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RESOLUTION NO. 6735 RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS RECEIVING AND APPROVING WRITTEN FINDINGS PREPARED IN RESPONSE TO WRITTEN OBJECTIONS, COMMUNICATIONS AND SUGGESTIONS RECEIVED AT OR BEFORE THE JOINT PUBLIC HEARING CONDUCTED FOR THE PROPOSED REDEVELOPMENT PLAN FOR THE NORTH REDLANDS REVITALIZATION PROJECT WHEREAS, the Community Redevelopment Agency of the City of Redlands (the "Agency") has prepared a proposed Redevelopment Plan (the "Plan") for the North Redlands Revitalization Project(the"Project") pursuant to the California Community Redevelopment Law, (CCRL; Health and Safety Code Section 33000, et seq.); and WHEREAS, on June 17, 2008 the Agency held a duly noticed joint public hearing with the City Council of the City of Redlands (the "City Council") to consider the Project; and WHEREAS, any and all persons having any objections to the Plan or who deny the existence of blight in the Project Area, or the regularity of any of the prior proceedings, were given an opportunity to submit written objections, communications and suggestions prior to the commencement of or at the joint public hearing and to give oral testimony at the joint public hearing and show cause why the Plan should not be adopted; and WHEREAS, the City Council has heard and considered all evidence, both written and oral, presented in support of and in opposition to the adoption of the Plan; and WHEREAS, pursuant to CCRL Section 33363, before adopting a redevelopment plan the City Council is required to make written findings in response to each written objection, communication or suggestion of an affected property owner or taxing entity; and WHEREAS, pursuant to the CCRL the City Council shall respond in writing to the written objections, comments and suggestions received before or at the noticed hearing, including any extensions thereof, and may additionally respond to the written objections, communications and suggestions that are received after the hearing; and WHEREAS, certain written objections, communications and suggestions to the Project were received on or before the joint public hearing and are attached hereto as Exhibit A and incorporated herein by reference. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF REDLANDS DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS: Section 1. The Recitals above are true and correct and are fully incorporated into this resolution and finding. 6735 NRRP Response to Obec#ions,doc Page 2 Section 2. Having reviewed such written objections, communications and suggestions, the City Council, pursuant to CCRL Sections 33363 and 33364, hereby adopts as Its written findings Exhibit B,which is attached hereto and incorporated herein by this reference, in response to each written objection, communication and suggestion set forth in Exhibit A. Section 3. The City Council has not accepted specified written objections, communications and suggestions for the reasons set forth in the attached Exhibit B. Section 4. The City Clerk shall certify to the passage and adoption of this Resolution and it shall thereupon take immediate effect and be in force. ADOPTED, SIGNED AND APPROVED on this 1't day of July 2008 rz- May ATTEST: Cityr �piek /4" L/ 1, Lorrie Poyzer, City Clerk of the City of Redlands, hereby certify that Resolution No. 6735 was duly adopted by the City Council of the City of Redlands at a regular meeting thereof held on the 1 st day of July, 2008, by the following vote: AYES: Councilmembers Gilbreath, Gallagher, Aguilar, Bean; Mayor Harrison NOES: None ABSENT: None ABSTAIN: None � LO ty�lark _.'7��oyzer7( 5735 NRRP Respose o On,ections doc � i I i EXHIBIT "A" WRITTEN OBJECTIONS, COMMUNICATIONS AND SUGGESTIONS k t STEPHEN W. ROGERS, P. E. CONSULTING 820 CHURCH ST. REDLANDS, CA 92374 PHONE: 909.556. 1988 (CELL) EMAIL: STEVE ROGERS@VERIZON.NET June 17, 2008 Honorable Mayor and City Council Members City of Redlands City Council and Redevelopment Agency City Hall 35 Cajon Street Redlands, CA 92373 RE: Item M. Joint Meeting- Public Hearing- City Council and Redevelopment Agency (June 17, 2008) -NORTH REDLANDS REVITALIZATION PROJECT (NRRP) PLAN AND FINAL ENVIRONMENTAL IMPACT REPORT (FEIR) Dear Sirs and Madam: I hereby object to adoption and creation of the proposed project entitled: "North Redlands Revitalization Project(NRRP), a Redevelopment Plan". As a member of the general public and owner of real property shown within the boundaries of said Plan, I offer the following comments and concerns regarding procedural discrepancies and technical deficiencies to the Plan and Final EIR documents as listed below. (NOTE: COMMENTS ARE PROVIDED REFERENCING PAGE NUMBER AND DOCUMENT COMPONENT INCLUDED WITHIN THE JOINT HEARING 3 EVIDENTIARY RECORD TO INCLUDE: TAB 2- "REDEVELOPMENT PLAN FOR THE NORTH REDLANDS REVITALIZATION PROJECT(NRRP)" &TAB 3- "FINAL (PROGRAM)ENVIRONMENTAL IMPACT REPORT(FEIR)FOR THE NORTH REDLANDS REVITALIZATION PLAN(NRRP)".) Comment#(Pa./doe.) Comment 1. (Cover, NRRP) March 2008 date does not correspond with latest amendments shown as June 2008 in remainder of document package. 2. (Pg.3,NRRP) "(Sec. 300)Revitalization Area Boundaries"references "Attachment A" as the area map for the NRRP and"Attachment C" as the legal description for the real property contained within the boundaries of the NRRP. a. "Attachment A" being the map of the proposed NRRP is erroneous as follows: Church Street right-of-way adjacent to my property(E/S Church,between Colton and Brockton Avenues)has been excluded from the Plan area boundaries while the adjacent lots including my property are included within the Plan. 2 b. "Attachment A"boundaries appear to be"gerrymandered"to exclude existing(or approved)Multiple Family Residential development and other areas "ripe" for potential shorter term redevelopment (vacant and underutilized parcels), including but not limited to: 1) "The Terrace" neighborhood bounded by Colton Ave., Church St., 6`h St., and the I-10 Freeway. Discussions with the consultant firm Urban Futures, Inc. (UFI) resulted in Mr. Steven Dukett indicating that he had originally recommended inclusion of"The Terrace" in order to avoid a"doughnut hole" between the existing Redevelopment area and the proposed Plan area, 2) Council Approved Multiple Family Residential development involving property within the old Redlands Lawn Bowling recreation area in Sylvan Park along the w/s University St., w/o Park Ave., 3) Neighborhood bounded by Church St., Brockton Ave.,University St. and Lugonia Ave., and 4) Neighborhood bounded by Colton Ave., Church St., Lugonia Ave. and Tribune St. c. Core of"Sub- Area A"as shown on"Attachment A"has been excluded from the Plan area and was referred to as "doughnut hole"by project consultants UFI. UFI could not offer reasonable rationale for exclusion of area in responding to my public comments and concerns that excluding core area from the Plan boundaries is creating an"inappropriate division". UFI Consultants indicate that I should"agree to disaffee" with them regarding this issue and other Plan boundary exclusion and inclusion concerns that were identified as b. above. d. "Attachment C"being the Legal Description describing the real property to be included within the boundaries of the NRRP is erroneous as follows: The legal description for"Sub- Area A"is not signed and stamped by the Licensed Land Surveyor or Registered Civil Engineer responsible for it's preparation. e. "Attachment C" legal descriptions purport accuracy of dimensions to 100h of a foot (.01) exceeding accuracy of some of the record information as shown on referenced mapping. Standard language for"meets and bounds"legal descriptions may utilize calls such as"more or less" not utilized with the "Attachment C" legal descriptions as proposed. If the legal descriptions are based upon a field survey, a Record of Survey should be filed with the County of San Bernardino depicting said survey. f. Exhibits (14 Sheets) are included with"Attachment C" Legal Descriptions without appropriate reference for attachment and are erroneous as follows: 1) "The Terrace"neighborhood bounded by Colton Ave.,Church St., 6t' St. and Interstate 10 is not appropriately depicted and is shown as"Existing Redevelopment Area"when it is not. Based on this exhibit, it would not be desirable to exclude "The Terrace" from being within a Redevelopment Plan area as is being proposed with the Plan, 2) Church St. is shown as (Yucaipa St.), s/o Colton Ave. and erroneously for first N/S street name west of the Colton and University intersection, 3) Exhibits Sheets 7,9, 10 &11 should show I-10 Freeway right-of-way accurately along with the BN SF Railroad right-of-way in the vicinity of Park Ave. 3. (Pg.14, NRRP) "(Sec. 50 1) Revitalization Area Map" description is inaccurate for properties along e/s Church St., between Colton and Brockton Avenues where properties are included within Plan boundaries, but adjacent street right-of-way is excluded(See Comment 2.a. above also). 3 4. (Pg.14, NRRP) "(Sec. 501) Revitalization Area Map" document indicates: "Attachment B illustrates land uses and street layouts currently permitted by the General Plan in the Revitalization Area."For the proposed"baseline" year of 2008, the General Plan analysis is substantially outdated since it was last updated in for the baseline year of 1995. According to the City's Planning Department,the General Plan Update is being pursued by a Consultant under contract with the City, but is tagging the proposed NRRP by a number of years (due to lack of City funding). The NRRP Plan and FEIR should not be based on substantially outdated planning and environmental documents such as the currently outdated General Plan and associated environmental documentation. For the NRRP Plantobe appropriately reviewed and analyzed under a comprehensive planniiig process it should be delayed until the General Plan Update and associated FOR are appropriately processed and adopted. If,however, the NRRP Plan and Final (Program)EIR as proposed are not processed concurrently with(but following)the General Plan Update and associated FEIR, the review and analysis provided at this time is inadequate under CEQA to address project impacts (especially cumulative impacts) on the environment. 5. (Pg. 15,NRRP) Under"(Sec. 505)The Agency is authorized to permit... educational, fraternal,... multi-model transit facilities..."and, "All such uses shall conform to the General Plan as it may be amended from time to time." Upon Questioning, consultant UFI indicated that understanding the.impacts of the expansion plans for the UniversityofRedlands and the proposed Metrolink rail extension to the University were outside of their scope of work for the NRRP Plan and FEIR. As with the previous comment, the only wgy to adequately analyze the University and transit expansion plans and their potential impact on the environment is to delay consideratioa,of the Plan until the General Plan Update and FEIR review and analysis of these elements is completed and their impacts on the NRRP plan are known. 6. (Pg. 17,NRRP) "(Sec. 517) Consistency with General Plan and Zoning Ordinance"-The existing General Plan and associated environmental review and analysis are substantially outdated for the base year 2008 proposed for the NRR.P Plan. See Comment 4 above also. 7. (Pg. 20,NRRP) "(Sec. 700)Actions by the City"- Based on the outdated nature of the General Plan and associated environmental documentation, the"Actions by the City" listed under a),b) and c) should be pursued concurrently with or prior to the adoption of the proposed NRRP Plan and FEIR. See Comments No. 4 and 6 above also. 8. ("Attachment D",NRRP) No economic and financial back-up has been provided to justify the Tax Increment Projections included with the NRRP Plan. Is the lending rate shown consistent with the rate that the RDA may realize for a project/plan/ district that does not retain the power of eminent domain? 9. (Cover, FEIR) Cover indicates May 2008 preparation date while body indicates June 2008 revision. 10. (Pg. GD-3,FEIR) Definition of"Program EIR" should refer to a specific type of EIR being a"Program EIR", rather than"...means the EIR prepared for the Project." 11. (Pg. E-9, FEIR) "Summary of Impacts, Mitigation Measures and Level of Significance after Mitigation—15 Transportation/Traffic"- Proposed Final (Program)EIR does not adequately review and analyze existing(baseline) and future traffic volumes anticipated for the term of the project(30 years), including substantial cumulative impacts as previously identified. A current CMP level traffic analysis 4 should be conducted in order to quantify baseline and future(buildout) traffic volumes and their associated impact on the existing City street network within and outside the NTRRP and qualify the street sections depicted or adjusted to meet capacity requirements for the(outdated) General Plan Circulation Element. See Comments 4 and 5 above also. 12. (Pg. E-11,FEIR) Under"Alternative Revitalization Area Alternative", area exclusions discussed in Comment 2 above contradicts language included in Plan FEIR regarding "conditions of deficiency and disuse". 13. (Pg. E-11,FEIR) Under"Limited Redevelopment Activities Alternative", the RDA's power of eminent domain has been eliminated from"activities"that are allowed under the NRRP Plan. As such, the document should analyze the alternative that eminent domain powers, as allowed by law, be included in the Plan and the associated economic feasibility of such an alternative. 14. (Pg. E-13,FEIR) "Summary of Issues to be Resolved by the Lead Agency"-The issues identified under items I through 4 have not been appropriately analyzed by the proposed Final (Program)EIR due to the condition and outdated nature of the existing General Plan and associated environmental documentation being utilized as a basis for the process. See Comments No. 4, 5, 6 and 7 above also. 15. (Pg. 10,FEIR) "Description of Program EIR and Relationship to Project"- See Comments No. 4, 5, 6, 7 and 14 regarding inadequacy of proposedfinal Program El for the environmental review and analysis of the proposed NRRP Plan. 16. (Pg. 11, FEIR) "Program EIR Advantages"- See Comments No. 4, 5, 6, 7 and 14 regarding inadequacy of proposed Final,.Pro gram EIR for the environmental review and analysis of the proposed NRRP Plan. 17. (Pg. 12, FEIR) "Specificity of Analysis"- The proposed Final Program EIR does not"evaluate the Project under the proposed Plan at the greatest level of specificity possible" due to the fact that the basis/baseline being utilized(current General Plan) is substantially outdated and inaccurate regarding the current conditions, anticipated future conditions and appropriate mitigation measures for the City, including the NRRP Plan area. See Comments No. 4,5,6,7 and 14 above also. 18. (Pg. 12, FEIR) Was the following statement used as a qualifier when a determination was being made to formulate the boundaries of the proposed NRRP? "No site-specific activities or actions that could be reasonably linked to a specific location have been identified by the Agency." Are there no on-going or approved development projects that by creation of the proposed Revitalization plan will become Redevelopment projects benefiting the NRRP? 19. (Pg. 13, FEIR) The"Analytical Approach"would only be applicable to the proposed Final Program EIR if the General Plan and associated environmental analysis and documentation were current and not substantially outdated and therefore inadequate as the basis for the Plan and the proposed Final Program EIR. 20. (Pg. 19, FEIR) Under"Relationship to General Plan Buildout(Beginning of third paragraph): The change in the environment between the existing baseline(the year 2008) and the expiration of the Plan (the year 2038) isexaminedto determine whether the iMpact(s) of the proiect would be significant." The review and analysis scenarios portrayed here are inadequate for the proposed NRRP Plan and Final (Program)EIR, as identified in Comments No. 4,5,6,7 and 14 above, due to the outdated nature of the current General Plan it's co=ongntjEkM�ent)plans and the Master EIR for the City of Redlands, 5 2 1. (Pg. 34, FEIR) The Upper Santa Ana River Wash Land Management and Water Conservation Plan ("Wash HCP") shows a path along the Church Street alignment that enters the proposed Wash HCP area. A General Plan Amendment or Update and associated environmental documentation will be required in order to reconfigure or relocate said path to an alternative alignment prior to the Wash HCP adoption and approval. 22. (Pg. 74, FEIR) The review and analysis of the impacts of Transportation/Traffic provided with the proposed NRRP and Final Program EIR are inadequate due to the outdated nature of the current General Plan, it's component(Element)plans and the Master EIR for the City of Redlands. See Comments No. 4.5,63,14 and 20 above also. 23. (Pg. 74, FEIR) Orange Street/Lugonia Ave. should be identified as State Route 38 under the description of the "Regional System". 24. (Pg. 75, FEIR) Church Street between Interstate 10 and Brockton Ave. has erroneously been placed in both the"Minor Arterials" designation and"Collector Streets" designation. 25. (Pg. 76, FEIR) Under"Rail", the statement that"The railroad track and proposed stations are located south of the I-10 and are not within the Revitalization Area..." is inaccurate and deceptive in nature. See Comments No. Lf,3) and 5 above also. 26. (Pg. 104, FEIR) Under"Transportation/Traffic" - Second paragraph, "...with respect to Plan adoption, cumulative impacts are considered less that significant, given that mitigation in the form of additional traffic analysis, as appropriate and necessary, is performed." This scenario is inappropriate and inaccurate due to the outdated nature of the current General Plan Circulation Element and the need to reanalyze the NRRP Transportation/Traffic impacts and appropriate mitigation with an updated CMP City-wide traffic analysis before Plan/FEIR approval. See Comments No. 4,5,6,7,14,20 and 22 above also. C: Daniel Hobbs, RDA Director State Clearinghouse, P.O. Box 3044, Sacramento, CA 95812- 3044 -----Original Message----- From: Steve Rogers [mailto:steve rogersa ,verizon.net Sent: Tuesday, June 10, 2008 4:33 PM To: Josefina Aguilar Cc: Daniel Hobbs; msaucedo@cityofrediands.org Subject: Re: Memorializing our conference call re NRRP Ms. Aguilar: Thank you for your attention to my concerns regarding the NRRP and your memo memorializing our discussions with the RDA's consultant team. Please let me be clear that staff and UFI have made an effort to clarify the project components with which I disagree, however; there has been an overall disconnect with City administrative personnel regarding these same concerns. Your memo infers that I had requested that my residence be removed from the project boundary area when in fact it was Mr. Hobbs'suggestion that this might be a possible compromise. Also, you suggest that I am not in agreement with the project because the district will not include eminent domain power. I was merely pointing out that the lending rates that the underwriters will offer the City RDA will be somewhat diminished because of the perceived lack of an "effective redevelopment plan" (w/o eminent domain powers). You also failed to point out the procedural concerns that I expressed due to the NRRP preceding ahead of the anticipated General Plan update an therefore making consideration of the NRRP premature until after preparation and approval of the General Plan update. Lastly and most importantly, I am philosophically opposed to a program that will serve to increase government, especially with the current trying and bleak economic outlook, and the program being placed on the backs of middle and lower income citizens and their properties. As I was indicating to you earlier today, I desire to review the final EIR for this project as well as the final report of the NRRP so that I might craft my comments for the City Council and State Clearinghouse with all information that should be available to me for review prior to the public hearing on this matter. Since you have taken such initiative in preparing the subject memo, I will be looking to you and not the consultant group, as you suggested, to provide me with such an opportunity to review the final documents that will be considered by City Council on June 17. Sincerely, Stephen Rogers I MAY-15-2006 06:32A FROM:HOLY TRINITY CCGIC H 9097988870 TO:7987503 P, M. =: i HOLY TRINITY COLIC,HOLINESS 1334 CLAY STREET 1418 TEXAS STREET REDLANDS,CA 92374 909 648-1201 These addresses of the properties are In the redevelopment areas for the plan. I am Bishop B.B.Brown,the Presiding Bishop of Holy Trinity C.O,G.LC.,Holiness. We are wondering about the Agency that wants to redevelop the Northside at the expense of the people of our Community. These people have been i here for along time In seeing the changes take place In Redlands with the absence of the orange groves,and the housing explosion as well as the businesses that have been built on the Northside of Redlands. So, the struggle of mortgages,poor economy,failing)obs,and now to be challenged by the thought of redevelopment In our Community. it Is a time of uncertainty for so many,and If we didn't know God where would we be. Now,the legislators of the City of Redlands want to send out a notice for more uncertainty. I am a representative of God,and His people that are truely called by His name. It Is time that we stop running,and work together In,a cgmmon bond to forge the many challenges that Reditrids is faced-ter)#tI. Sincerely, 81 HOP BB, Ft©WN F FICILY TT,N!TY.00GIC,-HOLINESS d i r f a f i i a E t i i i EXHIBIT "B" RESPONSES TO WRITTEN OBJECTIONS, COMMUNICATIONS, AND SUGGESTIONS AND FINDINGS Page 2 EXHIBIT "B" RESPONSES TO WRITTEN OBJECTIONS, COMMUNICATIONS, AND SUGGESTIONS AND FINDINGS Pursuant to Section 33355 of the California Community Redevelopment Law(the"CCRL"; Health and Safety Code Section 33000, et seq.), prior to its adoption of a redevelopment plan, the legislative body and the board of directors of a redevelopment agency shall hold individual public hearings or, at their election, a joint public hearing on the proposed redevelopment plan or amendment. The City Council of the City of Redlands (the "City Council") and the Redevelopment Agency of the City of Redlands (the "Agency") held a joint public hearing (the "JPH") on the proposed redevelopment plan (the "Plan") for the North Redlands Revitalization Project (the "Project"), which JPH was convened on June 17, 2008 and was closed on the same date. The City Council and Agency heard oral testimony at the JPH and accepted written objections, communications and suggestions prior to and at the JPH. Pursuant to CCRL Section 33363, "[t]he legislative body shall respond in writing to the written objections received before or at the noticed hearing, including any extensions thereof.—The written responses shall describe the disposition of the issues raised.". The following responses to objections (the "Responses") have been prepared to comply with the requirements of CCRL Section 33363. Note that unless otherwise defined, capitalized terms in these Responses have the same meaning as set forth in the Plan. GENERAL OVERVIEW A review of Attachment A to the Plan will show that the action which was before the Agency and City Council at the JPH proposed a redevelopment project containing approximately 859.6 acres of land (approximately 623.9 acres of land excluding right-of- ways)in two noncontiguous subareas(the"Project Area")consisting of 1,849 parcels. The subareas are identified in Attachment A to the Plan as Subareas A and B. Prior to or during the JPH written objections, communications and suggestions were received by the Agency and City Council from Stephen Rogers(i.e., a letter dated June 17, 2008 and an e- mail message dated June 10, 2008) and from Bishop B. B. Brown (i.e., letter sent via facsimile on May 15, 2008). A copy of each of these writings is included within Exhibit"A" to the Resolution. WRITTEN RESPONSES The written findings of the City Council in response to each of the above noted writings are arranged in the order that they were received, with the most recent listed first. Each objection, communication, and suggestion contained within each of the writings is then restated and a reasoned response is provided immediately thereafter. For ease of presentation, each objection, communication, and suggestion is generically referred to as NRRP Witten Responses to Objections v6-25-08 Page 3 an "Objection" and is numbered. Each reasoned response to each objection, communication, and suggestion is referred to as a "Response" and is also numbered. 1. Responses to Written Objections, Communications and Suggestions received from Stephen W. Rogers in his Letter of June 17, 2008 Objection 1-1: "(Cover, NRRP) March 2008 date does not correspond with latest amendments shown as June 2008 in remainder of document package. [Sic.] Response 1-1: The date of March 2008 reflected on the cover sheet for the proposed Redevelopment Plan for the NRRP is correctly listed. Pursuant to the March 18, 2008 adoption of its Resolution No. 417, the Agency Board received the proposed Redevelopment Plan for the NRRP and authorized it to be forwarded to the Planning Commission. This Agency Board action established the month and year of the proposed Redevelopment Plan for the NRRP. If ultimately adopted, the cover of the final Redevelopment Plan will reflect the month and year of its adoption. Objection 1-2: (Pg.3, NRRP) "(Sec. 300) Revitalization Area Boundaries" references"Attachment A"as the area map for the NRRP and "Attachment C"as the legal description for the real property contained within the boundaries of the NRRP. [Sic.] Response 1-2: Section 300 of the proposed Redevelopment Plan for the NRRP reads: "The boundaries of the Revitalization Area are illustrated on the Map contained in Attachment A; and the legal description of the boundaries of the Revitalization Area is set forth in Attachment C; both of which are attached hereto and incorporated herein." A reference to Attachment B, which illustrates the General Plan Land Use map of the Revitalization Area is not necessary in Section 300 as all three Attachments were first referenced in Section 200. Objection 1-3: "Attachment A" being the map of the proposed NRRP is erroneous as follows:-Church Street right-of-way adiacent tom Property(E/S Church, between Colton and Brockton Avenues) has been excluded from the Plan area boundaries while the adiacent lots, including my property, are included within the Plan. [Sic.] Response 1-3: Both Attachment A and C to the Redevelopment Plan are correct as reflected in the proposed Redevelopment Plan for the NRRP. Both Attachment A and C are intended to provide a clear and obvious depiction of the boundaries of the proposed Revitalization Area. In this regard, the proposed boundaries of the Revitalization Area are inclusive of adjacent pubic rights-of-way in some areas and not inclusive of adjacent public rights-of-way in other areas. The inclusion or exclusion of certain public rights-of-way is not a perquisite with respect to the eligibility of any particular area for inclusion within a redevelopment project area. The Report to the City Council prepared for the NRRP (the "Report to Council") provides a detailed explanation of the reasons for including the land NRRP Written Responses to Objections v6-25-08 Page 4 that has been recommended for inclusion within the boundaries of the proposed Revitalization Area (see Sections 2.0 through 7.0 of the Report to Council). In addition, Sub-Section 2.1 of the Report to Council provides the legal basis for selecting parcels to be included in the Revitalization Area. The Sub-Section 2.1 provides an excerpt of Sections 33320.1 and 33321 of the CCRL, which together form the legal basis for inclusion of land within any redevelopment project area. In addition, the boundaries of the Revitalization Area were specifically reviewed, considered and recommended by the North Redlands Visioning Committee(the"NRVC")during their meeting of August 20,2007. Approximately 50 community members attended this meeting. By way of background, the NRRP is a result of a grass-roots community-based effort to bring a community-oriented voluntary program of reinvestment and rejuvenation to the proposed Revitalization Area. In particular, a coalition of 12 community-based organizations, lead by the NRVC, together with a broad based indication of community support reflected in a 16 page resident's petition, requested that the Agency Board consider establishing a new redevelopment project area in North Redlands. In response to their request, direction to initiate the redevelopment planning work began with the March 20, 2007 adoption of Resolution 407 by the Agency Board. The purpose of NRVC, among other things, is to provide a forum for the community to express their needs and concerns and to create a means for formulating a"Plan of Action". Prior to 2007 and after a lengthy well reasoned effort, the NRVC prepared the North Redlands Vision Plan. The North Redlands Vision Plan formed the framework from which the North Redlands residents were able to communicate their needs and desires to the City. That Plan has been widely shared throughout the community and has earned significant community support and endorsements. In recognition of their leadership in the community, on October 16, 2007, the City Council adopted Resolution No. 6659, which among other things, officially appointed the NRVC as the community based organization responsible for providing a community participation program through public workshops and information sessions for residents, businesses, property owners, civic and business organizations and other interested parties for the purpose of receiving public input with respect to the NRRP. The NRVC carded out their duties in a very serious, business-like and thorough fashion. Since the initial meeting with the NRVC to review the subject of redevelopment, staff and/or Advisors have met with the NRVC 16 times. Their meetings were always well attended. In addition, the NRVC: hosted two community education workshops;one on May 15, 2008 and the other on May 19, 2008. Collectively, staff has estimated that approximately 120 persons attended these workshops. Throughout the planning process the NRVC was instrumental in sharing information in the community concerning the redevelopment planning effort. In fact, they prepared their own printed material sharing information on and inviting community participation with respect to the NRRP. In summary, the community of North Redlands, through the efforts of the NRVC, has recommended the boundaries of the NRRP Written Responses to Objections v6-25-08 Page 5 Revitalization Area as specifically delineated on Attachments A and C. Objection 1-4 "Attachment A" boundaries appear to be "gerrymandered" to exclude existing (or approved) Multiple Family Residential development and other areas "ripe"for potential shorter term redevelopment(vacant and underutilized parcels), including but not limited to: 1) "The Terrace" neighborhood bounded by Colton Ave., Church St., 6 St., and the 1-10 Freeway. Discussions with the consultant firm Urban Futures, Inc. (UFI) resulted in Mr. Steven Dukett indicating that he had originally recommended inclusion of "The Terrace" in order to avoid a "doughnut hole" between the existing Redevelopment area and the proposed Plan area, 2) Council Approved Multiple Family Residential development involving property within the old Redlands Lawn Bowling recreation area in Sylvan Park along the w/s University St., w/o Park Ave., 3) Neighborhood bounded by Church St., Brockton Ave., University St. and Lugonia Ave., and 4) Neighborhood bounded by Colton Ave., Church St., Lugonia Ave. and Tribune St. [Sic.] Response 1-4: The boundaries of the Revitalization Area were determined by a process consistent with the eligibility requirements specified in the CCRL. As noted above, the Report to Council prepared for the NRRP provides a detailed explanation of the reasons for including the land that has been recommended for inclusion within the boundaries of the proposed Revitalization Area(see Sections 2.0 through 7.0 of the Report to Council). In addition, Sub-Section 2.1 of the Report to Council provides the legal basis for selecting parcels to be included in the Revitalization Area. The Sub-Section 2.1 provides an excerpt of Sections 33320.1 and 33321 of the CCRL, which together form the legal basis for inclusion of land within any redevelopment project area. In order to be compliant with the CCRL, it is the data gathered to determine eligibility that drives the ultimate boundaries of the redevelopment project, not the other way around. The drawing of boundaries involves the exercise of judgment and reasonable minds may differ. Note, for example, that the objector indicates that additional territory should have been included. That said, the boundaries of the Revitalization Area were carefully drawn consistent with the data that were gathered with respect to the various qualifying factors specified in Sections 2.0 to 7.0 of the Report to Council. It is acknowledged that parcels outside of the recommended boundaries of the Revitalization Area were included within the "Survey Area", inclusive of the locations specified in Objection 1-4. Notwithstanding the apparent eagerness of the objector to have such neighborhoods or areas included within the recommended boundaries of the Revitalization Area, only those areas where the various qualifying factors specified in Sections 2.0 to 7.0 of the Report to Council were sufficient pursuant to the.CCRL were included in the recommended boundaries of the Revitalization Area. Finally, with respect to the conclusionary statement written relative to the "Terrace" area, this particular neighborhood was included within the Survey Area. However, it was not ultimately included within the recommended boundaries of the Revitalization Area for the same reasons as any other portion of the Survey Area may not have been included within the Revitalization Area, as described above. NRRP Written Responses to Objections v6-25-08 Page 6 Objection 1-5: Core of"Sub-Area A"as shown on"Attachment A"has been excluded from the Plan area and was referred to as"doughnut hole" by project consultants UFI. UFI could not offer reasonable rationale for exclusion of area in responding to my public comments and concerns that excluding core area from the Plan boundaries is creating an "inappropriate division". UFI Consultants indicate that I should "agree to disagree" with them regarding this issue and other Plan boundary exclusion and inclusion concerns that were identified as b. above. [Sic.] Response 1-5; The boundaries of the Revitalization Area were determined by a process consistent with the eligibility requirement specified in the CCRL. As noted above, the Report to Council prepared for the NRRP provides a detailed explanation of the reasons for including the land that has been recommended for inclusion within the boundaries of the proposed Revitalization Area(see Sections 2.0 through 7.0 of the Report to Council). In addition, Sub-Section 2.1 of the Report to Council provides the legal basis for selecting parcels to be included in the Revitalization Area. The Sub-Section 2.1 provides an excerpt of Sections 33320.1 and 33321 of the CCRL, which together form the legal basis for inclusion of land within any redevelopment project area. As a result of this detailed and time-consuming process, the data gathered justifies why the land proposed for inclusion within the Revitalization Area boundaries meets the eligibility criteria specified in the CCRL. However, there are portions of the Survey Area that the Agency's advisors did not recommended for inclusion within the recommended boundaries of the Revitalization Area. In such instances, the Agency's advisors (i.e., Urban Futures, Inc.) were of the view that such non-included territory did not exhibit sufficient qualifying factors as specified in Sections 2.0 to 7.0 of the Report to Council. Objection 1-6: "Attachment C" being the Legal Description describing the real property to be included within the boundaries of the NRRP is erroneous as follows: The legal description for "Sub- Area A" is not signed and stamped by the Licensed Lancs Surveyor or Registered Civil Engineer responsible for it's Preparation. [Sic.] Response 1-6: As clearly visible on page 12-12 of Attachment"C", Legal Description, of the proposed Redevelopment Plan for the NRRP, both the stamp and signature of the preparing Licensed Land Surveyor, Ronald A. Musser, appear. Mr. Musser's stamp and signature were affixed to the legal description which describes both Sub-Area "A" and "B" of the recommended Revitalization Area. Further, on January 8, 2008, the legal description was officially accepted by the California State Board of Equalization, Property and Special Taxes Department, which is the state agency responsible for the sufficiency of the legal descriptions for all proposed redevelopment project areas in California. Objection 1-7: "Attachment C" legal descriptions purport accuracy of dimensions to 100th of a foot (.01) exceeding accuracy of some of the record information as shown on referenced mapping. Standard language for "meets and bounds" legal descriptions may NRRP Written Responses to Objections v6-26-08 Page 7 utilize calls such as"more or less" not utilized with the "Attachment C" legal descriptions as proposed. If the le-gal descriptions are based upon a field survey, a Record of Survey should be filed with the County of San Bernardino depicting said survey. [Sic.] Response 1-7: Attachment C, which is the legal description for the NRRP boundary, was prepared using available survey records including tract maps, parcel maps, records of survey and Caltrans' right-of-way maps. A field survey was not performed. Therefore, filing of a Record of Survey is not required. Regarding boundary accuracy, boundary courses were defined using record data. Courses were adjusted to establish closure. In addition, each course is referenced to a feature (e.g., street centerline) and, as such, a ,"more or less" inclusion is not necessary. Furthermore, on January 8, 2008, the legal description was officially accepted by the California State Board of Equalization, Property and Special Taxes Department, which is the state agency responsible for the sufficiency of the legal descriptions for all proposed redevelopment project areas in California. Objection 1-8: Exhibits (14 Sheets) are included with "Attachment C" Legal Descriptions without appropriate reference for attachment and are erroneous as follows: 1) "The Terrace" neighborhood bounded by Colton Ave., Church St., 6th St. and Interstate 10 is not appropriately depicted and is shown as "Existing Redevelopment Area" when it is not. Based on this exhibit, it would not be desirable to exclude "The Terrace"from being within a Redevelopment Plan area as is being proposed with the Plan, 2) Church St. is shown as (Yucaipa St.), s/o Colton Ave. and erroneously for first NIS street name west of the Colton and University intersection, 3) Exhibits Sheets 7,9, 10 &11 should show 1-10 Freeway right-of-way accurately along with the BNSF Railroad right-of-way in the vicinity of Park Ave. [Sic.] Response 1-8: The referenced 14 sheets only purport to depict and describe the proposed Revitalization Area. As clearly visible on page 12-12 of Attachment "C", Legal Description, of the proposed Redevelopment Plan for the NRRP, both the stamp and signature of the preparing Licensed Land Surveyor, Ronald A. Musser, appear. Mr. Musser's stamp and signature were affixed to the legal description which describes both Sub-Area "A" and "B" of the recommended Revitalization Area. Further, on January 8, 2008, the legal description was officially accepted by the California State Board of Equalization, Property and Special Taxes Department, which is the state agency responsible for the sufficiency of the legal descriptions for all proposed redevelopment project areas in California. As a result, the legal description of the proposed Revitalization Area is correct and accurately describes and depicts the recommended boundaries of the proposed Revitalization Area. Further, the areas located outside of the proposed Revitalization Area are not germane to and have no bearing or effect upon the legal description of the proposed Revitalization Area(i.e., the"Terrace" area, location of Interstate 10, the railroad right-of-way, references to street names, etc.). Thus, any conclusions drawn with respect to any area outside the NRRP Written Responses to Objections A-25-08 Page 8 proposed boundaries of the Revitalization Area are also not germane to the proposed Revitalization Area. With respect to the objector's further appeal to include the "Terrace" area within the boundaries of the proposed Revitalization Area, the Agency utilized the detailed and tedious process of data gathering to justify why the land proposed for inclusion within the Revitalization Area boundaries meets the eligibility criteria specified in the CCRL. By default, those portions of the Survey Area that were not recommended for inclusion within the recommended boundaries of the Revitalization Area did not exhibit sufficient qualifying factors specified in Sections 2.0 to 7.0 of the Report to Council. It is thus concluded that the appeal of the objector to suggest inclusion of the referenced "Terrace" area within the boundaries of the Revitalization Area is not supportable by the data gathered pursuant to the qualifying factors specified in Sections 2.0 to 7.0 of the Report to Council. Objection 1-9: (Pg.14, NRRP) "(Sec. 501) Revitalization Area Map" description is inaccurate for properties along els Church St., between Colton and Brockton Avenues where properties are included within Plan boundaries, but adjacent street right-of-way is excluded (See Comment 2.a. above also). [Sic.] Response 1-9: Section 501 of the proposed Redevelopment Plan for the NRRP refers to Attachment"A", which is the map of the proposed Revitalization Area. Attachment A is correct as reflected in the proposed Redevelopment Plan for the NRRP. Attachment A is intended to provide a clear and obvious depiction of the boundaries of the proposed Revitalization Area. In this regard, the proposed boundaries of the Revitalization Area are inclusive of adjacent pubic rights-of-way in some areas and not inclusive of adjacent public rights-of-way in other areas. The inclusion or exclusion of certain public rights-of-way is not a perquisite with respect to the eligibility of any particular area for inclusion within a redevelopment project area. The Report to Council prepared for the NRRP provides a detailed explanation of the reasons for including the land that has been recommended for inclusion within the boundaries of the proposed Revitalization Area (see Sections 2.0 through 7.0 of the Report to Council). In addition, Sub-Section 2.1 of the Report to Council provides the legal basis for selecting parcels to be included in the Revitalization Area. The Sub-Section 2.1 provides an excerpt of Sections 33320.1 and 33321 of the CCRL, which together form the legal basis for inclusion of land within any redevelopment project area. In addition, the boundaries of the Revitalization Area were specifically reviewed, considered and recommended by the North Redlands Visioning Committee(the"NRVC")during their meeting of August 20, 2007. Approximately 50 community members attended this meeting. By way of background, the NRRP is a result of a grass-roots community-based effort to bring a community-oriented voluntary program of reinvestment and rejuvenation to the proposed Revitalization Area. In particular, a coalition of 12 community-based organizations, lead by the NRVC, together with a broad based indication of community support reflected in a 16 page resident's petition, requested that the Agency Board NRRP Written Responses to Objections v6-25-08 Page 9 consider establishing a new redevelopment project area in North Redlands. In response to their request, direction to initiate the redevelopment planning work began with the March 20, 2007 adoption of Resolution 407 by the Agency Board. The purpose of NRVC, among other things, was to provide a forum for the community to express their needs and concerns and to create a means for formulating a "Plan of Action". Prior to 2007 and after a lengthy well reasoned effort, the NRVC prepared the North Redlands Vision Plan. The North Redlands Vision Plan formed the framework from which the North Redlands residents were able to communicate their needs and desires to the City. That Plan has been widely shared throughout the community and has earned significant community support and endorsements. In recognition of their leadership in the community, on October 16, 2007, the City Council adopted Resolution No. 6659, which among other things, officially appointed the NRVC as the community based organization responsible for providing a community participation program through public workshops and information sessions for residents, businesses, property owners, civic and business organizations and other interested parties for the purpose of receiving public input with respect to the NRRP. The NRVC carried out their duties in a very serious, business-like and thorough fashion. Since the initial meeting with the NRVC to review the subject of redevelopment, staff and Advisors have met with the NRVC 16 times. Their meetings were always well attended. In addition, the NRVC hosted two community education workshops; one on May 15,2008 and the other on May 19, 2008. Collectively, staff has estimated that approximately 120 persons attended these workshops. Throughout the planning process the NRVC was instrumental in sharing information in the community concerning the redevelopment planning effort. In fact, they prepared their own printed material sharing information on and inviting community participation with respect to the NRRP. In summary, the community of North Redlands,through the efforts of the NRVC, has recommended the boundaries of the Revitalization Area as specifically delineated on Attachment A. Objection 1-10: (Pg.14, NRRP) "(Sec. 501) Revitalization Area Map" document indicates: "Attachment B illustrates land uses and street layouts currently permitted by the General Plan in the Revitalization Area." For the proposed "baseline" year of 2008, the General Plan analysis is substantially outdated since it was last updated in for the baseline year of 1995. According to the City's Planning Department, the General Plan Update is being pursued by a Consultant under contract with the City, but is lagging the proposed NRRP by a number of years (due to lack of City funding). The NRRP Plan and FEIR should not be based on substantially outdated planning and environmental documents such as the currently outdated General Plan and associated environmental documentation. For the NRRP Plan to be appropriately reviewed and analyzed under a comprehensive- planning process it should be delayed until the General Plan Update and associated FEIR are appropriately vocessed and adopted. If, however, the, NRRP Plan and Final NRRP Written Resoonses to Objections v6-25-08 Page 10 (Pro-gram) EIR as proposed are not processed concurrently with(but following)the General Plan Update and associated FEIR, the review and analysis -Provided at this time is inadequate under CEQA to address Proiect,impacts(especially cumulative impacts)on the environment. [Sic.] Response 1-10: California general plan law(i.e., Government Code Section 65300, et seq.) requires each city and county within the state to adopt "a comprehensive, long-term general plan for the physical development" of the land within its present and likely future boundaries. All other land use regulations and decisions within the jurisdiction must conform to the general plan. The general plan is supposed to depict a vision of the community's future; it is most easily thought of as a local land use "blueprint," from which all local land use decisions must derive. A city or county general plan typically covers a 20- to 30-year time period, and contains both broad general goals for the community, as well as specific policies and programs designed to implement those goals. The general plan also must include a diagram showing the general location and intensity of different land uses (e.g., housing, industry, commercial, open space) permitted in the different areas of that jurisdiction. With the exception of housing elements, however, which are treated very differently, local governments are granted a large degree of flexibility to tailor their general plan to meet local conditions. In fact, state law says that "the diversity of the state's communities ... requires ... [local governments] to implement [the adoption of general plans] in ways that accommodate local conditions and circumstances." With the sole exception of its Housing Element(one of seven mandatory general plan elements), the general plan is not required by State law to be updated on a regularly scheduled basis; however, it is permissible to periodically amend it to reflect certain changes, consistent with the limitations specified in the California general plan law. The City's General Plan was amended in 1997 to reflect the Principles of Managed Development adopted by the City's ballot initiative. (FEIR, Section 2.2, p.35-36) The City's General Plan, Section 1.40, Nature and Scope of the General Plan, states in pertinent part as follows: The Plan must be: Long-range: However imperfect our vision of the future is, almost any development decision has effects lasting more than 20 years. The Redlands General Plan is geared to ultimate development of the Planning Area. Comprehensive: It must coordinate all major components of the community's physical development. The relationship between land-use intensity and traffic is most obvious. NRRP Written Responses to Objections v6-25-08 Page 11 General: Because it is long-range and comprehensive, the Plan must be general. The Plan's purpose is to serve as a framework for detailed public- and private-development proposals. It establishes requirements for additional planning studies where greater specificity is needed before the City can act on development proposals. [Emphasis added.] Based on the foregoing, and as a matter of law, the City's General Plan is not outdated. Attachment B to the Revitalization Plan for the Project and Figure 4 of the FEIR properly reflect current General Plan land uses permitted in the Revitalization Area. In addition, Objection 1-10 cites a lack of City funding as a reason given for the delay in updating the General Plan. The increased revenues expected to be received by the Agency as a result of the implementation of the proposed Revitalization Plan will help to relieve the burden on the City caused by the blighting conditions in the Revitalization Area (as described in the Report to Council). No explanation or citation to legal authority or the record is provided by the objector for the statement: "If, however, the NRRP Plan and Final (Program)EIR as proposed are not processed concurrently with(but following)the General Plan Update and associated FEIR, the review and analysis provided at this time is inadequate under CEQA to address project impacts(especially cumulative impacts)on the environment." Objection 1-11: (Pg. 15, NRRP) Under "(Sec. 505) The Agency is authorized to permit .. educational, fraternal.... multi-model transit facilities..." and, "All such uses shall conform to the General Plan as it may be amended from time to time." Upon questioning, consultant UFI indicated that understanding the impacts of the expansion plans for the University of Redlands and the proposed Metrolink rail extension to the University were outside of their scope of work for the NRRP Plan and FEIR. As with the previous comment, the only way to adequately analyze the University and transit expansion plans and their potential impact on the environment is to delay consideration of the Plan until the General Plan Update and FEIR review and analysis of these elements is completed and their impacts on the NRRP plan are known., [Sic.] Response 1-11: The Revitalization Plan for the Project is a program for redevelopment in the Revitalization Area. It is a fiscal and administrative planning tool intended to focus on neighborhood revitalization and business development programs and projects in the Revitalization Area over the life of the Project. Analysis of environmental impacts related to expansion of the University of Redlands and/or the Metrolink extension are not within the scope of the FEIR for the Revitalization Plan. At such time(s) as individual projects, such as the University of Redlands and/or the Metrolink expansion, may be proposed for decision maker(s)approval, and there is meaningful data in connection therewith to inform decision makers, such projects would be subject to meeting CEQA requirements on their own merits. As stated in Response 1-10 above, the current General Plan is a long-term planning document promulgated in accordance with Government Code Section 65300, et seq., and it is not outdated as a matter of law. NRRP Written Responses to Objections A-25-08 Page 12 Further, the CCRL mandates that a redevelopment plan conform to the City's General Plan, as implemented by City zoning regulations; that is, if it is not permitted by the General Plan, it cannot be permitted by a redevelopment plan. In Redlands, the Plan does not change the General Plan or zoning codes; it is, instead, directed by them. As a result, the oversight and input opportunities currently available to property owners within the proposed Revitalization Area under the General Plan will be the same as it would be after Plan adoption; no more, no less. In addition, the objector's references to the University of Redlands and the proposed Metrolink rail extension relate to projects that may be pursued in the future; however, such projects should they come to pass are both located outside the boundaries of the proposed Revitalization Area. It should be noted that with respect to the proposed extension of the Metrolink light-rail service to the University of Redlands, a small portion of the train tracks needed to reach the University does cross the southeast corner of the NRRP; however, the envisioned light-rail platform is not proposed for any portion of the NRRP. As such, the areas located outside of the proposed Revitalization Area and any projects that may occur in such areas in the future are not germane to and have no bearing or effect upon the Redevelopment Plan for the proposed Revitalization Area. Objection 1-12: (Pg. 17, NRRP) "(Sec. 517) Consistency with General Plan and Zoning Ordinance"- The existing General Plan and associated environmental review and analysis are substantially outdated for the -base year 2008 proposed for the NRRP Plan. See Comment 4 above also. [Sic.] Response 1-12: See Responses 1-10 and 1-11 above. In addition, the CCRL mandates that a redevelopment plan conform to the City's General Plan, as implemented by City zoning regulations; that is, if it is not permitted by the General Plan, it cannot be permitted by a redevelopment plan. In Redlands, the Plan does not change the General Plan or zoning codes; it is, instead, directed by them. As a result, the oversight and input opportunities currently available to property owners within the proposed Revitalization Area under the General Plan will be the same as it would be after Plan adoption; no more, no less. Further, the statement that the existing General Plan and associated environmental review and analysis are "substantially outdated" represents the objector's opinion, is incorrect, and no further response is necessary. Objection 1-13: (Pg. 20, NRRP) "(Sec. 700) Actions by the City"- Based on the outdated nature of the General Plan and associated environmental documentation, the "Actions by the City" listed under a), b)and c)should be pursued concurrently with or prior to the adoption of the proposed NRRP Plan and FEIR. See Comments No. 4 and 6 above also. [Sic.) Response 1-13: See Responses 1-10 and 1-11 above. In addition, the CCRL mandates that a redevelopment plan conform to the City's General Plan, as implemented by City zoning regulations; that is, if it is not permitted by the General Plan, it cannot be NRRP Written Resblonses to Objections v6-25-08 Page 13 permitted by a redevelopment plan. In Redlands, the Plan does not change the General Plan or zoning codes; it is, instead, directed by them. As a result, the oversight and input opportunities currently available to property owners within the proposed Revitalization Area under the General Plan will be the same as it would be after Plan adoption; no more, no less. Further, the statement that the current General Plan and associated environmental documentation are "outdated" is incorrect. Moreover, Section 700 of the proposed Revitalization Plan provides a general list of actions that may be taken by the City, among others, in connection with the Agency's implementation of the Revitalization Plan to "ensure continued fulfillment of the purposes of the Revitalization Plan and to prevent the recurrence or spread in the area of conditions causing blight." (Revitalization Plan, p.20). Objection 1-14: ("Attachment D", NRRP) No economic and financial back-up has been provided to justify the Tax Increment Projections included with the NRRP Plan. Is the lending rate shown consistent with the rate that the RDA may realize for a project/ plan/ district that does not retain the power of eminent domain? [Sic.] Response 1-14: The objector contends that the record does not reflect the basis for the tax increment projections included within Attachment"D"to the proposed Redevelopment Plan for the NRRP. Section 10, PRELIMINARY ASSESSMENT OF PROPOSED METHOD OF FINANCING REVITALIZATION OF THE REVITALIZATION AREA, of the Report to Council includes a detailed description and background with respect to how the NRRP may be financed, including a justification of the tax increment projections. In addition to the text provided in Section 10, particular attention is drawn to Attachments"I", "J" and "K" which illustrate such justification. The objector has asked if the Agency's ability to raise capital and/or the cost of capital to finance the NRRP would be affected by lack of the power of eminent domain within a redevelopment area. Section 600 of the proposed Redevelopment Plan for the NRRP describes the Agency's methods for financing the NRRP. Section 10, PRELIMINARY ASSESSMENT OF PROPOSED METHOD OF FINANCING REVITALIZATION OF THE REVITALIZATION AREA, of the Report to Council further describes methods for financing the revitalization of the Revitalization Area. With respect to the issuance of bonds (or similar instruments), factors that limit the Agency's ability to issue debt are the amount of tax increment revenues available for repayment of such debt and the term during which such tax increment revenues are available to repay such debt. In addition, interest rates applicable to public financing are attributable to marketplace conditions, which are subject to change from time to time. The Agency's eminent domain powers or lack thereof do not affect the underwriting of such debt. Based upon data available from the California Redevelopment Association, approximately half of all redevelopment projects in California lack the power of eminent domain. Among those redevelopment agencies that have the power of eminent domain, many have refrained from exercising that power, but nonetheless have issued tax allocation bonds. The lack of the power of eminent domain by itself has not affected the ability to raise debt capital for redevelopment projects. NRRP Written Responses to Objections,6-25-08 Page 14 As stated in Section 414, Public Improvements,of the Plan,Attachment D(North Redlands Revitalization Project, Projects and Programs List) is a general list of possible projects which are "illustrative, but not exhaustive; the location, cost and description of improvements is subject to flexible application to the greatest extent allowable to achieve the greatest public benefit and to best achieve the objectives of this Plan" (p. 7). No "lending rate" is identified in Attachment D and it is unclear what the objector means by "lending" rate. No further response is possible. Objection 1-15: (Cover, FEIR) Cover indicates May 2008 preparation date while body indicates June 2008 revision. [Sic.] Response 1-15: The document entitled Final Program Environmental Impact Report, is actually not considered final until approved by the Agency Board and the City Council. The noted minor typographical inconsistency has been indentified by Agency staff and Advisors and will be corrected. This objection does not appear to address any specific environmental impacts of the project or the adequacy of the FEIR, and therefore, no further response is necessary. Objection 1-16: (Pg. GD-3, FEIR) Definition of "Program EIR" should refer to a specific type of ElRbeing a "Program EIR", rather than "...means the EIR prepared forthe Project." [Sic.] Response 1-16: Throughout the document, the EIR for the Project is variously referred to as the"Draft EIR"or the "Draft Program EIR," but(with the exception of the definition on p. GD-3) not as the "Program EIR." See Section 1.1 for a discussion of the purpose for a "Program EIR" and why the EIR for the Project is declared to be a "Program EIR." The definition on page GD-3 should properly read " 'Draft Program EIR' means the EIR prepared for the Project." Nevertheless, this comment does not appear to address any specific environmental impacts of the Project or the adequacy of the FEIR. Therefore, no further response is necessary. Objection 1-17: (Pg. E-9, FEIR) "Summary of Impacts, Mitigation Measures and Level of Significance after Mitigation — 2.5 Transportation/ Traffic"- Proposed Final (Program) EIR does not adequately review and analyze existing(baseline)and future traffic volumes anticipated for the term of the project(30 years), including substantial cumulative impacts as previously identified. A current CMP level traffic analysis should be conducted in order to quantify baseline and future (buildout) traffic volumes and their associated impact on the existing City street network within and outside the NRRP and qualify the street sections depicted or adjusted to meet capacity requirements for the (outdated) General Plan Circulation Element. See Comments 4 and 5 above also. [Sic.] NRRP Written Responses to Objections v6-25-08 Page 15 Response 1-17: The Revitalization Plan proposes a general program of redevelopment to be carried out over a 30-year period by the Agency within or for the benefit of that area defined as the Revitalization Area (see Figure 2, FEIR). No site-specific redevelopment projects have been identified by the Agency for Agency participation, because tax increment receipts have not yet accrued to fund such redevelopment projects. It would be speculative under such circumstances to attempt to identify where, when or to what extent an Agency implementation activity might impact traffic volumes on specific street sections in the Revitalization Area(See discussion in the FEIR, Section 2.5). Accordingly,the FEIR recommends Mitigation Measure T-1 as a condition of Project approval, to wit: T-1. Upon submission of an application for a site-specific development project within the Revitalization Area to the City, and pursuant to applicable local, regional, State and federal threshold requirements, applicant shall conduct a traffic analysis to determined the project's actual impact on Revitalization Area affected intersections and/or roadway segments. Scope of the analysis can be as simple as a trip generation study for small developments, or a full- scope analysis for larger developments. The traffic analysis will be used to determine whether the following mitigation measures, among others, are adequate or appropriate to mitigate the impacts of the project, or whether a greater or lesser mitigation requirement is needed: Recommended Mitigation for Cumulative Impacts In addition to mitigation measures required to address direct specific project impacts, depending on the results of the site-specific study and based on the City's traffic impact significance standards, a project may be required to implement one or more of the following measures to mitigate the project's impacts and improve the overall operation of traffic in the Revitalization Area: • Add and/or reconfigure lanes at intersections that operate at an unacceptable levels of service 0 Require new development to provide adequate on-site loading and unloading areas for truck deliveries • Require new development to provide adequate on-site parking • Restrict and/or eliminate on-street parking as appropriate • Consolidate curb cuts and driveway accesses between individual parcels • Add raised medians or other center divider treatments to restrict left turns at driveways and unsignalized intersections to right turns in and out only • Implement signal synchronization along main corridors NRRP Written Responses to Objections v6-25-08 Page 16 • Participate in a fair-share funding mechanism, such as a traffic impact fee program, an improvement benefit district, or other program, as established by the City. Enhance existing street lighting Additional mitigation measures, as appropriate and necessary, may be added at such time as site-specific projects are proposed from time to time for Agency assistance or participation. Also see Responses 1-10 and 1-11 above. The statement that the existing General Plan Circulation Element is outdated represents the objector's opinion and is not correct under the State laws governing the promulgation of the General Plan, and no further response is necessary. Objection 1-18: (Pg. E-11, FEIR) Under"Alternative Revitalization Area Alternative", area exclusions discussed in Comment 2 above contradicts language included in Plan FEIR regarding "conditions of deficiency and disuse". [Sic.] Response 1-18: In the objector's Objections 1-3 through 1-5 above, the objector identifies various "exclusions" of area from the Revitalization Plan, which the objector deems appropriate for inclusion, and states that this contradicts the language in the FEIR regarding conditions of deficiency and disuse. Objections 1-3 through 1-5 above, represent the objector's personal opinion with respect to what should or should not be included in the Revitalization Area, do not speak to the adequacy of the content of the FEIR or the mandates of CEQA. No further response is necessary. Objection 1-19: (Pg. E-11, FEIR) Under "Limited Redevelopment Activities Alternative", the RDA's power of eminent domain has been eliminated from "activities"that are allowed under the NRRP Plan, As such, the document should analyze the alternative that eminent domain powers, as allowed by law, be included in the Plan and the associated economic feasibility of such an alternative. [Sic.] Response 1-19: On March 20, 2007, by its Resolution No. 407, the Agency Board adopted the following policies with respect to the preparation and proposed adoption of the Revitalization Plan, to wit: i) The redevelopment plan for the North Redlands Revitalization Project shall not include the power of eminent domain; ii) The implementation of the North Redlands Revitalization Project shall primarily focus on neighborhood revitalization and business development programs and projects and resources; and NRRP Written Responses to Objections v6-25-08 Page 17 iii) The North Redlands Revitalization Project's planning and implementation phases shall include a significant, meaningful and ongoing community participation program. (Resolution No. 407, Section 3) Based on the foregoing Agency policies, consideration in the FEIR of an alternative including use of eminent domain in the Revitalization Area is not feasible pursuant to the policy direction provided by the Agency Board in its Resolution No. 407. Therefore, an infeasible alternative is not required to be considered in the FEIR in accordance CEQA Guidelines, Section 15126.6(a). Objection 1-20: (Pg. E-13, FEIR) "Summary of Issues to be Resolved by the Lead Agency"- The issues identified under items 1 through 4 have not been appropriately analyzed by the proposed Final(Program)EIR due to the condition and outdated nature of the existing General Plan and associated environmental documentation being utilized as a basis for the process. See Comments No. 4, 5, 6 and 7 above also. [Sic.] Response 1-20: See also Responses 1-10 through 1-13 above. The statement that the existing General Plan and associated environment documentation upon which the FEIR for the Project is tiered are"outdated" is incorrect as a matter of law, represents the objectors opinion, and no further response is necessary. Objection 1-21: (Pg. 10, FEIR) "Description of Program EIR and Relationship to Project"- See Comments No. 4, 5, 6, 7 and 14 regarding inadequacy of proposed Final Program EIR for the environmental review and analysis of the Proposed NRRP Plan. [Sic.] Response 1-21: Also see Responses 1-10 through 1-13 and 1-20 above. This statement represents the objector's personal opinion, does not speak to the content of the environmental document or the mandates of CEQA, and no further response is necessary. Objection 1-22: (Pg. 11, FEIR) "Program EIR Advantages"-See Comments No.4. 5, 6. 7 and 14 regarding inadequacy of proposed Final Program EIR for the environmental review and analysis of the proposed NRRP Plan. [Sic.] Response 1-22: Also see Responses 1-10 through 1-13 and 1-20 above. This statement represents the objector's personal opinion, does not speak to the content of the environmental document or the mandates of CEQA, and no further response is necessary. Objection 1-23: (Pg. 12, FEIR) "Specificity of Analysis"- The proposed Final Program EIR does not"evaluate the Project under the proposed Plan at the greatest level of specificity possible" due to the fact that the basis/ baseline being utilized (current General Plan) is substantially outdated and inaccurate regarding the current conditions, NRRP Written Responses to Ottections v6-25-08 Page 18 anticipated future conditions and appropriate mitigation measures for the City, including the NRRP Plan area. See Comments No. 4,5,6,7 and 14 above also. [Sic.] Response 1-23: Also see Responses 1-10 through 1-13 and 1-20 above. The statement that the existing General Plan and associated environmental analysis are "outdated" is incorrect, represents the objector's opinion, and no further response is necessary. No explanation or specific evidence is provided to support the allegation that the General Plan is inaccurate. The FEIR evaluates the proposed Revitalization Plan at the greatest level of specificity possible, given that the Revitalization Plan: i) is a fiscal and administrative planning tool that proposes a general program of redevelopment activities in the Revitalization Area; ii) identifies no site-specific redevelopment projects or programs for Agency participation, because, among other things, the Project is not yet funded; iii) makes no changes to the General Plan Land Use Element, Growth Management Element, Circulation Element or any other part of the General Plan; iv) makes no changes to the Zoning Ordinance or any other City code or regulation; v), conforms to the General Plan, as required by law, and is consistent with the General Plan's underlying environmental documentation upon which the Project FEIR is tiered. Under these circumstances, greater accuracy with respect to current conditions, anticipated future conditions and appropriate mitigation measures for the City is not realistically achievable without engaging in speculation as to the type of redevelopment implementation projects, their possible locations, level of development/redevelopment, and time at which such implementation may occur. Objection 1-24: (Pg. 12, FEIR) Was the following statement used as a qualifier when a determination was being made to formulate the boundaries of the proposed NRRP? "No site-specific activities or actions that could be reasonably linked to a specific location have been identified by the Agency." Are there no on-going or approved development projects that by creation of the proposed Revitalization plan will become Redevelopment projects benefiting the NRRP? [Sic.] Response 1-24: The Revitalization Plan proposes a general program of redevelopment activities to be carried out over a 30-year period by the Agency within or for the benefit of that area defined as the Revitalization Area (see Figure 2, FEIR). No site-specific redevelopment projects have been identified by the Agency for Agency implementation, because tax increment receipts have not yet accrued to fund such redevelopment projects in or for the benefit of the Revitalization Area. There may be private sector ongoing or approved projects in the Revitalization Area, but these projects are not being implemented by the Agency. All ongoing, approved, and projects approved in the future in the Revitalization Area, be they private projects, public projects or joint private/public projects will benefit the Revitalization Area, specifically, and the surrounding community,generally, over the life of the Plan. NRRP Written Responses to Objections 46-25-08 Page 19 Objection 1-25: (Pg. 13, FEIR) The "Analytical Approach" would only be applicable to the proposed Final Program EIR if the General Plan and associated environmental analysis and documentation were current and not substantially outdated and therefore inadequate as the basis for the Plan and the proposed Final Program EIR. [Sic.] Response 1-25: See also Responses 1-10 and 1-11 above. The statement that the existing General Plan and associated environmental analysis are"substantially outdated" and therefore "inadequate" is incorrect as a matter of law, represents the objectors opinion, and no further response is necessary. Objection 1-26: (Pg. 19, FEIR) Under "Relationship to General Plan Buildout (Beginning of third paragraph): The change in the environment between the existing baseline (the year 2008) and the expiration of the Plan (the year 2038) is examined to determine whether the impact(s) of the proiect would be significant." The review and analysis scenarios Portrayed here are inadequate for the proposed NRRP Plan and Final (Program) EIR, as identified in Comments No. 4,5,6,7 and 14 above, due to the outdated nature of the current General Plan, it's component(Element) plans and the Master EIR for the City of Redlands. [Sic.] Response 1-26: See also Responses 1-10 through 1-13 and 1-20 above. The statement that the existing General Plan, its component plans and associated environmental analysis are "outdated" and inadequate represents the objector's opinion, and no further response is necessary. Objection 1-27: (Pg. 34, FEIR) The Upper Santa Ana River Wash Land Management and Water Conservation Plan("Wash HCP")shows a path along the Church Street alignment that enters the proposed Wash HCP area. A General Plan Amendment or Update and associated environmental documentation will be required in order to reconfigure or relocate said path to an alternative alignment prior to the Wash HCP adoption and approval. [Sic.] Response 1-27: As of this date, there are no approved Habitat Conservation Plans ("HCP")in San Bernardino County(FEIR, Section 2.1, Land Use/Planning, p. 34). The City is a participant in the proposed future adoption of the Wash HCP; however, environmental documentation related to the Wash HCP is not within the scope of the EIR for the Revitalization Plan, because the Revitalization Area is not within the Wash HCP area as currently proposed. Moreover, the Revitalization Plan for the Project proposes no amendment to the General Plan; such General Plan amendment would be subject to environmental review on its own merits and is not within the scope of the FEIR. This comment does not appear to address any environmental impacts of the Project, and therefore, no further response is necessary. NRRP Written Recporises to Objenons v6-25-08 Page 20 Objection 1-28: (Pg. 74, FEIR) The review and analysis of the impacts of Transportation/ Traffic provided with the proposed NRRP and Final Program EIR are inadequate due to the outdated nature of the current General Plan, it's. component (Element) plans and the Master EIR for the Citv of Redlands. See Comments No. 4,5.6,7.14 and 20 above also. [Sic.] Response 1-28: See also Responses 1-10 through 1-13, 1-20 and 1-26 above. That the existing General Plan, its component(Element) plans, and associated environmental analysis are "outdated" represents the objector's opinion, and no further response is necessary. Objection 1-29: (Pg. 74, FEIR) Orange Street/Lugonia Ave. should be identified as State Route 38 under the description of the "Regional System". [Sic.] Response 1-29: State Route 38 extends from the 1-10 via Lugonia Avenue and Orange Street east and north in Redlands to Route 18 near Baldwin Lake via Barton Flats. The route was added to the State and national Freeway and Expressway system in 1959 and renamed State Route 38 in 1964. Although the objector is correct with respect to identification of State Route 38, the description provided under"REGIONAL SYSTEM"on page 74 is intended to describe what are commonly called freeways and only includes existing freeways. Objection 1-30: (Pg. 75, FEIR) Church Street between Interstate 10 and Brockton Ave. has erroneously been placed in both the "Minor Arterials" designation and "Collector Streets" designation. [Sic.] Response 1-30: Church Street is identified as a minor arterial in the General Plan Circulation Element, Section 5.5(k). Objection 1-31: (Pg. 76, FEIR) Under"Rail",the statement that"The railroad track and proposed stations are located south of the 1-10 and are not within the Revitalization Area..." is inaccurate and deceptive in nature. See Comments No. 1.f.3)and 5 above also. [Sic.] Response 1-31: The railroad track is located south of the 1-10 east to Church Street/Park Avenue, where it crosses the 1-10 and continues east. The small portion of the railroad right-of-way along Park Avenue between Church and University Streets is in the extreme southeast corner of the proposed Revitalization Area, i.e., in a triangular piece bounded by Park Avenue, University, and the 1-10. The alternative Metrolink stations proposed to date by SANBAG are not proposed to be within or directly adjacent to any boundary of the Revitalization Area. NRRP Writter,Responses to Objections v6-25-08 Page 21 Objection 1-32: (Pg. 104, FEIR) Under "Transportation/ Traffic" - Second paragraph, "...with respect to Plan adoption, cumulative impacts are considered less that significant, given that mitigation in the form of additional traffic analysis,as appropriate and necessary, is performed." This scenario is inappropriate and inaccurate due to the outdated nature of the current General Plan Circulation Element and the need to reanalyze the NRRP Transportation/Traffic impacts and appropriate mitigation with an updated CMP City-wide traffic analysis before Plan / FEIR aggroval. See Comments No. 4.5.6,7,14.20 and 22 above also. (Sic.] Response 1-32: Also see Responses 1-10 through 1-13, 1-20, 1-26 and 1-28 above. That the existing General Plan, its component (Element) plans, and associated environmental analysis are "outdated" is incorrect as a matter of law. Based on existing land uses as defined by the General Plan, until a site specific project is proposed, there is not "a need to reanalyze the NRRP Transportation/Traffic impacts and appropriate mitigation with an updated CMP City-side traffic analysis before Plan/FEIR approval." The General Plan is a long-term planning document, promulgated according to the requirements of Government Code Section 65300, et sec/. The Revitalization Plan, which is required by law to be consistent with the General Plan, proposes a general program of Agency redevelopment activities, focusing on neighborhood revitalization and economic development, within or for the benefit of the Revitalization Area (see FEIR, Figure 2). Because no site-specific projects have been proposed for implementation by the Agency under the Revitalization Plan, it is not practical or realistically possible to attempt to quantify specific transportation/traffic impacts on roadway segments or intersections within the Revitalization Area beyond those general land use and circulation parameters defined in the General Plan (see Section 1.7, Table 1). The FEIR for the Project recommends Mitigation Measure T-1 as a condition of Revitalization Plan adoption, which comprehensive mitigation measure calls for specific traffic impact analysis when and as specific projects are proposed for approval and determination of appropriate specific mitigation measures as necessary. To attempt to quantify such future specific impacts, short-term or long-term (cumulative), at this juncture would be speculative. City Council Finding: The City Council finds that on the basis of information in the record and the foregoing specific responses, the concerns expressed by Stephen W. Rogers in his Letter of June 17, 2008 have been addressed and the objections submitted, excepting the typographical adjustments noted above, are not accepted. 2. Responses to Written Objections, Communications and Suggestions received from Steve Rogers in his E-Mail message of June 10, 2008 to Josefina Aguilar of the Redevelopment Department NRRP Written Responses to Otjections v6-25-08 Page 22 Objection 2-1: Ms. Aguilar: Thank you for your attention to my concerns regarding the NRRP and your memo memorializing our discussions with the RDA's consultant team. Please let me be clear that staff and UFI have made an effort to clarify the project components with which I disagree, however; there has been an overall disconnect with City administrative personnel regarding these same concerns. Your memo infers that I had requested that my residence be removed from the project boundary area when in fact it was Mr. Hobbs' suggestion that this might be a possible compromise. [Sic.] Response 2-1: On June 2, 2008,Agency staff(i.e., Ms.Josefina Aguilar)and Advisors (including Messrs. Jon Huffman, Managing Principal, Steven H. Dukett, Managing Principal, and Richard Tillberg, Principal all of Urban Futures, Inc.)met with the objector via teleconference. Approximately ninety minutes were allocated to addressing the objector's questions and concerns which focused primarily on the criteria used to define the NRRP Project Area boundaries. UFI staff explained the purpose of the Plan proposed for the NRRP Area. The objector was informed that the Plan is a legal document that outlines a process and a basic framework within which specific redevelopment projects and/or programs will be undertaken by the Redevelopment Agency over the 30-year period of time that the Plan is effective. The content of the Plan and the qualifying eligibility for the NRRP is guided by the legal requirements contained in the CRRL as noted above. That meeting and the responses to the Objections noted herein are intended to illuminate and clarify the matters of concern and objection raised by the objector. With respect to the objector's real property, during the above noted meeting, the objector stated that his essential interest was to have his residence removed from the proposed Revitalization Area. Although this subject may have arisen at other times with other people, the four individuals noted in the first paragraph of Response 2-1 clearly remember the objector stating his request. Objection 2-2: Also, you suggest that I am not in agreement with the project because the district will not include eminent domain power. I was merely pointing out that the lending rates that the underwriters will offer the City RDA will be somewhat diminished because of the perceived lack of an "effective redevelopment plan" (w/o eminent domain powers). [Sic.] Response 2-2: The Agency's ability to raise capital and/or the cost of capital to finance the NRRP would not be affected by lack of the power of eminent domain within a redevelopment area. Section 600 of the proposed Redevelopment Plan for the NRRP describes the Agency's methods for financing the NRRP. Section 10, PRELIMINARY ASSESSMENT OF PROPOSED METHOD OF FINANCING REVITALIZATION OF THE REVITALIZATION AREA, of the Report to Council further describes methods for financing the revitalization of the Revitalization Area. With respect to issuing debt, the only factors that limit the Agency's ability to issue debt is the amount of tax increment revenues available for repayment of such debt and the term during which such tax increment NRRP Written Responses to Objections v6-26,08 Page 23 revenues are available to repay such debt. Further, interest rates applicable to public financing are attributable to marketplace conditions, which are subject to change on a regular basis. The Agency's eminent domain powers or lack thereof do no affect the underwriting of such debt. Based upon data available from the California Redevelopment Association, approximately half of all redevelopment projects in California lack the power of eminent domain. The lack of eminent domain by itself has not affected the ability to raise debt capital for these redevelopment projects. Objection 2-3: You also failed to point out the procedural concerns that 1 expressed due to the NRRP preceding ahead of the anticipated General Plan update an therefore making consideration of the NRRP premature until after preparation and approval of the General Plan update. [Sic.] Response 2-3: See Responses 1-10 and 1-32 above. In addition, the CCRL mandates that a redevelopment plan conform to the City's General Plan, as implemented by City zoning regulations, that is, if it is not permitted by the General Plan, it cannot be permitted by a redevelopment plan. In Redlands, the Plan does not change the General Plan or zoning codes; it is, instead, directed by them. As a result, the oversight and input opportunities currently available to property owners within the proposed Revitalization Area under the General Plan will be the same as it would be after Plan adoption; no more, no less. Objection 2-4: Lastly and most importantly, I am philosophically opposed to a program that will serve to increase government, especially with the current trying and bleak economic outlook, and the program being placed on the backs of middle and lower income citizens and their properties. [Sic.] Response 2-4: The adoption of the NRRP will not in and of itself increase government. The Agency has existed for approximately 40 years. In fact, the Agency adopted its first redevelopment plan on September 26, 1972. The Agency's business is managed by the City's Redevelopment Department. In addition,the Agency's efforts within the Revitalization Area would be primarily financed with tax increment funds. The Agency does not have a tax rate and does not tax anyone. Objection 2-5: As I was indicating to you earlier today, I desire to review the final EIR for this project as well as the final report of the NRRP so that I might craft my comments for the City Council and State Clearinghouse with all information that should be available to me for review prior to the public hearing on this matter. Since you have taken such initiative in preparing the subject memo, I will be looking to you and not the consultant group, as you suggested, to provide me with such an opportunity to review the final documents that will be considered by City Council on June 17. [Sic.] NRRP Written Responses to Ob;edions��-25-78 Page 24 Response 2-5: Agency staff and Advisors have met with and have spoken with the objector on several occasions and have provided the data requested for review. City Council Finding: The City Council finds that on the basis of information in the record and the foregoing specific responses, the concerns expressed by Steve Rogers in his E-Mail message of June 10, 2008 to Josefina Aguilar of the Redevelopment Department have been addressed and the objections submitted are not accepted. 3. RESPONSES TO WRITTEN OBJECTIONS, COMMUNICATIONS AND SUGGESTIONS RECEIVED FROM BISHOP B.B. BROWN IN HIS LETTER SENT VIA FACSIMILE ON MAY 15, 2008 Objection 3-1: These addresses of the properties are in the redevelopment areas for the plan. I am Bishop B.B. Brown, the Presiding Bishop of Holy Trinity C.O.G.I.C., Holiness. [Sic.] Response 3-1: Agency staff and Advisors have confirmed that the property specified in the objector's letter are located within the boundaries of the Revitalization Area. The objector's credentials were not verified and are accepted as stated. Objection 3-2: We are wondering about the Agency that wants to redevelop the Northside at the expense of the people of our Community. These people have been here for along time in seeing the changes take place in Redlands with the absence of the orange groves, and the housing explosion as well as the businesses that have been built on the Northside of Redlands. [Sic.] Response 3-2: The Agency's efforts within the Revitalization Area would be primarily financed with tax increment funds. The Agency does not have a tax rate and does not tax anyone. By way of background, the NRRP is a result of a grass-roots community-based effort to bring a community-oriented voluntary program of reinvestment and rejuvenation to the proposed Revitalization Area. In particular, a coalition of 12 community-based organizations, lead by the NRVC, together with a broad based indication of community support reflected in a 16 page resident's petition, requested that the Agency Board consider establishing a new redevelopment project area in North Redlands. In response to their request, direction to initiate the redevelopment planning work began with the March 20, 2007 adoption of Resolution 407 by the Agency Board. The purpose of NRVC, among other things, was to provide a forum for the community to express their needs and concerns and to create a means for formulating a"Plan of Action". Prior to 2007 and after a lengthy well reasoned effort, the NRVC prepared the North Redlands Vision Plan. The North Redlands Vision Plan formed the framework from which NRRP Written Responses to Objections 4-25-08 Page 25 the North Redlands residents were able to communicate their needs and desires to the City. That Plan has been widely shared throughout the community and has earned significant community support and endorsements. In recognition of their leadership in the community, on October 16, 2007, the City Council adopted Resolution No. 6659, which among other things, officially appointed the NRVC as the community based organization responsible for providing a community participation program through public workshops and information sessions for residents, businesses, property owners, civic and business organizations and other interested parties for the purpose of receiving public input with respect to the NRRP. The NRVC carried out their duties in a very serious, business-like and thorough fashion. Since the initial meeting with the NRVC to review the subject of redevelopment, staff and Advisors have met with the NRVC 16 times. Their meetings were always well attended. In addition, the NRVC hosted two community education workshops;one on May 15, 2008 and the other on May 19, 2008. Collectively, staff has estimated that approximately 120 persons attended these workshops. Throughout the planning process the NRVC was instrumental in sharing information in the community concerning the redevelopment planning effort. In fact, they prepared their own printed material sharing information on and inviting community participation with respect to the NRRP. In summary, the community of North Redlands, through the efforts of the NRVC, has recommended the boundaries of the Revitalization Area as specifically delineated on Attachments A and C. Objection 3-3: So,the struggle of mortgages, poor economy, falling jobs, and now to be challenged by the thought of redevelopment in our Community. It is a time of uncertainty for so many, and if we didn't know God where would we be. Now, the legislators of the City of Redlands want to send out a notice for more uncertainty. [Sic.] Response 3-3: As noted in Response 3-2, the NRRP is a community-based endeavor. All of the notices provided to property owners and residents were transmitted in accordance with the CCRL. In addition, the NRVC was also instrumental in noticing the greater community with respect to the NRRP. Objection 3-4: 1 am a representative of God, and His people that are truely called by His name. It is time that we stop running, and work together in a common bond to forge the many challenges that Redlands is faced with. [Sic.] Response 3-4: As indicated in Response 3-2, the NRRP is a community-based endeavor. In accordance with Agency Resolution No. 407, the NRRPs planning and implementation phases shall include a significant, meaningful and ongoing community participation program. In that respect, the objector is both invited and welcome to attend future meetings in the North Redlands community to discuss and review matters related to NRRP Written Responses to Objections A-25-08 Page 26 the NRRP. Such meetings will be held with the assistance of the NRVC pursuant to City Council Resolution No. 6659. City Council Finding: The City Council finds that on the basis of information in the record and the foregoing specific responses, the concerns expressed by Bishop B.B. Brown in his Letter sent via facsimile on May 15, 2008 have been addressed and the objections submitted, excepting those related to the addresses and credentials noted in Objection 3-1, are not accepted. NRRP Written Responses to Objections 6-25-08