoves, etc.) provided by the builder must be Energy Star qualified if an Energy Star designation is applicable for that appliance; d) low-flow appliances (i.e., toilets, dishwashers, shower heads, washing machines) shall be installed and; e) solar powered water heaters and photovoltaic cells (solar panels) shall be offered to homebuyers as an option constructed in accordance with Title 24 performance standards.

During Operational
Activities
Encourage Energy
Saving
City of San
Bernardino
Community
Development &
Housing
Department
Biological Resources
MM BIO-1a: Plummer’s Mariposa Lily. During the spring prior to grading, the developer shall retain a qualified biologist to conduct a focused survey of the proposed development areas to determine if this species is present onsite. The survey shall be conducted according to the standard protocol established by CDFGCDFW. If the species is present, the developer shall fund relocation of the plants to a suitable location within the permanent open space area.

Prior to Project-
Related
Disturbance of
Soils (14 days)
Prior to Grading
Activities, Prepare a
Focused Survey
Qualified
Biologist
MM BIO-1b: Burrowing Owl. Within 30 days of grading or any ground disturbance activities on the project site, a qualified biologist shall conduct a focused survey to determine if Burrowing owls are present onsite. The survey shall be conducted according to the Standard protocol established by CDFGCDFW. If burrowing owls are determined to be present on the site, mitigation shall follow the CDFGCDFW guidelines including passive relocation. the developer shall coordinate with the City and CDFW to develop a Burrowing Owl Plan, as described below, to be approved by the City and CDFW prior to commencing project activities. Additionally, the developer may be Prior to Project-
Related
Disturbance of
Soils (within 30
days of grading)
Prior to Grading
Activities, Conduct a
Focused Survey
Qualified
Biologist
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-5 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
required to obtain a Section 2081 incidental Take Permit, if impacts to Burrowing Owl cannot be avoided. The developer shall implement the 2081 Incidental Take Permit if required. If applicable, the Burrowing Owl Plan shall describe proposed avoidance, relocation, monitoring, minimization, and/or mitigation actions. The Burrowing Owl Plan shall include the number and location of occupied burrow sites and details on proposed buffers if avoiding the burrowing owls or information on the adjacent or nearby suitable habitat available nearby for relocation, details regarding the creation and funding of artificial burrows (numbers, location, and type of burrows) and management activities for relocated owls shall also be included in the Burrowing Owl Plan. The City shall implement the Burrowing Owl Plan following CDFW review and approval. If vegetation removal or ground disturbance begins within 30 days of the focused survey, no pre-construction survey would be required. If vegetation removal or ground disturbance activities begin after 30 days of the focused survey, a subsequent pre-construction survey would be required.

MM BIO-1c: Nesting Birds. If trees or large shrubs (over 4 feet in height) will be removed during the nesting season (February 1 through August 31), a qualified biologist shall conduct a nesting bird survey no more than 30 days prior to any disturbance to identify any potential nesting activity. If passerine birds are found to be nesting, or there is evidence of nesting behavior within 250 feet of the impact area, the biologist shall determine an appropriate buffer that shall be required around the nests. No vegetation removal or ground disturbance would occur within this buffer. For raptor species – birds of prey (e.g., hawks and owls) – this buffer would generally be 500 feet. A qualified biologist shall monitor the nests closely until it is determined that the nests are no longer active, at which time construction activities may commence within the buffer area.

Construction activity may encroach into the buffer area at the discretion of the biological monitor.

Prior to Project-
Related
Disturbance of
Soils
Nesting Bird Survey Qualified
Biologist
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-6 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
MM BIO-3a: Jurisdictional Land. Prior to grading, the developer shall obtain a Clean Water Act Section 404 Permit from USACE, a Clean Water Act Section 401 Certification from the RWQCB (Santa Ana Region), and a Streambed Alteration Agreement from CDFG CDFW if jurisdictional land will be impacted. Offsite mitigation, if necessary, shall be provided at a minimum 1:1 ratio depending on location and importance of the jurisdictional land removed. If the project provides onsite mitigation equal or in excess of its identified impact (i.e., removal of jurisdictional land), no permits maybe necessary. If there are impacts there will be a permit needed regardless of mitigation type, this determination shall be made by qualified biologists in consultation with City Planning, USACE, RWQCB, and CDFG CDFW staff based on the final land plan and value assigned to the proposed bio-swales and other drainage improvements onsite.

To further protect and offset removal of suitable habitat through the preservation of open space and preserve water quality through the implementation of standard Best Management Practices (BMPs):
Clearly delineating the limits of disturbance.
Avoiding impacts in preserved open space area.
Preserving of open space through a deed restriction.

Using properly maintained equipment and storing equipment outside of jurisdictional waters.
Properly implementing and monitoring water quality BMPs. Avoiding use of chemicals near sensitive areas.
Minimizing impacts to sensitive biological resources onsite including sensitive plant communities, jurisdictional waters, and sensitive wildlife species through the use of a biological monitor during vegetation removal.
Implementing a worker education program through a pre- construction meeting with a biologist, which will include developing procedures for minimizing the likelihood of spills, ensuring worker safety, education regarding nesting birds and sensitive species, surveying for sensitive species prior to construction, and obtaining any necessary permits prior to Prior to Grading
Activities
Obtain Section 404
Permit, Section 401
Certification, and
Streambed Alteration
Agreement
Qualified
Biologist and
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-7 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
initiation of construction, including those listed in this mitigation, State ESA permits, and/or Federal ESA permits. Crotch’s bumble bee (Bombus crotchii) is listed as a candidate species under the California Endangered Species Act. According to CDFW, the Project site is within the geographic range for Crotch’s bumble bee. Additionally, the Streambed Alteration Agreement would require avoidance, minimization and/or
mitigation measures to protect fish and wildlife and their habitat. Therefore, to minimize impacts to Crotch’s bumble bee from the Project, a qualified biologist shall conduct focused surveys within one year prior to vegetation removal and/or grading for the presence/absence of Crotch’s bumble bee.

Surveys shall be conducted during flying season when species is most likely to be detected above ground, between March 1 to September 1, by an approved qualified biologist, familiar with Crotch’s bumble bee behavior and live history. Surveys shall be conducted within the Project site and areas adjacent to the Project site where suitable habitat exists. Survey results including negative findings shall be submitted to CDFW 30 days prior to Project-related vegetation removal and/or ground- disturbing activities. If the species is identified onsite, and if “take” would occur, the developer shall apply for an incidental take permit and obtain “take” coverage prior to the initiation of Project activities.

Cultural Resources
MM CUL-2: The developer shall retain a qualified archaeologist with at least 3 years of regional experience in archaeology to monitor all ground-disturbing activities that occur within the proposed project area (which includes, but is not limited to, tree/shrub removal and planting, clearing/grubbing, grading, excavation, trenching, compaction, fence/gate removal and installation, drainage and irrigation removal and installation, hardscape installation [benches, signage, boulders, walls, seat walls, fountains, etc.], and archaeological work), grading to the satisfaction of the staff of the County Museum, and City Development & Housing Department, and Prior to Ground
Disturbing
Activities
Direct Observations,
Site Inspections
Qualified
Archaeologist
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-8 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
the consulting tribes, including Yuhaaviatam of San Manuel Nation Cultural Resources Management Department (YSMN, also known as San Manuel Band of Mission Indians). A sufficient number of archaeological monitors shall be present each workday to ensure that simultaneously occurring ground disturbing activities receive thorough levels of monitoring coverage.

MM CUL-3: If potentially significant archaeological or historic resources are encountered during subsurface activities, all construction within a 60 100-foot radius of the find shall cease until the monitor determines whether the resource requires further study. The developer shall include a standard inadvertent discovery clause in every construction contract to inform contractors of this requirement. Any previously undiscovered resources found during construction shall be recorded on appropriate DPR forms and evaluated for significance in terms of CEQA criteria by a qualified Secretary of the Interior (SOI) Archaeologist. Potentially significant cultural resources consist of, but are not limited to, glass, ceramics, stone, bone, wood, rock and shell artifacts or features, including hearths, structural remains, or pre-historic dumpsites. If the resource is determined to be significant under CEQA, a qualified SOI Archaeologist shall prepare and implement a research design and archaeological data recovery plan, if necessary. The archaeologist shall also perform appropriate technical analyses, prepare a full written report and file it with the appropriate information center, and provide for permanent curation of the recovered resources.

During Ground
Disturbing
Activities
Site Monitoring Qualified SOI
Archaeologist
MM CUL-4: Prior to the start of excavation, a qualified paleontological monitor will be retained to conduct an onsite monitoring program to ensure protection of previously unknown paleontological specimens. In the event a fossil is discovered during construction of the Project when the paleontological monitor is not present, excavation within 100 feet of the find shall be temporarily halted until the discovery is examined by a qualified paleontologist, in accordance with Society of Vertebrate Paleontology standards.

The developer shall include a standard inadvertent discovery clause in every construction contract to inform contractors of this Prior to
Grading/Excavation
Activities
Site Monitoring Qualified
Paleontological
Monitor
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-9 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
requirement. The paleontologist shall notify the City of the procedures that must be followed before construction is allowed to resume at the location of the find. If the find is determined to be significant and the Paleontologist determines that avoidance is not feasible, the paleontologist shall design and carry out a data recovery plan consistent with the Society of Vertebrate Paleontology standards. The plan shall be submitted to the City for review and approval. Upon approval, the plan shall be incorporated into the project. The Paleontologist shall also perform appropriate technical analyses, prepare a full written report and file it with the appropriate information center, and provide for permanent curation of any recovered resources.

MM CUL-5: If human remains are encountered during earth- disturbing activities for the Project, all work within 100 feet of the find shall stop immediately, an Environmentally Sensitive Area (ESA) physical demarcation/barrier constructed, and the San Bernardino County Coroner’s office shall be notified. If the Coroner determines the remains are Native American in origin, the NAHC will be notified and, in turn, will notify the person determined to be the Most Likely Descendent (MLD). The MLD will provide recommendations for treatment of the remains (CEQA Guidelines § 15064.5; Health and Safety Code § 7050.5; Public Resources Code §§ 5097.94 and 5097.98).

Ongoing
Throughout
Construction
Activities
Site Monitoring Qualified
Archaeologist
Geology and Soils
MM GEO-1b: Prior to the recordation of any tract map in the area north of the South Branch of the San Andreas Fault (PlanningArea15), the developer must demonstrate that the Reservoir in Planning Area 2 will have no impact on any homes in Planning Area 1 from a seiche event that could occur from strong seismic ground shaking. The Reservoir must be designed to withstand anticipated seismic shaking and must be dyked or otherwise protected so as to protect downstream homes from seiche flow damage.

Prior to the
recordation of any
map in the area
north of the South
Branch of the San
Andreas Fault.

Direct Observations,
Site Inspections
City of San
Bernardino
Community
Development &
Housing
Department
MM GEO-3a: Prior to the commencement of grading activities, the applicant shall retain a qualified geotechnical consultant to test any Prior to Grading
Activities
Direct Observations,
Site Inspections
City of San
Bernardino
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-10 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
areas planned for development that are underlain by existing imported fill soils to determine their in-situ compaction and suitability for excavation and reuse as engineered fill. Soil testing can be avoided if the applicant elects to remove the fill and place it either in areas where it will not support buildings, be located in paved or landscaped areas, or be disposed of offsite. This measure shall be implemented to the satisfaction of the City Geologist.

Community
Development &
Housing
Department
MM GEO-3b: The developer shall implement the grading
recommendations identified in the 2021 Leighton Report GeoMat 2007 and the CHJ 2006 reports. Prior to the commencement of building construction, the applicant shall retain a qualified engineer to design foundations adequate to support the Project’s structures where necessary, based on the recommendations of the 2021 Leighton ReportGeoMat 2007 study. Settlement analysis shall be performed once the structural design loads and foundation system geometry have been defied for each building.

Prior to Issuance of
Building Permit
Direct Observation of
Grading and
Foundation Designs
City of San
Bernardino
Community
Development &
Housing
Department
Hazards and Hazardous Materials
MM HAZ-1: Prior to issuance of occupancy permits, the developer shall prepare a Post-Fire/Flood Recovery Plan for review and approval by the City. As appropriate, this plan shall incorporate planning guidelines from the Alluvial Fan Task Force (AFTF) established by the California Department of Water Resources (DWR).

The plan will identify the potential risks to Project residents from various natural hazards from being located in the fire-prone foothills and adjacent to a large natural waterway (Badger Creek). The plan will outline measures to be implemented after major fires or floods that will help protect future project residents to the practical degree.

When approved, this plan shall be incorporated into the Specific Plan.

Prior to Issuance of
Occupancy Permits
Direct Observation of
Post-Fire/Flood
Recovery Plan.

City of San
Bernardino
Community
Development &
Housing
Department
Hydrology and Water Quality
MM HYD-1a: Prior to the issuance of grading permits for any portion or phase of the project, the project applicant shall receive City approval SWPPP and Grading Plan to the City of San Bernardino that identify specific actions and BMPs to prevent stormwater pollution Prior to Issuance of
Grading Permits
Direct Observations
and Review of SWPPP
and Grading Plan
City of San
Bernardino
Community
Development &
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-11 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
from construction sources. These BMPs shall be consistent with the Conceptual Water Quality Management Plan prepared for the project by PBS&J Engineers (see DEIR Appendix G)Q3 Consulting. The plans shall identify a practical sequence for site restoration, BMP implementation, contingency measures, responsible parties, and agency contacts. The applicant shall include conditions in construction contracts requiring the plans to be implemented and shall have the ability to enforce the requirement through fines and other penalties. The plans shall incorporate control measures in the following categories:
Soil stabilization practices.
Dewatering practices (if necessary).
Sediment and runoff control practices.
Monitoring protocols; and
Waste management and disposal control practices.

Once approved by the City, the applicant’s contractor shall be responsible throughout the duration of the project for installing, constructing, inspecting, and maintaining the control measures included in the SWPPP and Grading Plan.

Housing
Department
MM HYD-1b: Each SWPPP shall identify pollutant sources that could affect the quality of stormwater discharges from the construction site. Control practices shall include those that effectively treat target pollutants in stormwater discharges anticipated from project construction sites. To protect receiving water quality, the SWPPP shall include, but is not limited to, the following elements:
Temporary erosion control measures (such as fiber rolls, staked straw bales, detention basins, temporary inlet protection, check dams, geofabric, sandbag dikes, and temporary revegetation or other ground cover) shall be employed for disturbed areas. No disturbed surfaces will be left without erosion control measures in place during the winter and spring months
(September 30 – March 30).
Sediment shall be retained onsite by a system of sediment basins, traps, or other appropriate measures. Of critical Prior to Issuance of
Grading Permits
Direct Observations
and Review of SWPPP
Pollutant Sources
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-12 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
importance is the protection of existing catch basins that eventually drain to Cajon Creek.
The construction contractor shall prepare Standard Operating Procedures for the handling of hazardous materials on the construction site to eliminate or reduce discharge of materials to storm drains.
BMPs performance and effectiveness shall be determined either by visual means where applicable (i.e., observation of above- normal sediment release), or by actual water sampling in cases where verification of contaminant reduction or elimination, (inadvertent petroleum release) is required to determine adequacy of the measure.
Native grasses or other appropriate vegetative covers shall be established on the construction site as soon as possible after disturbance.

MM HYD-2a: Landscaping Management Plan. The developer shall develop and implement a Landscaping Management Plan (LMP) for landscaped areas with the goal of reducing potential discharge of herbicides, pesticides, fertilizers, and other contaminants to local waterways. All contractors involved in project-related landscaping conducted during the individual phases of development, as well as maintenance of landscaping following project completion, shall complete their work in strict compliance with the LMP. The applicant shall be responsible for ensuring that requirements of the LMP are provided to and instituted by future project landowners and managers following project completion. The LMP shall be prepared by a licensed landscape architecture firm with experience in methods to reduce or eliminate the use of landscape chemicals that could cause adverse effects to the environment. At a minimum, this LMP shall:

1. Require that pesticides and fertilizers not be applied in excessive quantities, and only applied at times when rain is not expected for at least 2 weeks, in an effort to minimize leaching and runoff into the storm drainage system.

Prior to Issuance of
Grading Permit
Direct Observation and
Review of Landscaping
Management Plan
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-13 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials

2. Encourage the use of organic fertilizers and mulching of landscaped areas inhibit weed growth and reduce water
demands.

3. Utilize native, perennial, drought-tolerant vegetation to minimize irrigation needs.

4. Specify the maintenance measures to be used (e.g., mowing) and will specify an application schedule for all fertilizer amendments and pesticide applications.

5. Identify a list of preferred herbicides and pesticides and instances in which their use would be appropriate and the associated application rate.

MM HYD-2b: Water Quality Maintenance Reports. The UHSP project shall form a Landscaping and Lighting Maintenance District (LLMD) to monitor water quality and provide regular reports to the City regarding water quality on the project site. A qualified professional shall be retained through the LLMD to prepare and provide annual documentation to the City Engineer that the onsite BMPs (i.e., water quality devices, improvements, and procedures) are functioning as planned to effectively protect water quality both onsite and on downstream uses/drainages. This includes the function and condition of bioswales, street sweeping, etc. These reports shall be made to the satisfaction of the City Engineer in consultation with the RWQCB if necessary. If a report indicates water quality objectives are not being met and/or the RWQCB has expressed concerns in this regard, the LLMD will take appropriate steps and/or make appropriate improvements to achieve these objectives, to the satisfaction of the City Engineer.

Prior to Issuance of
Grading Permit
Direct Observation and
Review of Landscaping
and Lighting
Maintenance District
(LLMD)
City of San
Bernardino
Community
Development &
Housing
Department
MM HYD-5: Prior to approval of any final maps, the developer shall submit drainage plans to the City Public Works Department for review and approval. The City shall review and approve all storm drain improvement plans prior to issuance of any encroachment or building permits that involve flood control facilities.

Prior to Approval
of any Final Maps
Direct Observation of
Drainage Plans
City of San
Bernardino
Community
Development &
Housing
Department
Land Use
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-14 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
MM LU-1: Prior to issuance of any occupancy permits, the developer shall coordinate with City, CSUSB, and USFS staffs to identify necessary access points and appropriate locations for such signage to clearly identify the USFS boundary along the perimeter of the University Hills property (i.e., Planning Area 24Planning Areas 1 and 2). Such signage will be placed at strategic locations, including any road or trail access points, to the satisfaction of the City in consultation with CSUSB and USFS staffs.

Prior to Issuance of
Occupancy Permits
Direct Observation and
Site Inspections
City of San
Bernardino
Community
Development &
Housing
Department
Noise
MM NOI-1a: At the time the grading permit application is submitted, the project applicant shall submit a Construction Noise Mitigation Plan to the City for review and approval. The plan shall depict the location of staging areas for construction equipment and describe how noise would be mitigated for any nearby sensitive receptors.

At the time, the
Grading Permit
Application is
Submitted
Direct Observation and
Review of Construction
Noise Mitigation Plan
City of San
Bernardino
Community
Development &
Housing
Department
MM NOI-1b: Stationary noise-generating equipment (such as pumps and generators) will be located as far as possible from nearby noise- sensitive receptors (i.e., homes located in PA 16-20Planning Area 1) and no closer than 200 feet from any existing home within the Project site once occupancy has begun.

Prior to Ground
Breaking
Disturbances
Direct Observation and
Site Inspection
City of San
Bernardino
Community
Development &
Housing
Department
MM NOI-1c: Noise-generating equipment will be shielded from nearby noise-sensitive receptors by noise-attenuating buffers such as structures or haul truck trailers.

Prior to Ground
Disturbing
Activities
Direct Observation and
Site Inspection
City of San
Bernardino
Community
Development &
Housing
Department
MM NOI-1d: Onsite noise sources located less than 600 feet from noise-sensitive receptors will be equipped with noise-reducing engine housings.

Prior to Ground
Breaking
Disturbances
Direct Observation and
Site Inspection
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-15 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
MM NOI-1e: Portable acoustic barriers able to attenuate at least 6 dB will be placed around noise-generating equipment in the “East Village” portion Planning Area 2 of the project site.

Prior to Ground
Breaking
Disturbances
Direct Observation and
Site Inspection
City of San
Bernardino
Community
Development &
Housing
Department
MM NOI-1f: Water tanks and equipment storage, staging, and warm- up areas will be located as far from noise-sensitive receptors as possible, and at least 200 feet from any existing home within the Project site once occupancy has begun.

Prior to Ground
Breaking
Disturbances
Direct Observation and
Site Inspection
City of San
Bernardino
Community
Development &
Housing
Department
MM NOI-1g: All construction equipment shall utilize noise reduction features (e.g., mufflers and engine shrouds) that are no less effective than those originally installed by the manufacturer.

Prior to Ground
Breaking
Disturbances
Direct Observation and
Site Inspection
City of San
Bernardino
Community
Development &
Housing
Department
MM NOI-1h: No construction equipment shall be allowed to idle for more than 5 minutes if it is within 100 feet of an existing house.

Ongoing
Throughout
Construction
Activities
Direct Observation and
Site Inspection
City of San
Bernardino
Community
Development &
Housing
Department
MM NOI-1i: Prior to approval of any subsequent tentative tract maps, the developer shall submit noise studies as appropriate for any residences within the project to assure that exterior and interior noise levels meet City noise standards based on actual final floor elevations, actual roadway cross sections and elevations, onsite topography after grading, etc. Walls or other attenuating improvements shall be installed as needed based on the results of these studies to ensure onsite residences meet the City’s noise regulations.

Prior to Ground
Breaking Approval
of any Subsequent
Tentative Tract
Maps
Direct Observation of
Noise Studies
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-16 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
Transportation and Circulation
MM TRANS-2: Recommended improvements may include a
combination of fee payments to established programs, construction of specific improvements, payment of a fair-share contribution toward future improvements, or a combination of these approaches.

For programmed improvements, the developer will pay into the regional transportation fee program. A summary of the intersection operations before and after implementation of these recommended improvements is provided on EIR Addendum Appendix D Table 9. A summary of the Project fair share percentages for these recommended improvements is provided on EIR Addendum
Appendix D, Traffic Impact Analysis Table 5 and similarly on Table 13 of the EIR Addendum.
#5 – University Parkway at I-215 Freeway NB Ramps: Add a third westbound right-turn lane.
#6 – University Parkway at I-215 Freeway SB Ramps: Add a dedicated northbound right-turn lane.

Prior to Issuance of
the Building
Permit.

Identified future
improvements that are
not currently in the
City's Master Facilities
Plan (MFP) will be
added and the
Developer Impact Fee
(DIF) adjusted to
include the additional
costs, then the project
will pay the
appropriate DIF
amount. The project
will pay the
appropriate fee for the
indicated future
improvements that are
already in the MFP and
DIF programs. It is
understood that some
freeway-related
improvements,
including some future
ramp improvements,
may not be fully
funded from available
sources in the future.
(Please refer to
Table 5-2 for
implementation and
funding of this
mitigation).

City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-17 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
MM TRANS-8: Prior to the commencement of construction, the developer shall provide a Construction Traffic, Staging, and Parking Management Plan to the City of San Bernardino for review and approval. All construction contracts shall include a clause requiring compliance with the Construction Traffic, Staging, and Parking Management Plan and the developer shall be able to enforce the provisions of the plan through penalties, up to and including, termination of the contract. The plan shall include the following provisions:
Construction truck traffic shall be limited to the following designated routes: Campus Parkway from the site and west of Northpark Boulevard to Kendall Drive, and Kendall Drive from Campus Parkway to Palm Avenue. Construction truck traffic shall be prohibited on all other roadways, unless compelling
circumstances warrant such movements (e.g., a major traffic accident).
Signage shall be installed at construction truck ingress and egress points alerting motorists to such movements.
Soil, debris, or other loose materials shall be covered with tarps or other restraining material during haul movements on
roadways.
On-site and off-site construction staging and parking locations shall be identified, as well as any necessary shuttle service needed to transport workers from off-site locations. For safety reasons, off-site staging or parking shall not be allowed west of Northpark Boulevard or on the CSUSB Cal State San Bernardino campus.
A pre-construction conference shall be held advising all construction contractors of the requirements of the
Construction Traffic, Staging, and Parking Management Plan.

Prior to
Construction
Activities
Review of Construction
Traffic, Staging, and
Parking Management
Plan
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-18 October 2025
Verification
Mitigation Measures (MMs) Implementation
Timing
Monitoring/ Reporting
Methods
Responsible for
Approval/
Monitoring Date Initials
Utilities and Service Systems
MM US-4a: Prior to the issuance of building permits, the applicant shall submit a Construction Debris Recycling Plan to the City of San Bernardino identifying the procedures by which construction and demolition would be salvaged and recycled to the maximum extent feasible. The plan shall include proof that a construction and demolition debris recycler is under contract to the applicant to perform this work. This Plan shall achieve at least a 50 percent reduction in construction waste, to the satisfaction of the City Planner.

Prior to the
Issuance of
Building Permits
Review of Construction
Debris Recycling Plan
City of San
Bernardino
Community
Development &
Housing
Department
MM US-4b: Prior to the issuance of occupancy permits, the developer shall provide the City with written assurance that all project residents will be provided with information on City and County waste reduction and disposal activities. This information may be provided by the developer or homeowners association (HOA) as appropriate. This measure shall be implemented to the satisfaction of the City Planner.

Prior to Issuance of
Occupancy Permits
Review of Information
on City and County
Waste Reduction and
Disposal Activities
City of San
Bernardino
Community
Development &
Housing
Department
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-19 October 2025
Conditions of Approval (COAs)
Verification
Tribal Cultural Resources Implementation
Timing
Monitoring/
Reporting Methods
Responsible for
Approval/
Monitoring Date Initials
COA TCR-1 Due to the heightened cultural sensitivity of the proposed project area, at the discretion of the consulting tribe(s), Tribal monitor(s) authorized to represent YSMN shall be present for all ground-disturbing activities that occur within the proposed project area (which includes, but is not limited to, tree/shrub removal and planting, clearing/grubbing, grading, excavation, trenching, compaction, fence/gate removal and installation, drainage and irrigation removal and installation, hardscape installation [benches, signage, boulders, walls, seat walls, fountains, etc.], and archaeological work). At the discretion of the consulting tribes, a sufficient number of Tribal monitors shall be present each workday to ensure that simultaneously occurring ground disturbing activities receive thorough levels of monitoring coverage.  A Monitoring and Treatment Plan that is reflective of the project mitigation (“Cultural Resources” and “Tribal Cultural Resources”) shall be completed by the qualified SOI Archaeologist and submitted to the Lead Agency for dissemination to YSMN. Once all parties review and agree to the plan, it shall be adopted by the Lead Agency – the plan must be adopted prior to permitting for the project. Any and all findings will be subject to the protocol detailed within the Monitoring and Treatment Plan.

During All
Ground
Disturbing
Activities
Monitoring Tribal Monitor
Approved by
YSMN and
City of San
Bernardino
Community
Development &
Housing
Department
COA TCR-2 If a pre-contact cultural resource is discovered during project implementation, ground-disturbing activities shall be suspended 60 feet around the resource(s), and an Environmentally Sensitive Area (ESA) physical demarcation/barrier constructed.

The SOI Project Archaeologist shall develop a research design that shall include a plan to evaluate the resource for significance under CEQA criteria. Representatives from YSMN, the Archaeologist, and the Lead Agency shall confer regarding the research design, as well as any testing efforts needed to delineate the resource boundary.

Following the completion of evaluation efforts, all parties shall confer regarding the resource's archaeological significance, its potential as a Tribal Cultural Resource (TCR), and avoidance (or other appropriate treatment) of the discovered resource.

During All
Ground
Disturbing
Activities
Site Monitoring Qualified SOI
Archaeologist
Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-20 October 2025
Conditions of Approval (COAs)
It is the preference of YSMN that removed cultural material be reburied as close to the original find location as possible. However, should reburial within/near the original find location during project implementation not be feasible, then a reburial location for future reburial shall be decided upon by YSMN, the landowner, and the Lead Agency, and all finds shall be reburied within this location.

Additionally, in this case, reburial shall not occur until all ground- disturbing activities associated with the project have been completed, all monitoring has ceased, all cataloguing and basic recordation of cultural resources have been completed, and a final monitoring report has been issued to Lead Agency, CHRIS, and YSMN.

All reburials are subject to a reburial agreement that shall be developed between the landowner and YSMN outlining the
determined reburial process/location and shall include measures and provisions to protect the reburial area from any future impacts.

Should it occur that avoidance, preservation in place, and on-site reburial are not an option for treatment, the landowner shall relinquish all ownership and rights to this material and confer with YSMN to identify an American Association of Museums (AAM)- accredited facility within the County that can accession the materials into their permanent collections and provide for the proper care of these objects in accordance with the 1993 CA Curation Guidelines.  A curation agreement with an appropriate qualified repository shall be developed between the landowner and museum that legally and physically transfers the collections and associated records to the facility.  This agreement shall stipulate the payment of fees necessary for permanent curation of the collections and associated records and the obligation of the Project developer/applicant to pay for those fees.

All draft records/reports containing the significance and treatment findings and data recovery results shall be prepared by the archaeologist and submitted to the Lead Agency and YSMN for their review and comment. After approval from all parties, the final reports and site/isolate records are to be submitted to the local CHRIS Information Center, the Lead Agency, and YSMN.

Addendum to the University Hills Specific Plan Project
City of San Bernardino Mitigation Monitoring and Reporting Program Page C-21 October 2025
Conditions of Approval (COAs)
Transportation and Circulation
Table 13: Summary of Project Fair Share for Recommended Improvements AM Peak Hour PM Peak Hour
Total Volume Total VolumeInt. # Intersection
2022 2026
Total
Growth
Project
Trips %
2022 2026
Total
Growth
Project
Trips %
Opening Year 2026 Cumulative Conditions
5 University Pkw. At I215
Freeway NB Ramps
3,663 4,23
7 578 128 22.3% 4,16
5 4,84
2 677 169 25.0%
Future Build-Out Year 2040 Cumulative Conditions
5 University Pkw. At I215
Freeway NB Ramps
3,663 4,37
9 716 128 17.9% 4,16
5 4,92
6 761 169 22.2%
6 University Pkw. At I215
Freeway SB Ramps
2,448 3,11
2 664 104 15.7% 2,97
0 3,98
6 1,016 91 9.0%
Source: Kimley-Horn. 2025. Traffic Impact Analysis: Table 5, Summary of Project Fair Share for Recommended Improvements.

RESOLUTION NO. 2026-001 - PC
35 EXHIBIT C
'$5(029$/-867,),&$7,21

ENCORE CAPITAL MANAGEMENT
770 TAMALPAIS DRIVE, #401B, CORTE MADERA, CA 94925
Phone: (415) 561-0600 Fax: (415) 561-0601 www.EncoreCM.com February 23, 2023
Stephanie Sanchez
Economic Development Project Manager
City of San Bernardino
201 North E St, 3
rd Floor
San Bernardino, CA 92401
Re: DA Removal Justification Letter
University Hills Specific Plan
Badger Canyon Road & W Frontline Road
Dear Mrs. Sanchez,
We appreciate your continued assistance with our revitalization of the University Hills Specific Plan. Your team’s engagement and responsiveness has been monumental in helping us tailor the revised site plan to fit the needs of the community.

Pursuant to continued conversations with city staff, we hereby formally request to remove the previous Development Agreement from title for the reasons below:

Significant Changes to Design Standards
The provisions of the previous agreement no longer apply since we no longer satisfy Section 1.1 of developing the project “in accordance with the Project Approvals” from 2012, given we are changing the density and intensity of use, size of buildings, zoning standards, and the size of the dedicated mitigation land area. The unit count has been significantly reduced from 980 medium to high density units to 437 single-family homes and the permanent open space acreage has grown from 235 to 251 acres.

Our unit mix below, no longer comprises 515 two-story townhomes. x 2,750 (50’ wide x 55’ deep) square foot lots
x 3,600 (40’ wide x 90’ deep) square foot lots
x 4,500 (50’ wide x 90’ deep) square foot lots
5-Year Performance Requirement
The project is also out of compliance with Section 3.1.1 and Exhibit F which states:

Prior to the fifth anniversary of the effective date [April 19, 2012] of the development agreement the Owner/Developer shall:

Acquire the necessary rights (easements, licenses, rights of way, encroachment permits, etc) to construct the Phase 1 Infrastructure, including roads, intersections, drainage facilities, slopes, fuel [modification] areas, water storage tank and water lines.

Complete a full submittal of completed construction plans, which will include the civil engineering and landscape architecture, for a phase of single family homes consisting of at least 25 lots, with an associated park.

ENCORE CAPITAL MANAGEMENT
770 TAMALPAIS DRIVE, #401B, CORTE MADERA, CA 94925
Phone: (415) 561-0600 Fax: (415) 561-0601 www.EncoreCM.com After meeting with San Bernardino County Flood Control and CSU San Bernardino, we have confirmed that these tasks were never completed by the April 19, 2017 deadline. We are meeting with these agencies regularly to discuss alternative options that may better serve all parties involved.

As always, we appreciate your continued attention to our project and look forward to delivering this community to the city. Please feel free to contact me with any questions or comments at [email protected].

Sincerely,
Julian Nan
Vice President
Encore University Hills LLC
Applicant

ATTACHMENT B
Project Justification Letter

ENCORE CAPITAL MANAGEMENT
770 TAMALPAIS DRIVE, #401B, CORTE MADERA, CA 94925
Phone: (415) 561-0600 Fax: (415) 561-0601 www.EncoreCM.com February 15, 2023
Elizabeth Mora-Rodriguez
Senior Planner
City of San Bernardino
201 North E St, 3
rd Floor
San Bernardino, CA 92401
Re: Justification Letter
University Hills Specific Plan Amendment
Badger Canyon Road & W Frontline Road
Applications: Specific Plan Amendment
Tentative Tract Map
Dear Mrs. Elizabeth Mora-Rodriguez,
On behalf of Encore University Hills LLC, we thank you for the City of San Bernardino’s continued attentiveness to our proposed development of 437 residential single-family homes as part of the formerly approved University Hills Specific Plan (“Project”). We look forward to working with the City to deliver a quality community designed to enhance this neighborhood within the City.

Site Plan
The Project proposes three primary lot configurations:
x 2,750 (50’ wide x 55’ deep) square foot lots
x 3,600 (40’ wide x 90’ deep) square foot lots
x 4,500 (50’ wide x 90’ deep) square foot lots
The proposed configurations had to be designed around the San Bernardino Valley Municipal Water District’s (SBVMWD) 75” Foothill Pipeline which runs through the property. SBVMWD requirements over the pipeline presented three constraints: (1) a 50’ wide easement to be maintained over the Project, (2) only streets and parkways allowed within the easement, and (3) minimum and maximum coverage of 6’ and 20’, respectively, over the pipeline at any given location within the Project. The pre-application site plan satisfies all three requirements and SBVMWD has provided their approval of our plan.

In order to keep home prices within reason for this Project that is being designed for the local community, we minimized our grading and wall costs by designing a site that balances and incorporates slopes in lieu of retaining walls where possible. To achieve a balanced site, we set the grade at the pipeline’s highest elevation located in the northwest region of “Parcel 1”, then lowered the site by maximizing slope fall toward the lowest point of the property while still meeting street circulation requirements for Fire and ADA.

In conjunction with these slope conditions, the introduction of shallower 50’x55’ lotsmade balancing the site possible.

The majority of the layout adheres to the original Specific Plan. Approximately 251 acres will remain permanent open space and no structures will be built within fault zones. Primary access to “Parcel 1” remains on a future road that will run parallel to Badger Canyon Road and connect to Devils Canyon Road, and access to “Parcel 2” and “Parcel 3” remains on a future road that will connect to Campus Circle. A Specific Plan Amendment will be processed to accommodate the design guidelines needed for single-family detached homes throughout the entire site.

ENCORE CAPITAL MANAGEMENT
770 TAMALPAIS DRIVE, #401B, CORTE MADERA, CA 94925
Phone: (415) 561-0600 Fax: (415) 561-0601 www.EncoreCM.com

19.64.070 Findings

1. The proposed plan is consistent with the General Plan The 437-unit single family detached residential plan is consistent with the city’s General Plan and is subject to Senate Bill 330 (SB 330), the Housing Crisis Act of 2019, because the Specific Plan was approved for up to 980 residential units in 2008. Although the overall unit count has decreased, the project remains in compliance with SB 330 because of its location within a Very High Fire Severity Zone, for which a full Fire Protection Plan was not previously prepared. The formerly approved Specific Plan also did not fully study two other important constraints on the site: (1) the SBVMWD Foothill Pipeline and (2) home construction within the fault zone. Due to constraints presented by the Very High Fire Severity Zone designation, the SBVMWD Foothill Pipeline mentioned above, and our desire to avoid building homes within the fault zone, the submitted site plan offers the best possible product configuration that can realistically be developed and built.

2. The proposed plan would not be detrimental to the public interest, health, safety, convenience, or welfare of the City
Now that the unit count is less than half the originally approved unit count, the project will not have more significant impacts than the previously certified EIR. We are avoiding plotting homes in the fault zones to put the safety of our future residents first, which also allows us to grow the overall open space areas north of the development. Pedestrians will be able to traverse the site and continue to access the trails that lead up into the foothills. All design standards will be coordinated with their respective city departments and local agencies to ensure they prioritize the public welfare of the community.

3. The subject property is physically suitable fo r the requested land use designation(s) and the anticipated land use development(s)
The site plan conforms to the guidelines of SBVWMD, ADA street circulation, SB County Fire, and fault zone setbacks while minimizing the impact of earthwork by keeping the site as balanced as possible. It was designed to reduce the quantity and costs of offsite and onsite infrastructure in consideration of the surrounding community. Reduced improvement costs will most often lead to more attainable home prices for future homebuyers.

4. The proposed plan shall ensure development of desirable character which will be compatible with existing and proposed development in the surrounding neighborhood The project maintains 251 acres of open space to preserve the natural landscape in the foothills north of the site. The intent is to preserve the natural environment around the project and find ways to integrate its features into the future community. The density is now much more compatible with surrounding neighborhoods in the University District and Verdemont by offering only single family detached livability.

5. The proposed plan will contribute to a balance of land uses so that local residents may work and shop in the community in which they live
California is in dire need of housing, especially workforce housing for first-time homebuyers and young families undergoing household formation growth. University Hills is intended to serve this demographic by delivering the American dream of homeownership to the local community. The development will support local retail by establishing a population base of frequent visitors exploring their local neighborhood.

California State University San Bernardino may provide employment options, and the proximity to the 215 Freeway will provide commuters access to nearby employment hubs.

ENCORE CAPITAL MANAGEMENT
770 TAMALPAIS DRIVE, #401B, CORTE MADERA, CA 94925
Phone: (415) 561-0600 Fax: (415) 561-0601 www.EncoreCM.com Thank you again for the opportunity to deliver this exciting new community to the local neighborhood. We look forward to your feedback through an in-person follow up meeting with each department. Please feel free to contact me with any questions or comments at [email protected].

Sincerely,
Julian Nan
Vice President
Encore University Hills LLC
Applicant

ATTACHMENT C
Location/Zoning Map

ATTACHMENT C – LOCATION/ZONING MAP

CITY OF SAN BERNARDINO

PLANNING DIVISION
PROJECT: SP 23-01 and SUB 23-05 (TTM 20595)

LOCATION MAP
HEARING DATE: January 13, 2026

NORTH

PROJECT SITE

ATTACHMENT D
Aerial Map

ATTACHMENT D – AERIAL MAP

CITY OF SAN BERNARDINO

PLANNING DIVISION
PROJECT: SP23-01 and SUB23-05

LOCATION MAP
HEARING DATE: January 13,2026
NORTH

PROJECT SITE

ATTACHMENT E
Draft University Hills Memorandum of Understanding

MEMORANDUM OF UNDERSTANDING
For Access to University Hills Development
Between Encore Capital Management (“Encore”)
and
California State University, San Bernardino (“CSUSB”)

FOR REVIEW PURPOSES ONLY

NOT VALID
This Memorandum of Understanding (“MOU”) establishes mutual understandings and commitments between Encore Capital Management (“Encore”) and California State University, San Bernardino (“CSUSB”) regarding access, construction coordination, and environmental and operational protections associated with the University Hills development adjacent to the CSUSB campus. The intent is to allow limited use of CSUSB property for roadway access while preserving the University’s academic, research, and operational interests.

1. BACKGROUND
x Encore is working in coordination with the City of San Bernardino and the San Bernardino County Flood Control District to amend the University Hills Specific Plan as last approved in 2008. x The proposed access improvements at the intersection of Devil’s Canyon Road and Campus Circle involve a small portion (~7,900 sq. ft.) of CSUSB property. x CSUSB maintains adjacent facilities including the Campus Land Laboratory, Geological Fault Study Area, and Murillo Family Observatory, which require protection from grading, dust, noise, vibration, stormwater alteration & erosion control, vector control, and light pollution. x Both parties wish to cooperate in good faith to facilitate compatible development, emergency safety, and environmental stewardship.

2. ACCESS RIGHTS AND CONDITIONS
Limited Access Grant:

CSUSB agrees to grant Encore non-exclusive access to approximately 7,900 sq. ft. of land at the Devil’s Canyon–Campus Circle intersection for roadway construction, grading, operations and maintenance, and the installation, operations and maintenance of utilities consistent with approved project plans, conditioned upon approval of the University Hills Specific Plan amendment and all other project entitlements and agreement upon the form of an easement per Section 8 below.

Access Conditions:

x All work shall be limited to the area shown in Exhibit A and shall avoid interference with CSUSB’s Land Laboratory or facilities yard.
x Encore shall provide written notice to the University at least 30 days prior to commencing any activity on or within 100 feet of CSUSB property.
x Encore shall provide all proposed traffic control and mitigation plans to the University 30 days prior to commencing any temporary road and traffic alterations on or adjacent to CSUSB property x The constructed road shall not be gated or restricted in a way that impedes University access. x The University Hills HOA shall maintain all improvements and indemnify CSUSB against liabilities arising from construction or operation within the easement area.

3. CONSTRUCTION MANAGEMENT AND CAMPUS PROTECTION
Encore shall:
x Coordinate construction schedules and traffic control and mitigation plans with CSUSB Facilities Management and University Police.
x Limit construction activities to 7:00 a.m.–5:00 p.m., Monday through Friday. x Implement dust, noise, and vibration controls to protect nearby research sites and observatory equipment.
x Prohibit construction staging or material storage within 100 feet of the Land Laboratory or fault access areas.
x Restore any disturbed CSUSB property to pre-construction conditions to the satisfaction of the University.

4. FAULT AND LAND LABORATORY ACCESS

x CSUSB shall retain unrestricted access to its Land Laboratory and geological research zones, including the San Andreas fault exposure, for educational and scientific purposes. x Encore shall design grading, retaining walls, and fencing to maintain continuous physical access to these research zones.
x No construction may occur that would obstruct, bury, or destabilize the exposed fault face. x Access routes shall remain open for educational use at all times during and after construction.

5. LIGHTING AND OBSERVATORY PROTECTION

x All outdoor lighting shall comply with International Dark-Sky Association (IDA) standards:
o Fully shielded, downward-directed fixtures
o Correlated color temperature ≤ 3000K
o No uplighting or exposed bulbs
x Encore shall submit a photometric plan to CSUSB Facilities Management for review before installation. x Any lighting found to violate dark-sky requirements shall be corrected within 60 days of written notice from CSUSB.

6. ENVIRONMENTAL, SAFETY, AND EMERGENCY RESPONSE COORDINATION

x Encore shall provide CSUSB with all hydrology, stormwater, and traffic control and mitigation plans affecting the campus or adjacent flood control facilities prior to final approval. x Roadway design speeds adjacent to CSUSB shall not exceed 40 mph. x Emergency Response: Encore shall coordinate with the City of San Bernardino Fire Department, Police Department, and CSUSB University Police to ensure the development does not negatively impact emergency response times to the CSUSB campus or surrounding areas. o An Emergency Services Access Plan shall be submitted for joint review by the City and CSUSB prior to final roadway approval.
o Encore shall implement mitigation measures recommended by those agencies to maintain or improve current response times.
o If monitoring after construction shows degradation of response times, Encore or the HOA shall cooperate with the City and CSUSB to fund or implement corrective improvements.

7. ENVIRONMENTAL AND BIOLOGICAL PROTECTION

Encore shall implement measures to protect biological, geological, and ecological resources near CSUSB property, including:
x Preservation of native vegetation and wildlife corridors adjacent to the Land Lab; x Protection of existing drainage flows and prevention of erosion or sedimentation onto CSUSB lands; and
x Compliance with all CEQA mitigation measures applicable to University Hills.

8. UTILITIES, EASEMENTS, AND DOCUMENTATION

x Encore shall not use or amend any existing CSUSB easements without express written approval in its sole discretion.
x Public utilities (including the University Hills sewer main) shall not cross CSUSB property unless separately negotiated.
x Separate Recorded Easement: The parties shall prepare, execute, and record a separate easement agreement based on CSUSB’s standard easement template to formally document:
o The exact boundaries of the access area (approx. 7,900 sq. ft.); o Construction and maintenance responsibilities;
o Provisions for fault access, lighting compliance, and emergency coordination; and o Applicable indemnities and insurance.
x The easement shall be recorded with the County of San Bernardino prior to commencement of construction affecting CSUSB land.

9. AGENCY REVIEW AND APPROVAL

Encore shall submit final roadway, lighting, and drainage designs to CSUSB for review and written concurrence before approval by the City of San Bernardino or San Bernardino County Flood Control District. No agency submittals or construction permits involving CSUSB property shall proceed without such written concurrence.

Encore shall obtain a construction permit from CSUSB for all improvements on CSUSB property.’

10. INSURANCE AND INDEMNIFICATION

Encore shall maintain:
x Commercial General Liability Insurance with minimum limits of $2,000,000 per occurrence and $5,000,000 aggregate, naming The Trustees of the California State University as additional insured; x Automobile and Contractor’s Liability Insurance with limits not less than $1,000,000; and x Workers’ Compensation Insurance as required by law.

Encore and the University Hills HOA shall defend, indemnify, and hold harmless CSUSB and the State of California from any claims arising from the activities contemplated under this MOU.

11. TERM AND TERMINATION

This MOU shall remain in effect for three (3) years from the Effective Date unless:
x Superseded by a definitive agreement or recorded easement; or x Terminated by the University if there has not been reasonable progress toward approval within 1 year; or x Terminated earlier by mutual written consent of both parties.

12. DISPUTE RESOLUTION
Any disputes regarding the interpretation or implementation of this MOU shall first be resolved through good-faith negotiation between designated representatives. If unresolved, the matter may be submitted to non-binding mediation before either party seeks other remedies.

13. NON-BINDING NATURE
This MOU represents the mutual intent of the parties and shall not create any legally binding obligations except as expressly provided in Section 8 regarding execution of a separate easement agreement.

14. EXHIBITS
x Exhibit A: Vicinity and Access Map (~7,900 sq. ft. parcel) x Exhibit B: Preliminary Road Alignment and Retaining Wall Concept x Exhibit C: Emergency Services Circulation Plan

10. Signatures

___________________________________
Encore University Hills, LLC
David Hardy, Vice President
Encore Capital Management
770 Tamalpais Drive, Suite 401B

Corte Madera, CA 94925
Phone: (951) 704-4508 | Email:[email protected]

__________________________________________
California State University, San Bernardino
Samuel Sudhakar, Vice President & CFO
California State University, San Bernardino
5500 University Parkway
San Bernardino, CA 92407
Phone: (909)537-5995 | Email:[email protected]

ATTACHMENT F
Original Approval of the SP-UH
Resolution 2008-422

ATTACHMENT G
University Hill Final SEIR Addendum Link

https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:5a989e44-6d36-4740-8cdd- 68c1fe5fde28

ATTACHMENT H
University Hills Final SEIR Addendum Appendix’s Link

https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:47e97317-553a-4951-b780- 35d4f7fc18bd

ATTACHMENT I
University Hills-Fire Protection Plan (Draft)

DRAFT
Preliminary Fire Protection Plan
University Hills
JULY 2025
Prepared for:

ENCORE UNIVERSITY HILLS LLC
3333 Michelson Drive, #620
Irvine, California 92612
Contact: David Hardy,
Director of Forward Planning and Entitlements
Prepared by:
3600 Lime Street
Building 2
Riverside, California 92501

Printed on 30% post-consumer recycled material.

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Table of Contents
SECTION PAGE NO.

Acronyms and Abbreviations..................................................................................................... ........................................ v Executive Summary ......................................................................................................................................................... vii 1 Introduction .................................................................................................................. ........................................1

1.1 Intent...................................................................................................................... .................................2

1.2 Applicable Codes and Existing Regulations ................................................................................... .......2

1.3 Project Summary ............................................................................................................. .......................3

1.3.1 Location.................................................................................................................. ...................3

1.3.2 Project Description ....................................................................................................... ............4 2 Project Site Risk Analysis.................................................................................................... .............................. 11

2.1 Field Assessment ............................................................................................................ .................... 11

2.2 Project Site Characteri stics and Fire Environment........................................................................... .1 1

2.2.1 Topography................................................................................................................ ............. 12

2.2.2 Climate ................................................................................................................... ................ 12

2.2.3 Vegetation ................................................................................................................ .............. 13

2.2.4 Fire History .............................................................................................................. ............... 13

2.3 Analysis of Wildfire Risk from Adding New Development ................................................................. 14

2.4 Off-site Wildfire Impacts................................................................................................... ................... 19

2.4.1 Vegetation Management..................................................................................................... .. 20

2.4.2 Firefighter Response ...................................................................................................... ....... 21

2.4.3 Ignition Resistant and No ncombustible Construction......................................................... 21

2.4.4 Shelter in Place Capability............................................................................................... ...... 22

2.4.5 Wildfire Risk Awareness Education ...................................................................................... 24 3 Anticipated Fire Behavior ..................................................................................................... ............................ 27

3.1 Fire Behavior Modeling ...................................................................................................... ................. 27

3.2 Fire Behavior Modeling Analysis............................................................................................. ............ 27

3.3 Fire Behavior Modeling Results.............................................................................................. ............ 29

3.3.1 Existing Conditions....................................................................................................... .......... 30

3.3.2 Post-Development Conditions............................................................................................... 30

3.4 Project Area Fire Risk Assessment........................................................................................... .......... 32 4 Emergency Response and Service................................................................................................ ................... 35

4.1 Emergency Response Fire Facilities.......................................................................................... ......... 35

4.1.1 Emergency Response Travel Time Coverage ....................................................................... 36

4.2 Estimated Calls and Demand for Service from the Project .............................................................. 38

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5 Fire Safety Requirements-Infrastructure, Building Ignition Resistance, and Defensible Space.................. 43

5.1 Fire Apparatus Access....................................................................................................... .................. 43

5.1.1 Roads..................................................................................................................... ................. 44

5.1.2 Gates ..................................................................................................................... ................. 46

5.1.3 Premises Id entification................................................................................................... ....... 47

5.1.4 Ongoing Infrastru cture Maintenance.................................................................................... 48

5.1.5 Pre-Construction Requirements............................................................................................ 4 8

5.2 Infrastructure and Fire Protection Systems.................................................................................. ..... 48

5.2.1 Water Supply.............................................................................................................. ............ 48

5.2.2 Hydrants .................................................................................................................. ............... 48

5.2.3 Automatic Fire Sprinkler Systems......................................................................................... 4 8

5.3 Ignition Resistant Construction and Fire Protection Systems .......................................................... 49

5.4 Defensible Space and Ve getation Management............................................................................... 50

5.4.1 San Bernardino County Fuel Modification Zone Standards and Defensible Space .......... 51

5.4.2 San Bernardino County Fuel Modification Zones ................................................................ 51

5.4.3 Ongoing Infrastructure and FMZ Maintenance.................................................................... 54

5.4.4 Construction Phase Ve getation Management ..................................................................... 54

5.5 Pre-Construction Defensib le Space Requirements........................................................................... 55 6 Wildfire Education Program.................................................................................................... .......................... 67

6.1 Recognition for Fire Safety and Maintaining Fire Insurance ............................................................ 67 7 Conclusion .................................................................................................................... ..................................... 69 8 List of Preparers............................................................................................................. ................................... 73 9 References .................................................................................................................... .................................... 75 TABLES
1 Fuel Models Used for Fire Behavior Modeling ................................................................................... ............. 28 2A Fuel Moisture and Wind Inputs ................................................................................................ ........................ 28 2B Fuel Moisture and Wind Inputs ................................................................................................ ........................ 28 3 Modeling Results for Existing Conditions ........................................................................................................ 30 4 Modeling Results for Post-Project Conditions .................................................................................. ............... 31 5 Fire Suppression Interpretation ............................................................................................... ........................ 32 6 Closest Responding SBCFPD Fire Station Summary ................................................................................ ...... 36 7 Project Emergency Response Analys is using Speed Limit Formula .............................................................. 37 8 Project Emergency Response Analysis using ISO Formula............................................................................. 37 9 Calculated Call Volume (Conceptual Based on 1,050 residents) for Project Site ........................................ 39

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EXHIBITS
1 Example of “higher density” development. ...................................................................................... ............... 16 2 Example of “moderate de nsity” development................................................................................................. 17 3 Example of “lower dens ity” development........................................................................................................ 18

FIGURES
1 Fire Hazard Severity Zone..................................................................................................... ...............................5 2 Project Location .............................................................................................................. .....................................7 3 Proposed Site Plan............................................................................................................ ...................................9 4 BehavePlus Analysis Map....................................................................................................... .......................... 33 5 SBCFPD Fire Stations Map ...................................................................................................... ......................... 41 6 View 1 Fuel Modificati on Plan — Parcel 1....................................................................................... ................. 57 6 View 2 Fuel Modificati on Plan — Parcel 1....................................................................................... ................. 59 6 View 3 Fuel Modificati on Plan — Parcel 1....................................................................................... ................. 61 6 View 4 Fuel Modificati on Plan — Parcel 1....................................................................................... ................. 63 6 View 5 Fuel Modificati on Plan — Parcel 1....................................................................................... ................. 65

APPENDICES
A Representative Photo Log
B Fire History Map
C BehavePlus Fire Behavior Modeling Summary
D Ignition-Resistant Construction Requirements
E Prohibited Plant List

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INTENTIONALLY LEFT BLANK
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Acronyms and Abbreviations
AAcronym aandd AAbbreviationn DDefinition
AMR American Medical Response
AMSL above mean sea level
APN Assessor’s Parcel Number
BOA Bill of Assurance
BTU British Thermal Unit
CAL FIRE California Department of Forestry and Fire Protection CBC California Building Code
CDI California Department of Insurance
CC&R Covenants, Conditions and Restrictions
CFC California Fire Code
CRC California Residential Code
SBCMWD San Bernardino County Municipal Water District
FAHJ Fire Authority Having Jurisdiction
FHSZ Fire Hazard Severity Zone
FMZ Fuel Modification Zone
FPP Fire Protection Plan
FRA Federal Responsibility Area
FRAP Fire and Resource Assessment Program
FS Fire Station
HOA Homeowners Association (HOA)
IBC International Building Code
ICEMA Inland Counties Emergency Medical Agency
IFC International Fire Code
IRC International Residential Code
I-215 Interstate 215
LRA Local Responsibility Area
MPH miles per hour
NFPA National Fire Protection Association
PRC Public Resources Code
Project University Hills
SBCFPD San Bernardino County Fire Protection District
SRA State Responsibility Area
VHFHSZ Very High Fire Hazard Severity Zone
WUI Wildland Urban Interface

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Executive Summary
This Preliminary Fire Protection Plan (FPP) has been prepared for the University Hills (Project) single-family detached residential units located north of California State University San Bernardino campus on the opposite side of Badger Hill in the County of San Bernardino, California. The Project is proposed construction of three-hundred and twenty- seven (327) single-family detached residential units; to include related on-site improvements that encompasses a span of 338.80 acres total gross area. This FPP provides me asures for fire protection that meet the applicable portions of San Bernardino County Fire Protection District (SBCFPD) standards and further evaluates and identifies the potential fire risk associated with the Project’s land uses and identifies requirements for water supply, fuel modification and defensible space, access, building ignition and fire resistance, and fire protection systems, among other pertinent fire protection criteria. The purpose of th is plan is to generate and memorialize the fire safety requirements and standards of the SBCFPD along with proj ect-specific measures based on the site, its intended use, and its fire environment.

This document provides analysis of the site’s fire environment and its potential impact on the Project as well as the Project’s potential impact on the existing fire protection service. Tasks completed in preparation of this FPP include data review, code review, site fire risk analysis, land use plan review, fire behavior modeling, and site-specific recommendations. Requirements and recommendations herein are based on site-specific fire environment analysis and Project characteristics and incorporates area fire planning documents, site risk analysis, and standard principles of fire protection planning.

As determined during the analysis of this site and its fi re environment, the Project, in its current condition, may include characteristics that, under favorable weather condit ions, could have the potential to facilitate fire spread.

Under extreme conditions, wind-driven wildfires from the no rth and/or east could cast embers onto the property.

Once the Project site is developed, the on-site fire potent ial will be much lower than its current condition due to conversion of wildland fuels to building footprints, park ing areas, managed landscapes, fuel modification areas, improved accessibility for fire personnel, and structures built to the latest ignition and ember resistant fire codes.

It is important to note that the fire safety requirements that will be implemented on this site, including ignition resistant construction standards, along with requirements for water supply, fire apparatus access, fuel modification and defensible space, the installation of National Fire Protection Association (NFPA) 13D automatic interior fire sprinkler systems within each of the residential buildings, an d fire response travel times were integrated into the code requirements and internal guidelines based on result s of post-fire assessments, similar to the After Action Reports that are now prepared after large fire events. When it became clear that specifics of how structures were built, how fire and embers contributed to ignition of s tructures, what effects fuel mo dification had on structure ignition, how fast firefighters could respond, and how much (and how reliable) water was available, were critically important to structure survivability, the Fire and Building codes were revised appropriately. San Bernardino County now boasts some of the most restrictive codes for building within Wildland Urban Interface (WUI) areas that focus on preventing structure ignition from heat, flame, and burning embers.

The proposed Project of three-hundred twenty-seven (327) single-family detached residential units encompass a span of 338.80 acres total gross area. The Project represents an amendment to the previously approved University Hills Specific Plan, incorporating 36.46 acres for resident ial uses, 20.64 acres for streets, alongside 46.86 acres dedicated to open space and parks. Additionally, 234.84 acres are deemed as a designated remainder. This area has been identified as a Hazardous Fire Area in the City of San Bernardino. The entire site has been designed with

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fire protection as a key objective. The site improvemen ts are designed to facilitate emergency apparatus and personnel access throughout the site. Driveway and road improvements with fire engine turnouts and turnarounds provide access to within 150 feet of the structures. Water availability and flow will be consistent with requirements including fire flow and hydrant distribution required by local and state codes. These features along with the ignition resistance of all structures, NFPA 13D automatic interior fire sprinkler systems, and the pre-planning, training and awareness will assist responding firefighters through prevention, protection, and suppression capabilities.

As detailed in this FPP, the Project’s fire protection systems will include a redundant layering of protection methods that have been proven to reduce overall fire risk. The fi re safety measures included herein, both required and recommended, are performance based and site–specific, co nsidering the Project’s unique characteristics rather than a prescriptive, one-size-fits-all approach. The fire protection systems are designed to increase building safety, as well as the safety of those occupyin g the structure, reduce the fire risk on site, minimize risks associated with typical uses, and aid the responding firefighters during an emergency. No singular measure is intended to be relied upon for the site’s fire protection, but rather, a system of fire protection measures, methods, and features combine to result in enhanced fire safety, reduced fire potential, and improved safety in the development.

Based on the results of this FPP’s analysis and findings, the following FPP implementation measures will be provided as part of the proposed development plan. Based on the analysis conducted herein, the Project meets all fire and building code requirements and includes appropri ate protections for the fire environment in which it is located. These measures are discussed in more detail throughout this FPP.

IImplementationn Measures:

1. The proposed buildings will be constructed of ignition resistant 1 construction materials and each single- family detached residential unit will include the installation of a National Fire Protection Association (NFPA) 13D automatic interior fire sprinkler system based on the latest adopted Building and Fire Codes for occupancy types.

2. Fuel Modification will be provided around the perimeter of Project site, as required by SBCFPD and will be a minimum of 100 feet wide in all directions through on-site Fuel Modification Zones (FMZ) and Defensible Space or a combination of on-site and off-site FMZ equivalent areas.

3. Paved roads are provided throughout the Project site.

4. Landscape plantings will not utilize prohibited plan ts that have been found to be highly flammable; landscape plant material must be drought tolerant and fire-resistant plantings recommended by the SBCFPD for use in Fuel Modification Zones (See Appendix E, Prohibited Plant List).

5. Fire apparatus access roads (i.e., pu blic, and private streets) will be provided throughout the residential development and will vary in width and configuration but will all provide at least the minimum required unobstructed travel lanes, lengths, turnouts, turnarounds, width, and clearances required by applicable codes. Primary access and internal circulation will comply with the requirements of the SBCFPD.

6. Each of the single-family detached residential units wi ll be equipped with automatic residential interior fire sprinkler systems respectively meeting NFPA 13D and SBCFPD requirements for the occupancy type.

7. Water capacity and delivery will be provided by a reliable water source for operations and during emergencies requiring extended fire flow.
1 A type of building material that resists ignition or sustained flaming combustion sufficiently to reduce losses from wildland-urban interface conflagrations under worst-case weather and fuel conditions with wildfire exposure of burning embers and small flames, as prescribed in CBC, Chapter 7A and State Fire Marshal Standard 12-7A-5, Ignition-Resistant Materials.

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8. FMZ Inspections. The University Hills Homeowners A ssociation (HOA) will hire a 3rd party, SBCFPD- approved, FMZ inspector and landscape plan reviewer to provide annual certification (written report submitted to SBCFPD by May 1) that the HOA ma intained property including all FMZs and met the requirements of this FPP.

9. Should future iterations of the Project’s site plan re sult in buildings that do not achieve a minimum of 100 feet of defensible space, then alternative materials and methods may be proposed to provide the functional equivalency of a full 100 feet of defensible space. Alternative materials and methods will be to the satisfaction of the SBCFPD and may include structur al hardening enhancements or landscape features, like non-combustible walls.

The following measures shall be established in the Covenants, Conditions and Restrictions (CC&Rs) for the Project and implemented by the Project’s Bill of Assurance (BOA) or Property Manager. Annual maintenance should occur before May 1st of each year and be inspected by SBCFPD or an approved third party.

1. On-going maintenance of all fuel modification zone s would occur at least annually or as needed by the Project’s Property Manager and/or BOA, or another approved entity.

2. The property owner and/or property management comp any will provide informational brochures at time of occupancy, which will include an outreach and educational role to ensure fire safety measures detailed in this FPP have been implemented and development-wide “Ready, Set, Go!”2 plans prepared.

Early evacuation for any type of wildfi re emergency within the development is the preferred method of providing business safety, consistent with the SB CFPD’s current approach for evacuation. As such, the Project will formally adopt, practice, and implement a “Ready, Set, Go!” approach to Project site evacuation. The “Ready, Set, Go!” concept is widely known and encouraged by th e state of California and most fire agencies, including; Pre-planning for emergencies, including wildfire emergencies, focuses on being prepared, having a well -defined plan, minimizing potential for errors, maintaining the Project site’s fire protection systems, and implementing a conservative (evacuate as early as possible) approach to evacuation and Project site uses during periods of fire weather extremes.

This FPP provides a detailed analysis of the Project, the potential risk from wildfire, and potential impacts on the SBCFPD, as well as analysis on meeting or exceeding the requirements of San Bernardino County. Further, this FPP provides requirements, recommendations, and measures to reduce the risk and potential impacts to acceptable levels, as determined by the SBCFPD.
2 https://sbcfire.org/readysetgofire/

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1 Introduction
This Preliminary Fire Protection Plan (FPP) has been prepared for the proposed Uni versity Hills single-family detached residential unit development (Project) in the County of San Bernardino (County), California. The purpose of this FPP is to evaluate the potential impacts resulting from wildland fire hazards associated with the Project’s land uses and identify and verify the proposed implementation measures adequately mitigate those risks to a level consistent with the County thresholds. Additionally, this plan established and memorializes the fire safety requirements and standards of the Fire Authority Having Jurisdiction (FAHJ), which is the San Bernardino County Fire Protection District (SBCFPD). Requirements, stan dards, and recommendations are based on Project-specific design features and incorporate input from the Project appl icant, planners, engineers, and architects, as well as the SBCFPD.

As part of the assessment, the FPP has considered the fire risks presented by the Project site including the property location, the site’s topography, geology, surrounding combus tible vegetation (fuel types), climatic conditions, fire history, and proposed land uses for the Project site an d the surrounding area. The plan addresses water supply, access, structural ignitability and fire resistive building features, fire protection systems and equipment, impacts to existing emergency services, defensible space, and vege tation management for the Project site and to address potential fire impacts to the surrounding area. This FPP also identifies and prioritizes areas for hazardous fuel reduction treatments and recommends the types and method s of treatment that will protect structures and essential infrastructures within the Project site. The FPP also recommends measures that developer and builders and the Property Manager will take to reduce the probability of structural and vegetation ignition.

The Project is located within the boundaries of the SBCFPD and thus the FPP addresses the SBCFPD’s response capabilities and response travel time within the Project area, along with projected funding for facility improvements and fire service maintenance.

The following tasks were performed toward the completion of this plan:
Gather Project site specific climate, terrain, and fuel data; Collect Project site photographs;
Process and analyze the data using the latest geographic information system (GIS) technology; Predict fire behavior using scientifically based fire be havior models, comparisons with actual wildfires in similar terrain and fuels, and experienced judgment;
Analyze and guide design of proposed infrastructure;
Analyze the existing emergency response capabilities; Assess the potential fire risk posed by the construction and operation of the Project to the Project site and surrounding area; and
Prepare this FPP detailing how fire risk will be mitigated on the Project site and in the surrounding areas, Through a system of fuel modification, structural ig nition resistance enhancements, and fire protection delivery system upgrades.

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Field observations were utilized to augment existing digital Project site data in generating the fire behavior models and formulating the recommendations presented in this FPP. Refer to Appendix A, Representative Photo Log for Project site photographs of existing conditions.

1.1 Intent
The intent of this FPP is to provide fire planning guidan ce and requirements for reducing fire risk and demand for fire protection services associated with the Project. To th at end, the fire protection “system” detailed in this FPP includes redundant layering of measures, including pre-planning, fire prevention, fire protection, passive and active suppression, and related measures proven to reduce fire risk. The fire protection system planned for the Project has proven, through real-life wildfire encroachment examples throughout Southern California, to reduce the fire risk associated with this type of residential development.

1.2 Applicable Codes and Existing Regulations
The FPP demonstrates that the Project site would comply with the San Bernardino County Fire Protection District (SBCFPD) Fire Code (Ordinance No. FPD 23-01), San Be rnardino County Development Code, Chapter 82.13 Fire Safety Overlay and California Code of Regulations, Title 24, Part 2, 2022 California Building Code (CBC), including Chapter 7A, which is based on the 2021 International Building Code, Part 2.5, 2022 California Residential Code (CRC), which is based on the 2021 International Residential Code (IRC), and Part 9, 2022 California Fire Code (CFC), including Chapter 49, which is based on 2021 International Fire Code (IFC). Additionally, SBCFPD references Fire Standards for informational purposes in clarifying and interpreting provisions of CFC, National Fire Protection Association (NFPA) and California Public Resources Code (PRC).

Chapter 7A of the CBC addresses structural ignition resi stance and reducing ember penetration into structures, a leading cause of structure loss from wildfires (Califor nia Building Standards Commission, 2023). Thus, code compliance is a critical component of the requirements of the FPP, given the Project’s wildland-urban interface (WUI) location and fire hazard severity zone designation. The entire Project site is located within an area considered to be a Local Responsibility Area (LRA) Very High Fire Hazard Severity Zone (VHFHSZ) as designated by CAL FIRE

3. Areas to west and south of the Projec t site are LRA High Fire Hazard Severi ty Zones (HFHSV) and Moderate Fire Hazard Severity Zones (MFHSVZ) (see Figure 1, Fire Hazard Severity Zone ). It should be noted that CAL FIRE released new LRA FHSZ maps for Southern California on March 24, 2025. Local agencies have 120 days from receiving the maps from CAL FIRE to adopt the new maps orprovide modifications that are additive. The review and possible acceptance of FHSZ designations in State Respon sibility Area (SRA), LRA, and FRA will be in compliance with California Government Code Sections 51175 thr ough 51189. Fire hazard designations are based on topography, vegetation, and weather, among other factors with more hazardous sites, including steep terrain, unmaintained fuels, and vegetation, and WUI locations. Projects situated in high and very high FHSZ areas require fire hazard analysis and the application of fire protecti on measures to create igniti on-resistant structures and defensible communities within these WUI locations. HFHSZ and VHFHSZ designations do not, in and of themselves, indicate that it is unsafe to build in these areas.

As described in this FPP, the University Hills Project site will meet all applicable fire and building code requirements for building in these higher fire hazard areas or meet the intent of the code through the application of Project site- specific fire protection measures. These codes have been developed through decades of post-fire structure saving 3 https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0

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and loss evaluations to determine what causes building loss during wildfires. The resulting fire codes now focus on mitigating former structural vulnerabilities through construction techniques and materials so that the buildings are resistant to ignitions from direct flames, heat, and embers, as indicated in the 2022 CBC (Chapter 7A, Section 701A Scope, Purpose, and Application) (California Building Standards Commission, 2023).

The Proposed Project will also be consistent with the following codes and regulations:
AApplicablee sectionss off thee 20222 Californiaa Buildingg Code,, includingg Ch.. 7AA – Materials and Construction Methods for Exterior Wildfire Exposure: minimum stan dards for a new building located in a WUI area to resist the intrusion of flame or burning embers projected by a vegetation fire. Applicablee sectionss off thee 20222 Californiaa Firee Code,, includingg Chapterr 499 (ass adoptedd andd amended,, addedd too byy SBCFPDD 20222 Firee Code)) – Requirements for Wildland-Urban Interface Fire Areas: minimum standards to increase the ability of a building to re sist the intrusion of flame or burning embers being projected by a vegetation fire.
Californiaa Publicc Resourcess Code,, Div.. 4,, Partt 2,, Ch.. 3,, Sec.. 4290: minimum fire safety standards related to defensible space in Hazardous Fire Areas; Sec.. 4291: Defensible space maintenance on Mountainous, Forest-, Brush- and Grass-Covered Lands.
Californiaa Governmentt Code,, Titlee 5,, Div.. 1,, Partt 1,, Ch.. 6.8,, Sec.. 51175-51189: Very High Fire Hazard Severity Zones. It should be noted the Project site is located within an area considered to be a LRA VHFHSZ as designated by CAL FIRE.
Californiaa Governmentt Code,, Titlee 7,, Div.. 2,, Ch.. 44 Sec.. 66474.02: requirements for tentative map approval in a very high fire hazard severity zone.

1.3 Project Summary

1.3.1 Location
The Project proposes construction of three hundred and twenty-seven (327) single-family detached residential units located north of California State University San Bernardino campus on the opposite side of Badger Hill in the County of San Bernardino, California. Regional access to the Projec t site is provided by Interstate 215 (I-215) from the University Parkway Exit. Local access to the site is prov ided along Badger Canyon Road. The existing site and surrounding areas are shown in Figure 2, Project Location.

The Project site covers a total gross area of 338.80 acr es, including 36.46 acres designated for three-hundred twenty-seven (327) single-family detached residential units, 20.64 acres for streets, and 46.86 acres allocated to open space and parks. An additional 234.84 acres are identified as a designated remainder within Tentative Tract Map No. 20595. The site is identified by Assessor’s Parcel Numbers (APNs) 0265-041-12-0-000, 0265-051-09-0- 000, 0265-021-13-0-00, 0265-011-07-0-000, 0265-01-08-0-000, and 0265-011-06-0-000. The site is bounded on the north by a designated remainder APN: 0265-021-13, on the east APN: 0265-031-25, on the south by open space flood control basin and further APN: 0265-041-15, and on west by open space and further APN: 0265-041- 15 (Figure 2).

A site visit conducted on February 24, 2025, by a Dudek Fire Protection Planner indicated that the site is currently vacant and undeveloped with naturally occurring vegetation which consists of low growing highly combustible plant species. The site is characterized by a large flat valley th at is slightly sloping south. The Project site’s existing conditions are shown in Appendix A, Representative Photo Log.

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1.3.2 Project Description
The University Hills Project (Project) proposes the development of three-hundred twenty seven (327) residential lots on a parcel of approximately 338.80 acres, located wi thin thein the Hazardous Fire Area in the City of San Bernardino (Figure 3, Proposed Site Plan ). The Project represents an amendm ent to the previously approved University Hills Specific Pla n, incorporating 36.46 acres for residentia l and related uses, alongside 46.86 acres dedicated to open space and parks. Additionally, 234.84 acres are deemed as a designated remainder. y{
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Project Site - Parcel 1
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FHSZ in LRA - Recommended 2007-2011
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Date: 3/18/2025 User: lterry Path: Z:\Projects\j1442800\MAPDOC\UniversityHills_Fire.aprx Map: FHSZ Layout: Figure 3 FHSZ - Par1 SOURCE: USGS 2024; CAL FIRE 2024 FIGURE 1
Fire Hazard Severity Zone
Fire Protection Plan - University Hills Project

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Fire Protection Plan - University Hills Project
SOURCE: USA Topo Maps 7.5 Minute Series San Bernardino North Quadrangle T ownship 1N; Range 4W; Section 4-5 and 8-9
Date: 3/18/2025 - Last saved by: lterry - Path: Z:\Projects\j1442800\MAPDOC\DOCUMENT\FPP\Figure 1 Project Location-Par1.mxd Project Site - Parcel 1
FIGURE 2
Adelanto
Apple Valley
Barstow
Big Bear
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Blythe
Bradbury
Brea
California
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Canyon Lake
Coachella
Colton Desert
Hot Springs
Indian
Wells
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Palmdale
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Mirage
Ridgecrest
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Jacinto
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Tu st in
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SOURCE: Kimley Horn 2025
Fire Protection Plan - University Hills Project
Proposed Site Plan
FIGURE 3

SAN BERNARDINO COUNTYFLOOD CONTROL DISTRICTPROPERTY

N CAMPUS PARKWAY

STATE OF CALIFORNIA PROPERTY
EX. UNIVERSITYCAMPUS CIRCLE

SAN BERNARDINO COUNTY

FLOOD CONTROL DISTRICT

PROPERTY

STATE OF CALIFORNIA PROPERTY
TOTAL LOT COUNT = 327

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2 Project Site Risk Analysis

2.1 Field Assessment
After reviewing available digital study area information, including topography, vegetation types, fire history, and the Project’s development footprint, a Dudek Fire Protection Planner conducted a field assessment of the University Hills Project area in February 24, 2025, in order to confirm and acquire Project site information, document existing conditions, and to determine potential actions for addressi ng the protection of the Project’s structures. While on the Project site, Dudek’s Fire Protection Planner assessed the area’s topography, natural vegetation, fuel loading, surrounding land use and general susceptibility to wildfire. The completed field tasks include:
Vegetation estimates and mapping refinements.
Fuel load analysis.
Topographic features documentation.
Photograph documentation.
Confirmation and verification of hazard assumptions.
Off-site, adjacent property fuel and topography conditions. The surrounding land use confirmations.
Necessary fire behavior modeling data collection.
Ingress and egress documentation.
Nearby Fire Station reconnaissance.

Study area photographs were collected (refer to Appendix A, Representative Photo Log), and fuel conditions were mapped using aerial images. Field observations were utilized to augment existing Project site data in generating the fire behavior models and formulating the recommendations detailed in this FPP report.

2.2 Project Site Characteristics and Fire Environment
Fire environments are dynamic systems and include ma ny types of environmental factors and Project site characteristics. Fires can occur in any environment where conditions are conducive to ignition and fire movement.

Areas of naturally vegetated open space are typically compri sed of conditions that may be favorable to wildfire spread. The three major components of fire environment are topography, climate, and vegetation (fuels). The state of each of these components and their interactions with each other determines the potential characteristics and behavior of a fire at any given moment. It is important to note that wildland fire may transition to urban fire if structures are receptive to ignition. Structure ignition depends on a variety of factors and can be prevented through a layered system of protective features including fire resistive landscapes directly adjacent to the structure(s), application of known ignition resistive materials and methods, and suitable infrastructure for firefighting purposes.

Understanding the existing wildland vegetation and urban fuel conditions on and adjacent to the Project site is necessary to understand the potential for fire within and around the Project site.

The following sections discuss the Project site characteristics, local climate, and fire history within and surrounding the Project site. The University Hills Project is similar co ncerning topography, vegetative cover, and proximity to

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adjacent residential areas, available access, and planne d use. The following sections discuss the characteristics of the Project site at a regional scale. The intent of eval uating conditions at this macro-scale is providing a better understanding of the regional fire environment, which is not constrained by property boundary delineations.

2.2.1 Topography
Topography influences fire risk by affecting fire spread rates. Typically, steep terrain results in faster fire spread up- slope and slower fire spread down-slope in the absence of wind. Terrain that forms a funneling effect, such as chimneys, chutes, or saddles on the landscape can result in especially intense fire behavior. Conversely, flat terrain similar to this Project site, tends to have an insignifican t effect on fire spread, resultin g in fires that are driven by vegetation and wind.

The overall Project site is relatively flat as it sits in larg e flat valley that is slightly sloping south, away from the San Bernardino Mountains towards the base of Badger Hill. Elevations at the Project site range from approximately 1,613 feet above mean sea level (AMSL) at the southern boundary to 1,865 feet AMSL at the northern limits of the site. Adjacent open space slightly slopes down along the western and southern borders of the project site.

2.2.2 Climate
Throughout Southern California and particularly at the Project site, climate plays a significant role in influencing fire risk. The region experiences a typical Mediterranean clim ate, characterized by warm, dry summers and cool, wet winters. Average high temperatures range from approx imately 43°F in December to around 96°F in August.

Precipitation has been averaging be tween 0.04 inches to 2.3 inches and typically occurs between November to April. The average hourly wind speed ranges between 5. 3 mph and 7.1 mph. The prevailing wind direction is an onshore flow from the west.4
From a regional perspective, the fire risk in southern California can be divided into three distinct “seasons” (Nichols et al. 2011, Baltar et al 2014). The first season, the most active season and covering the summer months, extends from late May to late September. This is followed by an intense fall season characterized by fewer but larger fires.

This season begins in late September and continues un til early November. The remaining months, November to late May cover the mostly dormant, winter season. Mensing et al. (1999) and Keeley and Zedler (2009) found that large fires in the region consistently occur at the end of wet periods and the beginning of droughts. Fires can be a significant issue during summer and fall, before the ra iny period, especially during dry Santa Ana wind events.

Although Santa Ana events can occur anytime of the year, they generally occur during the autumn months, although the last few years have resulted in spring (April - May) and summer events. Santa Ana winds may gust up to 75 miles per hour (mph) or higher. This phenomenon markedly increases the wildfire danger and intensity in the Project area by drying out and preheating vegetation (fuel moisture of less than 5% for 1-hour fuels is possible) as well as accelerating oxygen supply, and thereby, making possible the burning of fuels that otherwise might not burn under cooler, moist conditions.

The prevailing wind pattern is from the west (onshore), but the presence of the Pacific Ocean causes a diurnal wind pattern known as the land and sea breeze system. During the day, winds are from the west–southwest (sea), and at night winds are from the northeast (land). The highest wind velocities are associated with downslope, canyon, and Santa Ana winds.
4 https://weatherspark.com/y/1969/Average-Weather-in-San-Bernardino-California-United-States-Year-Round

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2.2.3 Vegetation

2.2.3.1 Fuels (Vegetation)
The proposed Project site and surrounding areas primar ily support low- to- moderate-load sage scrub plant communities intermixed with non-native grasslands, and disturbed habitat. Vegetation types were derived from an on-site field assessment of the Project site. The majority of the areas adjacent to the Project site are vegetated with sage scrub interspersed with grasses, riparian, and sp arse deciduous trees. The vegetation cover types were assigned corresponding fuel models for use during Projec t site fire behavior modeling. Section 3.0 describes the fire modeling conducted for the Project Area.

2.2.3.2 Vegetation Dynamics
The vegetation characteristics describe d above are used to model fire behavi or, discussed in Section 3.0 of this FPP. Variations in vegetative cover type and species composition have a direct effect on fire behavior. Some plant communities and their associated plant species have in creased flammability based on plant physiology (resin content), biological function (flowering, retention of dead plant material), physical structure (bark thickness, leaf size, branching patterns), and overall fuel loading. For example, non-native grass dominated plant communities become seasonally prone to ignition and produce lower inte nsity, higher spread rate fires. In comparison, sage scrub can produce higher heat intensit y and higher flame lengths under stro ng, dry wind patterns, but does not typically ignite or spread as quickly as light, flashy grass fuels.

As described, vegetation plays a significant role in fire behavior and is a critical component to the fire behavior models discussed in this report. A critical factor to consider is the dynamic nature of vegetation communities. Fire presence and absence at varying cycles or regimes disr upts plant succession, setting plant communities to an earlier state where less fuel is present for a period of time as the plant community begins its succession again.

Simply stated, high frequency fires tend to convert shrubl ands to grasslands or maintain grasslands, while fire exclusion tends to convert grasslands to shrublands, over time. In general, biomass and associated fuel loading will increase over time, assuming that disturbance (fire, or grading) or fuel reduction efforts are not diligently implemented. It is possible to alter successional pathways for varying plant communities through manual alteration.

This concept is a key component in the overall establishme nt and maintenance of the proposed fuel modification zones on-site. The fuel modification zones on the Project site will consist of irrigated and maintained landscapes as well as thinned native fuel zones that will be subject to regular “disturbance” in the form of maintenance and will not be allowed to accumulate excessive biomass (live or dead) over time, which results in reduced fire ignition, spread rates, and intensity. Conditions adjacent to the Project’s footprint (outside the fuel modification zones), where the wildfire threat will exist post-development, are classified as lo w to medium fuel loads due to the dominance of sage scrub-grass fuels.

2.2.4 Fire History
Fire history is a critical component of an FPP. Fire history data provides valuable information regarding fire spread, fire frequency, most vulnerable areas, and significant ignition sources, amongst others. In turn, this understanding of why fires occur in an area and how they typically sp read can then be used for pre-planning and designing defensible communities.

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Fire history represented in this FPP uses the Fire and Resource Assessment Program (FRAP) database. FRAP summarizes fire perimeter data dating to the early 1900s but is incomplete due to the fact that it mostly includes fires over 10 acres in size and has incomplete perimeter data, especially before the mid-20th century (Syphard and Keeley 2016). However, the data does provide a summary of recorded fires and can be used to show whether large fires have occurred in the Project area, which indicates whether they may be possible in the future.

According to available data from the CAL FIRE in the FRA P database, there have been 135 fires that have burned within 5 miles of the site since the beginning of the histor ical fire data record, the majority of which have burned within the San Bernadino Mountains, northeast and northwestof the Project site. Recorded wildfires within 5 miles range from approximately .38 acres to approximately 91,428 acres (2003 Old Fire). The 2003 Old Fire merged with the 2003 Grand Prix Fire crossing into Los Angeles County (2003 Padua Fire), one of the fourteen fires creating the 2003 Fire Siege. The 2003 Fire Siege combined a total of fourteen wildfires scorching over 750,000 acres in seven southern California counties5. Prior to that, the 1980 Panorama Fire (approximately 23,626 acres) destroyed three- hundred and twenty-five (325) buildings and four (4) fatalities, had been the area’s most devasting fire. The 2020 El Dorado Fire (approximately 22,774 acres) is the most significant recent fire, resulting in ten (10) destroyed structures, six (6) damaged structures and one firefighter death. There have been only two (2) fires on record that have burned on the Project site, the 1967 County Roads #15 Fire (approximately 453 acres) and the 1979 Sierra Series (approximately 1,838 acres)6. SBCFPD may have data regarding smaller fires (other fires less than 10 acres) that have occurred on-site that have not been included herein. Fire history for the general vicinity of the Project site is illustrated in Appendix B, Fire History Map.

Based on an analysis of the fire history data set, specifically, the years in which the fires burned, the average interval between wildfires within 5 miles of the site was calculated to be approximately every one to two years with intervals ranging between 0 (multiple fires in the same year) to 11 years. It should be noted that the longer end of this interval is from the first half of the 20 th century, where the database is incomplete. Based on the analysis, it is expected that there will be wildland fires within 5 miles of the site at least every 11 years and on average, every one or two years, as observed in the fire history record. Based on fire history, wildfire ri sk for the site is associated primarily with a Santa Ana wind driven wildfire burning or spotting on-site from the north.

2.3 Analysis of Wildfire Risk from Adding
New Development
Humans (i.e., human related activities or human created features, services (i.e., powerlines and electrical equipment), or processes) are responsible for the majori ty of California wildfires (Syphard et al. 2007, 2008; Romero-Calcerrada et al. 2008). Certain human activities result in sparks, flames, or heat that may ignite vegetative fuels without proper prevention measures in place. These ignitions predominantly occur as accidents, but may also be purposeful, such as in the case of arson. Equipmen t and powerlines cause a substantial number of fires in San Bernardino County. After that, roadways are a particularl y high source for wildfire ignitions due to high usage and vehicle-caused fires (catalytic co nverter failure, overheated brakes, dr agging chains, tossed cigarettes, and others) (Romero-Calcerrada et al. 2008)) . In Southern California, the population living at, working in, or traveling through the wildland urban interface is vast and provides a significant opportunity for ignitions every day. However, it is a relatively rare event when a wildfire occurs, an d an even rarer event when a wildfire escapes initial containment efforts. Approximately 90 to 95% of wildfires are controlled below 10 acres (CAL FIRE 2019). 5 https://permanent.fdlp.gov/lps47731/2003FireStoryInternet.pdf 6 https://calfire-forestry.maps.arcgis.com/apps/mapviewer/index.html?layers=e3802d2abf8741a187e73a9db49d68fe

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Research indicates that contained development projects like the University Hills Project, are not associated with increased vegetation ignitions. Syphard and Keeley (2015) summarize all wildfire ignitions included in the CALFIRE Fire and Resource Assessment Program (FRAP) database dating back over 100 years. They found that equipment- caused fires were by far the most numerous – and thes e also accounted for most of the area burned – followed closely by the area burned by powerline fires. Ignitions classified as equipment caused frequently resulted from exhaust or sparks from power saws or other equipment with gas or electrical motors, such as lawn mowers, trimmers or tractors and associated with lower density ho using. In San Diego County, and in areas like the open space areas near the Project site in San Bernardino County , ignitions were more likely to occur close to roads and structures, and at intermediate density land uses and structure densities.

As Exhibits 1 through 3 illustrate, new project density directly influences susceptibility to fire because in high density projects like the University Hills Project, there is one inte rface (the Project perimeter) with the wildlands whereas lower density development creates more structural expo sure to wildlands, less or no ongoing landscape maintenance (an intermix rather than interface), and co nsequently more difficulty for limited fire resources to protect well-spaced buildings. The intermix includes development amongst the unmaintained fuels whereas the proposed Project converts all fuels within the footprin t and provides a wide, managed fuel modification zone separating buildings from unmaintained fuel and creating a condition that makes defense easier. The majority of the Project site will be non-combustible paved surfaces, which will function as a fuel break because it will not allow ignition or fire spread. Syphard and Keeley go on to state that “The WUI, where housing density is low to intermediate is an apparent influence in most ignition maps,” furthe r enforcing the conclusion that lower density development poses a higher ignition risk than higher density developm ent. They also state that “Development of low-density, exurban housing may also lead to more homes being destroyed by fire” (Syphard et al. 2013). As discussed in detail throughout this FPP, the University Hills Project site is a planned ignition resistant residential development designed to include professionally managed and maintained fire pr otection components, and modern fire code compliant safety features that will greatly redu ce the hazard of fire spreading from th e wildlands to the Project or from the Project to the adjacent wildlands. The conversion of the la nd within the current Project footprint to the proposed condition will reduce the amount of structures and their associated ignition potential from the dangerous state of low-density development described by Syphard and Keeley to ignition-resistant stru ctures and Project perimeter.

Therefore, the development of the Project would not be ex pected to materially increase the risk of vegetation ignitions and would rather be expected to have reduced ignition potential.

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EExhibit 11.. Example of “higher density” development. Homes are ignition resistant and excludes readily ignitable vegetative fuels throughout and provides a perimeter fuel modification zone. This type of new development requires fewer fire resources to defend and can minimize the likelihood of on-site fires spreading off-site.

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EExhibit 22.. Example of “moderate density” development. Homes are located on larger properties and include varying levels of ignition resistance and landscape and fuel modification provision and maintenance. This type of development results in a higher wildland exposure level for all homes and does not provide the same buffers from wildfire encroaching onto the site or starting at a structure and moving into the wildlands as a higher density project.

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EExhibit 33.. Example of “lower density” development. Homes are interspersed amongst wildland fuels, are of varying ages, and include varying levels of fuel modification zone setbacks. Homes are exposed to most or all sides by flammable vegetation and properties rely solely on owners for maintenance, are often far distances from the nearest fire station, and have minimal buffer from on-site fire spreading to wildlands.

Moreover, frequent fires and lower density housing growth may lead to the expansion of highly flammable exotic grasses that can further increa se the probability of ignitions (Syphard et al. 2012). This is not the case with the Proposed Project as the landscapes are managed and ma intained to remove exotic fuels that may establish over time.

As discussed above, research indicates that it is less likely for higher density developments to be impacted by wildfires than lower density developments. The same protec tions that starve wildfire of fuels and minimize or prevent wildfire from transitioning into a contained, fuel-converted Project, such as the University Hills Project, also serve to minimize or prevent on-site fires from transitioning into the wildlands. Customized project FMZs are crucial as the strategic design and placement of fuels treatments can disrupt or slow fire spread, reduce fire intensity, and facilitate fire suppression within a la ndscape (Braziunas et al., 2021). This is true regardless of the direction a vegetation fire may be burning – whether toward a deve lopment or from within a development. The risk of a structure being destroyed is significantly lower when defe nsible space is implemented on both shallow and steep properties (Syphard et al., 2014). Even if just half the landscape is treated, the percentage of houses exposed to fire can decrease from 51% to 16% (Braziunas et al., 2021). Moreover, when FMZs are designed properly, they not only protect structures but also the surrounding environment. For example, when the Tahoe Basin experienced the Angora Fire in 2007, fuel treatments had the dual effect of saving homes and increasing forest survival (Safford et al., 2009). In areas where fuel management had been conducted prior to the Angora Fire, home loss was significantly reduced in the adjacent community and 85% of the trees survived, as compared to the 22% that

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survived in untreated areas (Safford et al., 2009).Fuel ma nagement treatments also facilitated the ecological benefit of reduced fire severity, including higher post-fir e soil litter cover, higher herbaceous plant cover, higher diversity, and lower levels of invasive beetles (Safford et al., 2009). At a minimum, managing defensible space can reduce risk across multiple scales by damping fire risk, reducing the impact of fire, and in turn reducing annual fire risk (Braziunas et al., 2021). The University Hills Project can be compared to these high density developments as it shares similar characteristics. The majority of the Project site will be composed of non-combustible paved surfaces to reduce ignitions and fire spread. These measures will reduce the Project’s overall susceptibility to fire, compared to low density developments.

Further, the requirement that all structures will include the installation of an automatic interior fire sprinkler system significantly reduces the likelihood that a building fire spreads to the point of flashover, where a structure will burn beyond control and produce embers. Interior sprinklers are ve ry efficient, keeping fires to the room of origin, or extinguishing the fire before the responding firefighters ar rive. Similarly, the irrigated fuel modification zones are positioned throughout the Project. Irrigated zones include plants with high internal moisture and spacing between plants and plant groups that 1) make it difficult to ignite and 2) make it difficult for fire to spread plant to plant.

Further, much of the Project area will be converted to non-combustible paved surfaces where no fires can ignite or spread. Lastly, the additional humans on the site result in fast detection of fires and fast firefighter response, a key in limiting the growth of fires beyond the incipient stage.

2.4 Off-site Wildfire Impacts
It is a relatively rare event when a wildfire occurs, an d an even rarer event when a wildfire escapes initial containment efforts. Approximately 90 to 95% of wildfires are controlled below 10 acres (CAL FIRE 2019). Studies (Keeley & Syphard 2018; Syphard et al. 2007; Syphard & Keeley 2015) show the ignition resistance and fire safety awareness of the Project and its population influences the li kelihood of fire ignitions and the potential for fire to spread off-site into adjacent wildland fuels and negative impact existing communities. As the research indicates, humans can drive wildfire ignition risk, but not discusse d, they can also reduce it. When fire protection is implemented at the parcel level and leverages ignition re sistant building materials, infrastructure improvements, and landscape design, the wildfire risk can be signific antly reduced in the surrounding environment (Newman et al., 2013). When wildfire is planned for and incorporated in to the building design, such as with the Project, it can not only withstand wildfire but prevent it. This prevention benefits the Project and the surrounding areas by reducing the landscape level fire risk. Further, given the Project’s mu lti-scale approach to fire protection, it is unlikely that the Project would be a significant source of ignitions and re sult in increased off-site impacts related to wildfire, as discussed herein.

Common ignition sources in Southern California are related to powerlines and vehicles (Keeley & Syphard, 2018).

Powerlines-based ignitions are a concern with respect to off-site wildfire impacts. The highest likelihood of vegetation ignitions in the Project area would be related to existing roadways such as the new Badger Canyon Road and existing North Campus Parkway. However, the Project provides roadside fuel modification through a fire break along Badger Canyon Road and North Campus Parkway. On going maintenance of these irrigated landscapes will continue in perpetuity as part of the Project. These efforts reduce or minimize the ability for a vehicle related spark, catalytic converter failure, or other ignition source to ignite and spread fire from the roadsides towards the Project.

The Project is not expected to significantly increase the already known fire risk associ ated with roads and in fact the Project- and road-adjacent fuel modification would aid in reducing the preexisting risk. Interior roadways in the parking lot are also not expected to result in significan t vehicle ignitions. The on-site roadways would comply with all fire department access requirements and be encompassed by the ignition-resistant construction of the building,

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non-combustible paved surfaces, and irrigated landscaping. Therefore, even if ignition were to occur on the Project interior roadways it is highly unlikely, and less likely than current conditions that it would spread beyond the Project site due to the level of hardscape and the adjacent fuel modifications areas.

Reducing WUI exposure can address the protection of a wide range of highly valued resources and can offer protection to critical resources, habitat communities, and landscapes (Scott et al., 2016). Despite the potential for more frequent fire ignitions from developments, when developments are planned accordingly, such as the Project, the fuel availability and fuel continuity decrease, while th e probability of fire suppression increases (Fox et al., 2018). This is a result of planned alterations to fue l, increased ignition resistant construction, enhanced fire protection features, higher wildfire risk awareness, and maintenance of fire protection features. The dual benefit of building a fire-hardened project, like the University Hills Project, is that the same features that protect the development from wildfire also play a significant role in protecting wildlands and surrounding areas from Project- related fires.

2.4.1 Vegetation Management
A study in Southern Italy found that the ignition potential of an area was significantly influenced by landcover types and human drivers were low or inconsistent (Elia et al., 2019). Urban interfaces with shrubland-dominated vegetation were found to be more fire-prone than those with grasslands or other natural spaces (Elia et al., 2019).

The Project area is a mixture of non-native grasslands, sa ge scrub, and disturbed habitats. All the existing fuel on the site and within FMZ areas will be converted into hardscape or irrigated landscaping. The fuel conditions will be addressed through various vegetation management techniques, such as fuel modification zones (FMZs). The original intent of FMZs, also known as defensible space, was to protect natural resources from fires in developed areas and have since evolved to protect communities and structures. In an FMZ, combustible vegetation would be removed and/or modified and partially or totally replaced with more appropriately sp aced drought-tolerant, fire- resistant plants. The goal is to provide a managed area wh ere fire spread is not facilitated toward the Project or away from the Project into wildland areas. Fuel modification works by redistributing the risk of fire on a landscape and altering the interaction between fire, fuels, and weather (Cochrane et al., 2012). FMZs typically target surface fires but can also reduce the likelihood of canopy fires, lower ember cast, and have a shadow effect on the untreated landscape by lowering the probability of burning and the potential fire size (Cochrane et al., 2012). As a result, the risk of a structure being destroyed, whether from a fire from within the development or outside the development, is significantly lower when defensible space is implemented.

The Project FMZ will serve to create defensible space a round the structures. Defensible space adjacent to structures also functions to limit the spread of fire from the built environment into off-site vegetation because the irrigated and maintained landscapes do not readily facili tate vegetation ignition or fire spread. Implementing defensible space can reduce the likelihood of structural ignition and support landscape-level risk reduction. The FMZ areas function as fuel breaks which are crucial in redu cing fire risk and facilitating effective fire prevention (Wang et al., 2021). The irrigated zone acts as a green barrier that uses sp ecific vegetation growth, such a high-internal moisture, fire-resistive species, to reduce fi re spread (Wang et al., 2021). The high-internal moisture and spacing between plant groups make it more difficult for ignition to occur and fires to spread from plant to plant.

This affects fire behavior by reducing flame lengths, slowing spread rates, and lowering fire intensity. If a fire from a structure or vehicle spreads to the irri gated zone the fire-resistive species in this zone would be less likely to ignite, reducing the likelihood of the fire spreading off-site (Wang et al., 2021). The use of irrigated areas to reduce wildfire impacts can achieve wildfire mitigation and offer wi ldfire protection in fire-prone areas beyond the Project site (Wang et al., 2021). Further, fuel treatments also have an ecological benefit by reducing the potential fire

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severity which can result in high post-fire litter cover, higher herbaceous plant cover, higher biodiversity, and lower levels of invasive pests, benefiting adjacent open space areas (Safford et al., 2009). The benefits of defensible space and FMZs are not solely limited to the built environm ent. Positioning the low plant density, irrigated areas directly adjacent to the ember-resistant Zone 0, and impl ementing defensible space provides a significant buffer between structures and open space areas. These techniques aid in preventing ignitions in the built environment but also across the larger landscape.

However, long-term protection of the development and th e surrounding area is dependent on the maintenance of fuel modification as even fire-safe designs can degrade over time. To alleviate this the Project will conduct regular assessments of the FMZs. During this maintenance, dead and dying material and undesirable plants will be removed. Thinning will also be conducted as necessary to maintain plant spacing and fuel densities. This will keep the FMZs and landscaped areas in a highly fire resistive condition free of accumulated flammable debris and plants.

Fuel treatments and defensible space do more than just protect structures. When they are a component of a place- based fire-hardened design, such as the Project, they can not only serve to protect structures from wildfire but function as a buffer for natural areas and surrounding communities. These features will further reduce the potential for wildfire in open space areas and potential impacts on surrounding communities.

2.4.2 Firefighter Response
As discussed in Section 4 below, the Project is anticipa ted to have an insignificant impact on the workload or response capacity from the closest fire station. Further, the on-site roads would be able to provide sufficient access for fire apparatus in a high-risk area. The Project also provides water supply and fire flow which are critical resources in firefighting. The Project defensible space areas will allow firefighters to safely position themselves at the development edge and begin tactical protection efforts (Warziniack et al., 2019). This allows firefighters to not only readily protect structures and reduce the likelihood of bu ilding ignitions but also gives them a safe position to respond to off-site wildfires. Using the Project’s fire protection features firefighters would be able to use the Project as a tactical resource for protecting open space areas, whether it be from on-site or off-site fires. The Project would create additional access for fire apparatuses that were not previously existing. Enhanc ing firefighters’ ability to respond to an incident increases their ability to suppress a fire whether on-site or off-site. The presence of on-site fire resources increases response capacity and could be the difference between a small fire or a full conflagration.

2.4.3 Ignition Resistant and Noncombustible Construction The WUI fire problem is largely structures lacking ignition resistant features (i.e., ember resistant vents, interior sprinklers); therefore, the best mitigation is to reduce th e likelihood of building ignition occurring (Zhou, 2013).

Structural characteristics play a significant role in whether a building burns, which is important in WUI environments as structures also serve as fuel (Gorte, 2011). The benefit of structure-based mitigation is that it not only lowers the on-site risk but also lowers the risk of wildfire acro ss a landscape (Mockrin et al., 2020). In WUI areas, this is because structures are also fuels that can spread a fire into open space. With the incorporation of ignition-resistant construction, the likelihood of structural ignition occurring within the Project area is minimized. The Project will provide new code compliant, ignition resistive structures, which lowers the threat from on-site fires impacting off- site areas as the structures themselves are highly unlikely to function as fuel. The Project includes vent coverings to prevent ember penetration, and the Project buildings will also include NFPA 13D automatic interior fire sprinkler systems for occupancy type in every residential building. This is crucial in preventing off-site impacts as embers can also be generated by a structure fire and can be blown ov er the fuel modification into native fuels. Automatic

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sprinklers can isolate a fire to the point of origin, limit it s ability to spread to the re st of the building, and even extinguish a fire before the responding firefighters arri ve, thus damping the likelihood of ember production. The installation of an interior fire sprinkler system within each structure also reduces impacts on fire response capacity as the automatic sprinklers will allow firefighters to focus on reducing additional ignitions beyond the point of origin.

Structure design, such as Project’s, is crucial in protecting an area against wind-driven fires. The Project provides features that not only prevent fire intrusion but prevent structures fires from escaping into off-site areas. This allows the Project to not only protect the immediate area but the surrounding environment.

2.4.4 Shelter in Place Capability
Sheltering-in-place is the practice of going or remaining indoors during or following an emergency event. This procedure is recommended if there is little time for the public to react to an incident and it is safer for the public to stay indoors for a brief time rather than travel outd oors. According to common Emergency Operations Plan language, shelter-in-place is an approach that has b een used and is actively contemplated for emergencies, including wildfires. Shelter-in-place advises people to stay secure at their current location.

Consistent with the Project’s approach, this tactic shall only be used if an evacuation causes a higher potential loss of life. Consideration should be given to assigning incident personnel to monitor the safety of citizens remaining in place. The concept of shelter-in-place is an available option in those instances where physical evacuation is impractical. Sheltering-in-place provides a safe haven within the impacted area.

This FPP provides significant evaluation and conclusions re garding the shelter-in-place capability of the Project’s buildings. Among other things, the Project has been design ed to include ignition-resistant structures with the use of ignition resistant construction materials, effective defensible space and fuel management zones, ember protection, and other redundant structure, infrastructure , building code, and water supply and flow requirements established as containing adequate protective features to function as temporary shelters during wildfires. All the on-site structures could be utilized for temporary refuge during wildfire. In addition, there may be protected open- air areas that would be enhanced to serve as temporary sh eltering sites as a contingency plan if evacuation is considered undesirable. These sites would be designated with input from SBCFD and may include green spaces, leeside of buildings, or other protected areas.

Sheltering-in-place also has many advantages because it can be implemented immediately, allowing people to remain in their familiar surroundings, and providing individuals with everyday necessities such as telephone, radio, television, food, and clothing. However, the amount of time people can stay sheltered-in-place is dependent upon availability of food, water, medical care, utilities, an d access to accurate and reliable information. It is not anticipated that any wildfire related shelter-in-place action would require longer than a few hours of on-site refuge.

The decision on whether to evacuate or shelter-in-place is carefully considered with the timing and nature of the incident. Sheltering-in-place is the preferred method of protection for people that are not directly impacted or in the direct path of a hazard. This will reduce congestion and transportation demand on the major transportation routes for those that have been directed to evacuate by police or fire personnel. Like with most new developments that incorporate ignition resistant construction, wide fuel modi fication zones, ember protection, and fire defensibility throughout, responding fire and law enforcement personnel will be able to direct people temporarily refuge on-site in designated buildings in the rare situation where shelter-in-place is determined to be safer than evacuating.

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Shelter-in-place at this location in the planned structures will also be an option available to emergency managers during a wildfire event. A shelter-in-place plan will be pr epared and provided to all on-site personnel outlining the actions to take if shelter in place notification is provided by emergency management sources.

The Project buildings will be constructed of ignition resistant construction. Because of the ignition resistant construction, fuel modification zone setbacks and the type of lower fire intensity vegetative fuels in the vicinity of the site, sheltering in place is considered to be a safe option if a fast-moving wildfire precludes complete evacuation of the Project site. The heat flux produced by the neares t unmaintained vegetative fuels is not at a high enough temperature to ignite a concrete building even if it is directly next to the building. In this case, the heat would dissipate rapidly in the provided building setbacks and the concrete or stucco structures would be capable of absorbing any residual heated air that may intersect with the buildings. The primary concern is anticipated to be with smoke and air quality rather than exposure to flames and heated air. Measures to safely refuge persons within the buildings and minimize smoke and air quality issues would be enacted in this scenario. For example, when wildfire ignites, it is common for HVAC systems to be turned off and they can be fitted with sensors that turn them off automatically when smoke is detected. This minimizes the potential for drafting smoke through the ventilation system into the buildings.

PProjectt Designn Feature: Most of the primary components of the Project’s layered fire protection system are required by Fire and Building codes, because they have been ev aluated in the lab and in real-time wildfires and found to result in saved structures. They are worth listing because they have been proven effective for minimizing structural vulnerability to wildfire. They also make shelter-in-pla ce possible as an evacuation contingency option when evacuation is not possible.

Even though current Building and Fire Codes require the se measures, at one time, ma ny of them were used as mitigation measures for buildings in fi re hazard areas, because they were kno wn to reduce structure vulnerability to wildfire. These measures were adop ted into the 2007 California Building Code and have been retained and enhanced in code updates since then. The following Proj ect features are required for new development in fire hazard areas and would form the basis of the system to provide adequate access by emergency responders and provide the protection necessary to minimize structural ignitions:
Application of the latest adopted ignition-resistant building codes; Exterior wall coverings are to be ignition resistant; For structures that achieve the minimum 100 feet of on-site fuel modification, all exterior windows, skylights, and exterior glazed door assemblies shall be constructed of multipaned glazing with a minimum of one tempered pane. All windows shall be UL listed , not of vinyl construction, and shall have a fire- resistant rating of not less than 20 minutes when evaluated according to NFPA 257/UL 263. Ember-resistant vents mesh screening should be between 1/16- and 1/8-inch noncombustible, corrosion resistant material (recommend BrandGuard, O’Hagin, or similar vents); NFPA 13D interior, automatic fire sprinkler systems within all residential buildings; Boxed or no eaves or soffits.
There would be no use of paper-faced insulation or combustible installation in attics or other ventilated areas; There would be no use of plastic, vinyl (with the exce ption of vinyl windows with metal reinforcement and welded corners), or light wood on the exterior.
- Any vinyl frames to have welded corners and metal reinforcement in the interlock area to maintain integrity of the frame certified to ANSI/AAMA/NWWDA 101/I.S 2 97 requirements.

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Skylights to be tempered glass (as applicable).
Rain gutters and downspouts shall be non-combustibl e. They would be designed to prevent the accumulation of embers, leaf litter or debris, which can ig nite roof edges, by requiring the installation of non-combustible debris covers and mesh over the top of rain gutters to minimize a common ignition point. Doors to be of approved noncombustible construction or would be solid core wood having stiles and rails not less than 1 3/8 inches thick or have a 20-minute fire rating. Doors to comply with City Building Code, There would be no combustible awnings, canopies, or similar combustible overhangs. No combustible fences to be allowed within 5 feet of structures. All chimneys and other vents on heat ing appliances using liquid fuel (n o solid fuel burning appliances), including outdoor fireplaces and permanent barbeques and grills, shall have spark arrestors that comply with the City Code. The code requires that openings would be between 1/16- and 1/8-inch and the screen would have comparable heat and corrosion resistance to 19-gauge galvanized or 24-gauge stainless steel.

Arrestors would be visible from the ground.
Modern infrastructure, access roads, and water delivery system; Maintained FMZs.

Notably, automatic interior fire sprinklers, which would be provided in all structures (required by code since 2010), have an extremely high reliability track record (NFPA 2021) of controlling fire in 96% of reported fires, and statistics indicate that fires in structures with sprinklers resulted in 82% lower property damage and 68% lower loss of life (Hall 2013). NFPA 13D fire sprinklers are designed for structure protection and life safety. For wildland fire defense, should embers succeed in entering a structure, sprinklers provide an additional layer of life safety and structure protection.

SSheltering-In-Placee ass ann Activee Emergencyy Optionn Sheltering-in-place or providing temporary refuge when evacuation is considered undesirable is not a new idea.

Sheltering-in-place has been a useful tool in the emergency management toolbox since the 1950’s. In some wildfire scenarios, temporarily sheltering in a protected structure is safer than evacuating. Huntzinger (2010) states that:
“If sheltering in place can provide the community with the same level of protection from an emergency incident as mass evacuation, this will be the recommended practice to use.” Many civilian deaths have occurred when the population evacuated late and was expos ed to wildfire on unprotected roadways (Braun, 2002, CFA 2004). By contrast, fire hardened projects that have implemented si milar fire protection, setbacks, and building standards have fared well in fire events, making them suitable for temporary shelter. Developments constructed in accordance with modern fire-safe development standards also surviv ed the 2003 Simi Fire, the 2008 Freeway Complex Fire, and the 2020 Silverado Fire without a single building lost . Nasiatka (2003) points out that another advantage to sheltering in place in an appropriately protected locati on is that there would be a substantial reduction in the number of evacuees that would need to be managed, allowi ng those evacuees at greater risk (i.e., in older, less protected communities) to evacuate more quickly.

2.4.5 Wildfire Risk Awareness Education
The Project includes an education awareness program that is a key piece in wildfire prevention in the area (Steffey et al., 2020). This program will provide wildfire inform ation for the area and create greater risk awareness for employees and customers. The wildfire education program wi ll be facilitated by the BOA, property manager, or similar entity and will disclose the potential wildfire risk and the requirements of the FPP. The educational program will also include information regarding the necessary la ndscape maintenance and structural-based fire protection

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features. Having ongoing education included in the Projec t creates a heightened level of wildfire risk awareness and fire protection measures. This benefits both the Pr oject and the surrounding area s as people would be more aware of the wildfire risk and potential impacts. Furth er, it decreases the likelihood the Project employees, customers, and other users would cause an uncontrolled ignition, and they would be aware of what steps to take if they observe an ignition. As such the impact on off-site areas would be further lowered by reducing the probability of ignition.

As described above it is not as simple to say development in areas with high fire hazards will equate to increased wildfire risk. It is possible to develop in these areas when fire is incorporated into Project design and create a site that is not only hardened against fire but designed to prevent fires. The dual benefit of creating a development that can prevent a fire is that it offers protection to the surrounding developed areas and the environment. The requirements and recommendations outlined in the FPP have been designed specifically for the proposed construction in the Project’s location and can significantly reduce the potential threat to off-site areas.

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3 Anticipated Fire Behavior

3.1 Fire Behavior Modeling
Following field data collection efforts and available data analysis, fire behavior modeling was conducted to document the type and intensity of fire that would be expected to be adjacent to the Project site given characteristic site features such as topography, ve getation, and weather (see Figure 1, Fire Hazard Severity Zone and Appendix B, Fire History). Dudek utilized BehavePlus software package (Andrews, Bevins, and Seli 2008) to analyze potential fire behavior on and adjacent to the Project site, with assumptions made for the pre- and post-Project slope and fuel conditions. Results are provided below and a more detailed presentation of the BehavePlus analysis, including fuel moisture and weather input variables, is provided in Appendix C, Fire Behavior Modeling Summary. BehavePlus modeling is described below followed by the fire spread modeling details.

3.2 Fire Behavior Modeling Analysis
An analysis was conducted to evaluate both pre- and po st- Project vegetation fire behavior variables and to objectively predict flame lengths, intensities, and spre ad rates for two pre- proposed Project scenarios were evaluated, including one average summer weather conditions (southwest of the proposed Project site and northeast of the Project site). Additionally, two scenarios were run for post-Project conditions (one average and one extreme weather condition respectively). These fire scenarios incorp orated observed fuel types representing the dominant vegetation representative within and adjacent to the deve lopment site, in addition to slope gradients, wind, and fuel moisture values for both the 50th percentile weat her (summer, on-shore and off-shore winds) and the 97th percentile weather (fall, off-shore winds). Modeling scenario locations were selected to better understand different fire behavior that may be experienced on or adjacent to the Project site.

To support the fire behavior modeling efforts conducted, a Dudek Fire Protection Planner analyzed the different vegetation types observed on and adjacent to the site an d were classified into the aforementioned numeric fuel models. As is customary for this type of analysis, the te rrain, and fuels directly adjacent to the site and proposed fuel modification zones (FMZ) are used for determining flame lengths and fire spread. Vegetation types, which were derived from the field assessment, were classified into f uel models. Fuel models are selected by their vegetation type, fuel stratum most likely to carry the fire, and depth and compactness of the fuels. Fire behavior modeling was conducted for vegetative types that are both on and adjacent to the proposed development. Fuel models were also assigned to illustrate post-Project fire behavi or changes. Fuel models were selected from Standard Fire Behavior Fuel Models: a Comprehensive Set for Use with Rothermel’s Surface Fire Spread Model (Scott and Burgan 2005).

Fuel models were also assigned to the fuel FMZs to illu strate post-Project fire behavior changes. Based on the anticipated existing and post-Project vegetation conditions, six different fuel models were used in the fire behavior modeling effort presented herein. Fuel model attributes are summarized in Table 1.

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Table 1. Fuel Models Used for Fire Behavior Modeling
FFuell
MModell
TTypee TTitle DDescription
AApplicationn
(Behavee Run)
Existingg conditions
SH5 High load dry
climate shrub
Heavy shrub load, depth 4 to 6 feet. Spread rate very
high; flame length very high.

Native chaparral
vegetation
SH2 Moderate load
dry climate shrub
The primary carrier of fire is woody shrubs and shrub
litter. Depth about one foot, no grass fuel is present.

Spread rate low; flame length low.

Native sage and forb
vegetation
SCAL18 Sage scrub,
buckwheat
The primary carrier of fire is sage, buckwheat, and
sparse grass. Average height about two to three feet.

Spread rate moderate; flame length moderate.

Native
sage/buckwheat
vegetation
Post--Project
GS1 Low load dry
climate grass-
shrub
The primary carrier of fire is grass and shrubs
combined. Shrubs are about one foot high; grass load
is low. Spread rate moderate; flame length low.

Thinned and
maintained native
vegetation
FB8 Irrigated
landscaping/
compact litter
The primary carrier of fire is landscaping litter, though lesser amounts of fine dead fuel may be present. The
landscaping material is generally hydrated with high
moisture content. Spread rate low; flame length low.

Irrigated landscaping
NB1 Urban or
suburban
development
Insufficient wildland fuel to carry wildland fire. Paved roadways, parking, hardscape
Tables 2A and 2B summarize the weather and wind input variables used in the BehavePlus modeling process.

Table 2A. Fuel Moisture and Wind Inputs
Variable Weatherr Conditionn (50thh Percentile)
1h Moisture 3%
10h Moisture 5%
100h Moisture 7%
Live Herbaceous Moisture 60%
Live Woody Moisture 90%
20-foot Wind Speed (mph) 20
BehavePlus Wind Adjustment Factor 0.4
Table 2B. Fuel Moisture and Wind Inputs
Variable Weatherr Conditionn (97thh Percentile)
1h Moisture 2%
10h Moisture 3%
100h Moisture 5%
Live Herbaceous Moisture 30%

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Table 2B. Fuel Moisture and Wind Inputs
VVariable WWeatherr Conditionn (97thh Percentile)
Live Woody Moisture 60%
20-foot Wind Speed (mph) 40
BehavePlus Wind Adjustment Factor 0.4

3.3 Fire Behavior Modeling Results
The results presented in Tables 3 and 4 depict values ba sed on inputs to the BehavePlus software and are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of different fuel types are not accounted for in this an alysis; rather, the models provide a worse-case wildfire behavior condition as part of a conservative approach. For planning purposes, the averaged worst-case fire behavior is the most useful information for conservative fuel modi fication design. Model results should be used as a basis for planning only, as actual fire behavior for a given lo cation would be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.

The results of fire behavior modeling analysis for pre- and post-Project conditions are presented in Tables 3 and 4, respectively. Identification of modeling run (fire scen arios) locations is presented graphically in Figure 4, BehavePlus Analysis Map.

Fire Scenario locations and descriptions:
SScenarioo 1. Fire flaming front approaching from the northeast towards the northern side of Parcel 1 Project boundary with 40 mph north/northeast winds; 18% downhill slope within 100 to 300 feet of edge of grading. - Existingg conditions: undeveloped land off-site (to be preserved as open space) and on site with native vegetation (chaparral, sage scrub).
- Post-developmentt conditions: include the same off-site conditio ns with irrigated manufactured slopes, fuel modification zones, and paved roadways on site. Scenarioo 2. Fire flaming front approaching from the southwest towards the western boundary of the Parcel 1 western boundary with 20 mph west/southwest winds; 6% uphill slope within 400 feet of edge of grading. - Existingg conditions: undeveloped land off-site and on-site with native vegetation (sage scrub, forbs). - Post-developmentt conditions: include the same off-site conditions with irrigated manufactured slopes, fuel modification zones, and paved roadways on site.

The results presented in Tables 3 and 4 depict values ba sed on inputs to the BehavePlus software reflecting a “moment in time” and are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of different fuel types are not accounted for in this analysis, but the models provide the worst-case wildfire behavior condition as part of a conservative approach. For planning purposes, the averaged worst-case fire behavior is the most useful informatio n for conservative fuel modification design. Model results should be used as a basis for planning only, as actual fire behavior for a given location would be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.

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3.3.1 Existing Conditions
As presented in Figure 4, BehavePlus Analysis Map , wildfire behavior in the off-site chaparral, modeled as SH5, would exhibit the most intense fire behavior with the sa ge/buckwheat vegetation, modeled as SCAL18 exhibiting similar fire behavior (refer to Table 3, Fire Behavior Resu lts for Existing Conditions). A worst-case fire under gusty Santa Ana winds and low fuel moistures is expected to be moving up to 4.7 mph. Flame length values were modeled at 35.5 to 36.3 feet. Spotting is projected to occur up to 1.8 miles from the flaming front.

Table 3. Modeling Results for Existing Conditions
FFiree Scenarios
SSpreadd Ratee
((mph)
FFirelinee Intensityy
((BTU/feet/second)
FFlamee
LLengthh
((feet)
SSpottingg
DDistance11
(miles)
SScenarioo 1:: 118%% ddownhilll sslope,, 400 mphh windd fromm NE Fuel Model SH5 – Chaparral 4.7 13,958 36.3 1.8
Fuel Model SCAL18 – Sage, buckwheat 2.1 13,342 35.5 1.8 Fuel Model SH2 – Sage, forbs 0.7 1,515 13.1 0.9
SScenarioo 2:: 66%% uuphhilll sslope,, 2200 mmphh windd fromm WW//SSW Fuel Model SH2 – Sage, forbs 0.3 603 8.6 0.4
NNote::
1 Spotting distance from a wind driven surface fire.

3.3.2 Post-Development Conditions
As presented in Table 4, Fire Behavior Results for Post-Project Conditions, Dudek conducted modeling of the Project site for post-development fuel recommendations for the Proj ect. The fuel modification area includes thinning and maintained vegetation, irrigated landscaping, and paved ro adways on the periphery of the proposed Project. For modeling the post-development condition, fuel modification was modeled as thinned native vegetation (Fuel Model GS1) and irrigated landscaping (Fuel Model 8). Fuel model assignments for all other areas remained the same as those classified for the existing condition.

The fuel modification areas experienced a significant reduction in flame length and intensity. The flames predicted during pre-development modeling during extreme weather conditions are reduced to less than 3.0 feet in length at the outer edges of the development due to the lack of co mbustible material present and the higher live and dead fuel moisture content for the irrigated landscaping.

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Table 4. Modeling Results for Post-Project Conditions
SScenario
Flamee
Lengthh (feet)
Firelinee Intensityy
(BTU/feet/second)
Spreadd Ratee
(mph)
Spottingg
Distance1
(miles)
Scenarioss 1:: 25%% downhilll sslope,, 400 mphh windd fromm NEE Fuel Model GS1 – maintained
shrubs for fuel modification

11.1 1067 2.0 0.8
Fuel Model 8 – Irrigated
landscaping/FMZ

2.6 46 0.1 0.3
Fuel Model NB1 – paved roadway NA NA NA NA
Scenarioss 2:: 20%% uphilll slope,, 200 mphh windd fromm SWW Fuel Model GS1 – maintained
shrubs for fuel modification

7.2 411 0.8 0.4
Fuel Model 8 – Irrigated
landscaping/FMZ

2.0 26 0.1 0.2
Note:
1 Spotting distance from a wind driven surface fire.

The results presented in Tables 3 and 4 depict values base d on inputs to the BehavePlus software and are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of different fuel types are not accounted for in this analysis, but the models provide the worst-case wildfire behavior condition as part of a conservative a pproach. For planning purposes, the averag ed worst-case fire behavior is the most useful information for conservative fuel modificati on design. Model results should be used as a basis for planning only, as actual fire behavior for a given location would be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.

The following describes the fire behavior variables (Heisch and Andrews 2010) as presented in Tables 4 and 5:

Surfacee Fire::
Flamee Lengthh (feet):: The flame length of a spreading surface fire within the flaming front is measured from midway in the active flaming combustion zone to the average tip of the flames. Firelinee Intensityy (Btu/ft/s): Fireline intensity is the heat energy release per unit time from a one-foot-wide section of the fuel bed extending from the front to the rear of the flaming zone. Fireline intensity is a function of rate of spread and heat per unit area and is re lated to flame length. Fireline intensity and the flame length are related to the heat felt by a person standing next to the flames. Surfacee Ratee off Spreadd (mph): Surface rate of spread is the "speed" the fire travels through the surface fuels. Surface fuels include litter, grass, brush, and ot her dead and live vegetation within about 6 feet of the ground.

The information in Table 5 presents an interpretation of the outputs for five fire behavior variables as related to fire suppression efforts. The results of fire behavior modeling efforts are presented in Tables 3 and 4. Identification of modeling run locations is presented graphically in Figure 4 of this FPP.

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Table 5. Fire Suppression Interpretation
FFlamee Lengthh (ft)
FFirelinee Intensityy
((Btu/ft/s) IInterpretations
Under 4 feet Under 100 BTU/ft/s Fires can generally be attacked at the head or flanks by people using hand tools. Hand line should hold the fire. 4 to 8 feet 100-500 BTU/ft/s Fires are too intense for direct attack on the head by people using hand tools. Hand line cannot be relied on to hold the fire. Equipment such as dozers, pumpers, and
retardant aircraft can be effective.
8 to 11 feet 500-1000 BTU/ft/s Fires may present serious control problems -- torching out, crowning, and spotting. Control efforts at the fire head will probably be ineffective.

Over 11 feet Over 1000 BTU/ft/s Crowning, spotting, and major fire runs are probable.

Control efforts at head of fire are ineffective.

3.4 Project Area Fire Risk Assessment
Wildland fires are a common natural hazard in most of southern California with a long and extensive history.

Southern California landscapes include a diverse range of plant communities, including vast tracts of grasslands and shrublands, like those found adjacent to the Projec t site. Wildfire in this Mediterranean-type ecosystem ultimately affects the structure and functions of vegetation communities (Keeley 1984) and will continue to have a substantial and recurring role (Keeley and Fotheringham 2003). Supporting this ar e the facts that 1) native landscapes, from forest to grasslands, become highly flammable each fall and 2) the climate of southern California has been characterized by fire climatologists as the worst fire climate in the United States (Keeley 2004) with high winds (Santa Ana) occurring during autumn after a six-month drought period each year. Based on this research, the anticipated growing population of western San Bernardino County WUI areas, and the regions fire history, it can be anticipated that periodic wildfires may start on, burn onto , or spot into the Project site. The most common type of fire anticipated in the vicinity of the Project area is a wind-driven fire fr om the north moving through the chaparral and sage scrub vegetation on the adjacent lands.

With the conversion of the landscape to ignition-resistant development, wildfires may still encroach upon and drop embers on the site but would not be expected to burn through the site or produce sustainable spot fires due to the lack of available fuels. Studies indicate that even with older developments that lacked the fire protection provided in the Project, wildfires declined steadily over time (Syphard, et. al., 2007 and 2013) and further, the acreage burned remained relatively constant, even though the number of ignitions temporarily increased. This is due to the conversion of landscapes to ignition resistant, maintained areas, more humans monitoring areas resulting in early fire detection and discouragement of arson, and fast response from the fire suppression resources that are located within these developing areas.

Therefore, it will be critical that the latest fire prot ection technologies, developed through intensive research and real-world wildfire observations and findings by fire prof essionals, for both ignition resistant construction and for creating defensible space in the ever-expanding WUI ar eas, are implemented, and enforced. The Project, once developed, would not facilitate wildfire spread and would reduce projected flame lengths to levels that would be manageable by firefighting resources for protecting the Project site’s structures, especially given the ignition resistance of the structures and the planned ongoing maintenance of the entire Project site landscape.

Parcel 1
206
Path: Z:\Projects\j1442800\MAPDOC\DOCUMENT\FPP\Figure 5 BehavePlusAnalysisMap-Par1.mxd Project Site - Parcel 1
0 1,500 750
Feet
SOURCE: AERIAL-ESRI IMAGERY (accessed 2025)
FIGURE 4
BehavePlus Analysis Map
Fire Protection Plan - University Hills Project

SCENARIO
RUN #1

BBehavePlus Modeling Results for Existing Conditions
Fire Scenarios
Spread
Rate
(mph)
Fireline Intensity
(BTU/feet/second)
Flame
Length
(feet)
Spotting
Distance1
(miles)
Scenario 1: 118% ddownhill slope, 40 mph wind from NE
Fuel Model SH5 – Chaparral 4.7 36.313958 1.8
Fuel Model SCAL18 – Sage, buckwheat 2.1 35.513342 1.8
Fuel Model SH2 – Sage, forbs 0.7 13.11515 0.9

BBehavePlus Modeling Results for Post-PProject Conditions Scenario
Flame
Length
(feet)
Fireline Intensity
(BTU/feet/second)
Spread
Rate
(mph)
Spotting
Distance1
(miles)
Scenario 1:: 25%% downhill sslope, 40 mph wind from NE Fuel Model GS1 – maintained shrubs for fuel
modification

11.1 2.01067 0.8
Fuel Model 8 – Irrigated landscaping/FMZ 2.6 0.146 0.3
Fuel Model NB1 – paved roadway NA NANA NA

SCENARIO
RUN #2
Scenario 2:: 6% uphill slope, 20 mph wind from W/SW
Fuel Model SH2 – Sage, forbs 0.3 8.6603 0.4
Scenario
2 : 220% uphill slope, 20 mph wind from SW

Fuel Model GS1 – maintained shrubs for fuel
modification

0.84117.2 0.4
Fuel Model 8 – Irrigated landscaping/FMZ 0.1262.0 0.2

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4 Emergency Response and Service

4.1 Emergency Response Fire Facilities
The Project site is located within the San Bernardino County Fire Protection District (SBCFPD) jurisdictional response area. Regionally, SBCFPD fire, emergency medical, and re scue services from 57 fire stations (full time and paid/volunteer)7. Inland Counties Emergency Medical Agency (ICEMA) provides emergency medical services and transportation (ambulance service) for residents of San Bernardino, Inyo, and Mono Counties. 8 The Valley Region Operating Area is American Medical Response (AMR)9. The SBCFPD serves over 2 million residents throughout 24 incorporated cities and all unincorporated portions of San Bernardino County’s Southern California Inland Empire.

At 20,160 square miles, San Bernardino County is the la rgest county in the continental United States. Figure 5 illustrates the fire station locations and Table 6 provides a summary of the location, equipment, and staffing levels for the closest responding fire stations.

The Project site lies within Battalion 4, East Valley Zone (Division 2) response area. 10 SBCFPD has mutual aid agreements through CONFIRE, a Joint Powers Authority located in San Bernardino County California established to provide communications, dispatch, computer information systems support, and geographic information systems to CONFIRE members and contract agencies. 11 CONFIRE member agencies are: A pple Valley Fire Protection District, Chino Valley Independent Fire District, Colton Fire Department, Loma Linda Fire Department, Rancho Cucamonga Fire District, Redlands Fire Department, Rialto Fire Department, San Bernardino County Fire District, Victorville Fire Department. The SBCFPD is the sponsoring agency of the Ca lifornia Office of Emergency Services Regional Task Force 6 (CA-RTF-6). CA-RTF-6 consists of 30 personnel specially trained and equipped for large or complex Urban Search and Rescue operations.

Primary response will be provided by Fire Station No. 232 (FS 232), locate d at 6065 N. Palm Avenue in the Verdemont neighborhood of northern San Bernardino. FS 23 2 is approximately five minutes from the Project site and serves the foothill suburban community known as Ve rdemont Heights. The station operates 24 hours a day, seven days a week, and is staffed by a three-person Engi ne Company consisting of a Captain, an Engineer, and a firefighter-paramedic. It is equipped with a Type 1 Medic Engine and a Type 3 Brush Engine (cross-staffed).

Secondary response will be provided by Fire Station No. 75 (FS 75), located at 2852 Macy Avenue in Muscoy, a nearby unincorporated community in San Bernardino C ounty. FS 75 is approximately seven minutes from the Project site and provides service to the valley region at the base of the foothills. The station operates 24 hours a day, seven days a week, and is staffed by a three-person Engine Company consisting of a Captain, an Engineer, and a firefighter-paramedic. It is equipped with a Type 1 Medic Engine and a Type 3 Brush Engine (cross-staffed).

Additional emergency response will be available from Fire Station No. 227 (FS 227), located at 282 W. 40th Street in the Wildwood Park neighborhood of San Bernardino. FS 227, which is slightly over seven minutes from the Project site, provides paramedic and fire services to northern po rtions of the city. The station operates 24 hours a day, 7 https://sbcfire.org/fp5/
8 https://icema.sbcounty.gov/
9 https://www.sbcounty.gov/uploads/LAFCO//Downloads/Service_Review_Fire/Report/Fire_Service_Review.pdf 10 https://sbcfire.org/fp5/
11 https://www.confire.org/about

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seven days a week, and is staffed by a three-person Engi ne Company consisting of a Captain, an Engineer, and a firefighter-paramedic. It is equipped with a Type 1 Medic Engine and a Type 3 Brush Engine (cross-staffed).

Further support may be provided by Fire Station No. 22 4 (FS 224), located at 2641 N. E Street, just north of downtown San Bernardino. FS 224 is approximately 10 minu tes and 30 seconds from the Project site and serves central urban areas of the city. The station operates 24 hours a day, seven days a week, and is staffed by a three- person Engine Company consisting of a Captain, an Engi neer, and a firefighter-paramedic, a three-person Truck Company consisting of a Captain, an Engineer, and a fire fighter, a two-person Squad Company consisting of two firefighter-paramedics, and a Battalion Chief. Available apparatus at FS 224 includes a Type 1 Medic Engine, a Medic Aerial Truck, a Medic Squad, and a Battalion Chief vehicle, enhancing its capacity to support major incidents.

In 2022, Medic Engine 224 was the fourth (4th) busiest fire engine in the nation.12 Table 6. Closest Responding SBCFPD Fire Station Summary SStation LLocation EEquipment SStaffing
Fire Station 232 6065 N. Palm Avenue
San Bernardino, California
(1) Type 1 Medic Engine
(1) Type 3 Brush Engine
3 on-duty
Fire Station 75 2852 Macy Avenue
Muscoy, California
(1) Type 1 Medic Engine
(1) Type 3 Brush Engine
3 on-duty
Fire Station 227 282 W. 40th Street
San Bernardino, California
(1) Type 1 Medic Engine
(1) Type 3 Brush Engine
3 on-duty
Fire Station 224 2641 N. E Street
San Bernardino, California
(1) Type 1 Medic Engine
(1) Medic Aerial Truck
(1) Medic Squad
(1) Battalion Chief
8 on-duty
SSource:: SBCFPD - https://www.iafflocal935.org/division-2 Within the area’s emergency services system, fire and emergency medical services can beprovided by other agencies.

Generally, each agency is responsible for structural fire protection and wildland fire protection within their area of responsibility. However, mutual aid agreements enable non-lead fire agencies to respond to fire emergencies outside their district boundaries. In the Project area, fire agencies cooperate under a statewide master mutual aid agreement for wildland fires. There are also mutual aid agreements in place with neighboring fire agencies and typically include interdependencies that exist among the region’s fire protection agencies for structural and medical responses but are primarily associated with the peripheral “edges” of each agency’s boundary.

4.1.1 Emergency Response Travel Time Coverage
In an effort to understand fire department response capa bilities, Dudek conducted an analysis of the travel-time response coverage from the closest responding fire stations. The response time analysis was conducted using travel distances that were derived from Google Road data. Travel times were calculated by applying the distance at speed limit formula (T=(D/S) * 60, where T=time, D=distance in miles, and S=speed in MPH) as well as the nationally recognized Insurance Services Office (ISO) Public Prot ection Classification Program’s Response Time Standard formula (T=0.65 + 1.7 D, where T= time and D = distance) for comparison. Tables 7 and 8 present tabular results of the emergency response time analysis using the distance at speed formula and the ISO formula, respectively. 12 https://www.instagram.com/sanbernardinocountyfire/p/CdgzlEOM6T4/

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Table 7. Project Emergency Response Analysis using Speed Limit Formula SStation
TTravell Distancee too Projectt
SSite
TTravell Timee too
PProjectt EEntrance**
TTotall Responsee
TTime**
Fire Station 232 2.9 miles 4 minutes
58 seconds
6 minutes
58 seconds
Fire Station 75 4.1 miles 7 minutes
2 seconds
9 minutes
2 seconds
Fire Station 227 4.4 miles 7 minutes
33 seconds
9 minutes
33 seconds
Fire Station 224 6.1 miles 10 minutes
27 seconds
12 minutes
27 seconds
Notes::
* Assumes travel distance and time to the Pr oject site into the development for the respective fire station. Also assumes application of the distance at speed limit formula (T=(D/S) * 60, where T=time, D=distance in miles, and S=speed in MPH), a 35-mph travel speed, and does not include turnout time.
** Assumes travel distance and ti me to the Project site into development from the respective fire station, and application of the distance at speed limit formula (T=(D/S) * 60, where T=time, D=distance in miles, and S=speed in MPH), a 35 mph travel speed along with dispatch and turnout time, which can add an additional two minutes to travel time.

Table 8. Project Emergency Response Analysis using ISO Formula Station
Travell Distancee too Projectt
Entrance
Travell Timee too
Projectt Entrance* Totall Responsee Time**
Fire Station 232 2.9 miles 5 minutes
35 seconds
7 minutes
35 seconds
Fire Station 75 4.1 miles 7 minutes
37 seconds
9 minutes
37 seconds
Fire Station 227 4.4 miles 8 minutes
8 seconds
10 minutes
8 seconds
Fire Station 224 6.1 miles 11 minutes
1 second
13 minutes
1 second
Notes::
* Assumes travel distance and time to the Pr oject site into the development for the respective fire station. Also assumes application of the ISO formula, T=0.65+1.7(Distance), a 35-mph travel speed, and does not include turnout time. ** Assumes travel distance and time to the Project site into the development for the respective fire station. Also assumes application of the ISO formula, T=0.65+1.7(Distance), a 35-mph travel speed , and dispatch and turnout time, which can add an additional two minutes to travel time.

The ISO response travel time formula discounts speed for intersections, vehicle deceleration, and acceleration, and does not include turnout time. As such, per the ISO response travel time formula:
FS 232 is located approximately 2.9 miles from the Project site and is the closet fires station to the Project site. FS 232 can respond to an incident at the Project site within approximately 7 minutes and 35 seconds. The second closet fire station is FS 75, located appr oximately 4.1 miles from the Project site. FS 75 can respond to an incident at the Project site within approximately 9 minutes and 37 seconds. FS 227 located approximately 4.4 miles from the Project site can respond to an incident within 10 minutes and 8 seconds.
FS 224 is located approximately 6.1 miles from the Project site. FS 224 can respond to an incident at Project site within approximately 13 minutes and 1 second.

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Emergency response time target thresholds include trave l time along with dispatch and turnout time, which can add two minutes to travel time. FS 232 would provide an initial response as the closest fire station. As indicated in Table 7 and Table 8, the total response time from FS 232 to the Project site does meet the response time standard of 6 minutes according to the nationally recognized National Fire Protection Association (NFPA) 1710.

According to LAFCO for San Bernardino County 3231 , the objective is to have a less than 5-minute response time 90% of the time in the district. FS 232 to the Project si te is outside the response time standard of less than 5 minutes for the objective in the district. FS 232 is estima ted to arrive at the Project site approximately 4 minutes 58 seconds (Speed Limit Formula) or 5 minutes and 35 se conds (ISO Formula) after departing the station. All response calculations are based on an average response speed of 35 mph and are consistent with NFPA 1710.

4.2 Estimated Calls and Demand for Service from
the Project
Determining the potential impact associated with the Pr oject’s estimated population increase is required to compare how many additional calls may be realized and determine what effects they may have on the available response resources. The estimated incident call volume of the Project is based on a conservatively calculated estimate from the maximum potential number of additional people that would be expected on site. Emergency call volumes related to typical projects can be reliably estimate d based on the historical per-capita call volume from a particular fire jurisdiction.

The following estimated annual emergency call volume generated by the Project is based upon per capita data for SBCFPD Division 2 (East Valley) July 1, 2024 – April 30, 2025. 13 Total population served: 5519,58214.
Total annual calls: 443,990, per capita call generation: ..0847 Total annual fire calls (Structure, Vegetation, Vehicle, Other): 44,560, per capita call generation: ..0087 Total annual medical aid calls: 333,395, per capita call generation: ..0642 Total other calls (Investigation, Hazardous Materials, Public Service, Rescue, Traffic Collisions): 55,223, per capita call generation: ..01000
Total miscellaneous calls: 8811, per capita call generation: .000155 Using the data above, the estimated annual emergency call volume for the Project site as calculated. In order to provide this conceptual estimate, Dudek made assumptions regarding the single-family detached residential units population within the Project site to estimate at 3.21 persons per household 15. The Project site estimated population for three hundred twenty-seven (327) single-family detached residential units is approximately 1,050 residents. Based on this estimate, the calculated call volume by type of call is provided in Table 9. 13 https://sbcfire.org/statistics/
14 Dudek estimated the census population for Division 2 (East Vall ey) from census tract populations within the SBCFPD Division 2 boundaries https://data.census.gov/all?q=san+bernardino 15 https://data.census.gov/all?q=san+bernardino

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Table 9. Calculated Call Volume (Conceptual Based on 1,050 residents) for Project Site
TTypee off Call
PPerr Capitaa Call
GGenerationn Factor
NNumberr off Estimatedd
AAnnuall Callss
TTotall Calls ..088477 889
TTotall Fires ..0087 99
TTotall Medicall Aidd ..0642 667
TTotall Other ..0100 1111
TTotall MISC ..0015 22
As mentioned, the single-family detached residential units will increase the call volume at a rate of conservatively calculated (the actual number of calls may be lower than this estimate) up to eighty-nine (89) calls per year (.24 calls per day or 7.4 calls per month). Fire Station 232 e mergency response time in 2021 totaled 1,579 calls per year16 (approximately 4.3 calls per day or 131 calls per month). The level of service demand for the Project raises the overall call volume but it is not expected to impact FS 232 to a point where they cannot meet the demand. For perspective, 5 calls per day are typical in an urban or suburban area. A busy fire station company would be one with 10 to 15 or more calls per day. When University Hills Project site is built out , FS 232 could potentially respond to additional .24 calls per day or 7.48 ca lls per month, although the number may be likely lower that based on the conservative nature of the population and calls per capita data used in this estimate. 16 https://www.iafflocal935.org/2018-call-stats/

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Waterman Ave
W Kendall Dr
E St
W Highland Ave
N River
sideAve Highland Ave
Kendal
l Dr
y210
y259
]^215
Fire Station 232
Fire Station 75
Fire Station 227
Fire Station 224
Project Boundary
Fire Station
0 5,000 2,500
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Date: 6/12/2025 User: rstrobridge Path: Z:\Projects\j1442800\MAPDOC\FPP\Encore Hills Fire Protection Plan.aprx Map: SBCFPD Fire Stations Map Layout: Figure 5 SBCFPD Fire Stations Map SOURCE: Bing Maps 2024, CALFIRE 2023
Fire Protection Plan - University Hills Project
SBCFPD Fire Stations Map
FIGURE 5

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5 Fire Safety Requirements-
Infrastructure, Building Ignition
Resistance, and Defensible Space
The FPP demonstrates that the development site would co mply with applicable portions of the San Bernardino County Fire Protection District Fire Code, Ordinance No. FPD 23-01, SBCFPD Fire Code Fire Prevention Standards A-1, A-2, A-3, A-4, SRA-1, as well as applicable portions of the San Bernardino County Development Code, Chapter

82.13 Fire Safety Overlay. SBCFPD Fire Code adopts with amendments the 2022 CFC, including Chapter 49, California Code of Regulations, Title 24, Part 9, ba sed on the 2021 edition of the International Fire Code.

Furthermore, the Project will be consistent with applicable portions of Article III, Section 5-61 – Building Code, which adopts with amendments the 2022 edition of the CBC, incl uding Chapter 7A, California Code of Regulations Title 24, Part 2 governs the building, infrastructure, and defensible space requirements detailed in this FPP. The Project will meet or exceed applicable codes or will provide alternative materials and/or methods (as warranted). While these standards will provide a high level of protection to structures within the development, there are no guarantees that compliance with these standards will prevent damage or destruction of structures by fire in all cases. The following summaries highlight important fire protection features. Prior to bringing combustible materials onto the site, utilities should be in place, fire hydrants operational, an approved all-weather roadway, or an approved road surface alternative in place, and interim defensible space zones established and approved. A response map update, including roads and fire hydrant locations, in a format compatible with current SBCFPD mapping shall be provided to the SBCFPD. The following summaries highlight important fire protection features.

5.1 Fire Apparatus Access
The proposed Project site will be accessible via tw o (2) access points, one on the existing North Campus Parkway and the other on the new Badger Canyon Road.

Project site access, including road widths and connectivit y, will comply with the requirements of the SBCFPD Fire Code Fire Prevention Standards A-1, A-2, A-3, A-4, SRA-1, the 2022 California Fire Code, and all other applicable codes including:
Roadways and/or driveways will provide fire departme nt access to within 150 feet of all portions of the exterior walls of the first floor of each structure (CFC 503.1.1). Further, there must be a walkway approved by th e SBCFPD leading from fire apparatus access roads to exterior openings (CFC 504.1).
Roadway design features (e.g., speed bumps, humps, speed control dips, planters, and fountains) that could interfere with emergency apparatus response speeds and required unobstructed access road widths will not be installed or allowed to remain on roadways without approval of an SBCFPD official (CFC 503.4). Given the Project is required by CFC D104.1 to ha ve at least two access points, those access points shall be placed a distance apart equal to not less than one half of the leng th of the maximum overall diagonal dimension of the lot or area to be served, measured in a straight line between accesses (D104.3).

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5.1.1 Roads
All fire access roads associated with the Project will be in compliance with SBCFPD Fire Code Fire Prevention Standards A-1, A-2, A-3, SRA-1, the 2022 California Fire Code, and all other applicable codes. Fire apparatus access roads shall be provided to within 150 feet of all exterior portions of the first story of every building, facility or structure as measured by an approved route around the exterior building or structure.

5.1.1.1 Maximum Dead-End Road Length
There are no dead-end fire apparatus access roads pla nned in the Project area. The fire access lanes around are continuous and loop around the entirety of the develo pment. Dead-end roads between 150 feet and 750 feet in length require a 96-foot diameter cul-de-sac or other ap proved method of fire apparatus turnaround (CFC Section D103.4). All dead-end fire access roads included at any phase of the development shall comply with the following:
The maximum length of dead-end fire access roadways shall be six hundred (six hundred) feet in length in all residential developments (SBCFPD Standard A-1).

5.1.1.2 Surface and Grade
Fire access roads must be able to support fully loaded fire engines and be of a subtle enough grade to facilitate their travel. The surface and grade of all fire appara tus access roads associated with the Project comply with SBCFPD Fire Prevention Standard Fire Apparatus Acce ss Road Design, Construction and Maintenance (SBCFPD Standard A-1):
All roads comply with access road standards of the capa bility of supporting an imposed load of at least 75,000 pounds, fire apparatus weight is distributed as 55,000 lbs. on the rear dual axles and 20,000 lbs. on the front axle.
Fire access roadways shall be paved with a concrete or asphalt material in order to provide “all weather” safe driving.
Unless otherwise approved, the grade of a fire apparatus access road shall not exceed 12% and the cross slope shall not exceed 5%.
The angles of approach and departure for fire appa ratus access roads shall be a maximum of 5% grade change for ten feet of approach and departure.
All turns within fire access roadways that accommodate two-way traffic of fire apparatus shall be a minimum of 19 feet inside radius and 45 feet outside radius.
Fire access roadways require at least a 50-foot straight section of roadway between radius turns.

5.1.1.3 Width and Clearance
Fire apparatus access roads must be of an appropriate width and clearance to facilitate the ingress and egress of engines. The width and clearance of fire access roads a ssociated with the Project comply with SBCFPD Fire Prevention Standard Fire Apparatus Access Road Designation and Marking (SBCFPD Standard A-2):
Fire apparatus access roadways serving all buildings, structures, or facilities, shall be a minimum of 26 feet in unobstructed width. Roadways that have raised medians shall have an unobstructed one-way width of

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20 feet with signage posted ‘per SBCFPD Standard A-2. Such medians shall be a maximum of 50 feet in width except where approved by the Fire Code Of ficial. Roadways with raised medians shall have intersections or median breaks located at a maximum of 600 feet apart or as approved by the Fire Code Official.
All fire access roadways shall be no less than 14 fe et 6 inches in unobstructed vertical clearance, as measured from the roadway surface at the highest elevation to the lowest point of any obstruction. Parking is not permitted on roadways that are less th an 32 feet in width. In addition, parking that is perpendicular or diagonal to the edge of the roadwa y shall not obstruct the required minimum width of 26 feet for fire access.

5.1.1.3.1 Aerial Fire Apparatus Access Roads
Approved aerial fire apparatus access roads shall be prov ided for buildings that are three (3) stories or more or thirty feet or more in height associated with the Proj ect comply with SBCFPD Fire Prevention Standard Fire Apparatus Access Road Design, Construction and Maintenance (SBCFPD Standard A-1):
Aerial fire apparatus access roads shall have a minimum unobstructed width of thirty (30) feet. All fire access roadways shall be no less than 14 fe et 6 inches in unobstructed vertical clearance, as measured from the roadway surface at the highest elevation to the lowest point of any obstruction Overhead utilities, powerlines, and any other items th at could be considered obstructions shall not be located within the aerial fire apparatus access area.
Aerial fire apparatus access shall be provided in location s to enable rapid and safe access to the roof of the building. The location of all roof access points shall be approved by SBCFPD.

5.1.1.4 Fire Lane Marking
All roadways equal to or less than SBCFPD Standards for width, including private roads, where the roadway width would preclude any parking along the sides of the road or where parking along only one side of the road is allowed shall be designated and marked as a fire lane associat ed with the Project comply with SBCFPD Fire Prevention Standard Fire Apparatus Access Road Designation and Marking (SBCFPD Standard A-2):
All roadways encircling and/or providing direct access to commercial developments shall be designated as a fire lane.
Areas within fifteen feet (15’) of any fire appliance shall be designated as a fire lane. All fire apparatus access roads shall be identified by approved signs, approved red curbs and/or approved pavement striping.

SSignage::
Signs shall be no less than eighteen inches (18” ) high by twelve inches (12”) wide and made of durable material.
Signs shall be labeled, “NO PARKING,” “FIRE LANE,”and “CVC 22500.1” in all upper-case letters. Letting shall be no less than three inches (3”) high with red letting on white background. “CVC 22500.1” shall have one inch (1”) letters.

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The perimeter of the sign shall have a one inch (1’’) red boarder. Signs shall be installed with no less than a seven- foot (7’) clearance from the bottom of the sign to finish grade.
Signs shall be installed with twenty-four inches (24”) of the curb face. Signs shall be located no more the fifty feet (50’) ap art when installed on one side of the street and one hundred feet (100’) apart when installed on both sides of the street. There shall be a sign within five feet (5’) of the beginning and end of any fire lane.

RRedd Curbing:
Curbing used to designate fire lanes shall be painted in a weather-resistant red paint. Reflective paint may be used for higher visibility.
Curbing shall be labeled, “NO PARKING – FIRE LANE – CVC 22500.1” in all upper-case letters. Lettering shall be no less than three inches (3”) high with white lettering on a red background and placed on the face and top of the curb.
Lettering shall be located no more than fifty feet (50’) apart and within five feet (5’) of the beginning and end of any fire lane.

5.1.2 Gates
Multiple gates may be proposed as part of the Project, one along the existing North Campus Parkway and another on the newly constructed Badger Canyon Road. All gates associated with the Project shall comply with the SBCFPD Fire Prevention Standard Gates and Other Obstructions to Fire Apparatus Access (SBCFPD Standard A-3):

Manuallyy Operatedd Securityy Gates::
Manual gates shall have a means of emergency operation that allows manual operation by one person.

Manually operated gates shall be equipped with an approved “Knox” padlock or equivalent locking system acceptable to SBCFPD.
Manual gates shall either slide open horizontally or swing inward in the direction of emergency vehicle ingress.
Gates provide emergency access to fuel modification zones or wildland areas shall have a clear open width of the access road.
Parking of vehicles shall not obstruct any entrance, or the operation of any gate installed per the requirements of SBCFPD. “NO PARKING” signs designed and installed in accordance with SBCFPB Standard A-2 may by required as directed by SBCFPD.
When required by SBCFPD, entry gates shall be installe d to provide a minimum of forty feet (40’) of fire apparatus stacking from the intersecting road.

Electrically Operated Security Gates
Electrically operated security gates at multifamily residential properties (apartments, gated housing tracts, etc.) shall be equipped with an emergency preemption device, or an automatic means of opening the gate for emergency access by SBCFPD. The location and type of emergency opening devices shall be approved

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by the SBCFPD and may include Opticom, or equivale nt sensors and/or Knox key switches as deemed necessary by SBCFPD.
Any preemption devices on electric gates shall override all normal gates operations and completely open the gate(s). After preemption devices are activated, ga tes shall be maintained in an open position for a minimum of twenty (20) minutes, after which the gate controller shall automatically reset and close the gates.
All electric motors operation security gates that obs truct fire apparatus access roadways or systems shall be listed in accordance with ASTM F2200 and UL 325 and shall reach the fully open position within a total time not to exceed one second for each one foot of obstructed required width. A safety loop or device that prevents the gate from closing on vehicles going through the gate shall be installed on all electric gates.
An automatic exit loop that activates the gate in the direction of egress shall be installed on all electric gates, or an additional preemption device/Knox swit ch may be installed in the direction of emergency vehicle egress with approved by SBCFPD.

Electric gates without battery backup power shall be provided with a manual release to allow the gate to be operated manually when electrical service is interrupted.

5.1.3 Premises Identification
Identification of roads and structures will comply with SB CFPD Fire Prevention Standard Building and Premises Identification (SBCFPD Standard B-1) as follows:
The address identification shall be legible and affixed to the building and placed in a position that is visible from the street or fire department access road fronting the property. All address identification characters shall contrast with their background. Address identification shall be Arabic numerals or alphabetical letters. Numbers shall be spelled out. Each character shall not be less than eight inches (8”) high with a minimum stroke width of one inch (1”). During the hours of darkness, they shall be electrically illuminated with an internal low voltage light source. Where building setbacks exceed 200 feet from the street, or where a ddress identification would not be visible or would otherwise be obstructed, additional non-illuminated address identification shall be displayed on a monument, sign or other approved me ans used to identify structures. Additional address identification characters shall not be less than six in ches (6”) in height, with a minimum stroke width of three-quarter inches (3/4”).
Where required, address identification shall be provided in additional approved locations to facilitate emergency response.
Address identification shall be maintained.
Buildings which have vehicular access to the rear side by means of a drive aisle, alley, or parking lot shall also display address identification meeting the minimu m requirements of this Standard on the rear of the building

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5.1.4 Ongoing Infrastructure Maintenance
The Project BOA and/or Property Manager(s) shall be responsible for long term funding and maintenance of internal private roads, communal fuel modification zones, and fir e protection systems (including fire sprinklers). The maintenance responsibilities of fuel modification zones a nd defensible space are discussed in more detail in section 5.4.

5.1.5 Pre-Construction Requirements
Prior to bringing lumber or combustible materials onto the site, site improvements within the active development area shall be in place, including utilities, operable fire hydrants, an approved, temporary roadway surface, and fuel modification zones established. These features shall be approved by the fire department designee prior to combustibles being brought on-site. Any combustible scra p materials will be noticed on a daily basis or more frequently, as required by the SBCFPD.

5.2 Infrastructure and Fire Protection Systems

5.2.1 Water Supply
Water service for Project site will be provided by San Bernardino County Municipal Water District, Division 1 17 (SBCMWD). All water storage and hydrant locations, mains, and water pressures would be designed to fully comply with SBCFPD Fire Flow Requirements. As detailed in th e SBCFPD Fire Code Section 507 and California Fire Code Section 903.2, all residential structures are required to have NFPA 13D property protection internal fire sprinklers.

Therefore, water supply must meet a two-hour fire flow requirement.

The water supply will be capable of supplying the required fire flow for fire protection and sized according to the applicable codes and design standards. An SBCFPD official wi ll be notified prior to a water supply test or provided with approved documentation before approval of the water supply system (CFC Section 507.4).

5.2.2 Hydrants
Fire Hydrant systems shall comply with SBCFPD Fire Code 507.5.1 through 507.5.6 and SBCFPD Fire Prevention Standards.

5.2.3 Automatic Fire Sprinkler Systems
Fire sprinklers systems shall be in accordance with SBCFPD Fire Prevention Standard Fire Sprinkler Systems in Non-Residential Buildings (SBCFPD Standard F-1), and Nati onal Fire Protection Association (NFPA) Standard 13.

Fire sprinkler plans for each structure will be submitted and reviewed by SBCFPD for compliance with the applicable fire and life safety regulations, codes, and ordinances as well as the SBCFPD Standard F-1. 17 https://open.sbcounty.gov/datasets/c84c98f3562e497db74ab82af4c1c6a7/explore?location=34.091056%2C- 117.329611%2C11.53

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5.3 Ignition Resistant Construction and Fire
Protection Systems
All new structures within the Project site will be constructed to Fire Code standards. Each of the proposed buildings will comply with the enhanced ignition-resistant cons truction standards of the 2022 CBC (Chapter 7A). These requirements address roofs, eaves, exterior walls, vents, appendages, windows, and doors and result in hardened structures that have been proven to perform at high leve ls (resist ignition) during the typically short duration of exposure to burning vegetation from wildfires. Appendix D, Ignition-Resistant Construction Requirements provides a summary of the requirements for ignition resistant construction.

While these standards will provide a high level of protection to structures in this development, there is no guarantee that compliance with these standards will prevent damage or destruction of structures by fire in all cases.

There are three primary concerns for structure ignition: 1) radiant and/or convective heat, 2) burning embers, and 3) direct flame impingement (NFPA 1144 2008, IBHS 2008, and others). Burning embers have been a focus of building code updates for at least the last decade, and new structures in the Wildland Urban Interface (WUI) built to these codes have proven to be very ignition resist ant. Likewise, radiant, and convective heat impacts on structures have been minimized through Chapter 7A exterior fire ratings for walls, windows, and doors. Additionally, provisions for modified fuel areas separating wildland fuels from structures have reduced the number of fuel-related structure losses. As such, most of the primary components of the layered fire protection system provided the Project are required by the SBCFPD but are worth listing because they have been proven effective for minimizing structural vulnerability to wildfire and, with the inclusion of requ ired NFPA 13D automatic interior fire sprinklers within all residential buildings for extinguishing interior fires, shoul d embers succeed in entering a structure. Even though these measures are now required by the latest Building and Fire Codes, at one time, they were used as mitigation measures for buildings in WUI areas, because they were known to reduce structure vulnerability to wildfire. These measures performed so well; they were adopted into the code. The following Project features are required for new development in WUI areas and form the basis of the system of protection necessary to minimize structural ignitions as well as providing adequate access by emergency responders:

1. The 7A Materials and Construction Methods for Exterio r Wildfire Exposure CBC chapter details the ignition resistant requirements for the following key components of building safely in wildland urban interface and fire hazard severity zones:
a. Roofing Assemblies (covering, valleys and gutters)
b. Vents and Openings
c. Exterior wall covering
d. Open Roof Eaves
e. Closed Roof Eaves and Soffits
f. Exterior Porch Ceilings
g. Floor projections and underfloor protection
h. Underfloor appendices
i. Windows, Skylights and Doors
j. Decking
k. Accessory structures

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2. New class-A fire rated roof and associated assembly. Wi th the proposed class-A fire rated roof, areas where there will be attic or void spaces requiring ventilat ion to the outside environment, the attic spaces will require either ember-resistant roof vents or a minimum 1/16-inch mesh (smaller sizes restrict air flow) and shall not exceed 1/8-inch mesh for side ventilatio n (recommend Vulcan, BrandGuard, O’Hagin or similar vents. Structures along the perimeter of the developm ent shall not have any vents on the side of the structures that face the fuel modification zones and/or off-site vegetation areas. All vents used for this Project will be approved by SBCFPD.

3. Per Chapter 7A of the CBC, for s tructures that achieve the minimum 100 feet of on-site fuel modification, all exterior windows, skylights, and exterior glazed door assemblies shall be constructed of multipaned glazing with a minimum of one tempered pane. All windows shall be UL listed, not of vinyl construction, and shall have a fire-resistant rating of not less than 20 minutes when tested according to NFPA 257/UL 263 (such as SaftiFirst, SuperLite 20-minute rated glass product), or be tested to meet the performance requirements of State Fire Marshal Standard 12-7A-2.

4. The proposed Project structures would be constructed of ignition resistant 18 construction materials and include the installation of National Fire Protection Association (NFPA) 13D automatic interior fire sprinkler systems within all residential buildings, based on the latest adopted Building and Fire Code requirements for each occupancy type.

5. Modern infrastructure, access roads, and water delivery system.

5.4 Defensible Space and Vegetation Management
WUI fire protection requires a systematic approach, whic h includes the components of infrastructure and water, structural safeguards (addressed in the FPP), and adequate defensible space setbacks. A critical component of a fire protection system for this Project is the provision for ignition-resistant landscapes. A fuel modification zone (FMZ) is a strip of land where combustible vegetation ha s been removed and/or modified and partially or totally replaced with more adequately spaced, drought-tolerant, fire resistant plants in order to provide a reasonable level of protection to structures from wildland fire. FMZs are designed to provide vegetation buffers that gradually reduce fire intensity and flame lengths from advancing fire by s trategically placing thinning zones, restricted vegetation zones, and irrigated zones adjacent to each other on the perimeter of the WUI exposed structures.

Cohen (1995) performed structure ignition fire research studies that suggest, as a rule-of-thumb, larger flame lengths and widths require wider fuel modification zones to reduce structure ignition. For example, valid Structure Ignition Assessment Modeling results indicate that a 20 -foot-high flame has minimal radiant heat to ignite a structure (bare wood) beyond thirty-three feet (horizonta l distance). Whereas a 70-foot-high flame requires about 130 feet of clearance to prevent structure ignitions from radiant heat (Cohen and Butler 1996). For this fire study example, bare wood was used, which is more combustible u nlike the ignition-resistant construction of the Project.

For the Project, assuming 42-foot flame lengths (mode led under a Santa Ana wind gust), the 100 feet of fuel modification is more than sufficient.

Based on the modeled extreme weather flame lengths for th e Project site once developed and FMZs are in place, wildfire flame lengths are projected to be approximat ely between 1 and 3 feet in height within the areas of the Project Footprint that are not paved (the well-maintained irrigated areas of the development). The adjacent sage 18 A type of building material that resists ignition or sustained flaming combustion sufficiently to reduce losses from wildland-urban interface conflagrations under worst-case weather and fuel conditions with wildfire exposure of burning embers and small flames, as prescribed in CBC, Chapter 7A and State Fire Marshal Standard 12-7A-5, Ignition-Resistant Materials.

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scrub intermixed with non-native grasslands would remain unaltered and retain the fire behavior of existing conditions. This can be altered when neighboring prope rty owners perform weed abatement. The fire behavior modeling system used to predict these flame lengths was not intended to determine su fficient FMZ widths, but it does provide the average predicted length of the flames, which is a key element for determining “defensible space” distances for providing firefighters with room to work and minimizing structure ignition. Due to site constraints, it is not possible to achieve a minimum 100 feet of on-site fuel modification width for every building on the Project site.

Areas of the development that do not achieve the requir ed minimum 100 feet of defensible space on site will provide off site equivalent defensible space and FMZs or provide a non-combustible, six-foot heat-deflecting wall.

5.4.1 San Bernardino County Fuel Modification Zone Standards and Defensible Space
Defensible space, coupled with property hardening, is essential to improve a building’s chance of surviving wildfire.

Defensible space is the buffer created between a building and the grass, trees, shrubs, or any wildland area that surrounds it. This space is needed to slow or stop the spread of wildfire, and it helps protect buildings from catching fire—either from embers, direct flame co ntact or radiant heat. Proper defensib le space also provides firefighters with a safe area to work in, to defend the building. The purpose of this section is to document SBCFPD’s standards and make them available for reference. SBCFPD’s Fire Co de are consistent with the 2022 California Fire Code (Section 4907 — Defensible Space), Government Code 51 175 – 51189, and Public Resources Code 4291, which require that fuel modification zones be provided aroun d every building that is designed primarily for human habitation or use within an SRA or a LRA VHFHSZ.

FMZ and Defensible Space, when properly maintained, along with other fire hazard reducing features, will effectively minimize the potential for structure ignition from direct flame impingement or radiant heat within the Project area.

Assembly Bill 3074, passed into law in 2020, requires a third zone for defensible space. This law required the Board of Forestry and Fire Protection to develop the regulation for a new ember-resistant zone (Zone 0) within 0 to 5 feet of the home by January 1, 2023. The intensity of wildfire fuel management for a traditional FMZ varies within the 100-foot perimeter of the structure, with more intense fu els’ reduction occurring closer to the structure. A Fuel Modification Plan shall be reviewed and approved by a SBCFPD Fire Safety Specialist for consistency with defensible space and fire safety guidelines. The Project’s Fuel Modification Plan — Parcel 1 (Figure 6) conceptually displays a non-combustible and fully irrigated FMZ area for the Project site.

To ensure long-term identification and maintenance, a fuel modification area shall be identified by a permanent zone marker meeting the approval of SBCFPD. All mark ers will be located along the perimeter of the fuel modification area at a minimum of 500 feet apart or at any direction change of the fuel modification zone boundary.

This applies only to the on-site FMZ areas and would not be provided off-site on roadways and similar landscapes that are providing FMZ equivalent. FMZs will be maintained on at least an annual basis or more often as needed to maintain the fuel modification buffer function.

5.4.2 San Bernardino County Fuel Modification Zones
The Fuel Modification Zones affect new structures and developments built in the high fire hazard areas. A plan shall be approved by the SBCFPD that helps protect develo pments by requiring vegetati on planted in zones around structures to be selected from an approved list and iden tifies areas that require brush clearance or thinning. The entire property from the exterior of the building to th e property lines will be eith er irrigated landscaping or

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non-combustible paved surfaces in the form of roads, wa lkways, parking areas, and loading and unloading areas.

The landscaping requirements for each zone is described below.

ZZONEE “O”” –– Emberr Resistantt Zonee
Zone 0 applies around all project structures. The first fi ve (5) feet from the home is the most important for preventing ember ignition. Keeping the area closet to bu ildings, structures, and decks clear will prevent embers from igniting materials that can spread the fire to the structure.

The majority of homes lost to wildfire are ignited by flying embers. Embers can travel miles ahead of the active front of wildfires.

What to do:

1. Use hard scape like gravel, pavers, or co ncrete. No combustible bark or mulch.

2. Remove all dead and dying plants, weeds, debris (leave s, needles, etc.) from your roof, gutter, deck, porch, stairways, and under any areas of your home.

3. Remove all branches within ten feet (10’) of any chimney or stovepipe outlet.

4. Limit combustible items (like outdoor fu rniture and planters) on top of decks.

5. Relocate firewood and lumber to Zone 2.

6. Replace combustible fencing, gates, and arbors atta ched to the homes with noncombustible alternatives.

7. Consider relocating garbage and recy cling containers outside this zone.

8. Consider relocating boats, RV’s vehicles, an d other combustible items outside this zone.

ZONEE “1”” –– “Wett Zone”” Keepp itt Lean,, Cleann andd Greenn withinn 300 feett off structures..

Zone 1 applies to all project structures and facilities incl uding parks and retention basins. Regularly clear dead or dry vegetation and create space between trees. Vegetation to be irrigated. During drought times when watering is limited, pay special attention to clearing dead or dying material. Removing dead plants and creating space between trees and shrubs creates a buffer on the property and reduces potential fuel for fire.

What to do:

1. Remove all the dead plants, grass, and weeds.

2. Remove dead or dry leaves and pine needles.

3. Trim trees regularly to keep branches at a minimum of ten feet (10’) from structures.

4. Plantings should be limited to well irrigated, well -spaced low fuel volume, high fuel moisture, drought tolerant, low profile fire resistive groundcover, shrubs or lawn

5. Spacing between shrubs should be two times the height of the shrub. Trees shall be limbed and pruned 1/3 of the height or six feet (6') from ground, spacing shall be thirty feet (30') for mature trees.

6. Create a separation between trees, shrubs, and items th at could catch fire, such as patio furniture, wood piles, swing sets, etc.

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ZZONEE “2”” 31-1000 feett fromm structures..

Zone 2 applies around all project structures beginning at the edge of Zone 1 (30 feet) and continuing outwards up to 100 feet. Zone 2 treatments continue to reduce potential fuel within 100 feet of structures. 100 feet of defensible space is required by Public Resource Code (PRC) 4291.

What to do:

1. Manufactured slopes and landscape plantings to be well-irrigated.

2. Natural vegetation should be maintained to have horizontal space between shrubs and trees and vertical space between grass, shrubs, and trees. Spacing between shrubs should be two times the height of the shrub. Trees shall be limbed and pr uned 1/3 of the height or six feet (6') from ground, spacing shall be thirty feet (30') for mature trees.

3. Maintain all vegetation free of deadwood.

4. Cut or mow annual grass down to maximum height of four inches (4”), no dry grass is allowed.

5. Remove fallen leaves, needles, twigs, bark, cones, and small branches. However, they may be permitted as mulch to a depth of three inches (3”).

6. Keep ten feet (10’) of clearance around exposed wood piles, down to bare mineral soil, in all directions.

7. Clear areas around outbuildings and propane tanks. Keep ten feet (10’) of clearance to bare mineral soil and no flammable vegetation for an additional ten feet (10’) around the exterior.

ZONEE “3”” 1000 feett fromm Propertyy Linee measuredd inwardss towardss project..

Zone 2 applies between the Project and unmaintained open space measured from the Property Line 100 feet inward. Remove and reduce fuel from a potential fi re pathway from unmaintained open space towards the structures.

What to do:

1. Manufactured slopes and landscape plantings to be well-irrigated.

2. Interrupt continuous fuel beds by providing horizont al space between shrubs and trees and vertical space between grass, shrubs, and trees. Spacing between sh rubs should be two times the height of the shrub, with twenty feet (20’) between large groupings of shrubs or trees. Trees shall be limbed and pruned 1/3 of the height or six feet (6’) from ground, spacing shall be thirty feet (30') for mature trees.

3. Maintain all vegetation free of deadwood.

4. Cut or mow annual grass down to maximum height of four inches (4”), no dry grass is allowed.

5. Remove fallen leaves, needles, twigs, bark, cones, and small branches. However, they may be permitted as mulch to a depth of three inches (3”).

6. Keep ten feet (10’) of clearance around exposed wood piles, down to bare mineral soil, in all directions.

7. Clear areas around outbuildings and propane tanks. Keep ten feet (10’) of clearance to bare mineral soil and no flammable vegetation for an additional ten feet (10’) around the exterior.

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5.4.3 Ongoing Infrastructure and FMZ Maintenance
Vegetation management, i.e., assessment of fuel modification zone conditions and removal of dead and dying and undesirable species; as well as thinning as necessary to maintain specified plant spacing and fuel densities, shall be completed annually by May 1 of each year and more often as needed for fire safety. The Project’s BOA and/or Property Manager shall be responsible for all fuel modification vegetation management in compliance with the plan and the SBCFPD requirements for all areas of the Project site, including fuel modification zones. The Project’s BOA and/or Property Manager will assure lots comply with th e plan initially and on an ongoing basis. Chapter 7A requirements for ongoing maintenance of fire-resistive building materials and fire sprinkler systems will be maintained to a code-complying level, as-approved in th is or similar documents, in perpetuity. Additionally, the Project’s BOA and/or Property Manager shall be responsible for ensuring long-term funding and ongoing compliance with all provisions of the FPP, including vegetation plan ting, fuel modification on the perimeter, and maintenance requirements on all communal areas and roadsides.

Maintenance of FMZ’s and Defensible Space is a critical component for the long-term fire safety of the Project. maintenance obligations will be as follows:
All future plantings shall be in accordance with SBCFPD fuel modification requirements. The SBCFPD will review landscape plans and provide corrections where necessary so that they are in compliance with SBCFPD standards.
Changing landscaping in communal areas will be reviewed by the SBCFPD and approved prior to installation.

PProject’ss BOAA and/orr Propertyy Manager::
The Project’s BOA and/or Property Manager will ma intain the access roads within the Development Footprint adjacent to open space areas.
The Project’s BOA and/or Property Manager will be required to annually maintain the FMZs (or as needed). The Project’s BOA and/or Property Manager will maintain all communal areas, including trees planted along internal roadways and in other areas throughout the Project.

5.4.4 Construction Phase Vegetation Management
Vegetation management requirements shall be implemen ted at commencement and throughout the construction phase. Vegetation management for the Project area shall be performed pursuant to the FPP and FAHJ on all building locations prior to the start of work and prior to any impo rt of combustible construction materials. Adequate, code complying, fuel breaks shall be created around all grading, site work, and other construction activities in areas where there is flammable vegetation. Fuel Modificatio n Zones will be maintained, as approved, throughout construction and in perpetuity thereafter. Caution must be used not to cause erosion or ground (including slope) instability or water runoff due to vegetation removal, vegetation management, maintenance, landscaping, or irrigation. Combustible materials will not be brought on-site without prior fire department approval.

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5.5 Pre-Construction Defensible Space Requirements
Per SBCFPD, a fuel modification plan (ref er to Figure 6) shall be submitted an d have preliminary approval prior to any subdivision of land; or, have final approval prior to the issuance of a permit for any permanent structure used for habitation; where, such structure or subdivision is lo cated within areas designated as a Fire Hazard Severity Zone within SRA or within the LRA. An on-site inspection must be conducted by the SBCFPD, and final approval of the fuel modification plan issued prior to a certificate of occupancy being granted by the building code official.

As an additional consultant recommendation, prior to br inging lumber or combustible materials onto the Project site, improvements within the active development area shall be in place, including utilities, operable fire hydrants, an approved, temporary roadway surfac e, and fuel modification zones established. As demonstrated in Figure 6, Fuel Modification Plan — Parcel 1 , there are some areas where 100 feet of Fuel Modification cannot be achieved on site. This section allows for a conservative fire analysis of the Project area.

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SOURCE: AERIAL-ESRI IMAGERY 2022; DEVELOPMENT-KIMLEY-HORN 2025 0 150 75
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Parcel 1

Project Site - Parcel 1
Property Line
Grading Limits
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Development
Roadway Access
Access Road
Emergency Vehicle Access
Water Quality Basin
Fuel Modification Zone
Zone 0 (0-5 ft)
Zone 1 (5-30 ft)
Zone 2 (30-100 ft)
Zone 3 Property line (PL) to 100 ft inward
0-100-ft (Water Tank)
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FIGURE 6 - View 1
Fuel Modification Plan - Parcel 1
Fire Protection Plan - University Hills Project

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FIGURE 6 - View 4
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Zone 2 (30-100 ft)
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0-100-ft (Water Tank)
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FIGURE 6 - View 5
Fuel Modification Plan - Parcel 1
Fire Protection Plan - University Hills Project

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6 Wildfire Education Program
Early evacuation for any type of wildfire emergency at th e Project site is the preferred method of providing for employees and customer safety, consistent with the SBCFPD’s current approach. As such, the Project’s BOA and/or Project’s Property Manager would formally adopt, practic e, and implement a “Ready, Set, Go!” approach to evacuation19. The “Ready, Set, Go!” concept is widely known an d encouraged by the State of California and most fire agencies. Pre-planning for emergencies, including wi ldfire emergencies, focuses on being prepared, having a well-defined plan, minimizing the potential for errors, main taining the Project site’s fire protection systems, and implementing a conservative (evacuation as early as possibl e) approach to evacuation and Project area activities during periods of fire weather extremes.

Project occupants would be provided ongoing education by the BOA/Property Management regarding wildfires and the FPP’s requirements. The educational information mu st include maintaining the landscape and structural components according to the appropriate standards de signed for the development. Informational handouts, website pages, mailers, fire-safe council participation, inspections, and seasonal reminders are some methods that would be used to disseminate wildfire and relocation awareness information. SBCFPD would review and approve all wildfire educational material and programs before printing and distribution.

Additionally, management of on-site entities occupying the site’s structures will be required to register for Countywide alerts via the Telephone Emergency Notifica tion Systems (TENS) and Sa n Bernardino Ready App (SB Ready)20. Personnel and employees will be strongly encouraged to also register to receive emergency alerts.

6.1 Recognition for Fire Safety and Maintaining
Fire Insurance
Insurance companies have begun to assess communities ag ainst guidelines above and beyond the fire code and local standards documented within this FPP. Due to th e heightened standard assessed by the insurance industry, homeowners and communities have been dropped from insurance or have experienced rate increases despite complying with the minimum codes and standards.

The Firewise USA program administered by NFPA is a certification program for communities to gain recognition for the fire-wise design and maintenance of their community. Fi rewise USA began in 2019 with seven sites that were challenged to improve the fire resilience of their commun ities through a focused approach to active wildfire risk reduction. This is done through a collaborative framework created to empower neighbors to get organized and take action to reduce wildfire risk at a local level. The progra m has grown to include over 1.5 million residents living in Firewise USA communities (Firewise USA, n.d.a). The insurance industry, due to Department of Insurance Regulation #REG-2020-00015, is required to recognize the Firewise certification and consider it when it comes to determining if a community is insurable; cuts to insurance premiums have been made based on this certification. Given the established framework of Firewise USA, its direct mentio n in regulatory language, and its existing adoption by multiple insurance companies, it can be reasonably an ticipated that more companies will require the same certification from customers that attempt to pursue discounted policies. 19 https://www.sbcounty.gov/uploads/SBCFire/documents/programs/20231130_sbcfire_ready_set_go_flyer.pdf 20 https://sbcfire.org/alertwarning/

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There are several requirements to be come a Firewise USA community and mu ltiple living documents must be prepared. Firewise USA communities must have a minimum of 8 dwelling units and a maximum of 2,500, meaning the proposed Project, in its entirety, would be able to pa rticipate in the program (Firewise USA, n.d.b). To become certified, a board or committee of volunteers made up of residents and partners such as a representative of the local FD would first need to be formed. A community wild fire risk assessment (CWRA) would then need to be completed, either independently or with assistance from a third-party consultant such as Dudek. The CWRA would need to be updated at least every five years. From th e CWRA, a three-year action plan would be created that prioritizes risk reduction actions to be taken within th e community and would need to be updated at least every three years. Every year, a worksheet would need to be filled out compiling the volunteer hours performed towards the goals outlined in the three-year action plan. One volunt eer hour is required to be performed per dwelling unit within the community, or an investment of monetary equivalent in mitigation efforts can be made in lieu of volunteer hours (Firewise USA, n.d.b).

In addition to the Firewise certification, the community can hire a qualified individual such as Dudek to assess the community regularly to document compliance with not o nly the fire code but the insurance industry minimums.

Wildfire Risk Assessments have proven valuable in helping communities maintain fire insurance or even apply for reduced premiums, given that the insurance industry evaluates fire resistant features above and beyond what the fire code requires.
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7 Conclusion
This FPP for the University Hills Project provides guidance for vegetation maintenance for the landscaped areas on the Project site. As described, vegetation maintenance meas ures will be provided on all landscaped areas of the proposed Project. The requirements and recommendations provided in this FPP have been designed specifically for the Project. This analysis and its fire protection justificat ions are supported by fire science research, results from previous wildfire incidents, and fire agencies that ha ve approved these concepts. The fire protection system provided for the Project site includes a redundant layering of code-compliant, fire-resistant construction materials and methods that have been shown through post-fire da mage assessments to perform extremely well against wildfire and ember storm conditions. To address areas where the Project is un able to meet the Fire Code due to site constraints, code-exceeding measures have been suggest ed to meet the intent of the provisions of the Fire Code. The use of these methods and materials along with ongoing maintenance will result in a development that will be highly defensible with minimal firefighting resource demands. It is Dudek’s professional opinion that this project, like any project built to the most recent fire safe ty code requirements, will not be vulnerable to fire losses experienced by older, less ignition resistant projects and the Project is considered to represent a low wildfire risk to its occupants based on its ability to provide for evacuations. It is necessary to understand that Projects occurring within fire hazard severity zones and wildland urban inte rface areas with higher potential fire hazards represent lower overall fire safety risk when the buildings and communi ty are built to ignition resistant levels as required by code. Conversely, older communities that do not include th e ignition resistant strategies may occur in a location that represents lower potential fire hazards outside of a fi re hazard severity zone or wildland urban interface but may actually be at higher overall fire risk due to the vulnerabilities inherent in their construction.

Ultimately, it is the intent of this FPP to guide the fire protection efforts for the Project in a comprehensive manner.

Implementation of the measures detailed in this FPP will reduce the risk of wildfire spreading from the Project site into surrounding areas and will improve the ability of firefighters to fight fires on the Project property and neighboring properties and resources, irrespective of the cause or location of ignition.

Note that this is a conceptual plan, which provides enoug h detail for SBCFPD’s approval. Detailed plans, such as improvement plans and building permits, demonstrating compliance with the concepts in the FPP and with City and County Fire Code requirements, would be submitted to SBCF PD at the time they are developed. Fire is a dynamic and somewhat unpredictable occurrence and as such, this FPP does not guarantee that a fire will not occur or will not result in injury, loss of life, or loss of property. There are no warranties, expressed or implied, regarding the suitability or effectiveness of the recommendations and requirements in this FPP, under all circumstances.

The Project’s developers, contractors, engineers, and architects are responsible for the proper implementation of the concepts and requirements set forth in the FPP. The Project’s BOA and/or property managers are also responsible for maintaining their structures and lots, including fuel modification and landscape, as required by this FPP, the SBCFPD, and as required by the City and County Fi re Codes. Alternative methods of compliance with this FPP can be submitted to the fire authority for consideration.

It will be extremely important for all employees, the Pr oject’s BOA and/or property managers, and occupants to comply with the recommendations and requirements descri bed and required by the FPP on their property. The responsibility to maintain the fuel modification and fire protection features required for the Project site lies with the Project’s BOA, and/or Property Manager or similar en tity. Said the responsible party would oversee ongoing education and maintenance of the communal areas, and the SBCFPD would enforce the vegetation management

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requirements detailed in this FPP. Such requirements would be made as part of deed encumbrances and CC&Rs for each lot, as appropriate.

It is recommended that the University Hills Project maintain a conservative approach to fire safety. This approach must include maintaining the landscape and structural components according to the appropriate standards and embracing a “Ready, Set, Go!” stance on evacuation. Th e Project is not to be considered a shelter-in-place development. However, the fire agencies and/or law enforcement officials may, during an emergency, as they would for any new development providing the layers of fire prot ection as the Project, determine that it is safer to temporarily refuge employees or visitors on the Project site. When an evacuation is ordered, it will occur according to pre-established evacuation decision points or as s oon as notice to evacuate is received, which may vary depending on many environmental and other factors. Fire is a dynamic and somewhat unpredictable occurrence, and it is important for anyone living at the WUI to educate themselves in practices that will improve safety.

The goal of the fire protection features, both required and those offered beyond the Codes, provided for the Project is to provide the structures with the ability to survive a wi ldland fire with little intervention of firefighting forces.

Preventing ignition to structures results in a reduction of the exposure of firefighters and occupants to hazards that threaten personal safety. It will also reduce property damage and losses. Mitigating ignition hazards and fire spread potential reduces the threat to structures and can help the fire department optimize the deployment of personnel and apparatus during wildfire. The analysis in this FPP pr ovides support and justifications for acceptance of the proposed fuel modification zones for the proposed Project Development Footprint based on the site-specific fire environment.

This plan is intended to outline the generally accepted prot ocols which it is anticipated will be designed and, as appropriate, refined by SBCFPD at the appropriate time(s ) into the final site-specific plan for the University Hills Project. Inasmuch as fire is a dynamic and often unpredic table occurrence, it cannot be guaranteed that, despite precautionary measures, a fire will not occu r or that it will not result in injury, loss of life, or damage to or loss of property. No warranties expressed or implied are made herein, notwithstanding that the goal remains to identify a suite of appropriate measures calculated, to the extent feasible under the circumstances, which would mitigate the potential for such injury or damage. Although the SBCF PD may determine to recommend, or mandate, particular ameliorative measures in advance, the responsibility to react to and implement suitable fire protection features required for the project site lies with the Project’s BO A and/or Property Manager. In the event the Project’s HOA and/or Property Management Company undertakes ongoing education and maintenance of the communal areas, this would be additive and support the common mission.

Likewise, the SBCFPD may elect to develop and/or im plement enforcement of vegetation management requirements. It is common to plan for these contingencie s by adopting a “Ready, Set, Go” stance on emergency response (whether fire, earthquakes, flooding, chemical sp ills, etc.) and on dislocation or evacuation, along with other components discussed below, where appropriate. Experience garnered from other situations tends to support that “shelter-in-place” may be, but is not always, the pr eferred option. Fire and/or law enforcement officials may, during an emergency, determine that it is safer to temporarily refuge residents on-site. Again, where evacuation is ordered, ideally it will align with pre-established evacu ation decision-tree points. Meetings and even drills are considered beneficial to augment the preparedness of owners, occupants, workers, and other potentially affected persons within the development for an incident that could occur with little or no warning.

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LLimitationn Onn Reliancee Orr Dependencee Uponn Reportt Any person or entity furnished with this report and/or who reviews it agrees that the advance written consent of Dudek be sought and furnished to such person or entity prior to the review, reliance or authorization as to any matters that are the subject of the reports by any person or entity (whether through act or omission as set forth in the report), other than Dudek’s direct client. In such case, obtaining Dudek’s consent shall not be subject to any fee or charge (other than reasonable copy costs, where applicable).

Dudek expressly disavows, does not assume any responsib ility for, nor will be liable for any claims, losses, or damages associated with any matters that are the subject of this or other reports it prepares or contributes to respecting this project, however characterized (including without limitation as sounding in tort, breach of contract, misrepresentation by act or omission, failure to adhere to applicable standards of professionalism, statutory liability, etc.), whether in law or equity, whether kno wn or unknown, and whether actual or contingent, excepting only Dudek’s direct client, as to which the limitation of liability provisions in the contract between Dudek and its client shall govern.

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8 List of Preparers
PProjectt Managerr andd Sitee Visitt
Austin Ott
Fire Protection Planner V
Dudek
Firee Behaviorr Modelingg
Doug Nickles
Fire Protection Planner V
Dudek
Firee Plann Preparerr
Dave Stimson
Fire Protection Planner II
Dudek
GISS Analystt andd Mappingg
Rachel Strobridge
Geospatial Analyst
Dudek

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Syphard AD, Radeloff VC, Keuler NS, Taylor RS, Hawbaker TJ, Stewart SI, Clayton MK (2008) Predicting spatial patterns of fire on a southern California landscape. International Journal of Wildland Fire 17, 602–613. doi:10.1071/WF07087
Syphard, Alexander D, Volker C Radeloff, Jon E. Keeley, Todd J. Hawbaker, Murray K. Clayton, Susan I. Stewart, Roger B. Hammer. 2007. Human Influence on California Fire Regimes. Ecological Applications. https://doi.org/10.1890/06-1128.1
Syphard AD, Bar Massada A, Butsic V, Keeley JE (2013) Land use planning and wildfire development policies influence future probability of housing loss. PLoS ONE 8(8), e71708. doi:10.1371/JOURNAL.

PONE.0071708
Syphard, Alexandra D. and Jon E. Keeley. 2015. Location, timing, and extent of wildfire vary by cause of ignition.

International Journal of Wildland Fire. 11 pp.

Syphard, Alexandra & Brennan, Teresa & Keeley, Jon. (2014). The role of defensible space for residential structure protection during wildfires. International Journal of Wildland Fire. 23. 1165-1175.

10.1071/WF13158.

Syphard, Alexandra & Keeley, Jon & Massada, Avi & Brennan, Teresa & Radeloff, Volker. (2012). Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildfire. PloS one. 7. e33954. 10.1371/journal.pone.0033954.

Syphard, A.D. and Keeley, J.E., 2016. Historical reconstructions of California wildfires vary by data source. International Journal of Wildland Fire, 25(12), pp.1221-1227.

Wang, H.H., Finney, M.A., Song, Z.L., Wang, Z.S. and Li, X.C., 2021. Ecological techniques for wildfire mitigation:

Two distinct fuel break approaches and their fusion. Forest Ecology and Management, 495, p.119376.

Warziniack, T., Champ, P., Meldrum, J., Brenkert-Smith, H., Barth, C.M. and Falk, L.C., 2019. Responding to risky neighbors: testing for spatial spillover effects for defensible space in a fire-prone WUI community. Environmental and Resource Economics, 73, pp.1023-1047.

Weather Spark. 2023. Climate and Average Weather Year-Round in San Bernardino, San Bernardino Climate, Weather By Month, Average Temperature (California, United States) - Weather Spark Weise, D.R. and J. Regelbrugge. 1997. Recent chaparral fuel modeling efforts. Prescribed Fire and Effects Research Unit, Riverside Fire Laboratory, Pacific Southwest Research Station. 5p.

Zhou, A. 2013. Performance evaluation of ignition-resistant materials for structure fire protection in the WUI. Fire and Materials 2013 - 13th International Conference and Exhibition, Conference Proceedings, January 2013, 355–366.

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INTENTIONALLY LEFT BLANK

Appendix A
Representative Photo Log

UNIVERSITY HILLS (2/24/2025)
ATTACHMENT 1

PHOTO LOG

PHOTO LOCATION KEY

1: IMG 0476-
0483
2: IMG 0485-
0492
3: IMG 0494-
0501
4: IMG 0503-
0510

Picture 1: IMG 0477 Taken at the southwest corner of the Project along Badger Canyon Road looking northeast over the Project area. Topography slopes upwards to north. VegetaƟon is dense 4-5-foot-tall shrubs.

Picture 2: IMG 0481 Taken at the southwest corner of the Project along Badger Canyon Road looking southwest away from the Project area. Some shrub vegetaƟon is present on the other side of the wash visible in the picture.

Picture 3: IMG 0509 Taken at the eastern boundary of the Project area looking west over the Project area. Topography slopes upwards towards the north. VegetaƟon on-site is 4-5-foot-tall dense shrubs.

Picture 4: IMG 0506 Taken at the eastern boundary of the project site looking east away from the project area.

Topography slopes downwards towards the south and east. VegetaƟon on and oﬀ-site is 4-5-foot-tall dense shrubs.

Appendix B
Fire History Map

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SOURCE: BASE MAP- ESRI MAPPING SERVICE; FIRE DATA-CALFIRE 2023 02 1
Miles

Date: 6/10/2025 - Last saved by: cgardner - Path: Z:\Projects\j1442800\MAPDOC\UniversityHills_Fire.aprx

APPENDIX B
Fire History Map
Fire Protection Plan - University Hills Project

Appendix C
BehavePlus Fire Behavior Modeling Summary

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1 BehavePlus Fire Behavior
Modeling History
Fire behavior modeling has been used by researchers for approximately 50+ years to predict how a fire will move through a given landscape (Linn 2003). The models have had varied complexities and applications throughout the years. One model has become the most widely used as the industry standard for predicting fire behavior on a given landscape. That model, known as “BEHAVE,” was developed by the U. S. Government (USDA Forest Service, Rocky Mountain Research Station) and has been in use since 1984. Since that time, it has undergone continued research, improvements, and refinement. The current version, Behave Plus 6.0, includes the latest updates incorporating years of research and testing. Numerous studies have been completed evaluating the validity of the fire behavior models’ ability to predict fire behavior given site specific inputs. One of the most successful ways the model has been improved has been through post-wildfire modeling (Brown 1972, Lawson 1972, Sneeuwjagt and Frandsen 1977, Andrews 1980, Brown 1982, Rothermel and Rinehart 1983, Bushey 1985, McAlpine and Xanthopoulos 1989, Marsden-Smedley, and Catchpole 1995, Grabner et. al. 1997, Alexander 1998, Grabner et al. 2001, Arca et al. 2007). In this type of study, Behave is used to model fi re behavior based on pre-fire conditions in an area that recently burned. Real-world fire behavior, documented during the wildfire, can then be compared to the predicted results of Behave and refinement to the fuel models incorporated, retested, and so on.

Fire behavior modeling conducted on this site includes a relatively high-level of detail and analysis which results in reasonably accurate representations of how wildfire may move through available fuels on and adjacent to the property. Fire behavior calculations are based on site-specific fuel characteristics supported by fire science research that analyzes heat transfer related to specific fire behavior. To objectively predict flame lengths, spread rates, and fireline intensities, this analysis incorporated predominant fuel characteristics, slope percentages, and representative fuel models observed on site. The BehavePlus fire behavior modeling system was used to analyze anticipated fire behavior in key areas within and adjacent to the proposed Project site. Predicting wildland fire behavior is not an exact science. As such, the movement of a fire will likely never be fully predictable, especially considering the variations in weather and the limits of weather forecasting. Nevertheless, practiced, and experienced judgment, coupled with a validated fire behavior modeling system, results in useful and accurate fire prevention planning information. To be used effectively, the basic assumptions and limitations of BehavePlus must be understood.
First, it must be realized that the fire model describes fire behavior only in the flaming front. The primary driving force in the predictive calculations is dead fuels less than one-quarter inch in diameter. These are fine fuels that carry fire. Fuels greater than one inch have an insignificant effect while fuels greater than three inches have no effect on fire behavior.
Second, the model bases calculations and descriptions on a wildfire spreading through surface fuels that are within six feet of the ground and contiguous to the ground. Surface fuels are often classified as grass, brushes, litter, or slash.
Third, the software assumes that weather and topography are uniform. However, because wildfire almost always burns under non-uniform conditions, the length of the projection period and choice of fuel model must be carefully considered to obtain useful predictions.

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Fourth, the BehavePlus fire behavior computer modeling system was not intended for determining sufficient fuel modification zone/defensible space widths. However, it does provide the average length of the flames, which is a key element for determining “defensible space” distances for minimizing structure ignition.

Although BehavePlus has some limitations, it can still provide valuable fire behavior predictions which can be used as a tool in the decision-making process. In order to make reliable estimates of fire behavior, one must understand the relationship of fuels to the fire environment and be able to recognize the variations in these fuels. Natural fuels are made up of the various components of vegetation, both live and dead, that occur on a site. The type and quantity will depend upon the soil, climate, geographic features, and the fire or other disturbance history of the site. The major fuel groups of grass, shrub, trees, and slash are defined by their constituent types and quantities of litter and duff layers, dead woody material, grass and forbs, shrubs, regeneration, and trees. Fire behavior can be predicted largely by analyzing the characteristics of these fuels. Fire behavior is affected by seven principal fuel characteristics: fuel loading, size and shape, compactnes s, horizontal continuity, vertical arrangement, moisture content, and chemical properties.
2 Modeling Inputs
Dudek utilized the BehavePlus software package to analyze fire behavior potential for the proposed development site in San Bernardino County, California. For this analysis, two pre- proposed Project scenarios were evaluated, including one average summer weather conditions northeast of the proposed Project site and southwest of the Project site. Additionally, two scenarios were run for post-project conditions (One average and one extreme weather condition respectively). The proposed Project site currently is undeveloped with largely unmaintained vegetation throughout the site. It is generally flat with minor change in elevation throughout the site and is covered with non- native grasses, sage scrub, and dispersed large shrubs. With that said, fuels and terrain adjacent to the development area could produce flying embers that may affect the proposed Project, but defenses will be built into the structures to prevent ember penetration and to extinguish fires that may result from ember penetration. It is the fuels directly adjacent to and within fuel modification zones that could have the potential to affect the proposed Project’s structures from a radiant and convective heat perspective as well as from direct flame impingement, however, the ignition resistant structures would be su rrounded by irrigated landscape and hardscape areas.

BehavePlus software requires site-specific variables for surface fire spread analysis, including fuel type, fuel moisture, wind speed, and slope data. The output variables used in this analysis include flame length (feet), rate of spread (feet/minute), fireline intensit y (BTU/feet/second), and spotting distance (miles), crown fire flame length (feet), crown fire intensity (BTU/feet/second), crown fire spotting distance (miles). The following provides a description of the input variables used in processing th e BehavePlus models for the proposed Project site. In addition, data sources are cited and any assumptions made during the modeling process are described.

2.1 Vegetation (Fuels)
The seven fuel characteristics help define the 13 standard fire behavior fuel models and the five custom fuel models developed for Southern California (Anderson 1982; Weise & Regelbrugge 1997). According to the model classifications, fuel models used in BehavePlus have been classified into four groups, based upon fuel loading (tons/acre), fuel height, and surface to volume ratio. Observation of the fuels in the field (on site) determines which

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fuel models should be applied in BehavePlus. The following describes the distribution of fuel models among general vegetation types for the standard 13 fuel models and the custom Southern California fuel models:
Grasses Fuel Models 1 through 3
Brush Fuel Models 4 through 7, SCAL 14 through 18
Timber Fuel Models 8 through 10
Logging Slash Fuel Models 11 through 13
In addition, the aforementioned fuel characteristics were utilized in the development of 40 more fire behavior fuel models developed for use in BehavePlus modeling efforts (Scott & Burgan 2005). These new models attempt to improve the accuracy of the standard 13 fuel models outside of severe fire season conditions, and to allow for the simulation of fuel treatment prescriptions. The following describes the distribution of fuel models among general vegetation types for the new 40 fuel models:
Grass Models GR1 through GR9
Grass-shrub Models GS1 through GS4
Shrub Models SH1 through SH9
Timber-understory Models TU1 through TU5
Timber litter Models TL1 through TL9
Slash blowdown Models SB1 through SB4
To support the fire behavior modeling efforts conducted for the proposed, a Dudek Fire Protection Planner analyzed the different vegetation types observed on and adjacent to the site and they were subsequently classified into the aforementioned numeric fuel models. As is customary for this type of analysis, the terrain, and fuels directly adjacent to the site and proposed fu el modification zones (FMZ) are used for determining flame lengths and fire spread.

Table 1. Existing Fuel Model Characteristics
FFuell Model
AAssignment VVegetation DDescription LLocation
FFuell Bedd Depthh
((Feet) 1
SH5 High load, dry climate
shrub
Represents the chaparral vegetation and
the shrubs within the proposed Project site
4-5 feet.

SH2 Moderate load, dry
climate shrub
Dense shrubs vegetation throughout the
proposed Project site
4-5 feet
SCAL18 Sage scrub, buckwheat Brush vegetation throughout the proposed Project site
4-5 feet
Note::
1 Listed fuel bed depths are a reflection of the fuel models that best depict the vegetation in and around the Proposed Project site and not an exact measure of local vegetation (Anderson 1982; Scott & Burgan 2005).

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Table 2. Post-development Fuel Model Characteristics
FFuell Modell
AAssignment VVegetation DDescription LLocation
FFuell Bedd Depthh
((Feet)11
GS1 Low load, dry climate
grass shrub
Onsite Zone 1 and 2 fuel modification 0.2 ft.

FB8 Irrigated
landscaping/compact
litter
Thinned landscape throughout the
perimeter of the Project site
<2.0 ft.

NB1 Urban or suburban
development
Paved roadway. 0 ft.

Note::
1 Listed fuel bed depths are a reflection of the fuel models that best depict the vegetation in and around the Proposed Project site and not an exact measure of local vegetation (Anderson 1982; Scott & Burgan 2005).

2.2 Topography
Topography influences fire risk by affecting fire spread rates. Typically, steep terrain results in faster fire spread up- slope and slower fire spread down-slope in the absence of wind. Flat terrain tends to have insignificant effect on fire spread, resulting in fires that are driven by wind. The proposed Project site is relatively flat and gently slopes from approximately 1,613 feet above mean sea level (AMSL) in the southeastern corner to approximately 1,865 feet AMSL in the northwest corner. The open space surrounding the Project maintains the same relatively flat slope.

2.3 Weather Analysis
Historical weather data for the San Bernardino County region was utilized in determining appropriate fire behavior modeling inputs for the proposed Project area. Average, on-shore (50 th weather percentile and extreme off-shore
(97th percentile) weather conditions were derived from Remo te Automated Weather Stations (RAWS) and utilized in the fire behavior modeling efforts conducted in support of this report. The Devore RAWS Station (RAWS ID 045113) was utilized to find average and extreme weathe r values for the proposed Project area. The station was closest as it is the closest at approximately 3 miles northeast of the proposed Project site and would adequately approximate proposed Project site weather conditions. Data from fire seasons dating back to 2017 and up through 2025 were included in the analysis.

RAWS fuel moisture and wind speed data were processed utilizing the Fire Family Plus software package to determine atypical (97th percentile) and typical (50th percentile) weather conditions. Data from the RAWS was evaluated from August 1 through December 31 for each year between 2017 and 2025 for 97th percentile weather conditions and from May 1 through September 30 for each year between 2017 and 2025 for 50th percentile weather conditions.

Following analysis in Fire Family Plus, fuel moisture information was incorporated into the Initial Fuel Moisture file used as an input in BehavePlus. Wind speed data resulting from the Fire Family Plus analysis was also determined.

Initial wind direction and wind speed values for the five BehavePlus runs were manually entered during the data input phase. The input wind speed and direction are an average surface wind at 20 feet above the vegetation over the analysis area. Table 3 summarizes the wind and we ather input variables used in the Fire BehavePlus modeling efforts.

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Table 3. Wind and Weather Input Variables
MModell Variable
SSummerr Weatherr (50tth Percentile) Onn
andd OOffshoree Wind
PPeakk Weatherr (97tth Percentile)
Offshoree Windd
Fuel Models SH5 SH5
1h Moisture 3% 2%
10h Moisture 5% 3%
100h Moisture 7% 5%
Live Herbaceous Moisture 60% 30%
Live Woody Moisture 90% 60%
20-foot Wind Speed (mph) 20 40
BehavePlus Wind
Adjustment Factor

0.4 0.4
3 Fire Behavior Modeling Efforts
As mentioned, the BehavePlus fire behavior modeling software package was utilized in evaluating anticipated fire behavior adjacent to the proposed Project site. Two focused scenarios were completed for pre-Project existing fuels conditions, and two were completed for the post proposed Project conditions. The results of the modeling effort included anticipated values for surface fires flame length (feet), rate of spread (mph), fireline intensity (Btu/ft/s), and spotting distance (miles). The aforementioned fire behavior variables are a vital component in understanding fire risk and fire agency response capabilities. Flame length, the length of the flame of a spreading surface fire within the flaming front, is measured from midway in the active flaming combustion zone to the average tip of the flames (Andrews, Bevins, and Seli 2008). Fireline intensity is a measure of heat output from the flaming front and also affects the potential for a surface fire to transition to a crown fire. Fire spread rate represents the speed at which the fire progresses through surface fuels and is another important variable in initial attack and fire suppression efforts (Rothermel and Rinehart 1983). Spotting distance is the distance a firebrand or ember can travel down wind and ignite receptive fuel beds. Two pre-Project and two post-Project fire modeling scenario locations were selected to better understand the different fire behavior that may be experienced on or adjacent to the site based on slope and fuel conditions; these fire scenarios are explained in more detail below:

Firee Scenarioo Locationss andd Descriptions::
Scenarioo 1. Fire flaming front approaching from the northeast towards the northern side of Parcel 1 Project boundary with 40 mph north/northeast winds; 18% downhill slope within 100 to 300 feet of edge of grading. - Existingg conditions: undeveloped land off-site (to be preserved as open space) and on site with native vegetation (chaparral, sage scrub).
- Post-developmentt conditions: include the same off-site conditions with irrigated manufactured slopes, fuel modification zones, and paved roadways on site. Scenarioo 2. Fire flaming front approaching from the southwest towards the western boundary of the Parcel 1 western boundary with 20 mph west/southwest winds; 6% uphill slope within 400 feet of edge of grading. - Existingg conditions: undeveloped land off-site and on-site with native vegetation (sage scrub, forbs).

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- PPost-developmentt conditions: include the same off-site conditions with irrigated manufactured slopes, fuel modification zones, and paved roadways on site.
4 Fire Behavior Modeling Results
The results presented in Tables 4 and 5 depict values based on inputs to the BehavePlus software and are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of different fuel types are not accounted for in this analysis. For planning purposes, the averaged worst-case fire behavior is the most useful information for conservative fuel modification design. Model results should be used as a basis for planning only, as actual fire behavior for a give n location will be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.

The proposed Project site maintains similar slope and vegetation types on and offsite. The fire behavior models have been run considering pre-Project and post-Project conditions. Under the summer weather conditions modeled in Scenario 1, a fire burning in the off-site chaparral, modeled as SH5, would exhibit the most intense fire behavior with the sage/buckwheat vegetation, modeled as SCAL18 exhibiting similar fire behavior (refer to Table 3, Fire Behavior Results for Existing Conditions). A worst-case fire under gusty Santa Ana winds and low fuel moistures is expected to be moving up to 4.7 mph. Flame length values were modeled at 35.5 to 36.3 feet. Spotting is projected to occur up to 1.8 miles from the flaming front.

The results of fire behavior modeling analysis for pre- and post-Project conditions are presented in Tables 4 and 5, respectively. Identification of modeling run (fire scenarios) locations is presented graphically in Figure 4, BehavePlus Analysis Map.

Table 4. Modeling Results for Existing Conditions
Firee Scenarios
Flamee
Length1 (feet)
Firelinee Intensity1
(BTU/feet/
second)
Spreadd Rate1
(mph)
Spottingg
Distance11
(miles)
Scenarioo 11 (PPre-PProject):: 18%% downhilll sslope,, 4400 mphh windd fromm NEE Fuel Model SH5 – Chaparral 36.3 13,958 4.7 1.8
Fuel Model SCAL18 – Sage,
buckwheat

35.5 13,342 2.1 1.8
Fuel Model SH2 – Sage, forbs 13.1 1,515 0.7 0.9
Scenarioo 22 (Pre--Project):: 66%% uphilll slope,, 200 mphh windd fromm W/SWW Model SH2 – Sage, forbs 8.6 603 0.3 0.4
Note::
1 Wind-driven surface fire.

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Table 5. Modeling Results for Post-Project Conditions
FFiree Scenarios
Flamee
Length1 (feet)
Firelinee Intensity1
(BTU/feet/
second)
Spreadd Rate1
(mph)
Spottingg
Distance11
(miles)
Scenarioo 11 (PPost--Project onsite)):: 25%% downhilll slope,, 400 mphh windd fromm NE Fuel Model GS1 – maintained shrubs
for fuel modification

11.1 1,067 2.0 0.8
Fuel Model 8 – Irrigated
landscaping/FMZ

2.6 46 0.1 0.3
Fuel Model NB1 – paved roadway N/A N/A N/A N/A
Scenarioo 22 (PPost-PProjectt onsite)):: 20%% uphilll slope,, 200 mphh windd fromm SW Fuel Model GS1 – maintained shrubs
for fuel modification

7.2 411 0.8 0.4
Non-burnable N/A N/A N/A N/A
Note::
1 Wind-driven surface fire.

The following describes the fire behavior variables (Heisch and Andrews 2010) as presented in Tables 4 and 5:

Surfacee Fire::
Flamee Lengthh (feet):: The flame length of a spreading surface fire within the flaming front is measured from midway in the active flaming combustion zone to the average tip of the flames. Firelinee Intensityy (Btu/ft/s): Fireline intensity is the heat energy release per unit time from a one-foot wide section of the fuel bed extending from the front to the rear of the flaming zone. Fireline intensity is a function of rate of spread and heat per unit area and is related to flame length. Fireline intensity and the flame length are related to the heat felt by a person standing next to the flames.
Surfacee Ratee off Spreadd (mph): Surface rate of spread is the "speed" the fire travels through the surface fuels. Surface fuels include litter, grass, brush, and ot her dead and live vegetation within about 6 feet of the ground.

The information in Table 6 presents an interpretation of the outputs for five fire behavior variables as related to fire suppression efforts. The results of fire behavior modeling efforts are presented in Tables 4 and 5. Identification of modeling run locations is presented graphically in Figure 4 of the FPP.

Table 6. Fire Suppression Interpretation
Flamee Lengthh
(ft)
Firelinee Intensityy
(Btu/ft/s) Interpretations
Under 4 feet Under 100 BTU/ft/s Fires can generally be attacked at the head or flanks by people using hand tools. Hand line should hold the fire.
4 to 8 feet 100-500 BTU/ft/s Fires are too intense for direct attack on the head by people using hand tools. Hand line cannot be relied on to hold the fire.

Equipment such as dozers, pumpers, and retardant aircraft can be effective.

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Table 6. Fire Suppression Interpretation
FFlamee Lengthh
((ft)
FFirelinee Intensityy
((Btu/ft/s) IInterpretations
8 to 11 feet 500-1000 BTU/ft/s Fires may present serious control problems -- torching out, crowning, and spotting. Control efforts at the fire head will probably be ineffective.

Over 11 feet Over 1000 BTU/ft/s Crowning, spotting, and major fire runs are probable. Control efforts at head of fire are ineffective.

Appendix D
Ignition-Resistant Construction Requirements

APPENDIX D / IGNITION-RESISTANT CONSTRUCTION REQUIREMENTS 14428
JULY 2025
D-1
As of the date of this fire protection plan, the following are the requirements for ignition resistant construction for The Proposed Project, including requirements under Chapter 7A of the California Building Code (CBC). In addition, exterior building construction including roofs, eaves, exterior walls, doors, windows, decks, and other attachments must meet the most current CBC Chapter 7A ignition resistance requirements at the time of building permit application.

1. All structures will be built with a Class A roof assembly, including a Class A roof covering. Roofs shall have a roofing assembly installed in accordance with its listing and the manufacturer’s installation instructions.

2. Where the roof profile allows a space between the roof covering and roof decking, the spaces shall be constructed to prevent the intrusion of flames and embers, be fire stopped with approved materials or have one layer of minimum 72-pound mineral-surfaced non-perforated cap sheet complying with ASTM D 3909 installed over the combustible decking. However, openings on barrel tiles or similar roof coverings, must be fire stopped (bird stopped) with approved materials to prevent the accumulation of debris, bird nests, etc. between the tiles and decking material.

3. When provided, exposed valley flashings shall be not less than 0.019-inch (No. 26 galvanized sheet gage) corrosion-resistant metal installed over a minimum 36-inch-wide underlayment consisting of one layer of minimum 72-pound mineral-surfaced non-perforated cap sheet complying with ASTM D 3909 running the full length of the valley.

4. All rain gutters, down spouts and gutter hardware shall be constructed from metal or other non-combustible material to prevent wildfire ignition along eave assemblies.

5. All chimney, flue or stovepipe openings attached to a fireplace, stove, or other solid or liquid fuel burning equipment or device shall be equipped with an appr oved spark arrester. An approved spark arrester is defined as a device intended to prevent sparks from escaping into the atmosphere and constructed of nonflammable materials, having a 12-gauge minimum thicknesses with openings no greater than ½ inch, or other alternative material the SBCFPD determines to provide equal or better protection. It shall be installed to be visible for the purposes of inspection and maintenance.

6. The exterior surface materials shall be non-combustible, including hard or ignition resistant, such as stucco.

In all construction, exterior walls shall extend from the top of the foundation to the roof and terminate at 2- inch nominal solid blocking between rafters at all ro of overhangs, or in the case of enclosed eaves, terminate at the enclosure.

7. All eaves, fascias, and soffits will be enclosed (boxed) with non-combustible materials. This shall apply to the entire perimeter of each structure. Eaves of heavy timber construction are not required to be enclosed as long as attic venting is not installed in the eaves. For the purposes of this section, heavy timber construction shall consist of a minimum of 4”x 6” rafter tails.

8. Paper-faced insulation shall be prohibited in attics or ventilated spaces.

9. Automatic interior fire sprinklers for residential buildings shall be installed according to the National Fire Protection Association (NFPA) 13D requirements.

10. Roof vents, dormer vents, gable vents, foundation ventilation openings, ventilation openings in vertical walls, or other similar ventilation openings shall be louvered and covered with 1/16-inch, noncombustible, corrosion-resistant metal mesh or other approved material that offers equivalent protection.

11. Attic or foundation ventilation louvers or ventilation openings in vertical walls shall not exceed 144 square inches per opening and shall be covered with 1/16” inch mesh corrosion-resistant metal screen or other approved material that offers equivalent protection. Ventilation louvers and openings may be incorporated as part of access assemblies.

APPENDIX D / IGNITION-RESISTANT CONSTRUCTION REQUIREMENTS 14428
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D-2

12. No attic ventilation openings or ventilation louvers shall be permitted in soffits, in eave overhangs, between rafters at eaves, or in other overhanging areas.

13. All fences and gate assemblies (fences, gates, and fence posts) attached or within five feet of a structure shall be of non-combustible material or pressure-treated exterior fire-retardant wood.

14. All projections (exterior balconies, decks, patio covers, unenclosed roofs and floors, and similar architectural appendages and projections) or structures less than five feet from a building shall be of non- combustible material, one-hour fire resistive construction on the underside, heavy timber construction, pressure-treated exterior fire- retardant wood or ignition resistant construction. When such appendages and projections are attached to exterior fire- resistive walls, they shall be constructed to maintain same fire-resistant standards as the exterior walls of the structure.

15. Accessory structures attached to buildings with habitable spaces and projections shall be in accordance with Chapter 7A of the CBC.

16. Detached accessory structures located less than 50 feet from a building containing habitable space shall be constructed in accordance with Chapter 7A of the CBC. a. Exception: Accessory structures less than 120 square feet in floor area located at least 30 feet from a building containing a habitable space.

17. Exterior doors shall be approved non-combustible co nstruction, solid core wood and shall conform to the performance requirements of standard SFM 12-7A-1 or shall be of approved noncombustible construction, or solid core wood having stiles and rails not less than 1 ⅜ inches thick with interior field panel thickness no less than 1¼ inches thick, or shall have a fire-resistance rating of not less than 20 minutes when tested according to National Fire Protection Association (NFPA) 252.

18. All glass or other transparent, translucent or opaque glazing materials, that is used in exterior windows, including skylights, or exterior glazed door assemblies shall be constructed of multipane glazing with one tempered pane meeting the requirements of Section 2406 (2016 CBC) Safety Glazing.

19. Vinyl window assemblies are deemed acceptable if the windows have the following characteristics:
a. Frame and sash are comprised of vinyl material with welded corners. b. Metal reinforcements in the interlock area.
c. Glazed with insulating glass, annealed or tempered (one layer of which must be tempered glass). d. Frame and sash profiles are certified in AAMA Lineal Certification Program. e. Certified and labeled to ANSI/AAMA/NWWDA 101/LS2-97 for Structural Requirements.

Appendix E
Prohibited Plant List

APPENDIX E

FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
14428
July 2025E-1
BBotanical NName CCommon NName CComment**
TTrees
Abiesspecies Fir F
Agonis juniperina Juniper Myrtle F
Casuarina cunninghamiana River She-Oak F
Chamaecyparisspecies (numerous) False Cypress F
Cryptomeria japonica Japanese Cryptomeria F
Cupressocyparis leylandii Leyland Cypress F
Cupressusspecies(C. fobesii, C. glabra, C.
sempervirens,)
Cypress (Tecate, Arizona, Italian, others) F
Eucalyptusspecies (numerous) Eucalyptus F, I
Juniperusspecies (numerous) Juniper F
Lithocarpus densiflorus Tan Oak F
Melaleucaspecies(M. linariifolia, M. nesophila, M.
quinquenervia)
Melaleuca (Flaxleaf, Pink, Cajeput Tree) F, I
Picea(numerous) Spruce F
Palmspecies (numerous) Palm F, I
Pinusspecies(P. brutia, P. canariensis, P. b. eldarica, P. halepensis, P. pinea, P. radiata, numerous others)
Pine (Calabrian, Canary Island, Mondell, Aleppo,
Italian Stone, Monterey)
F
Platycladus orientalis Oriental arborvitae F
Pseudotsuga menziesii Douglas Fir F
Tamarixspecies(T. africana, T. aphylla, T. chinensis,
T. parviflora)
Tamarix (Tamarisk, Athel Tree, Salt Cedar,
Tamarisk)
F, I
Taxodiumspecies(T. ascendens, T. distichum, T.
mucronatum)
Cypress (Pond, Bald, Monarch, Montezuma) F
Taxusspecies(T. baccata, T. brevifolia, T. cuspidata) Yew (English, Western, Japanese) F Thujaspecies(T. occidentalis, T. plicata) Arborvitae/Red Cedar F GGroundcovers, SShrubs && VVines
Acaciaspecies Acacia F, I
Adenostoma fasciculatum Chamise F
Adenostoma sparsifolium Red Shanks F
Agropyron repens Quackgrass F, I
Anthemis cotula Mayweed F, I
Arctostaphylosspecies Manzanita F
Arundo donax Giant Reed F, I
Artemisiaspecies(A. abrotanium, A. absinthium, A.
californica, A. caucasica, A. dracunculus, A.
tridentata, A. pynocephala)
Sagebrush (Southernwood, Wormwood,
California, Silver, Truetarragon, Big, Sandhill)
F
Atriplexspecies (numerous) Saltbush F, I
Avena fatua Wild Oat F
Baccharis pilularis Coyote Bush F
Bambusa species Bamboo F, I
Bougainvilleaspecies Bougainvillea F, I
Brassicaspecies(B. campestris, B. nigra, B. rapa) Mustard (Field, Black, Yellow) F, I

APPENDIX E

FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
14428
July 2025E-2
BBotanical NName CCommon NName CComment**
Bromus rubens Foxtail, Red brome F, I
Castanopsis chrysophylla Giant Chinquapin F
Cardaria draba Hoary Cress I
Cirsium vulgare Wild Artichoke F,I
Conyza bonariensis Horseweed F
Coprosma pumila Prostrate Coprosma F
Cortaderia selloana Pampas Grass F, I
Cytisus scoparius Scotch Broom F, I
Eriogonumspecies(E. fasciculatum) Buckwheat (California) F Fremontodendronspecies Flannel Bush F
Heterotheca grandiflora Telegraph Plant F
Hordeum leporinum Wild barley F, I
Juniperusspecies Juniper F
Lactuca serriola Prickly Lettuce I
Larrea tridentata Creosote bush F
Lolium multiflorum Ryegrass F, I
Lonicera japonica Japanese Honeysuckle F
Mimulus aurantiacus Sticky Monkeyflower F
Miscanthusspecies Eulalie Grass F
Muhlenbergiaspecies Deer Grass F
Nicotianaspecies(N. bigelovii, N. glauca) Tobacco (Indian, Tree) F, I Pennisetum setaceum Fountain Grass F, I
Perovskia atroplicifolia Russian Sage F
Phoradendronspecies Mistletoe F
Pickeringia montana Chaparral Pea F
Rhus (R. diversiloba, R. laurina, R. lentii) Sumac (Poison oak, Laurel, Pink Flowering) F Ricinus communis Castor Bean F, I
Rhus Lentii Pink Flowering Sumac F
Salviaspecies (numerous) Sage F, I
Salsola australis Russian Thistle F, I
Solanum Xantii Purple Nightshade (toxic) I
Silybum marianum Milk Thistle F, I
Thujaspecies Arborvitae F
Urtica urens Burning Nettle F
*F = flammable, I = Invasive
NNotes::

1. Plants on this list that are considered invasive are a partial list of commonly found plants. There are many other plants considered invasive that should not be planted in a fuel modification zone and they can be found on The Ca lifornia Invasive Plant Council’s Website www.cal-ipc.org/ip/inventory/index.p hp. Other plants not consider ed invasive at this time may be determined to be invasive after further study.

2. For the purpose of using this list as a guide in selecting pl ant material, it is stipulated that all plant material will burn under various conditions.

3. The absence of a particular plant, shrub, groundcover, or tr ee, from this list does not necessarily mean it is fire resistive.

4. All vegetation used in Fuel Modification Zones and elsewhere in this development shall be subject to approval of the Fire Code Official.

5. Landscape architects may submit proposals for use of certain ve getation on a project specific basis. They shall also submit justifications as to the fire resistivity of the proposed vegetation.

ATTACHMENT J
University Hills-Power Point

PLANNING COMMISSION
January 13, 2026
Item 2 Specific Plan Amendment 23-01
and Subdivision 23-05
Community Development & Housing Department

Adoption of the Addendum to the Final Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155) in compliance with the California Environmental Quality Act.

Approval of Specific Plan Amendment No. 23-01
Approval of Subdivision 23-05
Dissolve Development Agreement No. 08-02
404.3-acre
APNs: 0265-041-12, 0265-051-12 and -13; 0265-061-16; 0265-011-06, -07, and -08; 0265-051-09; and 0265-021-13
University Hills Specific Plan (SP-UH)
Community Development &
Housing Department
Proposed Project
LOCATION/ZONING MAP:

AERIAL MAP:

PLANNING AREAS: REFERENCE

ANALYSIS:

Project
Background
Amendment
Subdivision
Pedestrian and Bicycle Connectivity
Roadways, Traffic, and Circulation
Utilities and Infrastructure
Community Development & Housing Department
ANALYSIS:

Landscaping
Recreation Areas
Lighting
Off-Site Improvements
Construction Schedule
Dissolution of Development Agreement 08-02
General Plan Compatibility
Community Development & Housing Department

ACCESS TO PROPOSED DEVELOPMENT
Project Site
ACCESS 1: CONNECTION FROM CAMPUS CIRCLE TO BADGER CANYON RD
Project Site
EXISTING SITE: CAMPUS CIRCLE AND BADGER CANYON
ACCESS 1

EXISTING SITE: SOUTH TO CSUSB FROM ACCESS 1

ACCESS 2: CONNECTION FROM W DEVILS CANYON TO BADGER

CANYON RD
Project Site
EXISTING SITE: DEVILS CANYON AND BADGER CANYON ACCESS 2

TENTATIVE PARCEL MAP 20595 :

SITE PLAN:

FIRE DEPARTMENT FUEL MODIFICATION PLAN LAYOUT:

RECOMMENDATION:

The Planning Commission adopt Resolution No. 2026-0XX forwarding a Recommendation that the Mayor and City Council :

1. CONSIDER the Addendum to the certified Subsequent Final Environmental Impact Report (SCH #2007071155) for Specific Plan Amendment 23-01 and Subdivision 23-05, in accordance with Section 15164(a) of the Public Resources Code, and direct the Planning Commission Secretary to prepare and file with the Clerk of the County of San Bernardino a Notice of Determination as provided under Public Resources Code, Section 21152(c) and California Code of Regulations, Title 14, Section 15094; and

2. APPROVE Specific Plan Amendment 23-01 and Subdivision 23-05 based on the Findings of Fact and subject to the recommended Conditions of Approval.

Mayor and City CouncilJune 3, 2026

Mayor and City Council
June 3, 2026