HomeMy WebLinkAbout8043 RESOLUTION NO 8043
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS
ADOPTING ENVIRONMENTAL FINDINGS PURSUANT TO THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT ("CEQA"), ADOPTING
A STATEMENT OF OVERRIDING CONSIDERATIONS, AND CERTIFYING
THE FINAL SUBSEQUENT ENVIRONMENTAL IMPACT REPORT (SCH
No 2016081041) FOR A BALLOT INITIATIVE REGARDING VOTER-
APPROVED LAND USE INITIATIVES MEASURE U, MEASURE N, AND
PROPOSITION R OF THE CITY OF REDLANDS
WHEREAS, on December 5, 2017, the City Council of the City of Redlands ("City
Council") appioved Resolution No 7792 adopting the incorporation of the Transit Village
Overlay and all associated policies into the updated Redlands General Plan (2035 General Plan),
and
WHEREAS, on December 5, 2017, the City Council approved Resolution No 7793
adopting the Redlands 2035 General Plan, and
WHEREAS, also on December 5, 2017, the City Council approved Resolution No 7794
adopting Findings of Fact, a Statement of Overriding Considerations, and certifying the Final
Environmental Impact Report related to the General Plan Update, and
WHEREAS, the City Council now proposes to place an initiative measure on the ballot
for consideration by the qualified voters of the City at a municipal election in March of 2020
regaiding voter-approved land use initiatives Measure U, Measure N, and Proposition R (the
"Project"), and
WHEREAS, if approved by the voters, the proposed Project would exempt the Transit
Villages Planning Ai-ea from the provisions of Measures U and N, and Proposition R, and
WHEREAS, if approved by the voters, the proposed Project would allow the City
Council to consider future projects in the Transit Villages Planning Area ("TVPA") without the
burden of the annual 400 residential dwelling unit limitation, increase residential densities from
18 to 27 units/acre without the necessity of a super-majority vote of the City Council, no longer
require the maintenance of traffic levels of service "C" for all intersections, allow the creation of
new land use designations, and no longer require socio-economic studies for development
projects, and
WHEREAS, no construction or development is proposed under the proposed Project, and
WHEREAS, the City of Redlands is the Lead Agency pursuant to Public Resources Code
Section 21067 and CEQA Guidelines Section 15367 (Cal Code Regs , tit 14, § 15000 et seq ),
and has chosen to prepare a Subsequent Environmental Impact Report ("SEIR") to fully analyze
the proposed Project, and
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WHEREAS, in accordance with State CEQA Guidelines sections 15153 and 15162, the
City evaluated the proposed Project in light of the General Plan EIR, modified to reflect the
standards for subsequent environmental review set forth m Public Resources Code section 21166
and State CEQA Guidelines section 15162, to evaluate whether further environmental review for
the proposed Project would be required in light of the General Plan EIR, and
WHEREAS, because the conditions in Public Resources Code section 21166 and State
CEQA Guidelines section 15162 would be triggered by the proposed Project, but because only
minor additions of changes to the General Plan EIR would be necessary, it was determined that a
subsequent EIR should be piepaied pursuant to State CEQA Guidelines section 15162, and
WHEREAS, a Notice of Preparation was filed on June 18, 2019, with the San Bernardino
County Clerk of the Board, the Governoi's Office of Planning & Research (State
Clearinghouse), and Responsible and Trustee Agencies stating that a Subsequent Environmental
Impact Report (State Clearinghouse Number# 2016081041) would be prepared and would tier-
off the Geneial Plan EIR pursuant to State CEQA Guidelines sections 15152 and 15153, and
WHEREAS, the Notice of Preparation of a Draft Subsequent Environmental Impact
Report was issued for a 30-day review period between June 19, 2019, and July 19, 2019, in
accordance with State CEQA Guidelines section 15082(a), and
WHEREAS, pursuant to Public Resources Code section 21083 9 and State CEQA
Guidelines sections 15082(c) and 15083, the City held a duly noticed Scopmg Meeting on June
26, 2019, to solicit comments on the scope of the environmental review of the proposed Project,
and
WHEREAS, the proposed Project is moie specifically described and depicted in detail in
the Draft Subsequent Environmental Report (the "Draft SEIR"), and such descriptions aie hereby
incorporated herein by this i eference, and
WHEREAS, a Draft SEIR was prepared for the proposed Project, incorporating
comments received during the Notice of Preparation review period, in accordance with the
applicable provisions of the CEQA, and
WHEREAS, the Draft SEIR analyzed impacts to Land Use and Housing, Transportation,
and Utilities and Service Systems, and found that most impacts of the proposed Project were
fully evaluated and mitigated in the Geneial Plan EIR, and that the proposed Project would not
exacerbate conditions beyond what was indicated in the General Plan EIR, and
WHEREAS, in accordance with State CEQA Guidelines section 15085, a Notice of
Completion was filed on August 26, 2019, with the Governor's Office of Planning & Research
(State Clearinghouse No 2016081041), and
WHEREAS, as required by State CEQA Guidelines section 15087(a), the City published
the Notice of Availability in the Redlands Daily Facts on August 25, 2019, and provided the
Notice of Availability of the Draft SEIR to the public at the same time that the City sent Notice
of Completion to the Office of Planning and Research, and
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WHEREAS, the Draft SEIR was circulated for public review and comment for a period
of forty five (45) days in accordance with the applicable provisions of CEQA, beginning on
August 26, 2019, and ending on October 9, 2019, and
WHEREAS, during the 45-day public comment period, the City consulted with and
requested comments from all responsible and trustee agencies, other regulatory agencies, and
others pursuant to State CEQA Guidelines section 15086, and
WHEREAS, copies of the Draft SEIR and related documents were made available for
public review at the following locations in Redlands during regular business hours City Clerk's
Office at 35 Cajon Street, Suite 2, One Stop Permit Centel public counter at 35 Cajon Street,
Suite 15-A, Development Services Department public counter at 35 Cajon Stieet, Suite 20, and
A K Smiley Public Library at 125 West Vine Street, and
WHEREAS, electronic copies of the Draft SEIR and related documents were made
available for public review 24 hours daily at the following websites CEQAnet Database
maintained by the Governor's Office of Plannmg & Research (State Clearinghouse) at
<https //ceqanet opr ca gov>, and the City of Redlands website at <https //www
cityo fredlands oi g/po st/enviro nmental-do cuments>, and
WHEREAS, the custodian of documents and other material which constitute the record
of proceedings, upon which the City Council's decision is based, is the Development Services
Director, and all records are maintained in the City of Redlands Development Services
Department located at 35 Cajon Street, Suite 20, Redlands CA 92373, and
WHEREAS, the City received seven (7) written comment letters on the Draft SEIR, and
WHEREAS, pursuant to Public Resources Code section 21092 5, the City provided
copies of its responses to commenting public agencies at least ten (10) days prior to the City's
consideration of the Final SEIR, and
WHEREAS, on October 30, 2019, the City released the Final SEIR (the "Final SEIR"),
which consists of all written comment letters received on the Draft SEIR, written responses to all
written comment letters received on the Draft SEIR, and errata to the Draft SEIR, and
WHEREAS, the City Council's consideration of the Draft Subsequent EIR was scheduled
for November 5, 2019, at which time the City Council solicited comments from the public on the
Draft Subsequent EIR for the proposed Project, and
WHEREAS, the "SEIR" consists of the Final SEIR and its attachments and appendices,
as well as the Draft SEIR and its attachments and appendices (as modified by the Final SEIR),
and
WHEREAS, City of Redlands General Plan (dated December 5, 2017), the City of
Redlands General Plan Update DEIR (dated July 21, 2017), and the City of Redlands Municipal
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Code were all incorporated by reference into the SEIR pursuant to State CEQA Guidelines
section 15150, and
WHEREAS, all potentially significant adverse environmental impacts were sufficiently
analyzed in the SEIR, and
WHEREAS, as contained herein, the City Council has endeavored in good faith to set
forth the basis for its decision on the proposed Project, and
WHEREAS, all the requirements of the Public Resources Code and the State CEQA
Guidelines have been satisfied by the City in connection with the preparation of the SEIR, which
is sufficiently detailed so that all of the potentially significant environmental effects of the
proposed Project, as well as all feasible mitigation measures, have been adequately evaluated,
and
WHEREAS, the SEIR prepared in connection with the proposed Project sufficiently
analyzes all feasible mitigation measures necessary to avoid or substantially lessen the proposed
Project's potentially significant environmental impacts and a range of feasible alternatives
capable of eliminating or reducing these effects in accordance with CEQA, and
WHEREAS, all of the findings and conclusions made by the City Council pursuant to
this Resolution are based upon the oral and written evidence presented to it as a whole and the
entirety of the administrative record for the Project, which are incorporated herein by this
reference, and not based solely on the information provided in this Resolution, and
WHEREAS, environmental factors identified in the SEIR that the City finds do not
require further environmental ieview pursuant to Public Resources Code section 21166 and State
CEQA Guidelines section 15162, as the proposed Project will not result in any new impact or an
increase in the severity of significant impacts, are described in Section 2 below, and
WHEREAS, impacts of the proposed Project for which impacts were found to be less
than significant are described in Section 3, and
WHEREAS, impacts of the proposed Project, for which furthei environmental ieview
was required and where project-level significant and unavoidable environmental impacts
originally identified in the General Plan EIR and thus carried over into the SEIR which neither
exacerbated not identified new significant and unavoidable impacts were discussed, are furthei
described in Section 4 below, and
WHEREAS, the cumulative impacts of the proposed Project identified in the SEIR and
set forth herein, are described in Section 5 below, and
WHEREAS, the potential significant irreversible environmental changes that would
result fiom the proposed Project identified in the SEIR and set forth herein, are described in
Section 6 below, and
WHEREAS, the existence of any growth-mducmg impacts resulting from the proposed
Project identified in the SEIR and set forth herein, are described in Section 7 below, and
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WHEREAS, alternatives to the proposed Project that might eliminate or reduce
significant environmental impacts are described in Section 8 below, and
WHEREAS, the City Council has determined that the benefits of the proposed Project
outweigh its potentially significant effects, and the basis for that determination is set forth in the
Statement of Overriding Considerations included in Section 6 below, and
WHEREAS, prior to taking action, the City Council has heard, been presented with,
reviewed and considered all of the mformation and data in the administrative record, including
but not limited to the General Plan EIR as revised by the SEIR, and all oral and written evidence
presented to it during all meetings and hearings, and
WHEREAS, the SEIR reflects the independent judgment of the City and is deemed
adequate for purposes of making decisions on the merits of the proposed Project, and
WHEREAS, no comments made in the public hearings conducted by the City and no
additional information submitted to the City have produced substantial new information
requiring iecirculation of the SEIR or additional environmental review of the proposed Project
under Public Resources Code section 21092 1 and State CEQA Guidelines section 15088 5, and
WHEREAS, on November 5, 2019, the City conducted a duly noticed public hearing on
this Resolution, at which time all persons wishing to testify were heard and the proposed Project
was fully considered, and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred,
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF REDLANDS AS FOLLOWS
SECTION 1 FINDINGS
a) Recitals The above recitals are true and correct and incorporated herein by reference
b) Project Location Located in the City of Redlands, the geographical area of the City
affected by the proposed Project would be limited to the TVPA, an approximately 782-
acre area that is roughly described as the land within one-half mile radius from any of the
duce planned rail transit stations within the City of Redlands Measures U, N, and
Proposition R would continue to apply to the rest of the City in the way that these
measures currently apply
c) Project Description On June 4, 2019, the City Council directed staff to draft and place on
the March 2020 election ballot, an initiative that would remove application of the existing
City of Redlands 1978 voter-approved initiative measure commonly known as
Proposition "R," as that proposition was amended by the City of Redlands 1987 voter-
approved initiative measure commonly known as Measure "N", and the 1997 voter-
approved Measure "U", from future development within the TVPA The aforementioned
voter-approved measures would continue to apply to the remainder of the City A true
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and correct copy of the proposed ballot initiative is attached to this Resolution as Exhibit
"A," and is mcorpoiated herein by this reference
If the proposed ballot initiative is approved by the voters, it would allow the City Council to
consider future projects within the TVPA without the burden of the annual residential dwelling
unit limitation New residential units, specifically residential units in multi-family projects,
within the TVPA could be financed more efficiently and constructed faster than the current
regulations would permit Future City discretionary actions relating to proposed development
within the TVPA would not be constrained by the Genei al Plan limitations contained in Measure
U and the zoning restrictions in Proposition R, as amended by Measure N Specifically, the
proposed ballot initiative would permit the following
■ The City's 400 dwelling unit annual limitation on construction of residential
dwelling units would not be applicable within the TVPA,
• Residential densities may be mcieased within the TVPA from 18 to 27 units/acre
without the necessity of a super-majority vote of the members of the City
Council and the necessity of making certain findings,
■ The requirement for the maintenance of traffic levels of service "C" for all
intersections would not apply within the TVPA,
• The prohibition against the creation of new land use designations would not
apply within the TVPA,
• Socio-economic studies would not be requied for development projects within
the TVPA
d) CEQA Compliance The Draft and Final Subsequent Environmental Impact Report has
been prepared and circulated in accordance with all applicable provisions of CEQA for
Environmental Impact Reports The City finds that the Subsequent Environmental Impact
Report was prepared in compliance with CEQA, and that the City has complied with
CEQA's procedural and substantive requirements
e) Final SEIR was Presented to the Decision-Making Body of the Lead Agency As the
decision-making body for the Project, the City has reviewed and considered the
information contained m the Draft Subsequent Environmental Impact Report, related
technical studies and analyses, any public comments received and responses to
comments, and the Final Subsequent Environmental Impact Report The City determines
that the Subsequent Environmental Impact Report and related documents contain a
complete and accurate reporting of the environmental effects associated with the Project
The City finds that the Subsequent Environmental Impact Report has been presented in
its entirety to the City Council as the decision-making body of the City of Redlands
acting as the Lead Agency
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f) Independent Judgment of Lead Agency The Subsequent Environmental Impact Report
for the Project, prepared by the City's environmental consultant, reflects the City's
independent judgment and analysis The City has exercised independent judgment and
analysis m accordance with Public Resources Code section 21082 1(c)(3) in managing as
appropriate the environmental consultant, and directing the consultant in the preparation
of the Draft and Final Subsequent Environmental Impact Report The City has
independently reviewed and analyzed the Subsequent Environmental Impact Report and
related analyses and documents, and finds that the Subsequent Environmental Impact
Report reflects the independent judgment and analysis of the City of Redlands
SECTION 2 FINDINGS REGARDING ENVIRONMENTAL IMPACTS FOUND NOT
TO BE SIGNIFICANT
The City undertook analysis of the proposed Ballot Initiative Regarding Voter-Approved Land
Use Initiatives Measures U, N and Proposition R Project and evaluated it against the standards
set forth in Public Resources Code section 21166 and State CEQA Guidelines section 15162
With regard to all environmental factors (except Land Use and Housing, Transportation, and
Utilities and Service Systems), Chapter 5 of the Draft SEIR confirmed that the proposed
Project's impacts weie fully disclosed, evaluated, and mitigated (to the extent feasible) n the
General Plan EIR
CEQA does not require findings to address environmental effects that an EIR identifies as either
"no impact" or "less than significant" impact (State CEQA Guidelines § 15091 ) Similarly, in
the tiering context, if the proposed Project would result in a "reduced impact" or "no impact/no
new impact" compared to the General Plan EIR, CEQA does not require subsequent
environmental review and no findings for those impacts would be required (State CEQA
Guidelines § 15168, 15152 & 15153 ) Nevertheless, these findings fully account for all
environmental factors including environmental factors for which the Draft SEIR concluded that
no furthei environmental review is necessary
Pursuant to Public Resources Code section 21166 and State CEQA Guidelines section 15162, the
City Council hereby finds that none of the circumstances requiring subsequent environment
review for the following environmental factors would be required because the following
environmental factors weie fully disclosed, analyzed, and mitigated (to the extent feasible) in the
General Plan EIR
I Aesthetics.
1 Threshold 5 1(a) Have a substantial adverse effect on a scenic vista
Finding No Impact/No New Impact (Draft SEIR, pages 5-1 to 5-2 )
Accoi ding to the General Plan EIR, scenic vistas throughout the City consist of scenic corridors
and views to and from open spaces, canyonlands, hillsides, groves, and the San Bernardino
Mountains, as well as the scenic views found along scenic and historic drives wither the
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urbanized areas of the City The General Plan EIR stated that land use changes would occur
throughout the City, the majority of which would occur in or near already developed areas that
coincide with areas designated for development According to the General Plan EIR, the
following policies and actions would reduce impacts of development on scenic vistas 2-P 8, 2-
P 13, 2-A 28, 2-A 29, 2-A 32, 2-A 34, 4-A 17, and 6-P 6 The foregoing policies and actions
would also apply to the proposed Project and would similarly reduce impacts that new
development would have on scenic vistas For example, Action 2-A 29 calls for the retention of
existing easements and rights of way foi use as viewpoints, turnouts, and scenic walkways, and
Action 4 A-17 calls for the reliance on strong landscape treatments, setbacks, sign controls,
which would ensure that impacts to scenic vistas are less than significant These policies would
apply to any new developments that occur within the TVPA, with or without the Ballot Initiative
For buildings in the R-2 Multiple-Family Residential District, the maximum building height is
designated at 2 1/2 stories or 35 feet, according to Redlands Municipal Code Chapter 18 52, R-2
Multiple-Family Reszdentzal Dista act Chapter 18 60, R-3 Multiple-Family Residential District,
states that the maximum height of buildings in the R-3 Zone is four stories If the proposed
Project is approved, any future development within the TVPA (and throughout the balance of the
City) must comply with the maximum height restriction of the zoning code Chapters 18 52 and
18 60, for both the R-2 and R-3 Zones, requires that site plans and elevations be submitted to the
Planning Commission for review and approval whenever three or more dwelling units are
proposed for any building site This requirement would not be changed with the Ballot Initiative
As the proposed Project would not change existing land use of zoning designations, and all
development will continue to be subject to the existing development standards m the municipal
code iegardung Planning Commission review, and impacts to scenic vistas Consequently,
impacts that the proposed Project would have on scenic vistas would be the same as disclosed in
the General Plan EIR Because now new impact would occur, no new mitigation is necessary
2 Thi eshold 5 1(b) Substantially damage scenic resources, including, but not limited to,
tiees, rock outcroppings, and historic buildings within a state scenic highway
Finding No Impact/No New Impact (Draft SEIR,page 5-2 )
There are no officially designated state scenic highways in the City of Redlands, however, the
segment of Interstate 10 (I-10) between State Route 210 (SR-210) and SR-38 is an eligible state
scenic highway in the California Scenic Highway Mapping System(Caltrans 2011) A portion of
SR-38, within the Angeles National Foiest, approximately 14 5-miles east of the City of
Redlands is designated as an official state scenic highway Action 2-A 34 from the General Plan
requires that upholding the designation of the following streets listed in the policy within the
City, as scenic highways, drives, and historic streets, would continue to be applicable under the
proposed Project and would reduce impacts to scenic resources within a state scenic highway to
less than significant Therefore, impacts are less than significant foi the proposed Project and the
General Plan EIR as indicated on page 3 1-10 of the General Plan EIR Because no new impact
would occur, no new mitigation is necessary
3 Threshold 5 1(c) In nonurbamzed areas, substantially degrade the existing visual
character or quality of public views of the site and its surroundings (Public views are those that
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are experienced from publicly accessible vantage point) If the project is in an urbanized area,
conflict with applicable zoning and other regulations governing scenic quality
Finding No Impact/No New Impact (Draft SEIR,pages 5-2 to 5-3 )
The transit villages and surrounding areas would experience the most densification in the Land
Use Element of the 2035 Geneial Plan, however, the policies and actions in the General Plan
would ensure that any development oi redevelopment is visibly compatible with the surrounding
environment These policies and actions recognize the sensitivity of preserving the visual
character of existing neighborhoods and open spaces, including investment in ongoing
maintenance and improvements which is unlikely to lead to visual degradation, according to the
Genes al Plan EIR The action listed in Impact 5 1(a) —4-A 17—as well as the following policies,
2-P 9, 2-P 11, 2-P 14, 2-P 15, 2-A 23, 2-A 24, 2-A 25, 2-A 26, 2-A 30, 2-A 36, 2-A 37, 2-A 51,
2-A 67, 2-P 18, 2-A 77, 2-A 78, 2-A 79, 2-A 80, 2-A 81, 2-P 26, 2-P 27, 2-A 100, 4-P 10, 4-
A 13, 4-A 22, and 4-A 32, would be implemented foi the proposed Project
For example, Action 2-A 25 requnes any application that would alter oi demolish an
undesignated and non-surveyed resource over 50 years old to be assessed on the merits of the
structure, and to be approved by the Historic and Scenic Preservation Commission, Policy 2-P 18
calls for the reinforcement of Redlands' identity as a "Tree City" through cohesive streetscapes
that enhance its sense of place and its heritage, and that promote pedestrian comfort, and Policy
2-P 27 calls for the conservation of Downtown's character and historic assets while infusing it
with new uses, buildings, and activities, where new development should proportionately relate to
and complement existing structures and the pedestrian environment Therefore, compliance with
these policies would ensure that impacts to the existing visual character or quality of public
views are reduced to less than significant levels in the same way that these impacts were reduced
m the General Plan EIR Impacts of the proposed Project and General Plan EIR are less than
significant, as indicated on page 3 1-12 of the General Plan EIR Because no new impact would
occur, no new mitigation is necessary
4 Thi eshold 5 1(d) Create a new source of substantial light or glare, which would
adversely affect day or nighttime view in the area
Finding No Impact/No New Impact (Draft SEIR, pages 5-3 )
The proposed Project does not involve any specific development approvals Instead, the Ballot
Initiative would remove development constraints from new developments within the TVPA The
TVPA is urbanized and already has streetlights, building security lighting, and windows that
emit light Any new developments within the TVPA would be subject to the City's existing
General Plan including the following Actions, 2-A 35, which establishes standards for the
evaluation of exterior lighting foi new development and redevelopment to ensure that exterior
lighting is minimized and concealed to the maximum feasible extent, and 8-A 12, which calls for
exploring the use of high-efficiency technology, would ensure that impacts to light and glare, as
a result the proposed Ballot Initiative would not result in any new or more significant impacts to
light and glare than were evaluated and disclosed in the General Plan EIR Therefore, impacts of
the proposed Project and General Plan EIR are less than significant, as shown on page 3 1-16 of
the General Plan EIR Because no new impacts would occur, no new mitigation is necessary
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11 Agriculture and Forest Resources.
1 Threshold 5 2(a) Convert Pinne Farmland, Unique Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the maps pi epared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to non-agricultural use
Finding No Impact/No New Impact (Draft SEIR,pages 5-3 to 5-4 )
Approximately 7 percent of the total land in the City is put to agricultural use Prime and Unique
Farmland, as well as Farmland of Statewide Importance is scattered throughout the City, mostly
on the periphery where development is less intense According to maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the California Department of Conservation, the
TVPA is designated "Urban and Built-Up Land" (CDC 2016a) According to Figure 2 3-1,
Gene'al Plan Land Use, of the General Plan EIR, no portions of the TVPA rs designated as
agriculture Figure 3 2-1, Farmland Classifications, of the General Plan EIR, the Project area is
classified as "Urban and Built Up " However, General Plan EIR Actions 2-A 84, which calls foi
the establishment of new groves at the City's entrances/gateways to announce the City's citrus
heritage, where practical, and Action 2-A 87, would continue to apply As shown m Figure 3,
Transit Village Land Use, the areas affected by the proposed Project ale not adjacent to
agricultural areas and are developed with urban uses Therefore, no impact would occui The
General Plan EIR, on page 3 2-12, identified this impact as significant and unavoidable,
however, as there is no land designated as agriculture in the TVPA, the proposed Pioject, would
have no new impact, and therefore, would not exaceibate this impact beyond what was identified
in the General Plan EIR Because no new impact would occui, no new mitigation is necessary
2 Thi eshold 5 2(b) Conflict with existing zoning foi agricultural use, or a Williamson Act
contract
Finding No Impact/No New Impact (Draft SEIR,page 5-4 )
Property subject to Williamson Act contracts is spread throughout the periphery of the City,
where most contracted land is located in Crafton, San Tnnoteo Canyon, and north of the City
near the Santa Ana River Wash According to the California Department of Conservation, the
TVPA is designated "Urban and Built-Up Land" (CDC 2016b) Therefore, the proposed Project
would not conflict with an existing Williamson Act contract or zoning for agricultural use No
impact would occur The General Plan EIR identified this impact as being less than significant,
on page 3 2-16 of the General Plan EIR, however, as there are no Williamson Act contracts in
the project area or no properties zoned for agricultural use, this impact, under the proposed
Project, would have no impact, and therefore, would not exaceibate this impact beyond what was
identified in the General Plan EIR Because no impact would occur, no new mitigation is
necessary
3 Thi eshold 5 2(c) Conflict with existing zoning foi, or cause rezoning of, forest land (as
defined m Public Resources Code Section 12220(g)), timberland (as defined by Public Resources
Code Section 4526), or timberland zoned Timberland Production (as defined by Government
Code Section 51104(g)) (Draft SEIR, page 5-4 )
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Finding No Impact/No New Impact (Draft SEIR, page 5-4 )
The proposed Project would not change existing land use of zoning designations Theiefore, no
rezoning of forest land or timberland is proposed or would result from Project implementation
No impact would occur, and the policies and actions mentioned in General Plan EIR would
continue to be implemented As with the General Plan EIR, which identified that no impacts
would occur as the General Plan area does not have forest resources or land zoned for forest use
on page 3 16-1 of the General Plan EIR, the proposed Project would also result in no impact
Because no new impact would occui, no new mitigation is necessary
4. Threshold 5 2(d) Result in the loss of forest land or conversion of forest land to non-
forest use
Finding No Impact/No New Impact (Draft SEIR,page 5-4 )
The Project site is located in an urbanized area within the City of Redlands No land in the
Project site is designated as forest land Therefore, no forest land would be lost or converted due
to Project implementation No impact would occur As with the Geneial Plan EIR, which
identified that no impacts would occui as the General Plan area does not have forest resources or
land zoned for forest use on page 3 16-1 of the General Plan EIR, the proposed Project would
also iesult in no impact
5 Threshold 5 2(e) Involve other changes in the existing environment which, due to their
location or nature, could result in conversion of Farmland, to non-agricultural use or conversion
of forest land to non-forest use (Draft SEIR, page 5-7 )
Finding No Impact/No New Impact (Draft SEIR, page, 5-7 )
The Project site does not contain forest land Implementation of the proposed Project would not
change existing land use or zoning designations and would not iesult m the conversion of
farmland to nonagricultural use or forest land to non-forest use (see response to Impacts 5 2[a]
and 5 2[d]) Therefore, no impact would occur The Geneial Plan EIR, on page 3 2-16, identified
this impact as less than significant, howevei, as there is no land designated as agriculture in the
project area, this impact, under the proposed Project, would have no impact, and therefore,
would not exacerbate this impact beyond what was identified in the General Plan EIR Moieover,
as with the General Plan EIR, which identified that no impacts would occur as the General Plan
area does not have forest resources or land zoned for forest use on page 3 16-1 of the General
Plan EIR, the proposed Project would also result in no impact
III Air Quality•
1 Thr eshold 5 3(a) Conflict with or obstruct implementation of the applicable air quality
plan
Finding No Impact/No New Impact (Draft SEIR,pages 5-7 to 5-8 )
The South Coast Air Quality Management District (SCAQMD) adopted the 2016 Air Quality
Management Plan (AQMP) on March 3, 2017 Regional growth projections are used by
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SCAQMD to forecast future emission levels in the South Coast Air Basin (SoCAB) For
southern California, these regional growth projections are provided by the Southern California
Association of Governments (SLAG) and are partially based on land use designations included
in city/county general plans Typically, only Iarge, regionally significant projects have the
potential to affect the regional growth projections In addition, the consistency analysis is
generally only required in connection with the adoption of General Plans, specific plans, and
regionally significant projects The General Plan EIR determined that the Geneial Plan would be
consistent with the AQMP based on two key indicators of consistency One indicator of
consistency is whether a project would result in an increase in the frequency or severity of
existing air quality violations, cause or contribute to new violations, or delay timely attainment
of the AAQS The other indicator of consistency is whether a project would exceed the growth
assumptions of the AQMP
The proposed Project is a Ballot Initiative that, if approved by voters, would allow the City
Council to consider future projects within the TVPA without the burden of the annual residential
dwelling unit limitation No specific development project is proposed in the Ballot Initiative In
addition, the proposed Project would not increase or change the overall land use buildout
assumed and analyzed in the General Plan EIR Thus, the proposed Project would not affect the
regional growth of the City and would be consistent with the overall growth forecast assumed in
the General Plan FIR Furthermore, the proposed Project would not result in generation of
emissions beyond the emissions considered in the General Plan EIR Therefore, the proposed
Project would not obstruct implementation of the AQMP and no new or substantially greater
impacts would occur when compaied to those identified in the General Plan EIR The following
policies and actions in the General Plan would continue to be implemented if the proposed Ballot
Initiative is approved 4-P 44, 5-P 4, 5-P 5, 5-A 19, 5-P 19, 5-P 20, 5-A 27, 5-A 32, 5-A 34, 5-
A 37, 5-P 25, 5-P 26, 5-P 27, 5-A 66, 7-A 44, 7-A 46, 7-P 44, 7-P 45, 7-P 46, 7-P 47, 7-P 48, 7-
A 144, 7-A 145, 7-A 146, 7-A 147, 7-A 148, 7-A 149, 7-A 150, 7-A,151, 7-A 152, 8-P 1, 8-P 2,
8-P 3, 8-A 1, 8-A 2, 8-A 4, 8-A 7, 8-A 8, 8-P 8, 8-A 39, 8-A 40, 8-A 41, 8-A 45, 8-A 46 For
example, Action 7-A 46 encourages the provision of bike lockers, bike-sharing, and other
methods of supporting alternative modes of transportation, which would lessen impacts to air
quality due to loweied reliance on vehicles Overall, the proposed Project would be consistent
with the impacts identified in General Plan EIR, and the level of impact (less than significant)
remains unchanged, as indicated on page 3 3-20 of the General Plan EIR Because no new
impact would occur, no new mitigation is necessary
2 Thi eshold 5 3(b) Result in a cumulatively considerable net increase of any criteria
pollutant for which the project region is non-attainment under an applicable federal or state
ambient air quality standard
Finding No Impact/No New Impact (Draft SEIR,pages 5-8 to 5-9 )
Any project that produces a significant project-level regional air quality impact in an area that is
nn nonattainment adds to the cumulative impact Due to the extent of the SoCAB area and the
large number of cumulative project emissions, a project would be cumulatively significant if
project-related emissions exceed the SCAQMD regional significance emissions thresholds
(SCAQMD 1993)
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Construction
Construction activities produce combustion emissions from various sources, such as onsite
heavy-duty construction vehicles, vehicles hauling materials to and from the site, and motor
vehicles transporting the construction crew Site prepaiatlon activities produce fugitive dust
emissions (PM10 and PM2 5) from demolition and soil-distuibmg activities, such as grading and
excavation Air pollutant emissions from construction activities would vary daily as construction
activity levels change The General Plan EIR determined that while state (e g , California Air
Resources Board (CARB) Airborne Toxic Control Measures (ATCM) and regional (e g ,
SCAQMD Rule 403) regulations in addition to existing and proposed City policies and General
Plan EIR principles would minimize construction-related emissions, these regulations and
policies would not guarantee that emissions would be reduced to below the SCAQMD regional
significance thresholds Thus, regional construction-related impacts were determined to be
significant and unavoidable in the General Plan EIR
As stated, the proposed Project does not propose any specific development project and would not
result in increasing or changing the overall buildout land use assumptions analyzed in the
General Plan EIR Thus, the proposed Project would not result in any new impacts, or increase
the severity of impacts, with respect to violation of air quality standards or contnbutmg
substantially to an existing or projected au quality violation from construction activities
Therefore, no new or substantially greater short-term regional air quality impacts would occur
under the proposed Project when compared to those identified in the General Plan EIR The
proposed Project would be consistent with the impacts identified in Geneial Plan EIR, and the
level of unpact (significant and unavoidable) remains unchanged Because no new impact would
occur, no new mitigation is necessary
Operation
Typical long-term air pollutant emissions generated by development projects aie from area
sources (e g , consumer cleaning products and paints), energy usage (i e , natural gas used foi
heating and cooking), and mobile sources (i e , vehicle trips) Regional long-term impacts were
determined to be significant and unavoidable m the General Plan EIR as the 2035 General Plan
would result in emissions that exceed the SCAQMD iegional significance thuesholds
The proposed Project would not increase or change the overall buildout land use assumptions as
analyzed in the General Plan EIR and does not propose a specific development project Thus, the
proposed development would not introduce additional land use developments beyond those
consideied in the General Plan EIR and would not result in new additional sources of emissions
While, the Ballot Initiative would allow the City Council to consider future projects withal the
TVPA without the burden of the annual residential dwelling unit limitation, impacts in the 2017
General Plan EIR are based on the worst-case day at full buildout The policies and actions in the
General Plan EIR, including those mentioned m Impact 5 3(a), as well as 7-A 35 and 7-A 38,
would continue to be implemented Action 7-A 149 states that construction and giading projects
should minimize short-term impacts to air quality by requiring grading projects to provide a
storm water pollution prevention plan (SWPPP) in compliance with City requirements which
include best management practices (BMPs) that control pollutants from construction activities,
requiring grading projects to undertake measures to minimize NOx emissions from vehicle and
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equipment operations, and monitoring all construction to ensure that proper steps are
implemented Therefore, it would not result in new or substantially greater long-term iegional air
quality impacts compared to those identified in the General Plan EIR Overall, the proposed
Project is consistent with the project and cumulative impacts identified in General Plan EIR, and
the level of impacts (significant and unavoidable) remain unchanged, as shown on page 3 3-29 of
the General Plan EIR Because no new impact would occur, no new mitigation is necessary
3 Threshold 5 3(c) Expose sensitive receptors to substantial pollutant concentrations
Finding No Impact/No New Impact (Draft SEIR, pages 5-9 to 5-10 )
Construction
The General Plan EIR concluded that sensitive receptors would not be exposed to substantial
pollutant concentrations from construction activities as emissions from off-road construction
equipment and heavy-duty diesel trucks are regulated by CARB's ACTMs Thus, the General
Plan EIR determined localized construction-related air quality impacts to be less than significant
As discussed in Impact 5 3(b), no new additional development would occur if the proposed ballot
initiative is approved by voters compared to the land uses considered in the General Plan EIR
Furthermore, development would not occur outside of the areas designated for development as
analyzed in the General Plan EIR Thus, the proposed Project would not potentially result in
additional construction activities beyond that considered in the General Plan EIR Therefore, the
pioposed Project would not result in new, or substantially increase the severity of short-term
localized and health risk impacts compared to that identified in the General Plan EIR Overall,
the proposed Project is consistent with the impact identified in the General Plan EIR, and the
level of impact (less than significant) remains unchanged Because no new impact would occui,
no new mitigation is necessary
Operation
Types of land uses that have the potential to generate substantial stationary sources of emissions
include industrial land uses that would iequire a permit from SCAQMD, such as manufacturing
and chemical processing facilities, and warehousing operations where substantial truck traffic
could occui onsite Operation of non-industrial and non-warehousing development projects (e g ,
office, retail, residential, etc ) would generate onsite emissions fiom use of standard onsite
mechanical equipment such as heating, ventilation, and air conditioning units in addition to
occasional use of landscaping equipment foi property management Howevei, onsite criteria air
pollutant emissions generated from these sources are generally nominal In addition to onsite
emissions, pioposed development projects also have the potential to create pockets of carbon
monoxide (CO) called hotspots in areas of high vehicle congestion Hotspots are typically
produced at intersections, where traffic congestion is highest because vehicles queue for longer
periods and are subject to reduced speeds
The General Plan EIR determined localized operation-related air quality impacts to be less than
significant Per the General Plan EIR, stationary sources that have the potential to generate
substantial pollutant concentrations would be controlled through the SCAQMD permitting
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process per Rule 1401 Additionally, emissions associated with heavy-duty diesel trucks would
be controlled through compliance with CARB standards for diesel engines
The proposed Project does not propose a specific development project and would not result m an
increase of change in the overall buildout land use assumptions identified in the Geneial Plan
EIR Thus, no new land use developments would occur, and no additional vehicle trips would be
generated beyond what was considered in the General Plan EIR Therefore, compared to that
identified in the Geneial Plan EIR, the proposed Project would not result m new, or substantially
increase the severity of; operation-related localized air quality impacts with respect to exposure
of sensitive receptors to substantial pollutant concentrations from operational activities The
policies and actions of the General Plan EIR, 5-P 5, 7-P 44, 7-P 45, 7-P 46, 7-P 47, 7-P 48, 5-
A 27, 5-A 37, 5-A 66, 7-A 144, 7-A 145, 7-A 146, 7-A 147, 7-A 148, 7-A 150, 7-A 151, 7-
A 152, 7-P 49, 7-A 153, and 7-A 154 would continue to be implemented under the proposed
Project in order to lessen impacts to an quality For instance, Action 7-A 148 calls for the
development of requirements for ietrofitting existing residential buildings within the 500 foot
AQMD buffer along the freeway to abate air pollution, and limitations on new residential
developments within the buffer, thereby reducing impacts to an quality for those living within
the AQMD buffer Overall, the proposed Project is consistent with the impacts identified in the
Geneial Plan EIR, and the level of impacts (less than significant) would remain unchanged, as
indicated on page 3 3-31 of the General Plan EIR Because no new impact would occur, no new
mitigation is necessary
4 Thi eshold 5 3(d) Result m other emissions (such as those leading to odors) adversely
affecting a substantial number of people
Finding No Impact/No New Impact (Draft SEIR,page 5-11 )
The type of facilities that aie considered to have objectionable odors include wastewater
treatments plants, compost facilities, landfills, solid waste transfer stations, fiberglass
manufactul Ing facilities, paint/coating operations (e g , auto body shops), dairy farms, petroleum
refineries, asphalt batch plants, chemical manufacturing, and food manufacturing facilities
Additionally, during construction activities, construction equipment exhaust and application of
asphalt and architectural coatings would temporarily generate odors The General Plan EIR
detemmmed odor impacts would be less than significant as construction-related odors would be
temporary and occur at magnitudes that would not affect a substantial number of people and
because developments under the 2035 General Plan would be in compliance with all local, state,
and federal regulations related to control of operation-related odors
As stated, the proposed Project does not propose a specific development project and would
neither increase nor change the overall buildout land use assumptions identified in the General
Plan EIR Thus, no new and additional developments and construction activities would result
related to the proposed Project Therefore, no new or substantially greater odor impacts would
occur with implementation of the proposed Project when compared to those identified in the
General Plan EIR The policies and actions mentioned in the General Plan EIR, 7-P 44, 7-P 48,
7-A 144, 7-A 147, 7-A 148, and 7-A 149 would reduce impacts to air quality, and would
continue to be implemented by the proposed Project Overall, the proposed Project is consistent
with the impacts identified i1 the General Plan EIR, and the level of impacts (less than
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significant) would remain unchanged, as shown on page 3 3-32 of the General Plan EIR
Because no new impact would occur, no new mitigation is necessary
IV Biological Resources:
1 Threshold 5 4(a) Have a substantial adverse effect, eithei directly or through habitat
modifications, on any species identified as a candidate, sensitive, oi special status species in
local or regional plans, policies, or regulations, oi by the California Department of Fish and
Game oi U S Fish and Wildlife Service
Finding No New oi More Significant Impact (Draft SEIR, pages 5-11 to 5-12 )
There are 19 species that are state oi federally listed as rate, threatened, or endangered species
that have been oi were identified as potentially present within the General Plan Area Vegetation
types withm the Project site are designated as Developed/Ruderal and Annual Grassland, as
shown in Figure 3 4-1, Existing vegetation, of the General Plan EIR, wheie future development
in these areas are expected to a have a lowei impact on sensitive species and then habitats as
these vegetation types have limited value As shown in Figure 4, Aer ial Photograph, the TVPA
is an urban area with little biological value While much of the area is built it is possible that
some biological resources exist and therefore implementation of the policies and actions of the
General Plan EIR would reduce potential impacts to less than significant 6-P 7, 6-P 8, 6-A 11, 6-
A 12, 6-A 13, 6-A 14, 6-A 36, and 6-A 37 For example, Action 6-A 11 requires a biological
assessment of any proposed Project site within the Planning Area where species that are state or
federally listed as rare, threatened, oi endangered are identified as potentially present Therefore,
the proposed Project would have a less than significant impact to biological resources upon the
implementation of the Genial Plan policies and actions Impacts are less than significant for the
proposed Project and General Plan EIR as indicated on page 3 4-25 of the General Plan EIR
Because no new impact would occur, no new mitigation is necessary
2 Thr eshold 5 4 (b) Have a substantial adverse effect on any riparian habitat oi other
sensitive natural community identified in local or regional plans, policies, regulations or by the
California Department of Fish and Game or U S Fish and Wildlife Service
Fmdmg No New Impact (Draft SEIR, page 5-12 )
As stated in the General Plan EIR, future development may result in significant impacts on
riparian vegetation oi other sensitive natural communities, especially on land with native
vegetation adjacent to or immediately upstream of the Santa Ana River. Mill Creek, and San
Timoteo Creek However, most riparian areas are designated Open Space and would be
protected from direct impacts from development According to Figure 3 4-1, there are no riparian
habitats on the Project site The Project site is located in a highly urbanized area Therefore. no
impact would occur The General Plan EIR identified this impact as less than significant as
indicated on page 3 4-28 of the General Plan EIR however, as there are no riparian habitats in
the project area. no impacts would occur under the proposed Project Because no new impact
would occur, no new mitigation is necessary
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3 Thr eshold 5 4(c) Have a substantial advei se effect on federally protected wetlands as
defined by Section 404 of the Clean Water Act (iicludmg, but not limited to, marsh, vernal pool,
coastal, etc) through direct removal, fillmg, hydrological interruption, oi other means
Finding No New Impact (Draft SEIR, page 5-12 )
The General Plan EIR stated that several of the natural watercourses in Figure 3 4-2 Critical
Habitat and Pr incipal Water s. would likely be considered under the federal jurisdiction of the
USACE as waters of the U S These areas may include smaller diamages particularly in the hilly
areas in the southern and eastern portions of the General Plan Area, and the Zanja and Morey
Arroyo artificial ditches. The 2035 General Plan does not plan foi development on any federally
protected wetlands However accoidmg to Figure 3 4-2 there are no principal waters in the
Project site, and therefore, no impact would occur The General Plan EIR identified this impact
as less than significant as indicated on page 3 4-29 of the General Plan EIR, howevei, as there
are no wetlands in the project area, no impacts would occur under the proposed Project Because
no new impact would occui no new mitigation is necessary
4 Thr eshold 5 4(d) Interfere substantially with the movement of any native resident or
migratory fish oi wildlife species or with established native resident or migratory wildlife
corridors or impede the use of native wildlife nursery sites
Finding No New Impact (Dealt SEIR, pages 5-12 and 5-15 )
The General Plan EIR indicated that many drainages, canyons, and extensive hillsides with
native vegetation can provide corridors or areas for travel for local wildlife, especially where
such drainages or areas connect to larger areas of undisturbed native vegetation, all of which can
provide a variety of resources and protection for native wildlife. The proposed Project is in a
highly urbanized area within the City, according to Figure 3 4-1. the Project area is classified as
predominantly developed/rudei al, with small portions of annual grassland Additionally, Figure
3 4-2 indicates that there are no critical habitats in the Project area critical habitats are found in
the northern portion of the City. Due to the Project site's highly urbanized environment, and the
lack of large contiguous undisturbed native vegetation and critical habitat areas it is unlikely that
development in the TVPA would impact migratory wildlife and corridors, therefore. no impact
would occur The General Plan EIR identified this impact as less than significant, as indicated on
page 3 4-30 of the General Plan EIR, however, as there are no wildlife corridors or critical
habitats in the project area, no impacts would occui under the proposed Project Because no new
impact would occur, no new mitigation is necessary.
5 Thr eshold 5 4(e) Conflict with any local policies or ordinances protecting biological
resources, such as a tree preservation policy or ordinance
Fielding No New or More Significant Impact (Draft SEIR, page 5-15 )
The proposed Project would not change the existing policies and actions of the 2035 General
Plan that promote the health and maintenance of street trees Nor would the proposed Project
affect implementation of Municipal Code Chapter 12 52, Trees and Tree Protection Along
Streets and in Public Places The 2035 Geneial Plan is consistent with the Upper Santa Ana
Wash Land Management and Habitat Conservation Plan (Wash Plan) and the San Bernardino
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County General Plan Implementation of the proposed Project would be required to comply with
ordinances and programs to protect biological resources, and the following policies would reduce
impacts of the proposed Project to less than significant 2-A 70, 2-P 18, 2-P 19, 2-P 20, 2-A 77,
2-A 78, 2-A 79, 2-A 80, 2-A 81, 2-P 23, 2-A2-A 78, 2-A 79, 2-A 80, 2-A 81, 2-A, 2-A 87, and
6-A 10 Foi example, Action 2-P 20 of the General Plan EIR calls for the use of street trees to
differentiate arterials and to reduce the apparent width of wide streets, and Action 2-A 79 of the
General Plan EIR calls for the avoidance of sound walls as a standard on arterial streets in
residential areas Implementation of the proposed Project would be required to comply with
ordinances and programs to protect biological resources, as well as with the policies and actions
of the General Plan EIR, which would reduce impacts of the proposed Project to less than
significant Impacts are less than significant for the proposed Project and the General Plan EIR,
as indicated on page 3 4-33 of the General Plan EIR Because no new impact would occur, no
new mitigation is necessary
6 Threshold 5 40 Conflict with the provisions of an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, of other approved local, regional, or state habitat
conservation plan
Finding No New Impact (Draft SEIR, page 5-15 )
There aie no adopted regional HCPs or natural community conservation plans that cover the
Project site, however the City participates in the Wash Plan which has a habitat conservation
plan component. The Project site is located in a highly urbanized portion of the City. and is not
located within the Santa Ma River Wash. Therefore, no impacts would occur Because no new
impact would occur, no new mitigation is necessary
V Cultural Resources.
1 Threshold 5 5(a) Cause a substantial adverse change in the significance of a historical
resource as defined in CEQA Guidelines §15064 5 (Draft SEIR, pages 5-16 to 5-17 )
Finding No New or More Significant Impact (Draft SEIR, pages 5-16 to 5-17 )
The implementation of the 2035 General Plan would not directly result in the destruction of, or
damage to, historical resources, however, future development and redevelopment permitted
under the 2035 General Plan could result in changes that affect historic resources According to
Figure 3 8-1, Htstoi is Resow ces, of the General Plan EIR, the Project area contains local historic
landmarks and resources, national/state historic district (Santa Fe Depot District), national/state
district contributors, sites on the national register (US Post Office and Redlands Cential Railway
Company Car Barn), and portions of local district contributors (HD8 Smiley Park Neighborhood
District and Scenic District) Impacts that development within the TVPA may have on the
foregoing Historic Resources would be considered significant if they were to cause a substantial
adverse change to the historical resources as defined by State CEQA Guidelines section 15064 5
Thus, at the time of development or redevelopment, project-level CEQA documentation would
need to identify potential impacts on known or potential historic sites and structures
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At a minimum, the State CEQA Guidelines would require a project with potentially adverse
impacts to historic resources to conform with the Secretary of the Interior's Standards for the
Treatment of Historic Pioperties In addition, the Redlands Historic and Scenic Preservation
Oidinance (Ordinance 1954 § 1, 1986) as found in Redlands Municipal Code Chapter 2 62,
Historic and Scenic Preservation, and the policies and actions of the 2035 General Plan would
further work to avoid or minimize impacts of future development on historical resources 2-P 8,
2-P 9, 2-P 10, 2-P 11, 2-P 12, 2-P 14, 2-P 15, 2-A 23, 2-A 24, 2-A 25, 2-A 26, 2-A 27, 2-A 28, 2-
A 30, 2-A 31, 2-A 32, 2-A 33, 2-A 34, 2-A 36, 2-A 37, 2-A 38, 2-A 39, 2-A 40, 2-A 41, 2-A 42,
2-A 43, 2-A 44, 2-A 45, 2-A 46, 2-A 47, 2-A 48, 2-A 49, 2-A 50, 2-A 51, 2-A 52, 2-A 53, 2-
A 54, 2-A 55, 2-A 56, 2-A 57, 2-A 58, 2-A 59, 2-A 60, 2-A 61,2-A 62, 2-A 63, 2-A 64, 2-A 65,
2-A 66, 2-A 67, 2-A 68, and 2-A 70 For example, Action 2-A 25 requires any application that
would alter or demolish an undesignated and non-surveyed resource over 50 years old to be
assessed in the merits of the structure, and to be approved by the Historic and Scenic
Pieservation Commission The Pioject site includes historic resources, as depicted in Figure 3 8-
1, Histor is Resoui ces, of the General Plan EIR With the implementation of the policies and
actions of the 2035 General Plan, and the appropriate CEQA project-level analysis, impacts to
historic iesources would be less than significant Impacts of the proposed Project and the General
Plan EIR are less than significant as indicated on page 3 8-18 of the Geneial Plan EIR Because
no new impact would occur, no new mitigation is necessary
2 Thi eshold 5 5(b) Cause a substantial adverse change in the significance of an
archaeological resource pursuant to § 15064 5
Finding No New or More Significant Impact (Draft SEIR, page 5-17 )
The records search conducted for the 2035 Geneial Plan indicated the presence of 11 area
prehistoric resources within one mile of the 2035 Geneial Plan Ai ea As the records search area
has not been 100 percent studied and there are areas within the 2035 General Plan Area that have
never been examined oi researched, there is potential for new archaeological iesources to be
discovered in the future Futuie development allowed under the 2035 General Plan may involve
grading, excavation, overland vehicle travel, or other ground-disturbing activities, or could
facilitate public access to archaeological sites which could disturb oi damage unknown
archaeological iesources Although the implementation of the proposed Project may result in
actions that could adversely affect archaeological resources, the policies and actions of the
General Plan EIR would ensure that impacts to archaeological resources would be reduced to
less than significant 2-P 17, 2-A 71, 2-A 72, 2-A 73, and 2-A 74 For example, Action 2-A 72
requires that applicants for projects identified by the South Cential Coastal Information Center as
potentially affecting sensitive resource sites hire a consulting archaeologist to develop an
archaeological resource mitigation plan and to monitor the project to ensure mitigation measures
aie implemented Therefore, the implementation of the proposed Project would result in less than
significant impacts to archaeological resources Impacts of the proposed Project and the General
Plan EIR are less than significant as indicated on page 3 8-24 of the General Plan EIR Because
no new impact would occur, no new mitigation is necessary
3 Thr eshold 5 5(c) Disturb any human remains, including those interred outside of
dedicated cemeteries
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Funding No New or More Significant Impact (Draft SEIR, pages 5-17 to 5-18 )
The Geneial Plan EIR indicated that human remains, particularly those interred outside formal
cemeteries could be disturbed during gaffing, excavation, or other ground-distuibmg activities
associated with future development or redevelopment projects allowed under the 2035 General
Plan The treatment of Native American Human remains is regulated by Public Resources Code
Section 5097 98, as amended by Assembly Bill (AB) 2641, which addresses the disposition of
Native American burials, protects remains, and appoints the NAHC to resolve disputes Health
and Safety Code 7050 5 includes specific provisions foi the protection of human remains in the
event of discovery Although the 2035 Geneial Plan does not include any goals oi policies that
directly address the disturbance of human remains, future development and redevelopment
projects, as a iesult of the proposed Project, would be required to adhere to the appropriate laws
and regulations, including AB 52 and Senate Bill (SB) 18, which require consultation with
California Native American Tribes The City has completed consultation with Native American
tribes for the proposed Project On February 15, 2019, the City sent Consultation Request letters
to 22 tnbes, responses were received from the following tribes Agua Caliente Band of Cahuilla
Indians, San Manuel Band of Mission Indians, and Augustme Band of Cahuilla Mission Indians
The Agua Caliente Band of Cahuilla Indians and San Manuel Band of Mission Indians
concluded consultation stating that there would be no conflict as a result of the proposed Project
The Augustune Band of Cahuilla mission Indians had no concerns and did not request
consultation Thus, the implementation of the proposed Project would iesult in less than
significant impacts Impacts of the proposed Project and the General Plan EIR are less than
significant as indicated on page 3 8-28 of the General Plan EIR Because no new impact would
occur, no new mitigation is necessary
VI Energy
1 Threshold 5 6(a) Result in potentially significant environmental impact due to wasteful,
inefficient, oi unnecessary consumption of energy resources, during project construction or
operation
Fmdmg No New oi More Significant Impact (Draft SEIR, page 5-18 )
The Geneial Plan EIR indicated that development would increase future energy consumption
within the 2035 Geneial Plan area which would result in additional demand for electricity
and natural gas supply and services Although the implementation of the proposed Project
would increase the population and employment in the City, the increase would not exceed the
estimates shown in Table 2 3-5, Projected Population at Buildout (2035) and Table 2 3-6,
Projected Non-Residential Buildout (2035) of the General Plan EIR, and associated energy
demand above existing conditions Compliance with the state's current and future energy
code, Title 24 energy, and the policies and actions of the General Plan EIR would minimize
wasteful, mefficient energy consumption 7-A 44, 8-P 1, 8-P 2, 8-P 3, 8-A 1, 8-A 2, 8-A 3, 8-
A 4, 8-A 5, 8-A 7, 8-A 8, 8-A 9, 8-A 10, 8-A 11, 8-A 12, 8-A 13, 8-A 14, 8-A 15, 8-A 16, 8-
A 17, 8-A 18, 8-A 20, 8-A 27, 8-A 29, 8-A 35, 8-A 38, 8-A 39, 8-A 40, 8-A 41, 8-A 43, 8-
A 44, and 8-P 10 Foi example, Action 8-A 5 calls foi the acceleration of the adoption of
solar power and/or other alternative energy usage in Redlands though actions such as
developing guidelines, recommendations, and examples for cost-effective solar and/or other
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alternative energy-based installation, which would ensure efficient use of energy Impacts of
the proposed Project and the General Plan EIR are less than significant as indicated on 3 5-18
of the General Plan EIR Because no new impact would occur, no new mitigation is
necessary
2 Threshold 5 6(b) Conflict with oi obstruct a state oi local plan for renewable energy or
energy efficiency (Draft SEIR, pages 5-18 to 5-19 )
Finding No New oi More Significant Impact (Draft SEIR, pages 5-18 to 5-19 )
As indicated in the General Plan EIR, all future development under the 2035 General Plan
would be iequired to comply with the latest California Building Code (CBC) requirements,
including CBC Energy Efficiency Standards, as well as federal, state, and local rules and
regulations pertaining to energy consumption and conservation The General Plan EIR
includes policies and actions (See Impact 5 6[a]) that emphasize energy reduction strategies
The Climate Action Plan (CAP), which is intended for implementation through 2035,
includes an inventory of citywide greenhouse gas (GHG) emissions, forecasts of future
citywide GHG emissions, monitoring and reporting processes to ensure State GHG targets
are met, and options for reducing GHG emissions beyond State requirements Through the
implementation and compliance with federal, state, and local regulations as well as the
General Plan EIR policies and actions, the proposed Project would not conflict with or
obstruct plans for energy or energy efficiency 7-A 44, 8-P 1, 8-P 2, 8-P 3, 8-A 1, 8-A 2, 8-
A 3, 8-A 4, 8-A 5, 8-A 7, 8-A 8, 8-A 9, 8-A 10, 8-A 11, 8-A 12, 8-A 13, 8-A 14, 8-A 15, 8-
A 16, 8-A 17, 8-A 18, 8-A 20, 8-A 35, 8-A 38, 8-A 39, 8-A 40, 8-A 41, 8-A 43, 8-A 44, 8-
P 10, 2-A 5, 2-A 6, 2-A 18, 2-A 34, 2-A 69, 2-A 77, 2-A 80, 2-A 92, 2-A 99, 4-P 9, 4-A 12,
4-A 18, 4-A 95, 4-P 41, 4-P 44, 4-P 45, 4-A 99, 4-A 104, 4-A 105, 4-A 106, 4-A 108, 4-
A 110, 4-A 112, 4-A 113, 4-A 114, 4-A 115, 4-A 116, 4-A 118, 4-A 124, 4-A 125, 4-A 126,
4-A 131, 4-A 132, 4-A 134, 5-P 13, 5 P-14, 5-A 3, 5-A 4, 5-A 5, 5-A 6, 5-A 7, 5-P 16, 5-
P 17, 5-P 18, 5-A 17, 5-A 18, 5-A 19, 5-A 21, 5-P 19, 5-P 20, 5-A 22, 5-A 23, 5-A 24, 5-
A 25, 5-A 26, 5-A 27, 5-A 28, 5-A 29, 5-A 32, 5-A 33, 5-A 41, 5-A 47, 5-P 25, 5-P 26, 5-
A 54, 5-A 55, 5-A 56, 5-A 57, 5-A 58, 5-A 59, 5-A 60, 5-A 61, 5-A 62, 5-A 63, 5-A 64, 5-
A 65, 5-P 27, 5-A 66, 5-A 69, 5-A 72, 5-A 73, 7-P 17, 7-A 38, 7-A 39, 7-A 40, 7-A 42, 7-
P 47, and 7-A 146 For example, Action 8-A 40 of the General Plan EIR calls for the
promotion of Leadership in Energy and Environmental Design (LEED) certification program
for the design, operation, and construction of high-performance green buildings Impacts of
the proposed Project and the General Plan EIR are less than significant as identified on page
3 5-22 of the General Plan EIR Because no new impact would occur, no new mitigation is
necessary
VII Geology and Soils
1 Threshold 5 7(a)(1) Directly or indirectly cause potential substantial adverse effects,
including the risk of loss, injury, or death involving rupture of a known earthquake fault, as
delineated on the most recent Alquist-Prrolo Earthquake Fault Zoning Map issued by the State
Geologist for the area or based on other substantial evidence of a known fault Refer to Division
of Mines and Geology Special Publication 42
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Finding No New or More Significant Impact (Draft SEIR, page 5-19 )
As indicated in the Geneial Plan EIR, the 2035 General Plan Aiea is located within a seismically
active area where several faults and fault zones are considered active, Alquist-Priolo Earthquake
Fault Zones have been established for the majority of these faults and fault zones As indicated in
Figuie 3 6-2, Faults, of the General Plan EIR, the location of the proposed Project is not within a
fault zone In addition to adhering to the iequnements of the CBC, the proposed Project would
implement the following policies and actions to reduce impacts to less than significant 7-P 29,
7-A 110, 7-A 111, 7-A 112, 7-A 116, 7-A 117, and 7-A 132 For instance, Policy 7-P 29 calls foi
the investigation and mitigation of geologic and seismic hazards or to locate development away
from such hazards in order to preserve life and protect property The potential for impacts from
fault rupture is less than significant for both proposed Project and the Geneial Plan EIR, as stated
on page 3 6-15 of the Geneial Plan EIR Because no new or more significant impact would
occur, no new mitigation is necessary
2. Tlneshold 5 7(a)(2) Expose people of structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving strong seismic ground shaking
Finding No New or More Significant Impact (Draft SEIR, pages 5-19 to 5-20 )
The Geneial Plan EIR indicated that earthquakes in and near the 2035 General Plan Area have
the potential to cause ground shaking of significant magnitude The Geneial Plan allows for
additional development within the City, which could expose people and pioperty to strong
seismic ground shaking However, as indicated in the General Plan EIR, new buildings would be
constructed in compliance with the CBC Compliance with the CBC as well as the following
General Plan policies and actions would reduce impacts to less than significant 7-P 29, 7-A 110,
7-A 111, 7-A 112, 7-A 116, 7-A 117, and 7-A 132 Action 7-A 110 calls for the use of the
building inspection program to inventory and evaluate earthquake hazards in existing buildings,
the use of the most current seismic design standards and hazards reduction measures, and to
continue the project for the systematic upgrading of seismically unsafe buildings The potential
foi impacts from ground shaking are less than significant for both the proposed Project and the
General Plan EIR as indicated on page 3 6-16 of the General Plan EIR Because no new or more
significant impact would occur, no new mitigation is necessary
3 Threshold 5 7(a)(3) Expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving seismic-related ground failure, including
liquefaction
Finding No New or More Significant Impact (Draft SEIR, page 5-20 )
Liquefaction refers to loose, saturated sand or gravel deposits that lose their load-supporting
capability when subjected to intense shaking During intense shaking, any structures on these
sediments may float, sink, or tilt as if on water Liquefaction potential varies based on three main
factors 1) cohesionless, granular soils with relatively low densities (usually of Holocene age), 2)
shallow groundwater(less than 50 feet), and 3) moderate to high seismic ground shaking Lateral
spreading refers to lateral displacement of large, surficial blocks of soil as a result of pore-
pressure buildup or liquefaction in a subsurface layer
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According to Figure 3 6-4, Liquefaction Susceptibility, of the General Plan EIR, Iocations within
the 2035 Geneial Plan Aiea are considered prone to liquefaction hazards, including the areas in
the northern portion of the 2035 General Plan Area around the Santa Ana River, Mentone
Boulevaid, and Mill Creek Road Most of the areas susceptible to liquefaction have been
designated as Open Space, however, some industrial, commercial, and low-density residential
development are allowed in these areas The location of the proposed Project, according to
Figure 3 6-4, is not located within a liquefaction susceptibility zone As stated in the General
Plan EIR, ground failure including liquefaction from development would be addressed through
site-specific geotechmcal studies prepared in accordance with CBC requirements and standard
industry practices In addition to complying with these standards, the proposed Project would
implement the following policies and actions to ensure that impacts to liquefaction are seduced to
less than significant 6 A-36, 6-A 39, 7-P 29, 7-A 109, 7-A 114, 7-A 116, 7-A 117, and 7-A 132
For example, Policy 7-P 29 calls for the investigation and mitigation of geologic and seismic
hazards or to locate development away from such hazards, in order to preserve life and protect
property Potential impacts from liquefaction are less than significant for both the proposed
Project and the General Plan EIR as indicated on page 3 6-16 of the General Plan EIR Because
no new or more significant impact would occur, no new mitigation is necessary
4. TIn eshold 5 7(a)(4) Expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving landslides
Finding No New or More Significant Impact (Draft SEIR, pages 5-20 to 5-21 )
Susceptibility of slopes to landslides and other slope failures depends on several factors that are
usually present in combinations—steep slopes, condition of rock and soil materials, presence of
water, formational contacts, geologic shear zones, seismic activity, etc
The Geneial Plan EIR stated that highly landslide-susceptible areas aie primarily located in
various parts of southern Redlands and some smaller parts m the eastern portion of the 2035
Geneial Plan Aiea According to Figure 3 6-3, Landslide Potential, of the General Plan EIR, the
location of the proposed Project is not within a landslide potential zone Future development
would be required to address the impacts of landslides through site-specific geotechnical studies
prepared in accordance with the CBC requirements and will implement the following policies
and actions to ensure that impacts are reduced to less than significant 6 A-36, 6-A 39, 7-P 29, 7-
A 114, 7-A 116, 7-A 117, and 7-A 132 For instance, Action 7-A 114, states that for new
construction and exterior building expansions including multi-story additions or lateral
expansions, require the preparation of a geotecluncal/soils/geologic report by a registered civil
geotechnical/soils engineer and a certified engineering geologist The potential impacts from
landslides aie considered less than significant for both the proposed Project and the General Plan
EIR as indicated on page 3 6-17 of the General Plan EIR Because no new or more significant
impact would occur, no new mitigation is necessary
5 Tlar eshold 5 7(b) Result in substantial soil erosion oi the loss of topsoil
Finding. No New oi More Significant Impact (Draft SEIR, page 5-21 )
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Erosion is a normal and inevitable geologic process whereby earthen materials are loosened,
worn away, decomposed, or dissolved, and removed from one place and transported to another
Precipitation, water, waves, and wind are all agents of erosion
As indicated in the General Plan EIR, development associated with the 2035 General Plan would
likely include earthwork activities that could expose soils to the effects of erosion or loss of
topsoil Generally, earthwork and ground-disturbing activities require a grading permit,
compliance with which minimizes erosion, and the City's grading permit requirements ensure
that construction practices include measures to protect exposed soils, such as limiting work to
dry seasons, covering stockpiled soils, and use of straw bales and silt fences to minimize offsite
sedimentation Furthermore, as stated in the General Plan EIR, development that disturbs more
than one acre would be subject to compliance with a National Pollutant Discharge Elimination
System (NPDES) permit, including the implementation of best management practices (BMPs),
some of which are specifically implemented to reduce soil erosion or loss of topsoil, and the
implementation of a storm water pollution prevention plan (SWPPP) through the local
jurisdiction As the proposed Project would include ground disturbing activities that may cause
erosion or loss of topsoil, the proposed Project would comply with the aforementioned
regulations and permits, and implement the following General Plan EIR policies and actions to
reduce impacts 6-A 36, 6-A 39, 7-A 114, 6-A 37, and 7-A 115 Action 7-A 115 requires soil
erosion mitigation during construction Therefore, impacts to erosion or loss of topsoil as a result
of Pioject implementation would be reduced to less than significant upon implementation of
these policies and actions Impacts of the proposed Project and the General Plan EIR would be
less than significant as indicated on page 3 6-20 of the General Plan EIR Because no new or
more significant impact would occur, no new mitigation is necessary
6. Thi eshold 5 7(c) Be located on a geologic unit or soil that is unstable, or that would
become unstable as a result of the project, and potentially result in on- oi off site landslide,
lateral spreading, subsidence, liquefaction, or collapse
FindingNo New or More Significant Impact (Draft SEIR, pages 5-21 to 5-22 )
The General Plan EIR indicated that some improvements associated with implementation of the
2035 General Plan could be located on geologic units or soils that are unstable, of that could
become unstable and result in geologic hazards if not addressed appropriately Soils that exhibit
expansive properties when exposed to varying moisture content over time could result in damage
to foundations, walls, or other improvements Structures could be damaged as a result of
settlement, and construction of new structures in the vicinity of relatively steep slopes could
provide additional loading causing landslides oi slope failure from unstable soils As noted in the
General Plan EIR, the potential hazards of unstable soil or geologic units would be addressed
largely through the integration of geotechnical information in the planning and design process
for projects to determine the local soil suitability for specific projects in accordance with
standard industry practices and state-provided requirements, such as CBC iequireiments In
addition to preparing a geoteclunical report and complying with CBC requaeinents, future
development must also follow General Plan policies and actions 7-P 29, 7-P 30, 6-A 36, 6-A 39,
7-A 107, 7-A 109, 7-A 110, 7-A 114, 7-A 115, 7-A 116, 7-A 117, and 7-A 132, that ensure that
impacts as a result of unstable or expansive soils are reduced to less than significant For
instance, Action 7-A 117, which calls for the use of the Local Hazard Mitigation Plan and
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Emergency Operations Plan to address issues related to seismic hazards, emergency response
preparedness and recovery, and minimum road-width/clearance around structures, to reduce
impacts to less than significant Impacts of the proposed Project and the General Plan EIR would
be less than significant as indicated on page 3 6-21 of the General Plan EIR Because no new or
more significant impact would occur, no new mitigation is necessary
7. Threshold 5 7(d) Be located on expansive soil, as defined in Table 18-1-B of the
Uniform Building Code (1994), creating substantial direct or indirect risks to life or property
Finding No New or More Significant Impact (Draft SEIR, page 5-22 )
See response to 5 7(c) This impact is less than significant Because no new or more significant
impact would occur, no new mitigation is necessary
8 Threshold 5 7(e) Have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers aie not available for the disposal of
wastewater
Finding No New Impact (Draft SEIR, page 5-22 )
The City of Redlands Public Services Ordinance (Ord 1000 § 11, 1955) of Chapter 18 04,
Gene;al Provisions, prevents well drilling near septic tanks As the proposed Project is located in
a highly urbanized area within the City with adequate wastewater collection system, the
proposed Project would not require the installation of a septic tank or alternative wastewater
disposal system The proposed Project would connect to existing sewer main lines and service
lies within the Project area Therefore, no impact would occur The General Plan EIR identified
this impact as less than significant, on page 3 6-22 of the General Plan EIR, however, due to the
highly urbanized nature of the project area, no impacts would occur Because no new or more
significant impact would occur, no new mitigation is necessary
9. Threshold 5 7(D Directly or indirectly destroy a unique paleontological resource or site
or unique geologic feature
Finding No New of More Significant Impact (Draft SEIR, pages 5-22 to 5-23 )
Some portions of the City, especially in San Timoteo Canyon, are underlain by geologic
formations that have yielded fossiliferous materials, and it is possible that future development
within the City could cause significant impacts on these resources if they are disturbed during
grading or excavation activities Construction activities such as grading, excavation, and ground
disturbing activities may result in the accidental destruction or disturbance of paleontological
sites However, the majority of development anticipated under the 2035 General Plan would
involve redevelopment of or new development within existing developed areas Substantial
excavation activities for installation of new infrastructure would be limited to new development
in undeveloped areas, potential for this type of development does exist but is limited by the 2035
General Plan Thus, the likelihood of finding new or undiscovered paleontological resources
would be limited As the location of the proposed Project is in a highly urbanized area of the
City, it is unlikely that new or undiscovered paleontological resources would be discovered
Further, with the implementation of the General Plan policies and actions 2-P 17, 2-P 16, 2-A 75,
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and 2-A 76, impacts to paleontological resources would be less than significant For example,
Action 2-A 75 requues, as a standard condition of approval, that project applicants provide an
assessment as to whether grading for a proposed project would impact undeilymg soil units or
geologic formations that have a moderate to high potential to yield fossiliferous materials, prior
to issuance of a grading permit, if the potential for fossil discovery is moderate to high, iequue
applicants to provide a paleontological monitor during rough grading of the project Therefore,
impacts would be less than significant with the implementation of these policies and actions
Impacts of the proposed Project and the General Plan EIR are less than significant as identified
on page 3 8-26 of the General Plan EIR Because no new or more significant impact would
occur, no new mitigation is necessary
VIII Greenhouse Gas Emissions:
1 Thi eshold 5 8(a) Generate greenhouse gas emissions, either directly or indirectly, that
may have a significant impact on the environment
Finding No New Impact (Draft SEIR, page 5-23 )
Typical long-term greenhouse gas (GHG) emissions generated by development projects are from
area sources (e g , landscaping equipment), energy usage (i e , natural gas and electricity), and
mobile sources (i e , vehicle trips) in addition to watei demand, wastewater generation, and solid
waste disposal The General Plan EIR concluded that GHG emissions impacts would be less than
significant as the 2035 General Plan would meet the state mandated GHG emissions reduction
targets through year 2035
As described in Section 2 1 1 of the SEIR, if the proposed Ballot Initiative is approved by the
voters, it would allow the City Council to considei future projects within the TVPA without the
burden of the annual residential dwelling unit limitation The proposed Project would neither
introduce a specific development project, nor result in an increase of change to the overall
buildout land use assumptions analyzed in the General Plan EIR While, the Ballot Initiative
would allow the City Council to consider future development projects within the TVPA without
the burden of the annual residential dwelling unit limitation, impacts in the General Plan EIR are
based on annual emissions that would be genet ated by all land uses within the City at full
buildout The proposed Ballot Initiative does not altei the maximum buildout potential for
properties within the TVPA or the City The land use designation remains the same and the total
maximum intensity development remains unchanged Therefore, the emissions estimate
identified in the General Plan EIR would remain unchanged with the proposed Project Thus, the
proposed Project would not result in new or additional GHG emissions compaied to the
emissions identified in the General Plan EIR The policies and actions in the General Plan EIR
would continue to be implemented 2-A 5, 2-A 6, 2-A 18, 2-A 34, 2-A 69, 2-A 77, 2- 80, 2-A 92,
2-A 99, 4-P 9, 4-A 12, 4-A 18, 4-A 95, 4-P 41, 4-P 44, 4-P 45, 4-A 99, 4-A 104, 4-A 105, 4-
A 106, 4-A 108, 4-A 110, 4-A 112, 4-A 113, 4-A 114, 4-A 115, 4-A 116, 4-A 118, 4-A 124, 4-
A 125, 4-A 126, 4-A 131, 4-132, 4-A 134, 5-P 13, 5-P 14, 5-A 3, 5-A 4, 5-A 5, 5-A 6, 5-A 7, 5-
P 16, 5-P 17, 5-P 18, 5-A 17, 5-A 18, 5-A 19, 5-A 21, 5-P 19, 5-P 20, 5-A 22, 5-A 23, 5-A 24, 5-
A 25, 5-A 26, 5-A 27, 5-A 27, 5-A 28, 5-A 29, 5-A 32, 5-A 33, 5-A 41, 5-A 47, 5-P 25, 5-P 26,
5-A 54, 5-A 55, 5-A 56, 5-A 57, 5-A 58, 5-A 59, 5-A 60, 5-A 61, 5-A 62, 5-A 63, 5-A 64, 5-
A 65, 5-P 27, 5-A 66, 5-A 69, 5-A 72, 5-A 73, 7-A 24, 7-P 17, 7-A 38, 7-A 39, 7-A 40, 7-A 42,
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7-P 47, and 7-A 146 For example, Action 5-A 72 encourages developers to meet their minimum
parking requirements via shared parking between uses, payment of in-lieu fees, joint parking
districts, or off-site parking within a reasonable walking time ofl0 minutes or less Overall, the
proposed Project is consistent with the impact identified in the General Plan EIR, and the level of
impact (less than significant) would remain unchanged as identified on page 3 5-18 of the
General Plan EIR Because no new impact would occur, no new mitigation is necessary
2 Thi eshold 5 8(b) Conflict with an applicable plan, policy, or regulation adopted for the
purpose of reducing emissions of greenhouse gases
Finding No New Impact (Draft SEIR, page 5-24 )
Applicable plans adopted for the purpose of ieducnng GHG emissions include the California Air
Resources Board's (CARE) Scopmg Plan and the Southern California Association of
Governments' (SCAG) Regional Tiansportation Plan/Sustainable Communities Strategy
(RTP/SCS) The General Plan EIR detenmined impacts to be less than significant as the goals
and policies of the 2035 General Plan, which nncorpoiated the City's Climate Action Plan, would
be consistent with the overall goals that local, regional, and state plans include to reduce GHG
emissions
The proposed Project would neithei introduce a new specific development project nor increase of
change the overall buildout land use assumptions considered in the General Plan EIR Thus, the
proposed Project would not obstruct or interfere with implementation of the CARB Scopmg Plan
or SCAG's RTP/SCS Therefoie, no new or substantially greater impacts would occur with
implementation of the proposed Project when compared to those identified in the General Plan
EIR The policies and actions from Impact 5 8(a) would continue to be implemented under the
proposed Project Action 5-A 73, for example, calls for the development of flexible on-site
vehicle parking requirements, which would reduce impacts to GHG Overall, the proposed
Project is consistent with the impact identified in the General Plan EIR, and the level of impact
(less than significant) would remain unchanged as indicated on page 3 5-22 of the General Plan
EIR Because no new impact would occur, no new mitigation is necessary
IX Hazards and Hazardous Materials:
1 Thi eshold 5 9(a) Create a significant hazard to the public or the environment through the
routine transport, use, or disposal of hazardous materials
Finding No New or More Significant Impact (Draft SEIR, pages 5-24 to 5-25 )
As stated in the Geneial Plan EIR, the implementation of the 2035 General Plan would allow for
the development of land uses that may require the routine use, transport, and disposal of
hazardous material and waste within the 2035 General Plan Area Additionally, future
construction associated with buildout of the 2035 General Plan may generate hazardous materials
and waste Compliance with federal and state regulations regarding the use, transportation,
disposal, and accidental release of hazardous matenals would be required Locally, facilities
requiring a hazardous materials permit would be subject to routing inspection by the SBFD
Transportation of hazardous waste in connection with construction and operations of future
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development under the 2035 General Plan would be subject to USDOT's requirements for
hazardous materials tiansport and would requue earners to register with the DTSC As stated in
the General Plan EIR, there are no permitted hazaidous waste facilities in the 2035 General Plan
Area Future construction could requue the use of hazardous materials during construction
and/or operation, the implementation of the applicable fedeial, state, and local regulations, in
addition to the General Plan policies and actions 4-P 8, 4-P 18, 4-P 19, 4-P 20, 4-A 29, 4-P 59, 4-
P 60, 4-A 150, 4-A 152, 4-A 154, 5-P 1, 5-P 8, 5-P 23, 5-A 38, 5-A 39, 5-A 44, 5-P 28, 5-P 29,
5-P 30, 5-A 73, 5-A 74, 5-A 75, 5-A 76, 5-A 77, 7-P 31, 7-P 32, 7-A 119, and 7-A 120 For
example, Policy 4-P 19, which calls for the provision of lands to accommodate a wide range of
light industrial uses including research and development, manufacturing, agricultural processing,
and logistics near transportation conidors in areas where low- to moderate-intensity operations
would be sufficiently buffered, would reduce impacts to less than significant Impacts of the
proposed Project and the General Plan EIR are less than significant as indicated on page 3 7-36
of the General Plan EIR Because no new or more significant impact would occur, no new
mitigation is necessary
2 Threshold 5 9(b) Create a significant hazard to the public or the environment through
reasonably foreseeable upset and accident conditions involving the release of hazardous
materials into the environment
Finding No New of Mole Significant Impact (Draft SEIR, page 5-25 )
As stated in Impact 5 9(a), future development of land uses would involve the use,
tiansportation, disposal, and storage of hazardous materials which could cause personal injury,
property damage, environmental degradation, or death from the release of hazardous materials
caused by upset or accident conditions Although risk of upset and accident conditions involving
the ielease of hazaidous materials into the environment cannot be completely elimmated, it can
be reduced to a manageable level Existing iegulations at the fedeial, state, and local levels serve
to minimize the potential foi upset during routine tiansportation, use, and disposal, as discussed
in Impact 5 9(a) Proper implementation of the SBFD's CUPA programs would assist in ensuring
documentation of releases and threatened releases as well as the development of risk
management and hazardous materials ielease response plans As construction and/or operation of
future development could release hazardous materials into the environment, future projects
would implement existing federal, state, and local iegulations, in addition to the General Plan
policies and actions 4-P 8, 4-P 18, 4-P 19, 4-P 20, 4-A 29, 4-P 59, 4-P 60, 4-A 150, 4-A 152, 4-
A 154, 5-P 1, 5-P 8, 5-P 23, 5-A 38, 5-A 39, 5-A 44, 5-P 28, 5-P 29, 5-P 30, 5-A 73, 5-A 74, 5-
A 75, 5-A 76, 5-A 77, 7-P 31, 7-P 32, 7-A 119, 7-A 120, and 7-A 123, to reduce impacts to less
than significant For example, Policy 4-P 20, which calls for the provision of the concentration of
office, mdustrial, and commercial uses in appropriate locations near transportation corridors to
encourage the development of employment center and reduce the potential for land use conflicts
with sensitive use such as residential and schools, would reduce impacts to less than significant
Impacts of the proposed Project and the General Plan EIR are less than significant as indicated
on page 3 7-39 of the General Plan EIR Because no new or more significant impact would
occur, no new mitigation is necessary
3 Thi eshold 5 9(c) Emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or proposed school
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Finding No New or More Significant Impact (Draft SEIR, pages 5-25 to 5-26 )
The 2035 General Plan would allow land uses that would be reasonably expected to handle
hazardous materials or generate hazardous emissions Under the land use designations of the
2035 General Plan, there would be a range of land uses potentially allowed within a quarter mile
of existing schools (there are no new proposed schools in the 2035 General Plan) The most
intense uses allowed under the 2035 General Plan, under the Light Industrial of
Corllnercial/Industrial designations, include manufacturing, distribution, research and
development, and ancillary commeicial uses for the former, and auto services, commeicial retail
and services, manufacturing for the latter Heavy industries would only be permitted in areas
designated by the Santa Ana River Wash Plan, which is located away from schools
Of the 21 existing public and private schools in the 2035 General Plan Area, there are foul
schools that are located in areas where the 2035 General Plan contains only designations for
residential, paik, or other schools within a quarter mile of the property, two schools have 2035
General Plan designations for residential, park, or agricultural uses within a quarter mile, six
schools have 2035 General Plan designations for residential, commercial, office, agriculture,
packs, and public uses within a quarter mile, and the remaining nine schools all have 2035
Geneial Plan designations for Light Industrial or Commercial/Industrial within a quartet mile of
the school property
As indicated in the General Plan EIR, individual users of hazardous materials would continue to
be regulated by local disclosure, permitting, and notification requirements of the "Disclosure of
Hazardous Materials" program consistent with all federal, state, and local laws Public schools
are also required to evaluate and potentially amend their school safety plan on an annual basis In
the case that any new schools or alterations to existing schools would be required in the future,
the siting of schools, including existing facilities and upgradrg construction projects, would be
regulated by the California Department of Education (CDE), and new facilities would not be
constructed within a quartei mile of facilities emitting or handling hazardous waste or hazardous
materials consistent with CDE requirements In addition to these regulations, future development
would also comply with General Plan policies and actions 4-P 8, 4-P 20, 4-P 21, 4-A 30, 7-
A 118, 7-A 127, and 7-A 124, that will ensure impacts are less than significant For example,
Action 7-A 124 prohibits the development of projects that would reasonably be anticipated to
emit hazardous au emissions or handle extremely hazardous substances within a quartei mile of
a school, and therefore, would ensure that impacts to schools are less than significant Impacts of
the proposed Project and the General Plan EIR are less than significant as indicated on page 3 7-
41 of the Geneial Plan EIR Because no new of more significant impact would occur, no new
mitigation is necessary
4 Thr eshold 5 9(d) Be located on a site which is included on a list of hazardous materials
sites compiled pursuant to Government Code Section 65962 5 and, as a result, would it create a
significant hazard to the public or the environment
Fmdrng No New or More Sigmficant Impact (Draft SEIR, pages 5-26 to 5-27 )
There are numerous sites in the 2035 General Plan Area, including in the TVPA, that are
included on a list of hazardous material sites complied pursuant to Government Code Section
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1 1Resolutions\Res 8000-809918043 Ballot Initiative SEIR Findings Final doe
6592 5 of that need furthei investigation, as shown on Figure 3 71, Hazardous Mate!ials Sites,
and Table 3 7-1, Perinitted Hazardous Mate;icily Facilities, Table 3 7-2, DTSC Cleanup Sites
(EnviroStor), and Table 3 7-3, SWRCB Geoti acker Sites, of the General Plan EIR As indicated
in the General Plan EIR, several of the sites have had reported releases to the ground resulting in
soil and groundwater contamination and which are subject to various state and federal laws,
including CERCLA and RCRA, and various state and federal agency oversight, mcludmg EPA,
DTSC, and the RWQCB The sites aie in various stages of cleanup Redevelopment of sites with
existing soil or groundwater contamination in accordance with the 2035 General Plan could
potentially pose a significant hazard to the public of environment through the release of
hazardous materials However, as discussed in Impact 4 7-1 of the General Plan EIR, these sites
are regulated by existing federal and state policies and have been or are being investigated and
remediated Foi future projects, CEQA requires the City to reference the Cortese List and
disclose if the development project or any alternatives would be located on a listed site
complying with the applicable federal, state, and local regulations and programs In addition, the
following General Plan policies and actions are intended to seduce to less than significant levels
the impacts that projects would have associated with hazardous materials sites 4-P 8, 4-P 18, 4-
P 19, 4-P 20, 4-A 29, 4-P 59, 4-P 60, 4-A 150, 4-A 152, 4-A 154, 5-P 1, 5-P 8, 5-P 23, 5-A 38, 5-
A 39, 5-A 44, 5-P 28, 5-P 29, 5-P 30, 5-A 73, 5-A 74, 5-A 75, 5-A 76, 5-A 77, 7-P 31, 7-P 32, 7-
A 119, 7-A 120, 7-A 123, 7-A 127, and 7-A 124 Action 7-A 127 calls for the City of Redlands
Local Hazard Mitigation Plan to be used as a guide for identifying hazard risks and
vulneiabilities, identifying and prioritizing mitigation actions, encouraging the development of
local mitigation, and providing technical support foi these efforts, and would reduce impacts to
less than significant Impacts of the proposed Project and the General Plan EIR are less than
significant as indicated on page 3 7-41 of the General Plan EIR Because no new or more
significant impact would occui, no new mitigation is necessary
5 Thi eshold 5 9(e) For a project located within an airport land use plan or, where such a
plan has not been adopted, within two miles of a public airport or public use airport, would the
project result in a safety hazard for people residing or working in the project area
Finding No New Impact (Draft SEIR, page 5-27 )
Portions of the 2035 General Plan Area are within the airport land use plan area of the Redlands
Municipal Airport or within two miles of the SBIA The 2035 General Plan does not include
policies or land use changes that would conflict with the Redlands Municipal Airport ALUCP or
the guidelines for SBIA's compatibility zones as provided in the California Airport Land Use
Planning Handbook The TVPA is outside of the land use compatibility zone of the Redlands
Municipal Airport as shown in Figure 7-7, Airport Hazards, of the 2035 General Plan The
Project site is located in a highly urbanized area where development currently exists, and is not
within the land use compatibility zone, therefore no impact would occui The General Plan EIR
identified this impact as less than significant on page 3 7-43 of the General Plan EIR, however,
as the proposed Project is outside the land use compatibility zone, no impact would occur
Because no new impact would occur, no new mitigation is necessary
6 Thi eshold 5 9(f) Impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan
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Finding No New of More Significant Impact (Draft SEIR, page 5-27 )
The General Plan EIR stated that relevant emergency response or emergency evacuation plans
include the San Bernardino County Emergency Operations Plan, and to the extent that they
mitigate potential disasters in the 2035 General Plan Area, the Redlands HMP and the San
Bernardino County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) Physical
development undei the 2035 General Plan, including roadways, land uses, and increased
densities, could create obstacles to the implementation of emergency response or evacuation
plans adopted foi the 2035 General Plan Area However, the policies and actions in the General
Plan EIR would eliminate or reduce these impacts by seeking to use the Redlands HMP, which is
consistent with the MJHMP, as a guide for emergency planning, thus taking into account hazards
and promoting means to reduce risks as well as improve emergency access, ingress, egress,
emergency preparedness, and inter-jurisdictional cooperation throughout the 2035 General Plan
Area Future development throughout the City - regardless of the proposed Ballot Initiative -
could mterfere with an adopted emergency response plan or emergency evacuation program
Implementation of the following General Plan policies and actions would ensure that impacts
would be reduced to less than significant levels 7-A 119, 7-A 127, 5-P 7, 5-A 15, 7-A 90, 7-
A 91, 7-A 96, 7-A 117, 7-P 37, 7-P 38, 7-A 128, 7-A 129, 7-A 130, 7-A 131, 7-A 132, and 7-
A 133 Foi instance, Action 5-A 15 calls for the maintenance of access for emergency vehicles
and services by piovidmg two means of ingress/egress into new communities, limitations on the
length of cul-de-sacs, proper roadway widths and road grades, adequate turning radius, and other
requirements per the California Fire Code, which would ensure reduce impacts to emergency
vehicles Impacts of the proposed Project and the General Plan EIR are less than significant as
indicated on page 3 7-44 of the General Plan EIR Because no new or more significant impact
would occur, no new mitigation is necessary
7. Threshold 5 9(g) Expose people or structures to a significant risk of loss, injury or death
involving wildland fires, including where wildlands are adjacent to urbanized areas or where
iesidences are intermixed with wildlands
Finding No New or More Significant Impact (Draft SEIR, page 5-28 )
According to Figure 3 7-3, Far e Hazar ds and Fir e Safety Services, of the General Plan EIR, the
majority of Redlands is designated by CalFire as having a Moderate fire threat level, with areas
of High, Very High, and Extreme threat found on the periphery of the City and in the SOI
outside of the City limits m the canyonlands, Crafton, Mentone, and in the Santa Ana Wash As
indicated in the Geneial Plan EIR, new development that occurs pursuant to the 2035 General
Plan would generally occur within areas shown with Moderate fire threat, which covers most of
the already urbanized portions of the 2035 General Plan Area accessible to emergency services
and managed vegetation The Project site is located within areas classified as Moderate fire
threat, according to Figure 3 7-3 of the General Plan FIR The policies require all development to
adhere to safety standards provided in the CBC and California Fire Code, and promote close
coordination with the Redlands Fire Department and the fire services of neighboring jurisdictions
to ensure the safety of new development Therefore, new development would be required to
comply with state building and fire codes, as well as General Plan policies and actions 7-A 90, 7-
A 91, 7-A 96, 7-A 117, 5-P 7, 5-A 15, 6-A 35, 7-P 12, 7-P 28, 7-A 87, 7-A 88, 7-A 89, 7-A 93,
7-A 95, 7-A 101, 7-A 102, 7-A 103, 7-A 04, 7-A 105, 7-A 106, and 7-A 82, to ensure that
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impacts are less than significant For example, Action 7-A 89 requues adherence to applicable
building codes and standards in accordance with Fire Hazard Overlay Districts, California Fue
Code, and the California Building Code, and therefore compliance with these codes and
standards would reduce impacts involving wildland fires to less than significant Impacts of the
proposed Project and the General Plan EIR are less than significant as indicated on page 3 7-47
of the General Plan EIR Because no new or mole significant impact would occur, no new
mitigation is necessary
X. Hvdt alogv and Water Ouabty.
1 Threshold 5 10(a) Violate any watei quality standards or waste discharge requirements
oi otherwise substantially degrade surface or groundwater quality
Finding No New or More Significant Impact (Draft SEIR, pages 5-28 to 5-29 )
Development that occurs in the 2035 General Plan Area would increase imperious surfaces from
the placement of roads, parkuig lots, buildings, and other infi astructure Other sources of watei
quality impacts include direct discharge associated with industrial/commercial activities,
automobiles, agriculture, and heibicides The increase in impervious surfaces that is likely to
result from additional development and redevelopment under the 2035 Geneial Plan could
increase the amount of runoff and associated pollutants during construction and/oi operation
However, every construction activity as a result of the proposed Project, that has the potential to
negatively affect water quality is required to comply with the NPDES Stormwater Discharge
Permit The City's Pretieatment and Regulation of Wastes Oidinance (Ord 2268 § 1, 1995)
codified as Redlands Municipal Code Chapter 13 52, Pi eti eatinent and Regulation of Wastes,
and its Storm Diains Oidinance (Ord 2274 § 1, 1995) codified as Redlands Municipal Code
Chapter 13 54, Stoi in Di aiiis, would further protect water quality in the Project site As stated in
the General Plan EIR, the policies promote the protection of the City's natural water bodies,
prevent watei pollution, ensure preparation and implementation of applicable water quality
plans, require incorporation of BMPs, and otherwise ensure compliance with the City's NPDES
Permit and other related regulations Further, development would be subject to the RWQCB
requirements and the City of Redlands Municipal Code The Project site is highly urbanized and
is mostly developed with impervious surfaces All development is required to adhere to these
regulations, and with the implementation of General Plan policies and actions 6-P 19, 6-P 20, 6-
A 35, 6-A 40, 6-A 41, 6-A 42, 6-A 44, and 8-A 32 For example, Action 6-A 35 calls for the use
of Low Impact Development strategies, BMPs, pervious paving materials, and on-site unfiltiation
for treating and reducing stone water runoff before it reaches the municipal storm water system,
which would ensure that water quality standards are not violated However, the proposed Ballot
Initiative does not alter the maximum burldout potential for properties within the TVPA, or the
City The land use designations remain the same and the total maximum intensity development
remains unchanged Impacts of the proposed Project and the General Plan EIR are less than
significant, as identified on page 3 9-28 of the General Plan FIR Because no new or more
significant impact would occur, no new mitigation is necessary
2 Thi eshold 5 10(b) Substantially decrease groundwater supplies oi interfere substantially
with groundwater recharge such that the project may impede sustainable groundwater
management of the basin
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Fildina No New or More Significant Impact (Draft SEIR, page 5-29 )
The 2035 General Plan Area is in the Upper Santa Ana Valley Groundwatei Basin The City's
domestic water wells contribute approximately 50 percent of the water supply, additional
development under the 2035 Geneial Plan would increase demands for water The City's Well
Drilling Ordinance (Ord 2110 § 1, 1990) as codified in Redlands Municipal Code Chapter
13 42, Well Drilling, protects gioundwater from potential sources of contamination resulting
from well drilling Future development under the General Plan that would increase the demands
of water supplies would follow General Plan policies and actions 6-P 20, 6-A 35, 6-A 40, 6-
A 41, 8-A 32, 6-P 21, 6-A 34, 8-P 6, 8-A 22, and 8-A 25 For instance, Policy 8-P 6 calls for
minimizing dependence on imported water through efficient use of local surface sources, usmg
wise groundwater management practices, conservation measures, and the use of reclaimed
wastewater and non-potable water for in igation of landscaping and agriculture, where feasible,
which would reduce reliance on gioundwater supplies Therefore, these policies and action
would reduce impacts to less than significant However, the proposed Ballot Initiative does not
alter the maximum buildout potential for properties within the TVPA, or the City The land use
designations remain the same and the total maximum intensity development remains unchanged
As identified on page 3 9-30 of the General Plan EIR, the Geneial Plan EIR and the proposed
Project would result in less than significant impacts Because no new or more significant impact
would occur, no new mitigation is necessary
3 TIzn eshold 5 10(c)(1) Substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition of
impervious surfaces, in a manner which would result in a substantial erosion or siltation on- or
off-site
Finding No New oi More Significant Impact (Draft SEIR, pages 5-29 to 5-30 )
Future development oi redevelopment allowed under the 2035 General Plan could impact the
existing drainage system Increases to imperious surfaces would lead to increase storrnwater
flow, which could increase runoff into local storm drains Increased runoff volumes could result
in erosion, siltation, or flooding The Project site is located in a highly urbanized area that is
mostly developed with impervious surfaces However, the proposed Ballot Initiative does not
alter the maximum buildout potential for properties within the TVPA, or the City The land use
designations remain the same and the total maximum intensity development remains unchanged
All development would be subject to the City's Flood Damage Prevention Ordinance (Ord 2837,
2016) codified as Redlands Municipal Code Chapter 15 32, Flood Damage Prevention, City's
Storm Drains Ordinance (Old 2274 §1, 1995) codified as Redlands Municipal Code Chapter
13 54, Storm Drains, and General Plan policies and actions 6-P 19, 6-A 35, 6-A 40, 6-A 44, 6-
A 12, 6-A 36, 6-A 37, 6-A 39, 7-A 77, 7-A 78, and 7-A 80 For example, Action 6-A 39 requi es
that new development provides landscaping and revegetation of graded or disturbed areas with
drought-tolerrant native or non-invasive plants, in order to prevent erosion Therefore, impacts of
the proposed Project, to erosion and siltation, would be reduced to less than significant as with
the General Plan EIR, as identified on page 3 9-32 of the General Plan EIR Because no new or
mole significant impact would occur, no new mitigation is necessary
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4 Threshold 5 10(c)(2) Substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition of
impervious surfaces, in a maimer which would substantially increase the late or amount of
surface runoff in a manner which would result in flooding on- oi offsite
Finding No New or More Significant Impact (Draft SEIR, page 5-30 )
See 'espouse to Impact 5 10(c i) This impact would be less than significant Because no new or
more significant impact would occur, no new mitigation is necessary
5 Threshold 5 10(c)(3) Substantially altei the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river oi through the addition of
impervious surfaces, in a manner which would create or contribute runoff water which would
exceed the capacity of existing or planned stonnwater drainage systems or provide substantial
additional sources of polluted runoff
Finding No New or More Significant Impact (Draft SEIR, page 5-30 )
Increases in impervious surfaces would lead to incieased stonnwater flow The RWQCB ensures
compliances with NPDES Permit requirements, and construction activities within the Project site
that has the potential to negatively affect water quality must prepare a construction SWPPP
Projects that disturb one acre or more of impervious surface would be subject to the NPDES
Stonnwater Discharge Permit and stormwater pollution prevention requirements The Project site
is located in a highly urbanized area and is mostly developed with impervious surfaces The
proposed Project would implement the NPDES Permit, BMPs, and other related regulations, as
well as General Plan policies and actions 6-P 20, 6-A 35, 6-A 40, 6-A 41, 6-A 44, 6-A 34, 7-
A 77, 7-A 78, 6-A 38, 6-A 43, 7-A 76, and 8 A-10 Foi example, Action 6-A 43 ensures that
post-development peak stormwater runoff discharge rates do not exceed the estimated pre-
development rate The proposed Ballot Initiative does not alter the maximum buildout potential
for properties within the TVPA, or the City The land use designations remain the same and the
total maximum intensity development remains unchanged Therefore, impacts of the proposed
Project on the capacity of stonnwater drainage systems would be less than significant as with the
General Plan EIR, as identified on page 3 9-34 of the General Plan EIR Because no new or
more significant impact would occur, no new mitigation is necessary
6 Threshold 5 10(c)(4) Substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream oi river oi through the addition of
impervious surfaces, in a manner which would impede or redirect flood flows
Finding No New or More Significant Impact (Draft SEIR, page 5-30 )
The 2035 Geneial Plan designated land for commercial and residential development within 100-
year flood hazard areas, as identified in Figure 3 9-2, Flood Hazards Pursuant to Municipal
Code Chapter 15 32, Flood Damage Prevention, the City of Redlands requires a special use
permit for any development proposed m areas of special flood hazards Redevelopment of sites
within the 100-year flood hazard areas are required to meet current stonnwater management
regulations Portions of the Project site are located within the 100-year floodplam, as shown in
Figure 3 9-2, Flood Hazards, of the General Plan EIR However, the proposed Ballot Initiative
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does not alter the maximum buildout potential for properties within the TVPA, or the City The
land use designations remain the same and the total maximum intensity development remains
unchanged Future development must comply with the municipal code and the following General
Plan policies and actions 7-P 26, 7-A 74, and 7-A 81 Foi example, 7-A 74 calls for the
continued participation in the National Flood Insurance Program (NFIP) and the Community
Rating System to ensure that the City is incentivized to seduce the risk of damage from flooding
and improve flood preparedness, which would ensure that impacts to impeding or redirecting
flood flows ate less than significant Impacts of the proposed Project and the General Plan EIR
would be less than significant as identified on page 3 9-37 of the Genet al Plan EIR Because no
new or more significant impact would occur, no new mitigation is necessary
7 Thi eshold 510(d) In flood hazard, tsunami, oi seiche zones, risk release of pollutants
due to project inundation
Finding No New or More Significant Impact (Draft SEIR, page 5-31 )
A seiche is a surface wave created when a body of water is shaken, usually by earthquake
activity Smiles are of concern relative to water storage facilities because inundation from a
seiche can occur if the wave overflows a containment wall, such as the wall of a reservoir, water
storage tank, dam or other artificial body of water Although there are no large water tanks in the
area that could impact the Project site, there are dams in the region that could create flooding
impacts Thirteen dams in the greater Los Angeles area moved or cracked during the 1994
Northridge earthquake However, none were severely damaged This low damage level was due
in part to completion of the retrofitting of dams and reservoirs pursuant to the 1972 State Darn
Safety Act
The 2035 General Plan Area is located sufficiently inland to be out of what would be considered
a potential hazard area for seiches, tsunamis, and sea level rise, therefore, implementation of the
proposed Project would not risk the release of pollutants due to inundation The proposed Ballot
Initiative does not altei the maximum buildout potential for properties within the TVPA, or the
City The land use designations remain the same and the total maximum intensity development
remains unchanged The proposed Project would be required to be in compliance with the City's
existing regulations pertaining to flooding hazards, along with General Plan policies and actions
7-A 77, 7-A 78, 7-A 76, 7-A 74, 7-A 81, 2-A 92, and 7-A 132 For example, 7-A 78 calls for the
use of the Drainage Master Plan to implement improvements to the drainage system in order to
address flooding impacts, where feasible, "green initiatives" such as site infiltration basins and
bioretention should be used in places where they would be most effective Therefore, the City's
regulations and 2035 General Plan policies and goals would ensure that impacts associated with
the risk release of pollutants due to flood inundation would be less than significant, as with the
General Plan EIR, as Identified on page 3 9-39 of the General Plan EIR Because no new oi
more significant impact would occur, no new mitigation is necessary
8 Thn eshold 5 10(e) Conflict with or obstruct implementation of a water quality control
plan or sustainable groundwater management plan
Finding No New or Mole Significant Impact (Draft SEIR, page 5-31 )
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See response to Impact 5 10(a) The proposed Ballot Initiative does not altei the maximum
buildout potential for properties within the TVPA, of the City The land use designations remain
the same and the total maximum intensity development remains unchanged However, the
proposed Project would be required to comply with federal, state, and local regulations and
plans, as well as Geneial Plan policies and actions 7-A 123, 8-A 32, 6-P 21, 6-A 34, 8-P 6, 8-
A 22, 8-A 24, and 7-P 27 For example, Action 8-A 32 calls for the mitigation of impacts
associated with the expansion of existing landfills or development of new landfills to include
effects on streets and highways, diainage systems, groundwater, air quality, natural resources,
aesthetics, and property maintenance which would ensure compliance with water quality control
and groundwatei management plans The Project area is largely covered with urban uses and
streets, affording minimal groundwater recharge Compliance with the City's existing
regulations, along with General Plan EIR policies and actions would ensure that impacts
associated with water quality control and groundwater management plans would be less than
significant Impacts of the proposed Project and the General Plan EIR are less than significant, as
identified on page 3 9-28 of the General Plan EIR Because no new or mole significant impact
would occur, no new mitigation is necessary
XI. Mineral Resources.
1 TIzn eshold 5 11(a) Result in the loss of availability of a known mmeial resource that
would be of value to the region and the residents of the state
Finding No New Impact (Diaff SEIR, page 5-32 )
Changes to land use designations m areas designated by the California State Mining and Geology
Board (SMGB) as containing regionally significant aggregate resources classified as MRZ-2
(areas where geologic data indicate that significant PCC-Grade aggregate resources are present)
These changes included the reclassification of all areas designated as Flood Control/Construction
Aggregates Conservation/Habitat Preservation to the Open Space designation, as well as a
change m designation of an 86-acre property at the northeast corner of Crafton Avenue and
Madeira Avenue in Mentone from Flood Control/Construction Aggregates Conservation/Habitat
Preservation to Light Industrial
According to Figure 3 11-1, Muiei al Resoui ces, of the Geneial Plan EIR, portions of the Project
site are located in the MRZ-2 Zone, while the majority of the Project site is in the MRZ-3 Zone
(areas containing known or inferred mineral occurrences of undetermined mineral resource
significance) The Project site is currently developed and is located in a highly urbanized portion
of the City with no possibility of developing mineral extraction uses because of noise,
transportation, and proximity to homes The proposed Ballot Initiative does not alter the
maximum buildout potential for properties within the TVPA, or the City The land use
designations remain the same and the total maximum intensity development remains unchanged
Page 3 11-10 of the General Plan EIR identified this impact as less than significant, however, as
the project area is wither the MRZ-2 and MRZ-3 zones, and the project site is highly urbanized
and built out, impacts of the proposed Project would be less than significant Because no new
impact would occur, no new mitigation is necessary
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2 Threshold 5 110) Result in the loss of availability of a locally important mineral
resource recovery site delineated on a local general plan, specific plan or othei land use plan
Finding No New Impact (Draft SEIR, page 5-32 )
See response to section 5 11(a) The 2035 General Plan does not contain land use changes or
policies that would affect existing mining operations within or adjacent to the 2035 General Plan
Area The 2035 General Plan does not designate any locally important mineral resource recovery
sites in the 2035 General Plan Area, though it does include the Flood Control/Construction
Aggiegates Conservation/Habitat Preservation land designation which applies to land that would
potentially be used for aggregate mining activities Similarly, the proposed Ballot Initiative does
not contain land use changes or policies that would affect existing mining operations within or
adjacent to the 2035 Geneial Plan Area Indeed, the proposed Ballot Initiative does not alter the
maximum buildout potential foi properties within the TVPA, or the City The land use
designations iemaui the same and the total maximum intensity development remains unchanged
The Project site is currently developed and is located in a highly urbanized portion of the City
The proposed Project would not change existing land use or zoning designations therefore there
would be no impact on locally important rnineial resource recovery sites As identified on page
3 11-12 of the Geneial Plan EIR, the General Plan EIR and the proposed Project would result in
no impact Because no new impact would occur, no new mitigation is necessary
XII. Noise.
1 Thresholds 512(a) Geneiation of a substantial temporary or permanent increase in
ambient noise levels in the vicinity of the project in excess of standards established in the local
general plan or noise ordinance, or applicable standards of othei agencies
Fmdmg No New Impact (Diaft SEIR, page 5-33 )
Noise is regulated at the federal, state and local level depending on the noise source The General
Plan EIR analyzed potential noise impacts both from construction activities and from operation
at full build-out The proposed Project is a Ballot Initiative that, if approved by voters would
allow the City Council to consider future projects within the TVPA without the burden of the
annual residential dwelling unit limitation. No specific development project is proposed under
the proposed Project
As discussed in the Geneial Plan EIR, the City regulates noise associated with construction
equipment and activities through its noise ordinance in the Municipal Code and, since
compliance with the City's noise ordinance in Mumcipal Code Section 8.06 090 would be
iequired for any future construction. the noise impacts from construction activities were found to
be less than significant Since this would also be the case under the proposed Project, no new of
substantially greater impacts would occur when compared to those identified in the General Plan
EIR. and the level of impact (less than significant) remains unchanged.
The proposed Project would not increase or change the overall land use buildout assumed and
analyzed in the General Plan EIR The General Plan EIR identified permanent traffic noise
incieases of up to 1.2 dBA CNEL with future build-out plus project traffic conditions The
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proposed Project would not affect the regional growth of the City and would be consistent with
the overall growth forecast analyzed under the Geneial Plan EIR The overall traffic noise
increase would not be greater than analyzed under the Geneial Plan EIR The TVPA is oriented
around three of the future transit stations identified in the General Plan along the Redlands
Passenger Rail line which as discussed in the General Plan EIR, could expose people to noise
from railway operations Howevei, the rail line will have quiet zones at its street crossings For
all future developments within the City that fall within the required noise screening distances as
specified in the FTA Noise and Vibration Manual (FTA 2018), a detailed noise analysis would
be required. The screening distance for commuter rail is 750 feet with no obstruction between the
rail line and receptor and 375 feet with intervening buildings. This would also be required for
future development under the proposed Project Stationary sources (including but not limited to
HVAC equipment and truck loading docks) that may be part of future projects developed under
the proposed Project would be subject to the City's noise ordinance contained in the Municipal
Code Sections 8 06 070 and 8 06 080 The following General Plan policies and actions are
applicable to reducing noise impacts. 7-P.39. 7-P.40, 7-P.41, 7-P 42, 7-A 135, 7-A 136, 7-A 137
7-A 138, 7-A 139, 7-A 140, and 7-A 141 For example Policy 7-P 41 indicates, "Ensure that
new development is compatible with the noise environment by continuing to use potential noise
exposure criterion in land use planning " The proposed Project would be consistent with the
impacts identified in General Plan EIR and the level of impact (less than significant) remains
unchanged as identified on pages 3 12-32 through 3.12-49 of the General Plan FIR. Because no
new impact would occur, no new mitigation is necessary
2 Thresholds 5 120) Generation of excessive groundborne vibration of ground borne
noise levels
Finding No New Impact (Draft SEIR, page 5-34)
As discussed in the General Plan EIR, construction vibration would be less than significant. The
proposed Project is a Ballot Initiative that, if approved by voters would allow the City Council
to consider future projects within the TVPA without the burden of the annual residential
dwelling unit limitation No specific development project is proposed under the proposed
Project Overall the proposed Project would be consistent with the impacts identified in General
Plan EIR, and the level of impact (less than significant) remains unchanged
The TVPA rs oriented around duce of the future transit stations identified in the General Plan
along the Redlands Passenger Rail line, which as discussed in the General Plan EIR, could
expose people to vibi atoll fi om railway open ations. As discussed in the General Plan EIR, all
future developments within the City that fall within the required screening distances as specified
in the FTA Noise and Vibration Manual (FTA 2018) a detailed vibration analysis would be
required Overall, the proposed Project would be consistent with the impacts identified in
General Plan FIR, and the level of impact (less than significant) remains unchanged. as indicated
on pages 3 12-52 and 3 12-53 of the General Plan EIR Because no new impact would occur no
new mitigation is necessary
3 Threshold 5 12(c) For a project located within an airport land use plan or, where such a
plan has not been adopted, within two miles of a public airport or public use airport, would the
project expose people residing or working in the project area to excessive noise levels
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Finding No New Impact (Draft SEIR, page 5-34)
As discussed in the General Plan EIR, the Redlands Municipal Airport is located in the northeast
part of the city Howevei, the TVPA is not located within the published noise contours foi the
Redlands Municipal Airport or the San Bernardino International Airport and would not expose
people iesiding or working in the project area to excessive noise levels The proposed Project
would be consistent with the impacts identified in General Plan EIR, and the level of impact (less
than significant) remains unchanged, as identified on page 3 12-56 of the Geneial Plan EIR The
proposed Ballot Initiative does not alter the maximum buildout potential for properties within the
TVPA, or the City The land use designations remain the same and the total maximum intensity
development remains unchanged Because no new impact would occur, no new mitigation is
necessary
XIII Public Services:
1 Threshold 5 13(a) Would the project result in substantial adverse physical impacts
associated with the provision of new or physically altered governmental facilities, need foi
new or physically altered governmental facilities, the construction of which could cause
significant environmental impacts, in order to maintain acceptable service ratios, response
times, of other performance objectives for any of the public services
a (1) Fu e protection
Finding No New or More Significant Impact (Draft SEIR, pages 5-34 to 5-35 )
The demand for file protection services would increase due to the additional residents proposed
under the 2035 General Plan buildout period Population increases could result in increased
alarms and call volumes that could negatively impact the Fne Department response times The
majority of new development would be located in mfill sites in urbanized areas of the City, most
of which are in areas of low fire hazard severity However, residential development near the
Resource Preservation land use category in the canyons presents challenges for fire service New
residential and commercial development throughout the 2035 General Plan Area may increase
the likelihood of fire and the response time of fire services According to the General Plan EIR,
the Fire Department determined that it would need to increase the number of fire stations in order
to meet the increased future service demands Due to the minimal effects that the development of
new facilities would have on the environment, the concentration of most new development in
areas already well-served by fire protection services, and the addition of policies to reduce fire
hazards in the City, impacts to fire protection would be less than significant, according to the
General Plan EIR Moreover, the proposed Ballot Initiative does not alter the maximum buildout
potential for properties within the TVPA, or the City The land use designations remain the same
and the total maximum intensity development remains unchanged The following policies and
actions of the General Plan would continue to be applicable to the proposed Project and would
reduce impacts to less than significant levels 4-P 56, 4-P 57, 4-A 145, 4-A 146, 4-A 148, 6-
A 36, 6-A 39, 7-A 149, 8-A 9, 8-A 17, 8-A 39, 8-A 40, 4-P 59, 4-P 60, 4-A 150, 4-A 152, 4-
A 154, 7-P 28, 7-A 84, 7-A 85, 7-A 87, 7-A 88, 7-A 89, 7-A 91, 7-A 93, 7-A 94, 7-A 95, 7-A 96,
7-A 101, 7-A 102, 7-A 103, 7-A 104, 7-A 105, and 7-A 106 For example, Action 4-A 154 calls
for the inclusion of Police and Fire Departments in the review of new developments to provide
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feedback on building and site design safety Therefore, as the proposed Project focuses on the
TVPA of the City, which is highly urbanized and no Resource Preservation land uses are within
or adjacent to the TVPA, impacts of the proposed Project on fire protection would be less than
significant, as with the Geneial Plan FIR which identified less than significant impacts as seen
on page 3 13-27 Because no new or more significant impact would occur, no new mitigation is
necessary
o (2) Police protection
Finding No New or More Significant Impact (Draft SEIR, page 5-35 )
The Redlands Police Department would need to grow in order to accommodate the increases in
demand from the growing population and meet service standards in the future The Redlands
Police Department anticipates the need for significant improvements in staffing and facility
capacity m order to serve the 2035 population of79,000 residents Meeting facilities needs for an
expanded Police Department would likely require new construction or physically altering an
existing facility Development impact fees from new development would serve to ensure that
improvements are made in a timely manner so as to avoid deterioration of existing facilities,
according to the General Plan EIR The proposed Ballot Initiative does not alter the maximum
buildout potential for properties within the TVPA, of the City The land use designations remain
the same and the total maximum intensity development remains unchanged The following
policies and actions of the General Plan EIR would continue to be applicable to the proposed
Project and would reduce impacts to less than significant levels 4-P 56, 4-P 57, 4-A 145, 4-
A 146, 4-A 148, 6-A 36, 6-A 39, 7-A 149, 8-A 9, 8-A 17, 8-A 39, 8-A 40, 4-P 59, 4-P 60, 4-
P 61, 4-A 150, 4-A 151, 4-A 152, 4-A 153, 4-A 154, 7-P 23, 7-P 24, 7-A 68, 7-A 69, 7-A 70, 7-
A 71, 7-A 72, and 7-A 73 For instance, Action 7-A 68, calls for the incorporation of Crime
Prevention through Environmental Design principles and best practices into the Zoning
Ordinance and project review for new development and major renovations The policies and
actions of the Geneial Plan EIR would reduce impacts to the demand for police protection
services, including physical demands, and therefore, the proposed Project would have a less than
significant impact on police protection services, as with the General Plan EIR, as identified on
page 3 13-28 of the General Plan EIR Because no new or more significant impact would occur,
no new mitigation is necessary
o (3) Schools
Finding No New or More Significant Impact (Draft SEIR, pages 5-35 to 5-36 )
The school-aged population is expected to increase which would impact enrollment totals in
Redlands Unified School District (RUSD) facilities within the 2035 General Plan Area The
General Plan EIR stated that although ongoing demographic trends are causing reductions in the
percentage of school-aged children compared to the total population, the projected population
increase, for the 2035 General Plan, would result in the number of elementary school students
exceeding school capacity The General Plan EIR indicated that RUSD could utilize trailers and
portable classrooms to accommodate students in the interim, however, a new school may be
required RUSD owns land north of Mission Road in Loma Linda that could be utilized to
construct a new school if necessary The following General Plan policies and actions would be
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applicable to the proposed Project 4-P 56, 4-A 145, 4-A 146, 4-A 148, 6-A 36, 6-A 39, 7-A 149,
8-A 9, 8-A 17, 8-A 39, 8-A 40, 4-P 62, 4-A 156, 4-A 157, 4-A 158, and 4-A 159 For example,
Action 4-A 145 calls for the coordination of future development with the City's Capital
Improvement Program to ensure adequate funding and planning foi needed public services and
facilities Impacts of the proposed Project and the General Plan EIR are less than significant, as
identified on page 3 13-25 of the General Plan EIR Because no new oi more significant impact
would occur, no new mitigation is necessary
o (4) Parks
Filling No New or Mole Significant Impact (Draft SEIR, page 5-36 )
Without the development of new parks, the increase in population would place additional
physical demands on existing paiks An increase in the number of park users would cause parks
to be in active use for longer periods of time and/or used more intensively other the course of a
typical day As indicated in Table 3 13-6, Parkland Comparison (City of Redlands 2015 and
2035), of General Plan EIR, in 2035, with the development of 140 9 acres of proposed parkland
as designated in the 2035 General Plan, and the addition ofl0,355 residents, the parkland ratio
would be 6 9 acres per 1,000 residents, which would exceed the City's park standard of 5 acres
per 1,000 people Additionally, the City's development impact fees would ensure that new
parkland is distributed evenly throughout the 2035 General Plan Area, which would prevent the
overuse and physical deterioration of facilities The proposed Ballot Initiative does not alter the
maximum buildout potential foi properties within the TVPA, or the City The land use
designations remain the same and the total maximum intensity development remains unchanged
The following policies and actions would reduce impacts to parks 4-P 56, 4-P 57, 4-A 145, 4-
A 146, 4-A 148, 6-A 36, 6-A 39, 7-P 4, 7-P 5, 7-P 6, 7-P 7, 7-P 8, 7-P 9, 7-P 10, 7-P 11, 7-P 15,
7-A 1, 7-A 2, 7-A 3, 7-A 4, 7-A 5, 7-A 6, 7-A 7, 7-A 8, 7-A 9, 7-A 10, 7-A 11, 7-A 12, 7-A 13,
7-A 14, 7-A 15, 7-A 16, 7-A 17, 7-A 18, 7-A 19, 7-A 20, 7-A 21, 7-A 22, 7-A 23, 7-A 24, 7-
A 25, 7-A 26, 7-A 27, 7-A 28, 7-A 29, 7-A 30, 7-A 31, 7-A 32, 7-A 33, 7-A 34, 7-A 149, 8-A 9,
8-A 17, 8-A 39, and 8-A 40 For example, Policy 7-P 8 calls for minimizing substitution of
private recreation facilities for developer fee payment or park dedication to ensure that a public
park system will be permanently available to the entire community Impacts of the proposed
Project and General Plan EIR, as identified on page 3 13-19 of the General Plan EIR, aie less
than significant Because no new or more significant impact would occur, no new mitigation is
necessary
o (5) Othei public facilities
Finding No New oi More Significant Impact (Draft SEIR, page 5-36 )
The increase in residents, within the 2035 General Plan Area, would likely increase demand for
library and other community services The General Plan EIR indicated that a portion of this
increase in demand can be accommodated by extending the hours of operation of the Smiley
Library Development impact fees from new development would serve to ensure that
improvements are made in a timely manner so as to avoid the deterioration of existing library
facilities The proposed Ballot Initiative does not alter the maximum buildout potential for
properties within the TVPA, oi the City The land use designations remain the same and the
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total maximum intensity development remains unchanged Thus, similar to the General Plan
EIR, with the implementation of the following policies and actions, impacts to library facilities
would be less than significant 4-P 56, 4-P 57, 4-A 145, 4-A 146, 4-A 148, 6-A 36, 6-A 39, 7-
A 149, 8-A 9, 8-A 17, 8-A 39, and 8-A 40, as identified on page 3 13-26 of the General Plan
EIR Because no new or more significant impact would occur, no new mitigation is necessary
XIV Recreation
1 Threshold 5 14(a) Increase the use of existing neighborhood and regional paiks or othei
recreational facilities such that substantial physical deterioration of the facility would occui
or be accelerated
Finding No New or More Significant Impact (Draft SEIR, page 5-37 )
See response to Impact 5 13(d), above An increase in population could increase the demands on
existing neighborhood and regional paiks or other recreational facilities that could accelerate
substantial physical deterioration of these facilities However, the proposed Ballot Initiative does
not alter the maximum buildout potential foi properties within the TVPA, oi the City The land
use designations remain the same and the total maximum intensity development remains
unchanged Thus, population growth beyond what was disclosed in the General Plan EIR would
not occur with the proposed Project Any future development that would occui within the
TVPA, or elsewhere in the City, would be required to comply with the implementation of
policies and actions fiom the General Plan, and to pay development impact fees, which togethei
would ensure that impacts to the physical deterioration of existing neighborhood and regional
paiks or othei recreational facilities, as a result of project implementation, would be less than
significant, as with the General Plan EIR impacts, as identified on page 3 13-19 of the General
Plan FIR Because no new or more significant impacts would occur, no new mitigation is
necessary
2 Thi eshold 5 14(b) Include recreational facilities or require the construction or expansion of
recreational facilities which might have an adverse physical effect on the environment
Finding No New or More Significant Impact (Draft SEIR, page 5-37 )
See response to Impact 5 14(a). As stated. the proposed Project does not propose any specific
development project and would not result in increasing or than ig i the overall buildout land use
assumptions analyzed in the General Plan FIR. Thus, the proposed Project would not result in
any new impacts. or increase the severity of impacts. with respect to recreational facilities.
Impacts of the proposed Project and the General Plan EIR are less than significant as identified
on page 3.13-19 of the General Plan EIR. Because no new oi more significant impact would
occur, no new mitigation is necessary
XV. Transportation:
1 Threshold 5 15(a) Substantially increase hazards due to a geometric design feature (e g ,
sharp curves or dangerous intersections) or incompatible uses (e g farm equipment)
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Finding- No New or More Significant Impact (Draft SEIR, page 5-37 )
The proposed Project does not propose the development of specific projects, and none of the
growth management policies affect design requirements for safety and access The General Plan
EIR provides policies and actions to ensure a compatible and safe transportation network, and to
ensure that roadway facilities consider the needs of users of all modes The proposed Project
would continue to implement the following General PIan pohcies and actions 5-P 1, 5-P 4, 5-
P 8, 5-P 11, 5-P 14, 5-A 1, 5-A 2, 5-A 3, 5-A 4, 5-A 5, 5-A 8, 5-A 9, 5-A 10, 5-A 12, 5-P 16, 5-
A 17, 5-A 18, 5-A 25, 5-A 36, 5-A 50, 5-P 29, 5-P 30, 5-A 76, 5-A 77, 5-A 78, 5-A 79, and 5-
A 80 For example, Policy 5-P 29 of the Geneial Plan EIR calls for the update and
implementation of a truck route map to ensure it serves slipping needs in the City while
considering potential conflicts with preferred modes and other sensitive land uses in the City,
consistent with the layered network, and theiefoie, would reduce conflicts between incompatible
uses and between all transportation networks As with the Geneial Plan EIR, impacts of the
proposed Project would be less than significant with the incorporation of the General Plan EIR
policies and actions, as identified on page 3 15-52 of the General Plan EIR Because no new or
more significant impacts would occur, no new mitigation is necessary
2 Threshold 5 15(b) Result in inadequate emergency access
Finding No New or More Significant Impact (Draft SEIR, page 5-38 )
None of the growth management policies affect design requirements for safety and access, and
design review, including that for emeigency access, would be required on a project-by-project
basis As stated m the General Plan EIR, emergency vehicles take the fastest route to access an
emeigency, primary routes include Redlands Boulevard, Fern Avenue, Terracma Boulevard, and
Barton Road Of the primary evacuation routes, West Redlands Boulevard is located within the
Project area Implementation of current state and federal regulations, as well as the policies and
actions of the Geneial Plan, which include 5-A 3, 5-P 7, S-A 15, 7-A 90, 7-A 96, and 7-A 101
would reduce the potential impacts on intersections and roadway segments along emergency
access routes in the City For example, Action 5-A 15 calls for the maintenance of access for
emergency vehicles and services by providing two means of ingress/egress into new
communities, limitations on the length of cul-de-sacs, proper roadway widths and road grades,
adequate turning radius, and other requirements per the California Fire Code Impacts of the
proposed Project and the General Plan EIR, as stated on page 3 15-55 of the General Plan EIR,
are less than significant Because no new or more significant impacts would occur, no new
mitigation is necessary
XVI Tribal Cultural Resources.
1 Threshold 5 16(a)(1) Cause a substantial adverse change in the significance of a tribal
cultural resource, defined in Public Resources Code section 21074 as either a site, feature,
place, cultural landscape that is geographically defined in terms of the size and scope of the
Iandscape, sacred place, or object with cultural value to a California Native American tribe,
and that is listed or eligible for listing in the California Register of Historical Resources, or in
a local register of historical resources as defined in Public Resources Code section 5020 1(k)
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Finding No New or More Significant Impact (Draft SEIR, page 5-38 to 5-39 )
Public Resources Code section 21074 defines tribal cultural resouice as site features, places,
cultuial landscapes, sacred places, and objects of cultural value to a California Native America
tribe that is included or determined to be eligible in the California Registei of Historic Resources
and included in local register of historical resouices, or a resource determined by the lead agency
to be pursuant to criteria set forth in subdivision(c) of§ 5024 1
As stated in the General Plan EIR, the City of Redlands contacted the California Native
American Heritage Commission (NAHC) in July 2016 to iequest a search of its Sacred Lands
File, pursuant to SB 18 and AB 52 The NAHC provided a list with 13 California Native
American tribes to contact in accordance with SB 18 Of these tribes, the Agua Caliente Band of
Cahuilla Indians and the San Manuel Band of Mission Indians indicated that they did not identify
any cultural resources but requested drafts of the 2035 General Plan policies and the cultuial
section of the Geneial Plan EIR The following General Plan policies and actions would be
applicable to tribal cultural resources and the piotection of such resources 2-P 17, 2-A 71, 2-
A 72, 2-A 73, and 2-A 74 Compliance with the actions includes Action 2-A 72 that requires
applicants for projects identified by the South Central Coastal Information Center as potentially
affecting sensitive iesource sites hire a consulting archaeologist to develop an archaeological
resource mitigation plan and to monitor the project to ensure that mitigation measures aie
implemented, and, Action 2-A 73 that iequires that areas found during construction to contain
significant historic oi prehistoric archaeological artifacts be examined by a qualified consulting
archaeologist (RPA certified) oi historian for appropriate protection and preservation The 2035
General Plan policies and actions, coupled with compliance with AB-52 and SB-18, will ensure
coordination with the area's native tribes in the ieview and piotection of tribal cultuial resources
at development sites Impacts of the proposed Project and the General Plan EIR are less than
significant as indicated on page 3 8-25 of the General Plan EIR Because no new or more
significant impact would occui, no new mitigation is necessary
2 Thn eshold 5 16(a)(2) Cause a substantial adverse change in the significance of a tribal
cultural resource, defined in Public Resources Code section 21074 as either a site, feature,
place, cultural landscape that is geographically defined in terms of the size and scope of the
landscape, sacred place, oi object with cultural value to a California Native American tribe,
and that is A resource determined by the lead agency, in its discretion and supported by
substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of
Public Resources Code section 5024 1 In applying the criteria set forth in subdivision (c) of
Public Resource Code Section 5024 1, the lead agency shall consider the significance of the
resouice to a California Native American tribe
Finding No New or More Significant Impact (Draft SEIR, page 5-38 to 5-39 )
See discussion of Impact 5 5(a) in regard to state and local historical resources There are no
known tribal cultural resources in the 2035 General Plan Area, however, the 2035 Geneial Plan
Area has the potential to contain tribal cultuial resources from past Native American activities
Sensitive areas include lands along water sources and the many rock outcroppings and boulders
in the upland portions of the 2035 General Plan Area As the proposed Project would require
grading, overland vehicle travel, and other ground-distuibing activities, compliance with state
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and federal regulations regarding the protection of tribal cultural resources, such as AB 52 and
SB 18, as well as the following General Plan policies and actions, would ensuie that impacts to
tribal cultural resources as a result of Project implementation would be less than significant 2-
P 17, 2-A 71, 2-A 72, 2-A 73, and 2-A 74 These policies and actions would ensuie that potential
tribal cultuial resources are protected and that tribes are included in the review and protection
process of these resources The City has completed consultation with Native American tribes On
February 15, 2019, the City sent Consultation Request letters to 22 tribes, responses were
received from the following tribes Agua Caliente Band of Cahuilla Indians, San Manuel Band of
Mission Indians, and Augustine Band of Cahuilla Mission Indians The Agua Caliente Band of
Cahuilla Indians and San Manuel Band of Mission Indians concluded consultation stating that
there would be no conflict as a result of the proposed Project The Augustine Band of Cahuilla
mission Indians had no concerns and did not request consultation Therefore, impacts of the
proposed Project and the General Plan EIR are less than significant as indicated on page 3 8-25
of the General Plan EIR Because no new or more significant impact would occur, no new
mitigation is necessary
XVII Wildfire.
1 Threshold 5 17(a) Substantially impair an adopted emergency response plan or
emergency evacuation plan
Finding No New or More Significant Impact (Draft SEIR, pages 5-39 to 5-40)
In the event of an evacuation, emergency vehicles use the following primary routes, if available
Redlands Boulevard, Fern Avenue, Terracma Boulevard, and Barton Road Of the primary
evacuation routes, West Redlands Boulevard is located within the Project area The proposed
Project would not impair an adopted emergency response plan or emergency evacuation plan, as
future development would be required to comply with the General Plan policies and actions
aimed at ensuring that adequate emergency access is provided for existing and future
development Additionally, with the implementation of current state and federal regulations,
combined with General Plan policies and actions 5-A 3, 5-P 7, 5-A 15, 7-A 90, 7-A 96, and 7-
A 101, the proposed Project would reduce potential impacts along emergency access routes For
example, Action 5-A 17 calls for the maintenance of access for emergency vehicles and services
by providing two means of ingress/egress into new communities, limitations on the length of cul-
de-sacs, proper roadway widths and road grades, adequate turning radius, and other requirements
per the California Fire Code, and therefore, future development would continue to provide
emergency access during and post-construction As with the General Plan EIR, as identified on
page 3 15-55 of the General Plan EIR, impacts of the proposed Project would also be less than
significant
2 Threshold 5 17(b) Due to slope, prevailing winds, and other factors, exacerbate wildfiie
risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the
uncontrolled spread of a wildfire
Fmdin No New or More Significant Impact (Draft SEIR, page 5-40 )
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There are three primary factors used in accessing wildfire hazards — topography, weathei, and
fuel The Project area is generally flat and is in a highly urbanized environment According to
Figure 3 7-3, Fir e Ha. aw ds and Fire Safety Services, of the Geneial Plan EIR, the Project area is
in a moderate threat level area Theie are no slopes in or adjacent to the Pioject area, and because
it is urban there are fie hydrants and fire response access to the entire TVPA As noted above,
eineigency access during and after new developments are constructed will be in compliance with
the 2035 Geneial Plan Additionally, the following General Plan action aims to reduce impacts to
slopes 7-A 93 Action 7-A 93 iequires that new development minimize risks to life and property
through managing fire hazards by using multiple techniques, such as assessing site-specific
topography, slope, vegetation type, wind patterns, etc The following development principles
ensure that uncontrolled wildfire impacts are less than significant reduces fire fuel, ensure
access to existing fire hydi ants and water supply for suppression, and provide multiple access
points As identified on page 3 7-46 of the General Plan EIR, the General Plan EIR, as well as
the proposed Project would have less than significant impacts pertaining to exposing people or
structures to fire risks, and the proposed Project and General Plan EIR have less than significant
impacts on landslides, as identified on page 3 6-17 of the General Plan EIR
3 Threshold 5 17(c) Require the installation or maintenance of associated infrastructure
(such as roads, fuel breaks, emergency water sources, power lines oi other utilities) that may
exacerbate fire risk or that may result in temporary or ongoing impacts to the environment
Finding No New oi More Significant Impact (Draft SEIR, page 5-40 )
The proposed Project may require new infrastructure for electricity, natural gas,
telecommunications, and cable services The utilities would be installed to meet service
requirements The Project area is highly urbanized and is located in a moderate fie hazard area,
the proposed Project would not add infrastructure such as roads or overhead power lines ii areas
with wildland vegetation Therefore, impacts to exaceibating fire risks to the environment would
be less than significant foi the proposed Project as well as the General Plan EIR, which identified
that the project area is within a moderate fire hazard area, on page 3 7-46 of the Geneial Plan
EIR
4 Thi eshold 5 17(d) Expose people or structures to significant risks, including downslope
or downstream flooding or landslides, as a iesult of runoff, post-fire slope instability, or
drainage changes
Finding No New or More Significant Impact (Draft SEIR, page 5-41 )
See responses to Impact 5 7(a iv) on landslides, Impact 5 10(c iv) on flood flows, and Impact
5 17(b) on slopes The Project area is generally flat, is located in a highly urbanized portion of
the City and is within a moderate fire hazard zone According to Figure 3 6-3, Landslide
Potential, of the General Plan EIR, the location of the proposed Project is not within a landslide
potential zone Moreover, according to Figure 3 9-2, Flood Hazards, of the General Plan EIR,
portions of the Pioject area are located within the 100-year floodplain zone Therefore, it is
unlikely that the Project area would be susceptible to downslope or downstream flooding or
landslides as a iesult of post-fire slope instability Therefore, impacts would be less than
significant, for the proposed Project, as with the General Plan EIR, which identified less than
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significant impacts to landslides, flood flows, and slopes on pages 3 6-17 and 3 9-37 of the
General Plan EIR
Because the none of the circumstances in Public Resources Code section 21166 or State CEQA
Guidelines section 15162 is triggered for any of the foregoing environmental factors, no furthei
environmental review is required foi these areas and they were scoped out of the SEIR (Draft
SEIR, Chapter 5)
SECTION 3 ENVIRONMENTAL FACTORS FOR WHICH IMPACTS WERE
FOUND TO BE LESS THAN SIGNIFICANT
Fugal EIR This section identifies impacts of the proposed Project, as determined in Chapter 4,
Environmental Analysis, of the Draft SEIR, that examines the envnonnmental setting, and impacts
associated with the proposed Project All of the environmental impacts analyzed in Chapter 4 of
the Draft EIR did not require mitigation measures as these topics were found to be less than
significant This determination assumes compliance with the Existing Regulations as detailed in
Chaptei 4 of the Di aft SEIR
I LAND USE AND HOUSING
1 Impact 414 The proposed Pi oject would not divide an established community, no;
would the proposed P1 oject du ectly of uzdi;ectly result in population growth in the
pi oject al ea
Finding No New or More Significant Impact (Draft SEIR, pages 4 1-6 to 4 1-7 )
a Dividing an Established Community
The proposed Project will not result in construction, but the proposed Ballot Initiative would
allow the City to consider taller buildings and mole intense development (up to 27 dwelling units
per acre) without a 4/5ths vote of the City Council
A concern raised during the notice of preparation period was the potential for the proposed
Project to allow larger buildings that could visually and physically divide parts of the
TVPA As shown in Table 3-1, Existing Land Use Suininaiy, on page 3-2 in Chapter 3 of the
Draft SEIR, the 2035 General Plan already allows for a range of development types (e g
commercial, industrial, single and multi-family residential) within the TVPA Existing
zoning standards established by the Redlands Municipal Code (RMC) that apply in the
TVPA currently allow for taller buildings For example, properties located within the
boundaries of the existing Downtown Specific Plan (SP45) have a three stones or 55 foot
height limit, properties that are zoned C-3, General Commercial have no height limit (§
18 92 130 RMC), and properties that are zoned Industrial have a 50 foot height limit (§
18 108 100 RMC) Relatedly, properties zoned R-3, Multiple Family Residential, may be
constructed up to 4-stones (§ 18 60 120 RMC)
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If approved, the proposed Project would eliminate the 4/5ths vote and findings required to
allow residential projects with a density of more than 18 units to the acre to exceed 35 feet
within the TVPA While the 4/5ths vote and findings would allow a multiple family
residential structure in excess of 35 feet, Section 18 60 120 would restrict the building to
four stories Typically, a four-story residential structure can be designed within a 40-foot
height, although some design features may extend beyond 40 feet Section 18 152 030 of the
RMC governs the design elements that could exceed maximum height restnctions As the
existing condition allows projects to exceed the 35-foot height limit with a 4/5ths vote, and
if this requirement is removed, the underlying multiple family residential zoning standards
would still be applicable, and the iesulting buildings would be similar in height with or
without the proposed Project
The General Plan EIR indicated that the General Plan would not result in uses or development
that would physically divide any established community, nor would it propose new highways or
infrastructure that would physically divide the community The General Plan EIR indicated
that no impacts would occur, as identified on page 3 10-11 of the General Plan EIR, and
sumlarly, the proposed Project would result in no significant impacts, as the proposed
Project would be required to comply with the policies and actions of the 2035 General Plan
b Inducing Population Growth
The 2035 General Plan would result in an increase of 3,422 dwellmg units (not including
currently proposed housing units), 10,964 residents, as shown in Table 2 3-5, Projected
Population at Buildout (2035), of the 2035 General Plan EIR, and 14,561 jobs as shown in Table
2 3-6, Pr ojected Non-Residential Buildout (2035) The proposed Project could result in a
potential total of dwelling units by 171 (see Table 4 1-3, on page 4 1-16 in Chapter 4 1 of the
Draft SEIR) within the TVPA, by buildout of the 2035 General Plan The 171 units repiesents a
population of approximately 453 residents Assuming that all residents are new to the City, this
could increase the 2019 population by 0 63 percent If applied to the projected 2035 population
of 79,013, the total of 79,466 repiesents an increase of 0 57 percent, and remains below the
SCAG 2035 population estimate of 83,400 The SCAG population estimate is used for regional
planiung
According to Table 2 3-4, of the projected 3,422 dwelling units, 2,124 units would be single-
family residential, and 1,298 units would be multi-family residential at buildout Additionally, of
the 3,422 dwellmg units, a total of 1,148 dwelling units (224 single-family and 924 multi-family
units) would be constructed within the Transit Village
As the proposed Project does not adopt any new policies that would change the design of
intensity of development beyond what was evaluated in the 2035 General Plan EIR, there is
no impact on the potential to divide an established community Moreover, the proposed
Project would not significantly affect the regional growth of the City and would be consistent
with the overall population and employment growth forecasts evaluated in the 2035 General Plan
EIR As indicated on page 5-3 of the General Plan FIR, the impacts of the General Plan EIR
would not be growth-inducing beyond regional forecasts, and the proposed Project would not
result in new or more significant impacts in this regard (Draft SEIR, pages 4 1-6 to 4 1-7 )
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2 Impact 4 1-2 Pr oject implementation would not conflict with applicable plans adopted
for the purpose of avoiding or mitigating an environmental effect
Finding No New or More Significant Impact (Draft SEIR, pages 4 1-7 to 4 1-16 )
Many of the provisions of the Measure U address annexation, expansion into the rural
periphery of the City, and along the Santa Ana River Focused on the TVPA, the proposed
Project does not affect any of the existing measures that address these issues Furthei, the
growth management policies, and municipal code requirements continue to apply to areas of
the City outside of the TVPA
Measure N a zoning ordinance that amended Proposition R to limit the development of
residential dwelling units to 400 units per calendar year Of the 400 units, 50 units are
required to be reserved foi single-family home on existing lots of record as of the date of the
Measure, with the remainder to be allocated according to a competitive evaluation system
which emphasizes design factors The Measure also restricts changing land designations or
zoning to a higher density than Ruial Estate (R-E) for those lands designated as urban
reserve agricultural on June 1, 1987, and limits development on steep slopes The proposed
Project would amend Measure N and Proposition R to remove the TVPA from the annual
dwelling unit limitation but retain the annual dwelling unit limitation for the remainder of
the City
Table 4 1-1, Applicability Between Proposed Project and Measures U, N, and Proposition R, on
page 4 1-8 rn Chapter 4 1-1 of the Draft SEIR, includes a column identifying policies established
by Proposition R, as amended by Measure N, and by Measure U Table 4 1-1 then sets forth
which policies would continue to apply to proposed development within the TVPA if the Project
is approved, which would not apply, and which policies aie inapplicable to the TVPA
a Multiple-Family/ Single-Family Unit Mix
If the proposed Pioject is approved, housing units within the TVPA would not count toward
the Measure U planning goal of achieving a mix of 75 percent single family and 25 percent
multiple family housing units citywide As a result, future projects could increase density
within the TVPA changing the overall percentage of single and multiple family residential
units in the City The housing units shown in Table 4 1-2, Population and Housing Units
2000 — 2019, on page 4 1-14 in Chapter 4 1 of the Draft SEIR, shows that the existing r atro
of conventional single-family homes to other housing types may currently exceed the 75/25
percent expectation outlined in the 2035 General Plan Encouraging more density in the
TVPA may reduce expectations to build higher density in the remainder of the community
allowing the ratio in those areas of the City to remain unchanged or move closer to the
citywide goal of 75/25 multiple-/single-family residences
b Density and Height Limitation
Without making all the following findings, and a 4/5ths vote of the total authorized
membership of the City Council to approve a project, a development project is limited to a
density of 18 units per acre and 35 feet in height
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1 There are substantial and overriding economic or social benefits to the City
and its residents and taxpayers from the proposed density or height increase
2 The proposed density oi height increase will not cause adverse environmental
impacts, either individually oi cumulatively, directly or indirectly
3 The proposed density increase will not have a growth-inducing effect on other
property
4 The resulting use will be compatible with uses on adjacent land
5 The proposed density increase will not require substantial expansion of public
infrastructuie, facilities or services
The proposed Project would remove the requirement foi these findings within the TVPA
allowing the 2035 General Plan maximum of 27-units to the acie to apply without the need
for a 4/5ths vote The RMC however, will still apply to multiple family residential
development larger than a fourplex within the TVPA The Architectural Review Criteria
(RMC Section 1$ 20 170) establish the following must be considered by the Commission in
in review of the project
1 Site layout, orientation, location of structures and relationship to one another,
as well as open spaces and topography,
2 Harmonious relationship of building with existing and proposed adjoining
developments,
3 Maximum height, area, setbacks and overall mass of buildings, as well as
other structures such as walls, screens, towers oi signs, and effective
concealment of all mechanical equipment,
4 Harmony of construction materials and colors in relation to all exterior
elevations,
5 Location and type of planting, with due regard for the preservation of
specimen trees upon a site,
6 Design and appropriateness of signs in ielation to the architectural style of the
building,
7 Glazing or image reflective surfaces (specular reflectance) shall be limited to
a maximum reflectance value of twenty five percent (25%)
The findings for approval of a site plan in the RMC are similar to those in Measure U and
will continue to apply to projects within the TVPA The difference is that if the proposed
Project is approved, the Council can approve projects with a simple majority rather than a
4/5ths vote
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If the proposed Pioject is approved, a 4/5ths vote would not be necessary to exceed the 35-
foot height limitation of Measure U within the TVPA However, the 4-story limit
established in the R-3 Multiple-Family Residential District would apply the zoning standard
established by Section 18 60 120 of the RMC
As shown in Table 4 1-3, Maa.iinuni Potential Unit Yield within the TVPA Without 4/5ths
Council Vote, on page 4 1-16 in Chaptei 4 1 of the Draft SEIR, there are approximately
19 03 aci es of land zoned for multiple family residential Table 4 1-3 calculates the change
in the number of units that could be built if all the available land was able to accommodate
the maximum density allowable in the 2035 General Plan
If the buildout methodology in the 2035 General Plan EIR is followed, the unit yield would
be appioximately 80 percent of the maximum allowable density resulting in approximately
137 more units that could occur without a 4/5ths vote of the Council The estimated 514
multiple family units is below the 924 units estimated in Table 2 3-4 on page 2-29 of the
2035 General Plan EIR for Transit Village Housing by 2035 The 2035 General Plan EIR
evaluated environmental impacts associated with the full 27-units to the acre No mitigation
measures are included in the 2035 General Plan EIR for Land Use and Housing and as the
proposed Project is within the development assumptions for the 2035 General Plan EIR
Thus, because the proposed Ballot Initiative does not alter the maximum buildout potential
for properties within the TVPA, of the City, and because the land use designations remain
the same and the total maximum intensity development remains unchanged, the proposed
Ballot Initiative would not have new or more significant impacts with respect to conflicts
with existing land use plans
c Annual Residential Unit Cap
The provision of Proposition R which restricts the number of residential permits that could be
issued in a single calendar year would not apply within the TVPA if the pioposed Project is
approved Table 4 1-2 shows the population growth from 2000 to 2019 as estimated by the
California Department of Finance who bases growth, in part, by the numbers of building permits
reported by jurisdictions annually Table 4 1-2 shows that on average, the City added 109 new
homes per year The pioposed Project does not represent a significant increase un the number of
housing units and does not exceed the estimates in the General Plan EIR used for evaluating
buildout of the 2035 General Plan Therefore, the proposed Ballot Initiative would not result in
new or mole significant impacts in this regard
The Geneial Plan EIR indicated on pages 3 10-14 and 3 10-15 that no impacts would occur if the
2035 General Plan does not conflict with any other agencies' land use policies or plans and if
amendments to City policies and regulations are detailed in the General Plan Similarly, as the
proposed Project would not result in new or more significant impacts, no impact would occur
(Draft SEIR, pages 4 1-7 to 4 1-16 )
3 Impact 41-3 Project iinpleinentation would not i esult in displacing people and/oi
housing
Funding No New or More Significant Impact (Draft SEIR, pages 4 1-6 to 4 1-17 )
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The 2035 General Plan EIR mdicated that the majority of development in the 2035 General Plan
area is composed of residential uses, which are not anticipated to undergo substantial land use
changes The 2035 General Plan focuses on mfill residential development opportunities in vacant
areas in the City, while policies seek to preserve existing neighborhoods The 2035 General Plan
EIR indicated that it would be possible that some homes may be lost in the event of
redevelopment of sites where housing currently exists However, under the 2035 General Plan,
the overall number of dwelling units would increase and provide housing to serve the diverse
needs of the community, meaning that potentially displaced people would be able to find housing
elsewhere in the community As indicated in Impact 4 1-2, there would be an increase of 3,422
dwelling units in the City, and of these dwelling units, 1,148 dwelling units would be located in
the TVPA
The proposed Project does not propose any specific development The proposed Project would
not increase oi change the overall land use buildout assumed and analyzed in the 2035 General
Plan EIR, therefore, the proposed Project would not affect population in the City or regional
growth as the proposed Project would be consistent with the overall growth forecast assumed in
the 2035 General Plan EIR 2035 General Plan Policy 4-P 2 ("Provide foi the expansion of
housing and employment opportunities while ensuring a high quality of life is maintained in
Redlands") and Policy 4-P 16 ("Promote a variety of housing types to serve the diverse needs of
the community") would continue to be applicable under the proposed Project As indicated on
page 3 10-16 of the General Plan EIR, the General Plan EIR had less than significant impacts on
the displacement of people and housing, and similarly, the proposed Project would not result in
new or more significant impacts related to the displacement of people or housing (Draft SEIR,
pages 4 1-6 to 4 1-17 )
II TRANSPORTATION
1. Impact 4.2-1: The proposed Project would not conflict with a program,plan, ordinance,
oz policy addi esszng the circulation system, including ti anszt, roadway, bicycle, and
pedesti zan facilities
Finding No New oi Mole Significant Impact (Draft SEIR, pages 4 2-7 to 4 2-8 )
Impacts of the 2035 General Plan on the vehicular network were forecasted for intersection,
roadway, and freeway analysis According to Table 3 15-9, Futui e (Veal 2035) plus Pi oject
Intersection Level of Service, of the General Plan EIR, the following intersections, which aie
within the TVPA, would result in traffic levels of service (LOS) of less than "C " #19 Colton
Avenue and Eureka Street, #21 Colton Avenue and University Stieet, and #22 Colton Avenue
and Judson Street in the year 2035 The General Plan EIR states that using the relevant impact
criteria, and assuming the implementation of improvements in the 2035 General Plan, none of
the intersections would expect significant impacts with the full 2035 General Plan buildout
Moreover, Table 3 15-11, Future (Year 2035) plus Project Roadway Segment Level of Service
of the General Plan EIR, shows that none of the study roadway segments in 2035 would operate
at unacceptable levels of service, assuming full implementation of the 2035 General Plan
improvements Additionally, segment #54 of I-10, from Tennessee Street to Orange Street,
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would operate at a LOS C or better in 2035, while segment #55 of I-10, from 6th Street to
University St, which is within the TVPA would operate at a LOS E in 2035, as shown in Table
3 15-13, Future (Yea; 2035)plus Project Fi eeway Segment Level of Service, of the General Plan
EIR
The 2035 Geneial Plan includes policies and actions addressing changes in vehicle LOS
resulting from buildout Additionally, the 2035 General Plan includes policies and actions that
strengthen and expand the non-motorized tiansportation system and would not conflict with any
established plans, ordinances, or policies establishing measures of effectiveness for these forms
of circulation
Upon implementation of the proposed Project, the iequnement foi the maintenance of traffic
levels of service "C" for all intersections when considering new development, would no longer
apply within the TVPA Howevei, the Geneial Plan EIR indicated that the intersections within
the TVPA would not result in significant impacts if improvements aie implemented, and, as
shown in Table 3 15-11, none of the roadway segments would result in a LOS of less than C
Segment #55 of the I-10 would be the only freeway segment in the TVPA that would result in a
LOS of less than C in 2035 Because the freeway system is not within the City of Redland's
jurisdiction, as impacts on the freeway system would occur due to regional growth, regardless of
the implementation of the 2035 General Plan, impacts would be significant and unavoidable The
proposed Project would implement the following policies and actions of the General Plan EIR 5-
P 2, 5-P 3, 5-P 5, 5-P 10, 5-P 21, 5-P 23, 5-P 24, 5-A 30, 5-A 32, 5-A 34, 5-A 38, 5-A 39, 5-
A 40, 5-A 42, 5-A 43, 5-A 44, 5-A 45, 5-A 46, and 5-A 48 As indicated on page 3 15-34 of the
General Plan EIR, the impacts of the General Plan EIR aie significant and unavoidable as eight
of the proposed improvements are located on facilities that are partially or fully controlled by
other jurisdictions, and the City can not guarantee implementation As the proposed Project
would not result in new or more significant impacts in this regard, impacts of the General Plan
EIR and the proposed Project would be the same (Draft SEIR, pages 4 2-7 to 4 2-8 )
2 Impact 4 2-2 Adoption of the Gene;al Plan would conflict with an applicable congestion
management plan (CMP) including, but not limited to level of service standai ds and
tr avel demand measly es, or standards established by the county congestion management
agency for designated roads or highways
Fmdmg Less than Significant Impact (Draft SEIR, pages 4 2-8 to 4 2-9 )
Page 3 15-27 of the General Plan EIR, states that the performance criteria used for facilities in
the SANBAG San Bernardino County CMP facilities are as follows
• LOS E is the minimum acceptable level of service
■ Projects that degrade LOS E to LOS F, or worsen conditions at facilities already
operating at LOS F will result in a significant Impact
If all the proposed 2035 General Plan improvements were to be implemented, then six CMP
Intersections and 14 CMP roadway segments within the 2035 General Plan Area would not
degrade existing levels of service below acceptable levels or further degrade existing
unacceptable level of service However, as stated on page 3 15-49 of the General Plan EIR, some
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improvements of the General Plan EIR are partially or fully within the control of other
jurisdictions and cannot be guaranteed by the City, and without the proposed improvements, the
LOS would worsen at a roadway segment, Alabama Street from Palmetto Avenue and Pioneer
Avenue, already opeiating at LOS F This would result m a significant and unavoidable impact
under the General Plan EIR Howevei, as this roadway segment is not within the TVPA, and the
proposed Project does not increase density oi intensity of development beyond what was
analyzed in the General plan EIR, impacts of the proposed Project would not result in new or
more significant impacts Moreover, the proposed Project would implement the following
policies and actions of the General Plan EIR 5-P 2, 5-P 3, 5-P 5, 5-P 10, 5-P 21, 5-P 23, 5-P 24,
5-A 30, 5-A 32, 5-A 34, 5-A 38, 5-A 39, 5-A 40, 5-A 42, 5-A 43, 5-A 44, 5-A 45, 5-A 46, and 5-
A 48 (Draft SEIR, pages 4 2-8 to 4 2-9 )
3 Impact 4.2-3: The proposed Pi oject would not conflict oi be inconsistent with CEQA
Guidelines sr 15064 3, subdivision (b)
Fmdmg No New or More Significant Impact (Draft SEIR, pages 4 2-9 to 4 2-10 )
The proposed Project would remove the requirement for the maintenance of traffic levels of
service "C" for all intersections within the TVPA, or for areas where LOS C is already exceeded,
assure that it does not degrade as a result of development Even though, beginning July 1, 2020,
the City will geneially measure transportation impacts using VMT instead of LOS, LOS remains
relevant to the City's analysis of a subsequent project's merits because projects must still comply
with the Cuculation Element of the General Plan that has policies regarding level of service
The proposed Project would not inciease oi change the overall land use buildout assumed and
analyzed in the General Plan EIR Therefore, the proposed Project would not affect the projected
traffic assumed in the 2035 General Plan and remains consistent with the regional growth
forecast The proposed Project would continue to implement the following policies and actions
of the 2035 General Plan as stated in the discussion begnnrimg on page 3 15-57 of the General
Plan EIR 5-P 2, 5-P 3, 5-P 5, 5-P 10, 5-P 21, 5-P 23, 5-P 24, 5-A 30, 5-A 30, 5-A 32, 5-A 34, 5-
A 38, 5-A 39, 5-A 40, 5-A 43, 5-A 44, 5-A 45, 5-A 46, and 5-A 48
The proposed Project is intended to allow the City to consider future projects that would be
designed to maximize access to planned tiansit stops within the TVPA The expectation is that
future residents would use the transit stops in lieu of at least some of the vehicle trips ordinarily
associated with development No physical project or change in land use density is part of the
proposed Project Instead, the proposed Project removes existing impediments to City
consideration of transit-oriented design (TOD) features such as higher density, mid-rise
buildings, and new general plan designations, within the TVPA With the combination of
appropriate project design, oriented around future transit stations, the City anticipates a reduction
un VMT as future residents will have more transportation options within the TVPA than currently
exist
As the proposed Project does not provide for more development than currently projected in the
2035 General Plan and analyzed in the General Plan EIR, and as future development can take
advantage of currently planned transit routes allowing for a reduction in VMT, the proposed
Project is consistent with CEQA Guidelines Section 15064 3, subdivision (b) and with the
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conclusion in on page 3 15-60 of the Geneial Plan EIR, this impact is less than significant
impact (Draft SEIR, pages 4 2-9 to 4 2-10 )
III UTILITIES AND SERVICE SYSTEMS
1 Impact 4.3-1:Existing and/or pi oposed facilities would be able to accommodate pi oject-
gen cited utility demands
Finding No New of Mole Significant Impact (Draft SEIR, pages 4 3-11 to 4 3-12 )
The General Plan EIR projected future water supply and demand for the 2015 San Bernaidino
Valley Regional Urban Water Management Plan (RUWMP) based on existing water system
mfrastructure For the General Plan buildout year of 2035, the City assumed a service population
of 95,000 which is greater than the 2035 Planning Aiea population of 93,624 projected foi the
2035 General Plan As stated in the General Plan EIR, the 2035 demand for potable and raw
water is projected to be 30,313 acre feet (afa), or an average of 27 million gallons per day (mgd),
this amount can sufficiently be accommodated by the City's existing water treatment plants and
delivery infrastructure which have a capacity of 35 mgd The City's 2015 water use was 234
gallons pei capita pei day (GPCD) (SBVMWD 2017) The 171 housing units would result in
approximately 453 residents in the TVPA by buildout of the 2035 General Plan, which was
analyzed in the General Plan EIR, the water use would 106,002 GPCDb, or roughly 0 11 MGD
This water use is within the 35 MGD capacity of the City's existing water treatment plants and
distribution infrastructure
Additionally, according to the General Plan EIR, the City has a projected average wastewater
flow of 6 75 mgd at buildout of the 2035 General Plan, as the projected flow is within the 9 5
mgd secondary capacity and 7 2 mgd tertiary capacity, no new or expanded treatment facilities
are required to serve the 2035 General Plan population at buildout Monthly effluent reports to
the RWQCB show that the discharge permit levels for sodium and chloride are exceeded The
City has determined that the exceedances are as a result of wear on filtration media at the plant
The filtration media is a wear-item at the facility and needs to be replaced periodically to remain
within discharge requnements Replacement of the media is considered an on-going operation
and maintenance issue foi the facility The physical permitted capacity of the wastewater
treatment plant does not need to be expanded to accommodate the projected population in the
2035 Genial Plan
Moreover, as stated in the General Plan EIR, development proposed under the 2035 General Plan
would allow for the redevelopment of existing developed areas that would generate increased
storinnwater volumes, which in turn could create a need for new infrastructure The General Plan
EIR indicates that land use designations in the 2035 General Plan would focus new development
within the developed footprint of the City, allowing mfill projects to take advantage of existing
stormwater mfiastructure, where most sites that may be developed or redeveloped in the future
are already built with impervious sun faces
Acre Foot =325,851 gallons
b 234 GPCD z 453 people = 106,002 GPCD
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The proposed Project would be consistent with the overall growth forecast assumed in the
Geneial Plan EIR, as land uses are limited to those in the 2035 General Plan Therefore, the
proposed Project would not require or result in the relocation or construction of existing or
proposed facilities beyond what was considered in the General Plan EIR, and no new or
substantially greater impacts would occur when compared to those identified in the General Plan
EIR Similar to the General Plan EIR, the proposed Project would comply with state and local
regulations, as well as implement the policies and actions of the Geneial Plan EIR 4-P 56, 4-
A 145, 4-A 146, 4-A 148, 6-A 39, 7-A 149, 8-P 4, 8-P 5, 8-P 6, S-A 22, 8-A 23, 8-A 24, 8-A 25,
8-A 26, 8-A 28, 8-A 29, 6-P 19, 6-P 20, 6-P 21, 6-A 34, 6-A 35, 6-A 36, 6-A 37, 6-A 38, 6-A 39,
6-A 40, 6-A 41, 6-A 42, 6-A 43, and 6-A 44 Oveiall, the proposed Project would be consistent
with the less than significant impacts identified in the General Plan EIR, as indicated on pages
3 14-19 through 3 14-21 and page 3 14-25 of the General Plan EIR, and the proposed project
would have no new or more significant impacts in this regard (Draft SEIR, pages 4 3-11 to 4 3-
12 )
2 Impact 4 3-2 Available water supplies ar e sufficient to serve the project and reasonably
far eseeable future development during normal, dry, and multiple dry yea;s
Fri_.. zding No New or More Significant Impact (Draft SEIR, page 4 3-13 )
The General Plan EIR stated that the demand for potable and raw water at buildout for a
population of 95,000 in 2035 is projected to be 30,313 af, and demand for recycled water is
projected to be 5,402 af, the total demand would be 35,715 af in 2035 The additional 106,002
GPCD represents a total demand of 0 33 af According to the 2015 RUWMP, the City's
projected water supply for 2035 is 64,098 af from existing sources and entitlements
According to the General Plan EIR, the City has identified adequate supplies from existing water
sources and entitlements to meet demand through 2035 The General Plan EIR indicated that the
projected surface water diversions and groundwater extractions from the San Bernardino Basin
Area (Bunker Hill Subbasm) in 2035 would be 34,549 af for a population of 101,644 The
Geneial Plan EIR stated that the 2015 IRWMP found that this volume, in addition to the
requirements of other agencies relying on the Basin Area, could be accommodated as long as
extractions over safe yield are recharged to the Basin The IRWMP showed that projected
extractions from the Yucaipa Subbasm by the City of 1,816 af rn 2035, would be within the safe
yield amount for Yucaipa Subbasm, even when combined with the demands from other agencies,
as indicated in the General Plan EIR Moreover, the City would have adequate supply for
multiple dry years, in the event of a water shortage, the City would rely on its Water
Conservation Plan While a series of dry years would reduce supply, the City has the potential to
utilize multiple sources and offset normal supplies with additional groundwater and conservation
efforts without seeking additional entitlements or water sources, as stated in the General Plan
EIR
The proposed Project does not propose any specific development projects and would not result in
an increase or change in the overall buildout land use assumptions analyzed in the General Plan
EIR The proposed Project would not result in any new impacts or inciease the severity of
impacts, with respect to water supplies As with the General Plan EIR, the proposed Project
would implement the applicable policies and actions of the 2035 General Plan and would be in
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compliance with local and regional water management plans, as well as with SBx7-7 Therefore,
no new or substantially greater impacts to water supplies would occur under the proposed Project
when compared to those identified in the Geneial Plan EIR The General Plan EIR policies and
actions, 8-P 4, 8-P 5, 8-P 6, 8-A 22, 8-A 23, 8-A 24, 8-A 25, 8-A 26, 8-A 28, 8-A 29, 6-P 20, 6-
P 21, 6-A 36, 6-A 38, 6-A 39, 7-P 27, and 8-A 16, would continue to be implemented The
proposed Project would not result in any new or more significant impacts in this regard, beyond
the less than significant impacts identified in the General Plan EIR, on page 3 14-29 of the
General Plan EIR (Draft SEIR, page 4 3-13 )
3 Impact 4 3-3 Project-gene;ated wastewater could be adequately ti eated by the
wastewater service pr ovide;for the project
Finding No New or More Significant Impact (Draft SEIR, pages 4 3-13 to 4 3-14 )
According to the General Plan EIR, future residential uses in the City could generate additional
wastewater, which would result in an increase in wastewater conveyance, collection, and
tieatment needs over current levels As discussed in Impact 4 3-1, the existing wastewater
treatment capacity would be adequate to serve the 6 75 mgd flows projected foi 2035, therefore,
new or expanded facilities would not be required The Geneial Plan EIR indicated that the goals
and policies of the 2035 General Plan that aim to conserve water, by curbing demand for
domestic and commercial purposes, ensure coordinated planning for the provision of public
facilities including water infrastructure, and ensure that utilities be designed and constructed to
preserve the natural character of an area, these policies would assist in reducing the demand on
existing treatment infrastructure and allow for meaningful consideration of potential impacts of
any future decisions regarding the provision of new infrastructure In addition to the policies and
goals of the 2035 General Plan, current regulations require compliance with water quality
standards and would not allow for the development of proposed projects without adequate utility
capacity, including wastewater treatment capacity
Monthly effluent reports to the RWQCB show that the discharge permit levels for sodium and
chloride are exceeded The City has determined that the exceedances are as a result of wear on
filtration media at the plant The filtration media is a wear-item at the facility and needs to be
replaced periodically to remain within discharge requirements Replacement of the media is
considered an on-going operation and maintenance issue foi the facility The physical permitted
capacity of the wastewater tieatment plant does not need to be expanded to accommodate the
projected population in the 2035 General Plan The proposed Ballot Initiative would allow the
City Council to consider future development projects within the TVPA without the burden of the
annual residential dwelling unit limitation The proposed Project does not propose specific
development projects and would not result in an increase or change m the overall buildout of
land use assumptions analyzed in the Geneial Plan EIR The proposed Project would not result m
any new impacts or increase the severity of impacts, with respect to wastewater capacity Future
development allowed under the 2035 General Plan would be reviewed by the City and the
applicable wastewater providers to determine that sufficient capacity exists to serve the
development As with the General Plan EIR, the proposed Project would implement the
applicable General Plan policies and actions, A-P 56, 4-A 145, 4-A 146, 4-A 148, 8-P 4, 8-P 5,
8-P 6, 8-A 22, 8-A 23, 8-A 24, 8-A 25, 8-A 26, 8-A 27, 8-A 28, 8-A 29, and would comply with
federal, state, and local regulations Therefore, the proposed Project would not result in new or
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more significant impacts in this regard, beyond the less than significant impacts of the General
Plan EIR, as identified on page 3 14-30 of the General Plan EIR (Draft SEIR, pages 4 3-13 to
43-14 )
4. Impact 4.3-4: Eaasting and/or pi oposed facilities would be able to accommodate project-
genei ated solid waste and comply with I elated solid waste i egulations
Finding No New or More Significant Impact (Draft SEIR, pages 4 3-14 to 4 3-15 )
The City provides solid waste collection services foi the Project area Solid waste is primarily
disposed of at the California Street Landfill and the San Timoteo Sanitary Landfill operated by
the City of Redlands and the County of San Bernardino, respectively, both within the City limits
The daily maximum throughput of the California Street Landfill is 829 tons/day, and 2,000
tons/day foi the San Timoteo Sanitary Landfill The California Street Landfill has a maximum
permitted capacity of 10,000,000 cubic yards, and a remaining capacity of 6,800,000 cubic
yaids, the Landfill has an estimated cease operation date of January 1, 2042 The San Timoteo
Sanitary Landfill has a maximum permitted capacity of 20,400,000 cubic yaids, and a remaining
capacity of 11,402,000 cubic yards, the Landfill has an estimated cease operation date of January
1, 2043
AB 939 mandated California to generate a 25 percent diversion rate by 1995 and a 50 percent
diversion rate by 2020, California diverted 52 percent of its waste flora landfills in 2005
Therefore, the state, including the City of Redlands, reached this goal and is in compliance with
the law, according to the General Plan EIR Chapter 13 66, Recycling Requu ements foi Specified
Development Activity, of the City's Municipal Code establishes requirements for recycling,
including access points for solid waste and recycling collection vehicles, design of recycling and
trash enclosures, as well as capacity requirements for waste generation of buildings, m order to
facilitate compliance with state recycling mandates
According to the General Plan EIR, if the City produces 60,000 tons of disposal per year for the
next 20 years, it would only fill 24 percent of the remaining space in the landfills (5,000,000
tons) The 171 multi-family dwelling units, that could be built if all the available land zoned
High Density Residential within the TVPA was able to accommodate the maximum density
allowable in the 2035 General Plan, would generate 872 lbs/dayC of solid waste which would be
5,093,064 lbs or 2,547 tons of disposal, over the next 16 years As the General Plan EIR included
the unit potential from the proposed Project, approval of the Project would not result in adverse
impacts on landfill facilities
As previously indicated, the proposed Project does not propose any specific development
projects and would not result m an increase or change in the overall buildout land use
assumptions analyzed in the General Plan EIR The proposed Project would not result in any new
impacts or increase the seventy of impacts, with respect to solid waste As with the General Plan
51 lbs/dwelling unit/day(average of multifamily disposal rate)
171 units,5 1 lbs/dwelling urns/day—8721 lbs/dwelling unit/day
872 lbs/dwelling unit/day 365 days =318,316 5 lbs/di»elling unit/yea)
318,316 5 lbs/dwelling unit/yea) a 16 years(yea; 2035—yea) 2019) =5 093 064 lbs/dwelling unit =2546 532
tons/dwelling unit
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EIR, development of fixture land uses, as designated in the 2035 General Plan, would be required
to comply with federal, state, and local statutes and regulations pertaining to solid waste and
recycling, as well as the applicable 2035 General Plan policies and actions, 8-P 7, 8-A 30, 8-
A 31, 8-A 32, 8-A 33, 8-A 34, 8-A 35, 8-A 36, 8-A 37, 8-A 38, 8-A 42, which would further
ensure compliance with applicable regulations
Therefore, no new or substantially greater impacts to solid waste would occur undei the
proposed Project when compared to those identified rn the General Plan EIR The proposed
Project would not result in new or more significant impacts in this regard, beyond the less than
significant impacts identified in the General Plan EIR on page 3 14-33, in regard to landfill
capacity, and the no impact level of significance identified on page 3 14-35 of the General Plan
EIR, in regard to violating regulations related to solid waste (Draft SEIR, pages 4 3-14 to 4 3-
15 )
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SECTION 4 ENVIRONMENTAL FACTORS FOR WHICH FURTHER
ENVIRONMENTAL REVIEW WAS REQUIRED AND WHERE PROJECT-LEVEL
SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS WERE IDENTIFIED
The General Plan EIR identified that the following topics would result in significant and
unavoidable impacts
■ Agriculture and Forestry Resoul ces
■ Au Quality
■ Transportation
Agricultuie and Forestry Resources 3 2-1 Buildout of the General Plan would convert Prime
Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps
prepared pursuant to the Farmland Mapping and Monitoring Progi am of the California
Resources Agency, to non-agricultural use
Air Quality 3 2-2 Development under the General Plan would violate an quality standards or
contribute substantially to an existing or projected au quality violation 3 2-3 Development under
the General Plan would result in a cumulatively considerable net increase of any criteria
pollutant for which the 2035 General Plan region is nonattamment under an applicable federal or
State ambient au quality standard (including releasing emissions which exceed quantitative
thresholds for 03 precursors)
Transportation 3 15-1 Implementation of the General Plan could result in conflict with an
applicable plan, oidmance, or policy establishing measures of effectiveness of the circulation
system, taking into account all modes of transportation including mass transit and non-motorized
travel and relevant components of the circulation system, including but not limited to
intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit
Transportation 3 15-2 Adoption of the General Plan would conflict with an applicable
congestion management program (CMP) including, but not limited to level of service standards
and travel demand measures, or standards established by the county congestion management
agency for designated roads or highways
According to page 1-9 of the Draft SEIR, the Draft SEIR assumes that development within the
TVPA will be similar to that evaluated in the General Plan EIR, and that the significant and
unavoidable environmental findings will, therefore, be identical As such, the proposed Project
would not exacerbate the impacts and the significant and unavoidable level of significance would
continue under the proposed Project Additionally, although the proposed project could increase
the total number of units in the TVPA by 171 units, the population increase of 453 residents,
assuming that all of these residents are new to the City, would be below the SCAG 2035
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population estimate Therefore, the potential increase in population would not contribute nor
exacerbate the significant and unavoidable impacts
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SECTION 5 CUMULATIVE IMPACTS.
1 Land Use and Housing
Finding No New of More Cumulatively Consideiable Impacts (Draft SEIR, pages 4 1-17 to 4 1-
18 )
The land use effects of the proposed Project are limited to the TVPA, with all other provisions of
the 2035 General Plan applying to the iemainder of the City Cumulative population and housing
impacts are assessed relative to the City's 2035 General Plan and regional plans, mcludmg
SCAG's 2016-2040 RTP/SCS population, housing, and employment projections
The cumulative current and future projects in the City would include projects with residential
components Full build out under the 2035 Geneial Plan would result in an increase of 4,355
dwelling units, which include pipeline housing units and future development under the 2035
Geneial Plan Theiefoie, the future buildout scenario within the City would be 31,104 dwelling
units, 79,013 residents, and 31,471 households by 2035 Approval of the proposed Project would
allow up to a total of 171 dwelling units within the TVPA without a 4/5ths vote of the City
Council
Table 4 1-4, Projected Population Buildout (2035), on page 4 1-18 in Chapter 4 1 of the Draft
SEIR, shows the existing (2016) and projected residential and population growth in the City of
Redlands at buildout, as indicated in the General Plan EIR
As shown in Table 4 1 4, lines 1, 2 and 4 of this table represent existing housing, plus housing
approved but not constructed, plus future development outside of the TVPA If the figures on
these three lines are totaled, they represent approximately 74 5 percent single-family and 25 5
percent multiple family As the target percentages aie excluded fiom the TVPA, line 5 is
excluded from the calculations As calculated, the proposed Project does not result in a change in
multiple family/single family percentage in the City as a whole Measure U only requires that the
City "plan foi a housing mix at buildout" of 75% single-family and 25% multi-family, for
purposes of this SEIR, the calculated 74 5/25 5 percent ratio is acceptable
The City can currently approve the maximum allowable density of 27-units to the acre (i e , the
total of 171 dwelling units), as permitted under the 2035 General Plan, by making a series of
findings and a 4/5ths vote of the Council Page 2-31 of the General Plan EIR states that the
numbers in Table 4 1 4 evaluated environmental impacts of the 2035 General Plan using the
density of 27-units per acre for properties within the TVPA The result of the proposed Project
would be to eliminate the super-majority requirement and potentially allow for moie than 400
residential building permits to be issued m a calendar year within the TVPA The maximum
potential buildout of 514 units from Table 4 1-3 of this SEIR, represents less than two years of
buildout under the 2035 General Plan The proposed Project has the potential of accelerating the
buildout of the 2035 General Plan by two years However, no significant cumulative impact is
anticipated, as the total unit yield is within the estimates evaluated in the 2035 General Plan EIR
and below the regional population estimates for the City The proposed Project's contribution to
land use, population and housing, is not considered cumulatively consideiable
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2. Transportation
Finding No New of More Cumulatively Considerable Impact (Diaft SEIR, pages 4 2-10 to 4 2-
12 )
While the proposed Project is limited to the TVPA, traffic may have impacts that extend outside
of the Project area As the pioposed Project does not increase any land designation or result in
the approval of any development, the analysis of the 2035 General Plan contained it the General
Plan EIR remains unchanged Future development requests that may follow the proposed Project
would likely be evaluated under both the LOS and VMT standards as the former remains in the
General Plan Cu culation Element and the latter is the new method for measuring transportation
impacts The City has latitude in considering compliance with the 2035 Geneial Plan
While not part of the pioposed Project, its approval may lead to projects that help realize the
vision of the 2035 General Plan as stated in Section 4 5 Transit Villages
These are intended as a foundation for realizing the goal of a connected,
accessible, and active community by creating pedestrian- and transit-oriented
villages that reflect each station area's existing assets and unique characteristics
Components of the strategy serve to improve connectivity between the
proposed Transit Villages and the city's existing neighborhoods, provide new
jobs, housing, and entertainment opportunities in compact, walkable
environments, support multiple modes of transit, car travel, walking, and
bicycling, and provide new development and infLll opportunities as alternatives
to building at the edges of the city
The General Plan EIR evaluated buildout of the TVPA within a 20-year horizon and as shown in
Table 4 2-2, Future (Yea; 2035) Plus Project Intersections, Roadway and Freeway Segments
Level of Service, on page 4 2-11 in Chaptei 4 2 of the Draft SEIR, determined that all
intersections, and roadway and freeway segments would operate at a LOS of C or better in 2035,
except foi freeway Segment #55, which would continue to operate at a LOS of E ii 2035
While the requirement for the maintenance of traffic levels of service "C" for all intersections
would no longer apply within the TVPA, as shown in Table 4 2-2, buildout of the 2035 General
Plan all nnteisections and roadways within the TVPA would operate at or better than LOS C
Additionally freeway segment # 54 would also operate at a LOS of C or better, and only freeway
segment #55 would continue to operate at a LOS of E The freeway system is not within the
City's jurisdiction and impacts on the freeway system are related to regional growth that would
occur regardless of the implementation of the 2035 General Plan The Geneial Plan EIR
determined that impacts to this portion of the freeway would be significant and unavoidable As
the proposed Project does not change land use or density of that would change the buildout
calculations of the 2035 Geneial Plan, the impact analysis summary contained on page 3 15-33
of the General Plan EIR remains unchanged Therefore, the proposed Project does not result in
cumulatively considerable impacts beyond those evaluated nn the General Plan EIR
3 Utilities and Service Systems
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Finding No New or More Cumulatively Considerable Impact (Draft SEIR, pages 4 3-15 to 4 3-
16 )
Cumulative impacts are limited to the TVPA, and all other measures of the 2035 General Plan
and growth management ordinance would continue to apply foi the remainder of the City
Implementation of future projects would require project-specific environmental analyses to
evaluate utility facilities, wastewater capacities, water supplies, and landfill capacities that would
serve the individual projects Table ES-2 on page ES-5 of the General Plan EIR shows that
cumulative current and future projects in the City would result in an increase of 4,355 dwelling
units The proposed Project represents approximately 4 percent of the total estimated units from
vacant High Density Residential land within the TVPA
The 2035 General Plan projected an increase in dwelling units and residents within the City and
the General Plan EIR determined that future growth would result in an increased demand for
utilities However, no significant impacts are anticipated, as the increase in the demand foi
utilities is within the estimates evaluated in the General Plan EIR Furthermore, as noted on page
3 14-18 of the General Plan EIR, compliance with federal, state, and local regulations, as well as
the 2035 General Plan policies and actions would ensure that potential environmental impacts of
individual projects would be reduced to less than significant
The proposed Project does not include development projects and would not result in an increase
or change in the overall buildout of land use assumptions analyzed in the General Plan EIR
Overall, no significant cumulative impact is anticipated, and the proposed Project's contribution
is not considered cumulatively considerable
SECTION 6 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES.
Section 15126 2(c) of the State CEQA Guidelines requires that an Envuomnental Impact Report
(EIR) describe any significant irreversible environmental changes that would be caused by the
proposed Project should it be implemented Specifically, the State CEQA Guidelmes state
Uses of nonrenewable resources during the initial and continued phases of the
protect may be irreversible since a laige commitment of such resources makes
removal or nonuse thereafter unlikely Primary impacts and particularly,
secondary impacts (such as highways improvement which provides access to a
previously inaccessible area) generally commit future generations to similar uses
Also. irreversible damage can result from envnonmental accidents associated with
the project Irretrievable commitments of resources should be evaluated to assure
that such current consumption is justified
The proposed Project would not result in significant and irreversible environmental
changes beyond what was identified in the General Plan EIR The proposed Project does not
result in the development of specific projects and all future projects in the TVPA would be
required to conduct a project-specific environmental analysis. Additionally, the proposed project
is consistent with the growth forecasts of the General Plan EIR
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SECTION 7 GROWTH-INDUCING IMPACTS
Pursuant to Sections 15126(d) and 15126 2(d) of the State CEQA Guidelines. this section
examines ways that the proposed Project would fostei economic or population growth or the
construction of additional housing, either directly or indirectly in the surrounding environment
Also requned is an assessment of othei projects that would fostei other activities that could
affect the environment, individually or cumulatively
Economic and Population Growth
As discussed in the General Plan EIR, the City of Redlands was estimated to have a population
of approximately 68 049 as of 2015. and the City's population would increase to 79,013 people
by 2035 In 2016, the City had 27 248 jobs which is projected to inci ease to 42,769 jobs in 2035
By buildout the City would have a total of 31,104 dwelling units. which is an increase of 4.355
dwelling units from the 2015 total riumbei of dwelling units (26,749 dwelling units) While the
proposed Protect would eliminate the requuement for a 4/5ths vote to allow a maximum of 27
units to the acre within the TVPA, the 2035 General Plan and the Geneial Plan EIR assumed the
maximum density in both planning and environmental analysis respectively. The proposed
Project does not change any land use a designation or zoning Thus the proposed Project would
not result in an increase in population growth beyond what was disclosed in the General Plan
EIR.
Removal of Obstacles to Growth
The 4/5ths vote requirement, building height restrictions, maintaming traffic levels of service
"C," prohibiting the creation of new land use designations, and 400-dwelling unit annual cap, aie
considered obstacles to realizing the 2035 General Plan vision for the TVPA Removing these
requirements within the TVPA would allow the City to consider future projects that are transit
oriented and have higher density than the 400-dwelling unit annual cap would allow It is
expected that future projects would request a Specific Plan or similar planning approval that
would require Planning Commission and City Council approval Future protects would also
undergo project-specific enviromnental analysis as required by CEQA While the proposed
Project will remove obstacles to growth (i e , the 4/5ths vote requirement, building height
restriction and 400-dwelling unit annual cap, the density and intensity of development that could
occur in the TVPA remains limited by the land use designations that apply to the properties
within that area The proposed Ballot Initiative does not change the land use designations for
any properties within the TVPA Therefore, the growth projections and cumulative impacts
analyzed and disclosed in the General Plan EIR would be the same with the proposed Protect.
No new impacts would occur in this regard
As the proposed Project does not result m construction or require extension of services, the
Project would not remove a physical obstacle to growth within or outside of the TVPA.
SECTION 8. ALTERNATIVES.
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A Background
The Diaft SEIR analyzed two alternatives to the Project as proposed and evaluated these
alternatives for their ability to avoid or reduce the Project's significant environmental effects
while also meeting the majority of the Project's objectives The City finds that it has considered
and rejected as infeasible the alternatives identified in the SEIR and described below This
section sets forth the potential alternatives to the Project analyzed in the SEIR and evaluates
them in light of the Project objectives, as required by CEQA
Where significant impacts are identified, section 15126 6 of the State CEQA Guidelines requires
EIRs to considei and discuss alternatives to the proposed actions Subsection (a) states
(a) An EIR shall describe a range of reasonable alternatives to the project, or to the location
of the project, which would feasibly attain most of the basic objectives of the project but
would avoid or substantially Iessen any of the significant effects of the project, and evaluate
the comparative merits of the alternatives An EIR need not considei every conceivable
alternative to a project Rather it must consider a reasonable range of potentially feasible
alternatives that will foster informed decision-making and public participation An EIR is
not i equired to consider alternatives which are infeasible The lead agency is responsible for
selecting a range of project alternatives for examination and must publicly disclose its
ieasonmg for selecting those alternatives There is no ironclad rule governing the nature or
scope of the alternatives to be discussed other than the rule of season
Subsection 15126 6(b) states the purpose of the alternatives analysis
(b) Because an EIR must identify ways to mitigate oi avoid the significant effects that a
project may have on the environment (Public Resouices Code Section 21002 1), the
discussion of alternatives shall focus on alternatives to the project or its location which are
capable of avoiding or substantially lessening any significant effects of the project, even if
these alternatives would impede to some degree the attainment of the project objectives, oi
would be more costly
In subsection 15126 6(c), the State CEQA Guidelines describe the selection process for a iange
of reasonable alternatives
(c) The range of potential alternatives to the proposed project shall include those that could
feasibly accomplish most of the basic objectives of the Project and could avoid or
substantially lessen one or more of the significant effects The EIR should briefly describe
the rationale for selecting the alternatives to be discussed The EIR should also identify any
alternatives that were considered by the lead agency but were rejected as infeasible during
the scoping process and briefly explain the reasons underlying the lead agency's
determination Additional information explaining the choice of alternatives may be included
in the administrative record Among the factors that may be used to eliminate alternatives
from detailed consideration in an EIR are (i) failui e to meet most of the basic project
objectives, (ii) infeasibility, or(in) inability to avoid significant environmental impacts
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The i ange of alternatives required is governed by a "rule of reason" that iequires the EIR to set
forth only those alternatives necessary to permit a reasoned choice The EIR shall include
sufficient information about each alternative to allow meaningful evaluation, analysis, and
comparison with the proposed Project Alternatives are limited to ones that would avoid or
substantially lessen any of the significant effects of the Project Of those alternatives, the EIR
need examine in detail only the ones that the lead agency determines could feasibly attain most
of the basic objectives of the Project
B Project Objectives
The following objectives have been established foi the Project (Draft SEIR, page 6-2)
1 Encourage higher density residential development in the TVPA, consistent with the
Transit Villages concepts identified in the 2035 General Plan foi areas within a one-half mile
radius of each rail transit station, to promote compact neighborhoods wheie people can live in
close proximity to transit, and retail, office and entertanunent uses
2 Promote sustainable urban growth by encouraging development within the core areas of
the City, where mfi astructure already exists, at increased densities that translate into more
efficient provision of municipal services, and that, by the virtue of close proximity of housing to
jobs and services, will reduce vehicle miles travelled
3 Promote transit ridership by allowing more residential development to be located within
walking and biking distances from ti ansit facilities
4 Promote enhanced sense of community by encouraging higher density development in
core areas of the City that can provide and promote public spaces for residents to use and
congi egate
5 Encourage housing near jobs and entertainment opportunities in walkable environments
C Alternatives Considered And Rejected During The Seeping/Project Planning
Process
Section 15126 6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify
alternatives that were considered by the lead agency but were eliminated from detailed
consideration because they were determmned to be infeasible during the scoping process, and (2)
briefly explain the reasons underlying the lead agency's detem nnation Among the factors that
may be used to eliminate alternatives from detailed consideration in an EIR are (i) failure to
meet most of the basic project objectives, (ir) mfeasibrhty, and/or (ni) inability to avoid
significant environmental impacts
The following is a discussion of the alternatives considered during the scopmg and planning
process and the reasons why they were not selected for detailed analysis in the SEIR
1 Alternative Development Areas
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CEQA requires that the discussion of alternatives focus on alternatives to the project or its
location that aie capable of avoiding or substantially lessening any significant effects of the
project The key question and first step in the analysis is whether any of the significant effects of
the project would be avoided or substantially lessened by putting the project in another location
Only locations that would avoid or substantially lessen any of the significant effects of the
project need be considered for inclusion in the EIR (CEQA Guidelines § 15126[5][B][1]) The
location of the TVPA is unique in that it is focused on maximizing access to the planned transit
stations As the transit stations have been planned for some time and will be constructed by San
Bernardino County Tiansit Authority (SBCTA) rather than the City of Redlands, moving the
transit stations was also rejected as infeasible No other location in the City would have a similar
orientation, therefore changing the location was not considered feasible (Draft SEIR, page 6-3 )
2 Existing Exemptions of Measure U and Measuie N/Proposition R
Dining the SEIR process, assertions were made that the proposed Project was unnecessary
because an exemption for transit-oriented projects already exists within the Measuies and
Proposition R Table 6-1, on page 6-3 in Chapter 6 of the Draft SEIR, shows all existing Measure
U exemptions and their applicability to the proposed Project
As shown in Table 6-1 of the Draft SEIR, the exemptions of Measure U would not meet the
project objectives because none of the exemptions are applicable to the proposed Project, except
for exemption 2, special categories, point 5, which is potentially applicable as new development
in the Downtown Specific Plan 45 is exempt from Measure U Therefore it was determined that
there aie no existing exemptions that could be used in lieu of the proposed Project
D Alternatives Selected for Analysis
The following alternatives were determined to represent a reasonable range of alternatives with
the potential to feasibly attain most of the basic objectives of the project but avoid or
substantially lessen any of the significant effects of the project
1 No Project/Existing General Plan Alternative
Description The No Project alternative is required to discuss the existing conditions at the time
the notice of pi eparation is published and evaluate what would reasonably be expected to occur
in the foreseeable future if the proposed Project is not approved (CEQA Guidelines, Section
15126 6(e)) Pursuant to CEQA, this alternative is also based on the existing 2035 General Plan
The No Project/Existing General Plan Alternative assumes that the proposed Project would not
be adopted, and the TVPA would not be exempt from Measures U and N, and Proposition R
From a practical standpoint, this alternative would not allow for more than 400 housing units to
be built citywide during any calendar year, establishes 18 units to the acre as the maximum
density without a 4/5ths vote, and keeps building height for multiple family residential to 35 feet
This alternative would assume that future development would occur consistent with the 2035
General Plan, and all growth management policies would remain in place Impacts from
development of the 2035 General Plan were evaluated in the General Plan EIR All policies and
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programs intended to address environmental impacts would be implemented with any future
development
Impacts Table 6-3, Connpai ison of No Pi oject Alternative to General Plan EIR and Pi oposed
Project, on page 6-6 in Chapter 6 of the Draft SEIR, shows the General Plan EIR environmental
determination for each of the environmental issue areas and compares the No Project alternative
as well as the proposed Project
As shown in Table 6-3, the environmental determination foi each of the issue areas remains the
same and will therefore not be discussed further in this Chapter The impact of the proposed
Project on the following environmental issue areas were evaluated in the SEIR and are included
below for comparison with the No Project Alternative
Land Use and Housing Unlike the proposed Project, the No Project/Existing General Plan
Alternative would not exempt the TVPA from Measures U and N, and Proposition R While this
alternative would result in development of the 2035 General Plan as adopted, it may be more
difficult to implement the vision foi the TVPA articulated in Chapter 4 5 Transit Villages of the
2035 General Plan, however the changes to voting iequuements and the City's ability to consider
future projects, do not rise to the level of environmental impacts
Similar to the proposed Project, the No Project alternative does not change the buildout
assumptions contained in the 2035 General Plan and evaluated m the General Plan EIR
Similarly, this alternative does not change any iegional plans based on the existing general plan
designations or population projections Unlike the proposed Project, this alternative does not
allow the City flexibility in the consideration of future housing types or allow a new general plan
designation that may have a larger range of densities This alternative may also make it more
difficult for developers to invest in development in the TVPA because of the uncertainty in
obtaining building permits in any given year
As neither the proposed Project nor the No Project alternative would result in land uses different
than those in the 2035 General Plan and evaluated in the General Plan EIR concluding a less than
significant impact, the impact of the No Project alternative would also be less than significant
Transportation As described in Section 4 2, Ti ansportatron, of the Draft SEIR, the requirement
for the maintenance of traffic levels of service "C" for all intersections would no longer apply
within the TVPA Although the No Project/Existing General Plan Alternative would require the
continued maintenance of traffic levels of service "C" for all intersections in the TVPA, the
intersections within the TVPA that would operate below LOS C would not result in significant
impacts if improvements are implemented Also, none of the roadway segments in the TVPA
would operate at a LOS of less than C in 2035 Segment#55 of I-10 would result in a LOS of
less than C m 2035, however, because the City of Redlands does not have jurisdiction over
freeways, impacts would be significant and unavoidable
The adoption of SB 743 in 2013, eliminated the use of LOS as a deterimmei for significant
environmental impacts associated with development The new method of evaluation emphasizes
a reduction in vehicle miles travelled and includes consideration of methods of transportation
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that do not require use of a personal automobile (e g tram, bus, bicycle, walking, ride share)
The transition to VMT will occur in June 2020, shortly after consideration of the proposed
Project by the voters As such, the environmental analysis of future development projects in the
City will include consideration of VMT, with a goal of reduction the number of miles travelled
One method of reducing miles tiavelled is to incorporate alternative transportation methods near
homes In this instance, the TVPA is uniquely suited to encourage development where residents
could make maximum use of transit theieby reducing VMT One effect of the transition to VMT
will be that a project that does not maintain LOS C, will no longer automatically trigger an
envnonrnental analysis If the 2035 General Plan policy remains intact, future projects might be
denied for inconsistency with the General Plan but would not necessarily trigger an EIR In this
regaid, both the No Project alternative and the pioposed Project impact to LOS standards in the
TVPA would be identical
The No Project alternative would maintain the existing policies and iequirernents foi
consideration of projects within the TVPA This alternative would not allow for greater
flexibility in the consideration of development near the transit stations or recognize different
transportation systems that can occur with a more comprehensive mixed-use design However,
like the proposed Project, this alternative does not change the density and intensity of
development, therefore impacts would be identical to those of the proposed Project and evaluated
in the General Plan EIR
Utilities and Service Systems The proposed Project and the No Project/Existing General Plan
Alternative do not propose specific development projects, however, the buildout of both would
result in an increased demand for water, wastewater treatment, stone drainage, solid waste
disposal, and other services Compared to the proposed Project, impacts to utilities and service
systems would be the same, impacts would be less than significant
Conclusion The No Project/Existing General Plan Alternative would result in similar nnpacts to
all the topical areas compared to the proposed Project, as the proposed Project would not result
in an increase or change to the oven all burldout land use assumption of growth of the 2035
General Plan As this alternative does not allow the City to consider a range of development
options near the proposed transit stations, and does not reflect changes in state law emphasizing a
reduction in vehicle miles travelled, the No Project alternative would result in greater impacts to
transportation than the pioposed Project
Attainment of Pioject Objectives As described in Table 6-5 on page 6-11 of the Draft SEIR, the
No Project/Existing General Plan Alternative fails to meet all of the Project objectives
Fmdmg The City Council rejects Alternative 1 No Project/Existing General Plan Alternative on
the following grounds, each of which individually provides sufficient justification for rejection
of this alternative (1) the alternative fails to meet all of the Project objectives, (2) the alternative
would result in greater impacts to transportation than the proposed project, and (3) the alternative
is infeasible
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2 Thiee-Yeai Unit Total Alternative
Desci iption Rathei than eliminate the 400-dwelling unit per year cap within the TVPA, this
alternative would
® Exempt the TVPA fiom Measure U, and,
• Amend Measure N and Proposition R to eliminate the annual 400-dwelling unit
cap citywide and replace it with a 1,200-unit citywide cap per every three-year
period, without rollover of unused dwelling units
Impacts Table 6-4, Compaw ison of Thi ee-Year Unit Total Altei native to Genei al Plan EIR and
Proposed Project, on page 6-8 of the Draft SEIR, compares the Three-Yeas Unit Total
Alternative to the General Plan EIR and the proposed Project
As shown in Table 6-4, the environmental determination for each of the issue areas remains the
same and will therefore not be discussed further in this Chapter The impact of the proposed
Project on the following environmental issue areas were evaluated in the SEIR and are included
below for comparison with the Three-Year Unit Total alternative
Land Use and Housing Unlike the proposed Project, the Three-Year Unit Total would require
that development in the TVPA compete with the remainder of the City for the 1,200 dwelling
unit allotment over each three-yeai period As shown in Table 4 1-2 of the Draft SEIR, the City
has not met or exceeded the 400-unit annual cap in the last 19 years and averaged 109 units
annually during the same period However, the pace and pressure for iesidential development has
significantly increased in the past couple of years as evidenced by the number of applications
pending with the City Since development thioughout the City would be included in the three-
yea' 1,200 dwelling unit calculation, this alternative has the potential to limit future development
outside of the TVPA if one or more piojects are entitled within the TVPA that equal the three-
year unit total Conversely, a laige development project outside of the TVPA could limit the
residential development potential within the TVPA as the total city-wide unit count would apply
The proposed Project would allow the City to approve development within the TVPA consistent
with the Transit Villages component of the 2035 Geneial Plan This alternative could allow more
development outside of the TVPA which could slow implementation of the Transit Village
component of the 2035 General Plan
As with the proposed Project this alternative would not increase the development potential as
established in the 2035 General Plan and analyzed in the General Plan EIR
Transportation As described in Section 4 2, Ti anspoi tation, of the Draft SEIR, the requirement
foi the maintenance of traffic levels of service "C" for all intersections would no longer apply
within the TVPA As this alternative would exempt the TVPA from the provisions of Measure
U, the impacts would be identical to those of the proposed Project as discussed in Section 4 02 of
this SEIR
The adoption of SB 743 in 2013, eliminated the use of LOS as a determiner for significant
environmental impacts associated with development The new method of evaluation emphasizes
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a reduction in vehicle miles travelled and includes consideration of methods of transportation
that do not require use of a personal automobile (e g train, bus, bicycle, walking, ride share)
The transition to VMT will occur in June 2020, shortly after consideration of the proposed
Project by the voters As such, the environmental analysis of future development projects in the
City will include consideration of VMT, with a goal of reduction the number of miles travelled
One method of reducing miles travelled is to incorporate alternative tiansportation methods near
homes In this instance, the TVPA is uniquely suited to encourage development where residents
could make maximum use of tiansit thereby reducing VMT One effect of the transition to VMT
will be that a project that does not maintain LOS C, will no longer automatically trigger an
environmental analysis In this regard, both the Three-Year Unit Total alternative and the
proposed Project impact to LOS standards in the TVPA would be identical
Unlike the proposed Project, this alternative could lead to the consideration of large residential
projects outside of the TVPA Projects outside of the TVPA would be furthei from the transit
stations and unlikely to realize the vision for the Transit Villages as expressed in the 2035
General Plan Like the proposed Project, this alternative does not change the density and
intensity of development, therefore impacts would be identical to those of the proposed Project
and evaluated in the General Plan EIR
Utilities and Service Systems No specified development projects are proposed under the
proposed Project or the Three-Year Unit Total However, buildout under both the proposed
Project and this alternative would result in a demand for water, wastewater tieatment storm
drainage, solid waste disposal, and other services as evaluated in the General Plan EIR
Compared to the proposed Project, impacts to utilities and service systems would be the same,
impacts would be less than significant
Conclusion The Tluee-Yeas Unit Total alternative would result in similar impacts to all the
topical areas coinpaied to the proposed Project and the General Plan EIR If the 1,200 dwelling
units are entitled over several projects outside of the TVPA, this alternative may discourage
development within the TVPA as there would be added risk foi developers and lenders in
pursuing projects that may have to wart several years to obtain residential allocations needed to
start construction Consequently, this alternative might restrict development within the TVPA
and thus fail to meet the Project objectives such as focusing on higher density neat the transit
stations and sustainable urban growth reducing vehicle miles travelled These issues do not affect
the environmental conclusions in the General Plan EIR, or in the Draft SEIR
Attainment of Project Objectives The Three-Year Unit Total alternative would only address the
dwelling unit issued over a three-yeas period and would leave the remanndei of the growth
management policies intact This alternative would address only the ability of a developer (or
several developers) to obtain a building permit for residential uses and does not address the other
policies that could hinder future designs Unlike the proposed Project this alternative could result
in large residential development outside of the TVPA and further away from the transit stations
As shown in Table 6-5 of the Draft SEIR, the Three-Year Unit Total alternative fails to meet two
of the Project objectives
Finding The City Council rejects Alternative 2 Three-Year Unit Total Alternative, on the
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following grounds, each of which individually provides sufficient justification foi rejection of
this alternative (I) the alternative fails to meet two of the five Project objectives, and (2) the
alternative fails to avoid or reduce any of the Project impacts
E ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Section 15126 6(e)(2) of the State CEQA Guidelines indicates that an analysis of alternatives to
a proposed Project shall identify an environmentally superior alternative among the alternatives
evaluated in an EIR Based on the alternatives analysis contained within the Diafl EIR, the
proposed Project is identified as the Environmentally Superior Alternative
SECTION 6. STATEMENT OF OVERRIDING CONSIDERATIONS
The Draft SEIR includes thiesholds of significance that are used to establish normally acceptable
standaids for project impacts in the City The proposed Project meets these standaids through the
implementation of federal, state, and local regulations, as well as the policies and actions of the
2035 General Plan When an impact is above the normally accepted tlueshold and cannot be
mitigated, the impact is identified as significant and unavoidable in the General Plan EIR, and
subsequently the Draft SEIR
Pursuant to State CEQA Guidelines Section 15093(a), the City Council must balance, as
applicable, the economic, legal, social, technological, or other benefits of the Project against its
unavoidable environmental risks in determining whether to approve the project If the specific
benefits of the project outweigh the unavoidable adverse environmental effects, those
environmental effects may be considered acceptable
A Significant and Unavoidable Impacts
There were no significant and unavoidable adverse impacts identified in the Draft SEIR, beyond
those identified in the General Plan EIR, that would result fiom implementation of the proposed
Project Significant and unavoidable adverse impacts identified in the General Plan EIR are listed
below
Agriculture and Forestry Resources 3 2-1 Buildout of the General Plan would convert Prime
Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps
prepared pursuant to the Farmland Mapping and Monitoring Progi am of the California
Resources Agency, to non-agricultui al use
Air Quality 3 2-2 Development under the General Plan would violate air quality standards or
contribute substantially to an existing or projected air quality violation 3 2-3 Development under
the General Plan would result in a cumulatively considerable net increase of any criteria
pollutant for which the 2035 Geneial Plan region is nonattamment under an applicable federal or
State ambient au quality standard (including releasing emissions which exceed quantitative
thresholds for 03 precursors)
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Tiansportation 3 15-1 Implementation of the General Plan could result in conflict with an
applicable plan, ordinance, or policy establishing measures of effectiveness of the circulation
system, taking unto account all modes of transportation including mass transit and non-motorized
travel and relevant components of the circulation system, including but not limited to
mteisections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit
Transportation 3 15-2 Adoption of the Geneial Plan would conflict with an applicable
congestion management program (CMP) including, but not hmited to level of service standards
and travel demand measures, or standards established by the county congestion management
agency for designated roads or highways
B. Project Benefits
The underlying purpose of the proposed Project is to remove existing voter-approved
development restrictions from within the TVPA, which development restrictions constrain
transit-oriented development within the City
Having reduced the adverse significant environmental effects of the Project to the extent feasible
by adopting the mitigation measur es, having considered the entire administrative record on the
project, the City Council has weighed the benefits of the Project against its unavoidable adverse
impacts after mitigation in regards to aesthetics resources, agriculture and forestry resources, air
quality — operations, and transportation/traffic While recognizing that the unavoidable adverse
impacts are significant under CEQA thresholds, the City Council nonetheless finds that the
unavoidable adverse impacts that will result from the Project are acceptable and outweighed by
specific social, economic and other benefits of the Project
In making this determination, the factors and public benefits specified below were considered
Any one of these reasons is sufficient to justify approval of the Project Thus, even if a court
were to conclude that not every reason is supported by substantial evidence, the City Council
would be able to stand by its determination that each individual reason is sufficient The
substantial evidence supporting the var rous benefits can be found in the preceding findings,
which are incorporated by reference into this section, and in the documents found in the Records
of Proceeding
The City Council therefore finds that for each of the significant impacts which are subject to a
finding under CEQA Section 21081(a)(3), that each of the following social, economic, and
environmental benefits of the Project, independent of the other benefits, outweigh the potential
significant unavoidable adverse impacts and render acceptable each and every one of these
unavoidable adverse environmental impacts
1 The Project encourages higher density residential development in the TVPA, consistent
with the Transit Villages concepts identified m the 2035 Geneial Plan for areas within a
one-half mile radius of each rail transit station, to promote compact neighborhoods where
people can live in close proximity to transit, and ietail, office and entertainment uses
2 The Project promotes sustainable urban growth by encouraging development within the
core areas of the City, where infrastructure already exists, at increased densities that
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translate into more efficient piovision of municipal services, and that, by the virtue of
close proximity of housing to jobs and services, will seduce vehicle miles travelled
3 The Project promotes tiansit ridership by allowing more residential development to be
located within walking and biking distances from tiansit facilities
4 The Project promotes enhanced sense of community by encouraging higher-density
development in core areas of the City that can provide and promote public spaces for
residents to use and congregate
5 The Project encourages housing near jobs and entertainment opportunities in walkable
env nonments
SECTION 7 CERTIFICATION OF THE SEIR
The City Council hereby finds that it has been presented with the SEIR m conjunction with the
General Plan EIR, which together nt has reviewed and considered, and further finds that the SEIR
is an accurate and objective statement that has been completed in full compliance with CEQA,
the State CEQA Guidelines and the City's Local CEQA Guidelines and that the SEIR reflects the
independent judgment and analysis of the City
The City declares that no evidence of new significant impacts or any new information of
"substantial importance" as defined by State CEQA Guidelines section 15088 5 been received by
the City after circulation of the Di aft SEIR that would require recirculation
Therefore, the City hereby certifies the SEIR based on the entirety of the record of proceedings,
including but not limited to the following findings and conclusions
A. Findings
The General Plan EIR identified that the following topics would result in significant and
unavoidable impacts
• Agriculture and Forestry Resources
• Air Quality
• Tn amp ortation
As identified m the Draft SEIR, the proposed Project would not exacerbate the impacts The
significant and unavoidable level of significance would continue under the proposed Project
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B Conclusions
All significant environmental impacts from the implementation of the proposed Project have
been identified in the General Plan EIR and, with implementation of the policies and goals of the
General Plan EIR, all impacts will be mitigated to a less than significant level, except for the
impacts listed m subsection A above
Other reasonable alternatives to the proposed Project have been considered and rejected m favor
of the proposed Project
Environmental, economic, social, legal and other considerations and benefits derived from the
development of the proposed Project override the significant and unavoidable impact of the
proposed Project identified above
SECTION 8 CUSTODIAN OF THE RECORD
The documents and other materials that constitute the administrative record for the City's actions
related to the project are at the City of Redlands, 35 Cajon Street, Suite 20, Redlands, California
92373 The City Development Services Department is the custodian of the administrative record
for the project Copies of these documents, which constitute the record of proceedings, are and
at all relevant tunes have been and will be available upon request at the offices of the
Development Services Department This information is provided in compliance with Public
Resources Code Section 21081 6(a)(2) and CEQA Guidelines Section 15091(e)
SECTION 9. NOTICE OF DETERMINATION
City staff shall cause a Notice of Determination to be filed and posted with the County of San
Bernardino Registrar-Recorder/County Clerk and the State Clearinghouse within five (5)
working days of the City's final approval of the Project
SECTION 10 EFFECTIVE DATE This Resolution shall take effect upon adoption
ADOPTED, SIGNED AND APPROVED this 5th day of November, 2019
W Foster, Mayor
ATTEST
rule Donaldson, City Clerk
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I\Resolutions\Res 8000 8099\8043 Ballot Initiative SEIR Findings Final doc
I, Jeanne Donaldson, City Clerk of the City of Redlands, do hereby certify that the foregoing
Resolution was duly adopted by the City Council at a regular meeting thereof held on the 5th day
of November, 2019, by the following vote
AYES Councilmembers Barich, Tejeda, Momberger, Davis, Mayor Foster
NOES None
ABSTAIN None
ABSENT None
6ae-e0A-7
J e Donaldson, City Clerk
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I\ResolutionslRes 8000-8099\8043 Ballot Initiative SEIR Findings Final doe
Exhibit "A"
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I\Resolutions\Res 8000 8099\8043 Ballot Initiative SEIR Findings Final doc
November 2019 I Final Subsequent Environmental Impact Report
State Clearinghouse No 2016081041
BALLOT INITIATIVE RE VOTER APPROVED
LAND USE INITIATIVES MEASURES U, N, AND
PROPOSITION R PROJECT
City of Redlands
Prepared for
City of Redlands
Brian Desatnik Director of Development Services
35 Cajon Street Suite 20
Redlands,California 92373
(909)798 7593
bdesatnik@cityofredlands org
Prepared by
Place Works
Contact Mark Teague, Associate Principal
3 MacArthur Place,Suite 1100
Santa Ana,California 92707
714 966 9220
info@placeworks corn
www placeworks corn
PLACEWORKS
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
Table of Contents
Section Page
1 INTRODUCTION 1 I
1 1 INTRODUCTION 1 1
12 FORMAT OF THE t LIR 1 1
1 3 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES 1 2
2. RESPONSE TO COMMENTS 2 1
3 REVISIONS TO THE DRAFT SEIR . . . 3-I
3 1 INTRODUCTION 3 I
3 2 DRAFT SEIR REVISIONS IN RESPONSE TO\XIET TEN COMMENTS 3 1
LIST OF TABLES
Table Page
Table 2 1 Draft SEIR Comment Summary 2-1
November 2019 Page r
in introduction
1.1 INTRODUCTION
This Final Subsequent Environmental Impact Report(Final SEIR) has been prepared un accordance with the
California Environmental Quality Act (CEQA) as amended (Public Resources Code 21000 et seq) and
CEQA Guidelines (California Code of Regulations 15000 et seq)
According to the CEQA Guidelines,Section 15132,the Final EIR shall consist of
(a) The Draft Environmental Impact Report(DEIR) or a revision of the Draft,
(b) Comments and recommendations received on the DEIR either verbatim or in summary,
(c) A list of persons,organizations, and public agencies comments on the DEIR,
(d) The responses of the Lead Agency to significant environmental points raised in the review
and consultation process,and
(e) Any other information added by the Lead Agency
This document contains responses to comments received on the Draft SEIR for the Ballot Initiative RE
Voter Approved Land Use Initiatives Measures U, N, and Proposition R Project during the public review
period, which began August 26, 2019 and closed October 9, 2019 This document has been prepared in
accordance with CEQA and the CEQA Guidelines and represents the independent judgment of the Lead
Agency This document and the circulated DEER comprise the FEIR,in accordance with CEQA Guidelines,
Section 15132
1.2 FORMAT OF THE FEIR
This document is organized as follows
Section 1,Introduction This section describes CEQA requirements and content of this Final SEIR
Section 2, Response to Comments This section provides a list of agencies and interested persons
commenting on the Draft SEIR, copies of comment letters recen\ed during the public re\iew period, and
individual responses to written comments To facilitate review of the responses, each comment letter has
been reproduced and assigned a number (A1 for letters received from agencies and organizations, and R1
through R6 for letters received from residents) Individual comments have been numbered for each letter and
the letter is followed by responses with references to the corresponding comment number
November 2019 Page 1 1
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
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1 Introduction
Section 3.Recisions to the Draft EIR This section contains revisions to the Draft SEIR text and figures as
a result of the comments received by agencies and interested persons as described in Section 2,and/or errors
and omissions discovered subsequent to release of the Draft SEIR for public review
The responses to comments contain material and revisions that will be added to the text of the Final SEIR
The City of Redlands staff has reviewed this material and determined that none of this material constitutes
the type of significant nevv information that requires recirculation of the Draft SEIR for further public
comment under CEQA Guidelines Section 15088 5 None of this new material indicates that the project will
result in a significant nevv, environmental impact not previously disclosed in the Draft SEIR Additionally,
none of this material indicates that there would be a substantial increase in the severity of a previously
identified environmental impact that will not be mitigated, or that there would be any of the other
circumstances requiring recirculation described in Section 15088 5
1.3 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES
CEQA Guidelines Section 15204 (a) outlines parameters for submitting comments, and reminds persons and
public agencies that the focus of review and comment of DEIRs should be "on the sufficiency of the
document in identifying and analyzing possible impacts on the environment and ways in which significant
effects of the project might be avoided or mitigated Comments are most helpful when they suggest
additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the
significant environmental effects At the same time, reviewers should be aware that the adequacy of an EIR is
determined in terms of what is reasonably feasible CEQA does not require a lead agency to conduct every
test or perform all research, study, and experimentation recommended or demanded by commenters When
responding to comments, lead agencies need only respond to significant environmental issues and do not
need to provide all information requested by reviewers,as long as a good faith effort at full disclosure is made
in the EIR"
CEQA Guidelines Section 15204(c) further advises, "Reviewers should explain the basis for their comments,
and should submit data or references offering facts, reasonable assumptions based on facts,or expert opinion
supported by facts in support of the comments Pursuant to Section 15064, an effect shall not be considered
significant in the absence of substantial evidence" Section 15204 (d) also states, "Each responsible agency
and trustee agency shall focus its comments on environmental information germane to that agency's statutory
responsibility" Section 15204 (e) states, "This section shall not be used to restrict the ability of reviewers to
comment on the general adequacy of a document or of the lead agency to reject comments not focused as
recommended by this section
In accordance with CEQA,Public Resources Code Section 21092 5, copies of the written responses to public
agencies will be forwarded to those agencies at least 10 days prior to certifying the environmental impact
report The responses will be forwarded with copies of this Final SEIR, as permitted by CEQA, and will
conform to the legal standards established for response to comments on EIRs
Page 1 2 Plac l orks
2. Response to Comments
Section 15088 of the CEQA Guidelines requires the Lead Agency (Cite of Redlands) to evaluate comments
on environmental issues received from public agencies and interested parties who reviewed the Draft SEIR
and prepare written responses
This section provides all sx-ntten responses received on the Draft SEZR and the City of Redlands' responses
to each comment
Comment letters and specific comments are given letters and numbers for reference purposes Where
sections of the Draft SEZR are excerpted in this document, the sections are shown indented Changes to the
Draft SEIR text are shown m underlined text for additions and stnkcout for deletions
The following is a list of agencies and persons that submitted comments on the Draft SEIR dunng the public
review period
Table 2 1 Draft SEIR Comment Summary
Number
Reference Commenting Person/Agency Date of Comment Page No
Agencies&Organizations
Governor's Office of Planning and Research,State Clearinghouse,Scott
Al Morgan,Director October 10,2019 2 3
Residents
RI Edward Ferrari October 7 2019 2 7
R2 Tracy Wise October 7,2019 2 11
R3 Carol Hudson October 8,2019 2 15
R4 Jo Lynn Lambert October 8 2019 2 19
R5 Jo Lynn Lambert October 9 2019 2 23
R6 Mitchell Tsai Law(on behalf of Southwest Carpenters) October 9,2019 2 33
November 2019 Page 2 1
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2 Response to Comments
LETTER Al —Governor's Office of Planning and Research, State Clearinghouse, Scott Morgan,Director
(I page)
} STATE OF CALIFORNIA * $
a Governor's Office of Planning and Research
State Clearinghouse and Planning Unit °{rrc$ "'
Gavin Newsom Kate Gordon
Governor Director
October 10,2019
Brian Desamik
Redlands City of
PO Box 3005 35 Cajon Stre•t,Suit!.20
Redlands CA 92373
Subject Ballot Initiative to Amend Measure U Measure NI and Proposition R.
SCUT! 2016081041
Dear BrianDesatnil,.
The State Clearinghouse submitted the above named SIR to selected state agencies for review The review
period closed on 10'9 2019,and no state agencies submitted comments by that date This letter
a-knowledges that you have complied with the State Clearinghouse review requirements for draft
environmental documents pursuant to the California Environmental Quality Act please visit
Al 1 https iceganel.opr.ca.gov201608104114 for frill d.tails about your project
Please call the State Clearinghouse at(916)445-0613 if you have any questions regarding the
environmental review process If you have a question shout the above-named proje t,please refer to the
ten-digit Stale Clearinghouse number when contacting this office
Sincerely
Scott Morgan
Dire..tor,State Clearinghouse
1400 TENTH STREET PO SOX 3044 SACRAMENTO CALIFORNIA 95812-304-1
TEL 1916-44541613 statvclratieebemcn;opr.ca.goy www.oprca,gev
November 2019 Page 2 3
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2 Response to Comments
Al Response to Comments from Governor's Office of Planning and Research, State
Clearinghouse, Scott Morgan,Director,dated October 10,2019
Al-1 The commenter indicates that the State Cleannghouse submitted the SEIR to selected
state agencies for review and received no comments from state agencies during the
review period The commenter states that the Protect complied with the State
Clearinghouse review requirements for draft environmental documents
The comment does not address the adequacy of the Draft SEIR as at pertains to CEQA,
therefore,no further response is necessary
November 2019 Page 2
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2 Response to Comments
LETTER R1 —Edward Ferrari (1 page)
From. E�xard revers
To, 9"f.Dxotn
Subject, Pubic Cnmrmet,Transit Yliage EIR
Date. Monday,Octaber 7,2019 9:00:42 PM
Dear Mr Desatnik,
I am writing in order to give my comment on the recently released Environmental Impact
Report for the Transit Village initiative
I wish to state that I am entirely satisfied with the report and feel that it gives provision to
Rt i the areas of greatest concern for Redlands residents, including increased congestion and
water conservation
As a resident who commutes by ebike,and who will likely access the Arrow station
downtown by ebike I am excited by the provision that the EIR gives to the role of increased
bike infrastructure in reducing the environmental impact of development
Yours sincerely,
Edward Ferrari
November 2019 Page 2 7
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2 Response to Comments
RI Response to Comments from Edward Ferrari,dated October 7, 2019
R1-1 The commenter is in support of the proposed project
The commenter does not address the adequac3 of the SEIR, therefore, the comment is
noted,and no further response is required
November 2019 Page 2 9
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2 Response to Comments
LETTER R2—Tracy C\sse (1 page)
From Tracy W
To: Finn
Subject: Support for Transit Villages
Date: Monday October 7 2019 8:38:23 PM
I am email€ng with€m support for the proposed changes to Redlands City measures&
propositions in order to make transit illages an option for Redlands moving forward
I appreciate what has been done in the past to protect Redlands from out-of control
development However the world has changed since then'aid we need to put Redlands on a
secure footing for the future based on today's realities This includes considerations such as
market demands ensuring a stable tax base in the future,and adapting to the changing
climate Multi use buildings which include housing shops and businesses are a way to bring
R2 t density.provide much needed housing stock,leverage the coning train and mcrease
walkahility The transit village at the center of downtown for example,will tackle the empty
Redlands Mall and bring greater vibrancy to the heart of our city
I know that we as citizens rill have a voice through the planning process to speak out
regarding building design to ensure that the height and architecture of these new buildings is
in sync with the city that we love
I am planning to yore YES in March and will encourage others to do so as well,should this be
placed on the ballot
Tracy Wise
Redlands 92374
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2 Response to Comments
R2 Response to Comments from Tracy Wise,dated October 7,2019
R2 1 The commenter is in support of the proposed project
The commenter does not address the adequacy of the SEIR, therefore, the comment is
noted, and no further response is required
Nopemher 2019 Page 2 13
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2. Response to Comments
LETTER R3—Carol Hudson (2 pages)
From Carol ti
To Arian i`.,camib
Subject CEQA comments on the Draft SEIR for the Ballot Inibahve
Data. Tuesday October 8 2019 3.14'49 Ph4
October 8 2019
Mr Brian Desatnik Development Services DireLtor
City of Redlands
Mr Desatnik
Regarding the city s proposal to adopt a resolution placing the Ballot Initiative on the ballot
for the March 2020 election A Draft Subsequent Environmental Impact Report("Draft
SEIR")was issued to analyze the impacts of the Ballot Initiative in anticipation of the
measure being passed by the voters
l lust recently learned that the Draft SEIR public comment period closes on Wednesday,
October 9 Everything else related to the transit villages and redevelopment of our
downtown has been widely publicized,but this closing date has not
The City of Redlands Transit Villages Specific Plan Website at redlandstransitvillages.org
makes the following promise
"Here you will find up to date information about the project including the schedule,
upcoming meeting dates,documents and resources,contact information,and w ays to
participate Please browse the website and join the conversation about the future of the
R3 1 three proposed transit villages(University of Redlands,Downtown Redlands,and Nett
York Street)planned along the soon to be built San Bernardino to Redlands Arrow
passenger rail line(scheduled to start service in 2021)
Check back often to find updates on the community outreach process,check progress on
the preparation of the Specific Plan access meeting materials and presentations and review
draft documents"
Despite the Crty's promise,there is nothing on that website or its resources pages that
indicates the status of the California Environmental Quality Act(CCQA)rev ieit for the
Draft SLIR or the public comment period expiring Wednesday In addition,several of the
links provided under the"Resources' tab only give the message"Page not found'when
they are clicked While the City may have followed the letter of the law for providing
notice to the community of the Draft SEIR and its public comment period,it did not follow
the spirit of it by failing to update this particular website that is touted as the place to find
out about the transit villages
i am requesting that the City provide notice of the CEQA process on the Cit} of
Redlands Transit Villages Specific Plan Website at redlandstransitvillages.org website
November 2019 Page 2 15
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R3 t and bs other media outlets and that the public comment period be extended for an
COC`!TD additional 30 days
5nncercly,
Carol Hudson
Redlands,t A 9237h
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2. Response to Comments
R3 Response to Comments from Carol Hudson,dated October 8,2019
R3-1 The commenter requests that the City provide notice of the CEQA process on the City
of Redlands Transit Villages Specific Plan website and other media outlets and that the
public comment period be extended for an additional 30 days
A copy of the SEIR for the Ballot Initiative was available at the City of Redlands City
Clerk Office Citt of Redlands Development Services Department, and the A.K Smiley
Public Library dunng the CEQA.-mandated 45 day public comment period (August 26
2019 through October 9, 2019) Additionally, the SEIR is available on the City's website
at https //wwwcityofredlands.org/post/environmental-documents The SEM was
posted to the website during the public review and comment period and has remained
av ailable there since
The Redlands Transit Villages Specific Plan is a separate and independent project from
the proposed Ballot Initiative project The Ballot Initiative will remove constraints that
prevent the City from approving land use plans,zone changes or individual development
projects in the TVPA that exceed certain density and scale thresholds The Ballot
Initiative does not include any proposed land use plans or zone changes At this point in
time,there have been a number or public workshops and presentations on concepts that
might lead to the preparation and possible adoption of a Transit Village Specific Plan
However, no draft plan has been prepared and details of the potential plan are in
concept stage subject to change The City Council's placement of the Ballot Initiative
on the ballot does not commit the City to a particular course of action on the Transit
Village Specific Plan (Rio I'ista Farm &real? Cii i' COMO' of Solano (1992) 5
Cal App 4th 351, 271) Similarly; the City Council's action on the Ballot Initiative is not
dependent upon the Transit Villages Specific Plan (Chrst and illwisiry i County of Sari
Diego 1993) 13 Cal App 4th 31,45)
The Transit Villages Specific Plan website is devoted exclusively to that project and its
rele\ant planning and environmental documents It would create confusion to include
the SEM for the Ballot Initiative on the Transit Villages Specific Plan project website
Thus,the City did not post the document there
Finally, while the project areas of the Ballot Initiative and the Transit Villages Specific
Plan overlap, the proposed Ballot Initiative project makes changes to voter approved
land use initiative Measures LI,N&Proposition R The Ballot Initiative project does not
approve any site-specific development As noted on page 1-9 of the Draft SEW, the
development potential within the proposed project area if the ballot initiative is
approved, is the same as the existing General Plan As the proposed project does not
include any development or specific plan that would allow for development, and the
impacts are identical to those evaluated in the existing General Plan EIR, no ex-tension
of public review time is necessary
November 2019 Page 2 17
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2 Response to Comments
LETTER R4—Jo Lynn Lambert(2 pages)
From'Jo Lynn Lambert
Sent Tuesday October 08 2019 5 35 PM
To Brian Desatnik<bdesatmk@cityofredlands org>
Subject Ballot Initiative CEOA comments
City of Redlands Development Services Dept
Attn Brian Desatnik Development Services Director
Dear Mr Desatnik,
I first learned of the CEQA review on this ballot initiative from an article in
the Redlands Daily Facts published last Friday October 4 There was no
notice of this environmental review on the City's Transit Villages Planning
website and like many interested persons I did not know about it until
reading the newspaper article Other interested persons may not
subscribe to the Daily Facts and don t yet know about the public review
process
R4 t
Since reading the article, I have spent several hours reviewing the
environmental documents I have been a CEQA attorney for over 20
years, and yet I am having trouble digesting all of the information I would
imagine that people without my background in CEQA would have even
more difficulty reviewing these documents This is a very important issue
for the residents of the City of Redlands,and I don't think the
environmental review should be rushed I think this issue—and this
November 2019 Wage 2 19
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
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2 Response to Comments
process—deserve better notice to interested parties and a longer time to
understand the lengthy and complicated environmental documents(which
include the 2035 General Plan ElR as well as the Draft SEIR)
I am requesting that the public comment period be extended at least one
R41 month after the City provides broader notice of the opportunity to
CONPD comment At a minimum notice of the environmental review process and
the public comment period should be posted on the Transit Villages
Specific Plan Website, as this review relates directly to a ballot measure
that will impact the Transit Villages Planning Area
Thank you for your consideration of this request
Jo Lynn Lambert
Lambert Law
1111111111111111111111111
Redlands, CA 92373
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2 Response to Comments
R4 Response to Comments from Jo Lynn Lambert,dated October 8,2019
R4-1 The commenter requests that the public comment period be extended at least one
month after the City pros ides broader notice of the opportunity to comment, and states
that the notice of the environmental review and public comment period should be
posted on the Transit Villages Specific Plan website,at a minimum
According to State CEQA Guidelines, section 15105(a),the City circulated the SEIR for
public review for 45 da)s from August 26, 2019 through October 9, 2019 \ 30-day
extension of that time period is not warranted First,the 30 day extension would exceed
the maximum review period recommended in the State CEQA Guidelines (State
CEQA Guidelines, g 15105(a)) Second, the 45-day time period afforded many
interested parties sufficient time to re\iew the SEIR document which was of reasonable
length Third, any interested parties who wish to comment on the SEIR or the Ballot
Initiative project are free to submit comments on the environmental document and
project up until the time of the public hearing on this item Therefore, the public has
been afforded ample opportunity to review the relevant documents and an extension of
the time period is unwarranted
With regard to the conunenter's suggestion that the SEIR be listed on the Transit
Villages Specific Plan website,please see response to comment R3-1,above
November 2019 Page 2 21
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LETTER R5—Jo Lynn Lambert(3 pages)
From' Rnan riamik
To Its'I
Cc Pan iicHuah.Alicha 11.WEnt.ts'M, ;I:ran Fnatt
Subject. Fwd Comments on Ballot initiative Regarding Voter Approved Land Use Initiative; Measures U ti and
Proposition R
Date' Wednesday October 9 2019 5.41:08 P11
Begin forwarded message
From.Jo Lynn Lambert
Date.October 9 2019 at 5 34 17 PM PDT
To `hdLsmuhnLro1citvorr..rdlands.org"< dwsalml.Cr;C1I��r�fr dlalixls,<1r�>
Subject Comments on Ballot Initiative Regarding Voter Approved Land Use
Initiatives-Measures Ti,N and Proposition R
Dear Mr Desatnik
Since I don't knout whether my request for an extended comment period will be
granted I am submitting these questions on the Draft SEIR I support the concept of
the transit villages close to the railroad stations and think they will be a great addition
to the City of Redlands Since the proposed Ballot Initiative is a broad stroke that
would remove planning and zoning limitations over a large part of urban Redlands
including the entire downtown area I hope the City will proceed slowly thoughtfully
and with full transparency in deciding to approve putting this initiative on the ballot
To that end,the Subsequent Environmental Impact Report(SEIR)needs to be a clear
R5 1 comprehensive and accurate public information document Given its complexity I am
hopeful that additional time will be allowed for public review
These are some of the questions that I'm struggling with concerning the Draft SEIR
Project Description Section 2 1 1
In the bullet points summarizing what the proposed ballot measure would permit,why
is removal of the height limitation of 2 stories or 35 feet missing? It seems like that is
one of the most important points to relay to the public "Budding heights' is listed as
the number one area of controversy in Section 1 4
Are past building permits under Measure U's restrictions a good predictor of future
RS 2 annual residential units without it? (Draft SEIR at 4 1 16)
is it true that with approval of the Ballot Initiative any vacant areas in the TVPA
currently zoned High Density Residential(NOR)would not need any further
RS 3 discretionary decision from the Planning Commission or City Council to build a project
with 27 dwelling units/acre in 4 stories(if current zoning is in place) and would not
November 2019 Pabe 2 23
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2 Response to Comments
require environmental review under the California Environmental Quality Act(CEQA)?
R5 3 (See page 4 14) Am I understanding this correctly? The applicant would need site plan
CONT'D review,but that merely checks for compliance with standards and does not include
public review or approval by the Planning Commission or the City Council right?
The Draft SEER seems to use only the figure of 19 3 acres of vacant land currently zoned
HDR,without any other residential development included when it calculates the
difference in maximum buildout between the 2035 General Plan and the Ballot
Initiative (Draft SEIR at 4 1 16.) Is that correct? Based on this it shows a difference of
only 171 additional multiple-family residential DU more than assessed in the GP EIR
which is used several places to find less than significant impacts But didn t the GP
R5-4 Methodology estimate$0%buildout(see page 4 1 16)so that the difference in what
was analyzed is actually 514? Why wasn't that figure used? The figure of 19 3 acres of
new HDR is used in the Draft SEIR to assess the environmental impacts of approval of
the Ballot Initiative(see Draft SEIR at4 1 4)leads to the repeated conclusion that the
proposed project(the Initiative)does not result in additional dwelling units beyond
the bu ildout assumptions[in the GP EIR] and 'does not alter the maximum buildout
potential for properties within the TVPA (5ee as a few examples,Draft SEIR at 3 4„
417,533)
Isn t it also true that the proposed designations for the Transit Villages Specific Plan(TV
specific plan)calls for considerably more than 19 3 acres of vacant or underused land
to be newly designated as High or Medium Density Residential with building heights
RE 5 allowed up to 5 stories throughout much of the TVPA? If a proposal is on the Transit
Villages website and being considered by the City Planning Dit is ion and thus
reasonably foreseeable why isn t that covered in i.he assu mptions and build out
projections in the Draft SEIR?
Once the TV specific plan is adopted,the 2035 General Plan requires that the zoning
ordinance be revised to conform to the specific plan (See,e g,General Plan Draft EIR
(as finalized and certiried)(GP EIR)at p 3 10 13) Doesn tthis mean that relying on the
RS 6 current zoning to reduce impacts to less than significant is misplaced? (See e.g 4 1
6) Isn t the Draft SEIR understating the development potential that will occur in the
TVPA if the Ballot Initiative and then the TV specific plan are both approved?
Further,if(a)the TV specific plan is approved with these new classifications of more
High Density and Medium Density Residential(up to 5 stories tall 27 Dwelling Units
(DU)per acre) (b)the zoning ordinance is revised to match as required by the 2035
General Plan and(c)the Ballot Initiative is adopted—in whatever order—then
wouldn t that mean that any proposals within these areas that are vacant could also be
RS 7built without further discretionary review by the City Planning Commission or City
Council and without public participation through the CEQA process? And the same for
similar proposals on underused or other land that do not require a discretionary
demolition or other discretionary permit? And wouldn t this create greater impacts
than stated in the Draft SEIR? The 2035 Genera!Plan indicates that the TVPA would
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R5 7 have 71 29 acres of vacant land available for new development in adchtfon to
CON D redevelopment of existing developed parcels {Section 3 2)
Ocean tthis in turn indicate that the analyses for such impacts as Aesthetics,Noise
R5 8 Transportation{including parking),Land Use and Historic Resources—to name a few—
do not fully assess the impacts?
Theoretically{in other words assuming feasibility) what would be the tallest building
that could be built in a mixed use project having both commercial and High Density
R5 9 Residential components? It would be helpful to I now the answer to this question
under both the existing zoning and the latest proposal for the Transit Villages Specific
Plan
At page 4 1 7 Impact 4 1 2 why Ian t the latest language in the CEOA Guidelines used?
And why is the issue of whether the Ballot Initiative would conflict with 2035 General
i15 10 Plan policies not addressed? How is Action 5 A 73(p 3 14)to be implemented with
the exemptions proposed under the Ballot Initiative?
Overall,I am struggling to understand the interplay between the 2035 General Plan
the Transit Villages Specific Plan and the Ballot Initiative And perhaps the zoning
R5 11 ordinance It seems that they are interdependent and need to be studied that way
At any rate thank you for responding to my questions I trust that we can continue to
sort out these issues in a positive and productive way And 1 hope that the City will
allow time enough to do so
Thanks again
Jo Lynn Lambert
Lambert Law
1111111111.1111.111.1111111111111
Redlands CA 92373
November 2019 Page 2 25
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R5 Response to Comments from Jo Lynn Lambert,dated October 9,2019
R5 1 The commenter asks why the removal of the building height limitation of 2 stones or
35 feet is missing
The discussion of changes to building heights that would be allowed by the proposed
project begins on page 41-6 of the Draft SEIR The SEIR concludes that section
18 60 120 of the City of Redlands Municipal Code would restrict residential
development to a height of 4-stones, in the R-3, Multiple Family Residential, zone
Commercial buildings in the C-3, General Commercial, zone have no height limit except
within the Downtown Specific Plan (SP45) where heights are limited to 55-feet,
according to Section 18 92 130 of the City of Redlands Municipal Code
The Draft SEIR is amended in Section 3 0 Errata of this document, to include the
removal of the building height limitation in the list of development restrictions that
would be remo\ed by the Ballot Initiat€%e if approved by the voters
R5-2 The commenter asks if the past building permits under Measure U's restrictions are a
good predictor of future annual residential units without the restrictions
No, past building permit issuance is not a good predictor of future annual residential
development The State of California has declared there to be a statewide housing
shortage and has adopted policies aimed at encouraging greater housing production
throughout the State Home prices and rental rates are driving housing production
regionally, and employment growth in the Inland Empire has created increased demand
for housing locally, especially as commuting long distances becomes more and more
difficult
Table 41 2 on page 41-14 of the Draft SEIR shows the population and housing unit
growth between 2000 and 2019 As shown in die Table,at no time did the housing units
requested approach the current unit cap The proposed project does not include any
de\elopment proposal, but would remove the annual housing unit cap As explained on
page 7-2 of the Draft SEIR, any future development proposals would require both
Planning Commission and City Council approval All future projects will be
discretionary, and therefore subject to project-specific environmental analysis However,
without future discretionary action, the proposed project would not allow development
beyond what was projected in the General Plan EIR The existing limitations on housing
units do not affect the development of non-residential land uses that would typically be
responsible for population growth and housing demand
\-5,Tlhile the statewide and local demand for housing has increased, the City's potential to
build new homes is governed by die land use element of the General Plan As noted
throughout the Draft SEIR, the proposed project does not increase densrt\, or approve
any new project While building permits could be issued at more than 400 units per year
November 2019 Page 2 27
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
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2 Response to Comments
within the T\T , the maximum housing unit N ield is limited to the units shown in Table
41-4 of the Draft SEIR Therefore, the City may reach theoretical buildout faster than
originall} discussed in the General Plan EIR, but ma3 not exceed the total unit yield
without amending the General Plan
R5-3 The commenter asks if it is true that i acaiht areas in the TVPA currently zoned High-
Density Residential (HDR) would not need any further discretionary decision from the
Planning Commission or City Council to build a project with 27 dwelling units/acre in
four stones and would not require environmental review under CEQA,with approval of
the Ballot Initiative
No Refer to pages 41-14 through 41-15 of the Draft SEW Discretionary approval
would still be required, holm er, approvals can be done with a simple majority not a
4/5ths vote Commercial and multi-family residential buildings would require
discretionary design approval by the Planning Commission Some future projects, such
as the redevelopment of the Mall site,would require a tract map which requires Planning
Commission review and City Council approval as well CEQ& review would also be
required for future projects
R5 4 The commenter states that the Draft SEIR only references 19 3 acres of vacant land
currently zoned MDR, when it calculates the difference in maximum buildout between
the 2035 General Plan and the proposed project wlh€ch shows a difference of only 171
additional multiple-family residential units more than the General Plan EIR The
commenter states that the General Plan methodology used an 80 percent buildout, and
states that the difference would be 514 units The commenter asks why 514 units was
not used
The Draft SEIR focuses on the 171 dwelling units as the difference between the current
limitation and the maximum general plan allowed de%elopment The methodology for
the numbers difference in housing units is discussed below Table 41-3 on Page 41-16
of die Draft SEIR The existing yield at 18-units to the acre would result in 353 dwelling
units, if the proposed project is approved, the resulting yield would be 514 dwelling
units The difference is 171 dwelling units As noted in the methodology, the 514
dwelling units is below the 924 dwelling units estimated in the General Plan EIR
R5 5 The commenter states that the proposed designations of the Transit Villages Specific
Plan call for considerably more than 19 3 acres of vacant land or underused land to be
newly-designated as High or Medium-Density Residential with building heights of up
to five stones allowed throughout most of the TVPA The commenter asks why this is
not covered in the assumptions and build-out projections in the Draft SEW if a
proposal is on the Transit Villages Specific Plan website
The proposed project is independent of any specific plan and can be acted upon and
implemented without a specific plan As evaluated, the removal of the unit cap would
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2 Response to Comments
enable the TVPA to be developed to the macim un general plan density evaluated in the
General Plan EIR To build beyond the existing General Plan would require a general
plan amendment, public hearings, and a project-specific environmental analysis Future
projects Ina) benefit from the proposed project or may be consistent with the existing
General Plan
R5-6 The commenter states that relying on the current zoning to reduce impacts understates
the development potential that would occur in the TVPA, as the 2035 General Plan
requires that the zoning ordinance be revised to conform to the Transit'Villages Specific
Plan,if approved
The Ballot Initiat11.e and the Transit Villages Specific Plan are two separate pl'uuhing
efforts The two have separate and independent utility,the one does not depend on the
other If the Ballot Initiative is approved the Cm Council could take any number of
subsequent zoning actions with the TVPA It could also amend die general plan in that
area, if it so chooses The proposed project does not change the existing zoning. If a
future project proposes changes to general plan designations and/or zone districts, then
the environmental analysis for that proposal must include an evaluation of
environmental impacts associated with that change At this time any future zoning
changes would be too speculative to evaluate, and there is no certainty that one or more
specific phis would be considered by the City; or that zoning would change As the
proposed project makes no changes to either general plan designation or zoning, the
Draft SEIR used the existing zoning to calculate development potential that could occur
as a result of die proposed project
R5 7 The commenter states that if a) the Transit Village Specific Plan is approved with new
classifications of more High- and Medium-Density Residential,b) the zoning ordinance
is revised to match as required by the 2035 General Plan, and c) the proposed project is
adopted, then proposals within these vacant areas could be built without further
discretionary review by the Planning Commission or City Council and without the
public participation through CEQA The commenter states that this would also apply to
similar proposal on underused or other land that do not require a discretionary permit,
and as such,this would create greater impacts than stated in the Draft SEIR
See response to comment R5-3 regarding discretionary review Additionally, see
response to comment R5 6 The proposed project does not include any development
proposal
Moreover, the Transit Village Specific Plan is subject to its own CEQA process As
explained above in Response R3-1, the Ballot Initiative and die Transit Village Specific
Plan are two separate projects,each subject to their own EIR processes
November 2019 Page 2 29
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2. Response to Comments
R5-8 The commenter states that this would, in turn, indicate that the analyses for impacts
such as Aesthetics, Noise, Transportation, Land Use, Histonc Resources, and so forth,
do not fully assess the impacts
See response to comment R5-7 The proposed project does not result in the ability to
build beyond the current General Plan density and intensity evaluated in the General
Plan EIR Am impacts associated with any potential development allowed under the
Transit Village Specific Plan is ex aluated in the Transit Village Specific Plan EIR
R5 9 The commenter asks, theoretically; what the tallest building that could be built in a
mixed-use project having both commercial and High-Density Residential would be
Linder existing zoning height is controlled by the zone district, not by the use of the
building As the residential zone districts do not allow mixed use, any mixed-use
budding with residential would have to be in a commercial zone distract, and would
therefore be subject to height limits of commercial zone The most likely zone district is
the C 3 zone which has no height limit but has a maximum Floor Area Ratio (FAR) of
4 0 Therefore,it is not possible to know the height of a mixed-use project as the answer
depends on design of the building and setbacks It is mathematically possible to have 6-
8 stories but more likely to be 4 to 5 once parking and access is factored into the design
The proposed project makes no change to the zone distract in regard to mixed use, so
the existing zoning continues to apply
See also response to comment R5-1
R5 10 The commenter refers to Impact 41-2,on page 41 7 of the Draft SEIR, and asks why,
the latest language in the CEQA Guidelines is not used The commenter also asks why
the issue of whether the proposed project would conflict with the 2035 General Plan
policies is not addressed The commenter asks how Action 5 A 73,on page 3-14 of the
Draft SEIR, would be implemented with the exemptions proposed under the proposed
project
Impact 41-2 on page 41-7 uses a slightly shortened phrasing of the latest language in
the CEQA Guidelines in order to simplify the impact question The proposed project
would not conflict with any of the policies of the 2035 General Plan The policies that
pertain to Measure U would no longer be applicable to the TV PA but would continue to
be applicable to the rest of the General Plan area
In regard to Action 5 A 73, that addresses the provision of parking in the Downtown,
the proposed project does not make any changes to existing development standards,
therefore the current policies and requirements for parking continue to apply
R5 11 The commenter indicates that she is struggling to comprehend the relationship between
the 2035 General Plan, the Transit Villages Specific Plan, and the proposed project, as
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CITY OF REDLANDS
2, Response to Comments
well as the zoning ordinance, and states that the) may be interdependent and need to be
studied in that way
The Cit3 of Redlands General Plan was adopted on December S, 2017 The General
Plan includes the growth management policies included in Measures U, N, and
Proposition R The City's zoning ordinance implements the policies from the General
Plan and establishes development standards for the entire City
The proposed project would relieve the TVPA from the growth management provisions
of the General Plan (including Measures U, N, and Proposition R), but would not
change any of the existing zoning The growth management policies included in
Measures U,N,and Proposition R would continue to apply to the remainder of the City
The Transit Villages Specific Plan would amend both the General Plan and zoning for
the area within the Specific Plan If the proposed project is approved, then the Transit
Villages Specific Plan could benefit from the growth management relief However,if the
proposed project is not approved, the Transit Villages Specific Plan would need to
comply with the existing General Plan,including the growth management policies
It is also important to note that there is already an existing Downtown Specific Plan (SP
45) within the TVPA, and that nothing in either the proposed project or the existing
General Plan would preclude future Specific Plans from being proposed with or without
the proposed project See response to comment R3 1
November 2019 Page 2 31
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LETTER R6—Mitchell Tsai Law(on behalf of Southwest Carpenters) (5 pages)
P (626a 381-92.18 1'ri Knuth LI Slohno 1venue
> (626;389-541 I Mitchell M Tsai butte 104
1 inrtch(ajrnitchtsailace com Nuereei 1t 1.an Paeaderia C ahtornia 91 10I
VIA HAND DELIVER),,G.S.MAIL&E MAIL
October 9 21119
Attu Brian IDesatml.
Development Services Director
Cite of Redlands Development:crrices l:)cpt
35 Cajon Street,Suite 20
Redlands C 1 92373
Fm bdcstaiiiL(0 ilvofredlands.urg
RE Drift Suhsrgilent F;nvironmental Impact Report for li;tllrt Tomato e Recording
1 titer.Appn and 1.and I.se!natant es Rfe.asiires L.A,and Premposmon R.it.1 I.An.
2016081041
Deal \ir l)esauult,
On bchalt ofiouthwcst Regional Council ,t Carpenters(Collective)) "Commenters or
'Southwest Carpenters") m}Ottace is submitting these..o-nments on the City et Redlands
("City"or 'Lead Agency";Drift Subccyuent Environmental Impact Report;`DSEIR",(SC FI\o
201 6081 04 1)For the Ballot initiative Itetrardrni;4 oter Approved 1 inn Use lnitianves Measures L \
and Proposition R("Project")
fh..Southwest(arpenters is,i l,'hor union rcpresennng 3()(10(1 union c.irpenter,in so,snares
Including in vouthcrn C alitornaa and has a strong interest in well ordered l,iwid use planning Ind
iddressing the cinironmcntd impacts of development projects Commenters expressly reserve the
right to supplement These comments at or prior to hearings on the Project and at arl) later hearings
and proceeding,related to this Project C al Goy Code 65009(b),C al Pub Res C ode 21177(a)
R6 1 Bavrnre/d CIc sis{or 7.as.d Choler, r T3,rt r/haii(2004) 124 Cal App Ith 1184 1199 1203,see C,rlarte
I tee,arrla r llodeery atrr D.st (1997)60 C.al 1pp 4th 1109,1121
Commenter;rncorporrte by retereiut ill comments raising issues regarding,the I AR submitted prior
to ce'-atie.m-n of the Lilt for the Protect C'/e'rrs jar Gl ens I s'ojt r Crr af'l!'oadlaml(21)14)225
C 1-Ith 173 191(fimhng that ear party ra ho has olateetcd to the Protect,envirmmenral
doctnnentanor may assert ins issue tirneh raved l.it other parties)
Moreover,Commenters request that the Lea] Agency-provide nonce for any- and ill notices
referring or related to the Pro)ecr issued under the California Ens ironnaenral Quality Act
("CEQA"),C al PublLe Resources C ode t"PRC")s 21000 el si'a and the C ahfornra Planning and
Gnnini,I an ("Planning and Zoning Lass ),Cal Gov't Code s 6n0C10-65010 California Public
Resources C ode Sections 21092.2,and 21167(f)-ind Grp,eminent C ode Section 65092 require
igencies 10 mad such nonccs so im per,on cello has tiled a written request for them sc nth tin clerk
of the agency S goy erning bode
November 2019 Page 2 33
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N, & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
2 Response to Comments
of Redlands-Ballot Initiative to amend Measures U 2&Proposition R
October 1 2019
Page 2 of 5
I APPROVAL OF THE PROJECT WOULD VIOLATE THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT
' Protect Description and Bacl.ground
The Ballot Initiative Regarding Voter-Approved Land Use Initiatives Measures U iI and
Proposition R("Project")is being prepared to remove a set of constraints on development from
future del elopment projects that would be located near three transit stations in Redlands within a
Transit Village Planning Area(`TVPA'') The TVPA is d&fined as"an approximately 782 acre area
that is roughly described as the land within a one half mile radius from any of the three planned rail
transit stations within the City of Redlands (DSEIR,p 1 1)It is located at the confluence of
Interstate 10 (I 10)and Interstate 210(1210) The Project would specifically remove constraints
including
• A 4/5ths vote requirement for residential buildings exceeding two stories or o5 feet in
height and a l;5ths vote requirement for residential density greater then 18 dwelling units
per acre not to exceed 27 units per acre
• 4 requirement for the maintenance of traffic levels of service"C"for all intersections
• A prohibition against the creation of new land use designations,and the requirement of a
socioeconomic study for development projects,currently imposed b1 Measure U,and,
• 4 400 dwelling unit annual cap that applies to residential development citywide currently
R6 2 imposed by Measure N and Proposition R.
(DSEIR,p 1 1) The DSEIR states that the Project does not authorize or permit any specific
development projects at this time (DSDIR Appendix I p 1 0)
The T\,PA is currently identified as an urban in61l site that is surrounded by development on all
sides 1 he 7'82 acre site includes 280 52 acres of commercial and services development; 109 82 acres
of multi family residential,78.59 acres of single family residential,44 446 acres of schools,27 95 acres
of open space and recreational development;40 80 acres of industrial sites,and 71 29 acres of vacant
parcels (DSEIR p 3 1—3 2.)The DSEIR states that the Project"is a planning level action and it
does not approve any specific dec elopment project' at this time (DSEIR,p 2 3)However among
its overall goals is to
[e]ncourage higher density residential development in the TVPA consistent with the Transit
Villages concepts identified in the 2035 General Plan for areas within a one hail mile radius
of each rail transit station,to promote compact neighborhoods where people can live in
close proximitt to transit,and retail,office,and entertainment uses
(DSEIR p 2 2—2 3)
4s discussed below.the project raises concerns related to regional housing needs and transit-
oriented development that must be addressed prior to its approval in order to compl3 with the
requirements of CEQA
Pride 2 34 Placiil,.orks
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
2 Response to Comments
City of Redlands--Ballot Initiative to amend Measures U,\&Proposition P.
October 3 2019
Page 3 of 5
13 Background Concerning the California Environmental Quality Act
The California Ent ironmental Qualm Act(CEQA)has two basic purposes First,CEQA is
designed to inform decision makers and the public about the potential,significant environmental
effects of a project 14 California Code of Regulations("CCR or CEQA Guidelines')
15002(a)(1) 'Its purpose is to inform the public and its responsible officials of the environmental
consequences of their decisions h fore then are made Thus,the EIR`protects not onh the
ene ironment but also informed self got ernment' [Citation]" (Crhrens of Goleta I'allro r.Boarr!of
Srper7'Isorr(1990)o2 Cal 3d 553 564.)The EIR has been described as an ens ironmental alarm bell
whose purpose it is to alert the public and its responsible officials to environmental changes before
they have reached ecological points of no return'' (Berkelffy Keep Jets Over the Bay r Bd of Pad Comm'is
(2001)91 Cal App 4th 1344 1354("Berkelep'Jets");Connb oflnyo z ]or y(1973)32 Cal.4pp.3d 795,
810.)
Second,CEQA directs public agencies to avoid or reduce ens-ironmental damage when possible by
requiring alternatives or mitigation measures (CEQA Guidelines§ 15002(a)(2)and(3),see also
Berkelp'Jets,91 Cal App 4th 1344, 1354,Cztz`ens of Goleta Valle) s Booed of Saperessors(1990)52
Ca1.3d 550,Limn!Flggbts Improvement Ass'n zt Resents of theV1171Mzti ofCalfonna(1988)47 Cal.od 376
400)The EIR serves to pros.ide public agencies and the public in general with information about
the effect that a proposed protect is likely to hate on the environment and to identify ways that
Ro`2 environmental damage can be avoided or significantly reduced''(CEQA Guidelines 5 15002(a)(2).)
If the project has a significant effect on the environment,the agency may approve the project only
COtSf Q upon finding that it has"eliminated or substantiall} lessened all significant effects on the
environment to here feasible"and that am unavoidable significant effects on the cot ironment are
acceptable due to overriding concerns' specified in CEQA section 21081 (CEQA Guidelines S
15092(b)(2)(9—B))
While the courts retie' an EIR using an"abuse of discretion"standard,"the to iewing court is not
to`uncritically rely on every studs or analysis presented by a protect proponent in support of its
position'A`clearly inadequate or unsupported study is entitled to no judicial deference"'(Berkeley
jets,sepia 91 Cal.App 4th 1144,1355 [emphasis added,quoting Laurel Ni'igbts 47 Ca1.3d at 391,409
fn 12] Drawing this line and determining whether the EIR complies with CEQA's information
disclosure requirements presents a question of la% subject to independent review by the courts
(Szertrr Club z Colt of Fresno(2018)6 Cal 5th 502,915,Modem Overszg/t Coalzhon,Ins v Count)of
Madera(2011) 199 Cal.App.4th 48 102 131) 3s the court stated in Berkelpp'Jets,suppw,9l Cal App
4th at 1355
A prejudicial abuse of discretion occurs"if the failure to include relevant information
precludes informed decision making and informed public participation, thereby
thwarting the statutory goals of the FIR process
The preparation and circulation of an EIR are more than a set of technical hurdles for agencies and
developers to overcome The EIR s function is to ensure that government officials who decide to
build or approve a project do so with a full understanding of the environmental consequences arid,
equally important that the public is assured those consequences have been considered For the EIR
to sen e these goals it must present information so that the foreseeable impacts of pursuing the
November 2019 Page 2 35
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES ll N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
2 Response to Comments
Cit}of Redlands—Ballot Initiative to %atend Measures Li IN&Proposition R
October S 2n19
Page 4 of.5
protect can be understood and weighed and the public must he given an adequate opportunity to
comment on that presentation before the decision to go forward is made (Conrrnnitzesfo)a Better
Earn-mimed i Rrrhmoud(2010) 184 Cal App 4th 70,80[quoting L neyaizt 3rta Citrryns fa;Res en zble
Giwrdti Inc i' Crib if Rancho Cerzlosa(2007)40 Cal 4th 412 449-450])
C The Protect Fads to Properly Consider Regional Housing Needs or to Maximize
Transit Oriented Development
California's housing element law requires local governments to consider projected housing needs b3
income level to guide planning decisions The 2035 General Plan EIR states,"The Housing
Element last updated in 2014,is not being updated at this time and is not part of the Proposed
Project (DSEIR,Appendix 1,3 163)With regard to the Housing Element,the DSEIR itself
states,regarding housing mixture elements of Measure U, [t]he measure has not proved to be a
hindrance for Redlands to achieve its regional housing fair share needs,and Redlands continues to
R6 2 have a certified I Iousing Element"(DSEIR.p 4 1 2.)These clauses ignore the requirement for the
CONTO Project to consider the need for affordable housing in the TYPA This is particularly of concern
given that one of the Project's stated goals is to "[p]romote transit ridership by allowing more
residential development to be located within walking and biking distances from transit facilities''
(DSEIR,p 2-3),and the DSEIR's statement that the Project would allow the Cite to consider
fiiture projects that are transit oriented"
The RIINA Regional Housing Needs Assessment("RHNA') for the City requires
• 579 very low income units,
• 396 low income units,
• 45.a moderate income units,and
• An overall total of 2429 units
(2013 2021 Housing Element p 1 3) While the proposed Project may increase the density and the
overall number of housing units within the Tt,PA,it fails to provide any assurances that very low
income,lots income,or moderate income units will actually he constructed despite the removal of
limitations on height or density Further despite repeatedh alluding to the transit benefits of the
Project and that the TVPA consists of development"within a one half mile radius of rail transit
station[s], the Project fails to ensure that transit oriented development("TOD )is maximized,or
even prioritized The largest share of riders for public transportation are those with lower incomes,
or a ithout access to a c ehicle 1 Without requiring the inclusion of affordable housing,including lou
income and very low income units the Project can simph result in an increase in luxury overpriced
RB-3 housing with increased numbers of higher income residents,who are likely to use cars for
transportation,as opposed to lower income populations that are likely to make use of rail transit
Thus the Project is likely to result in higher numbers olvehicle trips with attendant impacts to air
quality,noise,greenhouse gas emissions,and traffic,among other factors,which must be addressed
by the DSEIR
'Manville M et al (January 2018) Failing Transit Ridership California and Southern California(Prepared for
the Southern California Association ofGovernments) pp 25 26
Page 2 36 PlacelFor,Lr
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
2 Response to Comments
Cc)of Redlands_Ballot Inittattve to Measures U N&Proposition R
October 3,2019
Page 5 of
II CONCLUSION
Commenters request that the Cttr, ret tie and recirculate the Prolect's ens tronmental impact report to
R6 3 address the aforementioned concerns If the City has any questions or concerns feel free to contact
CONT I] my office
Stncerelt,
V'itchell M Tsai
Jkttorneys tor Southwest Regional
Council of Carpenters
November 2019 Page 2 37
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
2 Response to Comments
Thls page atttentzona% left Ilan,.
Page 2 38 Place orlar
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
2 Response to Comments
R6 Response to Comments Mitchell Tsai Law (on behalf of the Southwest Carpenters), dated
October 9,2019
R6-1 The commenter requests that the City provide notice for any and all notices related to
the proposed project
The commenter will be added to die distribution list for notices related to the proposed
Ballot Initiative project
R6-2 The commenter states that the proposed project ignores the requirement for the
inclusion of affordable housing in the TVPA, and states that this is of particular
concern given that one of the proposed project's goals is to promote ridership by
allowing more residential development within walking/biking distance from transit
facilities The commenter states that while the proposed project may increase density
and the overall number of housing units, it fails to provide any assurances that very low
income,low income,or moderate-income units would actually be constructed
The purpose of the Ballot Initiative project is to put to a vote of the people whether to
amend Measures U & N and Proposition R The Ballot Initiative would remove
application of the e\isting City of Redlands 1978 voter-appro\ed initiative measure
commonly known as Proposition "R," as that proposition was amended by the City of
Redlands 1987 voter-approved initiative measure commonly known as Measure "N",
and the 1997 voter-approved Measure "U", from future development within the TVPA
Specifically, the proposed Ballot Initiative would permit the following
• The City s 400 dwelling unit annual limitation on construction of residential
dwelling units would not be applicable within the TV P El,
• Residential densities may be increased within the'TPA from 18 to 27 units/acre
without die necessity of a super majority vote of the members of the City Council
and the necessity of making certain findings.
• Removal of the 4/5ths vote requirement for residential buildings exceeding two
stones or 35 feet in height within the TPA,
• The requirement for the maintenance of traffic lei els of service C' for all
intersections would not apply within the TVPA,
• The prohibition against the creation of new land use designations would not apply
within the TVPA,
• Socio-economic studies would not be required for development projects within the
TVPA
Unless and until die voters act on the above Ballot Initiative,land use changes (whether
to the General Plan or Zoning) for areas within the TVPA cannot be altered if those
alterations would be inconsistent with the above principles
November 2019 Page 2 39
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
2 Response to Comments
The Ballot Initiative does not include, and in turn the SEIR does not consider, any
specific development proposal Similarly, the Ballot Initiative and its SEIR do not
increase density or intensit} of future development within the TVPA beyond what is
already allowed in the City's existing General Plan The proposed project evaluates a
ballot initiative that if approved, would allow development to occur at the density and
intensit prodded in the City's General Plan and evaluated in the General Plan EIR
Accordingly, there would be no more significant impacts related to V IT or air quality,
noise,greenhouse gas emissions, and traffic,than what was analyzed in the General Plan
EIR and the SEIR To the extent that the commenter is concerned about affordable
housing development within the TATA, those concerns are more appropriately directed
at the Transit Villages Specific Plan planning effort
R6-3 The commenter states that the proposed project fails to ensure that transit-oriented
development is maximized or prioritized The commenter states that the largest share of
riders for public transportation are those with lower incomes or without access to a
vehicle therefore, without requiring the inclusion of affordable housing the proposed
project could increase the number of luxury units which would increase the number of
higher-income residents who are likely to use cars, as opposed to the lower-income
populations that are likely to use transit
See response to comment RG-3
Page 240 Placeirorks
3. Revisions to the Draft SEIR
3.1 INTRODUCTION
This section contains revisions to the Draft SEIR based upon (1) additional or revised information required
to prepare a response to a specific comment, (2) applicable updated information that was not available at the
time of Draft SEIR publication, and/or (3) typographical errors This section also includes additional
mitigation measures to fully, respond to commenter concerns as well as provide additional clarification to
mitigation requirements included in the Draft SEIR The provision of these additional mitigation measures
does not alter any impact significance conclusions as disclosed un the Draft SEIR Changes made to the Draft
SEIR are identified here in strikeout text to indicate deletions and in underlined teat to signify additions
3.2 DRAFT SEIR REVISIONS IN RESPONSE TO WRITTEN COMMENTS
The following text has been revised un response to comments received on the Draft SETR
Pages 2 1 through 2-2, Section 2, Project Description. was revised to reflect the actual ballot initiative text The
recisions are minor in scope, and serve to clarify the Project Description without altering the substance or
character of the proposal The additional text provided herein comprehensively describes the proposal,
including related amendments to the General Plan and Housing Element that will be necessary to properly
implement the purpose of the ballot measure
Section 1. Sub section B2, entitled "Special Categories of Development," of Section
12 of the 2035 Redland., General Plan (Measure I:), entitled "Principles of Managed
De\clopmcnt," as hereby i.lendcd by the addition of subsection B2 C, which shall read au
follows.
"2. Special Categories of Dui clopmcnt The pro\isions of this initiative shall not apply to the
follow ung.
•
C.
D
E.
E. ...
C Tbz;zn,r,zpkri,a1 area of the Citj llcsi oarcd,2, the 'Traoszt T'zBagcs PLztzrru.'g f 1:e.2"a.,dcl5zc;cd
urE.,hzbit " I."n hz,.h z,, aa'z,bcd heat()sad zrranporatod h}'r:'f rcrrcc zntn the:ordroarrci."
Section 2 The 1987\otcr approi cd uutlati\c ordinance commonly known as Meaeure
N is hereby amended br the addition of a new Section 7 which shall rend as follows
November 2019 Page 3 1
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEER
CITY OF REDLANDS
3, Revisions to the Draft SEIR
'SECTION 7 EX'EMPTION TA: c67raphl:ai arza a(the Cirl. rl'. sllat:d a; thv Tr,anzl 11112f
P i11;111,7 lrea 1.; del t d w E_hLIJZt <11"IS hcr:15;: deemed fl2m !hi? or z sztz&lzze°
ordillall.c,iiid.11":,271.T,,'R.'.
`ection 3_ new section 15 is hereby added to the 1978 t otcr approz cd iintuiti\c
ordinance commonh known as Propel Lion R, as amended b) the 1987 otci appto,s cd
Lnitlatn c commonly known as Measure N, to read as follows-
<`5,:i'oi 1 Tllc,zoLea hz a'alc.2 of the Ca'y rl zi z;,:,d a; thz "Trat,sl, I'z',',I;. Family ,1lr a."xi
E, bil;L: " 1' r1G-.1)1_a a:hca bcil:te an i:oi r,2;'a1 Irr;z1r 'J1 z,b iei' zLeJa d
i���171i.T�•0�.1 thz 15ronszo8;of;iv; srrlifla;:e.'
Section 1 Chapter 4.2 of the Citti, of Redlands General Plan entitled
Principles of Managed Development" is hereby amended by the addition of Figlire 4.2-1
which depicts the geographical area of the Cite designated as the "Transit Villages Planning
Area" and which is attached to this Ordinance as Exhibit "A" and incorporated herein by
this reference
Section 2. Sub section B2, entitled "Special Categories of Development," of
Section 4.2 of the Redlands General Plan, entitled "Principles of Managed Development." is
hereby amended by the addition of subsection B2 G,which shall read as follows.
"2. Special Categories of Development.The provisions of this initiative shall not apply to the
following
B
C. .
D.
E.
F.
G Development within the geographical area of the City designated as the
"Transit Villages Planning Area as depicted in Figure 4.2 1"
Section 3 The 1987 voter-approved initiative zoning ordinance commonly
known as Measure N is hereby amended by the addition of Exhibit N 1 which is attached to
this Ordinance as Exhibit"A" and incorporated herein by this reference, and a new Section
7 which shall read as follows
"SECTION 7 ENTAIPTION The geographical area of the City designated as the "Transit
-'illages Planning Area" as depicted in Exhibit N 1, which is attached hereto and
incorporated herein by this reference, is hereby deemed exempt from the provisions of this
initiative ordinance and Measure R"
Section 4. Section 3 of the 1978 voter-approved initiative ordinance
commonly known as Proposition R. as amended by the 1987 voter approved initiative
commonly known as Measure N,is hereb\ amended to read as follows
Page 2 Placell''arks
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
"Section i Henceforth, further residential development shall be limited to four hundred
k4001 new residential dwelling units per calendar year. provided, however, that new
residential dwelling units constructed within the Transit Villages Planning Area shall he
exempt from such annual limitation In am ii en Year, if less than four hundred units are
approved or constructed outside of the boundaries of the Transit Villages Planning Area,
that unused number of dwelling units may not be carried forward to any future ear."
Section 5 The subsection entitled "Measure N" in Section 4.1 of the City of
Redlands General Plan is hereby amended to read as follows.
"Measure N, a growth control ordinance that amended the prey sous growth management
measure (Proposition R . was approved by the \oters in 1987 The measure limits the
development of residential dwelling units to 400 units per calendar year. Of the 400 units,
50 units are. by resolution, reserved for single-family homes, duplexes. triplexes, and four-
plexes on existing lots,with the remainder to be allocated according to a point system which
emphasizes design amenities The measure also restricts changing land designations or
zoning- to a higher densitT than Rural Estate (R-E) for those lands designated as urban
reserve agricultural on Tune 1, 1987, and limits development on steep slopes
In March 2020, the voters approved an initiative ordinance by which Measure N and
Proposition R were amended to exempt development within the geographical area of the
City designated as the Transit Villages Planning Area, as depicted in Figure 4.2-1, from the
provisions of both Measure N and Proposition R"
Section 6 The last sentence under the subsection "Measure U" in Chapter 4
of the City of Redlands General Plan is hereby amended to read as follows.
"Certain types of development are exempted from Measure LT, including_de\elopment on
existing lots of record, remodeling of existing single-fanuh homes, development related to
rail stations. and development protects Downtown,"
Section 7 The subsection entitled "Growth Management and Land Use
Elements" of Chapter 5 of the Housing Element of the City of Redlands General Plan is
hereby amended to read as follows.
"The Growth Management Element grew out of the first growth management voter
initiative, Proposition R that which Redlands voters passed in 1978. Redlands' voters
subsequently passed various other voter initiatives regarding growth management in 1987,
1997,and 2020."
Section 8 The subsection entitled "Annual Development Limitation and
Recent Growth"of Chapter 5 of the Housing Element of the City of Redlands General Plan
€s herehx amended t read as follows.
"Proposition R was amended by Measure N (a zoning ordinance) in 1987, this policy
restricts the development of residential dwelling units to 400 units a Year within the Cm.. and
the extension of utilities to 150 units per year outside the City limits (within the Sphere of
Norernber 2019 Page 3
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
3. Revisions to the Draft SEIR
Influence and therefore in the Counts of San Bernardino's iunsdiction). OE the 400 units
within the City, 50 are by resolution reset`ed for single family homes, duplexes, triplexes
and fourilexes on existing lots, the remainder are allocated on a point system, which
emphasizes design amenities. (This point system is described in the Residential Development
Allocation section that follows)
Measure U, adopted b\ the voters ui 1997, further articulated growth management policies
This General Plan Amendment reinforced and modified certain provisions of Measure N.
adopted Principles of Managed Growth, and reduced the det elopment dense s of San
Timoteo and Live Oak canyons by creating a new land use category Resource Presen anon
Measure 1 1 has a negligible effect on the ability of the City to accommodate future residential
det elopment because it concerns an area of the City with steep hillsides, natural resources.
and other conditions that would limit the development potential of this part of Redlands.
regardless of governmental controls In addition, under Measure U. no land designated by
the General Plan as Urban Resets e as of Tune 1, 1987, is to be re-designated for a higher
density than the RE designation as the same existed on Tune 1, 1987 unless specified findings
are made by a four fifths vote of the City*Council.
Moreover, an initiative ordinance adopted by the voters in March 2020. exempts
development within the geographical area of the City designated as the Transit Villages
Planning Area from the provisions of Proposition R,Measure N,and Measure U.
Growth management measures were originally adopted in response to rapid residential
de\elopment during the 1980s, -When 30 percent of the current housing stock was
constructed in a single decade. This pace of development 'aas an aberration in the city's
det elopment history and would not likely be repeated even without grorc,th management.
From April 2000 to January 2013, about 1,913 housing units, or about 147 per year, were
added to the city's housing stock This is much less than the maximum permitted under
Measure U. Under the present growth management system, the citv's housing supply could
expand by 12 percent ovei eight rears (400 units per ear between 2014 and 2021). although
a third less than the pace of det elopment during the 1980s, even this growth rate is unlikely
Moreo\er, the city's housing supply could expand by an even greater percentage due to
various categones of development exempt from Measure U "
Section 9 The first paragraph of the subsection entitled "Housing Type
Balance" of Chapter 5 of the City of Redlands General Plan is hereby amended to read as
follows.
"Measure 11, in place since 1997. also amended the Redlands General Plan Land Use
Element to "plan for a housing mix of 75 percent single-family and 25 percent multi family
dwelling units at buildout 'The City Council has adopted a clarification of this policy that
further adjusts these numbers by determining that "for-sale" condominiums (which are
considered multi-family dwellings by the Census and the Department of Finance) will be
considered single-family dwellings for purposes of this calculation In addition, the City
Page 34 Placel orks
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N, & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
Council has further clarified that development within the Transit Villages Planning Area as
depicted in Figure 4.2-1 will not be factored into "housing mix" referenced ohm e"
Section 10 The first paragraph of the subsection entitled "Residential
Development Allocation" of Chapter 5 of the Housing Element of the City- of Redlands
General Plan is hereby amended to read as follows.
"Residential Development Allocation (RD a)
Required by the Growth Management Element, the Residential Development Allocation
(RDA) determines which protects may move through the development process to receive
building permits. Residential subdivision protects that invoh e more than four units and that
are subject to the provisions of Proposition R and Measure N compete against each other
for an allocation of housing units from the pool of 400 dwelling units allowed each year
within the city limits and 150 utility connections permitted in the SDI. The City Council
makes allocations four times a year. 117 allocations in each of the first three quarters and the
remainder in the fourth Staff assists applicants in preparing applications Unused allocations
may not be carried forward to the next year Moreover, a protect must obtain at least ninety
points in order to receive an allocation"
Section 11. The first paragraph of the subsection entitled "Meeting the RIINA
Under Measure U" of Chapter 5 of the Housing Element of the City of Redlands General
Plan is hereby amended to read as follows.
"Meeting the RNHA Under Measure U
The growth management system will not constrain Redlands' ability to accommodate its
RNA During the eight y ears of the RIII\TA protection period (January- 1. 2014 to October
31, 20211, 2,429 units would need to be accommodated, or about 304 units per year. for
Redlands to meet its RI-ThTA.This development rate is feasible under the City's polic}, which
allows up to 400 units per year within cite limits lus unlimited additional SRO and
congregate care facilities,in addition to unlimited development within the geographical area
of the City designated as the Transit Villages Planning Area, which is exempt from the
provisions of Proposition R,Measure N, and Measure U)."
Section 12. Item number 7.9-4 of the subsection entitled "Additional
Programs" of Chapter 7 of the Housing Element of the City of Redlands General Plan is
hereby deleted in its entirety
Page 2-2, Section 2, Project Description was updated in response to comment RS-1 to reflect the missing text
about building heights from the proposed ballot initiative
If the proposed ballot initiative is approved by the voters,it would allow the City Council to consider future
projects within the TVPA without the burden of the annual residential dwelling unit limitation New
residential units, specifically residential units in multi-family projects, within the TVPA could be financed
more efficiently and constructed faster than the current regulations would permit Future City discretionary
November 2019 Page 3 5
BALLOT INITIATIVE RE VOTER APPROVED LAND USE INITIATIVES MEASURES U N & PROPOSITION R FINAL SEIR
CITY OF REDLANDS
3 Revisions to the Draft SEIR
actions relating to proposed de\.elopment within the TVPA would not be constrained by the General Plan
linutations contained in Measure Li and the zoning restrictions in Proposition R, as amended by Measure N
Specifically; the proposed ballot initiative would permit the following
• The City's 400 dwelling unit annual limitation on construction of residential dwelling units would not be
applicable within the TVPA,
• Residential densities ma) be increased within the TVPA from 13 to 27 units/acre without the necessity of
a super majority vote of the members of the City Council and the necessity of making certain findings,
• Removal of the 4/5ths vote requirement for residential buildings exceeding two stones or 35 feet in
height within the TVPA.
• The requirement for the maintenance of traffic levels of service "C" for all intersections would not apply
within the TVPA
• The prohibition against the creation of new land use designations would not apply within the TVPA,
• Socio economic studies would not be required for development projects within the TVPA
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